crime of BRIBING A LABOR OFFICIAL, in violation of Penal Law Section 180.15, as
follows:

Said defendants, on or about December 18, 1997, in New York County and elsewhere,
with intent to influence a labor official with respect to his acts, decisions and duties as a labor
official, conferred, offered, and agreed to confer a benefit, to wit, a sum of United States
currency, upon such labor official.

Canron Construction

COUNT 7

AND THE GRAND JURY AFORESAID, by this indictment, accuses the defendants

James Bonagura, Steven L. Crea, Arthur Zambardi, Saul Heifetz, DIBA Corp. and Grand Train

Corp., of committing 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 on or about August 13, 1998 to on or about January 12, 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 a subcontract for concrete and
masonry work at the 59th Street Bridge.

COUNT 8

AND THE GRAND JURY AFORESAID, by this indictment, accuses the defendants

James Bonagura, Steven L. Crea, Arthur Zambardi, Saul Heifetz, DIBA Corp. and Grand Train

Corp., of committing the crime of COMBINATION iN RESTRAINT OF TRADE AND

COMPETITION, in violation of General Business Law Sections 340 and 341, as follows:

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