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employed by and associated with that Criminal Enterprise, intentionally conducted and
participated in the affairs of said Enterprise by participating in a pattern of criminal activity.
The Lucchese Construction Group was a group of Lucchese Organized Crime Family
members and associates, construction industry contractors, and union officials, including all of the Defendants, and others known and unknown to the Grand Juiy, sharing a common purpose of engaging in criminal conduct, associated in an ascertainable structure, that was distinct from a pattern of criminal activity, and with a continuity of existence, structure, and criminal purpose beyond the scope of individual criminal incidents.
The common purpose of the Lucchese Construction Group was to make money for its
members by engaging in, among other things, criminal schemes related to the construction industry, including price fixing, bid rigging and other anticompetitive arrangements. Among the bids that members of the Enterprise rigged included those on construction sub-contracts involving New York City School Construction Authority projects at Intermediate School (“IS”)
in Queens County, Public School (“PS”) 33 in Queens County, and IS
254
in Bronx
County; subcontracts for rehabilitation projects with the New York City Department of Transportation for the 59th Street Bridge and the Triborough Bridge and Tunnel Authority for the Triboro Bridge; the renovation of the Park Central Hotel in New York County; and the construction of the Doral Arrowwood conference center in Westchester County.
In addition to being awarded rigged bids, construction industry contractor members of
the Enterprise (“contractor enterprise members”), through the influence and control of union official members of the enterprise, were able to realize lower labor costs. The corrupt arrangements involved various construction trade unions, including Builders and Allied Craftsmen Local Union No. 1 New York (“BAC Local l”)—the bricklayers union for the New |
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