D'Andrea in June of 1993.   Investigators had

Benchmark corporate records, GTECH records, and Smith's Kentucky

bank records subpoenaed.    By April 11, 1994, the investigation

had produced information that prompted the New Jersey Division of

the United States Attorney's Office to send Smith a target

letter.    Smith was thereafter advised that the FBI's evidence

indicated that he was involved in a kickback scheme to defraud

GTECH.    Smith allegedly would arrange for service providers in

New Jersey, New York, Texas, and Kentucky to be engaged by GTECH




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and to be paid for non-existent or over-valuedservices.1    These

service providers included Benchmark, Sambuca, and PGI in New

Jersey, and BID in Kentucky.    In return, these service providers

would send kickbacks to third parties in Kentucky designated by

Smith.   These third parties included IMC and Billy Adams, a

carpenter who frequently did work on Smith's farm.   When IMC,

Adams, and the three other designated third parties received the

"consulting fees" from the service providers in the various

states, they would transmit the funds to Smith and his wife or

apply them for their benefit.   According to an affidavit of

Smith's counsel, the United States Attorney sought Smith's

cooperation and threatened him with indictments in all four

states if he failed to cooperate.    Smith declined to cooperate

and indictments against him were simultaneously returned