p>

use and storage of the F‑40. The use tax due and owing to

the State of Rhode Island for this transaction was 7% of $275,000,

or $19,250

 

The 1972 Ferrari Daytona

 

b. On or about February 28, 1990, the defendant, ARTHUR

A. COIA, purchased a 1972 Ferrari Daytona ("the Daytona" ) , vehicle

Identification number 16549, from Shellton Sports Cars in Fort

Lauderdale, Florida, for $1,050,000. On or about August 18,1993,

the defendant, ARTHUR A. COIA, caused the Daytona to be

fraudulently registered to Viking's address on East Main Road in

Middletown, in order to evade paying the higher excise tax rate in

Barrington. As COIA continued to reside in Barrington and the

Daytona was not garaged in Middletown the local excise tax on the

64. Racketeering Acts Nos. 92 through 94

a. At all times material to Racketeering Acts Nos. 92 through 94, defendant JOHN CATANZARO was an auditor and steward for LIUNA Local 210, Buffalo, New York, and a representative of employees of Gregory and Cook, Inc., whose employees worked on the construction of pipelines in the State of New York and who were employed in an industry affecting commerce.

b. At all times material to Racketeering Acts Nos. 92 through 94, defendant JOSEPH A. TODARO, JR., was a business agent of LIUNA Local 210, Buffalo, New York, and was an officer and employee of a labor organization which represented, sought to represent and would admit to membership employees of Gregory and Cook, Inc., which was engaged in the construction of pipelines in the State of New York and whose employees were employed in and industry affecting commerce.

c. At all times material to Racketeering Acts Nos. 92 through 94, Gregory and Cook, Inc., whose principal offices were located Houston, Texas, was performing work on the construction of a brineline pipeline (hereafter" the brineline project") in the area of Buffalo, New York and was engaged in and its activities affected interstate commerce.

d. Beginning on or about August 25, 1986, and continuing thereafter up to and including June 15, 1987, in Buffalo, New York and elsewhere, defendant JOHN CATANZARO did unlawfully and willfully request, demand, receive, accept and agree to receive and accept

137

the payment of money in amounts in excess of $1000.00 from Gregory and Cook, Inc., and persons acting in its interest, in the form of wages and benefits for services not performed on the brineline project for the approximate time periods specified below corresponding to Racketeering Acts Nos. 92 through 94, which money and benefits defendant JOHN CATANZARO was not entitle to as legitimate compensation for, or by reason of, his services as an employee of Gregory and Cook, Inc., including his services on behalf of other employees of Gregory and Cook, Inc., all in violation of Title 29, United States Code, Section 186 (b) (1) and (d):

Racketeering Acts

92

93

94

Time Period of Wages Received

July 21,1986 to August 24, 1986


August 25, 1986 to December 22,1986

4. In 1973 in San Francisco, California, Arthur E. Coia and defendants ANGELO F0SCO, TERENCE O'SULLIVAN, JOHN GIARDIELLO, and SALVATORE TRICARIO met with Joseph Hauser to urge him to obtain an insurance company in Florida, in which they could be partners as to income and into which the Laborers Union insurance business should be funnelled, because they controlled the Insurance Commissioner of Florida.

-12-

On or about September 13, 1972, contracts for the provision of dental and vision services between the Southeast Florida Laborers District Council and DVCC was signed by defendants JAMES NORTON and BERNARD RUBIN.

6. In 1973 defendant TERENCE O'SULLIVAN met with Joseph Hauser and received stock in Equitable Health Corporation of America and cash as an illegal kickback.

7. On or about March 15, 1973, in the State of Florida, defendant SEYMOUR GOPMAN incorporated Fortune Services.

8. On or about May 1, 1973, defendant SEYMOUR GOPMAN, on behalf of Fortune Services, entered into a contract with Paul DiFranco, D.DS., P.A.

9. On or about December 13, 1974, in the State of Florida, defendant SEYMOUR GOPMAN incorporated Ace Services.

10. Between March 1974 and June 1976, in the Southern District of Florida, defendant JOHN GIARDIELLO received periodic payments of $5,000 as illegal kickbacks from Joseph Hauser:

11. Between March 1974 and June 1976, in the Southern District of Florida, defendant SALVATORE TRICARIO received periodic payments of $5,000 as illegal kickbacks from Joseph Hauser.

12. Between February 1972 and May 1976, in the Southern District of Florida, defendant SALVATORE TRICARIO received illegal kickbacks in varying amounts, in the form of cash, from representatives of DVCC.

13. In about June 1974, in the Southern District of Florida, defendant BERNARD G. RUBIN met with Joseph Hauser and received corporate stock in Farmers Financial Corporation as an illegal kickback, said stock being placed in the name of RUBIN's brother-in-law, Leonard Bucker, through a shell corporation known as Eastern Tower Crane Erectors, Inc.

-13-

14. During the period 1974 through 1976 in Chicago, Illinois, defendant JAMES CAPORALE made periodic visits to Consultants and Administrators for the purpose of receiving illegal kickbacks.

15. In about 1974 defendant ANGELO FOSCO met with Joseph Hauser and requested Hauser pay illegal kickbacks to him through a company to be called PF Insurance Agency, owned and operated by his son, defendant PAUL FOSCO

16. During 1974 throw 1976 defendant PAUL FOSCO had conversations with and received payments from employees of Consultants and Administrators as illegal kickbacks for his father, defendant ANGELO FOSCO, and others.

17. On or about April 1, 1975, in Chicago, Illinois, PF Agency, though defendant PAUL FOSCO as president, entered into an agreement with Farmers National.

18. In about mid-1974 defendant JAMES PINCKARD had a conversation with Daniel G. Milano concerning illegal kickbacks which were being paid by Consultants and Administrators to defendant ALFRED PILOTTO and others through Pinckard and Associates.

19. On or about October 29, 1974, in the State of Illinois, Pinckard and Associates was incorporated by defendant JAMES PINCKARD.

20. In the spring of 1974, in Chicago defendant ALFRED PILOTTO met with Daniel Milano (deceased) and discussed PILOTTO's assisting Consultants and Administrators with a new Chicago Dental Plan contract they were seeking in Chicago, Illinois, in return for illegal kickbacks to be paid to defendant ALFRED PILOTTO through the conduit of Pinckard and AssociaUL0 @c:\c-copy\inetpub\liuna\election\protests\_vti_pvt\structure.cnfUΎ>c:\c-copy\inetpub\liuna\election\protests\_vti_pvt\writeto.cnfU !"=c:\c-copy\inetpub\liuna\election\protests\_vti_cnf\search.htmU* 7c:\c-copy\inetpub\liuna\election\protests\_themes\liunaFILE08(H0.c.c.c.c0pR.c.c.c.c $AttrDefPtHd4 tDP H@ 1 yFILE0N7P8Z-H0.c E@yHr vH&0`D.c.cy.c&.PH@@ LLAX8 $I300((P@H$I30A( $I30$I30A( $I30FILE08P(`H.c.c.c.c0hP.c.c.c.cP%G%$BitmapH@T@P%G%G%BUtDP H@T@P%G%G%BUFILE08'H0.c.c.c.c0hL.c.c.c.c $BootPtHd4 tDP H@@  MmStXchbxbbbbbaaaaqc(c8cHcXdhcxcccccbbbbrd(d8dHdXehdxdddddccccse(e8eHeXfhexeeeeeddddtf(f8fHfXghfxfffffeeeeug(g8gHgXhhgxgggggffffvh(h8hHhXihhxhhhhggggwi(i8iHiXjhixiiiiihhhhxj(j8jHjXkhjxjjjjjiiiiyk(k8kHkXlhkxkkkkkjjjjzl(l8lHlXmhlxlllllkkkk{m(m8mHmXnhmxmmmmmllll|n(n8nHnXohnxnnnnnmmmm}o(o8oHoXphoxooooonnnn~p(p8pHpXqhpxpppppooooq(q8qHqXrhqxqqqqqppppr(r8rHrXshrxrrrrrqqqqs(s8sHsxsssssrrrrt(t8tHtXuhtxtttttssssu(u8uHuXvhuxuuuuuttttv(v8vHvXwhvxvvvvvuuuuw(w8wHwXxhwxwwwwwvvvvx(x8xHxXyhxxxxxxxwwwwy(y8yHyXzhyxyyyyyxxxxz(z8zHzX{hzxzzyyyy{({8{H{X|h{x{{{{{zzzz|(|8|H|X}h|x|||||{{{{}(}8}H}X~h}x}}}}}||||~(~8~H~Xh~x~~~~~}}}}(8HXhx~~~~(8HXhx(8HXhxȀ؀(8HXhx!!Ɂ!ف!!! !!)!9!I!Y!i!y!!!!!ɂ!ق!!! !!)!9!I!Y!i!y!!!!!Ƀ!ك!!! !!)!9!I!Y!i!y!!!!!Ʉ!ل!!! !!)!9!I!Y!i!y!!!!!Ʌ!م!!! !!)!9!I!Y!i!y!!!!!Ɇ!ن!!  Dir0ŨЄu T zta! CM39!! CM39!! CM39