The United States, through its attorneys, charges that:
DESCRIPTION OF THE OFFENSE
1. Beginning at least as early as 1999 and continuing until as late as May 2007, the exact dates being unknown to the United States, in Houston in the Southern District of Texas, and elsewhere, co-conspirators of the defendant,
did enter into and engage in a combination and conspiracy to suppress and eliminate competition by rigging bids, fixing prices and allocating market shares for sales of marine hose in the United States and elsewhere. The combination and conspiracy was in unreasonable restraint of interstate and foreign trade and commerce in violation of Section 1 of the Sherman Antitrust Act (15 U.S.C. § 1).
2. Defendant CHARLES J. GILLESPIE joined and participated in the conspiracy from at least as early as 2000 until as late as May 2007.
3. The charged combination and conspiracy consisted of a continuing agreement, understanding, and concert of action among the defendant and co-conspirators, the substantial terms of which were to rig bids, fix prices and allocate market shares for sales of marine hose in the United States and elsewhere.
4. For the purpose of forming and carrying out the charged combination and conspiracy, the defendant and co-conspirators did those things that they combined and conspired to do, including, among other things:
5. During the entire period covered by this Information, defendant CHARLES J. GILLESPIE was a Regional Manager in the Florida offices of a firm organized and existing under the laws of Italy, and with its principal place of business in Milan, Italy. During the entire period, this firm manufactured and sold marine hose in the United States and elsewhere.
6. Various corporations and individuals, not made defendants in this Information, participated as co-conspirators in the offense charged herein and performed acts and made statements in furtherance thereof.
7. Marine hose is a flexible rubber hose used to transfer oil between tankers and storage facilities and/or buoys. During the period covered by this Information, the conspirator firms shipped marine hose in a continuous and uninterrupted flow of interstate and foreign commerce across state lines in the United States and from locations outside the United States to companies located in the United States. In addition, substantial quantities of related equipment, as well as payments for marine hose, traveled in interstate and foreign commerce. The victims of this conspiracy included companies involved in the off-shore extraction and/or transportation of petroleum products, as well as the United States Department of Defense.
8. During the period covered by this Information, the business activities of the defendant and his co-conspirators in connection with the manufacture and/or sale of marine hose that are the subject of this Information were within the flow of, and substantially affected, interstate and foreign trade and commerce. During the conspiracy, the defendant and his co-conspirators sold hundreds of millions of dollars worth of marine hose and related products in the United States and elsewhere.
JURISDICTION AND VENUE
9. The combination and conspiracy charged in this Information was carried out, in part, within the Southern District of Texas within the five years preceding the filing of this Information.
All in violation of Title 15, United States Code, Section 1.