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 Fight For Justice

On the Keweenaw Bay Indian Community Reservation


1996-06-26 -- Fred Dakota Indictment


Fred Dakota indicted in Marquette, Michigan


June 26, 1996

Contact:           Judd R. Spray
                   Assistant U.S. Attorney
                   (906) 226-2500

          MARQUETTE, MICHIGAN - United States Attorney Michael
H.Dettmer announced today that a federal grand jury sitting in
Marquette, Michigan, returned a 54-count felony indictment
against Mr. Frederick S. Dakota, the Tribal Chairman of the
Keweenaw Bay Indian Community ("KBIC") in Michigan's Upper
Peninsula and Mr. Jerrold L. Polinsky, a coconspirator from
Atlantic City, New Jersey.

          The 63-page federal indictment alleges that Mr.
Dakota, a 59-year-old resident of Baraga, Michigan, "owed a duty
of loyalty, honesty, and integrity to the Keweenaw Bay Indian
Community."  The indictment further alleges that from May 1991
through December 1993, Mr. Dakota breached his duty by
conspiring to accept over $125,000.00 in numerous payments
"intending to personally benefit and enrich himself through the
receipt of kick-backs."  The indictment also charges that Mr.
Dakota underpaid his federal income taxes from 1991 through 1993
when he filed false U.S. Income Tax Returns which "he did not
believe to be true and correct . . . ."

          The federal grand jury charges that Mr. Dakota's
codefendant, Mr. Jerrold L. Polinsky, a 65-year-old resident of
Atlantic City, New Jersey, conspired to pay and did unlawfully
pay Mr. Dakota for agreeing to lease video gaming machines from
the Minnesota corporation International Gaming Management,
otherwise known as "IGM."  According to the indictment, Mr.
Dakota allowed "IGM" to place video gaming machines in the
Ojibwa Casino in Baraga, Michigan.  The grand jury alleges that
Mr. Dakota negotiated contracts on behalf of his tribe which
required "KBIC" to pay "IGM" 35 percent of the profits generated
by the video gaming machines.  According to the indictment "IGM"
would then pay money to codefendant Jerrold Polinsky through his
business, Spectrum Communications.  The scheme was completed,
according to the grand jury, when Spectrum Communications would
then in turn pay Mr. Dakota his "kickbacks."  Finally, Mr.
Dakota did not report as income the $125,000.00 in "kickbacks,"
according to the grand jury.

          The federal indictment culminates a two-year-long
investigation of Mr. Dakota that began in July 1994 when
Minnesota federal and state authorities searched "IGM's" offices
and other locations and seized a number of documents.  The
office of the United States Attorney for the Western District of
Michigan has worked closely with U.S. Attorney David L.
Lillehaug in Minneapolis, Minnesota.

          U.S. Attorney Michael H. Dettmer directed that a
federal task force be formed consisting of the Office of
Inspector General for the U.S. Department of the Interior, the
Criminal Investigation Division of the Internal Revenue Service
(IRS), and the Federal Bureau of Investigation (FBI).  Assistant
U.S. Attorney Judd R. Spray is handling the prosecution.

          Mr. Dakota and Mr. Polinsky are each named in one
count of the indictment for conspiracy to commit an offense
against the United States, in violation of 18 U.S.C. 
This count is punishable by up to five years in federal custody
and a $250,000.00 fine.

          Mr. Polinsky and Mr. Dakota are each individually
charged in 25 counts with violations of 18 U.S.C. 
proscribing thefts or bribery concerning programs receiving
federal funds.  These counts are each punishable by up to ten
years in federal custody and a $250,000.00 fine.

          In addition Mr. Dakota is charged in 3 counts
proscribing fraud and false statements related to the filing of
U.S. income tax returns, in violation of 26 U.S.C. 
These counts are each punishable by up to three years in federal
custody and a $100,000.00 fine.

          Mr. Dettmer stressed that the charges in an indictment
are merely an accusation, and the defendants are presumed
innocent until and unless proven guilty in a court of law.


THE UNITED STATES OF AMERICA,

vs.
                                             INDICTMENT
FREDERICK S. DAKOTA and
JERROLD L. POLINSKY,

                    Defendants.
                               /

THE GRAND JURY CHARGES:

                          BACKGROUND

At all times material and relevant to this Indictment:

     a.   The Keweenaw Bay Indian Community ("KBIC") was a
recognized Indian tribe organized under a Constitution and By-
laws approved by the Secretary of the Interior.  The KBIC Tribal
Council was the Community's governing body and is comprised of
12 members elected by popular ballot by the members of the
Keweenaw Bay Indian Community.

     b.   Defendant FREDERICK S. DAKOTA, was the elected Tribal
Chairman of the KBIC Tribal Council from 1990 to the present.
As Tribal Chairman, defendant Dakota was responsible for
presiding over all Tribal Council meetings and maintaining
general supervision of the affairs of the Tribal Council and
such matters as naturally pertained to the general welfare of
the Keweenaw Bay Indian Community and owed a duty of loyalty,
honesty, and integrity to the Keweenaw Bay Indian Community,
which required Dakota to conduct the affairs of the KBIC and his
personal affairs in such a manner that those two interests would
not compete nor conflict.

     c.   The United States Department of the Interior was an
agency of the United States.

     d.   The Bureau of Indian Affairs was a part of the
Department of the Interior and was delegated the authority,
under the direction of the Secretary of the Interior, to manage
the affairs and matters arising from the relations between the
United States and Indians.  Pursuant to Title 25, United States
Code, Section 2, the Secretary of the Interior is delegated the
authority to manage all Indian affairs and all matters arising
from Indian relations.  In accordance with Title 25, United
States Code, Section 13, the Bureau of Indian Affairs, under the
supervision of the Secretary of Interior, is authorized to
direct, supervise, and expend such moneys as Congress may
appropriate for the benefit, care, and assistance of Indians in
the United States.

     e.   The Office of Inspector General, United States
Department of the Interior, under the general supervision of the
Secretary of the Interior, is responsible for conducting and
supervising audits and investigations relating to the programs
and operations of the Department of the Interior.  Special
Agents of the Office of  Inspector General are authorized to
investigate violations of the laws of the United States and the
regulations of the Department of the Interior.

     f.   The Keweenaw Bay Indian Community (KBIC), Baraga,
Michigan, received federal benefits in excess of $10,000 under
Federal programs administered by the Bureau of Indian Affairs
during each continuous 12 month period  beginning January 1,
1991, through and including the year ending December 31, 1993.

     g.   During fiscal year 1991, the Indian tribal government
of KBIC received benefits in excess of $10,000 under Federal
programs involving grants, contracts, and other forms of Federal
assistance, that is, approximately $316,000 from the United
States Department of the Interior, Bureau of Indian Affairs.

     h.   During fiscal year 1992, the Indian tribal government
of KBIC received benefits in excess of $10,000 under Federal
programs involving grants, contracts, and other forms of Federal
assistance, that is, approximately $817,000 from the United
States Department of the Interior, Bureau of Indian Affairs.

     i.   During fiscal year 1993, the Indian tribal government
of KBIC received benefits in excess of $10,000 under Federal
programs involving grants, contracts, and other forms of Federal
assistance, that is, approximately $1,158,000 from the United
States Department of the Interior, Bureau of Indian Affairs.

     j.   KBIC operated a gaming facility known as the Ojibwa
Casino on its reservation in Baraga, Michigan.  On or about
April 29, 1991, the KBIC Tribal Council passed a motion which
designated Tribal Chairman FREDERICK S. DAKOTA as agent to
pursue the acquisition of slot machines for use in the Ojibwa
Casino.

     k.   International Gaming Management, Inc. ("IGM") was a
publicly-held company incorporated under the laws of the State
of Delaware.  IGM maintained operations in Minnesota and Nevada
and was involved in the gaming business by providing management
services to Indian tribal gaming operations and by leasing or
selling electronic gaming devices for use in Indian tribal
gaming operations.

     l.   JERROLD LOUIS POLINSKY was a shareholder of IGM and
personally benefitted from the business of IGM.  He was actively
involved in the business affairs of and served as a "consultant"
to IGM.

     m.   In or about May, 1991, electronic gaming devices owned
by IGM were placed in the Ojibwa Casino pursuant to a lease
agreement for such machines executed by IGM and defendant
FREDERICK S. DAKOTA as Tribal Chairman and agent for KBIC.  From

May, 1991, to August, 1993, the lease agreement provided that
IGM would receive 35 percent of the gross revenue from such
devices and KBIC would receive 65 percent of the gross revenue.
The original lease agreement was subsequently modified and from
August, 1993, through December, 1993, the terms of the lease
agreement provided that IGM would receive 30 percent of the
revenue from such devices and KBIC would receive 70 percent of
the revenue.

     n.   Beginning on or about June 4, 1991, and continuing
thereafter through December, 1993, pursuant to the terms of the
lease agreement referred to above KBIC made weekly payments in
varying amounts to IGM based on the revenues generated by the
gaming devices KBIC leased from IGM.  The total of such payments
for the period from on or about June 4, 1991, through August 15,
1993, was approximately $4,268,252, representing 35 percent of
the gross revenues from gaming devices leased by KBIC from IGM
between May, 1991, through August 15, 1993.  The total of such
payments for the period from August 16, 1993, through December,
1993, was approximately $841,972, representing 30 percent of
such revenues from August 16, 1993, through December, 1993.

     o.   Spectrum Communications, Inc. (Spectrum) was
incorporated under the laws of the State of Minnesota and was
created as an inter-active telephone communications company with
a "900 Line" which would facilitate the operation of a national
telephone lottery known as the Fortune Bay Lottery from the Bois
Forte Indian Reservation located in Minnesota.  JERROLD LOUIS
POLINSKY was the President    of Spectrum and maintained control
over the company.

     p.   Doris Haataja was a resident of Baraga, Michigan and
a social friend and business acquaintance of defendant FREDERICK
S. DAKOTA.

                           COUNT 1
                         (Conspiracy)

     Beginning in or about May, 1991, and continuing up to in or
about December, 1993, the exact dates being unknown to the Grand
Jury, within the Western District of Michigan, Northern
Division, the defendants,

                   FREDERICK S. DAKOTA, and
                      JERROLD L. POLINSKY

hereinafter called the defendants, together with each other and
with others known and unknown to the Grand Jury, did unlawfully
conspire, combine, confederate, and agree together and with each
other to commit offenses against the United States, that is to
corruptly give and corruptly accept things of value with intent
to influence and to be influenced and to reward defendant
FREDERICK S. DAKOTA, an agent of an Indian tribal government, in
connection with a business, transaction, and series of
transactions, that is the leasing and placement of electronic
gaming devices in and on the Keweenaw Bay Indian Community's
Ojibwa Casino in violation of  Title 18, United States Code,
Sections 666(a)(1)(B) and 666(a)(2).

                   OBJECTS OF THE CONSPIRACY

     The objects of the conspiracy were to violate the federal
statute listed above, to bring about personal financial gain by
unlawful means for defendants FREDERICK S. DAKOTA and JERROLD L.
POLINSKY and others known and unknown, to deprive the Keweenaw
Bay Indian Community of the loyal, honest and faithful services
of defendant FREDERICK S. DAKOTA, and to cover-up the conspiracy
and the violations of the federal law.

                          OVERT ACTS
     In furtherance of the conspiracy and to effect the objects
of the conspiracy, the defendants and others known and unknown
did commit the following overt acts, among others:

     1.   In or about May, 1991, the exact date unknown to the
Grand Jury, IGM and Spectrum agreed that Spectrum would deal
exclusively with and through IGM in return for which IGM agreed
to pay a fee to Spectrum  of 5 percent of the total revenues
received by IGM from all gaming devices leased by IGM to Indian
tribes in the State of Michigan.

     2.   In or about May, 1991, defendant FREDERICK S. DAKOTA,
as agent for KBIC, executed a lease agreement with IGM according
to which KBIC agreed to lease 100 video gaming machines from IGM
to be installed at the Ojibwa Casino.  Defendant FREDERICK S.
DAKOTA, intending to personally benefit and enrich himself
through the receipt of kick-backs to be paid to him by defendant
JERROLD L. POLINSKY from Spectrum's share of the revenues
generated by the video gaming machines to be leased by KBIC from
IGM, agreed that KBIC would pay 35 percent of the gross profits
from the machines to IGM, a greater share of its gaming revenues
than was paid by other tribes which leased gaming machines from
IGM at or about the same time, and KBIC would receive 65 percent
of the gross profits from the machines.

     3.   On or about June 15, 1991, for the purpose of
facilitating the payment of a portion of Spectrum's share of the
lease payments received by IGM from KBIC to defendant FREDERICK
S. DAKOTA, Spectrum , through its President, JERROLD L.
POLINSKY, and IGM, through its President, Douglas Polinsky,
executed a written agreement which provided that Spectrum  as
"Agent" intended to place/finance gaming devices in the State of
Michigan and IGM as "Distributor" agreed to pay 5 percent of the
total revenues from any IGM gaming devices placed by Spectrum.

     4.   Beginning on or about May 24, 1991 and on various
dates thereafter unknown to the Grand Jury, IGM installed
electronic gaming machines at KBIC's Ojibwa Casino pursuant to
the above lease agreement executed by defendant FREDERICK S.
DAKOTA, as agent for KBIC, and IGM.

     5.   IGM subsequently installed additional electronic
gaming machines at KBIC's Ojibwa Casino on various dates unknown
to the Grand Jury between May, 1991 and October, 1993, to a
total of approximately 207 machines by October 7, 1993, the
revenues derived from which were split according to the terms of
the original lease agreement and the lease agreement as modified
in August, 1993.

     6.   On or about June 14, 1991, IGM, having received a
payment from KBIC pursuant to the lease agreement referred to
above in the amount of $12,361.48 for the revenue period May 24,
1991, to June 9, 1991, issued a check made payable to Mr. Jerry
Polinsky in the amount of $630, an amount equal to approximately
5 percent of the payment made by KBIC to IGM, which check was
then deposited on or about June 17, 1991, into an account of
Spectrum.

     7.   On or about June 20, 1991, defendant JERROLD L.
POLINSKY signed a check drawn on an account of Spectrum in the
amount of $620 made payable to Fred Dakota and caused the same
to be delivered to defendant FREDERICK S. DAKOTA who negotiated
it through an account belonging to Doris Haataja at the Baraga
County Federal Credit Union, L'Anse, Michigan.

     8.   On or about June 28, 1991, IGM, having received a
payment from KBIC pursuant to the lease agreement referred to
above in the amount of $13,881.96 for the revenue period June
10, 1991, to June 23, 1991, issued a check made payable to Mr.
Jerry Polinsky in the amount of $710.00, an amount equal to
approximately 5 percent of the payment made by KBIC to IGM,
which check was then deposited on or about July 3, 1991, into an
account of Spectrum.

     9.   On or about June 28, 1991, defendant JERROLD L.
POLINSKY signed a check drawn on an account of Spectrum in the
amount of $694 made payable to Fred Dakota and caused the same
to be delivered to defendant FREDERICK S. DAKOTA who negotiated
it through an account belonging to Doris Haataja at the Baraga
County Federal Credit Union, L'Anse, Michigan.

     10.  From June 27, 1991, through December 29, 1993, IGM
disbursed approximately $257,388 to Spectrum of which amount
approximately $255,123 was derived from KBIC's lease payments to
IGM.

     11.  Between June 20, 1991, and December 27, 1993,
defendant FREDERICK S. DAKOTA received from defendant JERROLD L.
POLINSKY checks drawn on accounts of Spectrum  made payable to
"Fred Dakota" and signed by "Jerry Polinsky" as the maker or
drawer thereof as follows:

    Date       Check No.  Payee          Amount

  06-20-91     1013    Fred Dakota       $620
  06-28-91     1015    Fred Dakota       $694
  07-03-91     1017    Fred Dakota       $530
  07-25-91     1021    Fred Dakota       $1,410
  08-19-91     1029    Fred Dakota       $948
  09-19-91     1043    Fred Dakota       $1,550
  10-31-91     1050    Fred Dakota       $2,330
  11-12-91     1057    Fred Dakota       $3,145
  01-06-92     1062    Fred Dakota       $4,887
  02-25-92     1077    Fred Dakota       $5,904
  03-25-92     1098    Fred Dakota       $5,125
  04-24-92     1120    Fred Dakota       $4,590
  06-01-92     1154    Fred Dakota       $6,275
  07-07-92     1176    Fred Dakota       $6,700
  07-27-92     1194    Fred Dakota       $6,400
  08-14-92     1213    Fred Dakota       $7,550
  09-23-92     1253    Fred Dakota       $7,125
  11-24-92     1310    Fred Dakota       $5,350
  02-24-93     1042    Fred Dakota       $7,945
  04-11-93     1084    Fred Dakota       $8,250
  05-20-93     1142    Fred Dakota       $6,750
  06-25-93     1187    Fred Dakota       $6,569
  08-16-93     1239    Fred Dakota       $7,140
  10-01-93     1287    Fred Dakota       $6,071
  11-03-93     1316    Fred Dakota       $6,150
  12-27-93     1372    Fred Dakota       $7,250


$127,258


     12.  Defendant JERROLD L. POLINSKY attempted to conceal and
disguise the nature of the funds paid to defendant FREDERICK S.
DAKOTA by Spectrum, which funds were based on the revenues
derived from IGM's lease agreement with KBIC by causing the
above checks to bear the following notations, "FBL Consulting,"
"Consulting FBL," "Fortune Lottery Consulting" and "FBL
Consulting Fee" the same being a reference to Fortune Bay
Lottery, an enterprise having no relation to KBIC.

     13.  Defendant FREDERICK S. DAKOTA concealed the true
nature of his financial transactions with IGM, Spectrum, and
defendant JERROLD L. POLINSKY by failing to inform KBIC's tribal
government that he was receiving monetary payments from Spectrum
and defendant JERROLD L. POLINSKY which payments were based on
and related to revenues generated by electronic gaming machines
leased by KBIC from IGM.

Title 18, United States Code, Section 371.

The Grand Jury further charges:

                            Count 2

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about June 28, 1991, in the Western District of
Michigan, Northern Division, defendant JERROLD L. POLINSKY did
knowingly and corruptly give, offer, and agree to give something
of value to FREDERICK S. DAKOTA, that is, a check in the amount
of $694 drawn on an account of Spectrum made payable to "Fred
Dakota" and signed "Jerry Polinsky" as the maker and drawer
thereof, with intent to influence and reward FREDERICK S. DAKOTA
in connection with the business, transaction, and series of
transactions of KBIC involving something of value of $5,000 or
more.

Title 18, United States Code, Sections 666(a)(2)
Title 18, United States Code, Section 2.

                            Count 3

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully

set forth herein.

     2.   On or about June 28, 1991, in the Western District of
Michigan, Northern Division, defendant FREDERICK S. DAKOTA did
knowingly and corruptly solicit, demand, accept, and agree to
accept something of value from JERROLD L. POLINSKY, that is, a
check in the amount of $694 drawn on an account of Spectrum and
made payable to "Fred Dakota" and signed "Jerry Polinsky" as the
maker and drawer thereof, intending to be influenced and
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B)
Title 18, United States Code, Section 2.


                            Count 4

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about July 3, 1991, in the Western District of
Michigan, Northern Division, defendant JERROLD L. POLINSKY did
knowingly and corruptly give, offer, or agree to give something
of value to FREDERICK S. DAKOTA, that is, a check in the amount
of $530  drawn on an account of Spectrum and made payable to
"Fred Dakota" and signed by "Jerry Polinsky" as the maker and
drawer thereof, with intent to influence or reward FREDERICK S.
DAKOTA in connection with the business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(2)
Title 18, United States Code, Section 2

                            Count 5

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully

set forth herein.

     2.   On or about July 3, 1991, in the Western District of
Michigan, Northern Division, defendant FREDERICK S. DAKOTA did
knowingly and corruptly solicit, demand, accept, and agree to
accept something of value from JERROLD L. POLINSKY, that is, a
check in the amount of $530, drawn on an account of Spectrum and
made payable to "Fred Dakota" and signed by "Jerry Polinsky" as
the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B).
Title 18, United States Code, Section 2.


                            Count 6

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about July 25, 1991, in the Western District of
Michigan, Northern Division, defendant JERROLD L. POLINSKY did
knowingly and corruptly give, offer, or agree to give something
of value to FREDERICK S. DAKOTA, that is, a check in the amount
of $1,410 drawn on an account of Spectrum and made payable to
"Fred Dakota" and signed by "Jerry Polinsky" as the maker and
drawer thereof, with intent to influence or reward FREDERICK S.
DAKOTA in connection with the business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Section 666(a)(2)
Title 18, United States Code, Section  2


                            Count 7

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about July 25, 1991, in the Western District of
Michigan, Northern Division, defendant FREDERICK S. DAKOTA did
knowingly and corruptly solicit, demand, accept, and agree to
accept something of value from JERROLD L. POLINSKY, that is, a
check in the amount of $1,410  drawn on an account of Spectrum
and made payable to "Fred Dakota" and signed by "Jerry Polinsky"
as the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Section 666(a)(1)(B)
Title 18, United States Code, Section 2.

                            Count 8

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about August 19, 1991, in the Western District
of Michigan, Northern Division, defendant JERROLD L. POLINSKY
did knowingly and corruptly give, offer, or agree to give
something of value to FREDERICK S. DAKOTA, that is, a check in
the amount of $948  drawn on an account of Spectrum and made
payable to "Fred Dakota" and signed by "Jerry Polinsky" as the
maker and drawer thereof, with intent to influence or reward
FREDERICK S. DAKOTA in connection with the business,
transaction, and series of transactions of KBIC involving
something of value of $5,000 or more.

Title 18, United States Code, Sections 666(a)(2).
Title 18, United States Code, Section 2.

                            Count 9

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about August 19, 1991, in the Western District
of Michigan, Northern Division, defendant FREDERICK S. DAKOTA
did knowingly and corruptly solicit, demand, accept, and agree
to accept something of value from JERROLD L. POLINSKY, that is,
a check in the amount of $948 drawn on an account of Spectrum
and made payable to "Fred Dakota" and signed by "Jerry Polinsky"
as the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B)
Title 18, United States Code, Section 2.


                           Count 10

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about September 19, 1991, in the Western
District of Michigan, Northern Division, defendant JERROLD L.
POLINSKY did knowingly and corruptly give, offer, or agree to
give something of value to FREDERICK S. DAKOTA, that is, a check
in the amount of $1,550  drawn on an account of Spectrum and
made payable to "Fred Dakota" and signed by "Jerry Polinsky" as
the maker and drawer thereof, with intent to influence or reward
FREDERICK S. DAKOTA in connection with the business,
transaction, and series of transactions of KBIC involving
something of value of $5,000 or more.

Title 18, United States Code, Sections 666(a)(2).
Title 18, United States Code, Section 2.


                           Count 11

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about September 19, 1991, in the Western
District of Michigan, Northern Division, defendant FREDERICK S.
DAKOTA did knowingly and corruptly solicit, demand, accept, and
agree to accept something of value from JERROLD L. POLINSKY,
that is, a check in the amount of $1,550 drawn on an account of
Spectrum and made payable to "Fred Dakota" and signed by "Jerry
Polinsky" as the maker and drawer thereof, intending to be
influenced or rewarded in connection with a business,
transaction, amd series of transactions of KBIC involving
something of value of $5,000 or more.

Title 18, United States Code, Sections 666(a)(1)(B)
Title 18, United States Code, Section 2.

                           Count 12

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about October 31, 1991, in the Western District
of Michigan, Northern Division, defendant JERROLD L. POLINSKY
did knowingly and corruptly give, offer, or agree to give
something of value to FREDERICK S. DAKOTA with intent to
influence or reward FREDERICK S. DAKOTA, that is, a check in the
amount of $2,330 drawn on an account of Spectrum and made
payable to "Fred Dakota" and signed by "Jerry Polinsky" as the
maker and drawer thereof, in connection with the business,
transaction, and series of transactions of KBIC involving
something of value of $5,000 or more.

Title 18, United States Code, Sections 666(a)(2).
Title 18, United States Code, Section 2.

                           Count 13

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about October 31, 1991, in the Western District
of Michigan, Northern Division, defendant FREDERICK S. DAKOTA
did knowingly and corruptly solicit, demand, accept, and agree
to accept something of value from JERROLD L. POLINSKY, that is,
a check in the amount of $2,330 drawn on an account of Spectrum
and made payable to "Fred Dakota" and signed by "Jerry Polinsky"
as the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B)
Title 18, United States Code, Section 2.

                           Count 14

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about November 12, 1991, in the Western District
of Michigan, Northern Division, defendant JERROLD L. POLINSKY
did knowingly and corruptly give, offer, or agree to give
something of value to FREDERICK S. DAKOTA, that is, a check in
the amount of $3,145 drawn on an account of Spectrum and made
payable to "Fred Dakota" and signed by "Jerry Polinsky" as the
maker amd drawer thereof, with intent to influence or reward
FREDERICK S. DAKOTA in connection with the business,
transaction, and series of transactions of KBIC involving
something of value of $5,000 or more.

Title 18, United States Code, Sections 666(a)(2).
Title 18, United States Code, Section 2.

                           Count 15

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about November 12, 1991, in the Western District
of Michigan, Northern Division, defendant FREDERICK S. DAKOTA
did knowingly and corruptly solicit, demand, accept, and agree
to accept something of value from JERROLD L. POLINSKY , that is,
a check in the amount of $3,145 drawn on an account of Spectrum
and made payable to "Fred Dakota" and signed by "Jerry Polinsky"
as the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B).
Title 18, United States Code, Section 2.

                           Count 16

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about January 6, 1992, in the Western District
of Michigan, Northern Division, defendant JERROLD L. POLINSKY
did knowingly and corruptly give, offer, or agree to give
something of value to FREDERICK S. DAKOTA, that is, a check in
the amount of $4,887 drawn on an account of Spectrum and made
payable to "Fred Dakota" and signed by "Jerry Polinsky" as the
maker and drawer thereof, with intent to influence or reward
FREDERICK S. DAKOTA in connection with the business,
transaction, and series of transactions of KBIC involving
something of value of $5,000 or more.

Title 18, United States Code, Sections 666(a)(2).
Title 18, United States Code, Section 2.

                           Count 17

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about January 6, 1992, in the Western District
of Michigan, Northern Division, defendant FREDERICK S. DAKOTA
did knowingly and corruptly solicit, demand, accept, and agree
to accept something of value from JERROLD L. POLINSKY, that is,
a check in the amount of $4,887 drawn on an account of Spectrum
and made payable to "Fred Dakota" and signed by "Jerry Polinsky"
as the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B).
Title 18, United States Code, Section 2.

                           Count 18

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about February 25, 1992, in the Western District
of Michigan, Northern Division, defendant JERROLD L. POLINSKY
did knowingly and corruptly give, offer, or agree to give
something of value to FREDERICK S. DAKOTA, that is, a check in
the amount of $5,904 drawn on an account of Spectrum and made
payable to "Fred Dakota" and signed by "Jerry Polinsky" as the
maker and drawer thereof, with intent to influence or reward
FREDERICK S. DAKOTA in connection with the business,
transaction, and series of transactions of KBIC involving
something of value of $5,000 or more,

Title 18, United States Code, Sections 666(a)(2)
Title 18, United States Code, Section 2.

                           Count 19

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about February 25, 1992, in the Western District
of Michigan, Northern Division, defendant FREDERICK S. DAKOTA
did knowingly and corruptly solicit, demand, accept, and agree
to accept something of value from JERROLD L. POLINSKY, that is,
a check in the amount of $5,904 drawn on an account of Spectrum
and made payable to "Fred Dakota" and signed by "Jerry Polinsky"
as the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B).
Title 18, United States Code, Section 2.

                           Count 20

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about March 25, 1992, in the Western District of
Michigan, Northern Division, defendant JERROLD L. POLINSKY did
knowingly and corruptly give, offer, or agree to give something
of value to FREDERICK S. DAKOTA , that is, a check in the amount
of $5,125 drawn on an account of Spectrum and made payable to
"Fred Dakota" and signed by "Jerry Polinsky" as the maker and
drawer thereof, with intent to influence or reward FREDERICK S.
DAKOTA in connection with the business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(2).
Title 18, United States Code, Section 2.

                           Count 21

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about March 25, 1992, in the Western District of
Michigan, Northern Division, defendant FREDERICK S. DAKOTA did
knowingly and corruptly solicit, demand, accept, and agree to
accept something of value from JERROLD L. POLINSKY, that is, a
check in the amount of $5,125 drawn on an account of Spectrum
and made payable to "Fred Dakota" and signed by "Jerry Polinsky"
as the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B).
Title 18, United States Code, Section 2.

                           Count 22

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about April 24, 1992, in the Western District of
Michigan, Northern Division, defendant JERROLD L. POLINSKY did
knowingly and corruptly give, offer, or agree to give something
of value to FREDERICK S. DAKOTA, that is, a check in the amount
of $4,590 drawn on an account of Spectrum and made payable to
"Fred Dakota" and signed by "Jerry Polinsky" as the maker and
drawer thereof, with intent to influence or reward FREDERICK S.
DAKOTA in connection with the business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(2).
Title 18, United States Code, Section 2.

                           Count 23

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about April 24, 1992, in the Western District of
Michigan, Northern Division, defendant FREDERICK S. DAKOTA did
knowingly and corruptly solicit, demand, accept, and agree to
accept something of value from JERROLD L. POLINSKY, that is, a
check in the amount of $4,590 drawn on an account of Spectrum
and made payable to "Fred Dakota" and signed by "Jerry Polinsky"
as the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B).
Title 18, United States Code, Section 2.

                           Count 24

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about June 1, 1992, in the Western District of
Michigan, Northern Division, defendant JERROLD L. POLINSKY did
knowingly and corruptly give, offer, or agree to give something
of value to FREDERICK S. DAKOTA, that is, a check in the amount
of $6,275 drawn on an account of Spectrum and made payable to
"Fred Dakota" and signed by "Jerry Polinsky" as the maker and
drawer thereof, with intent to influence or reward FREDERICK S.
DAKOTA in connection with the business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(2).
Title 18, United States Code, Section 2.

                           Count 25

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about June 1, 1992, in the Western District of
Michigan, Northern Division, defendant FREDERICK S. DAKOTA did
knowingly and corruptly solicit, demand, accept, and agree to
accept something of value from JERROLD L. POLINSKY, that is, a
check in the amount of $6,275 drawn on an account of Spectrum
and made payable to "Fred Dakota" and signed by "Jerry Polinsky"
as the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B).
Title 18, United States Code, Section 2.

                           Count 26

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about July 7, 1992, in the Western District of
Michigan, Northern Division, defendant JERROLD L. POLINSKY did
knowingly and corruptly give, offer, or agree to give something
of value to FREDERICK S. DAKOTA, that is, a check in the amount
of $6,700 drawn on an account of Spectrum and made payable to
"Fred Dakota" and signed by "Jerry Polinsky" as the maker and
drawer thereof, with intent to influence or reward FREDERICK S.
DAKOTA in connection with the business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(2).
Title 18, United States Code, Section 2.

                           Count 27

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about July 7, 1992, in the Western District of
Michigan, Northern Division, defendant FREDERICK S. DAKOTA did
knowingly and corruptly solicit, demand, accept, and agree to
accept something of value from JERROLD L. POLINSKY, that is, a
check in the amount of $6,700 drawn on an account of Spectrum
and made payable to "Fred Dakota" and signed by "Jerry Polinsky"
as the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B).
Title 18, United States Code, Section 2.

                           Count 28

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about July 27, 1992, in the Western District of
Michigan, Northern Division, defendant JERROLD L. POLINSKY did
knowingly and corruptly give, offer, or agree to give something
of value to FREDERICK S. DAKOTA, that is, a check in the amount
of $6,400 drawn on an account of Spectrum and made payable to
"Fred Dakota" and signed by "Jerry Polinsky" as the maker and
drawer thereof, with intent to influence or reward FREDERICK S.
DAKOTA in connection with the business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(2).
Title 18, United States Code, Section 2.

                           Count 29

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about July 27, 1992, in the Western District of
Michigan, Northern Division, defendant FREDERICK S. DAKOTA did
knowingly and corruptly solicit, demand, accept, and agree to
accept something of value from JERROLD L. POLINSKY, that is, a
check in the amount of $6,400 drawn on an account of Spectrum
and made payable to "Fred Dakota" and signed by "Jerry Polinsky"
as the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B).
Title 18, United States Code, Section 2.

                           Count 30

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about August 14, 1992, in the Western District
of Michigan, Northern Division, defendant JERROLD L. POLINSKY
did knowingly and corruptly give, offer, or agree to give
something of value to FREDERICK S. DAKOTA, that is, a check in
the amount of $7,550 drawn on an account of Spectrum and made
payable to "Fred Dakota" and signed by "Jerry Polinsky" as the
maker and drawer thereof, with intent to influence or reward
FREDERICK S. DAKOTA in connection with the business,
transaction, and series of transactions of KBIC involving
something of value of $5,000 or more.

Title 18, United States Code, Sections 666(a)(2).
Title 18, United States Code, Section 2.

                           Count 31

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about August 14, 1992, in the Western District
of Michigan, Northern Division, defendant FREDERICK S. DAKOTA
did knowingly and corruptly solicit, demand, accept, and agree
to accept something of value from JERROLD L. POLINSKY, that is,
a check in the amount of $7,550 drawn on an account of Spectrum
and made payable to "Fred Dakota" and signed by "Jerry Polinsky"
as the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B).
Title 18, United States Code, Sections 2.


                           Count 32

1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about September 23, 1992, in the Western
District of Michigan, Northern Division, defendant JERROLD L.
POLINSKY did knowingly and corruptly give, offer, or agree to
give something of value to FREDERICK S. DAKOTA, that is, a check
in the amount of $7,125 drawn on an account of Spectrum and made
payable to "Fred Dakota" and signed by "Jerry Polinsky" as the
maker and drawer thereof, with intent to influence or reward
FREDERICK S. DAKOTA in connection with the business,
transaction, and series of transactions of KBIC involving
something of value of $5,000 or more.

Title 18, United States Code, Sections 666(a)(2).
Title 18, United States Code, Section 2.


                           Count 33
     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about September 23, 1992, in the Western
District of Michigan, Northern Division, defendant FREDERICK S.
DAKOTA did knowingly and corruptly solicit, demand, accept, and
agree to accept something of value from JERROLD L. POLINSKY,
that is, a check in the amount of $7,125 drawn on an account of
Spectrum and made payable to "Fred Dakota" and signed by "Jerry
Polinsky" as the maker and drawer thereof, intending to be
influenced or rewarded in connection with a business,
transaction, and series of transactions of KBIC involving
something of value of $5,000 or more.

Title 18, United States Code, Sections 666(a)(1)(B).
Title 18, United States Code, Section 2.

                           Count 34

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about November 24, 1992, in the Western District
of Michigan, Northern Division, defendant JERROLD L. POLINSKY
did knowingly and corruptly give, offer, or agree to give
something of value to FREDERICK S. DAKOTA, that is, a check in
the amount of $5,350 drawn on an account of Spectrum and made
payable to "Fred Dakota" and signed by "Jerry Polinsky" as the
maker and drawer thereof, with intent to influence or reward
FREDERICK S. DAKOTA in connection with the business,
transaction, and series of transactions of KBIC involving
something of value of $5,000 or more.

Title 18, United States Code, Sections 666(a)(2).
Title 18, United States Code, Section 2.

                           Count 35

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about November 24, 1992, in the Western District
of Michigan, Northern Division, defendant FREDERICK S. DAKOTA
did knowingly and corruptly solicit, demand, accept, and agree
to accept something of value from JERROLD L. POLINSKY, that is,
a check in the amount of $5,350 drawn on an account of Spectrum
and made payable to "Fred Dakota" and signed by "Jerry Polinsky"
as the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B).
Title 18, United States Code, Section 2.

                           Count 36

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about February 24, 1993, in the Western District
of Michigan, Northern Division, defendant JERROLD L. POLINSKY
did knowingly and corruptly give, offer, or agree to give
something of value to FREDERICK S. DAKOTA, that is, a check in
the amount of $7,945 drawn on an account of Spectrum and made
payable to "Fred Dakota" and signed by "Jerry Polinsky" as the
maker and drawer thereof, with intent to influence or reward
FREDERICK S. DAKOTA in connection with the business,
transaction, and series of transactions of KBIC involving
something of value of $5,000 or more.

Title 18, United States Code, Sections 666(a)(2).
Title 18, United States Code, Section 2.

                           Count 37

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about February 24, 1993, in the Western District
of Michigan, Northern Division, defendant FREDERICK S. DAKOTA
did knowingly and corruptly solicit, demand, accept, and agree
to accept something of value from JERROLD L. POLINSKY, that is,
a check in the amount of $7,945 drawn on an account of Spectrum
and made payable to "Fred Dakota" and signed by "Jerry Polinsky"
as the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B).
Title 18, United States Code, Section 2.

                           Count 38

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about April 11, 1993, in the Western District of
Michigan, Northern Division, defendant JERROLD L. POLINSKY did
knowingly and corruptly give, offer, or agree to give something
of value to FREDERICK S. DAKOTA, that is, a check in the amount
of $8,250 drawn on an account of Spectrum and made payable to
"Fred Dakota" and signed by "Jerry Polinsky" as the maker and
drawer thereof, with intent to influence or reward FREDERICK S.
DAKOTA in connection with the business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(2).
Title 18, United States Code, Section 2.

                           Count 39

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully

set forth herein.

     2.   On or about April 11, 1993, in the Western District of
Michigan, Northern Division, defendant FREDERICK S. DAKOTA did
knowingly and corruptly solicit, demand, accept, and agree to
accept something of value from JERROLD L. POLINSKY, that is, a
check in the amount of $8,250 drawn on an account of Spectrum
and made payable to "Fred Dakota" and signed by "Jerry Polinsky"
as the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B).
Title 18, United States Code, Section 2.

                           Count 40

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about May 20, 1993, in the Western District of
Michigan, Northern Division, defendant JERROLD L. POLINSKY did
knowingly and corruptly give, offer, or agree to give something
of value to FREDERICK S. DAKOTA, that is, a check in the amount
of $6,750 drawn on an account of Spectrum and made payable to
"Fred Dakota" and signed by "Jerry Polinsky" as the maker and
drawer thereof, with intent to influence or reward FREDERICK S.
DAKOTA in connection with the business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(2).
Title 18, United States Code, Section 2.

                           Count 41

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about May 20, 1993, in the Western District of
Michigan, Northern Division, defendant FREDERICK S. DAKOTA did
knowingly and corruptly solicit, demand, accept, and agree to
accept something of value from JERROLD L. POLINSKY, that is, a
check in the amount of $6,750  drawn on an account of Spectrum
and made payable to "Fred Dakota" and signed by "Jerry Polinsky"
as the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B).
Title 18, United States Code, Section 2.

                           Count 42

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about June 25, 1993, in the Western District of
Michigan, Northern Division, defendant JERROLD L. POLINSKY did
knowingly and corruptly give, offer, or agree to give something
of value to FREDERICK S. DAKOTA, that is, a check in the amount
of $6,569 drawn on an account of Spectrum and made payable to
"Fred Dakota" and signed by "Jerry Polinsky" as the maker and
drawer thereof, with intent to influence or reward FREDERICK S.
DAKOTA in connection with the business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(2) .
Title 18, United States Code, Section 2.

                           Count 43

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about June 25, 1993, in the Western District of
Michigan, Northern Division, defendant FREDERICK S. DAKOTA did
knowingly and corruptly solicit, demand, accept, and agree to
accept something of value from JERROLD L. POLINSKY, that is, a
check in the amount of $6,569 drawn on an account of Spectrum
and made payable to "Fred Dakota" and signed by "Jerry Polinsky"
as the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B).
Title 18, United States Code, Section 2.

                           Count 44

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about August 16, 1993, in the Western District
of Michigan, Northern Division, defendant JERROLD L. POLINSKY
did knowingly and corruptly give, offer, or agree to give
something of value to FREDERICK S. DAKOTA, that is, a check in
the amount of $7,140 drawn on an account of Spectrum and made
payable to "Fred Dakota" and signed by "Jerry Polinsky" as the
maker and drawer thereof, with intent to influence or reward
FREDERICK S. DAKOTA in connection with the business,
transaction, and series of transactions of KBIC involving
something of value of $5,000 or more.

Title 18, United States Code, Sections 666(a)(2).
Title 18, United States Code, Section 2.

                           Count 45

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about August 16, 1993, in the Western District
of Michigan, Northern Division, defendant FREDERICK S. DAKOTA
did knowingly and corruptly solicit, demand, accept, and agree
to accept something of value from JERROLD L. POLINSKY, that is,
a check in the amount of $7,140 drawn on an account of Spectrum
and made payable to "Fred Dakota" and signed by "Jerry Polinsky"
as the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B).
Title 18, United States Code, Section 2.

                           Count 46

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about October 1, 1993, in the Western District
of Michigan, Northern Division, defendant JERROLD L. POLINSKY
did knowingly and corruptly give, offer, or agree to give
something of value to FREDERICK S. DAKOTA, that is, a check in
the amount of $6,071 drawn on an account of Spectrum and made
payable to "Fred Dakota" and signed by "Jerry Polinsky" as the
maker and drawer thereof, with intent to influence or reward
FREDERICK S. DAKOTA in connection with the business,
transaction, and series of transactions of KBIC involving
something of value of $5,000 or more.

Title 18, United States Code, Sections 666(a)(2).
Title 18, United States Code, Section 2.

                           Count 47

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about October 1, 1993, in the Western District
of Michigan, Northern Division, defendant FREDERICK S. DAKOTA
did knowingly and corruptly solicit, demand, accept, and agree
to accept something of value from JERROLD L. POLINSKY, that is,
a check in the amount of $6,071 drawn on an account of Spectrum
and made payable to "Fred Dakota" and signed by "Jerry Polinsky"
as the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B).
Title 18, United States Code, Section 2.

                           Count 48

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about November 3, 1993, in the Western District
of Michigan, Northern Division, defendant JERROLD L. POLINSKY
did knowingly and corruptly give, offer, or agree to give
something of value to FREDERICK S. DAKOTA, that is, a check in
the amount of $6,150 drawn on an account of Spectrum and made
payable to "Fred Dakota" and signed by "Jerry Polinsky" as the
maker and drawer thereof, with intent to influence or reward
FREDERICK S. DAKOTA in connection with the business,
transaction, and series of transactions of KBIC involving
something of value of $5,000 or more.

Title 18, United States Code, Sections 666(a)(2).
Title 18, United States Code, Section 2.

                           Count 49

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about November 3, 1993, in the Western District
of Michigan, Northern Division, defendant FREDERICK S. DAKOTA
did knowingly and corruptly solicit, demand, accept, and agree
to accept something of value from JERROLD L. POLINSKY, that is,
a check in the amount of $6,150 drawn on an account of Spectrum
and made payable to "Fred Dakota" and signed by "Jerry Polinsky"
as the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B).
Title 18, United States Code, Section 2.

                           Count 50

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about December 27, 1993, in the Western District
of Michigan, Northern Division, defendant JERROLD L. POLINSKY
did knowingly and corruptly give, offer, or agree to give
something of value to FREDERICK S. DAKOTA, that is, a check in
the amount of $7,250 drawn on an account of Spectrum and made
payable to "Fred Dakota" and signed by "Jerry Polinsky" as the
maker and drawer thereof, with intent to influence or reward
FREDERICK S. DAKOTA in connection with the business,
transaction, and series of transactions of KBIC involving
something of value of $5,000 or more.
Title 18, United States Code, Sections 666(a)(2).
Title 18, United States Code, Section 2.

                           Count 51

     1.   The Grand Jury realleges and incorporates by reference
Background paragraphs a through p of this Indictment as if fully
set forth herein.

     2.   On or about December 27, 1993, in the Western District
of Michigan, Northern Division, defendant FREDERICK S. DAKOTA
did knowingly and corruptly solicit, demand, accept, and agree
to accept something of value from JERROLD L. POLINSKY, that is,
a check in the amount of $7,250 drawn on an account of Spectrum
and made payable to "Fred Dakota" and signed by "Jerry Polinsky"
as the maker and drawer thereof, intending to be influenced or
rewarded in connection with a business, transaction, and series
of transactions of KBIC involving something of value of $5,000
or more.

Title 18, United States Code, Sections 666(a)(1)(B).
Title 18, United States Code, Section 2.

                           Count 52

     On or about December 28, 1993, in the Northern Division of
the Western District of Michigan,

                      FREDERICK S. DAKOTA

a resident of Baraga , Michigan, did willfully make and
subscribe an individual 1991 U.S. Income Tax Return, Form 1040,
which was verified by written declaration that it was made under
the penalties of perjury and was filed with the Internal Revenue
Service, which said Form 1040 he did not believe to be true and
correct as to every material matter in that the said Form 1040
stated that the defendant's adjusted gross income during 1991,
was $32,549, whereas as he then and there well knew and
believed, he had understated his adjusted gross income which
caused him to underpay his federal income taxes.

Title 26, United States Code, Section 7206(1).

                           Count 53

     On or about December 28, 1993, in the Northern Division of
the Western District of Michigan,

                      FREDERICK S. DAKOTA

a resident of Baraga , Michigan, did willfully make and
subscribe an individual 1992 U.S. Income Tax Return, Form 1040,
which was verified by written declaration that it was made under
the penalties of perjury and was filed with the Internal Revenue
Service, which said Form 1040 he did not believe to be true and
correct as to every material matter in that the said Form 1040
stated that the defendant's adjusted gross income during 1992
was $33,380, whereas as he then and there well knew and
believed, he had understated his adjusted gross income which
caused him to underpay his federal income taxes.

Title 26, United States Code, Section 7206(1).

                           Count 54

     On or about April 15, 1994, in the Northern Division of the
Western District of Michigan,

                      FREDERICK S. DAKOTA

a resident of Baraga, Michigan, did willfully make and
subscribe an individual 1993 U.S. Income Tax Return, Form 1040,
which was verified by written declaration that it was made under
the penalties of perjury and was filed with the Internal Revenue
Service, which said Form 1040 he did not believe to be true and
correct as to every material matter in that the said Form 1040
stated that the defendant's adjusted gross income during 1992
was $54,288.09, whereas as he then and there well knew and
believed, he had understated his adjusted gross income which
caused him to underpay his federal income taxes.

Title 26, United States Code, Section 7206(1).

U.S. Attorney for the Western District of Michigan
Michael H. Dettmer, United States Attorney
330 Ionia Street, 5th Floor
Grand Rapids, Michigan 49503
Main Office Number: 616-456-2404

PA Office: 616-456-2404; fax: 616-456-2517; pager: 616-338-1495
Kaye B. Hooker: Public Information Officer
khooker@justice.usdoj.gov
Archived News Releases/Documents: http://www.usdoj.gov/press.html
gopher://gopher.usdoj.gov

To read a brief summary of FFJ and it's begining read Tina Lam's Detorit Free Press article

Copyright 2001 by Rose Edwards. All Rights Reserved.