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Essential to this committee's understanding of why I know the charges against me, the IRB's Opinion and Decision and the District Court's approval thereof were politically motivated, is an understanding of the history of the relationship between myself and Ron Carey. Prior to August 3, 1993, when I, in my capacity as an International Trustee, with the two other trustees, wrote Carey a letter (See Exhibit A) questioning his handling of the IBT's finances, I had the full and uncompromised support of Carey and my character and integrity were never questioned.

Some examples of Carey's respect for my character and integrity are as follows. On February 17, 1992, Carey requested that I escort him to a luncheon at the AFL-CIO winter meeting in Miami with elected Illinois politicians and labor leaders. On March 3, 1992, Carey appointed me Chairman of a three-man panel to hold hearings on trusteeship issues involving Local 1714 in Washington, D.C. On April 29, 1992, Carey appointed me to be a member of the three-man panel charged with hearing a jurisdictional dispute involving Local 413. This same day, Carey later appointed me to be a member of another three-man panel to conduct a hearing concerning a raid of Local 407. On November 24, 1992, Carey appointed me Chairman of a three-man panel to hear the trusteeship hearing concerning Local 507 in Cleveland, Ohio, which was headed by Harold Friedman. On January 13, 1993, Carey made me Trustee of Local 703, after he had removed Daniel Ligurotis.

forever.

In June of 1993, my relationship with Carey changed
From June 15-17, 1993, myself and the two other

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International Trustees performed an audit of the IBT's finances and discovered that the union was in a negative financial condition that put its financial stability in serious peril. Specifically, our audit showed, among other things, a significant increase in operating costs, low rates of return on our investments, and exorbitant per capita/affiliation fees.

In connection with this audit, in August of that year, myself and two other Trustees sent Carey a letter concerning these discrepancies and Carey's handling of the IBT's finances. (See Exhibit A.) We informed Carey that with a per capita tax at 3% per month and IBT membership having declined to below 1.5 million, prudence dictated that we devote our immediate attention to addressing the financial crisis facing the Union. To help this crisis we suggested to Carey that we look into the following areas for cutbacks:

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An immediate freeze on hiring.

A review of our compensation and benefits policies and practices.

A reduction in Executive headquarters staff.

The elimination of all non-essential positions.

A review of the qualifications, duties, responsibilities, and need for all International Representatives hired in 1992 and 1993.

Place an immediate hold on hiring any new employees
to the organizing department and review all 1992
and 1993 hires, their IBT affiliation, membership,
experience, etc.

The IBT should cease paying the employee portion of
FICA.

II.

Devise a more modest policy to replace the unlimited sick leave policy now in existence.

All IBT officers and employees in a country other than the U.S. should be compensated based upon the position's value in the relevant labor market of that country.

EXPENSE REIMBURSEMENT, TRAVEL AND RELATED PRACTICES

A return to a per diem method or expense reimbursement system and the elimination of IBT credit cards, with minor exceptions.

Impose stringent controls on all IBT air travel, car rentals and hotel expenses. Require IBT employees to cease the use of limousine service and utilize shuttle service and taxi-cabs when shuttles are unavailable.

Control the frequency of travel by General Executive Board (GEB) members and other employees to or from the IBT offices in Washington, D.C. The purpose and duration of the stay should be established prior to travel.

III. STRIKES AND OUT-OF-WORK BENEFITS

Establish a procedure for site review of strikes, the eligibility of members for out-of-work benefits including, but not limited to, whether recipients are employed elsewhere, if strikers would have been on layoff at the strike company, and determination of when strikes or boycotts are ineffective, lost, terminated, or abandoned.

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The IBT organizing department must be immediately surveyed as to the costs being incurred; personnel employed; compensation and expenses of personnel, the origin and experience of the personnel employed; and of course, we need to know how many millions of dollars are already spent; the number of new members who are under a contract and paying dues since the advent of the budget (multi-million) to put on these organizing drives.

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Reduce the printing of the IBT Magazine to six (6) times per year or quarterly. In addition, immediate consolidation or elimination of the Teamster News Releases and the Teamster Leader to reduce postage, handling, materials and printing costs.

VI. AFL-CIO AFFILIATION FEES

Decrease all affiliation fees to the AFL-CIO and their subdivisions by at least 50% of our current outlays.

VII. LUNCHROOM

The lunchroom's menu should be substantially modified to provide a more modest offering of soups, salads, sandwiches, dessert and beverages.

VIII. CONVENTION

It is most imperative that a convention be convened immediately to address the fiscal/financial issues that are taking irreversible tolls on our Union. The convention, amongst other issues, must address per capita taxes; affiliation fees; payroll and staffing of the IBT; strike benefits and all matters which impact the IBT negatively.

On or about September 17, 1993, myself and the other Trustees received a vicious, self-serving letter from Carey

regarding our questioning of his financial management of the IBT. In this letter Carey attacks me and the other Trustees for questioning his handling of IBT finances. In this letter, Carey states that "[i]f the tone of this letter seems sharp, it is meant to be."

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At a September 20-23,

1993 General Executive Board

and the other

meeting, Carey for the first time informed me Trustees that we were not welcome to stay when the Board went into Executive Session. We protested to no avail. On or about January 2-4, 1994, at another General Executive Board meeting, Carey again informed us that we were no longer welcome.

After we sent Carey the August 3, 1993 letter questioning his handling of IBT finances, Carey never asked me to serve on any more hearing panels. Furthermore, Carey's former constant contacts with me ceased, and Carey contacted me only through the IBT's General Counsel. Most telling, on June 30, 1994, less than one year after I questioned Carey's handling of IBT finances, these bogus charges were brought against me and led to my removal from office and the destruction of my career.

Specifically, the charges brought against me alleged that I brought reproach upon the IBT and violated the IBT's Constitution for allowing Peters to serve as a representative of Local 743 after his mandatory retirement in 1989. On December 20 and 21, 1994, the IRB held the hearing on the charges against me. At this hearing, the Chief Investigator did not present a single witness to testify in support of the charges. The only evidence the Chief Investigator offered was three volumes of exhibits relating to the charges. The Chief Investigator refused to even make a closing argument.

In response, through representation by Dan Webb and the law firm of Winston & Strawn, I offered four volumes of exhibits in

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