Defendant JOSEPH LIGAMBI, a/k/a "Uncle Joe," a/k/a "Unc," was a "made" member ofthe Enterprise who rose through its ranks to become its "underboss," then, after the incarcerationofhispredecessorJosephMerlino,the"actingboss"oftheEnterprise. Throughout the period ofthis indictment, defendant LIGAMBI directed the affairs ofthe Enterprise.
9. Joseph Massimino, a/k/a "Mousie," was a "made" member who served at times as the "underboss" of the Enterprise. In particular, Massimino was responsible for operating illegal gambling businesses, making extortionate extensions ofcredit and usurious loans, collecting extensions of credit using extortionate means and collecting other extortion payments on behalf oftheEnterprise. InMarch2004,Massiminowasconvictedofstatecriminalchargesand subsequently incarcerated. Massimino continued to participate in the Enterprise's affairs even while incarcerated, both personally and through others, including defendant LIGAMBI, Staino, Lucibello, and Verrecchia.
10. Defendant GEORGE BORGESI, the nephew of defendant LIGAMBI, was a "made" member who served in various roles including, the "consigliere" of the Enterprise. Although he was incarcerated throughout much ofthe period ofthe superseding indictment, defendant BORGES! continued to conduct and participate in the affairs ofthe Enterprise from
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his places o f incarceration through others such as defendant LIGAMBI, Louis Monacello, Associate #I, and others, who engaged in and facilitated loansharking and gambling activities under the control of defendant BORGESI.
11. Martin Angelina, a/k/a "Marty," was a high-ranking "made" member of the Enterprise. Among other responsibilities, Angelina participated in operating an illegal gambling business and in attempting to collect extensions o f credit using extortionate means.
12. Anthony Staino, Jr., a/k/a "Ant," was a "made member who rose to the rank of "caporegime" ofthe Enterprise and regularly assisted defendant LIGAMBI in controlling the Enterprise's affairs, including its gambling, extortion, and loansharking operations.
13. Joseph Licata, a/k/a "Scoops," was a "made" member who rose to the rank of "caporegime" ofthe North Jersey crew ofthe Philadelphia LCN Family and supervised Louis Fazzini, a/k/a "Big Lou," a "made" member of this crew, in the operation of an illegal sports gambling business, and other activities.
14. At times relevant to this indictment, other "made" members included Damion Canalichio, a/k/a "Dame," Gaeton Lucibello, "a/k/a The Big Guy," a/k/a "Gate," and Eric Esposito, as well as others known and unknown to the grand jury. Canalichio served the Enterprise in a variety of capacities, including assisting in the operations of the Enterprise's illegal sports bookmaking businesses and loansharking activities. Lucibello was a close associate ofMassimino and assisted Massimino in operating the Enterprise's affairs from prison, including facilitating the collection of unlawful debts and proceeds of extortion on behalf of Massimino. In addition, Lucibello assisted in controlling the Enterprise's illegal gambling rackets and personally participated in two illegal gambling businesses. ESPOSITO assisted Canalichio and Angelina in operating an illegal gambling business.
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15. During the period of this indictment, associates of the Enterprise included
Louis Barretta, a/k/a "Sheep," Gary Battaglini, Robert Verrecchia, a/k/a "Boots," a/k/a "Bootsie," and Robert Ranieri, a/k/a "Bobby," as well as Louis Monacello and others known and unknown to the grand jury. Louis Monacello was a close associate of defendant BORGES! and assisted him in operating the Enterprise's affairs from prison, including some of its loansharking and illegal gambling operations. Barretta operated aspects of an illegal sports bookmaking operation andloansharkingactivitiesonbehalfoftheEnterprise. BattagliniassistedBarrettaand Canalichio with their duties. Verrecchia assisted Massimino in operating illegal gambling businesses. Ranieri assisted Staino with loansharking and extortionate activities.
THE RACKETEERING CONSPIRACY
16. From in or about 1999, to in or about April 2012 ("the period of this superseding
indictment"), in the Eastern District of Pennsylvania and elsewhere, defendants
JOSEPH LIGAMBI, a/k/a "Uncle Joe," a/k/a "Unc," and GEORGE BORGESI, a/k/a "Georgie,"
and Joseph Massimino,a/k/a "Mousie," Martin Angelina, a/k/a "Marty,"Anthony Staino, Jr., a/k/a "Ant," Gaeton Lucibello, a/k/a "The Big Guy," a/k/a "Gate," Damion Canalichio,
a/k/a "Dame," Louis Barretta, a/k/a "Sheep," Gary Battaglini, Joseph Licata, a/k/a "Scoops," Louis Fazzini, a/k/a "Big Lou," Louis Monacello, Peter Caprio, and other persons known and unknown to the grand jury, being persons employed by and associated with the Philadelphia LCN Family, as described more fully in paragraphs 1-15 above, an enterprise which was engaged in, and the activities of which affected, interstate and foreign commerce, knowingly
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combined, conspired, confederated, and agreed together and with other
and unknown to the grandjury, to violate Title 18, United States Code,
to conduct and participate, directly and indirectly, in the conduct ofthe
Philadelphia LCN Family, through a pattern of racketeering activity, as
United States Code, Sections 1961(1) and 1961(5), as set forth in paragraphs 17-18 below, and through the collection of unlawful debts as defined in Title 18, United States Code, Section 1961(6), as set forth in paragraph 19 below.
PATTERN OF RACKETEERING ACTIVITY
17. The pattern ofracketeering activity, as defined in Title 18, United States Code,
Sections 1961(1) and 1961(5), through which the defendants and their co-conspirators agreed to conduct and participate in the conduct ofthe affairs ofthe Enterprise, consisted of:
A. multiple acts indictable under federal law:
1. Title 18, United States Code, Section 892, Making Extortionate
Extensions of Credit and Conspiring to do so;
2. Title 18, United States Code, Section 893, Financing Extortionate
Extensions of Credit;
3. Title 18, United States Code, Section 894, Collections of
Extortionate Extensions of Credit By Extortionate Means and
Conspiring to do so;
4. Title 18, United States Code, Section 1512, Tampering with a
Witness, Victim, or Informant;
5. Title 18, United States Code, Section 1951, Interference with
Commerce by Threats and Violence - Extortion;
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co-conspirators known Section 1962(c), that is, affairs ofthe
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6. Title 18, United States Code, Section 1955, Conducting, Financing, Managing, Supervising, and Directing Illegal Gambling Businesses;
7. Title 18, United States Code, Section 1084, Transmission of Bets and Gambling Information;
8. Title 18, United States Code, Section 1952, Interstate Travel and Transportation in Aid of Racketeering;
9. Title 18, United States Code, Section 1956, Laundering of Monetary Instruments and Conspiracy;
B. multiple acts involving:
1. Extortion, chargeable under Title 18, Pennsylvania Consolidated
Statutes Annotated, Sections 3923, 901, 903 and New Jersey
Statutes Annotated, 2C:20-5; 2C:5-l; 2C:5-2; 2C:2-6; and
2. Gambling, chargeable under Title 18, Pennsylvania Consolidated
Statutes Annotated, Sections 5513, 5514, 901, 903 and New Jersey
Statutes Annotated, 2C:37-2.
18. It was part ofthe conspiracy that each defendant agreed that a conspirator would
commit at least two acts of racketeering activity in the conduct of the affairs of the Enterprise. COLLECTION OF UNLAWFUL DEBT
19. The collection of unlawful debt through which the defendants and their co- conspirators agreed to conduct and participate, directly and indirectly, in the conduct of the affairs of the Enterprise consisted of the collection from various individuals of unlawful debts, as that term is defined by Title 18, United States Code, Section 1961(6), that is: (a) a debt which
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was incurred and contracted in gambling activity and which was incurred in connection with the business ofgambling, which activity and business were in violation ofthe laws ofthe United States and the Commonwealth of Pennsylvania; and (b) debts which were unenforceable under state and federal law in whole and in part as to principal and interest because of the laws relating to usury and which were incurred in connection with the business of lending money at a rate usurious under state and federal law, where the usurious rate was at least twice the lawfully enforceable rate.
MANNER AND MEANS OF THE CONSPIRACY
20. To further their goal of generating money for the Enterprise, the defendants, their co-conspirators, and associates, operated numerous illegal gambling businesses, made extortionate extensions of credit, used extortionate means to collect debts, loaned money at
usurious rates, extorted property and things of value from business owners, and stole money from an employee health benefit plan. To cultivate, exploit, and extend the Enterprise's affairs and its reputation for violence, and thereby to achieve its purposes, the defendants and their co- conspirators used, and conspired to use, acts ofviolence, including assaults and attempted assaults. The defendants and their co-conspirators operated the conspiracy using the following manner and means, among others.
Defendant LIGAMBI's Leadership Of The Enterprise
21. After the incarceration ofJoseph Merlino, the prior boss ofthe Philadelphia LCN Family, defendant LIGAMBI began to serve as the acting boss of the Enterprise and ran its affairs. In so doing, defendant LIGAMBI supervised and directed members and associates ofthe Philadelphia LCN Family, including all of the defendants named here, in the commission of various criminal acts as set forth in paragraphs 18-20 above, for the economic benefit ofthe
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members of the Enterprise, to perpetuate the Enterprise's existence, and to conceal it from law enforcement detection.
22. As the Enterprise's boss, defendant LIGAMBI would mediate disputes among members and associates ofthe Philadelphia LCN Family, and act as the final authority in settling such disputes and in collecting and allocating the distribution ofthe Enterprise's criminal proceeds.
Illegal Gambling Businesses
23. Defendant LIGAMBI along with defendant BORGES!, Staino, Massimino, Angelina, Lucibello, Canalichio, Barretta, Battaglini, Esposito, Licata, Fazzini, and their associates Verrecchia and others, operated numerous illegal gambling businesses in the Eastern District ofPennsylvania and elsewhere for the benefit ofthe Enterprise. Those businesses include those described in Counts 43 through 49 ofthis superseding indictment, which are incorporated by reference and summarized below:
A. The JMA Video Poker Business: Defendant LIGAMBI, Massimino, and Staino, and other conspirators participated in running an illegal electronic gambling device business that involved five or more persons and operated continuously in the Philadelphia, Pennsylvania region in violation of the laws of the Commonwealth of Pennsylvania.
1. In operating this business, defendant LIGAMBI, Massimino, and Staino caused electronic gambling devices, including video poker machines and other
gambling devices, to be placed in bars, restaurants, convenience stores, coffee shops and other locations in Philadelphia, Pennsylvania and its suburbs to be used for illegal gambling in violation of the laws of the Commonwealth of Pennsylvania.
2. Defendant LIGAMBI, Massimino, and Staino, operated and
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managed their illegal video poker and gambling machine business by using facilities in interstate commerce, including the telephone, to promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of their illegal gambling enterprise. Thereafter, defendant LIGAMBI, Massimino, and Staino performed additional acts to do the same in operating their illegal gambling enterprise. The [co-conspirators] also used coded phrases when discussing the Enterprise's illegal affairs over the telephone.
3. Staino regularly drove from his residence in New
Jersey to Philadelphia, Pennsylvania to collect gambling proceeds from the bars, restaurants, convenience stores, coffee shops and other locations where the illegal video poker and gambling machines were located.
4. Defendant LIGAMBI, Massimino, and Staino, used the Philadelphia LCN Family's reputation for violence to advance and sustain their illegal gambling business. For example, after federal law enforcement agents seized 34 of their illegal electronic gambling devices in April 2001, defendant LIGAMBI, Massimino, and Staino sought to obtain replacement machines and "stops" from another source. In or about May 2001, the [co- conspirators] extorted the owners of another illegal electronic gambling device business, that specialized in video poker machines, by forcing them to sell their illegal business, including 34 video poker machines which were located at over 20 "stops" in the Philadelphia region. To conceal this extortion, Massimino attempted to force the owners to sign a fictitious agreement of sale, and paid the owners a portion of the true value of the business, to create the false appearance that the extortion was a legitimate business transaction, when, it was not. To conceal the illicit nature oftheir business, the [co-conspirators] paid the owners over time in installments,
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partially by checks written by Staino, and issued receipts that they required one ofthe owners to sign.
5. In or about July 2002, defendant LIGAMBI, Massimino, and Staino created JMA Industries to attempt to conceal the illegal nature of their operations and the criminal proceeds of the illegal gambling business from law enforcement. The acronym "JMA" was comprised ofthe first initials ofthe defendant's first names or nicknames: "Joe" (defendant LIGAMBI), "Mousie" (Massimino) and "Anthony" (Staino). JMA Industries purported to be a company which leased electronic gambling devices to other businesses. In fact, the [co- conspirators] used JMA Industries to obscure the criminal nature of their illegal electronic gambling device business by making their operation appear legitimate. [ ] JMA Industries issued payments to Staino and to defendant LIGAMBI's wife, the origin of which were the criminal proceeds the [co-conspirators] and their associates collected in connection with their illegal electronic gambling device business.
B. "Lou's Crab Bar": Massimino, his associate,
Verrecchia, and their co-conspirators owned, operated, and facilitated the operation ofan illegal gambling business involving illegal gambling devices, including video poker machines, and illegal sports bookmaking, that is, illegally accepting wagers on horse racing in violation of Pennsylvania law. This business was operated at a Philadelphia establishment then known as Lou's Crab Bar, located at 1100-02 West Moyamensing Avenue, Philadelphia, Pennsylvania, which was also a regular meeting place for members ofthe Enterprise. Massimino used third party nominees to conceal his ownership and control ofthe illegal gambling business operating at Lou's Crab Bar.
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his co-conspirators owned, supervised, operated and managed two illegal gambling businesses, namely, illegal electronic gambling device businesses involving the illegal use ofvideo poker machines. These businesses were conducted at two Philadelphia sportsbars, Cholly Bears and DiNicks. Cholly Bears was located at located at 2535 South 13th Street, Philadelphia, Pennsylvania. DiNicks was located at 1528 Snyder Avenue, Philadelphia, Pennsylvania.
1. In addition to operating illegal gambling enterprises,
Lucibello advanced the Enterprise by protecting its territory with respect to its illegal gambling device businesses. In particular, Lucibello was responsible for mediating disputes among rival associates ofthe Philadelphia LCN Family. For example, on one occasion, when an Enterprise associate tried to block the opening of an illegal electronic gambling device business by another associate, Lucibello attempted to resolve the dispute by trading on his status as a made member of Philadelphia LCN Family. Lucibello ordered one associate to tell the other associate to "come see me. He should button up after he hears that."
D. "First Ward Republican Club": Angelina, Canalichio, Esposito, their criminal partner known to the grand jury as Associate #2, and other co-conspirators, conducted, financed, managed, supervised, directed, and owned all or part of illegal gambling businesses, namely illegal electronic gambling device business involving the illegal use ofvideo poker machines. These businesses were conducted at the First Ward Republican Club, a private club where Enterprise members met regularly, which was located at 2300 S. Woodstock Street, Philadelphia, Pennsylvania.
E. Sports Bookmaking: Canalichio, Staino, Barretta, Battaglini, Fazzini, and other co-conspirators directed and otherwise managed the day-to-day operation of illegal sports bookmaking businesses on behalf of defendant LIGAMBI, defendant BORGES!, Licata, and
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other members of the Enterprise, known and unknown to the grand jury. As part of the illegal sports bookmaking activity, the [co-conspirators] extended credit and collected gambling and usurious debts. Defendant LIGAMBI, Staino, Barretta, and Battaglini regularly collected debts, and caused the collection of debts, owed for sports bets to the Enterprise's illegal gambling businesses. After making these collections, Staino would meet with defendant LIGAMBI at LIGAMBI's residence to deliver proceeds. While incarcerated, defendant BORGESI received proceeds from the sports bookmaking operation that was operated and managed by Louis Monacello on BORGESl's behalf. As alleged in more detail below, the [co-conspirators] relied upon the Philadelphia LCN Family's reputation for violence to enforce their illegal debts and in making these collections.
Loansharking Activities
24. Defendant LIGAMBI, Staino, Massimino, defendant BORGES!, Canalichio, Angelina, Barretta, and Battaglini, and their co-conspirators, approved, supervised, and otherwise participated in extortionate extensions ofcredit, collections ofdebts using extortionate means, and other illegal demands, to generate income for the Enterprise and its members.
25. LIGAMBI, Staino, Massimino, BORGESI, Canalichio, Barretta and Battaglini, and their co-conspirators also extended loans charging usurious rates of interest as part of the illegal terms ofthe loan, and used extortionate means to collect payments related to these loans.
26. In connection with making and collecting extensions of credit and usurious loans, LIGAMBI, Staino, Massimino, BORGES!, Canalichio, Barretta, and Battaglini cultivated and exploited the violent reputation ofthe Enterprise to discourage resistance to their extortionate demands and to threaten borrowers that if they did not promptly repay the loans, with interest, they would suffer physical and economic harm. The [co-conspirators] also used express and
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implied threats ofphysical violence and economic harm to instill fear in their victims and to preserve and sustain the Enterprise as exemplified below:
A. In or about April 2002, Canalichio and Barretta threatened Victim A in connection with making an extortionate collection of a usurious loan debt when they told Victim A that they were attempting to collect "Uncle Joe's money" (referring to defendant LIGAMBI, the Enterprise boss), from Victim A. In a subsequent conversation, Barretta told Victim A that Canalichio was "capable of cracking" Victim A if necessary to collect that debt. On other occasions, in or about April and May 2002, Battaglini and Canalichio described to Victim A how they had repeatedly assaulted another debtor, including an instance where Canalichio caught the debtor by surprise and beat him with a bat.
B. Barretta and Battaglini repeatedly threatened Victim Bin connection with loansharking activities, using extortionate means, to collect and attempt to collect extensions of credit which arose from unpaid gambling debts. For example, in or about January 2002, Battaglini threatened Victim B by stating that if Victim B did not make his payment, Victim B would "see a side of me you ain't gonna fucking enjoy .... Cause right now I wanna fuckin' put a bullet in your head." On another occasion, in or about March 2002, Barretta explained to Victim B that it was important for Barretta to deal with gambling debtors who could pay him regularly because Barretta had to answer to the leadership ofthe Enterprise, stating: "[t]hey want their money Fridays, you know what I'm trying to say." Barretta also explained that the Enterprise was facing financial hardship because the defendants and their co-conspirators were financing the legal defenses for incarcerated Enterprise members as well as supporting their families.
C. Staino threatened Victim C in connection with extortionate collections of usurious loans. For example, on one occasion, when Victim C was having difficulty making
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payments, Staino threatened Victim C by stating that Staino ought to put a bullet in Victim C's head. On another occasion, in June 2003, Victim C told Staino that Victim Chad lent money -- which Staino had lent to Victim C -- to another debtor, who was having difficulty repaying it. Staino then responded to Victim C: "you know this motherfucker, I'm going to kill him. Ok?
I'm telling you right now I'm gonna kill him. Ok? And I don't talk like that." Staino directed Victim C that he needed to "talk to this kid," explaining: "You tell this motherfucker, but not on the phone ... He made his money. Everybody's making money and I can't get mine ... Now you can't get out ofthe situation ... You got all this fuckin' money out with this guy that nobody even fuckin' knows, and I'm gonna have to go fuckin' ... hurt this guy for something, for fuckin' something that I didn't even do ... I got fucking two gorillas ... fucking chop him up ... call him again, tell him I sat here with ya, tell him I'm agitated. That's all you got to say, he's very agitated, and ... you talked to him, and say 'okay, fine, next week is fine,' but ... without saying too much over the phone, but, ah, it ain't no little problem now. It's a big problem, because ... maybe he didn't know or whatever but now he knows so it's a different ball game ... I'll deal with him." During a different part ofthis conversation, in referring to the delinquent debtor, Staino told Victim C: "[h]e's using my fucking money ... There's 48 fuckin' thousand out there, plus nothin's comin' in. He's fuckin' flipping, you understand," referring to defendant
LIGAMBI. Later, during this conversation, Staino told Victim C: "Explain to this guy that this ain't a joke so ... it's getting to a dangerous point." On a different occasion in July 2003, when Victim C was late with a payment, Staino told Victim C that if Victim C's failure to pay Staino was raised with Enterprise Boss defendant LIGAMBI "there would be some major, major problems."
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attempted to collect those debts using extortionate means. On one occasion in 2005, while Massimino was incarcerated, Massimino sent a message to Victim D to repay Victim D's debt immediately. Massimino threatened that Victim D wouldn't "be able to hide anywhere in the U.S." from Massimino.
E. In August 2004, Staino, and his associate, Ranieri, attempted to threaten an individual known to the grand jury as "Dino," in connection with their making an extortionate extensionofcreditandcollectingitusingextortionatemeans. Atthetime,andunbeknownstto [Staino and Rainieri], "Dino" was a law enforcement officer acting in an undercover capacity. Staino and Ranieri warned "Dino" not to "fuck with" Staino in connection with repaying the debt. Stainoreiteratedtheimportanceof"Dino's"makingpromptpaymentsbythreatening: "Pleaseon my life. I like you. I don't want to fucking have to hurt you." It was further part of the conspiracy that Staino and Ranieri attempted to conceal their illegal activities and to prevent the detection by law enforcement of the conspiracy by directing "Dino" to produce a fraudulent IRS Form 1099 ("1099 Form") in connection with part of his repayment, so that Staino could disguise the repayment ofthe extortionate loan by creating the false appearance that the payment was legitimate income.
Loansharking and Associate #1
27. From approximately Spring 2005 until 2008, defendant BORGES! and Louis Monacello provided money to an individual known to the grand jury and identified here as Associate #1 for Associate #1 to make extortionate extensions ofcredit to others. Associate #1 provided a portion ofthe illegal proceeds collected from these extortionate extensions ofcredit to Monacello. Associate #1 also assisted Monacello in making extortionate demands from others, including Victims E and F.
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28. LIGAMBI, Staino, BORGES!, and Angelina, along with Louis Monacello, extended usurious loans and extortionate extensions of credit to and/or engaged in debt collections using extortionate means from Associate #1 by using the Enterprise's reputation for violence.
Extortion Activities
29. LIGAMBI, Staino, Massimino, Lucibello, BORGES!, and their co-conspirators, approved, supervised, and otherwise participated in extortion activities to generate income for the Enterprise and its members. For example, from 2000 to 2007, defendant LIGAMBI selected various bookmakers who were conducting criminal activity in Philadelphia and southern New Jersey, and ordered Louis Monacello to extort these bookmakers by demanding and collecting from them yearly "street tax," "tribute payments," or "Christmas payments" to avoid personal harm and the disruption o f their illegal bookmaking businesses.
30. From approximately 2002 to 2006, Massimino, with the assistance of Lucibello, extorted Bookmaker A by demanding that Bookmaker A provide yearly tribute payments to the Philadelphia LCN Family, through Massimino and Lucibello, to avoid personal harm and the disruption of Bookmaker A's illegal bookmaking business.
31. Defendant LIGAMBI, Massimino, and Staino extorted and caused the
extortion of business owners in the Philadelphia area, by obtaining property of the victims through express and implied threats and intimidation. For example, in May 2001, defendant LIGAMBI, Massimino, and Staino extorted the owners of an illegal electronic gambling device business, specializing in video poker machines, and forced them to sell that business as described in paragraph 23.A.4. To conceal the criminal nature oftheir demands, the [co-conspirators]
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created false and fictitious sales agreements which they attempted to force the victims to sign to make it appear as if their extortion was a legitimate business transaction, when it was not.
Obstruction & Concealment Activities
32. The defendants and their co-conspirators attempted to conceal their criminal
activities, including, but not limited to, those actions specifically described above. For example, the defendants and their co-conspirators regularly communicated in coded language over the telephone, participated in "walk and talks," that is, covert conversations while walking to and standing at locations where the defendants believed they could not be intercepted. The defendants also communicated with potential and prospective witnesses in an attempt to corruptly persuade them to withhold testimony, records, documents, and other objects from an official proceeding. The defendants also created and caused the creation of false and fictitious documents designed to hide the illegal nature oftheir activities, and established companies that had the appearance oflegitimacy, but in fact, were created to launder money and to conceal the illegal nature of their operations.
All in violation of Title 18, United States Code, Sections 1962(d).
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COUNT TWO
Conspiracy To Conduct an Illegal Gambling Business - The JMA Video Poker Business
1. From in or about 2000 to in or about December 2010, in the Eastern District of Pennsylvania and elsewhere, defendant
JOSEPH LIGAMBI, a/k/a "Uncle Joe," a/k/a "Unc,"
and Joseph Massimino, and Anthony Staino, Jr., knowingly conspired and agreed together and with other co-conspirators known and unknown to the grand jury, to violate Title 18, United States Code, Section 1955, by conducting, financing, managing, supervising, directing, and owning all or part of an illegal gambling business, that is: an illegal electronic gambling device business involved in the operation of electronic gambling devices, which constituted a violation of the laws of the Commonwealth of Pennsylvania (Title 18, Pennsylvania Consolidated Statutes Annotated, Section 5513), and which involved five or more persons who conducted, financed, managed, supervised, directed, and owned all or part of such business and which had been in substantially continuous operation for a period in excess ofthirty days and had a gross revenue of $2,000 in any single day in violation of Title 18, United States Code, Section 1955.
MANNER AND MEANS OF THE CONSPIRACY
The manner and means o f the conspiracy included the following:
2. Defendant LIGAMBI, Massimino, and Staino, operated, and directed
the operation of, an illegal electronic device gambling business in the Philadelphia, Pennsylvania region.
3. Defendant LIGAMBI, Massimino, and Staino caused numerous
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electronic gambling devices, including video poker machines and other gambling machines, to be placed in bars, restaurants, convenience stores, coffee shops and other locations in Philadelphia, Pennsylvania and its suburbs to be used for illegal gambling in violation ofthe laws o f the Commonwealth o f Pennsylvania.
4. Defendant LIGAMBI, Massimino, and Staino operated and managed
their illegal electronic gambling device business by using facilities in interstate commerce, including the telephone, to promote, manage, establish, carry on, and facilitate the promotion, management,establishmentandcarryingonoftheirillegalgamblingbusiness. Thereafter, defendant LIGAMBI, Massimino, and Staino performed additional acts to do the same in operating their illegal gambling business. The co-conspirators would use coded conversations when discussing their illegal affairs using the telephone.
5. Staino regularly drove from his residence in New Jersey to
Philadelphia, Pennsylvania to collect criminal proceeds from the network o f bars, restaurants, convenience stores, coffee shops and other locations that housed the defendants' illegal electronic gambling devices.
6. After federal law enforcement officers seized 34 of their illegal electronic gambling devices in April 2001, the co-conspirators devised a plan to attempt to conceal the illegal nature o f their operations from law enforcement detection.
7. In or about July 2002, defendant LIGAMBI, Massimino, and Staino,
created JMA Industries. The acronym "JMA" was comprised ofthe first initials oftheir first names or nicknames: "Joe" (defendant LIGAMBI) "Mousie" (Massimino) and "Anthony" (Staino). JMA Industries purported to be a company which leased electronic gambling devices to other businesses. In fact, the co-conspirators attempted to use JMA Industries to obscure the
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criminal nature oftheir illegal electronic gambling device business by making their operation appear legitimate[.] For example, JMA Industries issued W-2 forms to Staino and the wife of defendant LIGAMBI. In addition, JMA Industries issued payments to Staino and to defendant LIGAMBI's wife, the origin of which were the criminal proceeds the defendants collected in connection with their illegal electronic gambling device business.
OVERT ACTS
8. In furtherance ofthe conspiracy, and to achieve its objects, the
[co-conspirators] committed, and caused to be committed, in the Eastern District ofPennsylvania and elsewhere, the following overt acts, among others:
A. On numerous dates throughout the period of this superseding indictment, defendant LIGAMBI, Massimino, and Staino, and their co-conspirators placed and caused the placement of, illegal electronic gambling devices, including video poker and other gambling machines, in numerous bars, restaurants, convenience stores, coffee shops and other locations in the Philadelphia region.
B. On numerous dates throughout the period ofthis superseding indictment, defendant LIGAMBI, Massimino, and Staino, and their co-conspirators maintained and cause the maintenance of, the illegal electronic gambling devices described above.
C. On numerous dates throughout the period ofthis superseding indictment, defendant LIGAMBI, Massimino, and Staino, and their co-conspirators collected and caused the collection of, criminal proceeds generated as a result ofthe operation oftheir illegal gambling business.
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D. On or about February 3, 2001, at 10:33 a.m., Staino engaged in a conversation related to operating the illegal gambling business and discussed the need to fix one of the business's broken electronic gambling devices.
E. On or about February 6, 2001, at 11:10 a.m., Staino engaged in a conversation related to operating the illegal gambling business and discussed the need to replace a broken bill acceptor on an illegal electronic gambling device at one location with the bill acceptor from another location.
F. On or about February 13, 2001, Staino engaged in several conversations related to operating the illegal gambling business.
G. On or about February 22, 2001, Staino engaged in several conversations related to operating the illegal gambling business and directed a criminal partner, known to the grand jury and identified here as Associate #2, to repair a broken bill acceptor on an illegal electronic gambling device.
H. On or about February 27, 2001, Staino engaged in several conversations with a criminal associate, known to the grand jury and identified here as Associate #2, related to operating the illegal gambling business, including discussing directions that Massimino provided to the criminal partner to carry out the illegal gambling business' affairs.
L On or about March 7, 2001, at 5:23 p.m., Staino received a call from a criminal associate, known to the grand jury and identified here as PD who, while speaking in coded language, indicated that law enforcement officers had confiscated the illegal electronic gambling device located in his coffee shop. The criminal associate attempted to disguise the true nature ofthe illegal gambling device by describing the confiscated illegal electronic gambling device as a "coffee machine."
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J. On or about March 12, 2001, after Staino had caused the replacement of the illegal electronic gambling device which law enforcement officers seized from PD as described above, Staino engaged in a conversation with PD who had called to infonn him, in coded language, that the bill acceptor on the replacement electronic gambling device was not working. PD noted that "ah, expresso machine, no work too good" to which Staino replied, "What, is it broke?" to which PD responded "No, every time I put the coffee on, it send it right back to me." On or about March 13, 2001, Staino directed his criminal partner, known to the federal grand jury and identified here as Associate #2, to repair the replacement illegal electronic gambling device deceptively referenced by PD as an "espresso machine."
K. On or about April 5, 2001, Staino engaged in several conversations with criminal associates known to the grand jury and identified here as PD and Associate #2, related to operating the illegal gambling business, including coded conversations in which Staino directed Associate #2 to repair PD's "coffee machine," an electronic gambling device. When Associate #2 expressed confusion as to what Staino meant by "coffee machine," Staino clarified by stating: "Well, you know the thing, he says coffee machine."
L. On or about April 5, 2001, at 7:13 p.m., defendant LIGAMBI, and Staino engaged in a conversation where they discussed the payment arrangements they had with their criminal partner, known to the grand jury and identified here as Associate #2, in that Associate #2 worked for the illegal gambling business without charge.
M. On or about April 5, 2001, immediately following the conversation described in overt act L, Staino engaged in a conversation with defendant Massimino about the whereabouts of their criminal partner, known to the grand jury and identified here as Associate #2. DefendantLIGAMBIthenjoinedtheconversationandcomplainedtoMassiminothattheir
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illegal gambling business stood to lose money because Associate #2 was not attending to one of the co-conspirators' illegal electronic gambling devices fast enough at one ofthe illegal gambling business' "better" places. Specifically, defendant LIGAMBI noted, in the coded conversation, "Anthony (meaning Staino) will tell you but, that's one, fucking one ofthe best things, because last month, we, we blew it because, you know what I'm talking about." Massimino replied, "Yeah, all right, let Anthony come around and tell me," and then defendant LIGAMBI, directed Staino to do just that.
N. On or about April 9, 2001, at 5:14 p.m., after law enforcement agents from the Federal Bureau of Investigation executed a court-authorized search warrant at the premises of PD and seized an electronic gambling device, Staino received a telephone call from a criminal associate known to the federal grand jury and identified here as PD, who informed Staino, in a coded conversation: "Ant, listen to me buddy, listen to me please. They took my coffee machine. They took them." Staino then inquired: "They took them, they took them again?" PD responded: "The FBI this time." Staino responded using coded language, stating: "Okay, all right, I'll talk to you. Oh yeah, they took the coffee, okay."
0. On or about May 2001, after the FBI seized approximately 34 of their illegal electronic gambling devices from numerous different locations, defendant LIGAMBI, Massimino, and Staino approached the operators of another illegal electronic gambling device business and forced those operators to relinquish their illegal business for a fee that undervalued their business. Defendant LIGAMBI, Massimino and Staino then incorporated the assets of that business into their existing illegal electronic gambling device business.
P. In or about July 2002, defendant LIGAMBI, Massimino, and Staino, created a company, called JMA, Industries which was named after the three defendants.
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Q. On or about September 2, 2003, Massimino engaged in a discussion to promote the defendants' illegal electronic gambling device business.
R. On or about December 12, 2003, Massimino engaged in a conversation with a criminal associate, known to the grand jury and identified here as Associate #2, regarding the [] illegal electronic gambling device business.
S. On or about June 17, 2004, Massimino and his criminal partner, known to the grand jury and identified here as Associate #2, discussed matters related to the illegal gambling device businesses, including the need to attend to an illegal gambling device.
T. At various times, throughout the period of this superseding indictment, including Fall 2005 through the date o f this superseding indictment, Associate #2 would service, repair and otherwise maintain the illegal electronic gambling devices by traveling to locations throughout Philadelphia, Pennsylvania and its suburbs. For example, on or about May 18, 2010, Staino contacted Associate #2 about a broken electronic gambling device to seek his assistance.
All in violation ofTitle 18, United States Code, Section 371.
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COUNT THREE
Illegal Electronic Gambling Device Business - The JMA Video Poker Business
THE GRAND JURY FURTHER CHARGES THAT:
1. From in or about 2000 to in or about December 2010, in the Eastern District of Pennsylvania and elsewhere, defendants
JOSEPH LIGAMBI, a/k/a "Uncle Joe,"
11
a/k/a Unc,"
and Joseph Massimino, Anthony Staino, Jr., and others known and unknown to the grand jury, knowingly conducted, financed, managed, supervised, directed and owned all or part ofan illegal gambling business as that term is defined in Title 18, United States Code, Section l 955(b), and aided and abetted the conducting, financing, managing, supervising, directing and owning of an illegal gambling business, that is, an electronic gambling device business operated in violation of the laws of the Commonwealth of Pennsylvania (Title 18, Pennsylvania Consolidated Statutes Annotated, Section 5513), in which the illegal gambling business was conducted, and which involved five or more persons who conducted, financed, managed, supervised, directed and owned all or part of said business and which business remained in substantially continuous operation for a period in excess ofthirty days and which business had a gross revenue in excess of$2,000 in a single day.
In violation o f Title 18, United States Code, Sections 1955 and 2.
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COUNT FOUR Obstruction of .Justice
THE GRAND JURY FURTHER CHARGES:
On or about October 12, 2010, in the Eastern District ofPennsylvania, defendant
JOSEPH LIGAMBI, a/k/a"Uncle Joe," a/k/a "Unc,
knowingly intimidated, threatened, and corruptly persuaded, and attempted to intimidate, threaten and corruptly persuade, an individual known to the grand jury and identified here as Individual G, by placing his hand on Individual G and making threatening statements to Individual G with the intent to cause and induce Individual G to withhold a photograph from an official proceeding, namely a federal grand jury proceeding.
In violation of Title 18, United States Code, Section 1512(b)(2)(

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