Page 12 of 22

Grand Jury, who had previously supplied Rigged Shuffling Machines. Specifically, on or about September 7, 2023, the defendants AMMAR AWAWDEH, OSMAN HOTI, JOHN MAZZOLA, NICHOLAS MINUCCI and ROBERT STROUD conspired to commit and committed a gunpoint robbery of John Doe #7 to steal a specific model of Rigged Shuffling Machine from John Doe #7 that the defendants wanted to use in the illegal poker games.

47.

COUNT ONE
(Wire Fraud Conspiracy)

The allegations contained in paragraphs one through 46 are realleged and

incorporated as if fully set forth in this paragraph.

48. In or about and between April 2019 and the present, both dates being
approximate and inclusive, within the Eastern District of New York and elsewhere, the defendants ERNEST AIELLO, NELSON ALVAREZ, also known as “Spanish G,” LOUIS APICELLA, also known as “Lou Ap,” AMMAR AWAWDEH, also known as “Flapper Poker” and “Flappy,” SAUL BECHER, CHAUNCEY BILLUPS, MATTHEW DADDINO, also known as “Matty” and “The Wrestler,” ERIC EARNEST, also known as “Spook,” LEE FAMA, JOHN GALLO, MARCO GARZON, THOMAS GELARDO, also known as “Juice,” JAMIE GILET, TONY GOODSON, also known as “Black Tony,” KENNY HAN, SHANE HENNEN, also known as “Sugar,” HORATIO HU, also known as “H,” ZHEN HU, also known as “Jonathan Chan,” “Jonathan Hu,” “Scruli” and “Stanley,” DAMON JONES, also known as “Dee Jones,” JOHN MAZZOLA, also known as “John South,” CURTIS MEEKS, also known as “Curt,” NICHOLAS MINUCCI, MICHAEL RENZULLI, ANGELO RUGGIERO, JR., ANTHONY SHNAYDERMAN, also known as “Doc,” ROBERT STROUD, also known as “Black Rob,” SETH TRUSTMAN, SOPHIA WEI, also known as “Pookie,” and JULIUS ZILIANI, also known as “Jay,” together with others, did knowingly and intentionally conspire to devise a

12