knowingly and intentionally engaged in a contract, agreement, arrangement and combination in
unreasonable restraint of trade and competition, to wit, to restrain competition in the
construction industry throughout the City and State of New York by means of price fixing, bid
rigging and other anticompetitive arrangements relating to a project known to the Grand Jury as
Project I.

Pattern Act 3

The defendants Steven L. Crea, Joseph Datello, Saul Heifetz, and Lawrence Wecker
committed the crime of COERCION IN THE FIRST DEGREE, in violation of Penal Law
Section 135.65(1), as follows:

Said defendants, from on or about November 5, 1997 to on or about December 18, 1997,
in New York County and elsewhere, compelled and induced a person, known to the grand jury
as John Doe 1, to engage in conduct which the latter had a legal right to abstain from engaging
in, and to abstain from engaging in conduct in which he had a legal right to engage, by means of
instilling in him the fear that if the demand was not complied with, the actor or another would
cause physical injury to a person and cause damage to property.

Pattern Act 4

The defendants Steven L. Crea, Joseph Datello, Saul Heifetz, and Lawrence Wecker
committed the crime of COERCION IN THE FIRST DEGREE, in violation of Penal Law
Section 13 5.65(1), as follows:

Said defendants, from on or about November 5, 1997 to on or about December 18, 1997,
in New York County and elsewhere, compelled and induced a person, known to the grand jury
as John Doe 2, to engage in conduct which the latter had a legal right to abstain from engaging
in and to abstain from engaging in conduct in which he had a legal right to engage by means of
instilling in him the fear that if the demand was not complied with, the actor or another would
cause physical injury to a person and cause damage to property.

13