rigging and other anticompetitive arrangements, relating to the supply of modular construction
units at the School Construction Project at IS 93 Queens.

Pattern Act 35

The defendants Steven L. Crea, Steven Chait Osserman, Nicholas Russo and Kent
Building Systems Inc. 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 January 1, 1998 to on or about December 31, 1998, in
Queens County and elsewhere, compelled and induced a person, known to the grand jury as
John Doe 3, 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 36

The defendants, Steven L. Crea, Steven Chait Osserman, Nicholas Russo and Kent
Building Systems Inc. committed the crime of COMBINATION IN RESTRAINT OF TRADE
AND COMPETITION, in violation of General Business Law Sections 340 and 341, as follows:

Said defendants, from on or about January 1, 1998, to on or about December 31, 1998,
in Queens County and elsewhere, acting with others known and unknown to the Grand Jury,
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 the supply of modular construction
units at the School Construction Project at PS 33 Queens.

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