Case 1:26-cr-00177-KAM Document 1 Filed 06/12/26 Page 18 of 29 PageID #: 91
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transactions and series of transactions of the City of New York involving things of value of $5,000 or more, while the City of New York was in receipt of, in any one year period, benefits in excess of $10,000 under one or more Federal programs involving grants, contracts, subsidies, loans, guarantees, insurance and other forms of Federal assistance, contrary to Title 18, United States Code, Section 666(a)(2); and
(c) to use one or more facilities in interstate and foreign commerce
with intent to promote, manage, establish, carry on and facilitate the promotion, management, establishment and carrying on of one or more unlawful activities, to wit: Bribery in the Third Degree, in violation of New York Penal Law Section 200.00; Bribe Receiving in the Third Degree, in violation of New York Penal Law Section 200.10; and Criminal Liability for Conduct of Another, in violation of New York Penal Law Section 20.00, and thereafter to perform acts to distribute the proceeds of such unlawful activity and to promote, manage, establish, carry on and facilitate the promotion, management, establishment and carrying on of such unlawful activity, contrary to Title 18, United States Code, Section 1952(a)(3)(A).
50. In furtherance of the conspiracy and to effect its objects, within the
Eastern District of New York and elsewhere, the defendants ANTHONY J. CARONE, FRANK V. CARONE, CRYSTAL CHEN, and YAN PO ZHU, also known as “Andy Zhu,” together with others, did commit and cause the commission of, among others, the following overt acts:
OVERT ACTS
a. On or about September 19, 2022, the defendant FRANK V.
CARONE and the defendant YAN PO ZHU, also known as “Andy Zhu,” exchanged text
messages in furtherance of steering an Emergency Shelter Contract to the Microtel.