IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF PENNSYLVANIA
The United States of America, acting through it attorneys, charges:
DEFENDANT AND CO-CONSPIRATORS
1. Pittsburgh Rigging Company, Inc., (Pittsburgh Rigging), a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with offices in Clinton, Pennsylvania, is hereby made a defendant on the charge stated below.
2. Whenever in this Information reference is made to any act, deed or transaction of a corporation, the allegation means that the corporation engaged in the act, deed or transaction by or through its officers, directors, agents, employees or other representatives while they were actively engaged in the management, direction, control or transaction of its business or affairs.
3. Various individuals and companies not made defendants herein participated as co-conspirators in the offense charged herein and performed acts and made statements in furtherance thereof.
4. Bridge inspection and structural rigging services consist of providing engineering companies, contracted by federal, state and/or local governmental agencies to inspect the structural integrity of a bridge or group of bridges, with equipment and manpower in order to properly and safely conduct such inspections. A rigging subcontractor typically provides services that may include traffic control, safety boats, and boom and bucket trucks.
5. Beginning at least as early as September 1993 and continuing at least until September 1995, the exact dates being unknown to the United States, the defendant and co-conspirators entered into and participated in a combination and conspiracy to suppress and eliminate competition in unreasonable restraint of interstate trade and commerce.
6. The charged conspiracy consisted of an agreement, understanding and concert of action among the defendant and co-conspirators, the substantial terms of which were to allocate certain customers for bridge inspection and structural rigging services and to rig bids submitted to these customers.
7. For the purpose of forming and carrying out the charged conspiracy, the defendant and co-conspirators did those things they combined and conspired to do, including, among other things:
TRADE AND COMMERCE
8. During the period covered by this Information, the defendant and co-conspirators submitted bids, contracted for, provided and performed bridge inspection and rigging services both inside and outside the Commonwealth of Pennsylvania. Additionally, materials, labor and equipment were transported across state lines for use in performing some of the aforementioned bridge inspection and structural rigging contracts.
9. 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
10. The combination and conspiracy charged in this Information was formed and carried out, in part, within the Western District of Pennsylvania, within the five years preceding the filing of this Information.
ALL IN VIOLATION OF TITLE 15, UNITED STATES CODE, SECTION 1.