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NORTHERN DISTRICT OF OHIO EASTERN DIVISION
The Grand Jury charges: COUNT I CONSPIRACY TO RESTRAIN TRADE
1. The following companies and individuals are hereby indicted and made Defendants in the charge stated below in Count One:
2. Beginning at least as early as August 1997 and continuing at least until March 2003, the exact dates being unknown to the Grand Jury, the Defendants DEMILTA IRON & METAL and FRANCIS DEMILTA and co-conspirators entered into and engaged in a combination and conspiracy to suppress and restrain competition by allocating scrap metal suppliers for the purchase of scrap metal in Northeast Ohio. The charged combination and conspiracy unreasonably restrained interstate trade and commerce in violation of Section 1 of the Sherman Act (15 U.S.C. § 1). 3. The charged combination and conspiracy consisted of a continuing agreement, understanding, and concert of action among the Defendants and co-conspirators, the substantial terms of which were to allocate scrap metal suppliers for the sale of scrap metal in Northeast Ohio, and, in return for not soliciting scrap suppliers of its co-conspirators, DEMILTA IRON and METAL was sold scrap metal by its co-conspirators at prices below market value.
4. For the purpose of forming and carrying out the charged combination and conspiracy, the Defendants and co-conspirators did the following things, among others:
5. Defendant ALLIANCE NATIONAL LIMITED PARTNERSHIP is an Ohio limited partnership that was formed in or about April 1993 and does business as DEMILTA IRON & METAL, LTD. DEMILTA IRON & METAL is headquartered in Willoughby, Ohio, and has its principal place of business in Northeast Ohio. At all times relevant to this Indictment, DEMILTA IRON & METAL was owned by FRANCIS DEMILTA. At all times relevant to this Indictment, DEMILTA IRON & METAL was engaged in the purchase and sale of ferrous and nonferrous scrap metal in Northeast Ohio and elsewhere. DEMILTA IRON & METAL purchased scrap metal for resale from suppliers of scrap metal, then sold the scrap metal it purchased to mills and foundries located inside and outside the State of Ohio. 6. At all times relevant to this Indictment, FRANCIS DEMILTA was the founder, owner, and president of ALLIANCE NATIONAL LIMITED PARTNERSHIP, d/b/a DEMILTA IRON & METAL, LTD. Prior to forming ALLIANCE NATIONAL LIMITED PARTNERSHIP and DEMILTA IRON & METAL, FRANCIS DEMILTA was the founder, owner, and president of DeMilta Scrap & Salvage, Inc., a business that FRANCIS DEMILTA started in the early 1980s and which also was engaged in the purchase and sale of scrap metal. At all times relevant to this Indictment, FRANCIS DEMILTA was directly engaged in the purchase and sale of scrap metal and supervised the business activities of DEMILTA IRON & METAL. 7. Various individuals, companies, and corporations not made Defendants in this Indictment, participated as co-conspirators in the offense charged and performed acts and made statements in furtherance of it. 8. Whenever this Count refers to any act, deed, or transaction of any company or corporation, it means that the company or corporation engaged in the act, deed, or transaction by or through its officers, directors, employees, agents, or other representatives while they were actively engaged in the management, direction, control, or transaction of its business or affairs. TRADE AND COMMERCE 9. Ferrous and nonferrous scrap metal is a residual product that has value. Typically, manufacturing plants, mills, and foundries generate ferrous and nonferrous scrap metal as a by-product. In the scrap metal industry, this type of scrap is generally referred to as industrial scrap. For example, tool and die makers or stamping plants end up with small or odd-shaped pieces of scrap that are a by-product of their manufacturing process. This scrap is valuable if picked up, sorted, and sold to mills or foundries that desire scrap metal as part of their manufacturing process. The business of scrap metal companies, such as the Defendants and co-conspirators, generally involves placing collection boxes (e.g., lugger and roll off containers) at manufacturers' sites to collect the scrap metal, then picking it up, processing it, and reselling it to customers. 10. At all times relevant to this Indictment, Defendants DEMILTA IRON & METAL, FRANCIS DEMILTA, and co-conspirators (1) purchased ferrous and nonferrous scrap metal from individuals and companies located inside and outside the State of Ohio; (2) sold or shipped ferrous and nonferrous scrap metal to individuals and companies located inside and outside the State of Ohio; and (3) caused ferrous and nonferrous scrap metal to be purchased from, sold to, or shipped from or to, individuals and companies located inside and outside the State of Ohio.
11. At all times relevant to this Count, substantial quantities of ferrous and nonferrous scrap metal bought and/or sold by the Defendants and co-conspirators were shipped across state lines in a continuous and uninterrupted flow of interstate trade and commerce. 12. The activities of the Defendants and co-conspirators that are the subject of this Count were within the flow of, and substantially affected, interstate trade and commerce. JURISDICTION AND VENUE 13. The combination and conspiracy charged in this Count was formed and carried out, in part, by the Defendants DEMILTA IRON & METAL, FRANCIS DEMILTA, and co-conspirators in the Northern District of Ohio within the five years preceding the return of this Indictment. ALL IN VIOLATION OF TITLE 15, UNITED STATES CODE, SECTION 1.
The Grand Jury further charges:
14. RONALD VAUGHN is hereby indicted and made a Defendant in the charge stated below. 15. At all times relevant to this Indictment, Defendant RONALD VAUGHN was an employee of Alliance National Limited Partnership, d/b/a DeMilta Iron & Metal, Ltd. At all times relevant to this Indictment, RONALD VAUGHN was the vice president of DeMilta Iron & Metal, was directly engaged in the purchase and sale of scrap metal, and supervised the business activities of DeMilta Iron & Metal. RONALD VAUGHN and Francis DeMilta are brothers-in-law.
between DeMilta Iron & Metal and co-conspirators not to solicit each other's scrap metal suppliers) 16. On June 7, 2005, in the Northern District of Ohio, RONALD VAUGHN testified under oath as a witness before the Grand Jury, duly empaneled by the United States District Court for the Northern District of Ohio, sitting in Cleveland, Ohio, and knowingly made false material declarations concerning matters the Grand Jury was investigating, in violation of 18 U.S.C. § 1623. 17. At that time and place, the Grand Jury was conducting an investigation into possible violations of the Sherman Antitrust Act, 15 U.S.C. § 1, and other related federal offenses. The Grand Jury's investigation included the conduct of DeMilta Iron & Metal and its owners, officers, and employees, including RONALD VAUGHN and Francis DeMilta. 18. It was material to the Grand Jury's investigation to determine if any person or entity engaged in the purchase and sale of scrap metal had committed a violation of the Sherman Antitrust Act, 15 U.S.C. § 1, including any agreement to allocate scrap metal suppliers (also called accounts or customers). Thus, it was material to the Grand Jury to determine if RONALD VAUGHN had any awareness, knowledge, or information of, or participated in, any agreement or understanding with any competitor (i.e., another scrap metal dealer) to allocate scrap metal suppliers, in violation of 15 U.S.C. § 1, or other related federal criminal offenses. It was, therefore, material to the Grand Jury to determine: (a) if RONALD VAUGHN was aware of any agreement or understanding between DeMilta Iron & Metal and other scrap metal companies, including M. Weingold Company (hereinafter "M. Weingold" or "Weingold Company") or Harry Rock & Associates, Inc. (hereinafter "Rock" or "Rock Company"), to allocate or not to solicit each other's scrap metal suppliers; (b) if an agreement was struck at the Holiday Inn in 1997 or ever that DeMilta Iron & Metal would lay off of the accounts of its major competitor, M. Weingold, and its affiliated companies, including Rock, in return for M. Weingold and its affiliated companies laying off of DeMilta Iron & Metal's accounts; (c) whether there was ever at any time an agreement between DeMilta Iron & Metal not to compete with Weingold Company and its affiliated companies; (d) whether there was ever at any time an agreement between DeMilta Iron & Metal and Weingold Company and any of its affiliated companies to compete less vigorously than the companies would have competed but for an agreement; and (e) whether there was an agreement or understanding reached at a meeting at the Holiday Inn or after that DeMilta Iron & Metal would not solicit M. Weingold or its affiliated accounts in return for M. Weingold not soliciting DeMilta Iron & Metal's scrap metal accounts. 19. At the aforesaid time and place, RONALD VAUGHN, while under oath, knowingly declared falsely before the Grand Jury with respect to material matters as follows: (Page references are to the official Grand Jury transcript of RONALD VAUGHN, dated June 7, 2005. Declarations charged as false are underscored.)
[Vaughn Transcript, P. 112, Lines 9-25, and P. 113, Lines 1-5]. * * *
[Vaughn Transcript, P. 156, Lines 19-25 and P. 157, Lines 1-6.] * * *
[Vaughn Transcript, P. 158, Lines 13-25; P. 159, Lines 1-4].
20. The aforesaid declarations of RONALD VAUGHN, as he then and there knew, were false in that RONALD VAUGHN was, in fact, aware of an agreement or understanding between DeMilta Iron & Metal and M. Weingold, including its affiliated companies, including Rock, to allocate or not to solicit each other's scrap metal suppliers. Further, as RONALD VAUGHN then and there knew, this agreement was made at the Holiday Inn meeting, in which he was involved.
21. The aforesaid false material declarations charged in Count II of this Indictment were made by the Defendant RONALD VAUGHN before the Grand Jury sitting in the Northern District of Ohio within the five years preceding the return of this Indictment. ALL IN VIOLATION OF TITLE 18, UNITED STATES CODE, SECTION 1623.
(18 U.S.C. § 1623) The Grand Jury further charges: 22. Paragraphs 15, 16, and 17 of this Indictment are repeated, realleged, and incorporated in Count III with the same force and effect as if fully set forth in this Count.
23. RONALD VAUGHN is hereby indicted and made a Defendant in the charge stated below.
at the Holiday Inn between DeMilta Iron & Metal officials, including RONALD VAUGHN, and co-conspirators during which the collusive agreement was struck) 24. It was material to the Grand Jury's investigation to determine whether RONALD VAUGHN had any awareness, knowledge or information of, or participated in, any agreement or understanding with M. Weingold or Rock to allocate scrap metal suppliers (also called accounts or customers), in violation of 15 U.S.C. § 1, or other related federal criminal offenses, including: (a) whether RONALD VAUGHN had any awareness, knowledge, or information of, or participated in, a meeting at the Holiday Inn in which it was agreed or understood that Jack Weingold and his companies, M. Weingold and Rock, would not solicit and go after DeMilta Iron & Metal's accounts and, in return, DeMilta Iron & Metal would not solicit and go after M. Weingold and Rock accounts; (b) whether, at the Holiday Inn meeting, Jack Weingold ever discussed or proposed to RONALD VAUGHN or Francis DeMilta that he and his companies, M. Weingold and Rock, and DeMilta Iron & Metal should quit competing against each other, or suggested that competition between their companies should end; (c) whether, after the Holiday Inn meeting, there was an agreement or understanding that DeMilta Iron would not solicit M. Weingold accounts, and, in return M. Weingold would not solicit DeMilta Iron accounts (d) whether, at the Holiday Inn, Jack Weingold ever discussed or proposed to RONALD VAUGHN or Francis DeMilta that, by competing against each other, they were costing each other money, or whether the idea of ending competition was raised; (e) whether, at the Holiday Inn meeting, Jack Weingold ever proposed selling any volume of busheling (a type of scrap metal) to DeMilta Iron & Metal; (f) whether, at the Holiday Inn meeting, there was ever any discussion, even as a possibility, that M. Weingold would sell busheling to DeMilta Iron & Metal at a price $25 under the Iron Age price; (g) whether, at the conclusion of the Holiday Inn meeting, there were any definite plans for M. Weingold to sell busheling to DeMilta Iron & Metal; and (h) whether, at the Holiday Inn meeting, there was any proposed volume of busheling to be sold by M. Weingold to DeMilta Iron & Metal. 25. At the aforesaid time and place, while under oath, RONALD VAUGHN knowingly declared falsely before the Grand Jury with respect to material matters as follows:
[Vaughn Transcript, P. 159, Lines 5-25].
[Vaughn Transcript, P. 78, Lines 14-25; P. 79, Lines 1-25; and P. 80, Lines 1-22]. * * *
[Vaughn Transcript, P. 161, Lines 10-17]. * * *
[Vaughn Transcript, P. 76, Lines 6-19].
26. The aforesaid declarations of RONALD VAUGHN, as he then and there knew, were false in that: (1) RONALD VAUGHN was, in fact, aware not only that the idea of ending competition between M. Weingold and DeMilta Iron & Metal was proposed and discussed between Jack Weingold and RONALD VAUGHN and Francis DeMilta at the Holiday Inn, but that an agreement to allocate scrap metal suppliers was, in fact, struck at the Holiday Inn meeting whereby M. Weingold and Rock would not solicit DeMilta Iron & Metal's scrap metal suppliers in return for DeMilta Iron & Metal not soliciting M. Weingold's and Rock's scrap metal suppliers; (2) as part of this collusive agreement at the Holiday Inn meeting, busheling, volume, and pricing were proposed and discussed; (3) RONALD VAUGHN was, in fact, aware that Jack Weingold discussed the state of the competition between his company and DeMilta Iron & Metal and proposed (and the participants at the meeting, including RONALD VAUGHN, ultimately agreed) that this competition should end because it was costing each other money; (4) RONALD VAUGHN was, in fact, aware that a price of $25 under the Iron Age pricing was proposed and discussed at the Holiday Inn meeting, in which RONALD VAUGHN was involved; and (5) RONALD VAUGHN was aware, in fact, that, at this Holiday Inn meeting, plans were proposed and made for DeMilta Iron & Metal to buy busheling from M. Weingold. JURISDICTION AND VENUE 27. The aforesaid false material declarations charged in Count III of this Indictment were made by the Defendant RONALD VAUGHN before the Grand Jury sitting in the Northern District of Ohio within five years preceding the return of this Indictment. ALL IN VIOLATION OF TITLE 18, UNITED STATES CODE, SECTION 1623.
(18 U.S.C. § 1623)
The Grand Jury further charges: 28. Paragraphs 15, 16, and 17 of this Indictment are repeated, realleged, and incorporated in Count IV with the same force and effect as if fully set forth in this Count.
29. RONALD VAUGHN is hereby indicted and made a Defendant in the charge stated below.
(False material declarations about the substance 30. It was material to the Grand Jury's investigation to determine whether RONALD VAUGHN had any awareness, knowledge, or information of, or participated in, any meeting resulting in an agreement or understanding with any competitor (i.e., another scrap metal dealer) to allocate scrap metal suppliers (also called accounts or customers), in violation of 15 U.S.C. § 1, or other related federal criminal offenses, including: (a) whether, at a meeting at the Holiday Inn, an agreement was made whereby M. Weingold and Rock officials, including Jack Weingold and Loren Margolis, and DeMilta Iron & Metal officials, including RONALD VAUGHN and Francis DeMilta, agreed not to continue going after (i.e., soliciting) each other's business; (b) whether RONALD VAUGHN, in substance, accurately and truthfully described his one and only meeting with Francis DeMilta, Jack Weingold, and Loren Margolis at the Holiday Inn; and (c) whether it was resolved, at the conclusion of this Holiday Inn meeting, that the Defendants and co-conspirators would continue to compete, or whether instead a collusive agreement was struck limiting competition between the Defendants and co-conspirators. 31. At the aforesaid time and place, while under oath, RONALD VAUGHN knowingly declared falsely before the Grand Jury with respect to material matters as follows: (Page references are to the official Grand Jury transcript of RONALD VAUGHN dated June 7, 2005. Declarations charged as false are underscored.)
* * *
[Vaughn Transcript, P. 30, Lines 17-20; P. 31, Lines 9-19]. * * *
[Vaughn Transcript, P. 66, Line 25 to P. 68, Line 15]. * * *
[Vaughn Transcript, P. 69, Lines 19-25 and P. 70, Lines 1-5].
32. The aforesaid declarations of RONALD VAUGHN, as he then and there knew, were false in that: (1) RONALD VAUGHN was, in fact, aware that he and Francis DeMilta had participated in a meeting at the Holiday Inn with co-conspirators, at which an agreement was made by DeMilta Iron & Metal officials, RONALD VAUGHN and Francis DeMilta, and their co-conspirators, Jack Weingold and Loren Margolis, that DeMilta Iron & Metal would not continue to go after (i.e., not solicit) the scrap metal suppliers of Jack Weingold's companies, including M. Weingold and Rock, in return for Jack Weingold's companies not going after (i.e., not soliciting) the scrap metal suppliers of DeMilta Iron & Metal ; (2) RONALD VAUGHN was, in fact, aware that his description as to the substance of his one and only meeting at the Holiday Inn in which Jack Weingold, Loren Margolis, and Francis DeMilta also participated, was false and was intended to deceive and mislead the Grand Jury; and (3) RONALD VAUGHN was aware, in fact, that, opposite of how RONALD VAUGHN testified, at the conclusion of this Holiday Inn meeting, it was agreed that DeMilta Iron & Metal and co-conspirators would not continue to compete against each other. JURISDICTION AND VENUE 33. The aforesaid false material declarations charged in Count IV of this Indictment were made by the Defendant RONALD VAUGHN before the Grand Jury sitting in the Northern District of Ohio within the five years preceding the return of this Indictment. ALL IN VIOLATION OF TITLE 18, UNITED STATES CODE, SECTION 1623.
The Grand Jury further charges: 34. Paragraphs 15, 16, and 17 of this Indictment are repeated, realleged, and incorporated in Count V with the same force and effect as if fully set forth in this Count.
35. RONALD VAUGHN is hereby indicted and made a Defendant in the charge stated below.
discussed specific scrap metal accounts with Loren Margolis) 36. It was material to the Grand Jury's investigation to determine whether RONALD VAUGHN had any awareness, knowledge, or information of, or participated in, any meeting resulting in an agreement or understanding with any competitor (i.e., another scrap metal dealer) to allocate scrap metal suppliers (also called accounts or customers), in violation of 15 U.S.C. § 1, or other related federal criminal offenses, including: (a) whether RONALD VAUGHN, at any meeting or discussion with his competitor, Loren Margolis, ever talked to Margolis about specific scrap metal accounts other than Superior Quality; and (b) whether RONALD VAUGHN ever talked with Loren Margolis about any of the following specific accounts: ETS; Solon Industrial; or Bison Welding. 37. At the aforesaid time and place, while under oath, RONALD VAUGHN knowingly declared falsely before the Grand Jury with respect to material matters as follows: (Page references are to the official Grand Jury transcript of RONALD VAUGHN dated June 7, 2005. Declarations charged as false are underscored.)
[Vaughn Transcript, Page 106, Lines 3-17]. * * *
[Vaughn Transcript, P. 107, Lines 4-13]. * * *
[Vaughn Transcript, P. 108, Lines 2-25]. * * *
[Vaughn Transcript, P. 110, Lines 1-13].
38. The aforesaid declarations of RONALD VAUGHN, as he then and there knew, were false in that: (1) RONALD VAUGHN was, in fact, aware that, pursuant to the collusive agreement between DeMilta Iron & Metal and co-conspirators, RONALD VAUGHN talked with Loren Margolis about specific scrap metal accounts; and (2) RONALD VAUGHN was, in fact, aware that he talked to Loren Margolis about ETS, Solon Industrial, and Bison Welding.
39. The aforesaid false material declarations charged in Count V of this Indictment were made by the Defendant RONALD VAUGHN before the Grand Jury sitting in the Northern District of Ohio within the five years preceding the return of this Indictment. ALL IN VIOLATION OF TITLE 18, UNITED STATES CODE, SECTION 1623.
The Grand Jury further charges: 40. Paragraphs 15, 16, and 17 of this Indictment are repeated, realleged, and incorporated in Count VI with the same force and effect as if fully set forth in this Count.
41. RONALD VAUGHN is hereby indicted and made a Defendant in the charge stated below.
terminology related to the collusive agreement between DEMILTA IRON & METAL and co-conspirators) 42. It was material to the Grand Jury's investigation to determine whether RONALD VAUGHN had any awareness, knowledge, or information of, or participated in, any meeting resulting in an agreement or understanding with any competitor (i.e., another scrap metal dealer) to allocate scrap metal suppliers (also called accounts or customers), in violation of 15 U.S.C. § 1, or other related federal criminal offenses, including: (a) whether RONALD VAUGHN ever used, or heard, color-coded terminology in referring to the collusive agreement between DeMilta Iron & Metal and co-conspirators; and (b) whether RONALD VAUGHN and Loren Margolis ever used color-coded terminology, or whether RONALD VAUGHN ever heard Loren Margolis use color-coded terminology, as shorthand for the collusive agreement between DeMilta Iron & Metal and co-conspirators. 43. At the aforesaid time and place, while under oath, RONALD VAUGHN knowingly declared falsely before the Grand Jury with respect to material matters as follows: (Page references are to the official Grand Jury transcript of RONALD VAUGHN dated June 7, 2005. Declarations charged as false are underscored.)
[Vaughn Transcript, P. 110, Lines 14-25 and P. 111, Line 1]. * * *
[Vaughn Transcript, P. 111, Lines 18-23]. * * *
[Vaughn Transcript, P. 112, Lines 6-8]. * * *
* * *
[Vaughn Transcript, P. 274, Lines 1-8; 15-23].
44. The aforesaid declarations of RONALD VAUGHN, as he then and there knew, were false in that RONALD VAUGHN was, in fact, aware that he used or heard color-coded terminology in discussions with co-conspirators related to the collusive agreement between DeMilta Iron & Metal and co-conspirators.
45. The aforesaid false material declarations charged in Count VI of this Indictment were made by the Defendant RONALD VAUGHN before the Grand Jury sitting in the Northern District of Ohio within the five years preceding the return of this Indictment.
The Grand Jury further charges: 46. Paragraphs 15, 16, and 17 of this Indictment are repeated, realleged, and incorporated in Count VII with the same force and effect as if fully set forth in this Count.
47. RONALD VAUGHN is hereby indicted and made a Defendant in the charge stated below.
(False material declarations about a meeting at the
48. It was material to the Grand Jury's investigation to determine whether RONALD VAUGHN had any awareness, knowledge, or information of, or participated in, any meeting resulting in an agreement or understanding with any competitor (i.e., another scrap metal dealer) to allocate scrap metal suppliers (also called accounts or customers), in violation of 15 U.S.C. § 1, or other related federal criminal offenses, including: (a) whether RONALD VAUGHN met with Loren Margolis and Mark Weingold at the Holiday Inn; (b) whether RONALD VAUGHN ever met with Loren Margolis and Mark Weingold, at the Holiday Inn or elsewhere, to discuss increasing the monthly busheling sales from 150 tons to a higher tonnage level as part of the collusive agreement between DeMilta Iron & Metal and co-conspirators not to solicit each other's scrap metal suppliers; and (c) whether RONALD VAUGHN, along with Francis DeMilta, ever met with Loren Margolis and Mark Weingold at the Holiday Inn. 49. At the aforesaid time and place, while under oath, RONALD VAUGHN knowingly declared falsely before the Grand Jury with respect to material matters as follows: (Page references are to the official Grand Jury transcript of RONALD VAUGHN dated June 7, 2005. Declarations charged as false are underscored.)
* * *
[Vaughn Transcript, P. 147, Lines 23-25; P. 148, Lines 1-25; P. 149, Lines 1-25; and P. 150, Line 1-4.] * * *
[Vaughn Transcript, P. 161, Lines 18-25; P. 162, Lines 1-2].
50. The aforesaid declarations of RONALD VAUGHN, as he then and there knew, were false in that RONALD VAUGHN was, in fact, aware: (1) that RONALD VAUGHN had met with Loren Margolis and Mark Weingold at the Holiday Inn; and (2) that, at this meeting, which took place after Jack Weingold bought another local scrap metal company called Atlas Lederer, RONALD VAUGHN specifically requested that M. Weingold needed to increase its monthly busheling sales to DeMilta Iron & Metal or DeMilta Iron & Metal would begin to compete aggressively against M. Weingold and its affiliated companies.
51. The aforesaid false material declarations charged in Count VII of this Indictment were made by the Defendant RONALD VAUGHN before the Grand Jury sitting in the Northern District of Ohio within the five years preceding the return of this Indictment. ALL IN VIOLATION OF TITLE 18, UNITED STATES CODE, SECTION 1623.
The Grand Jury further charges: 52. Paragraphs 15, 16, and 17 of this Indictment are repeated, realleged, and incorporated in Count VIII with the same force and effect as if fully set forth in this Count.
53. RONALD VAUGHN is hereby indicted and made a Defendant in the charge stated below.
to Loren Margolis, Mark Weingold, and Howard Bahm about the quid pro quo pay-off of monthly busheling sales (150 tons) not being satisfactory after Jack Weingold bought Atlas Lederer) 54. It was material to the Grand Jury's investigation to determine whether RONALD VAUGHN had any awareness, knowledge, or information of, or participated in, any meeting resulting in an agreement or understanding with any competitor (i.e., another scrap metal dealer) to allocate scrap metal suppliers (also called accounts or customers), in violation of 15 U.S.C. § 1, or other related federal criminal offenses, including: (a) whether, after Jack Weingold bought another scrap metal dealer in the Cleveland area called Atlas Lederer, RONALD VAUGHN complained to Loren Margolis or Mark Weingold about the monthly sale of 150 tons of busheling to DeMilta Iron & Metal by M. Weingold no longer being satisfactory; (b) whether M. Weingold's agreement to increase its monthly busheling sales to DeMilta Iron & Metal from 150 tons to 350 tons was related in any way to Jack Weingold's purchase of Atlas Lederer; and (c) whether RONALD VAUGHN was privy to the reason why M. Weingold officials agreed to increase the monthly busheling sales to DeMilta Iron & Metal from 150 tons to 350 tons. 55. At the aforesaid time and place, while under oath, RONALD VAUGHN knowingly declared falsely before the Grand Jury with respect to material matters as follows: (Page references are to the official Grand Jury transcript of RONALD VAUGHN dated June 7, 2005. Declarations charged as false are underscored.)
[Vaughn Transcript, P. 150, Lines 6-12]. * * *
[Vaughn Transcript, P. 273, Lines 20-25]. * * *
[Vaughn Transcript, P. 167, Lines 9-14.]
56. The aforesaid declarations of RONALD VAUGHN, as he then and there knew, were false in that RONALD VAUGHN was, in fact, aware that, after Jack Weingold purchased Atlas Lederer: (1) RONALD VAUGHN met with Loren Margolis and Mark Weingold at the Holiday Inn and complained to them that the 150 ton busheling arrangement was not satisfactory and needed to be increased because Jack Weingold now controlled more scrap metal tons; (2) RONALD VAUGHN complained to Howard Bahm, an official of Rock Company, about the monthly busheling sales of 150 tons not being satisfactory after Jack Weingold bought Atlas Lederer; and (3) RONALD VAUGHN was, in fact, privy to the reason why the monthly busheling sales from M. Weingold to DeMilta Iron & Metal increased from 150 tons to 350 tons after Jack Weingold bought Atlas Lederer, in that RONALD VAUGHN, in meetings and discussions with M. Weingold officials, insisted that the monthly busheling sales by M. Weingold to DeMilta Iron & Metal needed to be increased or DeMilta Iron & Metal would end the collusive agreement struck at the Holiday Inn in August 1997 and begin to compete aggressively against M. Weingold and its affiliated companies.
57. The aforesaid false material declarations charged in Count VIII of this Indictment were made by the Defendant RONALD VAUGHN before the Grand Jury sitting in the Northern District of Ohio within the five years preceding the return of this Indictment. ALL IN VIOLATION OF TITLE 18, UNITED STATES CODE, SECTION 1623.
The Grand Jury further charges: 58. Paragraphs 15, 16, and 17 of this Indictment are repeated, realleged, and incorporated in Count IX with the same force and effect as if fully set forth in this Count.
59. RONALD VAUGHN is hereby indicted and made a Defendant in the charge stated below.
M. Weingold and Rock officials about Best Atlas and Best Atlas' accounts) 60. It was material to the Grand Jury's investigation to determine whether RONALD VAUGHN had any awareness, knowledge, or information of, or participated in, any agreement or understanding with any other scrap metal dealer, including Weingold Company and Rock Company, to allocate accounts or customers, in violation of 15 U.S.C. § 1, or other related federal criminal offenses, including: (a) whether RONALD VAUGHN ever talked to Jack Weingold, Loren Margolis, Mark Weingold, or Howard Bahm about Jack Weingold's acquisition of Best Atlas; and (b) whether RONALD VAUGHN ever talked about any Best Atlas accounts. 61. At the aforesaid time and place, while under oath, RONALD VAUGHN knowingly declared falsely before the Grand Jury with respect to material matters as follows: (Page references are to the official Grand Jury transcript of RONALD VAUGHN dated June 7, 2005. Declarations charged as false are underscored.)
[Vaughn Transcript, P. 204, Lines 20-25; P. 205, Lines 1-12].
62. The aforesaid declarations of RONALD VAUGHN, as he then and there knew, were false in that RONALD VAUGHN was, in fact, aware: (1) that RONALD VAUGHN did talk to Jack Weingold, Loren Margolis, Mark Weingold, and/or Howard Bahm about Jack Weingold's acquisition of Best Atlas; and (2) RONALD VAUGHN did talk to some of these M. Weingold or Rock officials about Best Atlas' accounts.
63. The aforesaid false material declarations charged in Count IX of this Indictment were made by the Defendant RONALD VAUGHN before the Grand Jury sitting in the Northern District of Ohio within the five years preceding the return of this Indictment. ALL IN VIOLATION OF TITLE 18, UNITED STATES CODE, SECTION 1623.
The Grand Jury further charges: 64. Paragraphs 15, 16, and 17 of this Indictment are repeated, realleged, and incorporated in Count X with the same force and effect as if fully set forth in this Count.
65. RONALD VAUGHN is hereby indicted and made a Defendant in the charge stated below.
RONALD VAUGHN gave to DeMilta Iron & Metal employees)
66. It was material to the Grand Jury's investigation to determine whether RONALD VAUGHN had any awareness, knowledge, or information of, or participated in, any agreement or understanding with any other scrap metal dealer, including M. Weingold and Rock, to allocate scrap metal suppliers (also called accounts or customers), in violation of 15 U.S.C. § 1, or other related federal criminal offenses, including: (a) whether RONALD VAUGHN gave any direction or instruction to Jarrod Mink, a DeMilta Iron & Metal employee, related to the Commercial Honing account; and (b) whether RONALD VAUGHN ever gave any direction or instruction to any trader, salesman, or buyer at DeMilta Iron & Metal to lay off of M. Weingold or Rock Company business. 67. At the aforesaid time and place, while under oath, RONALD VAUGHN knowingly declared falsely before the Grand Jury with respect to material matters as follows: (Page references are to the official Grand Jury transcript of RONALD VAUGHN dated June 7, 2005. Declarations charged as false are underscored.)
[Vaughn Transcript, P. 229, Lines 9-20].
68. The aforesaid declarations of RONALD VAUGHN, as he then and there knew, were false in that RONALD VAUGHN was, in fact, aware: (1) that RONALD VAUGHN did give direction and instruction to Jarrod Mink related to the Commercial Honing account; and (2) RONALD VAUGHN did direct and instruct traders, buyers, or salesmen of DeMilta Iron & Metal to lay off M. Weingold and Rock business.
69. The aforesaid false material declarations charged in Count X of this Indictment were made by the Defendant RONALD VAUGHN before the Grand Jury sitting in the Northern District of Ohio within the five years preceding the return of this Indictment. ALL IN VIOLATION OF TITLE 18, UNITED STATES CODE, SECTION 1623.
The Grand Jury further charges: 70. Paragraphs 15, 16, and 17 of this Indictment are repeated, realleged, and incorporated in Count XI with the same force and effect as if fully set forth in this Count.
71. RONALD VAUGHN is hereby indicted and made a Defendant in the charge stated below.
to employees about generating false, phony, or inaccurate weight tickets and about altering the unit weight of trucks used to buy scrap metal) 72. It was material to the Grand Jury's investigation to determine whether RONALD VAUGHN had any awareness, knowledge, or information of, or participated in, any scheme or artifice to defraud persons who sold scrap metal to DeMilta Iron & Metal, including: (a) whether RONALD VAUGHN ever directed anyone at DeMilta Iron & Metal, including Phil Zelznick or Jarrod Mink, to generate false, or phony, or inaccurate weight tickets; and (b) whether RONALD VAUGHN ever altered the weight of a truck to help establish a tare weight, which was then used to establish a unit weight for DeMilta Iron & Metal to pay one of its scrap metal suppliers. 73. At the aforesaid time and place, while under oath, RONALD VAUGHN knowingly declared falsely before the Grand Jury with respect to material matters as follows: (Page references are to the official Grand Jury transcript of RONALD VAUGHN dated June 7, 2005. Declarations charged as false are underscored.)
[Vaughn Transcript, P. 252, Lines 9-15.] * * *
[Vaughn Transcript, P. 254, Lines 15-20.]
74. The aforesaid declarations of RONALD VAUGHN, as he then and there knew, were false in that RONALD VAUGHN was, in fact, aware that: (1) RONALD VAUGHN did instruct Mink, Zelznick, and others at DeMilta Iron & Metal to generate false, phony, or inaccurate weight tickets; and (2) RONALD VAUGHN did alter the weight of a truck to establish a phony tare weight, which was then used as a basis to pay Parker Hannifin for its scrap metal.
75. The aforesaid false material declarations charged in Count XI of this Indictment were made by the Defendant RONALD VAUGHN before the Grand Jury sitting in the Northern District of Ohio within the five years preceding the return of this Indictment. ALL IN VIOLATION OF TITLE 18, UNITED STATES CODE, SECTION 1623.
(18 U.S.C. § 1503)
The Grand Jury further charges: 76. Each and every allegation in Paragraphs 14-75 of this Indictment is repeated, realleged, and incorporated in Count XII with the same force and effect as if fully set forth in this Count.
77. RONALD VAUGHN is hereby indicted and made a Defendant in the charge stated below.
78. From in or about March 1999 to the present, a federal grand jury sitting in the Northern District of Ohio has been investigating, among other things, possible federal antitrust offenses, and related criminal offenses, in the purchase and sale of industrial scrap metal. This investigation has included the Defendants DeMilta Iron & Metal, Francis DeMilta, and RONALD VAUGHN as well as others in the scrap metal industry.
79. On June 7, 2005, RONALD VAUGHN was subpoenaed to testify before the Grand Jury (Grand Jury 04-5-A). On this occasion, the foreperson of the Grand Jury administered the oath to RONALD VAUGHN and RONALD VAUGHN swore to tell the truth in the testimony he was about to give. 80. During his June 7, 2005, appearance before the grand jury, RONALD VAUGHN did knowingly and intentionally corruptly endeavor to influence, obstruct, and impede the due administration of justice, and did, in fact, influence, obstruct, and impede the due administration of justice, namely proceedings before the Grand Jury, by knowingly and intentionally providing false, misleading, deceiving, and evasive testimony to the Grand Jury as to his knowledge and awareness of, and participation in, an agreement or understanding involving RONALD VAUGHN, DeMilta Iron & Metal, and Francis DeMilta with co-conspirators to allocate scrap metal suppliers, as well as concealing from the Grand Jury the true reason for, and nature of, the monthly busheling sales to DeMilta Iron & Metal from M. Weingold at a price below market value. RONALD VAUGHN misled the grand jury into believing that these monthly busheling sales were legitimate, when in fact they were related to the collusive agreement in that they were intended to, and did, compensate DeMilta Iron & Metal in return for DeMilta Iron & Metal's not soliciting the scrap metal suppliers of M. Weingold and its affiliated companies. Moreover, RONALD VAUGHN provided false, misleading, deceiving, and evasive testimony concerning his knowledge and awareness of, or participation in, numerous acts in furtherance of this illegal collusive agreement, for which conduct any participants could possibly be prosecuted for violations of Title 15, Section 1, of the United States Code. 81. Further, in his June 7, 2005, appearance before the Grand Jury, RONALD VAUGHN did knowingly and corruptly endeavor to influence, obstruct, and impede the due administration of justice, and did, in fact, influence, obstruct, and impede the due administration of justice, namely proceedings before the Grand Jury, by knowingly providing false, misleading, deceiving, and evasive testimony to the Grand Jury as to RONALD VAUGHN's knowledge or awareness of, and participation in, DeMilta Iron & Metal's short weighting some of its scrap metal suppliers. In the scrap metal industry, "short weighting" occurs when an account or customer is paid less for its scrap metal because the scrap metal dealer, here DeMilta Iron & Metal, intentionally alters the weight of the scrap metal being purchased, thereby resulting in less money being paid to the scrap metal supplier. It was material to the Grand Jury to determine if DeMilta Iron & Metal short weighted any of its suppliers, accounts, or customers, conduct that could possibly be prosecuted as violations of 18 U.S.C. § 1341 (mail fraud), 18 U.S.C. § 1343 (wire fraud), 18 U.S.C. § 2314 (interstate transportation of goods fraudulently taken), or 18 U.S.C. § 371 (a conspiracy to commit a crime or crimes against the United States). 82. It was part of the corrupt endeavor that, during his testimony before the Grand Jury, RONALD VAUGHN made the following materially false and intentionally misleading, deceiving, and evasive statements and representations, in substance, under oath: (a) RONALD VAUGHN was not aware of an agreement or understanding between DeMilta Iron & Metal and its co-conspirators, M. Weingold, Rock and their officials, not to solicit each other's scrap metal suppliers; (b) RONALD VAUGHN was not aware that, at the conclusion of a meeting at the Holiday Inn, there was an agreement or understanding between Jack Weingold and his companies and DeMilta Iron & Metal that DeMilta Iron & Metal would not solicit M. Weingold and Rock accounts in return for M. Weingold and Rock Company not soliciting DeMilta Iron & Metal accounts, and, further, RONALD VAUGHN was not aware that a proposal was even made at the Holiday Inn that these competitors quit competing; (c) RONALD VAUGHN was not aware of any discussion at the Holiday Inn where the idea of ending competition between Jack Weingold and his companies and DeMilta Iron & Metal was even proposed; (d) RONALD VAUGHN was not aware of any discussion at the Holiday Inn about a set volume of busheling being sold to DeMilta Iron & Metal; (e) RONALD VAUGHN was not aware that, at this Holiday Inn meeting, Jack Weingold suggested it was crazy for his companies and DeMilta Iron & Metal to continue competing against each other because all competition did was cost them money; (f) RONALD VAUGHN and the participants at the Holiday Inn meeting talked about continuing to compete against each other and continuing to go after each other's business; (g) RONALD VAUGHN, at the Holiday Inn meeting, talked about only three things: (1) the participants' intention not to physically touch, handle, or move each other's on-site boxes; (2) RONALD VAUGHN's and Francis DeMilta's intention to continue to compete against Jack Weingold and his companies; and (3) RONALD VAUGHN's and Francis DeMilta's intention to do some business with Jack Weingold, though no definite plans were discussed or even proposed about DeMilta Iron & Metal's buying busheling from Weingold Company; (h) RONALD VAUGHN, either at the Holiday Inn meeting or at some later time, never talked to Loren Margolis about specific scrap metal accounts, including ETS, Solon Industrial, Bison Welding, or Superior Quality; (i) RONALD VAUGHN never heard or used the terminology in talking to Loren Margolis, or anyone at M. Weingold or Rock, that "blue equals blue," "black equals blue," "brown equals blue," and "green equals green," which was a short-hand way the co-conspirators used to refer to their agreement to allocate scrap metal suppliers; (j) RONALD VAUGHN did not meet with Loren Margolis and Mark Weingold at the Holiday Inn on Wilson Mills Road, or any other place other than at DeMilta Iron & Metal's yard, nor did RONALD VAUGHN ever meet with Loren Margolis and Mark Weingold and talk about the tonnage arrangement on busheling needing to be increased from 150 tons to a higher level after Jack Weingold bought Atlas Lederer; (k) RONALD VAUGHN did not complain to either Loren Margolis or Mark Weingold that the 150-ton per month busheling arrangement i.e., the quid pro quo pay-off in return for the agreement between DeMilta Iron & Metal and their co-conspirators not to solicit each other's scrap metal suppliers was no longer satisfactory, since Jack Weingold, after buying Atlas Lederer, now controlled an even larger share of the market; (l) RONALD VAUGHN never complained to Howard Bahm, a Rock official, that the 150-ton per month busheling arrangement was no longer satisfactory after Jack Weingold bought Atlas Lederer; (m) No agreement was struck at the Holiday Inn, or at some later time, that DeMilta Iron & Metal would lay off M. Weingold and Rock accounts in return for M. Weingold and Rock laying off DeMilta Iron & Metal accounts; (n) There was never an agreement or understanding reached at any time, either at the Holiday Inn meeting or some later time, between DeMilta Iron & Metal and M. Weingold, including any of its affiliated companies, not to compete with each other, or to compete less vigorously than the companies would have competed but for their collusive agreement; or that DeMilta Iron & Metal would not solicit M. Weingold or Weingold-affiliated scrap metal suppliers in return for M. Weingold not soliciting DeMilta Iron & Metal scrap metal suppliers; (o) At the Holiday Inn meeting in which RONALD VAUGHN participated along with Francis DeMilta, Jack Weingold, and Loren Margolis, there was no discussion or mention of the possibility that M. Weingold would sell 150 tons of busheling to DeMilta Iron & Metal, nor was there any discussion about the possibility that busheling would be sold to DeMilta Iron & Metal by M. Weingold Company at $25 under the prevailing Iron Age price; (p) RONALD VAUGHN never met with Mark Weingold, Loren Margolis, and Francis DeMilta at the Holiday Inn off of Wilson Mills Road; (q) RONALD VAUGHN never talked to Jack Weingold, Loren Margolis, Mark Weingold, or Howard Bahm about Jack Weingold's purchase of Best Atlas or about Best Atlas accounts; (r) RONALD VAUGHN never gave any direction or instruction to Jarrod Mink, a former DeMilta Iron & Metal employee, related to an account called Commercial Honing; (s) RONALD VAUGHN never gave any instruction or direction to any trader or salesman or buyer of DeMilta Iron & Metal to lay off M. Weingold or Rock business; (t) RONALD VAUGHN was not privy to whether the increase in monthly busheling sales to DeMilta Iron & Metal by M. Weingold was related in any way to Jack Weingold's acquisition of Atlas Lederer; (u) RONALD VAUGHN never directed Jarrod Mink, or Phil Zelznick, or any other employee of DeMilta Iron & Metal, to generate false or phony or inaccurate weight tickets; and (v) RONALD VAUGHN never altered the weight of a truck to help establish a false tare weight, that was then used to pay one of DeMilta Iron & Metal's scrap metal suppliers. 83. It was further part of the corrupt endeavor that, at the time RONALD VAUGHN testified and made each of the above-described materially false and intentionally, misleading, and deceiving statements and representations to the Grand Jury, RONALD VAUGHN was then and there aware and knew that they were false and misleading and deceiving, in that: (a) RONALD VAUGHN, through his direct participation as a co-conspirator, was aware of an agreement or understanding between DeMilta Iron & Metal and its co-conspirators, M. Weingold, Rock, and their officials that they would allocate and not solicit each other's scrap metal suppliers, and that M. Weingold would make monthly busheling sales to DeMilta Iron & Metal at a price $25 below the prevailing Iron Age price; (b) RONALD VAUGHN, through his direct participation as a co-conspirator, was aware that, at the conclusion of a meeting at the Holiday Inn, there was an agreement or understanding between DeMilta Iron & Metal and co-conspirators that they would not solicit each other's scrap metal suppliers, and, further, RONALD VAUGHN was aware that not only had such a proposal been made at the Holiday Inn meeting, it was acted upon; (c) RONALD VAUGHN, through his direct participation as a co-conspirator, was aware of a discussion at the Holiday Inn where the idea of ending competition between Jack Weingold and his companies and DeMilta Iron & Metal was proposed; (d) RONALD VAUGHN, through his direct participation as a co-conspirator, was aware of a discussion at the Holiday Inn about a set volume of busheling being sold to DeMilta Iron & Metal; (e) RONALD VAUGHN, through his direct participation as a co-conspirator, was aware that, at this Holiday Inn meeting, Jack Weingold suggested it was crazy for his companies and DeMilta Iron & Metal to continue competing against each other because all that was doing was costing them money; (f) RONALD VAUGHN, through his direct participation as a co-conspirator, was aware that, at the Holiday Inn meeting in August 1997, with RONALD VAUGHN, Francis DeMilta, Jack Weingold, and Loren Margolis all present, there was no talk or discussion among these co-conspirators about M. Weingold and DeMilta Iron & Metal continuing to compete against each other or continuing to go after each other's business, rather the discussion at this meeting involved ending competition between the companies; (g) RONALD VAUGHN, through his direct participation as a co-conspirator, was aware that, at the Holiday Inn meeting in August 1997, with RONALD VAUGHN, Francis DeMilta, Jack Weingold, and Loren Margolis all present, these co-conspirators talked about more than just the three things described by RONALD VAUGHN in his Grand Jury testimony, in fact they talked about and then agreed to allocate and not solicit each other's scrap metal suppliers and they talked about and then agreed that M. Weingold would sell busheling to DeMilta Iron & Metal monthly at a price $25 under Iron Age. (h) RONALD VAUGHN, through his direct participation as a co-conspirator, either at the Holiday Inn meeting or at some later time, did talk to Loren Margolis about specific scrap metal accounts, including ETS, Solon Industrial, Bison Welding, and Superior Quality; (i) RONALD VAUGHN, through his direct participation as a co-conspirator, did hear or use certain terminology in talking to Loren Margolis, and at least one other M. Weingold official, namely, that "blue equals blue," "black equals blue," "brown equals blue," "green equals green," which was a short-hand way of referring to the supplier allocation agreement between DeMilta Iron & Metal and M. Weingold and Rock; (j) RONALD VAUGHN, through his direct participation as a co-conspirator, did meet with Loren Margolis and Mark Weingold at the Holiday Inn on Wilson Mills Road, not just at DeMilta Iron & Metal's yard, and RONALD VAUGHN did meet with Loren Margolis and Mark Weingold and talked about the monthly sales of busheling from M. Weingold to DeMilta Iron & Metal needing to be increased from 150 tons to a higher tonnage level; (k) RONALD VAUGHN, through his direct participation as a co-conspirator, did complain to Loren Margolis and Mark Weingold that the 150-ton per month busheling arrangement was no longer satisfactory after Jack Weingold bought Atlas Lederer; (l) RONALD VAUGHN, through his direct participation as a co-conspirator, did complain to Howard Bahm, a Rock official, that the 150-ton per month busheling arrangement was no longer satisfactory after Jack Weingold bought Atlas Lederer; (m) RONALD VAUGHN, through his direct participation as a co-conspirator, was aware that an agreement was struck at the Holiday Inn in August 1997 and that, pursuant to this collusive agreement, DeMilta Iron & Metal would lay off M. Weingold and Rock scrap metal suppliers, and, in return, M. Weingold and Rock would lay off DeMilta Iron & Metal scrap metal suppliers, and, further, that M. Weingold would, in return for DeMilta Iron & Metal's not soliciting the scrap suppliers of M. Weingold and its affiliated companies, sell busheling to DeMilta Iron & Metal on a monthly basis at a price $25 under the prevailing Iron Age price; (n) RONALD VAUGHN, through his direct participation as a co-conspirator, was aware that an agreement or understanding was reached at the Holiday Inn between DeMilta Iron & Metal and M. Weingold and its affiliated companies not to compete against each other; (o) RONALD VAUGHN, through his direct participation as a co-conspirator, was aware that, at the Holiday Inn meeting, the co-conspirators talked about the possibility that M. Weingold Company would sell a set volume of busheling to DeMilta Iron & Metal, and, further, that it would be sold at a price $25under the Iron Age price; (p) RONALD VAUGHN, through his direct participation as a co-conspirator, did meet with Mark Weingold, Loren Margolis, and Francis DeMilta at the Holiday Inn; (q) RONALD VAUGHN, through his direct participation as a co-conspirator, did talk to Jack Weingold, Loren Margolis, Mark Weingold, and/or Howard Bahm about Jack Weingold's purchase of Best Atlas and Best Atlas accounts; (r) RONALD VAUGHN, through his direct participation as a co-conspirator, did give direction or instruction to Jarrod Mink, a former employee of DeMilta Iron & Metal, related to an account called Commercial Honing; (s) RONALD VAUGHN, through his direct participation as a co-conspirator, did give instruction or direction to traders or salesmen or buyers of DeMilta Iron & Metal to lay off M. Weingold or Rock business; (t) RONALD VAUGHN, through his direct participation as a co-conspirator, was, in fact, privy to whether the increase in monthly busheling sales to DeMilta Iron & Metal by M. Weingold Company was related to Jack Weingold's acquisition of Atlas Lederer; in fact, as RONALD VAUGHN well knew, these increased busheling sales were directly related to meetings and discussions that RONALD VAUGHN had with Loren Margolis and Mark Weingold, during which RONALD VAUGHN complained that the busheling quid pro quo pay off was unfair after Jack Weingold bought Atlas Lederer, and that it needed to be increased or DeMilta Iron & Metal would end the collusive agreement and begin competing with M. Weingold and its affiliated companies; (u) RONALD VAUGHN did direct Jarrod Mink and Phil Zelznick, both former employees of DeMilta Iron & Metal, to generate false or phony or inaccurate weight tickets; and (v) RONALD VAUGHN did alter the weight of a truck to help establish a false tare weight, which was then used to establish an inaccurate unit weight used to pay a DeMilta Iron & Metal scrap metal supplier.
84. This corrupt endeavor to influence, obstruct, and impede the due administration of justice, which did, in fact, impede the due administration of justice, was carried out by the Defendant RONALD VAUGHN in the Northern District of Ohio within five years preceding the return of this Indictment. ALL IN VIOLATION OF TITLE 18, UNITED STATES CODE, SECTION
1503.
Original document Signatures on file with the Clerk of Courts, pursuant to the E-Government Act of 2002. UNITED STATES OF AMERICA v. ALLIANCE NATIONAL LIMITED PARTNERSHIP,
d/b/a DEMILTA IRON & METAL, LTD; FRANCIS DEMILTA; and RONALD VAUGHN
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