The Government’s successful prosecutions of Teamsters officials and La Cosa Nostra figures have exposed rampant labor racketeering, extortion, embezzlement, bribery and other corrupt activities conducted by La Cosa Nostra through its instrument, the International Brotherhood of Teamsters (IBT). In several cases the Government has obtained convictions against IBT officials and La Cosa Nostra figures for their involvement in labor extortion schemes. Federal juries have also convicted La Cosa Nostra figures of using other IBT Locals in schemes to maintain La Cosa Nostra cartels in particular industries. Plaintiff United States of America submits the memorandum of law in support of its motion for preliminary relief, pursuant to the civil remedies provisions of the Racketeer Influenced and Corrupt Organizations statute, 18 U.S.C. §1964. The preliminary relief sought by the Government is narrowly drawn to address the immediate and pressing problem of Teamsters corruption fostered by La Cosa Nostra and unremedied by the IBT leadership.