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IN THE UNITED STATES DISTRICT COURT
THE UNITED STATES CHARGES THAT:
1. From approximately September 1991 through approximately April 1995, in the Eastern District of Virginia and elsewhere,DONALD M. KOTOWICZ,
defendant herein, and others entered into and engaged in a combination and conspiracy to rig bids at certain public real estate auctions in the Eastern District of Virginia.
2. 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:
The proceeds of the secret auctions were distributed as payoffs to the conspirators in return for suppressing competition at certain public real estate auctions.
3. For the purpose of forming and carrying out the charged combination and conspiracy, the defendant and co-conspirators did the following, among other things:
4. The business activities of the defendant and his co-conspirators that are the subject of this Information were within the flow of, and substantially affected, interstate trade and commerce.
(A violation of Title 15, United States Code, Section 1.)