The memorandum outlines for the very first time, the case against Irv and Chris Gotti in great detail.

The document was submitted to the US District Court after Gerald Lefcourt, attorney for Irv Gotti, filed a motion to declare the search of Irv’s offices unconstitutional.

Lefcourt also sought to discredit affidavits from IRS criminal agent Francis Mace who claimed the label was funded by Kenneth