Case: 1:20-cr-00111 Document #: 1 Filed: 02/19/20 Page 1 of 28 PageID #:1

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
UNITED STATES OF AMERICA

)
)

)
)

vs.

VINCENT DELGIUDICE,
also known as "IJncIe Mick,"
MATTHEW KNIGHT,
also known as "sweaters" and

)
)
)
)

"McDougal,"
JUSTIN HINES,
KEITH D. BENSON,
TODD BIANKEN,
NICHOLAS STELI"A,
MATTHEW NAMOFF,
CASEY URLACHER,
VASILIOS PRASSAS, and
EUGENE DELGIUDICE,
also known as "Gino"

NO.

z&cR 111

Vlolations: Title 18, United
States Code, Sections 371,
rgr5
vooan.rvoo
and 1956

*ff:ffi$h,

NIAGISTRATE

ffiffiffi,ffiffi
FEB

te 2o2o

)

THOMAS G. BRUTON
CLERK, U.S. DISTRICT GOURT

COUI\TT ONE

The SPECIAL JANUARY 2019 GRAND JURY charges:

1.

At times material to this indictment:

a.

Company A, located in Costa Rica, maintained an internet'based

gambling platform through a website. An individual who accepted wagers from
others on the outcome of sporting and other events (a "bookmaker") could, in return
for the payment of a fee to Company A, provide access to Company A's website so that

the bookmaker's customers could use the website to place wagers with

the

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bookmaker. The bookmaker collected and paid out money depending on the outcome
of the bet(s) placed by the bookmaker's customer on the website.

b.

Individuals 1 and 2 were affiliated with Company A.

c.

There were in force and effect criminal statutes in the State of

Illinois that prohibited gambling, including Chapter 720 Illinois Compiled Statutes,
Sections 5/28-1(d(z),

2.

(d(r), (d(tr) and

(a)(12), and 5/2s'1.1(b) and

(0.

Beginning no later than in or around 2016, and continuing until in or

around 2019, at Chicago, Lemont, Frankfort, Orland Park, and Woodridge, in the
Northern District of Illinois, Eastern Division, and elsewhere,
VINCENT DELGIUDICE,
also known as "LJncle Mick,"
MATTHEW KNIGHT,
also known as "Sweaters" and"McDougal,"
JUSTIN HINES,
KEITH D. BENSON
TODD BI,ANKEN,
NICHOIAS STELI,A,
MATTHEW NAMOFF,
CASEY URLACHER,
VASILIOS PRASSAS, and
EUGENE DELGIUDICE,
also known as "Gino,"
defendants herein, together with Individuals 1 and 2 and others known and unknown
to the Grand Jury, conspired to commit an offense against the United States, that is,

to knowingly conduct, finance, manage, supervise, direct and own all or part of an
illegal gambling business, in violation of Tit1e 18, United States Code, Section 1955.

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3.

It was part of the conspiracy that the defendants, together with others,

agreed to knowingly conduct, finance, manage, supervise, direct and own all or part

of an illegat gambling business, that is, a business involving sports bookmaking, in

violation of the laws of the State of Illinois, including,T20Illinois Compiled Statutes,
Sections blzl-Lb)(z),
business was

(d(s), (a)(rr), and (a)(12), and 5/2s'1.1(b)

in substantially continuous operation for a period in

and (0; wtrictr
excess of

thirty

days, and which involved fi.ve or more persons who conducted, financed, managed,
supervised, directed and owned all or part of the business.

4.

It was further part of the conspiracy that

defendant \TNCENT

DELGIUDICE, also known as "IJncIe Mick", conducted, managed, supervised, and
directed. a multi'mitlion dollar illegal gambling business based in the greater Chicago

area which accepted wagers from as many as approximately 1,000 gamblers on the
outcome of sporting events including major league baseball, college and professional

basketball, professional and college football and other professional and amateur
sporting events.

5.
Company

It was further part

of the conspiracy

that VINCENT DELGIUDICE paid

A more than $10,000 a month for a website, www.unclemicksports.com,

which was used to manage the accounting, betting, record keeping and logistics of the

illegal gambling business. Gamblers used this website to view odds, place wagers on
sporting events, and see winnings and losses.

3

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6.

It

was further part of the conspiracy that VINCENT DELGIUDICE

recruited gamblers for the illegal gambling business, provided gamblers with
gambling accounts on www.unclemicksports.com, and unique log-ins and passwords

to this website, and regularly

communicated

with the gamblers. VINCENT

DELGIUDICE collected and paid out money in cash to the gamblers whom he had
recruited.

7.

It

was further part of the conspiracy that VINCENT DELGIUDICE

recruited. MATTHEW KNIGHT, also known as "sweaters" and "McDougal," CASEY

URLACHER, JUSTIN HINES, KEITH D. BENSON, TODD BLANKEN, NICHOLAS
STELLA, MATTHEW NAMOFF, and VASILIOS PRASSAS (collectively, the "agentdefendants") and others to work as agents for the illegal gambling business. The
agent'defendants and other agents recruited sub-agents and additional gamblers for
the illegal gambling business and supervised and regularly communicated with the
sub-agents and gamblers whom they recruited.

8.

It was further part

of the conspiracy that VINCENT DELGIUDICE paid

the agent'defendants, other agents, and the sub-agents a commission based upon a
percentage of their recruited gamblers' gambling losses.

9.

It was further part

of the conspiracy

that VINCENT DELGIUDICE used

a cellphone to access the www.unclemicksports.com website and monitor betting by
gamblers, the agent-defendants, and others.

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10. It was further part of the conspiracy that VINCENT

DELGIUDICE

regularly communicated, using coded language and otherwise, with the agent'
defendants, other agents and the sub-agents, in person and in conversations and text
messages over cellphones concerning the placing of wagers, the collection and paying

out of money in cash to the gamblers, and other matters concerning the operation of
the illegal gambling business.

11. It was further part of the conspiracy that typically,

on a weekly basis,

individuals affiliated with Company A, including Individuals 1 and 2, communicated

information to VINCENT DELGIUDICE about how the gamblers and agents had
performed, i.e., whether they had won or lost money on that week's wagers. This

information was sometimes communicated by an anonymous, end'to'end encrypted,
secure communication telephone application called "Threema," to ensure that the

communications remained

secret. Based upon this information,

VINCENT

DELGIUDICE, the agent-defendants, other agents, and sub-agents arranged,
depending on the outcome of the placed wagers, to collect payment for Iosses from
gamblers, and to pay gamblers for winning bets.

12. It was further a part of the conspiracy that VINCENT DELGIUDICE,
the agent'defendants, other agents, and the sub'agents regularly met with the
gamblers whom they had recruited to collect money in cash the gamblers had lost on
wagers, or pay out money in cash on wagers which the gamblers had won. The co'

conspirators and

the gamblers referred to this as "settling up."

EUGENE

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DELGIUDICE, also known as "Gino," assisted in the collection and paying out of
money in cash to gamblers whom had been recruited by VINCENT DELGIUDICE.

TODD BLANKEN assisted in the collection and paying out of money in cash to
gamblers recruited by JUSTIN HINES, MATTHEW KNIGHT and VINCENT
DELGIUDICE.

13. It was further part of the conspiracy

that the agent'defendants, other

agents and the sub'agents delivered and caused the cash which they collected from

the gamblers to be delivered to VINCENT DELGIUDICE.

14. It was further part of the conspiracy that \{INCENT

DELGIUDICE

directed EUGENE DELGIUDICE to meet gamblers and collect money owed by
gamblers for losses or pay money to the gamblers for their winnings. EUGENE

DELGIUDICE delivered the money he collected to VINCENT DELGIUDICE or left

it at DELGIUDICE's residence.

15. It was further part of the conspiracy that VINCENT
accepted payments

DELGIUDICE

from the agent'defendants, other agents, sub-agents

and

gamblersi maintained gambling recordsi and stored cash, gold bars, and other
proceeds of the illegal gambling business at his residence in Orland Park, Illinois.

16. It was further part of the conspiracy that, in order to conceal the money
which he made from the illegal gambling business, VINCENT DELGIUDICE:

a.

purchased money ord.ers with cash, and used. the money orders to

pay his personal expensesi

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b.

directed gamblers and agents who owed him money from

gambling losses to pay his personal expenses and the expenses of his family such as
his childrens'college tuition, and other such expensesi

c.

directed gamblers and agents who owed him money from

gambling losses to purchase cashier's checks made payable to companies which
VINCENT DELGIUDICE owned and/or controlledi and

d.

directed gamblers and agents who owed him money from

gambling losses to purchase cashier's checks made payable to companies which were
controlled or managed by Company A.

L7.

It was further part of the conspiracy that VINCENT DELGIUDICE used

Federal Express to deliver cashier's checks purchased by gamblers and agents who
owed him money from gambling losses to Company A

in Costa Rica to cover the

fees

associated with the operation of the www.unclemicksports.com website.

18. It

was further a part of the conspiracy that the defendants did

misrepresent, conceal, and hide, and cause to be misrepresented, concealed and
hidden the purposes of and the acts done in furtherance of the conspiracy.

Overt Acts

19.

In furtherance of the conspiracy and to effect its objects, the defendants,

together with Individuals 1 and 2 and others, committed and caused to be committed

the following overt acts, among others, in the Northern District of Illinois, Eastern
Division, and elsewhere:

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a.

On or about October 24, 2016, VINCENT DELGIUDICE sent a

text message to Gambler A stating, "66,789- Plse confirm and 10 this week if
possible."

b.

On or about November 22, 2016, at Chicago, VINCENT

DELGIUDICE met with Gambler A and collected a payment of $10,000 representing
gambling losses owed by Gambler A to VINCENT DELGIUDICE.

c.

On or about September 12,2018, MATTHEW KNIGHT met

a

gambler in Frankfort, Illinois and collected $500 in gambling losses from the gambler.

d.

On or about October 10, 2018, VINCENT DELGIUDICE sent two

cashier's checks totaling approximately $21,700 by Federal Express from Orland

Park, Illinois to pay the fees of Company A for operating and maintaining the
gambling website.

e.
message

On or about October 27, IOIS,MATTHEW KNIGHT sent a text

to Gambler A, which read, "Morning Bronco, going through figs, can you

please teII Bronco 33 to pay or play, hasn't played since February, down 938."

f.

On or about October 29, 20t8, VINCENT DELGIUDICE and

MATTHEW KNIGHT discussed amounts owed to and by certain gamblers.

g.

On or about November 19, 2018, MATTHEW KNIGHT sent a

message to a gambler, "Owe u2254,

h.

will drop."

On or about December 11, 2018, TODD BLANKEN
8

and

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VINCENT DELGIUDICE talked by telephone and discussed money owed by
gamblers, and meeting gamblers to collect money for gambling losses.

i.

On or about December 12, 20L8, EUGENE DELGIUDICE met

Gambler B in Woodridge, Illinois and collected money constituting gambling losses
owed by Gambler B to VINCENT DELGIUDICE.

j.

On or about December 14, 2018, JUSTIN HINES spoke with

VINCENT DELGIUDICE by phone and said that he had ten "guys" who lose $15,000
a year.

k.

On or about December 16, 2018, CASEY URLACHER asked

VINCENT DELGIUDICE to create an online log'in and password for a new gambler
on VINCENT DELGIUDICE's gambling website.

l.
Company

On or about December 16, 2018, VINCENT DELGIUDICE called

A and asked for a log-in and password for a new gambler for CASEY

URLACHER with a $500 maximum bet, a maximum wager for the week of $3,000
and a $1,000 settle up figure.

m.

On or about December 17, 2018, MATTHEW NAMOFF called

VINCENT DELGIUDICE to discuss problems with VINCENT DELGIUDICE's
gambling website.

n.

On or about December 17, 2018, agent TODD BLANKEN and

VINCENT DELGIUDICE talked by phone and discussed meeting gamblers to collect
money owed for gambling losses.

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o.

On or about December 19, 2018, VINCENT DELGIUDICE and

NICHOLAS STELLA exchanged text messages concerning NICHOLAS STELLA's
gamblers and STELLA stated, "Between my two big losers

in Minnesota,

they've

dumped 73k."

p.

On or about December 20, 2019, EUGENE DELGIUDICE met

Gambler B in Woodridge, Illinois and collected money constituting gambling losses
owed by Gambler B to VINCENT DELGIUDICE.

q.

On or about December 21, 2018, in Oak Brook, Illinois, CASEY

URLACHER gave VASILIOS PRASSAS an envelope containing gambling debts owed
to VINCENT DELGIUDICE.

r.

On or about December 21,20t8, in Oak Brook, Illinois, VASILIOS

PRASSAS gave an envelope containing gambling debts owed by CASEY URLACHER

to VINCENT DELGIUDICE, stating, "This is Casey's."

s.

On or about December 26, 2018, CASEY URLACHER spoke by

phone with VINCENT DELGIUDICE and asked VINCENT DELGIUDICE to shut
down Gambler C's account until Gambler C paid a gambling debt.

t.

On or about December 26, 20L8, VINCENT DELGIUDICE

contacted Company A and asked Individual2 to shut down Gambler C's account.

u.

On or about December 26, 20L8, after Gambler C wired CASEY

URLACHER $3,000, CASEY URLACHER texted DELGIUDICE and directed
VINCENT DELGIUDICE to turn Gambler C's account back on.
10

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v.

On or about December 27, 2018, JUSTIN HINES told a gambler

by text message that he was "down 1450."

w.

On or about December 28, 2018, NICHOLAS STELLA spoke by

phone with WNCENT DELGIUDICE and complained that Company A had taken a
game down.

x.

On or about January 6, 2019, VINCENT DELGIUDICE told

TODD BLANKEN by phone that he had 1,006 "customers" and had won $100,000, or
about $100 per player.

y.

On or about January 10, 2019, KEITH BENSON purchased a

cashier's check made payable,

at VINCENT DELGIUDICE's instruction, to

a

company that was controlled and managed by Company A.

z.

On or about January

1-1^,

2019, TODD BLANKEN sent multiple

text messages to a gambler and set up a meeting to collect a $1,500 payment on the
gambling debt the gambler owed.

aa. On January 15, 20L9, KEITH BENSON and VINCENT
DELGIUDICE discussed gambling limits for a gambler and BENSON stated that he
was able to log into the gambling website as an administrator.

bb. On or about January 19, 20T9, MATTHEW

NAMOFF and

VINCENT DELGIUDICE discussed collecting money from a gambler and \TINCENT
DELGIUDICE told MATTHEW NAMOFF to state that he is "with Mr. Delgiudice."

cc.

On or about January
11

2t,

2019, VASILIOS PRASSAS texted

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VINCENT DELGIUDICE and told him he was tryingto "collect" and would meet with
VINCENT DELGIUDICE later.

dd. On or about January 21, 2019, KEITH BENSON asked
VINCENT DELGIUDICE to help him place a bet for a gambler who wanted to wager
$5,000 on a sporting event.

ee.
message

On or about January 22, 20t9, NICHOLAS STELLA sent a text

to VINCENT DELGIUDICE asking DELGIUDICE to send a

message

directing gamblers to "settle up" afber the Super Bowl.

ff.

On or about January 28, 2019, VINCENT DELGIUDICE

prepared a note listing the amount of money due from JUSTIN HINES' gamblers for
the previous week's betting, and texted it to JUSTIN HINES.

gg. On or about January 28, 2019, VINCENT DELGIUDICE
prepared a note listing the amount of money due from NICHOIAS STELI"A'S
gamblers for the previous week's betting, and texted

hh.

.

it to NICHOIAS STELLA.

On or about January 28, 2019, MATTHEW NAMOFF called

VINCENT DELGIUDICE and discussed a new gambler who wanted to wager large
bets

with NAMOFF.

ii.

On or about February 1, 20L9, CASEY URLACHER met

VINCENT DELGIUDICE in Lemont, Illinois, and paid him money owed for gambling
losses.

jj.

On or about February 7, 20L9, WNCENT DELGIUDICE told

t2

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EUGENE DELGIUDICE by telephone the amounts owed by his gamblers.

kk.

On or about February 7, 2019, KEITH BENSON and VINCENT

DELGIUDICE discussed by phone wagers that had been placed on the Super Bowl.

II.

On or about February 7, 2019, EUGENE DELGIUDICE asked

VINCENT DELGIUDICE if he wanted EUGENE DELGIUDICE to stack and count
the money he collected from DELGIUDICE's gamblers.

All in violation of Title

18, United States Code, Section 371.

13

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COUNT TWO
The SPECIAL JANUARY 2019 GRAND JURY further charges:

Beginning no later than in or around 20L6, and continuing until in or around
2019, at Chicago, Lemont, Frankfort, and Orland Park, in the Northern District of

Illinois, Eastern Division, and elsewhere,
VINCENT DELGIUDICE,
also known as "Uncle Mick,"

MATTHEW KNIGHT,
also known as "Sweaters" and "McDougal,"
JUSTIN HINES,
KEITH D. BENSON
TODD BLANKEN,
NICHOLAS STELIA,
MATTHEW NAMOFF,
CASEY URI,ACHER,
VASILIOS PRASSAS, and
EUGENE DELGIUDICE,
also known as "Gino,"
defendants herein, together with others known and unknown to the Grand Jury, did

knowingly conduct, finance, manage, supervise, direct and own all or part of an illegal
gambling business, that is, a business involving sports bookmaking, which business
was in substantially continuous operation for a period in excess of

thirty

days, which

involved five or more persons who conducted, financed, managed, supervised,
directed and owned aII or part of the business, and which was

in violation of the

following laws of the State of Illinois:720Illinois Compiled Statutes, Sections
r(a)(z), (a)(s), (a)(rr), and (a)(12), and 5/2s-1.1(b) and (d);

In violation of Title 18, United States Code, Sections 1955 and

t4

2.

5128-

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COUI{T THREE
The SPECIAL JANUARY 2019 GRA,ND JURY further charges:

1.

Paragraph One of this indictment is incorporated here.

2.

Beginning no later than in or around March 2018 and continuing until

on or about March 18, 2019, at Orland Park in the Northern District of Illinois,
Eastern Division, and elsewhere,

VINCENT DELGIUDICE,
also known as "Uncle Mick,"
defendant herein, did conspire with Individuals 1 and 2 and with others known and

unknown to the Grand Jury, to knowingly transport, transmit, and transfer, and
cause to be transported, transmitted, and transferred, monetary instruments and

funds from a place in the United States to and through a place outside the United
States, with the intent to promote the carfying on of specified unlawful activity,
namely, the operation of an illegal gambling business, in violation of Title 18, United

States Code, Section 1955, in violation of Title 18, United States Code, Section
rgs6(a)(2)(A).

IIIegal Gambling Business

3.

It was part of the conspiracy that VINCENT DELGIUDICE

conducted,

managed, supervised, and directed an illegal gambling business based in the greater
Chicago area which accepted wagers on the outcome of sporting events including

major league baseball, college and professional basketball, professional and college
football and other professional and amateur sporting events.
15

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4.
Company

It was further part of the conspiracy that VINCENT DELGIUDICE paid

A more than $10,000 a month for a website, www.unclemicksports.com,

maintained

in

Costa Rica, which was used to manage the accounting, betting,

recordkeeping and logistics of the illegal gambling business. Gamblers used this
website to view odds, place wagers on sporting events, and see winnings and losses.

5.

It

was further part of the conspiracy that VINCENT DELGIUDICE

recruited gamblers for the illegal gambling business, provided gamblers with
gambling accounts on www.unclemicksports.com, and unique log-ins and passwords

to this website, and regularly

communicated

with the gamblers. VINCENT

DELGIUDICE collected and paid out money in cash to the gamblers whom he had
recruited.

6.

It

was further part of the conspiracy that VINCENT DELGIUDICE

recruited more than five individuals to work as agents for the illegal gambling
business. The agents recruited additional gamblers for the illegal gambling business
and supervised the gamblers whom they recruited. The agents provided the gamblers

with gambling accounts on www.unclemicksports.comi monitored and tracked their
betting on the websitei and collected and paid out money in cash to the gamblers
whom they had recruited. VINCENT DELGIUDICE paid the agents a commission
based upon a percentage of their recruited gamblers' gambling losses.

7.

It was further part of the conspiracy that VINCENT DELGIUDICE used

a cellphone to access the www.unclemicksports.com website and monitor betting by

16

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gamblers, the agent, and others.

8.

It

was further part of the conspiracy that workers at Company A,

including Individuals

1 and 2,

communicated information

to

VINCENT

DELGIUDICE about how the gamblers and agents had done, r.e., whether they had

won or lost money on that week's betting. This information was sometimes
communicated

by an

anonymous, end'to'end encrypted, secure communication

telephone application called "Threema" to ensure that the communications remained

secret. Based upon this information, VINCENT DELGIUDICE and the

agents

arranged to collect payment for losses from gamblers, and to pay gamblers for
winning bets.

9.

It was further a part

of the conspiracy that VINCENT DELGIUDICE

and the agents collect money in cash which the gamblers had lost on wagers, and paid

out money in cash on wagers which the gamblers had won.

Delivery of Gambling Proceeds to Costa Rica

10.

It was further part of the conspiracy that Individuals

1 and

2, and others

who worked for or were associated with Company A, instructed VINCENT
DELGIUDICE to obtain certified checks in the names of various entities and to send

the cashier's checks via Federal Express to a specified address in Costa Rica in
payment for the fees associated with the operation of the www.unclemicksports.com
website used by the illegal gambling business.

11.

It was further part of the conspiracy that Individuals
t7

1 and

2, andothers

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who worked for or were associated with Company A:

a.

supplied VINCENT DELGIUDICE with the names of the entities

to whom the certified checks were to be made payable toi

b.

supplied VINCENT DELGIUDICE with addresses in Costa Rica

where the Federal Express packages containing cashier's checks were to be senti

c.

directed VINCENT DELGIUDICE to place the cashier's checks

inside an envelope, then insid.e a larger manila envelope, then insid e a mag:azrne and
then inside a Federal Express envelope, in order to conceal the checks before express

mailing themi and

d.

directed VINCENT DELGIUDICE to state,

if

asked, that the

Federal Express packages contained "documents."

72. It was further part of the conspiracy that VINCENT DELGIUDICE
directed gamblers and agents who lost wagers and owed money to the illegal
gambling operation to pay their debts by purchasing cashier's checks and money
orders made payable to entities identified by Individuals 1 and 2, and others who
worked for or were associated with Company A.

13.

It was further part of the conspiracy that VINCENT DELGIUDICE used

Federal Express to cause the cashier's checks and money orders to be delivered to the
addresses

in Costa Rica supplied by Individuals 1 and 2, and others who worked for

or were associated with Company A.

18

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L4. It was further part of the conspiracy that VINCENT

DELGIUDICE

caused a total of at least 12 cashier's checks totaling at least $113,625 to be express-

mailed via Federal Express in Orland Park, Illinois to an address in Costa Rica.

15. It was further a part of the conspiracy

that the defendant and his

co-

conspirators did misrepresent, conceal, and hide, and cause to be misrepresented,
concealed and hidden, the purposes

of and the acts done in furtherance of the

conspiracy.

All in violation of Title

18, United States Code, Sections 1956(h) and 2.

19

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COUNT FOUR
The SPECIAL JANUARY 2019 GRAND JURY further charges:

On or about March 29, 20L8, at Orland Park, in the Northern District of
Illinois, Eastern Division, and elsewhere,
VINCENT DELGIUDICE,
also known as "I]ncle Mick,"
defendant herein, did knowingly transport, transmit, and transfer, cause to be
transported, transmitted, and transferred, and attempt to transport, transmit, and

transfer, monetary instruments and funds from a place in the United States to and
through a place outsid.e the United. States with the intent to promote the carrying on
of specified unlawful activity, namely, the operation of an illegal gambling business,

in violation of Title

18, United States Code, Section 1955, that is VINCENT

DELGIUDICE caused to be mailed from Orland Park, Illinois, by Federal Express
five cashier's checks and money orders in the amounts of $14,000 (Chase Cashier's
Check No. 9210816068), $5,000 (Huntington Check No. 658248), and three $1,000

BB&T Personal Money Orders (Nos. 6000245954, 6000245952, and 6000245955), to
an address in Costa Ricai

In violation of Title 18, United States Code, Sections 1956(d(2)G).

20

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COUNT FI\TE
The SPECIAL JANUARY 2019 GRAND JURY further charges:
On or about May 29, 2018, at Orland Park, in the Northern District of Illinois,

Eastern Division, and elsewhere,

VINCENT DELGIUDICE,
also known as "IJncIe Mick,"
defendant herein, did transport, transmit, and transfer, cause to be transported,

transmitted and transferred, and attempt to transport, transmit and transfer
monetary instruments and funds from a place in the United States to and through a
place outside the United States with the intent to promote the carrying on of specified

unlawful activity, namely, the operation of an illegal gambling business, in violation

of Title 18, United States Code, Section 1955, that is, VINCENT DELGIUDICE
caused to be mailed from Orland Park, Illinois, by Federal Express a cashier's check

in the amount of $12,000 (Chase Cashier's Check No. 1408521531), and a number of
Western Union money orders, including Western Union Money Order 17-754980862,

in the amounts of $500 each, to an address in Costa Ricai
AIt in violation of Title 18, United States Code, Sections fgS6(a)(2)(A).

2t

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COUNT SIX
The SPECIAL JANUARY 2019 GRAND JURY further charges:
On or about July 5,

zlitf.,at Orland Park, in the Northern District of Illinois,

Eastern Division, and elsewhere,

VINCENT DELGIUDICE,
also known as "Uncle Mick,"
defendant herein, did transport, transmit, and transfer, cause to be transported,

transmitted and transferred and attempt to transport, transmit and transfer
monetary instruments and funds from a place in the United States to and through a
place outside the United States with the intent to promote the carrying on of specifi.ed

unlawful activity, namely, the operation of an illegal gambling business, in violation

of Title 18, United States Code, Section 1955, that is, VINCENT DELGIUDICE
caused to be mailed from Orland Park, Illinois, by Federal Express two cashier's
checks in the amounts of $10,000 (US Bank Cashier's Check 4365506379) and $5,000

(Huntington Cashier's Check 20t2476565), to an address in Costa Ricai

Atl in violation of Title 18, United States Code, Sections 1956(a)(2)(A).

22

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COUNT SE\IEN
The SPECIAL JANUARY 2019 GRAND JURY further charges:

On or about October 10, 2018, at Orland Park, in the Northern District of

lllinois, Eastern Division, and elsewhere,
VINCENT DELGIUDICE,
also known as "Uncle Mick,"
defendant herein, did transport, transmit, and transfer, cause to be transported,

transmitted and transferred and attempt to transport, transmit and transfer
monetary instruments and funds from a place in the United States to and through a
place outside the United States with the intent to promote the carrying on of specified

unlawful activity, namely, the operation of an illegal gambling business, in violation

of Title 18, United States Code, Section 1955 that is, VINCENT DELGIUDICE
caused to be mailed from Orland Park, Illinois, by Federal Express two cashier's

checks

in the amounts of $10,000 (Chase Cashier's Check No. 9210816785)

$11,700 (Chase Cashier's Check No. 9439727569), to an address in Costa Ricai

Atl in violation of Title 18, United States Code, Sections fgf0(a)(2xA).

23

and

 Case: 1:20-cr-00111 Document #: 1 Filed: 02/19/20 Page 24 of 28 PageID #:24

COUNT EIGHT
The SPECIAL JANUARY 2019 GRAND JURY further charges:

On or about December L7, 2018, at Orland Park, in the Northern District of

Illinois, Eastern Division, and elsewhere,
VINCENT DELGIUDICE,
also known as "IJncIe Mick,"
defendant herein, did transport, transmit, and transfer, cause to be transported,

transmitted and transferred and. attempt to transport, transmit and transfer
monetary instruments and funds from a place in the United States to and through a
place outside the United States with the intent to promote the carrying on of specified

unlawful activity, namely, the operation of an illegal gambling business, in violation

of Title 18, United States Code, Section 1955, that is, VINCENT DELGIUDICE
caused to be mailed from Orland Park,' Illinois, by Fed.eral Express two cashier's
checks in the amounts of $10,000 (fCn' Cashier's Check No. 305929064) and $10,500
(Chase Cashier's Check No. 14085 22567),to an address

in Costa Ricai

AII in violation of Title 18, United States Code, Sections fgS6(d(2)(d.

24

 Case: 1:20-cr-00111 Document #: 1 Filed: 02/19/20 Page 25 of 28 PageID #:25

COUNT NINE
The SPECIAL JANUARY 2019 GRAND JURY further charges:

On or about January L4, 2019, at Orland Park, in the Northern District of

Illinois, Eastern Division, and elsewhere,
\TNCENT DELGIUDICE,
also known as "IJncle Mick,"
defendant herein, did transport, transmit, and transfer, cause to be transported,

transmitted and transferred and attempt to transport, transmit and transfer
monetary instruments and funds from a place in the United States to and through a
place outside the United States with the intent to promote the carrying on of specified

unlawful activity, namely, the operation of an illegal gambling business, in violation

of Tit1e 18, United States Code, Section 1955, that is, VINCENT DELGIUDICE
caused to be mailed from Orland Park, Illinois, by Federal Express three cashier's
checks

in the amounts of $10,200 (Chase Cashier's Check No. 9470334046), $8,500

(Lemont Bank and Trust Check No. 131067), and $6,725 (Cashier's Check
7t42515696), to an address in Costa Ricai
A1l in violation of

Title 18, United States Code, Sections 1956(d(2)(A).

25

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FORFEITURE ALLEGATION ONE
The Special JANUARY 2019 GRAND JURY alleges:

1.

Upon conviction of an offense in violation of Title 18, United States Code,

Section 1955, as set forth in this indictment, VINCENT DELGIUDICE shall forfeit
to the United States of America any property which constitutes and is derived from
proceeds which were obtained, directly and indirectly, from offenses committed in

violation of Title 18, United States Code, Section 1955, as well as property involved

in and used to facilitate the

offense, as provided

in Title

18, United States Code,

Sections g8f(a)(f)(C) and 1955(0, and Title 28, United States Code, Section 2a61G).

2.

The property to be forfeited includes, but is not limited to:

a.

The following specific property:

i.

$1,060,792

in

cash seized

by law

defendant's residence on or about

April

enforcement from
15, 2019i and

ii.

gold coins valued at $92,623 seized by law enforcement
from defendant's residence on or about April 15, 2019i and

iii.

silver bars and jewelry valued at $347,895 seized by law
enforcement from defendant's residence on or about April
15, 2019i and

iv. A

2077 Lexus GX automobile identified by Vehicle

Identification Number JTJJMTFXSHS

17

37

69.

b.

The following real estate: 15708 Shire Drive, Orland Park,
Illinois, further described as Lot 2 in equestrian place, South,
being a subdivision of part of the Southeast Ya of Section 17,
Township 36 North, Range 12, East of the third principal
meridian in Cook County, Illinois, PIN 27-17-312-021-0000

c.

A personal money judgment in the amount of $8,000,000.

 Case: 1:20-cr-00111 Document #: 1 Filed: 02/19/20 Page 27 of 28 PageID #:27

3.

If any of the property described above, as a result of any act or omrssron

by a defendantl cannot be located upon the exercise of due diligencei has

been

transferred or sold to, or deposited with, a third partyi has been placed beyond the

jurisdiction of the Courti has been substantially diminished in valuei or has been
commingled

with other property which cannot be divided without difficulty, the

United States of America shall be entitled to forfeiture of substitute property,
provided in Title 21, United States Code Section 853(p).

27

as

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FORFEITURE ALLEGATION TWO
The SPECIAL JANUARY 2019 GRAND JURY further alleges:

1.

Upon conviction of an offense in violation ofTitle 18, United States Code,

Section 1956, as set forth in this indictment, VINCENT DELGIUDICE shall forfeit

to the United States of America any property involved in such offense, and any
property traceable to such property, as provided in Title 18, United States Code,
Section 982(a)(1).

2.

The property to be forfeited includes, but is not limited to a personal

money judgment in the amount of at least approximately $113,625.

3.

If any of the property described above, as a result of any act or omission

by defendant: cannot be located upon the exercise of due diligencei has

been

transferred or sold to, or deposited with, a third partyi has been placed beyond the

jurisdiction of the Courti has been substantially diminished in valuei or has been
commingled

with other property which cannot be divided without difficulty,

the

United States of America shall be entitled to forfeiture of substitute property,
provided in Title 21, United States Code, Section S53(p).

A TRUE BILL:

FOREPERSON

UNITED STATES ATTORNEY
28

as