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Case 2:10-cv-00129-RLH-GWF Document 1 Filed 01/29/10 Page 1 of 17

DANIEL G. BOGDEN
United States Attorney
Nevada State Bar No. 2137
DANIEL D. HOLLINGSWORTH
Assistant United States Attorney
Nevada State Bar No. 1925
Lloyd D. George United States Courthouse
333 Las Vegas Boulevard South, Suite 5000
Las Vegas, Nevada 89101
Telephone: (702) 388-6336
Facsimile: (702) 388-6787
E-mail: [email protected]
Counsel for the United States of America

UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA

UNITED STATES OF AMERICA,

Plaintiff,

v.

$2,700,000.00 IN UNITED STATES
CURRENCY,

Defendant.

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COMPLAINT FOR FORFEITURE IN REM

The United States of America, by and through Daniel G. Bogden, United States Attorney for

the District of Nevada, and Daniel D. Hollingsworth, Assistant United States Attorney, in a civil cause

for forfeiture, respectfully states as follows:

SUBJECT MATTER JURISDICTION

1. This Court has jurisdiction under 19 U.S.C. §§ 1603, 1608, and 1610; Supplemental Rules

for Admiralty or Maritime Claims and Asset Forfeiture Actions (“Fed. R. Civ. P. Supp. Rule”); 18

U.S.C. §§ 981 and 983; 28 U.S.C. §§ 1345, 1355, and 1395; and 31 U.S.C. § 5317(c)(2).

IN REM JURISDICTION

2. This Court will have in rem jurisdiction over the $2,700,000.00 in United States Currency

(“defendant”) if this Court signs an Order for Summons and Warrant of Arrest in Rem for the Property

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Case 2:10-cv-00129-RLH-GWF Document 1 Filed 01/29/10 Page 2 of 17

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and the Clerk of the Court issues a Summons and Warrant of Arrest in Rem for the Property, which

will be executed upon the defendant and returned to the Court.

VENUE

3. This Court has venue of this matter pursuant to 28 U.S.C. §§ 1355 and 1395 because the

above-named defendant is now and, during the pendency of this action, will be in the jurisdiction of

this Court and because the defendant was found in this judicial district.

PARTICULAR DESCRIPTION

4. The defendant is more particularly described as follows: $2,700,000.00 in United States

Currency.

PLACE OF SEIZURE

5. On or about September 16, 2008, defendant was seized by duly authorized agents of the

United States Immigration and Customs Enforcement (“ICE”), Las Vegas, Nevada.

CUSTODY OF ASSET

6. The defendant is in the care, custody, and control of the United States Department of the

Treasury’s Seized Asset Forfeiture Fund.

7. This is filed timely.

TIMELY FILING

VALUE

8. The defendant’s value is $2,700,000.00 in United States Currency.

FACTS

The Jelinsky Organization

9. In or about 2005 to in or about 2007, Michael Jelinsky and Jeffrey Jelinsky (“Jelinskys”)

operated an illegal gambling business involving unlicensed bookmaking in violation of Nevada State

law and federal law. Jeffrey Jelinsky, Michael Jelinsky, Barbara Jelinsky, Leigh Jelinsky, Kristie

Gulia, David Datzkow, Nicholas Masesso, John DeCrosta, aka Jack DeCrosta (“DeCrosta”), John

Astarita (“Astarita”), Kevin Regan, Charles Pecchio, Howard Rubinsky (“Rubinsky”), Knud

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Christiansen (“Christiansen”), and Sanford Goldfarb (“Goldfarb”) were all members of the Jelinsky

Organization. The Jelinsky Organization took wagers by telephone and by internet from individuals

in California, Colorado, Connecticut, Nevada, New Jersey, New York, Florida, and Texas and

illegally used offshore race books, as well as casino race books in or about Las Vegas, Clark County,

Nevada to layoff some of its illegal betting business. The Jelinsky Organization used interstate wire

communications, among other ways, to take illegal bets, to lay off illegal bets, and to launder the

illegal bookmaking proceeds. The Jelinsky Organization accepted wagers over the telephone and the

internet web sites, including www.ssi28.com and www.bookmaker.com. Both internet sites are race

and sports books located in Costa Rica. The Jelinsky Organization used www.ssi28.com to set up on-

line wagering accounts for its clients and www.bookmaker.com to lay off some of its illegal

bookmaking wagers. Jeffrey Jelinsky, Michael Jelinsky, Barbara Jelinsky, Leigh Jelinsky, Kristie

Gulia, David Datzkow, Nicholas Masesso, Decrosta, Astarita, Kevin Regan, Charles Pecchio,

Rubinsky, Christiansen, and Goldfarb were not licensed by the State of Nevada to operate a gambling

business.

10. During the time period mentioned above, Jeffrey Jelinsky took wagers from clients by

telephone and through internet accounts with a race and sports book in Costa Rica. Jeffrey Jelinsky

paid a fee to the Costa Rican race and sports book for providing him with a set of customer accounts.

When Jeffrey Jelinsky acquired a new betting customer who wanted to wager online, he would set up

the person’s account with an identification number and a password that allowed the person to logon

to www.ssi28.com and to place wagers. He also would set limits on the betting customer’s wagering

activity. The Costa Rican race book tracked all of the Jelinsky Organization’s clients’ wagering

activity and maintained win/loss figures for the Jelinsky Organization.

11. During the aforementioned time, Michael Jelinsky assisted the Jelinsky Organization’s

illegal bookmaking operation by providing Jeffrey Jelinsky with handicapping information, financing,

and laundering the illegal bookmaking proceeds. The Jelinsky Organization through Jeffrey Jelinsky

and Michael Jelinsky intentionally gave fraudulent, false, and misleading handicapping information

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to its bettors to insure they would lose their bets to the Jelinsky Organization. Barbara Jelinsky

assisted the Jelinsky Organization’s illegal bookmaking operation with financing and laundering the

illegal bookmaking proceeds. Leigh Jelinsky and Kristie Gulia assisted the Jelinsky Organization’s

illegal bookmaking operation by laundering the illegal bookmaking proceeds. Goldfarb was a client

bettor of the Jelinsky Organization and assisted the Jelinsky Organization’s illegal bookmaking

operation by laundering the illegal bookmaking proceeds. The Jelinsky Organization included

individuals and illegal bookmakers with access to large amounts of cash and casino chips who assisted

the Jelinsky Organization by transferring cash and casino chips between the Jelinsky Organization

and bettors and by collecting and paying illegal bets won and lost.

12. In or about 2005 to in or about 2007, James Scott, Louis J. Tavano, and Richard Tavano

assisted the Jelinsky Organization’s illegal bookmaking operation by establishing bettors’ accounts

with International Racing Group (“IRG”), an offshore race book that claimed to be on the Island of

Curacao, Netherland Antilles, but also was managed and operated in part in Nevada. IRG was a

subsidiary of Youbet.com. IRG provided telephonic race book services by allowing its customers to

call by telephone and place wagers on horse races. Rubinsky assisted the Jelinsky Organization’s

illegal bookmaking operation by establishing an offshore account with www.bookmaker.com, an

offshore race and sports book located in Costa Rica, to layoff some of the betting accepted by the

Jelinsky Organization’s illegal bookmaking operation. By having the betting account at

www.bookmaker.com and laying off bets accepted by the Jelinsky Organization, it reduced the payout

risk associated with booking some of the large wagers.

The Poker Palace Casino, the Palms Casino, and the Jelinsky Organization

13. During various times in or about 2005 to in or about 2007, the Jelinsky Organization

conducted its illegal bookmaking inside the Poker Palace Casino and the Palms Casino, in or about

Las Vegas, Clark County, Nevada and North Las Vegas, Clark County, Nevada. By conducting

business inside these casinos the Jelinsky Organization had up-to-date race and sports book

information and the ability to layoff quickly any wagers the Jelinsky Organization considered too

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risky to keep within its illegal bookmaking. David Datzkow, Nicholas Masesso, Decrosta, Astarita,

Kevin Regan, and Charles Pecchio assisted the Jelinsky Organization’s illegal bookmaking operation

as runners who placed bets with the licensed casino race books on behalf of the Jelinsky Organization

and collected money from winning bets with licensed casino race books and from bettors who bet with

the Jelinsky Organization. The size of the Jelinsky Organization’s illegal bookmaking is shown by

the increase of the Poker Palace Casino race book handle when the Jelinsky Organization operated

there. (The handle is the gross amount of money risked in pari-mutuel wagering. Pari-mutuel

wagering is a system of betting on horse races whereby all wagers go into a pool. The winners divide

the total amount of all bets, after deducting management expenses, in proportion to the sums they have

wagered individually. Pari-mutuel watering provides no risk to the Poker Palace Casino.) In or about

April 2005, before one of the various times the Jelinsky Organization laid off wagers at the Poker

Palace Casino in pari-mutuel wagering, the Poker Palace Casino race book’s monthly handle was

approximately $100,000. By October 2005, after the Jelinsky Organization began using the Poker

Palace Casino to lay off wagers, the Poker Palace Casino race book’s monthly handle had risen to

over $10,000,000. Similarly, in or about November 2005, the monthly pari-mutuel handle at the

Palms Casino race book was approximately $200,000. By July 2006, after the Jelinsky Organization

began operating its illegal bookmaking at the Palms Casino, its monthly handle was approximately

$7,100,000. Between the Poker Palace Casino, the Palms Casino, and the offshore accounts, the

Jelinsky Organization wagered millions of dollars each month.

14. On or about April 4, 2007, the Jelinsky Organization moved part of their operation from

the Palms Casino back to the Poker Palace Casino. The Jelinsky Organization operated its illegal

bookmaking at the Poker Palace Casino by laying off wagers and used the Poker Palace Casino to

generate and to launder some of the proceeds the Jelinsky Organization’s activities generated. The

Poker Palace Casino’s management and the Jelinsky Organization illegally agreed and conspired to

give the Jelinsky Organization approximately an eleven percent (11%) rebate of, or share in the

revenues of, the Jelinsky Organization’s pari-mutuel wagering. The Poker Palace Casino and the

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Jelinsky Organization agreed the Poker Palace Casino would rebate the Jelinsky Organization 11%

if it bet $250,000 a week and would rebate the Jelinsky Organization up to 12% if it bet over $500,000

a week. The Poker Palace Casino held contests that insured members of the Jelinsky Organization

would win the contest receiving the 11% rebate. The contest was an artificial mechanism designed

solely to rebate money to the Jelinsky Organization. The Poker Palace Casino and the Jelinsky

Organization determined the amount of each contest based upon what the Jelinsky Organization

wagered for the week. For example, if the Jelinsky Organization had a handle of $400,000 for the

week, the Poker Palace Casino arranged to have two contests for $22,000 each, thereby rebating to

the Jelinsky Organization $44,000, or 11% of their handle. This arrangement between the Poker

Palace Casino and the Jelinsky Organization allowed the Jelinsky Organization to receive an 11%

no-risk return on their wagering activity. At least three key employees at the Poker Palace Casino

conspired with the Jelinsky Organization to arrange and to facilitate the fixed contest. This rebate

arrangement laundered illegal proceeds by giving the appearance that these monies were derived from

legitimate gambling activity.

15. On June 24, 2007, DeCrosta sent Astarita to give Jeffrey Jelinsky the $5,000.00 entry fee

for the Poker Palace Casino rebate contest and his figures (the amount DeCrosta wagered at the Poker

Palace Casino for the week) so Jeffrey Jelinsky could determine DeCrosta’s rebate. On July 2, 2007,

Jeffrey Jelinsky and Joe Bahel (“Bahel”), the Director of Operations at the Poker Palace Casino,

arranged two rebate contests of $11,300.00 each for the next day and agreed to an 11.5 % rebate for

that week. Bahel also warned the percentage of the handle would go down if the Jelinsky

Organization did not raise its handle. Jeffrey Jelinsky admitted numerous times that the Poker Palace

Casino contests were rigged and were very good for the Jelinsky Organization. Michael Jelinsky

admitted numerous times that the Poker Palace Casino contests were fictitious, allowing rebates to

be paid to the Jelinsky Organization. DeCrosta and Astarita were involved in the Poker Palace Casino

rebating contests for the Jelinsky Organization and themselves. On July 30, 2007, Michael Jelinsky

requested that Bahel change the date of the rebating contest because Michael Jelinsky had problems

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getting enough people to go to the Poker Palace Casino. The Poker Palace Casino required the

Jelinsky Organization to have at least four people at the rebate contest. Bahel agreed to two rebating

contests on another day for $33,600 each. The Jelinsky Organization won all the rebating contests

because the Poker Palace Casino and the Jelinsky Organization had the rebating contests fixed to

insure the Jelinsky Organization won.

16. Effective June 30, 2007, Nevada Gaming Regulation 6A, which provided Nevada casinos

with an exemption from the Bank Secrecy Act (“BSA”) requirements, expired. Starting July 1, 2007,

Nevada casinos were required to comply with all BSA regulations, which include filing Currency

Transaction Reports (“CTR”) for any cash transaction over $10,000.00. As a result of the CTR

regulations, DeCrosta was concerned he could no longer wager over $10,000.00 a day. To avoid the

CTR reporting requirements, DeCrosta wanted to limit his wagering to $8,000.00 a day. DeCrosta

operated his own illegal bookmaking and messenger betting business and used the rebate contest at

the Poker Palace Casino to lay off some of his action and collect the rebate. On June 30, 2007, to

avoid the CTR reporting requirements, DeCrosta discussed an arrangement that Astarita would bet

all of Johnny’s money at the Poker Palace Casino. Johnny is one of DeCrosta’s clients in his illegal

gambling business. DeCrosta decided to keep wagering for his client, Paul, because Paul did not bet

over the $10,000.00 per day at the Poker Palace Casino. DeCrosta’s actions were to avoid the CTR

reporting requirements for any cash transaction over $10,000.00. DeCrosta structured his illegal

activities at the Poker Palace Casino, which violates federal law and state law. On or about June 30,

2007, the Poker Palace Casino management agreed to work with DeCrosta to avoid the CTR reporting

requirements. On or about June 30, 2007, the Poker Palace Casino Race and Sports Book manager,

William Reynolds, arranged for DeCrosta to bet under two separate players’ numbers to structure his

illegal bookmaking wagers, allowing DeCrosta to avoid the CTR reporting requirements. On July 9,

2007, DeCrosta had wagered for his illegal gambling clients a total of $90,122.00 under three separate

players’ numbers, provided by the Poker Palace Casino, so that he avoided the CTR reporting

. . .

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requirements. On or about July 9, 2007, DeCrosta also bet $8,200.00 at the Poker Palace Casino for

Michael Jelinsky under player number 72 and gave Michael the rebate for this wager.

17. Joseph Kreyer (“Kreyer”) worked for the Poker Palace Casino in the late 1990s as a

ticket writer in the Race and Sports Book. At that time, the Poker Palace Casino ran a handicapping

contest designed to offer rebates to high volume players. Kreyer left Las Vegas to work at the

Tonkowa Indian reservation. Kreyer returned to Las Vegas in 2005, approached Brad Fetuish

(“Fetuish”), General Manager of the Poker Palace Casino, and requested that Fetuish start running

the rebating contests again. Kreyer negotiated the contest with Fetuish, and during the negotiations,

Kreyer asked Fetuish if he wanted 17% on $10,000 or 4.5% on a couple million dollars. Kreyer

recruited the Jelinsky Organization to play at the Poker Palace Casino. Kreyer negotiated the rebate

with each player. Kreyer negotiated the day and time of each contest with Bahel. The contest rules

required four contestants. Kreyer paid other individuals to enter the contest. Kreyer put up the

entrance fee of $2,500 and paid each person $50 for entering. The entrance fee was set very high so

that no players except the associates of the Jelinsky Organization would enter. Michael Jelinsky’s

handle was put under Kreyer’s player number 61. Fetuish and Bahel knew Michael Jelinsky’s handle

was under player number 61.

18. Between April 2005 and September 2007, the increase in revenues generated by the

Poker Palace Casino as a result of the illegal rebating contest was approximately $7,900,000.00.

John DeCrosta and the Jelinsky Organization

19. Between 2005 and 2007, John DeCrosta illegally placed horse race bets for the Jelinsky

Organization, assisting the Jelinsky Organization in their illegal bookmaking and illegal gambling

business. DeCrosta operated his own illegal messenger betting operation, including placing horse race

bets. DeCrosta placed interstate telephone calls in the State of Nevada and outside the State of

Nevada, providing information on available wagers, placing horse race bets, and discussing balances

owed or paid on the bets. He placed bets for players, including Michael Jelinsky, Paul Mattise, and

John Egidio, among others, who used him as their agent. DeCrosta participated and received rebates

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of money from pari-mutuel bets in the illegal rebating conspiracy with the Jelinsky Organization and

the Poker Palace Casino. DeCrosta conspired with the Jelinsky Organization and the Poker Palace

Casino to structure money, and did structure money, to avoid the banking reporting requirements.

Howard Rubinsky, Knud Christiansen, and the Jelinsky Organization

20. Between 2005 and 2007, Rubinsky engaged in the business of betting and wagering,

using wire communications to transmit in interstate and foreign commerce bets, wagers, and

information to assist the placing of bets and wagers on sporting events, contests, and horse racing.

Rubinsky assisted the Jelinsky Organization in its illegal bookmaking and illegal gambling business.

Christiansen participated in the illegal bookmaking business in Nevada. Christiansen moved money

between Rubinsky and the Jelinsky Organization. Rubinsky established illegal wagering accounts

for the Jelinsky Organization with www.bookmasker.com in Costa Rica. Rubinsky assisted the

Jelinsky Organization by moving money between the Jelinsky Organization and its wagering clients

and associates. Rubinsky lived in Florida and used the interstate telephone calls to communicate with

the Jelinsky Organization.

21. Between 2005 and 2007, Rubinsky participated in numerous financial transactions to

launder the proceeds of the illegal bookmaking operation of the Jelinsky Organization. On July 6,

2007, Jeffrey Jelinsky met with Goldfarb and collected $50,000 in Wynn Casino gaming chips for

payment on an illegal gambling debt. On July 10, 2007, Jeffrey Jelinsky left Rubinsky a message,

stating he had $50,000 for him in Wynn gaming chips. On July 10, 2007, while Rubinsky was in

Florida and Jeffrey Jelinsky was in Nevada, they discussed that the Jelinsky Organization owed

Rubinsky $50,000. On July 11, 2007, Jeffrey Jelinsky met with Christiansen and gave him the

$50,000 in Wynn Casino gaming chips for Rubinsky. On July 24, 2007, Jeffrey Jelinsky arranged to

have Goldfarb wire $100,000 to HSBC Bank account in the name of Laurence Feingold Attorney

Trust Account, pursuant to the instructions of Rubinsky. These monies were then wired, in two

separate transactions, from the HSBC account to Rubinsky and an associate of Rubinsky in Las

Vegas. On August 22, 2007, Jeffrey Jelinsky and Rubinsky engaged in a telephone call between

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Nevada and Florida, during which Rubinsky instructed Jeffrey Jelinsky to have Goldfarb wire $65,000

into an escrow account at City National Bank, held in a third party name. These monies were

subsequently wired to the escrow account and then a check from the third party was deposited into

an account held by Rubinsky. All of these monies represent the money laundered proceeds of illegal

bookmaking and illegal gambling.

Sandy Goldfarb and the Jelinsky Organization

22. Between 2005 and 2007, Goldfarb made numerous telephone calls to the Jelinsky

Organization. In the majority of these calls, Goldfarb placed wagers with Jeffrey Jelinsky, discussed

wagering activity, or discussed account balances. When Jeffrey Jelinsky received Goldfarb’s wagers,

Jeffrey Jelinsky either booked the wagers himself or made telephone calls to www.bookmaker.com

race book to layoff Goldfarb’s wagers. Jeffrey Jelinsky had Goldfarb launder some of the illegal

gambling proceeds by wire transferring money to bank accounts provided by Rubinsky. Then

Rubinsky had an associate deliver the money to the Jelinsky Organization in Las Vegas. The Jelinsky

Organization used the money to pay other clients and to promote the illegal bookmaking and illegal

gambling activities. Goldfarb assisted the Jelinsky Organization in laundering the proceeds of its

illegal bookmaking operation by facilitating the movement of money between the Jelinsky

Organization, its clients, and its associates. The Jelinsky Organization compensated Goldfarb usually

in the form of a reduction in his gambling debt for his assistance in laundering the illegal proceeds.

23. On June 20, 2007, Goldfarb wire transferred $30,000 to Blackthorn Estate Buyers, a

company owned by Craig Bagon, to pay a gambling debt owed by the Jelinsky Organization. On July

6, 2007, Goldfarb obtained $50,000 in Wynn gambling chips and gave them to Jeffrey Jelinsky. The

Jelinsky Organization paid its gambling debt to Rubinsky with the $50,000 in Wynn gambling chips.

On July 25, 2007, Goldfarb wired transferred $100,000 to HSBC Bank with part of that money being

laundered through additional accounts until Rubinsky received some of the money. The Jelinsky

Organization paid its gambling debt to Rubinsky through Goldfarb. On August 23, 2007, Goldfarb

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wire transferred $60,000 to an Escrow Account to pay a gambling debt owed to Rubinsky by the

Jelinsky Organization.

John Astarita and the Jelinsky Organization

24. Between 2005 and 2007, Astarita was a member of the Jelinsky Organization and ran his

own illegal bookmaking business and messenger betting service. Astarita was also a regular

participant in the Poker Palace Casino contest. Astarita wagered large amounts of money at the Poker

Palace Casino and received a rebate by means of the fictitious contest. Astarita was a messenger

bettor for the Jelinsky Organization and John Egidio. Astarita placed illegal wagers through

bookmakers located outside the State of Nevada and laid off wagers through offshore casinos,

including www.bookmaker.com. Astarita made numerous calls to Costa Rica to place illegal bets

with www.bookmaker.com. He also placed illegal bets with Euro Off-track in the British Isles.

Astarita had weekly summaries of his clients account balances, with daily logs of each client’s

detailed wagering information and activities for each day. Astarita has no other source of income

except his illegal bookmaking business and messenger betting service.

25. On June 24, 2007, DeCrosta sent Astarita to give Jeffrey Jelinsky the $5,000.00 entry fee

for the Poker Palace Casino rebate contest and his figures (the amount DeCrosta wagered at the Poker

Palace Casino for the week) so Jeffrey Jelinsky could determine DeCrosta’s rebate. On June 25,

2007, Astarita provided $10,000 to the Jelinsky Organizatin through Jeffrey Jelinsky for the Poker

Palace Casino contest. On July 14 and 16, 2007, Astarita admitted operating his own illegal gambling

business and not wagering his own money. On July 18, 2007, the Jelinsky Organization delivered

money to Astarita from the Poker Palace Casino contest, and Astarita paid Robert Black $110,000 for

an illegal gambling debt.

26. In August 2007, the Poker Palace Casino conducted ten rigged rebate contests. A total

of $385,800.00 was paid out to the Jelinsky Organization. All contest payments were made in cash.

In September 2007, the Poker Palace Casino conducted seven rigged rebate contests. A total of

$214,300.00 was paid out to the Jelinsky Organization. All contest payments were made in cash. For

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the months of August and September 2007, Astarita’s total pari-mutuel handle at the Poker Palace

Casino was at least $731,465.20. Astarita received at least $73,146 in cash payments from the Poker

Palace Casino contest over this period. Astarita averaged approximately 12% of the total contest

payout at Poker Palace Casino. The total cash payouts from the contest at the Poker Palace Casino,

between April 2007 and July 2007, were $1,185,200. Astarita collected approximately $142,000 in

contest payouts between April 2007 and July 2007, for a total of $215,146 in cash payments from the

contest between April 2007 and September 2007. Astarita stored his illegal bookmaking and

messenger runner service at the Rampart Casino safe deposit box number 77. Astarita accessed the

box on a weekly basis, sometimes more than once a day. All of Astarita’s seized money represents

proceeds from his illegal gambling activities. Astarita did not have any other source of legitimate

income over this period of time. Astarita was involved in operating an illegal gambling business, to

include messenger betting, illegal bookmaking, and illegal wagering with offshore and out of state

bookmakers. Astarita was also involved in money laundering and structuring.

FIRST CAUSE OF ACTION

27. The United States realleges, readopts, and reincorporates all the allegations contained

in paragraphs 1 through 26 fully set forth herein.

28. The defendant is involved in a transaction or attempted transaction in violation of 18

U.S.C. § 1956(a)(1), or is property traceable to such property, and is subject to forfeiture pursuant to

18 U.S.C. § 981(a)(1)(A).

SECOND CAUSE OF ACTION

29. The United States realleges, readopts, and reincorporates all the allegations contained

in paragraphs 1 through 26 as though fully set forth herein.

30. The defendant is involved in a transaction or attempted transaction in violation of 18

U.S.C. § 1956(a)(2), or is property traceable to such property, and is subject to forfeiture pursuant to

18 U.S.C. § 981(a)(1)(A).

. . .

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THIRD CAUSE OF ACTION

31. The United States realleges, readopts, and reincorporates all the allegations contained

in paragraphs 1 through 26 as though fully set forth herein.

32. The defendant is involved in a transaction or attempted transaction in violation of 18

U.S.C. § 1957, or is property traceable to such property, and is subject to forfeiture pursuant to 18

U.S.C. § 981(a)(1)(A).

FOURTH CAUSE OF ACTION

33. The United States realleges, readopts, and reincorporates all the allegations contained

in paragraphs 1 through 26 as though fully set forth herein.

34. The defendant constitutes, or is derived from, proceeds traceable to violations of 18

U.S.C. § 1084 and Nev. Rev. Stat. §§ 199.480, 463.160, 463.430, 464.010, 465.092, and 465.093, a

specified unlawful activity as defined in 18 U.S.C. §§ 1956(c)(7)(A) and 1961(1)(B), or a conspiracy

to commit such offense, and is subject to forfeiture pursuant to 18 U.S.C. § 981(a)(1)(C).

FIFTH CAUSE OF ACTION

35. The United States realleges, readopts, and reincorporates all the allegations contained

in paragraphs 1 through 26 as though fully set forth herein.

36. The defendant constitutes, or is derived from, proceeds traceable to violations of 18

U.S.C. § 1341, a specified unlawful activity as defined in 18 U.S.C. §§ 1956(c)(7)(A) and 1961(1)(B),

or a conspiracy to commit such offense, and is subject to forfeiture pursuant to 18 U.S.C. §

981(a)(1)(C).

SIXTH CAUSE OF ACTION

37. The United States realleges, readopts, and reincorporates all the allegations contained

in paragraphs 1 through 26 as though fully set forth herein.

38. The defendant constitutes, or is derived from, proceeds traceable to violations of 18

U.S.C. § 1343, a specified unlawful activity as defined in 18 U.S.C. §§ 1956(c)(7)(A) and 1961(1)(B),

. . .

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or a conspiracy to commit such offense, and is subject to forfeiture pursuant to 18 U.S.C. §

981(a)(1)(C).

SEVENTH CAUSE OF ACTION

39. The United States realleges, readopts, and reincorporates all the allegations contained

in paragraphs 1 through 26 as though fully set forth herein.

40. The defendant constitutes, or is derived from, proceeds traceable to violations of 18

U.S.C. § 1952(a)(1) and Nev. Rev. Stat. §§ 199.480, 463.160, 463.430, 464.010, 465.092, and

465.093, a specified unlawful activity as defined in 18 U.S.C. §§ 1956(c)(7)(A) and 1961(1)(B), or

a conspiracy to commit such offense, and is subject to forfeiture pursuant to 18 U.S.C. § 981(a)(1)(C).

EIGHTH CAUSE OF ACTION

41. The United States realleges, readopts, and reincorporates all the allegations contained

in paragraphs 1 through 26 as though fully set forth herein.

42. The defendant constitutes, or is derived from, proceeds traceable to violations of 18

U.S.C. § 1952(a)(3) and Nev. Rev. Stat. §§ 199.480, 463.160, 463.430, 464.010, 465.092, and

465.093, a specified unlawful activity as defined in 18 U.S.C. §§ 1956(c)(7)(A) and 1961(1)(B), or

a conspiracy to commit such offense, and is subject to forfeiture pursuant to 18 U.S.C. § 981(a)(1)(C).

NINTH CAUSE OF ACTION

43. The United States realleges, readopts, and reincorporates all the allegations contained

in paragraphs 1 through 26 as though fully set forth herein.

44. The defendant constitutes, or is derived from, proceeds traceable to violations of 18

U.S.C. § 1955 and Nev. Rev. Stat. §§ 199.480, 463.160, 463.430, 464.010, 465.092, and 465.093, a

specified unlawful activity as defined in 18 U.S.C. §§ 1956(c)(7)(A) and 1961(1)(B), or a conspiracy

to commit such offense, and is subject to forfeiture pursuant to 18 U.S.C. § 981(a)(1)(C).

TENTH CAUSE OF ACTION

45. The United States realleges, readopts, and reincorporates all the allegations contained

in paragraphs 1 through 26 as though fully set forth herein.

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46. The defendant constitutes, or is derived from, proceeds traceable to violations of 18

U.S.C. § 1956(a)(1), a specified unlawful activity as defined in 18 U.S.C. §§ 1956(c)(7)(A) and

1961(1)(B), or a conspiracy to commit such offense, and is subject to forfeiture pursuant to 18 U.S.C.

§ 981(a)(1)(C).

ELEVENTH CAUSE OF ACTION

47. The United States realleges, readopts, and reincorporates all the allegations contained

in paragraphs 1 through 26 as though fully set forth herein.

48. The defendant constitutes, or is derived from, proceeds traceable to violations of 18

U.S.C. § 1956(a)(2), a specified unlawful activity as defined in 18 U.S.C. §§ 1956(c)(7)(A) and

1961(1)(B), or a conspiracy to commit such offense, and is subject to forfeiture pursuant to 18 U.S.C.

§ 981(a)(1)(C).

TWELFTH CAUSE OF ACTION

49. The United States realleges, readopts, and reincorporates all the allegations contained

in paragraphs 1 through 26 as though fully set forth herein.

50. The defendant constitutes, or is derived from, proceeds traceable to violations of 18

U.S.C. § 1957, a specified unlawful activity as defined in 18 U.S.C. §§ 1956(c)(7)(A) and 1961(1)(B),

or a conspiracy to commit such offense, and is subject to forfeiture pursuant to 18 U.S.C. §

981(a)(1)(C).

THIRTEENTH CAUSE OF ACTION

51. The United States realleges, readopts, and reincorporates all the allegations contained

in paragraphs 1 through 26 as though fully set forth herein.

52. The defendant is involved in violations of 31 U.S.C. § 5313, or a conspiracy to commit

such violations, or is traceable to any such violations or conspiracy, and is subject to forfeiture

pursuant to 31 U.S.C. § 5317(c)(2).

. . .

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FOURTEENTH CAUSE OF ACTION

53. The United States realleges, readopts, and reincorporates all the allegations contained

in paragraphs 1 through 26 as though fully set forth herein.

54. The defendant is involved in violations of 31 U.S.C. § 5324, or a conspiracy to commit

such violations, or is traceable to any such violations or conspiracy, and is subject to forfeiture

pursuant to 31 U.S.C. § 5317(c)(2).

CONCLUSION

Because of the foregoing, the defendant is subject to seizure and to forfeiture and has become

and is forfeited to the United States of America, plaintiff, under 18 U.S.C. § 981(a)(1)(A) and (C) and

31 U.S.C. § 5317(c)(2).

WHEREFORE, the United States of America, Plaintiff, prays as follows:

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2.

Due process issue to enforce the forfeiture of the defendant;

Due notice be given to any interested party to appear and to show cause why the

forfeiture should not be decreed;

3.

4.

The defendant be condemned and be forfeited to the United States; and

This Court enter other and further relief as it deems just and proper.

DATED this 29th day of January, 2010

Respectfully submitted,

DANIEL G. BOGDEN
United States Attorney

/s/DanielDHollingsworth
DANIEL D. HOLLINGSWORTH
Assistant United States Attorney

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