agreements with the Concrete Workers District Council Benefit Fund by employing non-union
workers and paying his union workers cash overtime. Martinelli created a fifteen thousand
dollar a week cash “off the books” payroll which defrauded the Fund and caused numerous
false remittance reports to be filed with the Fund in order to conceal the secret payroll.

Defendants Anthony O’Donnell and Anthony Rucereto worked with Sean Richard, an
associate in Dominic Truscello’s crew. Sean Richard was the principal of S & S Contractors
Inc., a subcontractor that violated its collective bargaining agreement with the Carpenters’
Union by using non-union labor at the Park Central Hotel project. Sean Richard was the son-in-
law of John Riggi, the boss of the DeCavalcante Organized Crime Family of La Cosa Nostra, a
New Jersey based organized crime family that also operated in New York.

Defendant Finbar O’Neill was an officer of Terra Firma Construction Management and
General Contracting LLC. O’Neill used Zambardi, Reynolds and Giuseppe Palmeri to coerce a
contractor to remove a lien from a project after Zambardi stole money from the contractor.
O’Neill also paid the “mob tax” and falsified business records to conceal Zambardi’s theft and
his payment of the “mob tax.”

III. Union Official Members of the Lucchese Construction Group

Defendant Joseph Pezzullo, the brother of Anthony Pezzullo, was a shop steward for
Local 1 of the Builders and Allied Craftsmen Union who in return for bribe payments, violated
his duty as a union official by under reporting hours worked on shop steward reports.
Defendants Henri LaBarbera and Thomas Zmich were Local 1 shop stewards who, in return for
bribe payments, violated their duties as union officials by under reporting hours on shop
steward reports for the PS 33 and IS 93 projects.

Defendant Santo Lanzafame was the President of the Builders and Allied
Craftsmen Local 1. Lanzafame appointed LaBarbera as shop steward on PS 33 with the
knowledge that LaBarbera would file false shop steward reports in exchange for bribe

10