Pattern Act 111

The defendants Arthur Zambardi, Anthony Barbagallo, John Cucchiarella, and Joseph
Pezzullo, committed the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST
DEGREE, in violation of Penal Law Section 175.10, as follows:

Said defendants, on or about May 20, 1997, in Queens County and elsewhere, with
intent to defraud, including the intent to commit another crime and aid and conceal the
commission thereof, made and caused to be made a false entry in the business records of an
enterprise, to wit a BAC Local Union No. 1, NY Shop Steward’s Time Report for work
performed at Project 3 for the week ending May 20, 1997.

The Park Central Hotel Project

Pattern Act 112

The defendants Steven L. Crea, Dominic Truscello, Joseph Datello, Anthony Rucereto,
Anthony O’Donnell, Michael Forde, Martin Devereaux and Gerald Woods 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 in or about January 1998 through on or about April 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 renovation project at the Park
Central Hotel.

Pattern Act 113

The defendant Anthony Rucereto, committed the crime of BRIBING A LABOR
OFFICIAL, in violation of Penal Law Section 180.15, as follows:

58