The Doral Arrowwood Project

Pattern Act 127

The defendants Steven L. Crea, Lawrence Wecker, Joseph Datello, Anthony Rucereto,

Anthony O’Donnell and Kenneth Gordon 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 August 1999 through in or about December 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 the award of a construction project at
the Doral Arrowwood Conference Center.

Pattern Act 128

The defendants Lawrence Wecker, Joseph Datello, Anthony Rucereto, and Anthony
O’Donnell, committed the crime of COMMERCIAL BRIBING IN THE FIRST DEGREE, in
violation of Penal Law Section 180.03, as follows:

Said defendants, from in or about August 1999 through in or about December 1999 in
New York County and elsewhere, conferred, and offered and agreed to confer a benefit upon an
employee, agent and fiduciary without the consent of the latter’s employee and principal with
intent to influence his conduct in relation to his employer’s and principal’s affairs, and the value
of the benefit conferred and agreed to be conferred exceeded one thousand dollars and caused
economic harm to the employer and principal in an amount exceeding two hundred and fifty
dollars.

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