UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
UNITED STATES OF AMERICA
v.
ROMEO BLACKMAN, aka “O” or “O-Dog,”
TERRANCE SMITH, aka “T,”
JOLICIOUS TURMAN, aka “Jo Jo,” and,
NATHANIEL MCELROY, aka “Nate” or
“Nation”

Violations: Title 18, United States
Code, Sections 1959(a)(1), 1959(a)(3),
1959(a)(5), 1962(d), and 924(c)(1)(A)
and 2.

COUNT ONE
The SPECIAL FEBRUARY 2017 GRAND JURY charges:
THE RACKETEERING ENTERPRISE
At all times material to this indictment:
1.

The defendants, and others known and unknown to the Grand Jury,

were members and associates of the “Goonie Boss/Goonie Gang” street gang, a
criminal organization whose members and associates engaged in acts of violence,
including but not limited to murder, attempted murder, assault with a dangerous
weapon and assault resulting in serious injury, and which operated on the South Side
of Chicago, in the Northern District of Illinois, Eastern Division, and elsewhere.
2.

The “Goonie Boss/Goonie Gang” street gang, including its leadership,

membership, and associates, constituted an “enterprise,” as defined in Title 18,
United States Code, Section 1961(4) (hereinafter, “the Goonie Enterprise”), that is, a
group of individuals associated in fact, which enterprise engaged in, and the activities
of which affected, interstate and foreign commerce.
1

 3.

The Goonie Enterprise constituted an ongoing organization whose

members functioned as a continuing unit for a common purpose of achieving the
objectives of the enterprise.
4.

ROMEO BLACKMAN, aka “O” or “O-Dog,” TERRANCE SMITH, aka

“T,” JOLICIOUS TURMAN, aka “Jo Jo,” and NATHANIEL MCELROY, aka “Nate”
or “Nation,” the defendants, and others known and unknown to the Grand Jury, were
leaders, members and associates of the Goonie Enterprise who carried out and
directed other members of the Goonie Enterprise in carrying out unlawful and other
activities in furtherance of the conduct of the Goonie Enterprise’s affairs.
5.

The Goonie Enterprise has been engaged in a long standing and violent

feud with several rival Englewood street gangs, including, “Push Squad” and “TLove,” among others. Over the course of these conflicts, Goonie Enterprise members
and associates have committed acts of violence against their rivals, inside rival areas,
and any areas rivals are perceived to be.
6.

Certain members and associates enjoyed significant power and respect

within the Goonie Enterprise.

ROMEO BLACKMAN, aka “O” or “O-Dog,” the

defendant, acted as one of the Goonie Enterprise’s leaders.
PURPOSES OF THE ENTERPRISE
7.

The purposes of the Goonie Enterprise included, but were not limited to,

the following:
a.

Acquiring, preserving, and protecting power, territory, operations

and proceeds for the enterprise through the use of threats, intimidation and violence,
2

 including but not limited to, acts of murder, attempted murder, assault with a
dangerous weapon, and other acts of violence and threats of violence;
b.

Promoting and enhancing the enterprise and its members’ and

associates’ activities;
c.

Increasing the status of the enterprise through the use of social

media platforms;
d.

Keeping victims, rival gang members, and witnesses in fear of the

enterprise and its leaders, members and associates through acts and threats of
violence;
e.

Taking steps designed to prevent law enforcement’s detection of

the enterprise’s criminal activities;
f.

Seeking to prevent punishment, including criminal punishment,

for its leaders, members, and associates, through threats of and by the use of murder,
violence, and intimidation directed towards witnesses, victims and others; and
g.

Enriching the leaders, members and associates of the enterprise

through, among other things, theft of firearms and the illegal trafficking of controlled
substances.
ROLES IN THE ENTERPRISE
8.

At all times material to this indictment:
a.

ROMEO BLACKMAN, aka “O” or “O-Dog, was a leader of the

Goonie Enterprise and, in that role, BLACKMAN oversaw, directed, guided and

3

 participated in the illegal activities of the enterprise, including, but not limited to,
acts involving murder and other acts of violence.
b.

TERRANCE SMITH, aka “T,” served the enterprise by, among

other things, directing and participating in the illegal activities of the enterprise,
including, but not limited to, acts involving murder and other acts of violence.
c.

JOLICIOUS TURMAN, aka “Jo Jo,” served the enterprise by,

among other things, directing and participating in the illegal activities of the
enterprise, including, but not limited to, acts involving murder.
d.

NATHANIEL MCELROY, aka “Nate” or “Nation,” served the

enterprise by, among other things, providing firearms that were used by members of
the enterprise to conduct their illegal activities, including, but not limited to acts
involving murder and other acts of violence.
RACKETEERING CONSPIRACY
9.

Beginning no later than in or about 2014 and continuing through in or

about June 2018, in the Northern District of Illinois, Eastern Division, and elsewhere,
ROMEO BLACKMAN, a/k/a “O” or “O-Dog”
TERRANCE SMITH, a/k/a “T,”
JOLICIOUS TURMAN, a/k/a “Jo Jo” and
NATHANIEL MCELROY, a/k/a “Nate” or “Nation”
defendants herein, and others known and unknown to the Grand Jury, being persons
employed by and associated with the Goonie Enterprise, which engaged in, and the
activities of which affected, interstate commerce, knowingly conspired to violate Title
18, United States Code, Section 1962(c), that is, to conduct and participate directly
and indirectly, in the conduct of the affairs of that enterprise through a pattern of
4

 racketeering activity consisting of multiple acts involving murder, in violation of
Chapter 720, Illinois Compiled Statutes, Sections 5/5-1, 5/5-2, 5/8-1, 5/8-2, 5/8-4, and
5/9-1, 5/9-2, and 5/9-3.
10.

It was further part of the 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.
MEANS AND METHODS OF THE RICO CONSPIRACY
11.

It was further part of the conspiracy that the means and methods by

which the defendants and their associates conducted and participated in the conduct
of the affairs of the enterprise included the following:
a.

Members of the enterprise and their associates initiated members

through the practice of causing them to endure physical assaults conducted by
members of the enterprise at various gang-related gatherings;
b.

Members of the enterprise and their associates initiated members

through the practice of encouraging them to shoot at rival gang members;
c.

Members of the enterprise and their associates employed and

used gang-related terminology, symbols and gestures;
d.

Members of the enterprise and their associates promoted the

enterprise on social media sites including Facebook. For example, Goonie members
posted comments, photographs, and videos and used the Facebook Live feature
during which they, among other things, proclaimed their membership in the

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 enterprise and boasted about illegal activities, including murders and other acts of
violence;
e.

Members of the enterprise and their associates attended meetings

at which they discussed, planned and otherwise engaged in criminal activity
including murder, attempted murder, assault with a dangerous weapon, assault
resulting in serious injury and witness tampering;
f.

Members of the enterprise enforced discipline and rules of the

enterprise, by enforcing a system of “violations,” in which the members of the
enterprise and others threatened and physically assaulted those individuals who
violated the rules, questioned authority or posed a threat to the leaders or purpose of
the enterprise;
g.

To perpetuate the enterprise and to maintain and extend their

power, members of the enterprise and their associates committed illegal acts,
including, but not limited to, murder, attempted murder, assault with a dangerous
weapon, assault resulting in serious injury and witness tampering against
individuals who posed a threat to the enterprise or jeopardized its operations,
including rival gang members and witnesses to the illegal activities of the enterprise;
h.

Members of the enterprise and their associates used multiple

cellular telephones to communicate with one another concerning and during the
commission of the enterprise’s illegal activities;

6

 i.

Members of the enterprise and their associates utilized Facebook

to communicate with one another concerning and during the commission of the
enterprise’s illegal activities;
j.

Members of the enterprise and their associates obtained, used,

carried, possessed, brandished, and discharged firearms in connection with the
enterprise’s illegal activities, including, but not limited to, murder, attempted
murder, and assault with a dangerous weapon;
k.

Members of the enterprise and their associates managed the

procurement, transfer, use, maintenance, concealment, and disposal of firearms and
dangerous weapons within the enterprise to protect their territory, personnel and
operations, and to deter, eliminate and retaliate against competitors, rival criminal
organizations and persons, and individuals suspected of cooperating with law
enforcement;
l.

Members of the enterprise and their associates concealed and hid,

and caused to be concealed and hidden, the purposes of the acts done in furtherance
of the enterprise, and used coded language and other techniques and other means to
avoid detection and apprehension by law enforcement and otherwise to provide
security to members and associates of the enterprise.
m.

Members of the enterprise and their associates monitored law

enforcement radio frequencies in order to detect and avoid law enforcement inquiry
into their illegal activities;

7

 n.

Members of the enterprise and their associates possessed,

distributed, and possessed with intent to distribute marijuana and controlled
substances in the conduct of the affairs of the enterprise;
o.

Members of the enterprise and their associates committed

murders in the conduct of the affairs of the enterprise including, but not limited to,
the following:
i.

The

murder

of

Johnathon

Johnson

by

ROMEO

BLACKMAN on or about January 22, 2014;
ii.

The murder of Alonzo Williams by ROMEO BLACKMAN

on or about March 21, 2014;
iii.

The murder of Stanley Bobo by ROMEO BLACKMAN,

TERRANCE SMITH and others, known and unknown to the Grand Jury, on or about
October 23, 2014;
iv.

The murder of Krystal Jackson by ROMEO BLACKMAN

and TERRANCE SMITH on or about November 19, 2014;
v.

The murder of Andre Donner by ROMEO BLACKMAN and

others, known and unknown to the Grand Jury, on or about December 13, 2015;
vi.

The murder of Davon Horace by ROMEO BLACKMAN and

others, known and unknown to the Grand Jury, on or about January 15, 2016;
vii.

The murder of Gerald Sias by ROMEO BLACKMAN,

NATHANIEL MCELROY and others, known and unknown to the Grand Jury on or
about May 26, 2016;
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 viii.

The murder of Ramal Hicks by JOLICIOUS TURMAN and

others, known and unknown to the Grand Jury, on or about June 20, 2016;
ix.

The murder of Gerald Bumper by individuals, known and

unknown to the Grand Jury, on or about June 30, 2016; and
x.

The murder of Kenneth Whittaker by JOLICIOUS

TURMAN, and others, known and unknown to the Grand Jury, on or about July 1,
2016.
p.

Members of the enterprise and their associates committed

attempted murders in the conduct of the affairs of the enterprise, including but not
limited to, the following:
i.

The attempted murders of Victim 1, Victim 2 and Victim 3

by ROMEO BLACKMAN and TERRANCE SMITH on or about October 23, 2014;
ii.

The attempted murder of Victim 4 by TERRANCE SMITH

on or about February 4, 2015; and
iii.

The attempted murder of Victim 5 and Victim 6 by ROMEO

BLACKMAN, NATHANIEL MCELROY, and others, known and unknown to the
Grand Jury on or about May 26, 2016.
q.

Defendants and their associates committed assaults with a

dangerous weapon and assault resulting in serious injury in the conduct of the affairs
of the enterprise.

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 NOTICE OF SPECIAL FINDINGS FOR COUNT ONE
12.

Each of the murders identified in Paragraph 11(o) was committed in

violation of Chapter 720, Illinois Compiled Statutes, Section 5/9-1(a), in that in each
instance, the named defendants killed the named victim without lawful justification
in performing acts which caused the death of the named victims: (a) intending to kill
and do great bodily harm to the named victim, and knowing that such acts would
cause death of the named victim; and (b) knowing that such acts created a strong
probability of death and great bodily harm to the named victim;
13.

Each of the murders identified in Paragraph 11(o)(i), (iii)-(viii), (x) was

committed in violation of Chapter 720, Illinois Compiled Statutes, Section 5/91(b)(11), in that in each such instance (a) the murder was committed in a cold,
calculated and premeditated manner pursuant to a preconceived plan, scheme and
design to take a human life by unlawful means; and (b) the conduct of the named
defendant(s) created a reasonable expectation that the death of a human being would
result therefrom;
14.

Each of the murders identified in Paragraph 11(o)(i)-(vi), and (viii), and

(x) was committed in violation of Chapter 730, Illinois Compiled Statutes, Section
5/5-8-1(d)(iii), in that ROMEO BLACKMAN (the murders in paragraph 11(o)(i), (ii),
(v), and (vi)); TERRANCE SMITH (the murders in paragraph 11(o)(iii) and (iv), and
JOLICIOUS TURMAN (the murders in paragraph 11(o)(viii) and (x), each personally
discharged a firearm that proximately caused great bodily harm, permanent
disability, permanent disfigurement, and death to another person;
10

 15.

The murder identified in Paragraph 11(o)(iii) was committed in violation

of Chapter 720, Illinois Compiled Statutes, Section 5/9-1(b)(15), in that TERRANCE
SMITH intentionally discharged a firearm from a motor vehicle and the victim was
not present within the motor vehicle; and
16.

Each of the attempted murders identified in Paragraph 11(p)(i) and (ii)

was committed in violation of Chapter 730, Illinois Compiled Statutes, Section 5/5-81(d)(iii) in that TERRANCE SMITH personally discharged a firearm that
proximately caused great bodily harm, permanent disability, and permanent
disfigurement; and
17.

With respect to ROMEO BLACKMAN, TERRANCE SMITH, and

JOLICIOUS TURMAN they are each over 18 years of age and have each murdered
more than one victim, in violation of Chapter 730, Illinois Compiled Statutes, Section
5/5-8-1(a)(1)(c)(ii).
All in violation of Title 18, United States Code, Section 1962(d).

11

 COUNT TWO
The SPECIAL FEBRUARY 2017 GRAND JURY further charges:
1.

Paragraphs One through Eight and paragraph Eleven (a) through (n) of

Count One are incorporated here.
2.

At all times relevant to this Indictment, the Goonie Enterprise,

including its leadership, membership, and associates, constituted an enterprise as
defined in Title 18, United States Code, Section 1959(b)(2), namely a group of
individuals associated in fact, which was engaged in, and the activities of which
affected interstate and foreign commerce. The Goonie Enterprise constituted an
ongoing organization whose members functioned as a continuing unit for a common
purpose of achieving the objectives of the enterprise.
3.

At times relevant to this Indictment, the Goonie Enterprise, through its

leadership, membership and associates, engaged in racketeering activity as defined
in Title 18, United States Code, Sections 1959(b)(1), namely acts involving murder,
in violation of Illinois law.
4.

On or about March 21, 2014, at Chicago, in the Northern District of

Illinois, Eastern Division,
ROMEO BLACKMAN, aka “O” or “O-Dog,”
defendant herein, and others known and unknown to the Grand Jury, for the purpose
of gaining entrance to and maintaining and increasing position in the Goonie
Enterprise, an enterprise engaged in racketeering activity, did knowingly commit the

12

 murder of an individual, namely, Alonzo Williams, in violation of the laws of the State
of Illinois (Chapter 720, Illinois Compiled Statutes, Sections 5/9-1, 5/5-1, and 5/5-2);
In violation of Title 18, United States Code, Section 1959(a)(1).

13

 COUNT THREE
The SPECIAL FEBRUARY 2017 GRAND JURY further charges:
1.

Paragraphs One through Three of Count Two are incorporated here.

2.

On or about October 23, 2014, at Chicago, in the Northern District of

Illinois, Eastern Division,
ROMEO BLACKMAN, aka “O” or “O-Dog” and
TERRANCE SMITH, aka “T,”
defendants herein, and others known and unknown to the Grand Jury, for the
purpose of gaining entrance to and maintaining and increasing position in the Goonie
Enterprise, an enterprise engaged in racketeering activity, did knowingly commit the
murder of an individual, namely, Stanley Bobo, in violation of the laws of the State
of Illinois (Chapter 720, Illinois Compiled Statutes, Sections 5/9-1, 5/5-1, and 5/5-2);
In violation of Title 18, United States Code, Sections 1959(a)(1) and 2.

14

 COUNT FOUR
The SPECIAL FEBRUARY 2017 GRAND JURY further charges:
1.

Paragraphs One through Three of Count Two are incorporated here.

2.

On or about November 19, 2014, at Chicago, in the Northern District of

Illinois, Eastern Division,
ROMEO BLACKMAN, aka “O” or “O-Dog” and
TERRANCE SMITH, aka “T,”
defendant herein, and others known and unknown to the Grand Jury, for the purpose
of gaining entrance to and maintaining and increasing position in the Goonie
Enterprise, an enterprise engaged in racketeering activity, did knowingly commit the
murder of an individual, namely, Krystal Jackson, in violation of the laws of the State
of Illinois (Chapter 720, Illinois Compiled Statutes, Sections 5/9-1, 5/5-1, and 5/5-2);
In violation of Title 18, United States Code, Sections 1959(a)(1) and 2.

15

 COUNT FIVE
The SPECIAL FEBRUARY 2017 GRAND JURY further charges:
1.

Paragraphs One through Three of Count Two are incorporated here.

2.

On or about November 19, 2014, at Chicago, in the Northern District of

Illinois, Eastern Division,
ROMEO BLACKMAN, aka “O” or “O-Dog” and
TERRANCE SMITH, aka “T,”
defendant herein, and others known and unknown to the Grand Jury, for the purpose
of gaining entrance to and maintaining and increasing position in the Goonie
Enterprise, an enterprise engaged in racketeering activity, did knowingly attempt to
commit the murder of an individual, namely, Victim 1, in violation of the laws of the
State of Illinois (Chapter 720, Illinois Compiled Statutes, Sections 5/9-1, 5/5-1, and
5/5-2);
In violation of Title 18, United States Code, Sections 1959(a)(5) and 2.

16

 COUNT SIX
The SPECIAL FEBRUARY 2017 GRAND JURY further charges:
1.

Paragraphs One through Three of Count Two are incorporated here.

2.

On or about November 19, 2014, at Chicago, in the Northern District of

Illinois, Eastern Division,
ROMEO BLACKMAN, aka “O” or “O-Dog” and
TERRANCE SMITH, aka “T,”
defendant herein, and others known and unknown to the Grand Jury, for the purpose
of gaining entrance to and maintaining and increasing position in the Goonie
Enterprise, an enterprise engaged in racketeering activity, did knowingly attempt to
commit the murder of an individual, namely, Victim 2, in violation of the laws of the
State of Illinois (Chapter 720, Illinois Compiled Statutes, Sections 5/9-1, 5/5-1, and
5/5-2);
In violation of Title 18, United States Code, Sections 1959(a)(5) and 2.

17

 COUNT SEVEN
The SPECIAL FEBRUARY 2017 GRAND JURY further charges:
1.

Paragraphs One through Three of Count Two are incorporated here.

2.

On or about November 19, 2014, at Chicago, in the Northern District of

Illinois, Eastern Division,
ROMEO BLACKMAN, aka “O” or “O-Dog” and
TERRANCE SMITH, aka “T,”
defendant herein, and others known and unknown to the Grand Jury, for the purpose
of gaining entrance to and maintaining and increasing position in the Goonie
Enterprise an enterprise engaged in racketeering activity, did knowingly attempt to
commit the murder of an individual, namely, Victim 3, in violation of the laws of the
State of Illinois (Chapter 720, Illinois Compiled Statutes, Sections 5/9-1, 5/5-1, and
5/5-2);
In violation of Title 18, United States Code, Sections 1959(a)(5) and 2.

18

 COUNT EIGHT
The SPECIAL FEBRUARY 2017 GRAND JURY further charges:
1.

Paragraphs One through Three of Count Two are incorporated here.

2.

On or about February 4, 2015, at Chicago, in the Northern District of

Illinois, Eastern Division,
TERRANCE SMITH, aka “T,”
defendant herein, and others known and unknown to the Grand Jury, for the purpose
of gaining entrance to and maintaining and increasing position in the Goonie
Enterprise, an enterprise engaged in racketeering activity, did knowingly and
intentionally commit assault with a dangerous weapon and assault resulting in
serious bodily injury upon an individual, namely, Victim 4, in violation of the laws of
the State of Illinois (Chapter 720, Illinois Compiled Statutes, Sections 5/12-3.05(a)(1),
5/5-1, and 5/5-2);
In violation of Title 18, United States Code, Section 1959(a)(3).

19

 COUNT NINE
The SPECIAL FEBRUARY 2017 GRAND JURY further charges:
On or about February 4, 2015, at Chicago, in the Northern District of Illinois,
Eastern Division,
TERRANCE SMITH, aka “T,”
defendant herein, knowingly used, carried, brandished and discharged a firearm,
during and in relation to a crime of violence for which he may be prosecuted in a court
of the United States, namely an assault with a dangerous weapon in aid of
racketeering activity, in violation of Title 18, United States Code, Section 1959(a)(3)
as charged in Count Eight of this Indictment;
In violation of Title 18, United States Code, Section 924(c)(1)(A).

20

 COUNT TEN
The SPECIAL FEBRUARY 2017 GRAND JURY further charges:
1.

Paragraphs One through Three of Count Two are incorporated here.

2.

On or about December 13, 2015, at Chicago, in the Northern District of

Illinois, Eastern Division,
ROMEO BLACKMAN, aka “O” or “O-Dog,”
defendant herein, and others known and unknown to the Grand Jury, for the purpose
of gaining entrance to and maintaining and increasing position in the Goonie
Enterprise, an enterprise engaged in racketeering activity, did knowingly commit the
murder of an individual, namely, Andre Donner, in violation of the laws of the State
of Illinois (Chapter 720, Illinois Compiled Statutes, Sections 5/9-1, 5/5-1, and 5/5-2);
In violation of Title 18, United States Code, Section 1959(a)(1).

21

 COUNT ELEVEN
The SPECIAL FEBRUARY 2017 GRAND JURY further charges:
1.

Paragraphs One through Three of Count Two are incorporated here.

2.

On or about January 15, 2016, at Chicago, in the Northern District of

Illinois, Eastern Division,
ROMEO BLACKMAN, aka “O” or “O-Dog,”
defendant herein, and others known and unknown to the Grand Jury, for the purpose
of gaining entrance to and maintaining and increasing position in the Goonie
Enterprise, an enterprise engaged in racketeering activity, did knowingly commit the
murder of an individual, namely, Davon Horace, in violation of the laws of the State
of Illinois (Chapter 720, Illinois Compiled Statutes, Sections 5/9-1, 5/5-1, and 5/5-2);
In violation of Title 18, United States Code, Section 1959(a)(1).

22

 COUNT TWELVE
The SPECIAL FEBRUARY 2017 GRAND JURY further charges:
1.

Paragraphs One through Three of Count Two are incorporated here.

2.

On or about June 20, 2016, at Chicago, in the Northern District of

Illinois, Eastern Division,
JOLICIOUS TURMAN, aka “Jo Jo,”
defendant herein, and others known and unknown to the Grand Jury, for the purpose
of gaining entrance to and maintaining and increasing position in the Goonie
Enterprise, an enterprise engaged in racketeering activity, did knowingly commit the
murder of an individual, namely, Ramal Hicks, in violation of the laws of the State of
Illinois (Chapter 720, Illinois Compiled Statutes, Sections 5/9-1, 5/5-1, and 5/5-2);
In violation of Title 18, United States Code, Section 1959(a)(1).

23

 FORFEITURE ALLEGATION
The SPECIAL FEBRUARY 2017GRAND JURY further alleges:
1.

The allegations of Count One of this Indictment are incorporated here

for the purpose of alleging that certain property is subject to forfeiture to the United
States, pursuant to title 18, United States Code, Section 1963.
2.

As a result of their violation of Title 18, United States Code, Section

1962(d), as alleged in the foregoing Indictment,
ROMEO BLACKMAN, a/k/a “O” or “O-Dog”
TERRANCE SMITH, a/k/a “T,”
JOLICIOUS TURMAN, a/k/a “Jo Jo” and
NATHANIEL MCELROY, a/k/a “Nate” or “Nation”
defendants herein, shall forfeit to the United States, pursuant to Title 18, United
States Code, Section 1963(a)(1), (a)(2), and (a)(3), any interest acquired or maintained
in violation of Section 1962; any interest in, security of, claim against, or property or
contractual right of any kind affording a source of influence over, any enterprise
which the person has established, operated, controlled, conducted, or participated in
the conduct of, in violation of Section 1962; and any property consisting, or derived
from, any proceeds which the person obtained, directly or indirectly, from
racketeering activity or unlawful debt collection in violation of Section 1962.
3.

If any property described above as being subject to forfeiture pursuant

to Title 18, United States Code, Section 1963(a)(1), (a)(2), and (a)(3), as a result of
any act or omission of the defendants:
a. Cannot be located upon the exercise of due diligence;
b. Has been transferred to, sold to, or deposited with a third person;
24

 c. Has been placed beyond the jurisdiction of the Court;
d. Has been substantially diminished in value;
e. Has been commingled with other property which cannot be subdivided
without difficulty;
it is the intent of the United States to seek forfeiture of substitute property belonging
to the defendants under the provisions of Title 18, United States Code, Section
1963(m).
A TRUE BILL:
FOREPERSON

UNITED STATES ATTORNEY

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