Canron Construction

Pattern Act 44

The defendants James Bonagura, Steven L. Crea, Arthur Zambardi, Saul Heifetz, DIBA
Corp. and Grand Train Corp. 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 August 13, 1998 to on or about January 12, 1999, in
New York 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 a subcontract for concrete and
masonry work at the 59th Street Bridge.

Pattern Act 45

The defendants James Bonagura, Steven L. Crea, Arthur Zambardi, Saul Heifetz, DIBA
Corp. and Grand Train Corp. 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 September 1, 1998 to on or about June 30, 1999, in
New York 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 a concrete and masonry subcontract
at the New York City School Construction Authority Project at IS 254 Bronx.

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