FOR THE WESTERN DISTRICT OF VIRGINIA
The United States of America, acting through its attorneys, charges:
DESCRIPTION OF THE OFFENSE
1. Frederick Racer Glick is made a defendant on the charge stated below.
2. Beginning at least as early as April 1996, and continuing thereafter at least through November 1997, the exact dates being unknown to the United States, the defendant and others engaged in a combination and conspiracy in unreasonable restraint of interstate trade and commerce in violation of Section 1 of the Sherman Act, 15 U.S.C. § 1.
3. The charged combination and conspiracy consisted of a continuing agreement, understanding and concert of action among the defendant and co-conspirators, the substantial term of which was to suppress competition by refraining from full competitive bidding against one another for certain commercial plate glass installation contracts in southwestern Virginia.
4. For the purpose of forming and carrying out the charged combination and conspiracy, the defendant and co-conspirators did the following things, among others:
discussed the submission of prospective bids on certain commercial plate glass installation contracts;
designated and agreed which co-conspirator would be the low bidder on each of the contracts discussed; and
submitted collusive, noncompetitive and rigged bids in accordance with agreements reached.
DEFENDANT AND CO-CONSPIRATORS
5. The defendant, during all or part of the period covered by this Information, was sales manager and chief estimator of Glass & Metals, LLC, a commercial plate glass contractor headquartered in Harrisonburg, Virginia.
6. Various firms and individuals, not made defendants in this Information, participated as co-conspirators in the offense charged and performed acts and made statements in furtherance of it.
TRADE AND COMMERCE
7. The business activities of the defendant and co-conspirators that are the subject of this Information were within the flow of, and substantially affected, interstate trade and commerce.
JURISDICTION AND VENUE
8. The charged combination and conspiracy was formed and carried out, in part, within the Western District of Virginia, within the five years preceding the filing of this Information.