MAR 13 '96 07:07PM USAO EDMI STRIKE FOR Case 9:96-mj-05051-AEV ,l 0 P.l Document 1 Entered on FLSD Docket 03/18/1996 Page 1 of 57 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN - SOUTHERN DIVISION UNITED STATES OF AMERICA, Plaintiff, v. CRIMINAL ACTION NO. '~I 0 (,0 i-n VIOLATIONS : ,,,, ~-~c:• en ~:;~ ~::H~ ·:•' :~· ~,:.' ... ~·'* OOH ~ 18 t1eSaCe 5§ "i24(i1} (1) 1 1S03 1 19Sl (a) 1 196-2 (d) ' D-1 JACK WILLIAM TOCCO, D-2 ANTHONY JOSEPH ZERILLI, D-3 TONY GIACALONE, D-4 ANTHONY JOSEPH TOCCO, D-5 VITO WILLIAM GIA~ONE, D-5 ANTHONY JOS!PH CORRADO, D-7 PAOL CORRADO (son of Anthony Corrado), D-8 NOVE TOCCO, D-9 PAUL CORRADO (son ot Dominic Corrado), D-10 PETER JACK CORRADO, D-11 PETER ANTHONY ~ORRADO I D-12 JOHN BATISTA SCIARROTTA, D-13 JOHN MICHAEL JARJOSA, D-14 NORMAN N!RSES BAGDASARIAN, D-15 PAUL JOSEPH TOCCO, D-16 THOMAS KENNETH LENHARD, and P-17 FRANK S!RT WHITCHER Defendants. --------------------------------' ~ THE GRAND JURY CHARGES: I NDI CTKENT comrr· oNE . (18 u.s.c. S l962(d) -Racketeer Influenced and Corrupt 0r9anizations - Conspiracy) 0 - 1 D-2 D-3 D-4 D-~ D-6 D-7 PAUL CORRADO (son o! Anthony Corrado) D-8 NOVE TOCCO JACK WILLIAM TOCCO ANTHONY JOSEPH ZERILLI TONY GIACALONE ANTHONY JOSEPH TOCCO VITO WILLIAM GIACALONE ANTHONY JOSEP~ CORRADO 0-9 PAUL coruuoo (son of Dominic Corrado) 1963, and 2. ·--~·~-.. ····.::!!. :·.ti~·: •""": -- ""! .. ...•~· •.. . . . : ...- . . .. •.·· I.... ' • ' . - I1• c..::
41 • • .l • • THE ENTERPRISE. 1. That at all times material to this Indictment, clandestina criminal cr~an!zation commonly known·to it• ~embera ; "Cosa Nostra," and 11'l'he outfit," and commonly known to.the qener1 public as the "M,.!ia," existad in the United Statas ot America. 2. 'l'hat at all times material to th~s Indictment, thi c~andestine criminal organization [hereinafter referred to as th1 Cosa Nostra) .comprised groups o! individuals kno:wn as "families' which were based in and about various cities located within the~ United States o! America including Detroit, MichiqanJ New York~ City, New York/ Chicaqo, Illinois; Boston, Massachusetts; Buffalo,! ' 3. That at all times material to this Indictment, the cosa No.stra "tamilies" which were based in and about Detroit, New York City, Chicago, Boston, Buffalo, and Philadelphia engaged in criminal activities for financial qain which included sports boo~aking and the operation of illeqal lotteries (numbers), extortion (including extortion in exchange for "protection")~ making and collecting interest on usurious loans (loansharking): and unlawfully acquiring and maintaining undisclosed interests in gaming casinos otherwise apparently oparating lawfully in Nevada. 4. That from at least in or about January 1966 and continuinq .throuqh the date of this Indictment, the exact dates beinq unknown to the Grand Jury, in the Eastern District of Michigan and elsewhere, JACK WILLIAM TOCCO, ANTHONY JOSEPH ZERILLI, 2 Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 2 of 57 - ••IUOl"'TI USAO EDMI STRIKE FOR P.2 0 0 New York; and Philadelphia, Pennsylvania. ..
~- .. J ' .• ,... ~ l::J ' 9 6 07:08PM USAO EDMI STRIKE FOR P.3 Page 3 of 57 Case 9:96-mj-05051-AEV0Document 1 Entered on FLSD Docket 03/18/1996 TONY GIACALONE, ANTHONY JOSEPH TOCCO, VITO WILLIAM GIACALONE, AN'I'HqNY JOSEPH CORRADO, PAUL CORRADO (son of Anthony Corrado), NOVE TOCCO, and PAUL CORRADO · (son of Dominic· Corrado), Defendants herein, as members of the cosa Nostra 11 family" located· in and about Detroit, Michiqan [hereinafter referred to as the Detroit cosa Nostra Family], and others known and unknown to the Grand Jury, did constitute an enterprise [herein designated the Detroit Cosa Nostra Family] within the meaning of Title 18, United States· Coda, Sect~on 1961(4); that "is, a group of individuals assoc~ated in fact although not a legal entity engaged in various criminal activities including: acts indictable under Title 18, United States Code, · ~. Section 892 (relating to making extortionate extensions o! credit); Section 894 (relating to collecting extensions of cradit by extortionate means); Section 1503 (relating to obstruction of justice); Section 1512 (relating to tamperinq with a witness) 1. Section 1951 (relating to interference with commerce by ext.ortion) 1 and Section 1952 (relating to interstate travel and the use of interstate facilities in aid of racketeering)1 acts chargeablR under Section 750.157a(a) of the Michigan Compiled Laws Annotated [hereinafter referred to as the MCLA] (relating ~o conspiracy to commit first degree murder, conspiracy to commit arson, and conspiracy to commit extortion); Section 750.157a(b) ot the MCLA (relating to conspiracy to violate gambling laws); Section 750.213 (relatinq to extortion); and in the collection of unlawfui debts, as ~etined in Title 18, United States Code, Section 1961(6). 5. That at all times material to this Indictment~ tne 3 ()
.. 0 ,.IM!'; .L.:J :~o ~ar •~atn.....rt u~Hu t.UMl oTRI.KE FOR P.4 Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 4 of 57 0 Detroit Coca Nostra ~amily was structured in the followinq manner, and the Defendants and other persons employed by and associated with the Detroit Cosa Nostra Family functioned in the following roles:· A. The Detroit Cosa Nostra Family comprisad a -qroup ot .individuals commonly known as members. Many of these members were related by blood or by marriage to one or more other members of the Detroit Cosa Nostra Family as well as to members ot other Cosa Nostra families. Admission to membership in the Detroit Cosa Nostra Family was based in part on the existence o! a relationship by I blood or by marriage to present or past (deceased) members. B. The Detroit Cosa Nostra Family was headed by a member commonly known as the Boss. The Boss was elected by the other members of the Detroit Cosa Nostra Family. The Boss was responsible for the overall management of the activities of the other Detroit Cosa Nostra Family members, including giving final approval to any· activity generally affecting the Detroit Cosa Nostra Family as a whole. The Boss .representee! the Detro!t Cosa Nostra Family in dealings with other Cosa Nostra families. The Boss was responsible for arbitrating and finally deciding disputes between members, disputes between members and associates, and disputes between .members and members or associates of other Cosa Nostra families. The Boss, like 4
• ..1 ) 'f • 0 ~ 1~ ' 9 6 07:09PM USAO EDMI STRIKE FOR P.S Page 5 of 57 Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 any oth~r member of the Detroit Cosa Nostra Family, also participate4 in criminal activities for financial qain and to protect the Detroit Cosa Nostra Family and ita members. The· Boss also shared in the division of· certain. .. revenues received by_ the Boss and other members· of the Detroit Cosa Nostra Family. Additionally, the Boss ot the Detroit Co~a Nostra Family was at times a member ot the "Commiss_ion," a group consisting o! the bosses of Cosa Nostra families located in New York City, Chicago, and various other locations within the United states o! America, who made decisions concerning matters a!tecting I all the Cosa Nostra families. c. From i-n and about June 1979 and continuing through the date of this Indictment, JACK WILLIAM TOCCO, Defendant herein, was the Boss of the Oetroit Cosa Nostra Family. D. Subordinate to the Boss in the Detroit cosa Nostra Family, and superior to the remaining members, were a number of members commonly known as Capos or Captains. The Capos were responsible for participatinq with the Boss .and other Capos in making decisions conc~rninq the affairs ot the Detroit Cosa Nostra Family. These decisions included decisions relating to membership, leadership posi~ions, and the co~ductinq of criminal activities by the members and associates ot the Detroit cosa Nostra Family. These decisions also
........ .6.._ -'\J ILJII '"'ILJI-'' '• u...:;,nv [..VI IJ. .:::J 11"-.L"-~ r V"'- P.6 Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 6 of 57 '..:' 0 - 1•. included approval for any proposed activity which might affect another member or the Detroit Cosa Nostra Family as a whole, s~ch as the use of violence. The Capos were respons'ible for overs11uaing and advising certain other members of the Detroit co~a ~ostra Family, and for· approvinq activitiss these members sought to conduct. Col'l\ll\on.ly, the members subordinate to a particular Capo were also related to him by blood or by marriage·. The capos, like any of the other members of the Oetr~it Cosa Nostra Family, also participated in criminal activities tor financial qain and to proteet the Detroit Cosa Nostra I. Family and its members. The capos also shared in the division of certain revenues received by other members of. the Detroit Cosa Nostra Family. E. From in and about January 1966 and continuing until in or about 1979, a time perio~ durinq which Joseph Zerilli (now deceased) was the Boss of the Detroit Cosa Nostra Family, JACK WILLIAM TOCCO, Detendant herein, was a member and a capo in the Detroit cosa Nostra Family. F. At all times material to this Indictment, ANTHONY JOSEPH ZERILLI, TONY GIACALONE, ANTHONY JOSEPH TOCCO, VITO WILLIAM GIACALONE, a n d ANTHONY JOSEPH CORRADO, Defendants herein, were Capos of the Detroit Cosa Nostra Family. C. Subordinate to the Boss and Capos were the remaininq members of the Detro!t cosa Nostra ·Family. 6
a. ) • ll.• o- • " ''' ..,_, .Ju "-' r • o::.J:::>rn U;:)HU t..UI'IJ. :::>I I'<:J.I<..t.. rUt< P.7 . Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Do0cket 03/18/1996 Page 7 of 57 These ramaininq members, like the Boss and cap·os, also participatad in criminal activities tor financial qain an~ to protect ~he Detroit Cosa Nostra Family and its members. ·The members also utilized and directed the activitias of indiviauals commonly known as associates who participated in the activities of members of the Oetroit Cosa Nostra Family by performing necessary and helpful roles in criminal activities and who thereby served as insulation against prosecution for the members ot the Detroit Cosa Nostra Family. H. At all times materi.al to this Indictment, PAUL I CORRADO (son of Anthony Corrado), NOVE ~occo, and .PAUL CORRADO (so.n ot Dominic Corrado) , Defendants herein, were members of the Detroit Cosa Nostra Family. THE BACRETEERING CONSPIRACY. 6. That from in or about January 1966 and continuinq throuqh the date of this Indictment, the exact dates being unknown to the Grand ~ury, in the Eastern District of Michigan and elsewhere, jAcK WILLIAM TOCCO, ANTHONY JOSEPH ZERILLI, TON'{ GIACALONE, AN~HONY JOSEPH TOCCO, VITO WILLIAM GIACALONE, ANTHONY JOSEPH CORRADO, PAUL CORRADO (con of Anthony Corrado), NOVE ~occo, and_PAUL CORRADO (son ot Dominic Corrado), Defendants herein, beinq persons employed by and associated with the Detroit Cosa Nostra Family, an enterprise as defined in Title lS, United States Code, Section 196_1(4) 1 which enterprise was enqaqed in, and the activities of which affected, interstate colMlerce, cUd unlawfully1 7 knowingly1 and will.tully
MAR 13 ' 9 6 07:10PM USAO EDMI STRIKE FOR P.S Case 9:96-mj-05051-AEV0Document 1 Entered on FLSD Docket 03/18/1996 Page 8 of 57 0 combine, conspira, confederate, and agree with each other and with persons known and unknown to the Grand Jury, to commit an offense aqainst th~ United sta~es, to wit: to violate Title 18, united States Code, Section 1962(c), that is, to conduct and participate, direct~y a n d indi~eetly, i n t h e c o n d u c t o t t h e attai~s o ! t h e Detroit coaa Nostra Family through a pattern ot rackateerinq activity,·to wit·, multip~e acts as set forth below: A. Acts indictable under Title 18, United States Code, .Section 892 (relating to mak~nq exto~tionate extensions o! credit, and conspiracy to do so); B. Acts indictable under Title 18, United States ~ Code, Section 894 (~alat~nq to collecting extensions of credit by extortionate means, and conspiracy to do so); c. Acts indictable under Title 18, United states Code, Section 1503 (relating to obstruction of justice); D. Acts indic~able under Title lB, United States Code, Section 1512 (relating to tampering with a witness); E. Acts indictable under Title 18, United states Coda, Section 1951 (relating to interference with commerce by extortion, and attempt, and conspiracy to do so); F. Acts indictable under Title 18, United States Code, Section 1952 (relating to interstate travel and the use of interstate facilities in aid of unlawful business enterprises involving gambling); 8 •!
.. ·0 -· ~ .A.ILJI I I U....JnV ~UI-IJ. ;:::)Ir<:J.t\.~ rUt( P.9 Case 9:96-mj-05051-AEV 0 Document 1 Entered on FLSD Docket 03/18/1996 Page 9 of 57 Acta involvinq murder includinq acts charqeable under sa·ction 750.i57a(a) ot the MCLA (relatinq to conspiracy to commit t.irst degree murder in violation ot Section 750.316 o! the MCLA)I H. Acts involving qam~linq includinq acts. charqeable under Section 7SO.l5_7a(b) of the MOLA (relat~nq to conspiracy to viol~te qamblinq law&)7 I. Acts involving arson includinq acts chargeable under · Section 750 .157a (a) ot the MCLA (ralatinq to .. conspiracy to commit arson in violation ot Section 750.77 of the MCLA); and I J . Acts chargeable under Sections 750.213 and 750.157a(a) or the MCLA (relating to. extortion and conspiracy to commit extortion). MANNER AND MEANS OF THE CONSPIBACY. 7. It was a part o! the conspiracy that the Oetendan~s and their co-conspirators, in order to protect the Detroit 9osa Nostra Family and its members, would and did commit acts indictable under Title 18, United States Code, Section 1503 (relating to obstruction of justice), and acts indictable under Title 19, United States Code, section 1512 (relating to tampering with a witne!!l), in connection with efforts to obstruct criminal investigations and to prevent witnesses from testifying about the Detroit Cosa Nostra Family and i t s members. 8. It was further a part ot the conspiracy that the G. involving extortion including acts
.. • J.••~ () 0 Defendants and tl:leir co-conspirators would and did commit acts indictable under Title 18, United States Coda, section 1951 (relating to interference with commerce by extortion, and attempt, and conspiracy to do so), acts chargeable under Section 750.1!7a(a) of the MCLA (relating to conspiracy to commit first degr.ee murder in violation of Section 750.316 of the MCLA), acts chargeable under se~tion 750 .157a (a) 'of the M.CLA (relating to conspiracy to coll'll'llit arson in violation ot Section 750.77 of tha MCLA), and acts charqeable under Sections ·750.213 and 750.157a(a) o! the MCLA (relating to extortion and conspiracy to commit extortion), in connection with et~orts to obtain •oney and other property from I persons through the use of express and implied threats that harm would be done to those persons, their property, or their ~usinesses if they did not pay. A. It was further a part of the conspiracy that the Defendants and their co-conspirators would tarqet for extortion individuals unlikely to ·complain to the authorities because th.ey were themselves enqaqed . in conducting unlawful sports bookmaking and operating illegal (numbers) lotteries. B. It was turther a part of the conspiracy that the Defendants and their co-conspirators would discuss, plan, and commit acts o! violence to induce thG targeted sports bookmakers and illegal (numbers) lottery operators to pay them. c. It was further a part of the conspiracy that 10 ;;~o ~r·J.t:Jrl'l U~HU t.l.JMl !::>11-<lKt:.. ~UI< P . 1 0 Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 10 of 57
. '•· ', 0 the Defendants and their co-conspirators would and did construct and detonate a prototype destructive device, that is, an improvised bomb, in conne.ction with a plan to use a similar improvised ·bomb to induce Ramzi Yaldoo, the' operator ot an illegal (numbers) lottery, to pay them money. D. It was ·further a part of the conspiracy that the Defendants and t~eir co-conspirators would and did _shoot the windows of Airtime Communications,. 'located at 8630 Michiqan Avenue, Detroit, Michigan·, a business ·owned and operated by Ramzi Yaldoo, to induce him to pay them I money. E. It was·further a part of the conspiracy that the Defendants and their co-conspirators would and did plan to murder Jesus Morales, the operator of an illegal (numbers) lottery, who had rebuffed their attempts at extortion. 9. It was further a part of the conspiracy that the Defendants and their co-conspirators would and did commit acts indictable under Title lB, United States Code, Section 1951 ·(relating to interfa~ence with commerce by extortion, and attempt, and conspiracy to do so) , and. acts chargeable under Sections 750.213 and 750.157a(a) of the MCLA (relating to ex~ortion and conspiracy to conunit axtortion)., in connection with efforts to· obtain money and other property from persons conducting legitimate business activities. 11 ~ 13 ' 9 6 07:11PM USAO EDMI STRIKE FOR Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 11 of 57 P.11
• I.•·I 0 A. It was further a part ot. the conspiracy that the Defendants and their co-conspirators would and did dem·and "insurance payments" from Harold ·stern, a saqinaw, Michigan businessman, to insure the safety ot stern and his family. B. It was further a part of the conspiracy that the Defendants and their co-conspirators would discuss and plan to commit acts of violence to induce tarqeted individuals to· pay them~· c. It was further a part of the conspiracy that NOVE TOCCO, Defendant herein, would and ·aid hire Frank I Bert Whitcher to physically assault and beat Carlo John Catenacci in connection with a plan to induce him to pay money, telling Frank Bert Whitcher that he could inflict ae much·harm to Catenacci as he wished, so lonq as Catenacci was not killed. 10. It was !urther a part of the conspiracy that the Defendants and their co-conspirators would and did commit acts indictable unde~ Title 18, United States Code, Section 892 (relatinq ·to making extortionate extensions 6t credit, and conspiracy to do so), and acts indictable under Title lB, United States Code, ·Sl!ction 894 (relating to collecting extensions of credit by extortionate means, and conspiracy to do eo), in connection with thQ conducting of loansharking and the collection of both legitimate and illegitimate debts and claims. A. It was turther a part of the conspiracy that 12 I"IMI'I. .i..J :::10 1::)( • .l..l.r-'1'1 U~HU LVMl ~l!<lKL ~OR P.12 Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 12 of 57
;;.;>o t:H • J.J.rn U:>HV t.LII'U ~11-<lKI:.. r01-< P.13 Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 13 of 57 ... .' 0 0 the Defendants and their co-conspirators would and did .make extortionate extensions of credit at usurious rates in excess ot ten (10) percent per month. B. It was. further a part of the conspiracy that the·De!endants and their co-conspirators would and did make extortionate· extensions o! credit reqardinq both leqitimate and ill~qitimate debts and clai~s. C. It was further a part o! the .conspiracy that the· Defendants and their co-conspirators would use the reputation of the Detroit Cosa Nostra Family to assist them in collecting legitimate ahd illeqitimate debts and I claims. 11. It was further a part of the conspira.cy that the Defendants and their cc:>-conspirators. would and did commit acts chargeable under section 750 .157a (b) o! the MCLA (relating to conspiracy to violate qambl.ing laws), in connection wi_th the conducting o~ unlawful gambling activities. 12. It was turther a part of the con~pir_acy that the ·oefendants and their co-conspirators would and did commit acts chargeable under .Section 750.157a (b) ot the MCLA · (relating to conspir~ey to v.~olate gambling l.aws) , and acts charqeable under Se9tion 750.·157a(a) of the MCLA (relatinq to conspiracy to commit first deqree murder in violatio·n of section 750.316 of the MCLA), in connection with the conducting of unlawful gambling activities. A. It was further a part of_ the conspiracy that the Defendants and their co-conspirators would tinance, 13
~ 1~ '96 07:12PM USAO EDMI STRIKE FOR P.14 Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 14 of 57 I . t .. • 0 manage, and conduct unlaw!ul sports bookma~ing and operate illegal (numbers) lotteries and clandestine 00 "after-hours" gaming oparations which were controll~d by the Detroit Cosa Nostra Family. B. It was turther a part of the conspi~aey that the Defendants and their co-conspirators would and did plan to murder Har~y. Bowman, also known as "Taco," because he had interfered with their unlawful gambling activitie"s. 13. It was further a part of tha conspiracy that the· Defendants and thei'l:" co-conspirators would and did commit acts indictable under Title 18, United states Code, Section 1952 (relating to interstate travel and the use of interstate facilities in aid o! unlawtul business enterprises involving gambl~ng), in connection with unlawfully acquiring and attempting to acquire undisclosed fin~ncial ·interests in ga~ing casinos operated under the laws of the state .of Nevada, to wit: (a) the Frontier Hotel located in Las Vegas, Nevada; (b) the Aladdin Hotel and Casino, located in Las Vegas, Nevada; and (c) the Edgewater Hotel and Casino, located in Laughlin, Nevada. A. It was further a part o! the conspiracy that the Defendants and their eo-conspirators would·and d~d use individuals, such as Maurice Friedman, a~ tronts or straw men to conceal their undisclosed financial interests in the Frontier Hotel located in Las Veqas, Nevada from the State of Nevada gaming authorities. 14
" '.·. MH~ 1~ ' 9 5 07:12PM USAO EDMI STRIKE FOR Case 9:96-mj-05051-AEV0Document 1 Entered on FLSD Docket 03/18/1996 Page 15 of 57 B. It was further a part or the conspiracy that the Defendants and their co-conspirators would and did usa individuals, such as James Tamer, as fronts or straw men to represent their interests in the Aladdin Hotel and Casino located in Las Vegas, Nevada, and_to conceal their interests from tha State ot Nevada gaming authorities. c. It was further a part of tha conspiracy that the Defendants and their co-conspirators would and did use individuals, such as William Pompili, as fronts or straw men to represent their interests in the Edqewater Hotal and casino located in Laughlin, Nevada, and to I conceal their interests from the State of Nevada gaming authorities. 14. It was further a part of the conspiracy that tha Defendants and their co-conspirators wo~ld and did share in revenue from their illegal activities. 15. It was further a part ot the conspiracy that the Defendants and their co-conspirators, iri order to perpetuate the Detroit Cosa Nostra Family and to facilitate their criminal activities, would. and did. coordinate their activities with, and assist, and seek assistance from, the members and associates of other Cosa Nostra tamilies. 1~. 'It was further a part of the conspiracy that the Detenda~ts and their co-conspirators would and did cause and procure Theodore Forman, who was then employed as an attorney by the Tax Division ot the United States Department of JustieQ in 15 P.lS
...• I ·0 , ,..,," ..."" ::>o ~:~r • J.c.rn U:>HV t.1JI'Il ~ 11-<lKt. ~ Ul'< P.16 Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 16 of 57 Washington, o.c., to unlawfull~ obtain grand jury material relatinq to an investigation into the criminal activities of VITO W~LLIAM ·GIACALONE, Defendant herein, his son, Jack Vito Giacalone·, and Nathaniel carl Deday LaRene, his lawyer. 17. It was further a part of the conspiracy that the Defendants and their co-conspirators, in order to perpetuate the Detroit Cosa Nostra ·Family and to facilitate their criminal activities, would and did attempt to conceal from law enforcement authorities the existence of the D'etroit Cosa Nostra Family, the identity ·of its members and associates, the ways in which it conducted its affairs, and the decisions and orders issued by its I leaders to others workinq tor it. 18. It was turther a part of the conspiracy that .the Defendants each . agreed· that two or more acts ot racketeering activity would be committed in the conduct of the affairs of the Detroit Cosa Nostra Family. OVERT ACTS In furtherance of the conspiracy, and to atfac~.the ,opjacts thereof, the Defendants and their co-conspirators committed ·and caused to be committed the following overt acts, amo~q others, in the Eastern Dis~rict ot Michigan and elsewhere: 1. On or about October 20, 1966, ANTHONY JOSEPH ZERILLI, Defendant herein, traVQled from Detroit; Michigan to Los .Angeles, California. 2. In or ~bout Summer 1973, TONY GIACALONE and VITO WILLIAM GIACALONE, Defendants herein, met Nicholas Troqan near Saginaw, 16
.~~ ·. . \ liN~". J..:J . '::'0 IQ(. l.:St-'M U~RO EDMI STRIKE FOR P.17 Page 17 of 57 Case 9:96-mj-05051-AEV0Document 1 Entered on FLSD Docket 03/18/1996 Michigan. 3 . o r .. 4•. In or about July .1977, TONY GIACALONE, Defendant herein, met Harold Stern in Saginaw, Michiqan. ~. In or about summer 1978, TONY GIACALONE, Defendant. herein, met Robert Moskal in Saginaw, Michigan•. 6. On or about April 16, 19801 JACK WILLIAM TOCCO and ANTHONY JOSEPH COR.RADO, Defendants herein, traveled from Datro'it, Michigan to Toledo, Ohio. 7. On or about July 22, l9SO,.JACK WILLIAM TOCCO, Defendant I herein, met Rafaelle Quasarano at the Corfu Restaurant located in Roseville, Michigan. a. On o r a b o u t S~ptember 3 1 1 9 8 0 , JACK WILLIAM TOCCO a n d ANTHONY JOSEPH CORRADO, Oe!endants herein, met Joseph Todaro and Jo~eph Todaro, Jr., members of the Buffalo cosa Nostra Family, at Larco 1 s Restaurant lo~ated in Detroit, Mich~gan. 9. On or about october 1, 1981, JACK W.ILLIAM TOCCO, Defendant herein, met Sam Baqnasco, Frank Versaci, Jose'ph Mirabile, and others, at The Nugget Restaurant, located at 14620 East Eight Mile Road, in Detroit, Michigan. 10. On or about August 18, 1982, VITO WILLIAM GIACALONE, Defendant herein, traveled from Toledo, ohio to Romulus, Michigan. I n Defendant herein, met Nicholas 'I'rogan in ·Oakland County,. Michigan·. a b o u t Summer 1 9 7 3 , ANTHONY JOSEPH CORRADO, . . 11 • . on or about October 17, .1991, NOYE: TOCCO and PAUL CORRADO (son of Dominic Corrado), Defendants herein, drove to the residence of Robert Monro located at 13925 Ridgewood Drive, Plymouth, 17
IIH~ .1..::1 "':lb I:::J(;l_ji-'M U:>RO EDMI STRIKE FOR Case 9:96-mj-05051-AEV0Document 1 Entered on FLSD Docket 03/18/1996 Page 18 of 57 •• Michigan. 12. ·on or about Nov~mber 51 1991, NOVE TOCCO an~ PAUL CORRADO (son of Dominic Corra~o), Defendants herein, and John Batista Sciarrot~a,- met George Wierzba at the Wyoming Lunch Restaurant, located at S063 Wyominq, Dearborn, Michigan. 13. On or about January 9, 1992, NOVE TOCCO and PAUL CORRADO (son of Domin~c Corrado), Defendants herein, drove ~Y the residence of Harry Bowman, also .known as "Taco," located at 10434 Merlin Av~nue, Detroit, M1chigan. 14. On or about January 10, 1992, ANTHONY JOSEPH CORRADO, NOVE TOCCO, and PAUL CORRADO (son ot Dominic Corrado), Defendants herein, met at Bobby ~·s Foods - Spirits, located at 35101 Harper Avenue, Clinton Township, Michigan. 15. On or ab~ut January 24, 1992, NOVE Tocco and PAUL CORRADO (son of Dominic Corrado), Defendants herein, and Peter Jack Corrado, met John Johns at Elizabeth 1 s By th~ Lake Restaurant, located at 23722 Jefferson Avenue, St. Clair Shores, Michigan. 1 6 . on· or about .February 2, l-992, PAUL CORRADO (son of Do~inic corra~o), Defendant ~erein, and John Batista Sciarrotta, drove to Kelly's Corner, located at 5119 Trenton, Detro!~, Michiqan. 17. on or about February J, 1992, PAUL CORRADO (son o! Oomiriic Corrado), Defendant herein, and John Batista Sciarrotta, drove by the residence ·of Jesus Morales, located at 2334 Junctior,,. Oetroit, Michigan. 18. On or about February 10, 1992, ANTHONY JOSEPH CORRAOO, 18 P.18
.. •• V Document 1 Entered on FLSD Docket 03/18/1996 Page 19 of 57 MAR 13 '96 07:13PM USAO EDMI STRIKE FOR P.19 Case 9:96-mj-05051-AE0 ·NOVE TOCCO, PAUL CORRADO. (son o! Dominic Corrado), Defendants herein,· and John Batista sciarrotta, met at the 'l'ravia Restaurant; located at 34396 Ha~per Avenue, Mt. Clemens, Michigan." 19•. On or about February 10, 1992, ANTHONY JOSEPH ZERILLI, NOVE TOCCO, and PAUL CORRADO (son ot Dominic Corrado), Def~nd~nts herein, met a~ the Spaghetti Palace Restaurant, located at· 31653 Gratiot, Roseville, Michigan. 20. On or about March 18, 1992, ANTHONY JOSEPH. CORRADO and PAUL CORRADO (son ot.oominic Corrado), Oefendants herein, and John Batista Soiarrotta and Norman Nerses Saqdasarian, met at Luciano's Restaurant, located at 39091 car-Pointe Plaza, Clinton Township, Michigan. 21. On or about March 22, 1992, NOVE TOCCO and PAUL CORRADO (son of Dominie Corrado), DefQndants herein, drove by the residence of Jesus Morales, located at 2334 Junction, Detroit, Michi9an. 22. In or about April 1992 or May 19921 ANTHONY JOSEPH CORRADO and PAUL CORRADO (son of Anthony Corrado), De!end.ants herein, received photocopies of official government documents in B~rminqham, Michigan from Theodore Forman, then an atto~ney emplpyed by the Tax Divisi~n of the United States Department ot Justice. 23. On or about May a, 1992, PAUL CORRADO (son of Dominic Corrado), Oetendant herein, and Norman Nerses Bagdasarian met.in a. vacant lot near the intersection of Rosa Parks Boulevard and Michigan Avenue, in DQtroit, Michigan. 24. On or about M~y 9, 1992, PAUL CORRADO (son o! Dominic 19
•• 0 MAR 13 '96 07:14PM USAO EDMI STRIKE FOR P.20 . Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 20 of 57 0 Corrado), Defendant herein, and Peter Anthony Corrado detonated a · c!estructive c!evice, that is, an improvised bomb, in the vicinity ot Meldrum R~ad.and Marine City Highway, St. Clair ~ounty, Michiqan. 25. ·o~ ·or about May 13, 19921 NOVE TOCCO and ~AUL CORRADO (son ot Dominic Corrado), Defendants herein, and Peter Anthony Corrado met at 1546 Shore Club Drive, st. Clair Shores, Michigan. 2 6 . On o r a b o u t J u n e 2 , 1 9 9 2 , NOVE TOCCO a n d PAUL.CORRADO (son of Dominic Corrado), Defendants herein, drove to the vic~nity ot. 8630 Mi'ch~qan Avenue, Detroit, Michigan, with a destructive device, that is, an improvised bomb, in the automobile. 27. On or about June 16i 1992, NOVE TOCCO and PAUL CORRADO ' (son of Domini~ Corrado) 1 Defendants herein, used· a firearm to shoot the windows of Airtime Communications, a business owned and operated by Ramzi Yaldoo, located at 8630 Michigan Avenue, Detroit, Michigan. 28. On or about June 17, 1992, ANTHONY JOSEPH TOCCO, ANTHONY JOSEPH CORRADO, a n d PAUL CORRADO ( s o n o ! D o m i n i c C o r r a d o ) , Defendant& herein, and Peter Jack Corrado mQt in st~rlinq Heiqhts~· Michigan. 29~ on or about June 26, 1992, NOVE TOCCO and PAUL co~o (son o! Dominic Corrado), De!endants herein, and John Michael Jarjosa mat Ramzi Yaldoo in Detroit, Michigan. 3 0 . I n o r a b o u t F a l l 1 9 9 2 , ANTHONY JOSEPH ZERILLI a n d TONY GIACALONE, Defendants herein, met Carlo John Catenacci, in Macomb county, Michigan. 31. On or about September 16, 1992, NOVE TOCCO, Defendant 20
MAR 13 '96 07:14PM USAO EDMI STRIKE FOR P.21 Case 9:96-mj-05051-AEV0Document 1 Entered on FLSD Docket 03/18/1996 Page 21 of 57 herein, met Sam Martin. 32. on or about October 7, 1992, NOVE TOCCO, Defendant her.ein, and Paul Joseph Tocco, drove to the parking lot ot the Sahara Restaurant ·located at the northwest corner of Coolid.qa Hiqhway and Nina Mile Road, Oak Park, Michiqan. 33. On or about October 7, 19921 NOVE TOCCO, Defendant hereinI mat Georqe Yatooma in the parkinq lot of the ~ahara Restaurant located at the northwest corner ot Coolidge ~iqhway and Nine Mile Road, Oak Park, Michigan. 34. On or about october 23, 199.2, NOVE TOCCO and PAUL CORRADO (son of Domini~ Corrado), Defendants·herein, drove by the residence I of Harry Bowman, also known as 11Taco," located at 10434 Merlin Avenue, Detroit, Michigan• .35. On or about November 16, 1992, NOVE TOCCO anti PAUL CORRADO (son of Dominic Corrado), Defendants herein, drove to Airtime Communications, a business owned and operated by Ramzi Yaldoo, located at 8630 Michigan Avenue, Detroit, Michigan. 36. On or about December 4, 1992, NOVE TOCCO and PAUL CORRADO (son of Dominic Corrado), Defendants herein, met Daniel Abraham at Drink's Saloon, located at 19380 Allen Road, Brownstown Township, Michigan. 37. On or about December 14, 1992, beginning at approximately 12:35 p.m., NOVE TOCCO, Defendant herein, and Frank Bert Whitcher had a conversation. 38. on or about Oecemb~r 19, 1992, at approximately .3:45 p.m., NOVE TOCCO and ANTHONY JOSEPH ZERILLI, Defendants h~rein, 21
rltil": J..;j ''::lb l:~rr:14PM USAO EDMI STRIKE FOR P.22 Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 22 of 57 0 drove to ·the Harbor Point Condominiums, a complex con~aining the residence of carlo John catenacci, at 26421 Harbor Point Drive, Harrison Township, Michigan. 39. on or about March.ll, 1993, VI'l'O WILLIAM GIACALONE, Defendant he~ein, traveled from the Detroit, Michigan area to the Federal Correctional Institution located at Morgantown, West Virginia to meet Jack Vito Giacalone. 40. In or about Fall 1994, NOVE Tocco, Defe~dant herein, met Louis Calcaterra at the· Firehouse Lounge, located at 31185 Utica~ F r a s e r , Michigan~ 41. In or about Fall 1994, NOVE TOCCO, Defendant herein, met ~ Louis Calcaterra at T.G.I. Fridays Restaurant, located near the intersection of Schoenherr Road and Hall Road, Sterling Height~, Michigan. 42. In or .about Summer 1995, NOVE TOCCO, Defendant ·herein, met Ramzi Yaldoo and George Yatooma at the Sahara Restaurant located at the northwest corner of Coolidqa Highway and Nine Mile Road, Oak Park, Michigan. 43. In or about February 1996, NOVE TOCCO, Defendant herein, met Ramzi Yaldoo at Airtime Communications, a business owned and operat~d by Ramzi Yaldoo, located at B6JO Michigan Avenue, Detroit, Michigan. All in violation of Title 18, United states Code, sections l962(d) and 1963(a). 22
MAR 13 '96 07:15PM USAO EDMI STRIKE FOR P.23 Case 9:96-mj-05051-AEV0Document 1 Entered on FLSD Docket 03/18/1996 Page 23 of 57 • COUNT TWO (18 u.s.c. S lg62(d) - Racketeer'Influenced and Corrupt Orqanlzations - Conspiracy) \ D-1 D-2 D-3 D-4 ANTHONY JOSEPH TOCCO D-5 VITO WILLIAM GIACALONE D-6 ANTHONY JOSEPH CORRADO .. JACK. WILLIAM TOCCO ANTHONY JOSEPH ZERILLI .TONY. GIACALONE 1. The alleqations contained in paragraphs ~ne (1) throuqh five (5) of count One are hereby realleqec! and incorporated ·by reference in this count as if tully aet :forth herein• THE RACKETEERING ¢0NSPIRACY. I 6. That from in or about January 1966 and continuing throuqh the date of this Indictment, the exact dates beinq unknown to the Grand Jury, in the Eastern District of-Michigan and elsewhere, JACK WILLIAM TOCCO, ANTHONY JOSEPH ZERILLI 1 TONY . GIACALONE, ANTHONY JOSEPH TOCCO, VITO WILLIAM GIACALONE, a n d ANTHONY JOSEPH CORRADO, Defendants herein, being persons employed by and associated wit~ the Detroit Cosa Nostra Family, an enterprise as defined in Title 18, United States Code, Section 1961(4), which enterprise was engaged in, and the · activities of which affected, in~erstate commerce, did unlawfully, knowingly, and ·willfully combine, conspire, confederate, and aqree with each other and with persons known and unknown to the Grand Jury, to commit an offense against the United states~ to wit: to violate Title lB, United States Code, Section 1962(c), that is, to conduct and participate, d~rectly and indirectly, in the conduct o! the affairs of the Detroit Cosa 23 \ •J
•l 0 Nostra Family through the collection of unlawful debt. • 0 MANNER AND MEANS QF THE CONSPIRACY. 7. It was a part of the conspiracy that the Defendants an~ their co-conspirators would conduct and participate, directly and· indirectly, in the conduct or the attairs of the Detroit cosa Nostra Family through multiple acts of collection ot unlawtul debt. a. It was a part of the conspiracy that the Defendants and their co-conspirators would and did knowingly collect unlawtul debts and aid, abet, counsel, command, induce, and procure the collection of unlawful debts in va~ious and varyi_ng amounts from various and varying ..persons, both known and unknown, said unlawful debts having been incurred and contracted in qambling activity which was in violation of the laws of the State of ·Michiqan, an~ which was incurred in connection with the business of gambling in violation or the laws of the State of Michigan (Sections 750.92, 750.157a(b), 750.167(d), 750.301, 750.304, and 750.314 of the Michigan Compiled Laws Annotated. 9. It was further a part o! the conspiracy that the Defendants and their co-conspirators would collect unlawful debts, as defined in Title 18, United States Code, Section 1961(6), incurred in_connection with sports bookmaking and illegal (numbers) lottery activities conducted by the Defendants and t.heir co- conspirators. 10. It was further a part of the conspiracy that each Defendant aqreed that one or more collections of an unlawful debt, as de!ined in Title 18, United states Code, section 1961(6), would 24 ~ 13 '96 07:15PM USAO EDMI STRIKE FOR Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 24 of 57 P.24 .
riHI"<: 1.::1 ''::fb ~:::~r:1~1-'M USAO EDMI STRIKE FOR P.25 Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 25 of 57 • '0 • 0.•' ba made in the conduct of the affairs ot th• Detroit Coaa Nostra Family·. QYERT ACTS · In furtherance ·of the conspiracy, and to effect the objects thereof, the Defendants and th&ir eo-conspirators committed and caused to b• committed the following overt acts, amonq others, in the Eastern District of Michiqan and elsewhere: 1. In or about January of each year durini the time frame of this Indictment, the Defendants and their co-conspirators would distribute a portion of the profits generated from illegal gambling amonq themselvei_an~ the remaining members ~f the hierarchy of the Detroit Cosa Nostra Family. All in violation ot Title lB, United· States Code, Sections 1962 (d) and 1963 (a). 25
MAR 13 '96 07:16PM USAO EDMI STRIKE FOR P.26 Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 26 of 57 0 J'OR!'!JI'l'UB!S 1. The alleqations ot Counts One and Two ot this Indictment are ~Qreby realleged and incorporated by rete~ence tor the purpose . ot alleging forfeitures pursuant to the.provisions ot Title 18, UnitQd States Code, Section 1963. 2 . T h a t JACK WILLIAM TOCCO, ANTHON¥ JOSEPH Z~ILLI, TONY GIACALONE, ANTHONY JO~EPH TOCCO, VITO WILLIAM GIACALONE, ANTHONY JOSEPH CORRADO, PAUL CORRADO (son or Anthony Corrado), NOVE TOCCO~ and PAUL CORRADO (son or Dominic Corrado), Defendants herein, have property constituting and derive~ !rom proceeds which they obtained, directly and indirectly, from a conspiracy to conduct. an en~erprise through a pattern of racketeering activity in violation of Title 18, United States Code, Sections 1962(c) and l962(d), as to which proceeds derived therefrom the Defendants are jointly and severally liable, thereby making all such property, or an amount equivalent thereto, in whatever form, wherever located, and in whatever names held, subject to forfeiture to the United States of America pursuant to Title 18, United States Code, Section 1963 (a) (3). 3 . T h a t JACK WILLIAM TOCCO, ANTHONY JOSEPH ZERILLI, TONY TOCCO 1 VITO WILLIAM GIACALONE 1 a n d D e f e n d a n t s h e r e i n , h a v e prop~rty GIACALONE, ANTHONY JOSEPH ANTHONY JOSEPH CORRADO, constituting and derived !rom proceeds which they .obtained, ~irectly and indirectly, from a conspiracy to conduct·an enterprise through the collection of unlawful debt in violation ot Title 16, · United States Code, Sections 1962 (c) and 1952 (d), as to which 26
I o· l"lt"1!";; .I.,:) - '=fb ~r • lbt-'1'1 U::>HO I:.DMl ~I ~lKI:. FOR Case 9:96-mj-05051-AEV0Document 1 Entered on FLSD Docket 03/18/1996 Page 27 of 57 ·proceeds derived therefrom the Oetendants are join"t;ly and severally liaDle, thereby makinq all such property, or an amount equivalent thareto, in whatever torm, wherever located, and in whatever name·s held, SUDject to forfeiture to the United States of America pursuant to Title 18, United States Code, Saction 1963(a) (3). P.27
•,I• Case 9:96-mj-05051-AEV0Document 1 Entered on FLSD Docket 03/18/1996 Page 28 of 57 COUNT THREE (18 u.s.c. S 924(c) (l) -Using or carrying a firearm 4urinq and in relation to a crime o! violence) D-9 PAUL CORRADO (son of Dominic Corrado) 1. That on or about May 9, 1992, in the !astern District o! Michigan, PAOL CORRADO (son of Dominic Corrado), Defendant herein·, did knowingly use and carry a firearm, to wit: a destructive 4evice, durinq and in·relation to a crime of violenoa for which the Defendant may be prosecuted in a court· o! the United States, to wit: conspiracy to violate Section l962(c) throuqh a pat~ern o! racketeering activity comprised, in .part, of racketeerinq activ~ty I involving murder and extortion, in violation of Title 18, United States Code, Sections 1962(d) and l963(a), as charged in Count One of· this Indictment. All in violation of Title lB, United States Code, Sections 924(o)(1) and 2. MAR. 13 '96 07:16PM USAO EDMI STRIKE FOR · P.28 28
~ 1~ ~~o 07:17PM USAO EDMI STRIKE FOR Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 29 of 57 . . .. 0 0 comrr :roUR (18 o.s.c. S 924(c) (1) - Usinq or carrying a firearm during and in relation to a crime ot violence) D-8 NOVE TOCCO . D-g PAUL CORRADO (son ot Dominic Corrado) 1. That on or about 3uno 2, 199l, in the Eastern District of Michigan, NOVE TOCCO and PAUL CORRADO (son ot·oominic Corrado), Defendants herein, ~id knowingly use and carry a firearm, to vit: a destructive dev;ce, during and in relation to a crime of violence tor which the Defendants may be prosecuted in a court of the United states, to wit: conspiracy to violate Section 1962(c) through a pattern of racketreerinq activity comprised, in part, of racketeering activity involving murder and extortion, in violation ot Title 18, United States Code, Sections 1962(d) and 1963(a), as charqed in count one o! this Indictment. All in violation of Title 18, United States Code, Sections 924(c)(1) and2. 29
•I t-Il MAR 13 '96 07:17PM USRO EDMI STRIKE FOR P.30 Page 30 of 57 o· 0 comr.r liVE Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 (18 o.s.c. 5 924(c) (l) -Using or carryinq a ti~earm-durinq and. · . in relation to a crimo of violence) D-8 NOVE TOCCO D-9 PAUL CORRADO (son of Dominic Corrado) 1. That on or about June 16, 1992, in tha·Eastern District of Michigan, NOVE TOCCO and PAUL CORRADO (son·ot Dominic Corradq), Defendants herein, ·did knowingly use and carry a· firearm, to wit: a rifle, ·during and in rela·tion to a ·crime ot violence for which the Defendants may be prosecuted in a cou~t of the United stat~s, to wit: conspiracy to violate Section 1962(c) through a pattern of racketeerinq activity comprised, in part, of racketeerinq activity involvinq murder and extortion, in violation o! Title 18, United states Co~e, Sec~ions l962(d) and l963(a), as charqed in Count One of this Indictment. All in violation of Title 18, United States Code, Sections 924(c)(l) and 2. 30
tl. I Case 9:96-mj-05051-AEV 0Document 1 '. Entered on FLSD Docket 03/18/1996 P.31 Page 31 of 57 ~OtlNT S I X (18 u.s.c. S 1951 - Conspiracy to Interfere with Commerce by. Extortion) D-1 JACK WILLIAM TOCCO D-2 ANTHONY JOSEPH ZERILLI ·o-3 TONY GIACALONE . . D-4 · ANTHONY JOSEPH TOCCO D-S VITO WI~IAM GIACALONE D-6 ANTHONY JOSEPH CORRADO D-8 NOVE TOCCO D-9 PAUL CORRADO- (son ot Dominic Corrado). D-10 PETER JACK CORRADO D-11 PETER ANTHONY CORRADO D-12 JOHN BATISTA SCIARROTTA 0-13 JOHN MICHAEL JARJOSA 0-14 NORMAN NERS!S BAGDASARIAN 0-15 PAUL 'JOSEPH TOCCO D-16 THOMAS KENNETH LENHARD t 1. That beginninq in or about April 1991 and continuinq ~hrough the date of this Indictment, the exact dates being unknown to the Grand Jury, in the Eastern District ot Michiqan, JACK WILLIAM TOCCO, ANTHONY JOSEPH ZERILLI, TONY GIACALONE, ANTHONY JOSEPH TOCCO, VITO WILLIAM GIACALONE, ANTHONY JOSEPH CORRADO, NOVE TOCCO, PAUL CORRADO (son of Dominic Corrado), PETER JACK CORRADO, PETER ANTHONY CORRADO, JOHN BATISTA SCIAR:ROT'I'A, JOHN MICHAEL JARJOSA, NORMAN NERSES BAGDASARIAN, PAUL JOSEPH TOCCO, a n d THOMAS KENNETH LENHARD, Defendants herein, and other pers.ons both known and unknown to the Grand Jury,- did unlawfully, knowingly, and. willfully combine, conspire, confederate, and agrea together and with each other, to obstruct, delay, and affect commarce as that term is detined in Title 18, United States Co.de, Section 1951(~) (3), and the movement of articles and commodities in such commerce, by extortion, as that term is defined in Title 18, United 31
MHI'< 1.:1 •':1b l:::lr:1WM USRO EDMI STRIKE FOR P.32 Case 9:96-mj-05051-AEV0Document 1 Entered on FLSD Docket 03/18/1996 Page 32 of 57 States Code, Section 19~l(b) (2), in th~t the Defendants di~ agree to obtain the property of Robert Monro1 Jesus Mor~lea1 George Wierzba, Ramzi Yaldoo, John Johns, Georqe Yatooma, Sam Martin, Daniel Abraham, and George Sophiea: _to wit, United states cur~ency, with their consent having been induced by the wronqtul use of actual and threatened force, violence, and fear, includinq fear of economic harm. All in violation of Title 18, United States Code, Section 1951(a). I 32
·- ..... 00 .COJZNT BIVEN (18 u.s.c. S 924(c) (1) -Using ·or carrying a firaarm during and in relation to a crime of violence) D-9 PAUL CORRADO (son .ot Dominic Corrado) D-11 PETER ANTHONY CORRADO 1. That on or about May 9, 1992, in the Eastern District ot Michigan, PAUL CORRADO (son o! Dominic Corrado) and PETER ANTHONY CORRADO, Defendant.s herein, did knowingly"" use and carry a firearm, to wit: a destructive device, during and in relation to a crime of violence for which the Defendants may be prosecuted in a court of the United States, to wit: conspiracy to interfere with commerce by extortion in violat~on o! Title 18, United States Code, Section 195l(a), as charged in Count Six of this Indictment. All in violation or Title 18, United States Code, Sections 924(c)(1) and2• nMI"'I. J..:J :::10 I O f • J . O r r l u::,Hu t..UMl !::ilt<lKt.. 1-Ut< Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 33 of 57 33 P.33
<- .. -'. llr"'JJ'- .A....J ::10 "'r • J. ern U::>HU t..i.JI'll ~ll'<lK.t.. tUI'< Case 9:96-mj-05051-AEV P.34 00 .COUN'l' EI!'JH'l' Document 1 Entered on FLSD Docket 03/18/1996 Page 34 of 57 (18 u.s.·c. s 924(c) (l) - Usinq or carryinq a fir•arm during and in relation to a ~rimQ ot violence) D-8 NOVE TOCCO D-9 PAUL CORRADO (son ot Dominic·corrado) D - 1 2 JOHN BATISTA SCIARROTTA . 1. That on or about June 2, 1.9921 in the Eastern District o! . Michigan, .NOVE TOCCO,. PAUL CORRADO (son ot Dominic Corrado) 1 and JOHN BATISTA SCIARROTTA, Defendants herein,· did knowinqly use and carry a firearm;· t;o ·wit: a destructive device, during and 'in relation to a crime of violence for which the Defendants ma~ be prosecuted in a court ot the United·States, to wit: conspiracy to I interfere with commerce by extortion in violation of Title 18, United States Code, Section 1951 (a) , as charged in Cpunt Six ot' this Indictment. All in ViQlation of Title 18, Unitad States Code, Sections 924(c) (1) .and 2. 34
.' MAR 13. '96 07!18PM USAO EDMI ST~IKE FOR Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 35 of 57 s;otrnT NINE (18 u.s.c. S 924 (c)(~) - Using or carryinq a tirearm ·durin~ and in relation to a crime of violence) 0 - 8 NOVE TOCCO D-9 PAUL CORRADO (son ot Dominie Corrado) 1. That on or about June 16, 1992, in the Eastern District of Michiqan, PAUL CORRADO (son of Dominic Corrad?) and NOVE TOCCO, Def.endants herein, did knowingly use and carry ·a firearm, to wit: a rifla, during and in _relation to a crime ot violenca tor which the Defendants m~y be prosecuted in a court of the United States, to wit: conspiracy to interfere with commerce by extortion in violation of Title ~18, United States Code, Section 1951 (a), as charged in Count Six of this Indictment. All in violation of Title 18,. United states Code, Sections 924(c)(1) and 2·. 'I ·. 0 P.35 35
'I CasMeAR9:9136-m'9j6-05075:18-PAMEV0DoEcDuMmIeSnTtR1IKEnFOteRred on FLSD Docket 03/18/1996 Page 3P6.o36f 57 () COUN'I'TEN (18 u.s.c. 5 19~1 - Interference with commerce by Extortion) 0-1 0-2 0-3 D-4 D-5 D-6 D-8 0-9 PAUL CORRADO (son ot Dominic Corrado) D-12 JOHN BATISTA SCIARROTTA 1. That beginning in or about April 1991 and eontinuinq through in or about October ~991, the exact dates being unknown to the Grand Jury, in the Eastern Dist.rict of Michiqan, NOVE 'l'Oc.co, PAUL CORRADO (son of Dominic Corrado), and JOHN BATISTA SCIARROTTA, I DefQndants herein, did knowingly and unlawfully obstruct, delay, .and affect commerce as that term is defined in Title 18, United States Code, Section 195l(b) (3), and the movement.ot articles ~nd commodities in such commerce, by extortion, as that term is defined in Title 18, United States Code, Section 195l(b) (2), in that the· Defendants did obtain the property of Robert Monro: to wit, United states currency, with his consent having been induced by the wrongful ~se of actual and threatened force, violence, and tear, including fear of economic harm. 2. That at the said time and place, JACK WILLIAM TOCCO, ANTHONY JOSEPH ZERILLI, TONY GIACALONE, ANTHONY JOSEPH TOCCO, VITO WILLIAM GIACALONE, and ANTHONY JOSEPH CORRADO, Defendants herein, did knowingly aid, abet, counsel, eommand, induce, and procure the commission of the above alleg~d offan&e. All in violation of Title 18, United States Code, Sections l95l(a) and 2. JACK WILLIAM TOCCO ·ANTHONY JOSEPH ZERILLI . TONY GIACALONE · ANTHONY JOSEPH TOCCO VITO WILLIAM GIACALONE ANTHONY JOSEPH CORRADO NOVE TOCCO 36
, MAR13·'96 Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Dock0 0~1 D-2 D-3 D-4 D-5 D-6 D-8 D-9 D - 1 2 JACK WI~IAM TOCCO ANTHONY JOSEPH ZERILLI TONY GI~CALONE. ANTHONY JOSEPH TOCCO VITO WILLIAM GIACALONE ANTHONY ·JOSEPH CORRADO NOVE TOCCO PAUL CORRADO (son of Dominic Corrado) JOHN BATISTA SCIARROTTA 1. That in or about Summer 1991, the exact dates beinq 07:19PM USODMI STRIKE FOR P.37 COUNT ELEVEN (18 u.s.c. S 1951 - AttemptQd InterferencG with Commerce by · Extortion) unknown to the Grand Jury, in the Eastern District of Michigan, NOVE TOCCO, PAUL CORRADO ·(son o! Dominic Corrado) 1 and JOHN BATISTA t SCIARROTTA, Defendants herein, did knowingly and unlawfully attempt to obstruct, ·delay, and affect commerce as th.at term is defined.in Title 16, United states Coda, Section 195l(b) (3), and the movement of articles and commodities in such commerce, by extortion, as that term is defined in Title 18, United States Code, Section l95l(b)(2), in that the De!endants did attempt to obtain the property of Jesus Morales: to wit, United states currency, with h{s consent having bliilen induced by thG wronq!ul usa of actual and threatened force, violence and !ear, including fear ot economic harm. 2. That at the said time and place, JACK WILLIAM TOCCO, ANTHONY JOSEPH ZERILLI, TONY GIACALONE, ANTHONY JOSEPH TOCCO, VITO WILLIAM GIACALONE, and ANTHONY JOSEPH CORRADO, Oetendants. herein, did knowingly aid, abet, counsel, command, induce, and procure the commission ot the above alleged offense. All in viola~ion or Title ~6, United States code, Sections 1951(a) and 2• 37 et 03/18/1996 Page 37 of 57
MAR 13 '96 07:19PM U c EDMI STRIKE FOR Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 3P8.3o8f 57 COTJN'l' TWELYE (18 u.s.c. S 1951 - InterferQnce with commerce by .Extortion) D-1 JACK WILLIAM TOCCO D-2 ANTHONY· JOSEPH ZERILLI D-3 'TONY GIACALONE D - 4 ANTHONY JOSEPH TOCCO D-5 VITO WILLIAM GIACALONE D-6 ANTHONY JOSEPH CORRADO D-8 NOVE TOCCO D-9 .PAUL CORRADO (son ot Dominic Corrado) . D - 1 2 JOHN BATISTA SCIARROTTA 0 - 1 4 NORMAN NERSES BAGDASARIAN· 1. That beginning in or about November ·19~1 and continuiriq through in or about April 1994, tha exact dates bainq unknown to the Grand Jury, in the Eastern District o! Michigan, NOVE TOCCO, t PAUL· CORRADO (son of Dominic Corrado), JOHN BATISTA SCIARROTTA, and NORMAN NERSES BAGDASARIAN, Defendants herein, did knowingly and unlawfully obstruct, delay, and affect commerce a& that tarm is defined in Title 18, United states Code, Section 195l~b) (3), and the movement of articles and comrnodities in such commerce, by extortion, as that term is defined in Title lS, United States Code, ·section l95l(b) (2), in that the Defendants did obtain the property of G~orge Wierzba: to wit, United States currency, with his consent having been induced by the wrong!ul use of actual and threatened force, violence, and fear, including fear ot economic harm. 2. That at the said time and place, JACK WILLIAM TOCCO, ANTHONY JOSEPH ZERILLI, TON~ GIACALONE, ANTHONY JOSEPH TOCCO, VITO WILLIAM GIACALONE, and ANTHON~ JOSEPH CORRADO, Defendants herein, did knowingly-aid, abet, counsel, command, induce, and procure the commission of the above alleged offense. All in violation o! Title 181 UnitGd states Code, SGctions 1951 (a) and 2. 38
'l ..... ! MAR 13 '96 07:20PM U4:) EDMI STRIKE FOR Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Doc0 .. COUNT TIURTEEN (18 u.s.c. S 1951- InterferancQ with·Commarca by Extortion) D-1 JACK WILLIAM TOCCO D-2 ANTHONY JOSEPH ZERILLI 0 - 3 TONY GIACALONE D-4· ANTHONY JOSEPH TOCCO D-5 VITO WILLIAM GIACALONE D-6 ANTHONY JOSEPH CORRADO D-B NOVE TOCCO D-9 PAUL CORRADO (son of Dominic Corrado) D-ll PETER ANTHONY CORRADO D - 1 2 D - 1 3 D - 1 6 JOHN BATISTA SCIARROTTA JOHN MICHAEL JARJOSA THOMAS KENNETH LENHARD 1. That b~qinninq in or about ~anuary 1992 and continuinq through the date of this Indictment, the exact dates beinq unknown .. to the Grand Jury, in the Eastern Di~trict o! Michiqan, NOVE TOCCO, PAUL CORRADO (son of Dominic Corrado), PETER ANTHONY CORRADO, JOHN I BATISTA SCIAAROTTA, LENHARD, Defendants herein, did knowingly and unlawfully obstruct, delay, and affect commerc~ as that term is defined in TitlQ 18, United States Code, Section l95l(b) (3), and the ~ovement of articles and commodities in such commerce, by extortion, as that ter~ is defined in Title 18, · United states Code, Section 195l(b) (2) 1 in that the Defendants 9id obtain the property of Ramzi Yaldoo: to wit, United States currency, with his consent havinq been induced by the wrongful use of actual'and threatened force, violence, and fear, including fear of economic harm• . 2. 'That at the said time and place, .JACK WILLIAM TOCCO, . ANTHONY JOSEPH ZERILLI, TONY GIACALONE, ANTHONY JOSEPH TOCCO, VITO WILLIAM GIACALONE, an~ ANTHONY JOSEPH CORRADO, Defendants herein, did knowingly aid, abet, counsel, command, induce, and procurQ the commission o! the above alleged offense. All in violation of Title 18, United Stat~s Code, Sections 1951 (a) and 2. ket 03/18/1996 Page 3P9. 3o9f 57 JOHN MICHAEL JARJOSA, a n d THOMAS KENNETH 39
.. MAR 13 '96 07:20PM ~EDMI STRIKE FOR P.40 Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 40 of 57 RQ'Qlfl' FOURTEEN (18 u.s.c. S 924(c) (1) -Using or carrying a tirearm durinq and in relation to a crime o! violonce) D-9 PAUL CORRADO (son of Dom-inic Corrado) D-ll. PETER ANTHONY CORRADO . . 1. That on. or about May 9, 1992; in the Eastarn District of ~ichigan, PAUL CORRADO (son of Dominic Corrado) and PETER ANTHONY CORRADO, Defendants herein, did knowinqly·use and carry a .tirearm, to vit: a destructive device, durinq and in relation to a crime of. violonce tor which the Defendants may be prosecuted in a court of the United states, to wit: interference with commerce by extortion in violation o! Title .la, United states Code, Section l95l(a), as. charqed in count Thirteen of this lndictment. All in violation of Title 18, United states Code, Sections 924(c)(1) and2. 40
MAR 13 '96 07:20PM ~ EDMI STRIKE FOR Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 41 of 57 COtnrr FIFTEEN (l.B u.s.c. s 9·24 (c) (1) - Usin9 or carryinq a firearm durinq and in relation to a crime of violence) D-8 NOVE TOCCO D-9.· PAUL CORRADO (son of Dominic Corrado) D - 1 2 JOHN BATISTA'SCIARROTTA 1. That on or about June 2, 1.992, in the Ea~tern District ot Michiqan, NOVE ·~occo, PAUL CORRADO (son of·Oominic Corrado), and JOHN BATISTA SCIARROTTA, Defendant~ herein, did knowinqly use and carry a ·firea~, to wit:· a. destructive dQ!Vice, du~inq a_nd in relation to a crime o! violence fo+ which the Defendants may be prosecuted in a court of the United States, to wit: interference I with commerce by extortion in violation of Title 18, United states Code, Section 1951 (a) , as charged in Count · Thirteen of this Indictment. All in violation of Title.lB, United States Code, Sections 924(c)(l) and 2. 41 0 P.41
MAR 13 '96 07:20PM ~ EDMI STRIKE FOR P.42 Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 42 of 57 COUN'.l' ar:Ul!M (18 u.s.c. S 924.(c) (1) - Using OJ; carrying a tirearlll during and in relat~on to a crime ot violence) · D-9 PAUL CORRADO (son of Dominic Corrado) 1. That on or about J~na 16, 1992, in the Eastern District of Michiqan, NOVE TOCCO and PAUL CORRADO (son ot Dominic Corrado), Defendants herein, did knowingly use and carry a firearm, to wit: a ritle, during and in relation to a crime of violence for which ·the Defendants may b~ prosacuted fn a court of the Unlted States, to wit: interference with commerce.by extortion in violation of Title 18, United States Code, Section 195l(a), as charged in Count Thirteen of this Indictment. All in violation ot Title 18, United states Code, Sections 924(c)(l) and2. D-8 NOVE TOCCO 42
_.MAR13'9607:21PMU~EDMISTRIKEFOR 0 P.43 Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 43 of 57 (18 u.s.c. S 1gs1 - Attempted Interference wi~h Commerce.'by Extort~on) 0-1 .JACK WILLIAM TOCCO D-2" D-3 0-4 o-s D-6 o-a 0-9 0 - 1 0 ANTHONY J O S E P H Z E R I L L I TONY GIACALONE ANTHONY JOSEPH TOCCO VITO WILLIAM GIACALONE ANTHONY JOSEPH CORRADO NOVE TOCCO PAUL CORRADO (son of Dominic Corrado) PETER JACK CORRADO 1. That in or abol,lt January 1992, the· exa~t dates beinq. unknown to the Grand Jury, in the Eastern District of Michigan, NOVE TOCCO, PAUL CORRADO (son of Dominic Corrado), and PETER JACK ' CO~Do, Defendants herein, did knowingly and unlawfully attempt to obstruct, delay, and affect commerce as that term is defined in Title 18, United States Code, section l95l(b) (3), and the movement of articles and commodities in such commerce, by extortion, as that term is defined in Title 18, United States Code, section 195l(b) (2), in .that the Defendants did attempt to obtain the property of John Johns: to wit, United States currency; with his consent having been induced by the wrongful use of actual and threatened force, violence and te~r, i~cludinq fear o! economic harm. 2. That at the said time and place, JACK WILLIAM TOCCO, ANTHONY JOSEPH ZERILLI, TONY GIACALONE, ANTHONY JOSEPH TOCCO, VITO WILLIAM GIACALONE, and ANTHONY JOSEPH CORRADO, De!endants herein, did knowingly aid, abet·, counsel, c·omman~, induce, and procure the commission o~·the above alleged offense •. All in viol~t1on of Title 18, Uni{ed States Code, Sections 195l(a) and 2. 43
MAR 13 '96 07:21PM ~0 EDMI SrRIKE FOR P.44 Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 44 of 57 COUNT EIGHTEEN (lB u.s.c. S 1503 - Obstruction of Justice) 0 - 6 ANTHONY JOSEPH CORRADO D-7 PAUL CORRADO ·cson of Anthony Corrado) ... 1. That at all times material to this Indictment, the Tax Division of the United States Department of. Justice [hereinaf·tQr referred to as ~ho Tax·oivision] had ·final approval authority over all proposed_ federal criminal income tax prosecutions to be brought in the United States of America. 2. That at all times. material to thi& Indictment, attorneys assigned to the Criminal Enforcemen·t Section of the Tax Division ~ere responsible fo~ reviewing information submitted by special agents of the Criminal Investigation Division of the Internal Revenue service to determine whether to authorize prosecution for ·federal criminal income tax violations in particula~ cases. 3. · That at all times material to this Indictment, Theodore Forman was employed as an attorney by the Criminal Enforcement Section of the Tax Division in Washington, D.C. 4. That at all times material to this Indictment, among the information included in reports submitted by special agents of the criminal Investigation Division of the Internal Revenue Service to attorneys in the criminal Enforcement ~action of the Tax Division, ·in connection with their evaluation of the merits o! proposed ..,. federal criminal income tax prosecutions, were transcripts of qrand jury testimony obtained during the course of fedQral criminal income tax investigations. ~- That at all times material to this Indi~tment, Theodore 44
'. MAR 13· '96 07:21PM Uc:> EDMI STRIKE FOR P.45 Case 9:96-mj-05051-AEV Document 1 Entered on FLSD Docket 03/18/1996 Page 45 of 57 Forman, as an attorney Qmployed by the Criminal Enforceme.nt Section of the 'l'ax Division, kn.ew that the secrecy of transcripts· of grand jury. testimony was protected by federal ·law which limits th~ir disc~osure ~o onlr certain authorized persons, and was respons~ble for upholding this law. 6. That in or about 1991, special agents of the Criminal Investigation Division of the Internal Revenue Service began participating in a qrand jury investigation, designated as grand jury case number 91-3-4, then being conducted in Detroit, Michigan, into federal criminal violations, including fQdQral incol\le tax offenses, which had possibly been committed by Vito William '. Giacalone and others [hereinafter referred to as Grand Jury
The most high profiled and wild members were the two Giacalone brothers. And even they pretty much knew what they were doing. And trusted by Joe Z and Tocco.
Detroit always reminded me of the West Side. They've always been blessed with exceptionally capable leaders and a family is only as good as it's leader. I don't know how powerful they are these days, but I know they are very active.
Detroit always reminded me of the West Side. They've always been blessed with exceptionally capable leaders and a family is only as good as it's leader. I don't know how powerful they are these days, but I know they are very active.
A lot of personal and familial relationships between Detroit,Chicago and the West Side...even to this day with Danny Pagano brother in law being Johnny Matassa Jr...
