FOR THE TERRITORY OF GUAM
THE GRAND JURY CHARGES:
1. IL YOUNG CHO is hereby indicted and made a defendant herein.
2. Beginning as early as December 17, 1997 and continuing at least until May 26, 1998, the exact dates being unknown to the Grand Jury, the defendant and co-conspirators entered into and engaged in a combination and conspiracy to suppress and restrain competition for a Government of Guam Department of Parks and Recreation ("DPR") project to repair structures at Wettengel Football Field damaged by Typhoon Paka ("the Wettengel Football Field Project"), in unreasonable restraint of territorial trade and commerce in violation of the Sherman Act, Title 15, United States Code, Section 3.
DEFENDANT AND CO-CONSPIRATORS
3. During the period covered by this Indictment, IL YOUNG CHO was a citizen of the Republic of Korea, a resident of the Territory of Guam, and in control of Cho Iron Works, a construction business located in Agaña, Guam.
4. Various individuals and corporations, not made defendants in this Indictment participated as co-conspirators in the offense charged and performed acts and made statements in furtherance of it.
5. The charged combination and conspiracy consisted of an agreement, understanding, and concert of action among the conspirators, the substantial term of which was to rig price quotations to be offered for the Wettengel Football Field Project.
6. For the common purpose of forming and carrying out the charged combination and conspiracy, the defendant and co-conspirators performed the following acts, among others:
7. During the period covered by this Indictment, the activity that was the object of the conspiracy involved substantial commerce in the Territory of Guam. The Wettengel Football Field Project was quoted, performed, invoiced, and paid in the Territory of Guam.
JURISDICTION AND VENUE
8. The combination and conspiracy charged in this Indictment was formed and carried out, in part, within the District of Guam, within five years preceding the return of this Indictment.
ALL IN VIOLATION OF TITLE 15, UNITED STATES CODE, SECTION 3.