65.

In or about and between December 2023 and April 2024, both dates being approximate and inclusive, within the Eastern District of New York and elsewhere, the defendants MALIK BEASLEY, also known as “Beas,” “Bease,” “MB” and “5,” WILLIAM BROWN, also known as “Willo,” EDWARD DAVIS, also known as “Ed,” “ED” and “E Davis,” ROBERT GORODETSKY, also known as “Rob,” ERNESTO PLASCENCIA, also known as “Ernie,” “Erny,” “Ernie P” and “Erny P,” and PAOLO ZAMORANO, also known as “PZ,”
together with others, did knowingly and intentionally conspire:

(a)

to conduct one or more financial transactions in and affecting
interstate commerce, which transactions in fact involved the proceeds of specified unlawful activity, to wit: (i) wire fraud, in violation of Title 18, United States Code, Section 1343 and (ii) sports bribery, in violation of Title 18, United States Code, Section 224, knowing that the property involved in the transactions represented the proceeds of some form of unlawful activity, and with the intent to promote the carrying on of the specified unlawful activity, contrary to Title 18, United States Code, Section 1956(a)(1)(A)(i);

(b)

to conduct one or more financial transactions in and affecting interstate commerce, which transactions in fact involved the proceeds of some form of unlawful activity, to wit: (i) wire fraud, in violation of Title 18, United States Code, Section 1343 and (ii) sports bribery, in violation of Title 18, United States Code, Section 224, knowing that the property involved in the transactions represented the proceeds of some form of unlawful activity, and knowing that the transactions were designed in whole and in part to conceal and disguise the

19