COUNT 4

AND THE GRAND JURY AFORESAID, by this indictment, accuses the defendants
Steven L. Crea, Joseph Datello, Saul Heifetz, and Lawrence Wecker, of committing the crime of
COERCION IN THE~ FIRST DEGREE, in violation of Penal Law Section 135.65(1), as
follows:

Said defendants, from on or about November 5, 1997 to on or about December 18, 1997,
in New York County and elsewhere, compelled and induced a person known to the grand jury
as John Doe 1 to engage in conduct which the latter had a legal right to abstain from engaging
in and to abstain from engaging in conduct in which he had a legal right to engage by means of
instilling in him the fear that if the demand was not complied with, the actor or another would
cause physical injury to a person and cause damage to property.

COUNT 5

AND THE GRAND JURY AFORESAID, by this indictment, accuses the defendants
Steven L. Crea, Joseph Datello, Saul Heifetz, and Lawrence Wecker, of committing the crime of
COERCION IN THE FIRST DEGREE, in violation of Penal Law Section 135.65(1), as
follows:

Said defendants, from on or about November 5, 1997 to on or about December 18, 1997,
in New York County and elsewhere, compelled and induced a person known to the grand jury
as John Doe 2 to engage in conduct which the latter had a legal right to abstain from engaging
in and to abstain from engaging in conduct in which he had a legal right to engage by means of
instilling in him the fear that if the demand was not complied with, the actor or another would
cause physical injury to a person and cause damage to property.

COUNT 6

AND THE GRAND JURY AFORESAID, by this indictment, accuses the defendants
Joseph Datello, Saul Heifetz, Lawrence Wecker and Lisa Construction Corp., of committing the

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