Sample RICO Indictment


http://www.justice.gov/usao/nj/Press/files/pdffiles/2011/Scarfo,%20Nicodemo%20et%20al.%20Indictment.pdf

The Enterprise

2. The criminal organization, including its members and

associates, constituted an

~enterprise” as that term is defined

in Title 18, United States Code, Section 1961(4), that is, a

group of individuals associated in·fact (hereafter the

~ScarfoPelullo

Enterprise” or the

~Enterprise”). The Enterprise

constituted an ongoing organizationwhQse members and associates

functioned as a continuing unit for the common purpose of

achiev~ng

its objectives. The Enterprise, which operated in the

District of New Jersey and elsewhere, was engaged in, and its

 

activities affected, interstate and foreign commerce.

 

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