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Affidavit in Support of Search and Seizure WarrantsI. Purpose of the Affidavit
This affidavit is submitted in support of applications for two search warrants andone seizure warrant. It also will be submitted in support of a complaint for civil forfeitureof real property and the contents of bank accounts. Based on the following information,I submit that there is probable cause to believe that John ZORZIT and Nick'sAmusements did knowingly and unlawfully conduct an illegal gambling business inviolation of 18 U.S.C. section 1955.I submit that there is also probable cause to believe that John ZORZIT and Nick'sAmusements did knowingly and unlawfully conduct, attempt to conduct, and causeothers to conduct financial transactions affecting interstate commerce that involved theproceeds of a specified unlawful activity, that is an illegal gambling business, knowingthat the transactions were designed in whole or in part to conceal or disguise the nature,the location, the source, the ownership, and the control of those proceeds, and knowingthat the property involved in the financial transactions was the proceeds of some form ofunlawful activity, in violation of 18 U.S.C. sections 1956(a)(1 )(B)(i) and 1957.I submit that there is also probable cause to believe that the items described on
Attachment A
constitute evidence, fruits, and instrumentalities of the above-describedoffenses and are likely to be found in the following tvllOlocations:a. 8100 Harford Road, Baltimore, Maryland 21234, known as the businesslocation of Nick's Amusements, Inc.b. 18 Brett Manor Cour:t, Cockeysville, Maryland 21030, known as theresidence of ZORZIT.I submit that there is also probable cause to believe that the contents of thefollowing accounts include illegal gambling funds uSledin violation of 18 U.S.C. section1955, which are subject to seizure and forfeiture pursuant to 18 U.S.C. section 1955(d),and that the contents of the following accounts also have been involved in transactionsin violation of 18 U.S.C. section 1956(a)(1 )(B)(i) and section 1957, and, therefore, thecontents of those accounts are subject to seizure and forfeiture pursuant to 18 U.S.C.sections 981(a)(1)(A) and 984:a. Bank of America business account number 0039-2723-2479 in the nameof Nick's Amusements, Inc., Florida.b. Bank of America business account number 0039-3307-6137 in the nameof Nick's Amusements, Inc., Music Account.c. Bank of America business account number 0044-6704-3897 in the nameof Nick's Amusements, Inc., General Account.
 
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d. Bank of America business account number 0039-3396-8753 in the nameof Nick's Amusements, Inc., Loan Account.e. Bank of America business account number 0039-3836-8138 in the nameof Nick's Amusements, Inc., Tournament.f. Bank of America business account number 0039-3836-8455 in the nameof Norino Properties, LLC.g. Bank of America business account number 0039-2466-3397 in the nameof Norino Properties, LLC, Number 2.h. Bank of America business account number 0039-2466-2796 in the nameof Norino Properties, LLC,
T/A
Stoneybrook Veranda Green, Unit 1524.i. Bank of America business account number 0039-2466-2806 in the nameof Norino Properties, LLC,
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Clubside Circle. j. Bank of America business account number 0039-3723-5453 in the nameof Nerino Properties
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Construction, Inc.k. Bank of America business account number 0044-6704-3606 in the nameof Norino Management, Inc., General Account.I. Bank of America business account number 0039-3836-9580 in the nameof Balsamo And Norino Properties, LLC.m. Bank of America business account number 0039-3723-4700 in the nameof Balsamo-Norino Properties, LLC.n. Bank of America business account number 0039-2466-2864 in the nameof Balsamo-Norino Properties, LLC, Number 2.I submit that there is also probable cause to believe that the cash proceeds of theillegal gambling business, which are forfeitable pursuant to 18 U.S.C. section 1955(d),are traceable into the purchase of the following real properties, and that these realproperties are, therefore, subject to forfeiture pursuant to 18 U.S.C. section981(a)(1)(C); I submit that the purchase of the real properties with the proceeds ofspecified unlawful activity is a financial transaction in violation of 18 U.S.C. section1956(a)(1 )(B)(i), and, therefore, the real properties, which were involved in suchtransactions, are also subject to forfeiture pursuant to 18 U.S.C. section 981(a)(1)(A):a. 2709 Washington Boulevard, Baltimore, Maryland.b. 18 Brett Manor Court, Hunt Valley, Maryland.c. 1122 West Baltimore Street, Baltimore, Maryland.d. 29948 Garrett Highway, Accident, Maryland.e. 43 Fire Tower Road, Friendsville, Maryland.
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202 Teaberry Lane, Accident, Maryland.g. 216 East Alder Street, Garrett, Maryland.h. 6900 Belair Road, Baltimore, Maryland.i. 409 Eastern Avenue, Essex, Maryland.
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1112 Beech Drive, Middle River, Maryland.k. 424 South Payson Street, Baltimore, Maryland.
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I. 8100 Harford Road, Baltimore, Maryland.m. 408 Ingleside Avenue, Catonsville, Maryland.n. 194 Unz Lane, Swanton, Maryland.o. 532 North Montford Avenue, Baltimore, Maryland.p. 14 Stillwater Drive (lot 17), Swanton, Maryland.q. 10 Warren Road, Cockeysville, Maryland 21030.
II. Affiant
I am a Special Agent with the Internal Revenue Service (IRS), CriminalInvestigation Division (CID), and have served in that capacity since December of 2003.Your affiant's official responsibilities include conducting investigations of possiblecriminal violations of Internal Revenue Laws (Title 26 of the United States Code), theBank Secrecy Act (Title 31 of the United States Code), the Money Laundering ControlAct (Title 18 of the United States Code) and related offenses. Your affiant hassuccessfully completed Criminal Investigator Training and Special Agent InvestigativeTechniques Training at the Federal Law Enforcement Training Center. The trainingincluded courses in financial investigative techniques, accounting, tax, criminalinvestigation techniques, criminal law and search warrants.Immediately prior to becoming a Special Agent, your affiant was employedapproximately ten months as a Special Agent Student Trainee with IRS-CI. As aSpecial Agent Student Trainee, your affiant's responsibilities included assisting SpecialAgents with investigations, by analyzing bank, re!cords, reconciling tax returns toavailable books and records and conducting interviews of principals, witnesses andothers. Your affiant has a Bachelor of Science Degree, majoring in ManagementScience with a concentration in Accounting.I have participated in the execution of numerous search and seizure warrants.These included searches of residences, businesses and safe deposit boxes. Materialssought and seized during execution of these warrants included records pertaining to theincome and expenditures of businesses and individuals, currency, monetaryinstruments and assets.
III. Applicable Statutes
The following federal and state statutes are applicable to this affidavit:18 U,S.C. Section 1955. Prohibition of an Illegal Gambling Business:(a) Whoever conducts, finances, manages, supervises, directs, or owns all orpart of an illegal gambling business [has violated the criminal laws of the UnitedStates].(b) As used in this section-
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