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Laborers for JUSTICE director obtains indictment after complaining for 13 years

The Laborers Network http://www.thelaborers.net

—– Original Message —–

From: Laborers for JUSTICE

TO: Various U.S. Attorneys and DOL-OIG Agents

Sent: Thursday, November 09, 2000 4:13 PM

Subject: Zeuberis Indictment after 13 years of complaining of corruption in laborers local 5

 U.S DOJ Press Release Nov. 9, 2000

          Gentlemen:

In 1987, 13 long years ago, I first began reporting about corruption in Laborers Local 5 and in the Laborers Union. The indictment does not mention the one years dues of $228 my employer paid in 1994 that was never credited to my account, rendering me ineligible  to run for office in 1996. I have a copy of the check stub of the check my employer, now out of business  , sent in 1994. I have paid the Laborers Union one more year’s dues than I have been a member.  I want my account to be credited and submit this indictment as evidence that when I tell authorities someone is a crook, I know what I am talking about. 🙂 Keep up the good work and indict all of them, including the embezzlers in Lazaretto’s local 152 I reported in 1999.

Thanks

Jim McGough
Laborers for JUSTICE, Director
773-728-2326

Zeuberis Indictment

 UNITED STATES DISTRICT COURT 
                 NORTHERN DISTRICT OF ILLINOIS
                      EASTERN DIVISION

 

UNITED STATES OF AMERICA                          )

)    No:

)    Hon.

)    Violations: Title 18, United

  1.                           )    States Code, Section 1962(c);

)    Title 29, United States Code,

)    Sections 501(c) and 439(c).

FRANK B. ZEUBERIS                                       )   

 

COUNT ONE

The SPECIAL JANUARY 1999-1 GRAND JURY charges:

  1. At all times material to this Indictment:

(a)  Defendant FRANK B. ZEUBERIS held the positions of President and Business Manager of Local Number 5 of the Laborers International Union of North America (�LIUNA�), AFL-CIO (�Local 5″), and was entrusted with the power and responsibility of presiding as chairman over all Local 5 membership and Executive Board meetings, signing all checks or orders for payment of monies from the Local 5 accounts together with the Secretary-Treasurer, and verifying that the affairs and business of Local 5 were conducted in accordance with the constitutions, rules, regulations, policies, practices, lawful orders and decisions of LIUNA and Local 5.

(b)  Under Section 501(a) of Title 29, United States Code, defendant FRANK B. ZEUBERIS occupied positions of trust in relation to Local 5 and its members as a group, and was under a duty, taking into account the special problems and functions of a labor organization, to hold Local 5’s money and property solely for the benefit of Local 5 and its members, and to manage, invest, and expend the same in accordance with Local 5’s  constitution and to refrain from dealing with Local 5 as an adverse party or in behalf of an adverse party in any matter connected with his duties and from holding or acquiring any pecuniary or personal interest which conflicted with the interests of Local 5, and to account to Local 5 for any profit received by him in whatever capacity in connection with transactions conducted by him or under his direction on behalf of Local 5.

  1. From on or about April 1, 1994 through and including July 11, 1997, James A. DiForti , now deceased, served as Secretary-Treasurer of Local 5, having been nominated and appointed to that position by defendant FRANK B. ZEUBERIS.
  2. At all times material to this indictment, Joann Zeuberis was the wife of defendant FRANK B. ZEUBERIS and a part-time clerical employee of Local 5.

The Enterprise

  1. At all times material to this Indictment:

(a)  Local 5 was an �enterprise� within the meaning of Title 18, United States Code, Section 1961(4), that is, it was a labor union with principal offices at 403 West 14th Street, Chicago Heights, Illinois.

 

(b)  Local 5 also was a �labor organization� within the meaning of Title 29, United States Code, Sections 402(i) and 402(j), engaged in an industry affecting commerce.

(c)  Local 5 was governed by a seven (7) member Executive Board consisting of the President and Business Manager, Vice-President, Recording Secretary, Secretary-Treasurer, and three other members elected by the membership of Local 5, with powers and duties established by and set forth in the Uniform Local Union Constitution.

(d)  The Local 5 Executive Board (�Executive Board�) was entrusted with the authority to make commitments and disbursements in its discretion from the funds, assets and property of Local 5 for the regular, recurrent and incidental expenses of Local 5 including salaries and other compensation, allowances and reimbursements for expenses.

(e)  Salary increases, other than for cost-of-living, proposed to be effective during a term of office required the further approval of the membership of Local 5, either by majority vote of the members present at a meeting of the Local after written notice of the proposal to all members in good standing, or approval of the increase at two consecutive membership meetings.

 

(f)  The Executive Board was required to meet at least once a month and, when possible, prior to the regular meeting of the Local 5 membership, and to submit a report of its activities and its minutes to each regular meeting of the Local 5 membership.

(g)  Written minutes of all Local 5 membership and Executive Board meetings were required to be prepared and maintained.

  1. From on or about April 1, 1994 to on or about October 23, 1998, in the Northern District of Illinois, Eastern Division, and elsewhere,

FRANK B. ZEUBERIS

defendant herein, being a person employed by and associated with the enterprise described in paragraph 4(a), above, that is, Local 5, which was engaged in and the activities of which affected interstate commerce, unlawfully and knowingly conducted and participated, directly and indirectly, in the conduct of the affairs of the enterprise through a pattern of racketeering activity as specified in paragraph 13, below.

           Conduct of the Affairs of the Enterprise

  1. It was part of the conduct of the affairs of the enterprise that defendant FRANK B. ZEUBERIS dominated and controlled the financial and other affairs of Local 5 throughout the time that he was President and Business Manager.

 

  1. It was part of the conduct of the affairs of the enterprise that defendant FRANK B. ZEUBERIS granted unauthorized salary and paid vacation increases and bonuses to himself, James A. DiForti, and Joann Zeuberis, causing an approximate financial loss to Local 5 of $473,106.
  2. It was part of the conduct of the affairs of the enterprise that defendant FRANK B. ZEUBERIS made and caused to be made false Executive Board and Regular Membership meeting minutes reflecting non-existent authorizations of salary increases, paid vacation increases, bonuses, and vehicle expense reimbursement.
  3. It was part of the conduct of the affairs of the enterprise that defendant FRANK B. ZEUBERIS made and caused to be made false and misleading statements to LIUNA to circumvent its disclosure requirement regarding gifts and donations.
  4. It was part of the conduct of the affairs of the enterprise that defendant FRANK B. ZEUBERIS granted unauthorized vehicle lease expense reimbursement to James A. DiForti.
  5. It was part of the conduct of the affairs of the enterprise that defendant FRANK B. ZEUBERIS did convert a salaried Local 5 Business Agent�s position to his own use in order to obtain $5,000 from the appointee.
  6. It was part of the conduct of the affairs of the enterprise that defendant FRANK B. ZEUBERIS caused false vehicle repair invoices to be prepared and submitted to Local 5 to obtain fraudulent vehicle expense reimbursement.

The Pattern of Racketeering Activity

 

  1. The pattern of racketeering activity as defined in Title 18, United States Code, Sections 1961(1) and 1961(5), consisted of the following racketeering acts indictable under and in violation of Title 29, United States Code, Section 501(c), any two of which constitute a pattern of racketeering activity:

Racketeering Act One

From on or about April 7, 1994, and continuing through and including October 9, 1998, in the Northern District of Illinois, Eastern Division, FRANK B. ZEUBERIS, defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to his own use the moneys, funds, and property of Local 5 in the approximate amount of $29,500, said sum constituting an unauthorized salary increase.

In violation of Title 29, United States Code, Section 501(c).

Racketeering Act Two

From on or about April 7, 1994, and continuing through and including July 11, 1997, in the Northern District of Illinois, Eastern Division, FRANK B. ZEUBERIS, defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to the use of another the moneys, funds, and property of Local 5 in the approximate amount of $17,100, said sum constituting an unauthorized salary increase to James A. DiForti.

In violation of Title 29, United States Code, Section 501(c).

                    Racketeering Act Three

 

From on or about May 3, 1994, and continuing through and including July 14, 1997, in the Northern District of Illinois, Eastern Division, FRANK B. ZEUBERIS, defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to the use of another the moneys, funds, and property of Local 5 in the approximate amount of $14,510, said sum constituting unauthorized vehicle lease expense reimbursement to James A. DiForti.

In violation of Title 29, United States Code, Section 501(c).

                     Racketeering Act Four

From on or about June 2, 1994, and continuing through and including October 9, 1998, in the Northern District of Illinois, Eastern Division, FRANK B. ZEUBERIS, defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to his own use the moneys, funds, and property of Local 5 in the approximate amount of $45,600, said sum constituting an unauthorized salary increase.

In violation of Title 29, United States Code, Section 501(c).

                     Racketeering Act Five

 

From on or about June 2, 1994, and continuing through and including July 11, 1997, in the Northern District of Illinois, Eastern Division, FRANK B. ZEUBERIS, defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to the use of another the moneys, funds, and property of Local 5 in the approximate amount of $32,600, said sum constituting an unauthorized salary increase to James A. DiForti.

In violation of Title 29, United States Code, Section 501(c).

                     Racketeering Act Six

From on or about June 24, 1994, and continuing through and including October 9, 1998, in the Northern District of Illinois, Eastern Division, FRANK B. ZEUBERIS, defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to the use of another the moneys, funds, and property of Local 5 in the approximate amount of $22,500, said sum constituting an unauthorized salary increase to Joann Zeuberis.

In violation of Title 29, United States Code, Section 501(c).

                    Racketeering Act Seven

From on or about November 1, 1994, and continuing through and including December 12, 1994, in the Northern District of Illinois, Eastern Division, FRANK B. ZEUBERIS, defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to his own use the moneys, funds, and property of Local 5 in the approximate amount of $9,600, said sum constituting an unauthorized bonus.

In violation of Title 29, United States Code, Section 501(c).

Racketeering Act Eight

 

From on or about November 1, 1994, and continuing through and including December 12, 1994, in the Northern District of Illinois, Eastern Division, FRANK B. ZEUBERIS, defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to the use of another the moneys, funds, and property of Local 5 in the approximate amount of $6,500, said sum constituting an unauthorized bonus to James A. DiForti.

In violation of Title 29, United States Code, Section 501(c).

Racketeering Act Nine

From on or about November 1, 1994, and continuing through and including December 12, 1994, in the Northern District of Illinois, Eastern Division, FRANK B. ZEUBERIS, defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to the use of another the moneys, funds, and property of Local 5 in the approximate amount of $1,500, said sum constituting an unauthorized bonus to Joann Zeuberis.

In violation of Title 29, United States Code, Section 501(c).

Racketeering Act Ten

From on or about January 3, 1995, and continuing through and including January 24, 1995, in the Northern District of Illinois, Eastern Division, FRANK B. ZEUBERIS, defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to the use of another the moneys, funds, and property of Local 5 in the approximate amount of $1,000, said sum constituting unauthorized paid vacation to James A. DiForti.

 

In violation of Title 29, United States Code, Section 501(c). Racketeering Act Eleven

From on or about January 3, 1995, and continuing through and including February 3, 1995, in the Northern District of Illinois, Eastern Division, FRANK B. ZEUBERIS, defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to the use of another the moneys, funds, and property of Local 5 in the approximate amount of $2,650, said sum constituting unauthorized paid vacation to Joann Zeuberis.

In violation of Title 29, United States Code, Section 501(c).

                    Racketeering Act Twelve

From on or about January 9, 1995, and continuing through and including November 4, 1995, in the Northern District of Illinois, Eastern Division, FRANK B. ZEUBERIS, defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to his own use the moneys, funds, and property of Local 5 in the approximate amount of $10,550, said sum constituting unauthorized paid vacation.

In violation of Title 29, United States Code, Section 501(c).

                   Racketeering Act Thirteen

 

From on or about January 27, 1995, and continuing through and including October 9, 1998, in the Northern District of Illinois, Eastern Division, FRANK B. ZEUBERIS, defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to his own use the moneys, funds, and property of Local 5 in the approximate amount of $48,500, said sum constituting an unauthorized salary increase.

In violation of Title 29, United States Code, Section 501(c).

                   Racketeering Act Fourteen

From on or about January 27, 1995, and continuing through and including July 11, 1997, in the Northern District of Illinois, Eastern Division, FRANK B. ZEUBERIS, defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to the use of another the moneys, funds, and property of Local 5 in the approximate amount of $25,800, said sum constituting an unauthorized salary increase to James A. DiForti.

In violation of Title 29, United States Code, Section 501(c).

                   Racketeering Act Fifteen

From on or about January 27, 1995, and continuing through and including October 9, 1998, in the Northern District of Illinois, Eastern Division, FRANK B. ZEUBERIS, defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to the use of another the moneys, funds, and property of Local 5 in the approximate amount of $19,400, said sum constituting an unauthorized salary increase to Joann Zeuberis.

In violation of Title 29, United States Code, Section 501(c).

                   Racketeering Act Sixteen

 

From on or about March 3, 1995, and continuing through and including October 9, 1998, in the Northern District of Illinois, Eastern Division, FRANK B. ZEUBERIS, defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to the use of another the moneys, funds, and property of Local 5 in the approximate amount of $9,450, said sum constituting an unauthorized salary increase to Joann Zeuberis.

In violation of Title 29, United States Code, Section 501(c).

                  Racketeering Act Seventeen

From on or about July 7, 1995, and continuing through and including December 22, 1995, in the Northern District of Illinois, Eastern Division, FRANK B. ZEUBERIS, defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to the use of another the moneys, funds, securities, property and other assets of Local 5 in the approximate amount of $7,500, said sum constituting an unauthorized bonus to James A. DiForti.

In violation of Title 29, United States Code, Section 501(c).

                   Racketeering Act Eighteen

 

From on or about July 21, 1995, and continuing through and including December 6, 1995, in the Northern District of Illinois, Eastern Division, FRANK B. ZEUBERIS, defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to his own use the moneys, funds, and property of Local 5 in the approximate amount of $29,600, said sum constituting an unauthorized bonus.

In violation of Title 29, United States Code, Section 501(c).

                   Racketeering Act Nineteen

From on or about September 22, 1995, and continuing through and including December 6, 1995, in the Northern District of Illinois, Eastern Division, FRANK B. ZEUBERIS, defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to the use of another the moneys, funds, and property of Local 5 in the approximate amount of $6,400, said sum constituting an unauthorized bonus to Joann Zeuberis.

In violation of Title 29, United States Code, Section 501(c).

            Racketeering Acts Twenty Through Thirty

Counts Two through Twelve of this Indictment are incorporated by reference herein as if fully set forth, and constitute Racketeering Acts Twenty through Thirty of this Count.

All in violation of Title 18, United States Code, Section 1962(c).

 

                           COUNT TWO

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

  1. Paragraphs 1, 3 and 4(b) through 4(g) of Count One of this Indictment are hereby realleged and incorporated herein as if fully set forth.
  2. From on or about May 8, 1996, and continuing through and including October 9, 1998, in the Northern District of Illinois, Eastern Division,

FRANK B. ZEUBERIS,

defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to the use of another the moneys, funds, and property of Local 5 in the approximate amount of $25,400, said sum constituting an unauthorized salary increase to Joann Zeuberis.

In violation of Title 29, United States Code, Section 501(c).

 

COUNT THREE

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

  1. Paragraphs 1 and 4(b) through 4(g) of Count One of this Indictment are hereby realleged and incorporated herein as if fully set forth.
  2. From on or about September 3, 1996, and continuing through and including November 1, 1996, in the Northern District of Illinois, Eastern Division,

FRANK B. ZEUBERIS,

defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to his own use the moneys, funds, and property of Local 5 in the approximate amount of $5,000, said sum constituting an unauthorized bonus.

In violation of Title 29, United States Code, Section 501(c).

 

COUNT FOUR

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

  1. Paragraphs 1, 2 and 4(b) through 4(g) of Count One of this Indictment are hereby realleged and incorporated herein as if fully set forth.
  2. From on or about September 3, 1996, and continuing through and including November 22, 1996, in the Northern District of Illinois, Eastern Division,

FRANK B. ZEUBERIS,

defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to the use of another the moneys, funds, and property of Local 5 in the approximate amount of $5,000, said sum constituting an unauthorized bonus to James A. DiForti.

In violation of Title 29, United States Code, Section 501(c).

 

COUNT FIVE

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

  1. Paragraphs 1, 3 and 4(b) through 4(g) of Count One of this Indictment are hereby realleged and incorporated herein as if fully set forth.
  2. From on or about September 3, 1996, and continuing through and including November 15, 1996, in the Northern District of Illinois, Eastern Division,

FRANK B. ZEUBERIS,

defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to the use of another the moneys, funds, and property of Local 5 in the approximate amount of $5,000, said sum constituting an unauthorized bonus to Joann Zeuberis.

In violation of Title 29, United States Code, Section 501(c).

 

COUNT SIX

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

  1. Paragraphs 1 and 4(b) through 4(g) of Count One of this Indictment are hereby realleged and incorporated herein as if fully set forth.
  2. From on or about October 24, 1997, and continuing through and including November 5, 1997, in the Northern District of Illinois, Eastern Division,

FRANK B. ZEUBERIS,

defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to his own use the moneys, funds, and property of Local 5 in the approximate amount of $5,000, said sum constituting an unauthorized bonus.

In violation of Title 29, United States Code, Section 501(c).

 

COUNT SEVEN

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

  1. Paragraphs 1, 3 and 4(b) through 4(g) of Count One of this Indictment are hereby realleged and incorporated herein as if fully set forth.
  2. From on or about October 24, 1997, and continuing through and including November 5, 1997, in the Northern District of Illinois, Eastern Division,

FRANK B. ZEUBERIS,

defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to the use of another the moneys, funds, and property of Local 5 in the approximate amount of $5,000, said sum constituting an unauthorized bonus to Joann Zeuberis.

In violation of Title 29, United States Code, Section 501(c).

 

COUNT EIGHT

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

  1. Paragraphs 1 and 4(b) through 4(g) of Count One of this Indictment are hereby realleged and incorporated herein as if fully set forth.
  2. From on or about January 5, 1996, and continuing through and including April 2, 1998, in the Northern District of Illinois, Eastern Division,

FRANK B. ZEUBERIS,

defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to his own use the moneys, funds, and property of Local 5 in the approximate amount of $53,150, said sum constituting unauthorized paid vacation.

In violation of Title 29, United States Code, Section 501(c).

 

COUNT NINE

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

  1. Paragraphs 1, 2 and 4(b) through 4(g) of Count One of this Indictment are hereby realleged and incorporated herein as if fully set forth.
  2. From on or about January 19, 1996, and continuing through and including May 1, 1997, in the Northern District of Illinois, Eastern Division,

FRANK B. ZEUBERIS,

defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to the use of another the moneys, funds, and property of Local 5 in the approximate amount of $2,000, said sum constituting unauthorized paid vacation to James A. DiForti.

In violation of Title 29, United States Code, Section 501(c).

 

COUNT TEN

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

  1. Paragraphs 1, 3 and 4(b) through 4(g) of Count One of this Indictment are hereby realleged and incorporated herein as if fully set forth.
  2. From on or about January 19, 1996, and continuing through and including April 2, 1998, in the Northern District of Illinois, Eastern Division,

FRANK B. ZEUBERIS,

defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to the use of another the moneys, funds, and property of Local 5 in the approximate amount of $19,350, said sum constituting unauthorized paid vacation to Joann Zeuberis.

In violation of Title 29, United States Code, Section 501(c).

 

COUNT ELEVEN

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

  1. Paragraphs 1 and 4(b) through 4(g) of Count One of this Indictment are hereby realleged and incorporated herein as if fully set forth.
  2. From in or about January 1997, and continuing through on or about March 7, 1997, in the Northern District of Illinois, Eastern Division,

                      FRANK B. ZEUBERIS,

defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to his own use the moneys, funds, property, and other assets of Local 5, that is, the salaried position of Local 5 Business Agent and the sum of $5,000 from the person appointed to this position.

In violation of Title 29, United States Code, Section 501(c).

 

COUNT TWELVE

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

  1. Paragraphs 1 and 4(b) through 4(g) of Count One of this Indictment are hereby realleged and incorporated herein as if fully set forth.
  2. From on or about May 20, 1996, and continuing through and including August 1, 1998, in the Northern District of Illinois, Eastern Division,

FRANK B. ZEUBERIS,

defendant herein, did embezzle, steal, and unlawfully and willfully abstract and convert to his own use the moneys, funds, and property of Local 5 in the approximate amount of $2,946, said sum constituting unauthorized and fictitious vehicle repair expense reimbursement.

In violation of Title 29, United States Code, Section 501(c).

 

COUNT THIRTEEN

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

  1. Paragraphs 1 and 4(b) through 4(g) of Count One of this Indictment are hereby realleged and incorporated herein as if fully set forth.
  2. In or about the mid to latter part of February 1996, in the Northern District of Illinois, Eastern Division,

FRANK B. ZEUBERIS,

defendant herein, did willfully make and cause to be made a false entry in a record of Local 5 required to be kept by Section 436 of Title 29, United States Code, that is, the minutes of the Regular Meeting of the Local 5 membership of February 6, 1996, purporting to empower the Business Manager to raise salaries of deserving officers and employees, a record on a matter required to be reported in the annual financial report of Local 5 required to be filed with the Secretary of Labor.

In violation of Title 29, United States Code, Section 439(c).

 

                        COUNT FOURTEEN

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

  1. Paragraphs 1 and 4(b) through 4(g) of Count One of this Indictment are hereby realleged and incorporated herein as if fully set forth.
  2. In or about the mid to latter part of March 1996, in the Northern District of Illinois, Eastern Division,

FRANK B. ZEUBERIS,

defendant herein, did willfully make and cause to be made a false entry in a record of Local 5 required to be kept by Section 436 of Title 29, United States Code, that is, the minutes of the Regular Meeting of the Local 5 membership of March 5, 1996, purporting to authorize pay raises for the officers and staff, a record on a matter required to be reported in the annual financial report of Local 5 required to be filed with the Secretary of Labor.

In violation of Title 29, United States Code, Section 439(c).

 

COUNT FIFTEEN

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

  1. Paragraphs 1 and 4(b) through 4(g) of Count One of this Indictment are hereby realleged and incorporated herein as if fully set forth.
  2. In or about the mid to latter part of September 1996, in the Northern District of Illinois, Eastern Division,

FRANK B. ZEUBERIS,

defendant herein, did willfully make and cause to be made a false entry in a record of Local 5 required to be kept by Section 436 of Title 29, United States Code, that is, the minutes of the Executive Board Meeting of September 3, 1996, purporting to authorize the payment of bonuses, a record on a matter required to be reported in the annual financial report of Local 5 required to be filed with the Secretary of Labor.

In violation of Title 29, United States Code, Section 439(c).

 

COUNT SIXTEEN

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

  1. Paragraphs 1 and 4(b) through 4(g) of Count One of this Indictment are hereby realleged and incorporated herein as if fully set forth.
  2. In or about the mid to latter part of October 1996, in the Northern District of Illinois, Eastern Division,

FRANK B. ZEUBERIS,

defendant herein, did willfully make and cause to be made a false entry in a record of Local 5 required to be kept by Section 436 of Title 29, United States Code, that is, the Executive Board Minutes for Tuesday, October 1, 1996, purporting to authorize the payment of bonuses, a record on a matter required to be reported in the annual financial report of Local 5 required to be filed with the Secretary of Labor.

In violation of Title 29, United States Code, Section 439(c).

 

COUNT SEVENTEEN

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

  1. Paragraphs 1 and 4(b) through 4(g) of Count One of this Indictment are hereby realleged and incorporated herein as if fully set forth.
  2. In or about the latter part of February 1997, in the Northern District of Illinois, Eastern Division,

FRANK B. ZEUBERIS,

defendant herein, did willfully make and cause to be made a false entry in a record of Local 5 required to be kept by Section 436 of Title 29, United States Code, that is, the Executive Board Minutes for a Special Meeting on February 20, 1997, purporting to authorize the hiring of a Business Agent, a record on a matter required to be reported in the annual financial report of Local 5 required to be filed with the Secretary of Labor.

In violation of Title 29, United States Code, Section 439(c).

 

COUNT EIGHTEEN

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

  1. Paragraphs 1 and 4(b) through 4(g) of Count One of this Indictment are hereby realleged and incorporated herein as if fully set forth.
  2. In or about the mid to latter part of October 1997, in the Northern District of Illinois, Eastern Division,

FRANK B. ZEUBERIS,

defendant herein, did willfully make and cause to be made a false entry in a record of Local 5 required to be kept by Section 436 of Title 29, United States Code, that is, the Executive Board Minutes for October 7, 1997, purporting to authorize the payment of bonuses, a record on a matter required to be reported in the annual financial report of Local 5 required to be filed with the Secretary of Labor.

In violation of Title 29, United States Code, Section 439(c).

 

COUNTS NINETEEN THROUGH TWENTY-EIGHT

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

  1. Paragraphs 1 and 4(b) through 4(g) of Count One of this Indictment are hereby realleged and incorporated herein as if fully set forth.
  2. On or about the dates hereinafter set forth, in the Northern District of Illinois, Eastern Division,

FRANK B. ZEUBERIS,

defendant herein, did willfully make and cause to be made a false entry in a record of Local 5 required to be kept by Section 436 of Title 29, United States Code, that is, a repair invoice for fictitious repairs to a Local 5 vehicle, as hereinafter set forth, a record on a matter required to be reported in the annual financial report of Local 5 required to be filed with the Secretary of Labor.

COUNT              FALSE INVOICE NUMBER         DATE

NINETEEN                51842                   May 20, 1996

TWENTY                  51896                   April 21, 1997

TWENTY-ONE              51899                   July 16, 1997

TWENTY-TWO              51955                   August 12, 1997

TWENTY-THREE            51929                   October 6, 1997

TWENTY-FOUR             51974                   November 4,1997

TWENTY-FIVE             51970                   January 8, 1998

TWENTY-SIX              51940                   February 5, 1998

 

TWENTY-SEVEN            51961                   March 30, 1998

TWENTY-EIGHT            51936                   July 1, 1998

Each in violation of Title 29, United States Code, Section 439(c).

 

                     FORFEITURE ALLEGATION

The SPECIAL JANUARY 1999-1 GRAND JURY further charges:

  1. The allegations contained in Count One of this Indictment are realleged and incorporated herein by reference for the purpose of alleging forfeiture pursuant to Title 18, United States Code, Section 1963.
  2. As a result of his violation of Title 18, United States Code, Sections 1962(c), as alleged in the foregoing Indictment,

                      FRANK B. ZEUBERIS,

defendant herein:

(a)  has acquired and maintained interests in violation of Title 18, United States Code, Section 1962, which interests are subject to forfeiture to the United States pursuant to Title 18, United States Code, Section 1963(a)(1);

(b)  has an interest in, security of, claims against, and property and contractual rights, which afford a source of influence over the enterprise, named and described herein, which defendant has established, operated, controlled, conducted and participated in the conduct of, in violation of Section 1962, which interests, securities, claims, property, and rights are subject to forfeiture to the United States, pursuant to Title 18, United States Code, Section 1963(a)(2);

 

(c)  has property constituting and derived from proceeds which the defendant obtained, directly and indirectly, from racketeering activity in violation of Title 18, United States Code, Section 1962, which property is subject to forfeiture to the United States pursuant to Title 18, United States Code, Section 1962(a)(3);

  1. The United States� intent to forfeit includes, but is not limited to, the defendant�s interest in the following assets:

(a)  $473,106 in United States currency and all interest and proceeds traceable thereto, in that such sum in aggregate is proceeds that the defendant obtained, directly and indirectly, from the aforesaid pattern of racketeering activity during the period charged in Count One, in violation of Title 18, United States Code, Sections 1962 and 1963(a)(3).

 

  1. If any of the above-described forfeitable property, as a result of any act or omission of the defendant —

(a)  cannot be located upon the exercise of due diligence;

 

(b)  has been transferred to, sold to, or deposited with a third person;

 

(c)  has been placed beyond the jurisdiction of the Court;

 

(d)  has been substantially diminished in value; or

 

(e)  has been commingled with other property which cannot be subdivided without difficulty;

 

it is the intent of the United States, pursuant to Title 18, United States Code, Section 1963(m), to seek forfeiture of any other property of said defendant up to the value of the above property, including, but not limited to, the following:

(1)  the real property commonly known as 9634 Keilman Street, St. John, Indiana  46373.

 

All pursuant to Title 18, United States Code, Section 1963.

 

A TRUE BILL:

 

                

FOREPERSON

 

 

 

                     

UNITED STATES ATTORNEY