. . .
THE RELEVANT PLACES
2. The predicate criminal activity took place at the Township of Galloway,
and at the City of Ventnor, in the
County of Atlantic, at the Borough of Elmwood Park, at the Borough of Fort
Lee, at the Borough of Glen Rock, and
at the Township of Wyckoff, all in the County of Bergen, at the Township of
�Belleville, at the Township of Cedar Grove, at the Borough of Glen Ridge,
and at the Township of West Caldwell,
all in the County of Essex, at the Township of East Amwell, in the County of
Hunterdon, at the Borough of
Farmingdale, and at the Township Neptune, both in the County of Monmouth, at
the Township of East Hanover, at the
Borough of Florham Park, at the Township of Parsippany, and at the Township
of Pequannock, all in the County of
Morris, at the Township of Brick, and at the Township of Toms River, both in
the County of Ocean, at the Borough
of Bloomingdale, at the City of Clifton, at the Borough of Hawthorne,and at
the Borough of North Haledon, all in
the County of Passaic, at the City of Rahway, in the County of Union, in the
State of New York, in the Commonwealth of Pennsylvania, elsewhere, and
within the jurisdiction of this Court.
THE ENTERPRISE
3. JOSEPHDI NAPOLI, MATTHEW MADONNA, RALPH V. PERNA, NICODEMO SCARFO, JR.,
JOSEPH M. PERNA, MICHAEL CETTA, FRANK
CETTA, JOHN G. PERNA, RALPH M. PERNA, JOHN MANGRELLA, GARY MEDURE, ELLIOT
PORCO, MARTIN TACCETTA, ANTONIO RUSSO,
ALFONSO CATALDO, MICHAEL RAMUNO, III, RONALD SCRIPPS, GIANNI IACOVO, ROBERT
DECRESCENZO, CHARLES BOLOGNA, JAMES
FURFARO,ROBERT ROMANO, JOHN TURI, MICHAEL MAFFUCCI, GEORGE MAIORANO, BLERIM
IBRIAMI, SHPETIM HANI, ROSANNA PERNA,
VITA CETTA, EDWIN SPEARS, SAMUEL A. JULIANO, MICHAEL BRUINTON, DWAYNE
SPEARS, KRISTEN GILLIAM, all of whom are
co-conspirators, and Francine Hightower
who is a co-conspirator and member of the enterprise, but not charged in
this indictment, and other persons whose
identities are both known and unknown to the State Grand Jurors, would
constitute an enterprise within the meaning
of N.J.S.A. 2C:41-1c, that is, a union or group of individuals associated in
fact, or associates thereof, which,
among other names, members or associates thereof self identified as the
"Lucchese" organized crime family or the
"Nine-Trey Gangster Bloods," for the purposes set forth below.
THE PURPOSES OF THE ENTERPRISE
The purposes of the enterprise would include the maintenance of its strength
and the assurance of its perpetuation
through specific rules and protocols applicable to its members and
associates, including: discussing matters
pertaining to the operation, conduct and control of the enterprise with no
one other than members or highly
trusted associates of the enterprise; resolving disputes or seeking
direction from superiors within the enterprise
through a specific chain of command; enforcing the protocols of the
enterprise through any means necessary,
including threats or use of violence; keeping a
member's immediate supervisor within the enterprise informed of illegal
activities and law enforcement activities
targeting the enterprise; collectively generating income on behalf of and
for the benefit the enterprise through
various illicit schemes; and dividing proceeds from enterprise members'
criminal activities in accordance with
enterprise protocol. A further purpose of the enterprise would be to shield
its operation from detection by law
enforcement authorities by, among other means: using code names when
communicating; resorting to in-person
meetings; using
wireless telephones in fictitious or nominee names; prohibiting membership
or association in the .enterprise to
those who may have law enforcement familial relationships or familial
relationships with those who may have
cooperated with law enforcement.
THE PATTERN OF RACKETEERING ACTIVITY
The pattern of racketeering activity, as defined in N.J.S.A. 2C:41-1d,
engaged in by members of the enterprise,
did consist of at least two incidents �of racketeering conduct during the
relevant time period stated above,
including but not limited to: gambling offenses in violation of N.J.S.A. 2C
: 37-1 et ~, theft offenses in
violation of N.J.S.A. 2C:20-1 et ~, aggravated assault in violation of
N.J.S.A. 2C:12-1b(1), forgery and
fraudulent practices in violation of N.J.S.A. 2C:21-1 et ~, failure to file
tax returns or reports in violation of
N.J.S.A. 54:52-8, failure to pay gross income taxes in violation of
N.J. S.A. 54:52-9, bribery in violation of N.J.S.A. 2C:27-2, possession with
intent to di stribute controlled
dangerous substances in violation of N.J.S.A. 2C:35-5 et ~, unlawful use of
firearms in violation of N. J.S.A.
2C:39-1 et ~, money laundering in violation of N.J.S.A. 2C:21-25, involving
property valued in excess of $500,000,
and conspiracy to commit the foregoing crimes in violation of N.J.S.A. 2C :
5-2, primarily in the following ways:
. . .
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