This document is available in three formats: this web page (for browsing content), PDF (comparable to original document formatting), and WordPerfect. To view the PDF you will need Acrobat Reader, which may be downloaded from the Adobe site. For an official signed copy, please contact the Antitrust Documents Group.

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA


UNITED STATES OF AMERICA,    

                  v.

DUNN ENGINEERING
ASSOCIATES, P.C.



|
|
|
|
|
|
|
|
|         

Criminal No.: 05 CR 128

Filed: 04/11/05

Violation: 18 U.S.C. § 201(c)(1)(A)



INFORMATION

The United States of America, acting through its attorneys, charges:

I.

The Defendant

1. Dunn Engineering Associates, P.C. ("Defendant") is a professional corporation organized and existing under the laws of the State of New York.

II.

Description of the Offense

2. From approximately May 24, 2001 to June 07, 2003 the Defendant performed traffic engineering services for the Traffic Services Administration, a division of the District of Columbia's Department of Transportation (hereinafter collectively referred to as the "D.C. D.O.T.") under its $17.5 million Integrated Traffic Management System ("I.T.M.S.") contract.

3. At all times relevant to this Information D-1 and D-2, neither of whom is named as a defendant herein, were principals, officers and owners of the Defendant with supervisory authority for the Defendant's performance of the I.T.M.S. contract.

4. From approximately May 2001 to April 2003 A-1, not named as a defendant herein, was the D.C. D.O.T. Associate Director charged with the administration and oversight of the I.T.M.S. contract.

5. On or about October 18, 2002 the Defendant, through D-2 after consultation with D-1, gave an item of personal value to A-1, to wit, it paid a $1,348.91 hotel bill for and on behalf of A-1.

6. In giving the item of personal value detailed in Paragraph 5 both D-1 and D-2 were acting within the scope of their respective employment as officers of the Defendant and with an intent to benefit the Defendant.

7. The gift of the item of personal value detailed in Paragraph 5 was not provided for by law for the proper discharge of A-1's official duty.

8. The Defendant, through D-1 and D-2, gave the item of personal value detailed in Paragraph 5 for an official act to be performed by A-1, a public official, to wit, favorable treatment of the Defendant by A-1 in his future administration and oversight of the I.T.M.S. contract.

III.

Jurisdiction and Venue

The offense charged in this Information was carried out in the District of Columbia within the five years preceding the filing of this Information.

ALL IN VIOLATION OF TITLE 18 UNITED STATES CODE, SECTION 201(c)(1)(A).

DATED: 04/11/05

_______________/s/________________
R. HEWITT PATE
Assistant Attorney General

_______________/s/________________
SCOTT D. HAMMOND
Deputy Assistant Attorney General

_______________/s/________________
MARC SIEGEL
Director of Criminal Enforcement

_______________/s/________________
LISA M. PHELAN
Chief, National Criminal
Enforcement Section

Antitrust Division
United States Department of Justice

_______________/s/________________
PETER H. GOLDBERG
Attorney, Antitrust Division
United States Department of Justice
1401 H Street, NW, Suite 3700
Washington, D.C. 20530
Tel: (202) 307-5784

_______________/s/________________
JOHN SCHMOLL
Attorney, Antitrust Division
United States Department of Justice
1401 H Street, NW, Suite 3700
Washington, D.C. 20530
Tel: (202) 307-5780