Count One Rico

Racketeering conspiracy “Enterprise”

Exhibit # 9

Count One charges that from June through December 1994, Robert Carozza, Micheal P.Romano Sr Anthony Ciampi, Sean Thomas Cote, Enrico Ponzo, Mark F.SpisakJohn J.Patti III,Eugene A. Rida Jr, John M. Arciero, Vincent M. Marino, Nazzaro Ralph Scarpa and Paul A. DeCologero, being employed by and associated with an enterprise, as defined in 18 U.S.C 1961(4), did unlawfully and Knowingly conduct and participate directly and indirectly, in the conduct of the affairs of the Enterprise, Which was  engaged in and the activities of which affected interstate commerce, through a pattern of Racketeering activity, as defined by 18 U.S.C 1961(1) and (5).Marino was named in the Following Racketeering acts Guilty of counts 1, 2, 3 : Racketeering Act A-1, Racketeering Act A-2


  • The Alleged Marino conspiracy was from 1989 through 1994, however Marino was in federal prison from 1989 through 1993, no testimony from anyone, from anywhere showed that Marino had any visits, telephone communications, letters, e-mail or other communications with anyone from the alleged criminal conspiracy from 1989 through 1993 while Marino was in federal custody. Thus the alleged conspiracy from 1989 through 1993 should be stricken from the record.

    1. From a date in or before June,1989, through in or after December, 1994, in or in the District of Massachusetts and else where, the Patriarca Family of La Cosa Nostra,including its leaders,members and associates, did constitute an enterprise (the “Enterprise”) Within the meaning of Title 18, United States code, section 1961 (4), that is , a group of individuals associated in fact, which engaged in various criminal activities, including multiple acts involving murder in violation of the laws,and unknown to the Grand Jury to murder one Enrico .M Ponzo, in violation of Massachusetts General Laws, Chapter 256, section 1,and Chapter 274,Section 7.


B. Act of racketeering Involving the Felonious Receiving,Concealment,Buying,Selling and Otherwise dealing in Controlled Substances in Violation of the Laws of the United States

Racketeering Act B

  From in or  before summer,1993, through in or after December,1994, in the District if Massachusetts and else where,the defendents,


                               Michael P. Romano, SR.,

                               Anthony Ciampi,

                              Enrico M. Ponzo

                              John J. Patti,III,

                             John M. Arciero,

                             Vincent M. Marino,

                             Nazzaro R. Scarpa

                             Paul A.Decologero,

Did knowingly, willfully and intentionally  combine, conspire, confederate and agree with each other and with persons known and unknown to the Grand Jury, Knowingly and intentionally to possess with intent to distribute a quantity of a mixture or substance containing  cocaine, a schedule II controlled substance, in Violation of Title 21, United States code, section 846.

One thought on “Count One Rico”

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