payments. Defendants Jeremiah Sullivan, Sr., John Cucchiarella, and Anthony Barbagallo were
Business Agents for Local 1, who violated their duties as union officials by allowing the use of
non-union labor and the falsification of union shop steward reports. Cucchiarella and
Barbagallo received bribe payments for their involvement in the use of non-union labor and the
falsification of union shop steward reports.

Defendant Michael Forde was President of Local 608 of the United Brotherhood of
Carpenters and Joiners of America, and defendant Martin Devereaux was a Business Agent for
Local 608. Both Forde and Devereaux received bribe payments in return for violating their
duties as union officials by allowing the use of non-union labor and the violation of other union
requirements by contractor enterprise members.

Defendant Gerald Woods was the Executive Secretary-Treasurer/Business Manager for
the Northern New Jersey Regional Council of Carpenters United Brotherhood of Carpenters and
Joiners of America. Woods received bribe payments from defendant Anthony Rucereto in
return for violating his duties as a union official by allowing the use of non-union labor and the
violation of other union requirements by contractor enterprise members, and improperly
sponsoring S & S Contractors Inc. and LVC Window Blinds and Drapery Inc. for United
Brotherhood of Carpenters and Joiners International Agreements.

Pattern of Criminal Activity

During the period of this offense, each of the defendants, as specified below,
participated in a pattern of criminal activity with intent to participate in the affairs of the
Lucchese Organized Crime Family as follows:

Pattern Act 1

The defendants Steven L. Crea, Dominic Truscello, Joseph Tangorra, Joseph Datello,
Philip DeSimone, Anthony Pezzullo, Joseph Tnmcale, Arthur Zambardi, Saul Heifetz,
Lawrence Wecker, Kenneth Gordon, Joseph Martinelli, Nicholas Russo, Steven Chait

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