The Laborers Network
http://www.thelaborers.net/
United States Courthouse, Suite
9200
I Courthouse Way
Boston, Massachusetts 02210
January 27,2000
Brendan
V. Sullivan, Jr.
Howard
W. Gutman
Williams
& Connolly
725
12th St., N.W.
Washington,
D.C. 20005-5901
Re:
Arthur A. Coia
Criminal No- 00-
Dear
Mssrs. Sullivan and Gutman:
This letter sets forth the Agreement
between the United States Attorney for the District of Massachusetts
(“the U.S., Attorney”) and your client, Arthur A. Coia (“’Defendant”) in the
above captioned case. The Agreement is as follows:
1. Entry of Plea
Defendant shall today plead guilty to
the annexed Information. (In the event the Court’s schedule does not permit the
entry of Defendant’s plea today, the plea shall be entered at the earliest
practicable date). Defendant expressly and unequivocally admits that he in fact
knowingly and intentionally committed the crime charged in the Information, and is in fact guilty of that offense. The U.S.
Attorney and Defendant agree to the accuracy of the attached Agreed Factual
Basis, which represents the factual basis for the Information.
2.
Penalties
Defendant faces the following maximum
penalties; Five years’ imprisonment; $250,000 fine; three years’ supervised
release; $100 special assessment.
3.
Sentencing Guidelines
The parties
agree to jointly take the following positions at sentencing with regard to offense
conduct, adjustments and criminal history under the United States Sentencing
guidelines:
a) The applicable guideline to Count one is
U.S.S.G. §2F1.10 with a base offense level of 6.
b) The loss resulting from
the defendant's conduct is $99,646.79, and therefore a six-level enhancement is
warranted pursuant to U.S.S.G, §2F1.,1(b)(1)(G).
c)
The
offense involved more than minimal planning and involved a
scheme to defraud more than one victim, and therefore a two-level enhancement-is
warranted pursuant to U.S.S.G. §2F2.1(b)(2),
d) The defendant is entitled to a two-level
reduction for acceptance of responsibility pursuant to U.S.S.G. §3EI,I(a).
e) The defendant is entitled to a
four-level downward departure pursuant to U.S.S.G. §5K2.0 for his cooperation
in the reform process of the Laborers’ International Union of North America.
f) According to the information presently
available to the U.s. Attorney, the Defendant is in criminal history category
1. The guideline range for level 8, criminal history category I is 0-6 months.
The U.S. Attorney’s agreement that the
disposition set forth in Paragraph 4 below is appropriate in
this case is based, in part, on Defendant’s prompt acceptance of personal
responsibility for the offense of conviction in this case, as reflected by his
agreement to the attached Agreed Factual Basis.
The U.S. Attorney specifically may, at
his sole option, be released from his commitments under this Agreement,
including, but not limited to, his agreement that paragraph 4 constitutes the
appropriate disposition of this case, if at any time between his execution of
this Agreement and-sentencing, Defendant:
a.
Fails to admit a complete factual basis for
the plea;
b. Fails to truthfully admit his conduct in the
2
offenses
of conviction;
c. Falsely denies
or frivolously contests, relevant conduct for which Defendant is accountable
under U.S.S.G. §1B1.3;
d.
Fails to provide truthful information to the United States
Probation Office about his financial status, unless relieved of that obligation
by the Court;
e. Gives false or misleading
testimony in any proceeding relating to the criminal
conduct charged in this case and any relevant conduct for which Defendant is
accountable under U.S.S.G. 5 1B1.3. The U.S. Attorney will not seek testimony
from the Defendant between his execution of this
Agreement and sentencing;
f. Engages in acts which form a
basis for finding that Defendant has obstructed or impeded the administration
of justice under U.S.S.G. § 3C1.1;
g. Intentionally
fails to appear in Court or violates any condition of release; and/or
h.
Commits a crime.
The U.S. Attorney hereby agrees that Defendant’s
agreement to the attached Agreed Factual Basis satisfies provisions (a)-(c)
above and that testimony adopting the Agreed Factual Basis would satisfy (e) in the event Defendant
were called to give testimony. Defendant expressly understands that he may not
withdraw his plea of guilty, unless the Court rejects or modifies this
Agreement under Fed. R. Crim. P. 11(e)(4).
4. Agreed Disposition
The U.S. Attorney and Defendant agree pursuant to
Fed. R. Crim. P. 11(e)(1)( C ) that the following is the appropriate
disposition of this case:
a. A two Year term of probation. The
conditions of probation shall be: the conditions and agreements set forth in
paragraph 5 below, which shall be imposed as special conditions of probation
subject to the provisions of paragraphs 5 and 11©, below; the mandatory
conditions set forth in 18 U.S.C. § 3563 (a) (1) and (3); and the conditions of
3
probation set forth in 18 U.S.C, § 3563 (b) (8) 1 (b) (15),
(b)(17), and (b)(18) The United States Attorney and Defendant agree that the
conditions set forth in 18 U.S.C. § 3563(b)(2) will be satisfied on the date of
the guilty plea and that therefore 18 U.S.C. § 3563(a) (2) is satisfied. The
U.S. Attorney and Defendant agree that the reporting requirements set forth at
18 U.S.C. § 3563(b)(15) and (b)(17) should reflect that Defendant does not
reside in this judicial district and may choose, inter..a1ia to retire
or become self-employed.
b.
A fine of $10, 000.
c.
Restitution of the tax loss of $99,646.79 to the
State
of Rhode Island and the Town of Barrington, Rhode Island.
d.
$100 special assessment.
The appropriate disposition of this case includes no home confinement, intermittent confinement, or
incarceration, and no restitution,
forfeitures, fines or other sentence or conditions of probation except as
expressly set forth in this Agreement. The U.S. Attorney and Defendant agree
that there is no basis for departure from the sentencing range established by the United States Sentencing Guidelines, except as explicitly
described in paragraph 3, above, The U.S. Attorney and the Defendant further
agree that the Defendant shall pay the fine~ restitution, and special
assessment set forth in this paragraph on the day of pleading guilty. In the
event the Court rejects this agreement pursuant to Fed. R. Crim. p. 11(e)(4)
and the Defendant withdraws his plea of guilty, these funds shall be returned
to the Defendant.
5. Agreement
Concerning Future Union Activities
a. On January 1,
2000, the Defendant retired as General President from the Laborer’s
International Union Of North America (“LIUNA”) and became the General President
Emeritus, an honorary position that involves no service as a consultant or adviser
(as those terms are used and defined for purposes of 29 U.S.C. § 504) to LIUNA
or any of its affiliated or subordinate entities, and which involves
no decision making authority concerning or over, or control over LIUNA or any of its
affiliated or subordinate entities. For purposes
4
of this Agreement, the term “affiliated
or subordinate entities” includes any labor organization, employee benefit
plan, labor management cooperation committee, or trust established or
maintained by LIUNA or any of its subordinate labor organizations.
b.
The U.S. Attorney and the Defendant hereby agree
that, as a result of his guilty plea, and as a condition of his probation (in
accord with paragraph 11 (C), below), the Defendant will remain retired from
LIUNA as General President Emeritus pursuant to the terms of compensation on
the date of his retirement and will be barred, whether within or outside LIUNA,
from any service as a consultant or adviser (as those terms are used and
defined f or purposes Of 29 U.S.C. § 504) to LIUNA or any of its affiliated or
subordinate entities, or in any capacity from any decision making authority
concerning or over, or control over LIUNA or any of its affiliated or
subordinate entities. In addition, the U.S. Attorney and the Defendant hereby
agree that, as a result of his guilty plea and as a condition of his probation
(in accord with paragraph 11 (C), below), the Defendant will not accept any
compensation increases from LIUNA above the level of the current
constitutionally-mandated salary of the General President.
c. The U.S.
Attorney and the Defendant hereby agree that the Defendant, as a result of his
guilty plea and as a condition of his probation (in accord with paragraph 11
(C), below) shall be disqualified by operation of law from serving in any of
the capacities described in 29 U.S.C. § 1111 for the period specified in that
statute unless the sentencing court sets a lesser period pursuant to U.S.C. §
1111(a). The U.S. Attorney and the Defendant agree that pursuant to the
definition of “consultant” set forth in 29 U.S.C. § 1111(c) (2), the Defendant
is not precluded from working for an entity that provides goods or services
(including, but not limited to, consultation, advice, or other assistance) to
an employee benefit plan so long as he is not personally involved in the
provision of such consultation, advice, or other assistance. The U.S. Attorney
and the Defendant further agree that to the extent it is necessary, the
U.S.
5
Attorney
will join in a motion pursuant to 29 U.S.C.§ 1111 (a) (B) to give effect to
this understanding.
d. The United
States Attorney and the Defendant hereby agree that, consistent with-subparagraphs 5(a) and 5(b), above, the
Defendant, as a result of his guilty plea and as a condition of his probation (in accord with
paragraph 11 (C) , below) , shall be disqualified from serving: (a) as a consultant or adviser, as those terms are used in 29 U.S.C.
§ 504 (a) (1) , to LIUNA or any of its affiliated or subordinate entities;
(b) as an officer, director, trustee, member of any executive board or similar governing body,
business agents manager, organizer, employee, or representative, as those terms are used in 29
U.S.C. § 504(a)(2), of LIUNA or any of its affiliated or subordinate entities; and (c) in any capacity
that involves decision making authority concerning, or decision making authority over, or custody of, or
control of the moneys, funds, assets, or property of LIUNA or any of its affiliate or subordinate
entities, as those terms
are
used in 29 U.S.C. § 504(a) (5).
e. The United States Attorney and the
Defendant hereby agree that, consistent with subparagraphs 5(a) and 5(b),
above, the Defendant will also he barred personally from serving for a period
of five years as an employee of any other labor organization, including as an
officer, director, trustee, member of any executive board or similar governing
body, business agent, manager, or organizer, as those terms are used in 29
U.5.C. § 504(a)(2).
f.
Nothing in this
agreement shall be construed to preclude the Defendant from serving: (a) as a
consultant or adviser, as those terms are used in 29 U. S. C. § 504 (a)
(1), to labor organizations other than LIUNA or any of LIUNA’s affiliated or
subordinate entities; (b) as a labor relations consultant
or adviser to a Person engaged in industry or activity affecting commerce, or
as an officer, director, agent, or employee of any group or
association of employers dealing with any labor organization, or
in a position having specific collective bargaining authority or direct
responsibility in the areas of labor-management
6
relations
in any corporation or association engaged in
an industry or activity affecting commerce, as those ‘terms are
used in 29 U.S.C. § 504 (a) (3), except that in such capacities, the
Defendant shall not personally serve as a consultant, adviser, or labor
relations consultant (as those terms are used and defined for
purposes of 29 U.S.C. § 504) to LIUNA or any of its affiliated or subordinate entities.
Further, in any of the capacities listed’ in this paragraph, the Defendant may
not receive any compensation that is calculated based, on proceeds or profits
from any dealings with LIUNA or any of its affiliated or subordinate entities.
g. The
provisions of subparagraphs 5 (a), (b) , (d) , (e.) and (f) above shall be imposed
consistent with paragraph 11 ©, below, and in lieu of any
other bar under 29 U.S.C. § 504, if any.
6. Waiver of Rights to Appeal and to Bring Collateral Challenge
Defendant is aware that he has the right
to challenge his sentence and guilty plea on direct appeal. Defendant is also aware that he may, in Some circumstances, be
able to argue that his plea should be set aside, or his sentence set aside or
reduced, in a collateral challenge such as pursuant to a motion under 28 U.S.C. § 2255.
In consideration of the concessions made
by the U.S. Attorney in this Agreement, Defendant knowingly and voluntarily
waives his right to appeal or collaterally challenge:
(1)
Defendant’s guilty plea and any other aspect of
Defendant’s conviction, including, but not limited to, any ruling on pretrial
5uppression motions or any other pretrial dispositions$ of motions and issues;
and
(2)
The imposition by the District Court of the sentence
agreed to by the parties, as set out in paragraph 4, even if the Court rejects
one or more positions advocated by the parties with regard to the application
of the U.S. Sentencing Guidelines.
7.Plea Tendered Pursuant to Fed. R. Crim P. 11(e)(1)(C) an
11(e) (4)
The sentencing disposition agreed upon by the parties and
7
their respective calculations under the
sentencing Guidelines are not binding upon the United States Probation Office. Defendant’s
plea will be tendered pursuant to Fed. R. Crim.P.11(e)(1)(C) and 11 (e) (4).
Defendant cannot withdraw his plea of guilty unless the sentencing judge rejects or modifies this Agreement. I f the
sentencing judge rejects or modifies this Agreement,
or in the event the U.S. Attorney withdraws from this Agreement pursuant to
paragraph 3 of thi5 Agreement, this Agreement shall become null and void and
none of its terms and conditions will be binding on either party. The U.S.
Attorney agrees that in the event the Court rejects this Agreement and the
Defendant withdraws his plea of guilty, or in the event the U.S.
Attorney withdraws from this Agreement pursuant to paragraph 3 of this
Agreement, no writings, agreements, Agreed Factual Basis,
admissions, or other statements made by either party or their counsel during or
following these plea negotiations shall be admissible for any purpose at any
proceeding.
8.Civil
Liability
By entering into this Agreement, the U.S. Attorney does not compromise any civil,
maritime, or administrative liability, if any, Which Defendant may have
incurred or may incur as a result of his conduct and his plea of guilty to the
charge specified in paragraph I of this Agreement.
9.
Withdrawal of Plea By Defendant
Other than as provided in paragraph 7 above, should Defendant move to withdraw his guilty plea at any time, this Agreement shall -be null and void at the option of the U.S. Attorney.
10. Expedited
Sentencing Date
The U.S. Attorney and the Defendant
agree to seek sentencing today, if the Court is available and willing, and if
not, to seek an expedited sentencing date from the Court.
11.
Breach of Agreement
(A) If the U.S.
Attorney determines that Defendant has failed to comply with
any Provision Of this Agreement, has violated any condition of his pretrial
release, or has committed any crime following his execution of this Agreement
through the termination of his period- of probation, the U.S. Attorney may, at
his sole option be released from his commitments under this Agreement in their
entirety by notifying Defendant, through counsel or otherwise, in writing, The
U.S. Attorney and the Department of
8
Justice
may also pursue all remedies available to them under the law, irrespective of
whether the U.S. Attorney elects to be released from his commitments under this
Agreement. Further, the U.S. Attorney and the Department of Justice may pursue
any and all charges which have been, or are to be, dismissed or not initiated pursuant
to this Agreement. Defendant recognizes that no such breach by him of an
obligation under this Agreement shall give rise to grounds for withdrawal of
his guilty plea. Defendant understands that, should he breach any provision of
this Agreement through the termination of his period of probation, the U.S. Attorney
will,
have the right to use against Defendant before any grand jury, at any trial or
hearing, or for sentencing purposes, any statements which may be made by him
subsequent to this agreement, and any information, materials, documents or
objects which may be provided by him to the government subsequent to
this Agreement, without any limitation. In this regard, Defendant hereby waives
any defense to any charges which he might otherwise have under any statute of
limitations or the Speedy Trial Act, not to include any
such defenses that he had at the time of the signing of this Agreement.
(B) For purposes of paragraph 11(A)
above, other than with respect to a violation of paragraph 5 of this Agreement (which is covered in
paragraph 11 (C), below), the U.S. Attorney and Defendant agree that, following
sentencing, unless Defendant commits a crime following his execution of this
agreement through then, term of his probation, Defendant has complied with all
provisions and conditions referred to in paragraph 11(A)-
(C) The U.S. Attorney and Defendant
agree that if, at any time following sentencing and prior to the end of his
term of probation, the Court determines that Defendant has committed a material
breach of paragraph 5 of this Agreement, the Court may find a violation of
probation and shall have the authority to enter an appropriate order,
including, but not limited to, the payment by the Defendant to the United States of
any proceeds or profits derived from this breach, and in addition, any other
appropriate fine. If, following the term of probation, the Court determines
that Defendant has committed a material breach of paragraph 5 of this
Agreement, the Court may find the Defendant in contempt of an order of the
Court and shall have the authority to enter an appropriate order, including,
but not limited to, the payment by the Defendant to the United States of any
proceeds or profits derived from this breach, and in addition, any other
appropriate fine, Nothing in this paragraph is intended to limit the statutory
authority of the Court set forth in 16 U.S.C. § 3565 or any other applicable
statute to punish material breaches of paragraph 5.
9
12,
Who is Bound By Agreement
In the event the
Court accepts this Agreement and the Defendant is sentenced pursuant to this
Agreement, the U.S. Attorney agrees that he will not prosecute the Defendant
for any act, conduct, transaction, or offense, if any, that is known by the
Organized Crime and Racketeering Section of the Department of Justice or the
U.S. Attorney on the date of the signing, of this Agreement. The U.S. Attorney
also will not prosecute any member of Defendant’s immediate family for any act,
conduct, transaction,, or offense,, if any,, related to the conduct alleged in
the attached Information, or related to any conduct involving
personal vehicles that occurred prior to the date of the signing of this
Agreement. In addition, as evidenced by Attachment A hereto, the Deputy
Assistant Attorney General of the Criminal Division of the Department of
Justice agrees that the United States will not prosecute the Defendant for any
act,, conduct,, transaction, or offense, if any, that is known by the Organized
Crime and Racketeering Section of the Department of Justice or the U.S.
Attorney on the date of the signing of this Agreement. As is also evidenced by
Attachment A hereto, the Deputy Assistant Attorney General of the Criminal
Division of the Department of Justice agrees that the United States will not
prosecute any member of Defendant’s immediate family for any act, conduct,
transaction, or offense, if any, related to the conduct alleged in the attached
Information, or related to any conduct involving personal vehicles that
occurred prior to the date of the signing of this Agreement. This Agreement is
otherwise limited to the U.S. Attorney for the District of Massachusetts, and
cannot and does not otherwise bind the Attorney General of the United States or
any other federal, state or local prosecutive authorities, This paragraph shall
not preclude prosecution for an act involving murder or other crime of
violence.
13.
No Waiver of Attorney-Client Privilege
The parties agree that neither
Defendant’s signing of the Acknowledgment nor any other part of this agreement
shall be construed as a waiver of Defendant’s attorney-client privilege or the
work-product doctrine.
14.
Complete Agreement
This letter contains the complete and only
agreement between the parties relating to the disposition of this case. No
promises, representations or agreements have been made other than those set
forth in this letter. This Agreement supersedes prior under5tandings, if any, of the parties, whether written or oral.
10
This
Agreement can be modified or supplemented only in a written memorandum signed by
the parties or on the record in court.
11
If this letter accurately reflects the
Agreement between the U.S. Attorney
and Defendant, please have Defendant sign the Acknowledgment of Agreement
below. Please also sign below as witness. Return the original of this letter to
Assistant U.S. Attorneys Alex Whiting and Ernest S. DiNisco.
Very
truly yours,
DONALD
K. STERN
United
States Attorney
BY s/James
B. Farmer
JAMES B. FARMER
Assistant
U.S. Attorney
Chief,
Criminal Division
STEPHEN P. HEYMANN
Assistant
U.S. Attorney
Deputy
Chief,
Criminal
Division
ALEX WHITING
ERNEST S. DiNISCO
Assistant
U. S. Attorneys
12
ACKNOWLEDGMENT OF
PLEA AGREEMENT
I have read this letter in its entirety
and discussed it with my attorney. I hereby acknowledge that it fully sets
forth my agreement with the United States Attorney’s Office for the District of
Massachusetts. T further state that no additional promises or representations
have been made to me by any official of the United States in connection with
this matter. I understand the crime to which I have agreed to plead guilty, the
maximum penalties for the offense and Sentencing Guideline penalties
potentially applicable to it. I am satisfied with the legal representation
provided to me by my attorney. We have had sufficient time to meet and discuss
my case. We have discussed the charge against me, possible defenses I might
have, the terms of this Plea Agreement and whether I should go to trial. I am
entering into this Agreement freely, voluntarily, and knowingly because I am
guilty of the offense to which I am pleading guilty and I believe this
Agreement is in my best interest,
s/Arthur Coia
ARTHUR A. COIA
Defendant
Date:
1/27/00
I
certify that Arthur A. Coia has read this Agreement and that we have discussed
its meaning, I believe he understands the Agreement and is entering into the
Agreement voluntarily and knowingly.
s/Howard Gutman.
Brendan V. Sullivan, Jr.
Attorneys for Defendant
13
AGREED FACTUAL BASIS
From in or about June, 1991, through in
or about September, 1997, in the District of Rhode Island, the District of Massachusetts,
and elsewhere, the defendant, ARTHUR A. COIA, whose permanent abode was in
Barrington, Rhode Island, knowingly defrauded the State of Rhode Island and the
Town of Barrington of certain automobile tax revenues by engaging in the
following course of conduct:
1. On or about July 30, 19911 the defendant,
ARTHUR A. COIA, purchased a 199.1 Ferrari F-40 (“the F-40”), vehicle
identification number ZFFMN34A6MOO89653, from Autohaus, a Ferrari dealership
located in Cohasset, Massachusetts, for $450,0OO in the name of Viking. (A
close personal friend of Coia’s for at least 40 years was the President and
owner of a group of automobile businesses and dealerships that operated under
the name Viking, and had businesses located inter alia, in Middletown and
East Providence, Rhode Island.) In or about March, 1993, the defendant,
ARTHUR A. COIA, purchased the F-40 from Viking for $275, 000, and obtained
financing through Viking from the Chase Manhattan Bank. Viking collected no use
tax on this transaction, and the defendant, ARTHUR A. COIA, paid no use tax
to the State of Rhode Island in connection with his use and storage of the
F-40. The use tax due and owing to the State of Rhode Island for this
transaction was 7% of $275,000, or $19,250.
2. On or about February 28, 1990, the defendant, ARTHUR A.
COIA,
purchased a 1972 Ferrari Daytona (“the Daytona”), vehicle identification number
16549,. from Shelton Sports Cars in Fort Lauderdale, Florida, for $1,050,000. on
or about August 18, 1993, the defendant, ARTHUR A. COIA, caused the Daytona to
be fraudulently registered to Viking’s address on East Main Road in Middletown,
in order to evade paying the higher excise tax rate in Barrington. As COIA
continued to reside in Barrington and the Daytona was not garaged in
Middletown, the local excise tax on the vehicle was due to Barrington. However,
the fraudulent registration of the vehicle in Middletown caused it to be taxed
at the lower rate in Middletown, rather than in Barrington. In or about
February or March, 1994, COIA renewed the registration on the Daytona,
again at Viking’s address on East Main Road in Middletown. Accordingly, the Daytona
continued to be taxed by Middletown, rather than by Barrington, through the 1996
tax year. In total, the defendant, ARTHUR A. COIA, defrauded the Town of
Barrington of $57,865.01 in taxes in connection with his ownership of the
Daytona.
3. In or about August, 1993, the defendant, ARTHUR
A. COIA, purchased a 1973 Ferrari 365 GTB4 (“the 365 GTB”), vehicle
identification number 365GTB416943, from Ferrari of Los Gatos in Los Gatos,
California, for $215,000. On or about September 10, 1993, the defendant, ARTHUR
A. COIA, used a fraudulent invoice from Viking Pontiac for $2,160 to register
the vehicle without paying
2
the full use tax of $15,050 due to the
State of Rhode Island. C01A was able to register the vehicle in Rhode Island
while paying a use tax of only seven percent of $2t160, or $151.20.
4. The defendant, ARTHUR A. COIA, also caused
the 365 GT8 to be fraudulently registered to Viking’s address on East Main’
Road in Middletown, again in order to evade paying the higher excise tax rate in Barrington. As COIA continued to reside in Barrington and
the 365 GTB was not garaged in Middletown, the local excise tax on the vehicle
was due to Barrington. However, the fraudulent registration of the vehicle in
Middletown caused it to be-taxed at the lower rate in Middletown, rather than
in Barrington. In or about February, 1994, COIA renewed the registration on the
365 GTB, again at Viking’ s address on East Main Road in Middletown.
Accordingly, the 365 GTB continued to be taxed by Middletown, rather than by
Barrington, through the 1994 tax year, after which the vehicle’s registration
was changed back to the COIA’s Barrington address and taxes were thereafter
paid to Barrington. In total, the defendant, ARTHUR A. COIA, defrauded the Town
of Barrington of $7,632.98 in taxes in connection with his ownership of the 365
GTB.
5. In or about August, 1995, the defendant, ARTHUR
A. COIA, for
the purpose of defrauding the state and local taxing authorities of tax
revenues owed on certain automobiles, did knowingly and willfully cause a tax
bill from the Town of
3
Barrington
for the tax year 1994 to be sent to COIA’s residence in Barrington by the Postal Service by mail.
DONALD
K STERN
United
States Attorney
By:
s/JAMES B. FARMER
James B Farmer
Assistants U.S. Attorney
Chief,
Criminal
Division
STEPHEN
P. HEYMANN
Assistant
U.S. Attorney
Deputy
Chief,
Criminal
Division
ALEX
WHITING
ERNEST
S. DiNISCO
Assistant
U. S. Attorneys
S/Arthur Coia
ARTHUR A.COIA
Defendant
Date: 1/27/00
s/Howard Gutman
Brendan V. Sullivan, Jr.
Howard
W. Gutman
Attorneys
for Defendant
Date:
1/27/00
4
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Laborers for JUSTICE© 1999 All Rights reserved
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2615 W Peterson Av
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