©1999

EXHIBIT K 
99C 5229

                                                    )
                                                    )
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In re    BRUNO CARUSO        )
            FRANK CARUSO         )
            LEO CARUSO               )      No._________________
            JAMES DiFORTI          )
                                                     )


DISCIPLINARY CHARGES

    Pursuant to Sections 3 and 5(a) of the LIUNA Ethics and Disciplinary Procedure, the General Executive Board Attorney ("GEB Attorney") hereby commences disciplinary proceedings against BRUNO CARUSO, FRANK CARUSO, LEO CARUSO and JAMES DIFORTI through the charges set forth below, The GEB Attorney alleges as follows:

  INTRODUCTION

    The Charged Persons

    1.     BRUNO CARUSO is an associate of the Chicago Outfit, BRUNO CARUSO currently holds the positions of President and Business Manager of Local 1001 and is a delegate to the Construction & General Laborers' District Council of Chicago and Vicinity ("Chicago District Council" or "CDC"). BRUNO CARUSO has held the following union positions, among others: President and Business Manager of the Chicago District Council, Trustee of the CDC's affiliated Welfare Fund and Chairman of the CDC's affiliated Political Action League.

    2.     FRANK "TOOTS" CARUSO is an associate of the Chicago Outfit. FRANK CARUSO resigned as a LIUNA member in April of 1995 but retains his right to reinitiate his LIUNA membership. FRANK CARUSO has held the following union positions, among others: President and Business Manager of Local 1006, Sergeant at Arms for the Chicago District Council, delegate to the Chicago District Council,, Trustee of the CDC's affiliated Laborers' Fund, and Director of the Chicago District Council's affiliated Pension Fund.

    3.     LEO CARUSO is an associate of the Chicago Outfit. LEO CARUSO currently holds the position of President/Business Manager of Local 1006 and is a delegate to the Chicago District Council. LEO CARUSO has held the following union positions, among others: Sergeant at Arms of the Chicago District Council, Executive Board Member and Secretary-Treasurer of Local 1006, and Trustee to the CDC's affiliated Pension Fund,

    4,     JAMES DiFORTI ("DiFORTI") is an associate of the Chicago Outfit and is currently under indictment for murder. DiFORTI resigned as a LIUNA member in July of 1997, but retains his right to reinitiate his LIUNA membership. DfFORT1 has held the following union positions, among others: Business Agent for Local 1002, Business Agent for Local 1006, Secretary-Treasurer of Local 5, Coordinator of Committees of the Chicago District Council, and delegate to the Chicago District Council.

    The Structure and Operations of the Chicago Outfit

    5.     La Cosa Nostra (the "LCN" also referred to as the "Mob" or the "Mafia", is a criminal organization operating in various cities throughout the United States. It Is in the business of profiting from illegal activity. The LCN is divided into units, each of which is called a "family". The Chicago family of the LCN is commonly referred to as the "Chicago Outfit" or the "Outfit".

    6.     The Chicago Outfit conducts illegal activities through entities known as "crews". Each crew is headed and supervised by a person generally referred to as a "crew boss" and consists of "made members." A "made member" is an individual who has been formally initiated into an organized crime family and shares in the profits of the criminal enterprise. Crews also

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consist of "associates", individuals who work on behalf of made members and/or who facilitate mob activities through their participation in illegal or legitimate enterprises.

    The 26' Street Crew
    7,     The 266 Street Crew (sometimes referred to as the "Southside" or "Chinatown" crew) of the Chicago Outfit operates out of the 26' Street or Chinatown area of Chicago Over the past three decades, the 26' Street Crew has been involved in gambling, chop shop operations, extortion, political corruption, union corruption and other forms of criminal activity.

    8.     Frank "Skids" Caruso was the boss of the 26' Street Crew from sometime in the 1950's through the 1970's. Angelo "The Hook" LaPietra became the boss of the 26' Street Crew W_ in or around the early 1980's until his conviction in the mid- I 980s on charges of conspiracy to illegally control gambling operations in Las Vegas and Teamsters Pension Fund operations in Chicago. Joseph "Shorty" LaMantia was a member and a supervisor of the 26' Street Crew for a number of years prior to his conviction on charges of racketeering conspiracy, gambling and extortion in or around 1996. Fred Roti was an Alderman for the I" Ward in Chicago who was involved in political corruption for a number of years until his conviction on charges of racketeering, bribery and extortion in or around 1993 John "Apes" Monteleone is the current boss of the 26' Street Crew and has been for a number of years.

    9.     Some other members or associates of the 26" Street Crew and/or the Chicago Outfit at various times over the past three decades are: Pat Marcy, James LaPietra, Richie "The Cat" Catazone, Donald "Captain D" DiFazio, Larry Pusiteri, Marco D'Amico, Robert "Bobby" Abbinante, Ken Eto, Frank Caruso, Joe Granata, James Peter "Duke" Basile, Leonard Patrick, James LaValley, William Jahoda, Richard Mara, Robert Cooley, Charles Francis ("Guy") Bills,

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"Dirge" Imperato and Michael Corbitt.

BRUNO CARUSO's Connections to The Chicago Outfit

    10,     BRUNO CARUSO is the son of former 26' Street Crew boss Frank "Skids" Caruso, the brother of mob associate FRANK CARUSO, the cousin of mob associate LEO CARUSO and the nephew of convicted felon and former I" Ward Alderman Fred Roti.

    11.     BRUNO CARUSO has admitted connections to the following bosses, members and/or associates of the Chicago Outfit, among others: Angelo "The Hook" LaPietra, James LaPietra, John "Apes" Monteleone, Larry Pusiteri, Richie "The Cat" Catazone, "Dirge" Imperato, Donald "Captain D" DiFazio, and Joseph "Shorty" LaMantia.

    12,     Beginning in the late 1960's BRUNO CARUSO attended illegal dice games in the 26' Street Area run by members and associates of the 26' Street Crew including Joseph "Shorty" LaMantia, Larry Pusiteri, Donald "Captain D" DiFazio and Richie "the Cat" Catazone.

    13.     BRUNO CARUSO has been observed on a number of occasions with Pat Marcy, a I" Ward politician who received large sums of money from the Chicago Outfit, On approximately two occasions, BRUNO CARUSO was seen passing envelopes to Pat Marcy.

    14.     On a number of occasions, BRUNO CARUSO has been observed meeting with former 2601 Street boss, Angelo LaPietra and current 26' Street boss, John Monteleone.

    15.     In or around March of 1994, BRUNO CARUSO was observed meeting with Joseph "Shorty" LaMantia, John "Apes" Monteleone, FRANK CARUSO and DiFORTI.

    16.     On June 16, 1997, BRUNO CARUSO was served with the Complaint for Trusteeship in the Chicago District Council matter. Approximately one hour after receiving the

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Complaint, BRUNO CARUSO traveled to the home of convicted felon and former I` Ward Alderman, Fred Roti

    17,     A number of individuals closely associated with the Chicago Outfit 'identify BRUNO CARUSO as an associate of the 26' Street Crew.

FRANK CARUSO's Connections to the Chicago Outfit


    18.     FRANK CARUSO is the son of former 26' Street Crew boss Frank "Skids" Caruso, the brother of mob associate BRUNO CARUSO, the cousin of mob associate LEO CARUSO and the nephew of convicted felon and former 1st Ward Alderman Fred Roti.

    19.     FRANK CARUSO has associated with at least the following members or associates of the Chicago Outfit;
Robert "Bobby" Abbinante, Marco D'Arnico, Charles Francis "Guy" Bills, Richie "the Cat" Catazone, Larry Pusiteri, Joseph "Shorty" LaMantia.

    20.     Beginning in the late 1960's FRANK CARUSO attend ed illegal dice games in the 26' Street Area run by members and associates of the 26' Street Crew including Joseph "Shorty" LaMantia Larry Pusiteri, Donald "Captain D" DiFazio and Ritchie "the Cat" Catazone

    21.     In the late 1960s, FRANK CARUSO was observed with Paul "The Walter" Ricca.

    22.     At various times from the early 1960s to the early 1980s, FRANK CARUSO socialized and participated in illegal activities such as burglaries, robberies, bookmaking and chop shop activities with mob associate Charles Francis "Guy" Bills, Richie Mara and others.

    23.     In or around March of 1994, FRANK CARUSO was observed meeting with Joseph "Shorty" LaMantia, John "Apes" Monteleone, BRUNO CARUSO and DiFORTI.

    24.     In or around April of 1995, FRANK CARUSO resigned from LIUNA the day he

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received a notice of deposition from the GEB Attorney's Office.

    25.     A number of individuals closely associated with the Chicago Outfit identify FRANK CARUSO as an associate of the 261h Street Crew

LEO CARUSO's Connections to the Chicago Outfit

    26,     LEO CARUSO is the nephew of former 26' Street Crew boss Frank "Skids" Caruso and the cousin of mob associates BRUNO CARUSO and FRANK CARUSO.

     27.     LEO CARUSO has admitted connections with the following members or associates of the Chicago Outfit, among others: Donald "Captain D" DiFazio, Richie "the Cat" Catazone, Larry Pusiteri, Joseph "Shorty" LaMantia. 

    28.     Beginning in the late 1960's LEO CARUSO attended and, at times held a financial interest in, illegal dice games in the 26' Street Area run by members and associates of the 26' Street Crew including Joseph "Shorty" LaMantia, Larry Pusiteri, Donald "Captain D" DiFazio and Richie "the Cat" Catazone.

    29.     At various times, LEO CARUSO has held a no-show job with the City of Chicago. In 1991, LEO CARUSO resigned from his street sweeping job during the pendency of an investigation of city workers who were not on duty during work hours,

    30.     A number of individuals closely associated with the Chicago Outfit identify LEO CARUSO as an associate of the 261h Street Crew.

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        JAMES DiFORTI's Connections to the Chicago Outfit

    31,     JAMES DiFORTI has associated with at least the following members or associates of the Chicago Outfit:            

                    John "Apes" Monteleone, Joseph "Shorty" LaMantia, Vince Solano, Angelo LaPietra.

    32.     In the 1970s and 1980s, DiFORTI was involved in "juice loans" for the Chicago Outfit. DiFORTI also participated in burglaries during this period.

    33.     In or around 1988, DIFORTI murdered Bill "the Pallet Man" Benham in a dispute over a $100,000 "juice loan".

    34.     In or around March of 1994, DIFORTI was observed meeting with Joseph "Shorty" LaMantia, John "Apes" Monteleone, BRUNO CARUSO and FRANK CARUSO.

    35.     DiFORTI resigned from all of his positions in LIUNA in July of 1997, just a few days prior to the hearing on the GEB Attorney's Complaint for trusteeship against the Chicago District Council and the day he was arrested for murder.

    3 6.     A number of individuals closely associated with the Chicago Outfit identify DIFORTI as an associate of the 26' Street Crew.

Manifestations of Mob Corruption within LIUNA.

    37.     BRUNO CARUSO, FRANK CARUSO, LEO CARUSO and DiFORTI have played significant roles in the corruption of the Chicago District Council and certain of its affiliated locals since the 1980s. For decades, the participation of these respondents, and others with ties to organized crime, has resulted in a breakdown of democratic practices within the Chicago District Council, its affiliated funds and certain of its affiliated locals. Decisions

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regarding the transfer of official positions within the Chicago District Council and certain affiliated unions have been made by officials with mob ties. A strong mob presence in the CDC, its affiliated funds and certain affiliated locals has been perpetuated, and democratic, constitutional selection of officers has been prevented, through a pattern of abuse that has resulted in: the avoidance of election.5 through uncontested nominations, repeated transfers of authority through power of appointment between elections, appointments or uncontested nominations of unqualified or marginally qualified individuals and the longstanding failure of LIUNA officials in Chicago to address allegations of mob connections, no-show jobs or criminal arrests, indictments or convictions.

    38.     BRUNO CARUSO, FRANK CARUSO, LEO CARUSO and DiFORTI are aware of, and a part of, this organized crime corruption of LIUNA. These respondents have failed to take action or to investigate allegations of organized crime influence within LIUNA that they were aware of, a part of, or should have been aware of through publicized reports and allegations. Respondents themselves have obtained and retained various positions of power through undemocratic practices and have permitted others to do the same. Through the following examples, among others, some or all of the respondents have violated their duties of loyalty, the constitutional duties of LIUNA members and have permitted LCN influence within the union: (a) the appointment of FRANK CARUSO as a Sergeant at Arms of the Chicago District Council while he was under arrest for extortion; (b) the failure to hold a proper election in 199T, (c) the transfer of the coordinator of committee position at the Chicago District Council to made members and associates during the 1990s; (d) the appointment of BRUNO CARUSO to various positions of power within LIUNA in 1994; (e) the appointment of DiFORTI to a position of

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power in Local 5 in 1994; (f) the appointment of LEO CARUSO to various positions of power in 1995; (g) the retention of FRANK CARUSO in an affiliated pension fund in 1995.

 

Charge 1 - BRUNO CARUSO
Barred Conduct - Membership in the Chicago Outfit

    BRUNO CARUSO is, or has been, an associate of the 26h Street crew of the Chicago Outfit and, by virtue of this status, he has committed barred conduct under the EDP.


Charge 2 - BRUNO CARUSO
Barred Conduct - Knowing Association with Chicago Outfit Members and Associates-

    BRUNO CARUSO has committed barred conduct under the EDP by knowingly associating with various members and associates of the Chicago Outfit, including:

Charge 3 - BRUNO CARUSO
Violation of Duty of Loyalty

    BRUNO CARUSO has violated the obligation of undivided loyalty incumbent upon all union members, officers and employees of LIUNA, including but not limited to, those duties set forth in the LIUNA Ethical Practices Code and those duties of union officials set forth in 29 U,S,C. §501(a), to wit: BRUNO CARUSO failed to take any steps to investigate or eradicate organize crime influence within the Chicago District Council and certain of its affiliated locals. Specifically, BRUNO CARUSO failed to inform his fellow officers and CDC delegates of the ties that FRANK CARUSO, LEO CARUSO, DiFORTI and others had to the Chicago Outfit and he failed to take any steps to investigate publicized reports of organized crime influence or violations of law by certain CDC officers and delegates including Vincent Solano, James Caporale, John Matassa, FRANK CARUSO and others.

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Charge 4 - BRUNO CARUSO
Barred Conduct -- Permitting LCN Influence

    BRUNO CARUSO has permitted members andJor associates of the LCN to exercise control or influence over the affairs of the Chicago District Council and certain of its affiliated entities by permitting those with ties to the LCN to hold positions of trust and to exercise those positions to further LCN influence. BRUNO CARUSO participated in a pattern of organized crime influence over the Chicago District Council resulting in a failure of democratic process and the selection of members and associates of the Chicago Outfit to top positions within the Chicago District Council and certain of its affiliated entities.

Charge 5 - BRUNO CARUSO
Violation of Constitutional Duties of LIUNA Members and Officers

    In permitting the LCN to exercise control or influence over the Chicago District Council and certain of its affiliated entities as alleged more specifically in Charge 4, BRUNO CARUSO failed to honor his obligations as a LIUNA member to refrain from interfering with the proper conduct of LIUNA business in violation of Article III, Section 3(d) of the Uniform Local Constitution, Ws duty as an Executive Board member of a LIUNA Local to see to it that the affairs and business of the Local are being properly conducted in violation of Article IV, Section 4(H)(9) of the Uniform Local Constitution, and his duty as an Executive Board member of the Chicago District Council to see to it that the-affairs and business of the Chicago District Council are being properly conducted in violation of Article VU, Section 7(i), of the Uniform District Council Constitution.

Charge 6 - FRANK CARUSO
Barred Conduct - Membership in the Chicago Outfit

    FRANK CARUSO is, or has been, an associate of the 26' Street crew of the Chicago Outfit and, by virtue of this status, he has committed barred conduct under the EDP.

Charge 7 - FRANK CARUSO
Barred Conduct - Knowing Association with Chicago Outfit Members and Associates

    FRANK CARUSO has committed barred conduct under the EDP by knowingly associating with various members and associates of the Chicago Outfit, including.-

Robert "Bobby" Abbinanti, Marco D'Amico, Charles Francis "Guy" Bills, Richie "the Cat" Catazone, Larry Pusiteri, Joseph "Shorty" LaMantia.

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Charge 8 - FRANK CARUSO
Violation of Duty of Loyalty

    FRANK CARUSO violated the obligation of undivided loyalty incumbent upon ail union members, officers and employees of LIUNA, including but not limited to, those duties set forth in the LIUNA Ethical Practices Code and those duties of union officials set forth in 29 U.S.C. §501 (a), to wit: FRANK CARUSO failed to take any steps to investigate or eradicate organize crime influence within the Chicago District Council and certain of its affiliated locals. Specifically, FRANK CARUSO failed to inform his fellow officers and CDC delegates of the ties that BRUNO CARUSO, LF-0 CARUSO, DIFORTI and others had to the Chicago Outfit and he failed to take any steps to investigate publicized reports of organized crime influence or violations of law by certain CDC officers and delegates including Vincent Solano, James Caporale, John Matassa and others.

Charge 9 - FRANK CARUSO
Barred Conduct - Permitting LCN Influence

    FRANK CARUSO permitted members and/or associates of the LCN to exercise control or influence over the affairs of the Chicago District Council and certain of its affiliated entities by permitting those with ties to the LCN to hold positions of trust and to exercise those positions to further LCN influence. FRANK CARUSO participated in a pattern of organized crime influence over the Chicago District Council resulting in a failure of democratic process and the selection of members and associates of the Chicago Outfit to top positions within the Chicago District Council and certain of its affiliated entities.

Charge 10 - FRANK CARUSO

    In permitting the LCN to exercise control or influence over the Chicago District Council and certain of its affiliated entities as alleged more specifically in Charge 9, FRANK CARUSO failed to honor his obligations as a LIUNA member to refrain from interfering with the proper conduct of LIUNA business in violation of Article III, Section 3(d) of the Uniform Local Constitution and his duty as an Executive Board member of a LIUNA Local to see to it that the affairs and business of the Local are being properly conducted in violation of Article IV, Section 4(14)(9) of the Uniform Local Constitution.

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Charge 11 - LEO CARUSO
Barred Conduct - Membership in the Chicago Outfit

    LEO CARUSO is, or has been, an associate of the 26' Street Crew of the Chicago Outfit and, by virtue of this status, he has committed barred conduct under the EDP.

Charge 12 - LEO CARUSO
     Barred Conduct - Knowing Association with Chicago Outfit Members and Associates

    LEO CARUSO has committed barred conduct under the EDP by knowingly associating with various members and associates of the Chicago Outfit, including:

Charge 13 - LEO CARUSO
Violation of Duty of Loyalty

    LEO CARUSO has violated the obligation of undivided loyalty incumbent upon all union members, officers and employees of LIUNA, including but not limited to, those duties set forth in the LIUNA Ethical Practices Code and those duties of union officials set forth in 29 U,S,C. §50 1 (a), to wit: LEO CARUSO failed to take any steps to investigate or eradicate organized crime influence within the Chicago District Council and certain of its affiliated locals. Specifically, LEO CARUSO failed to inform his fellow officers- and CDC delegates of the ties that FRANK CARUSO, BRUNO CARUSO, DIFORTI and "others had to the Chicago Outfit and he failed to take any steps to investigate publicized reports of organized crime influence or violations of law by certain CDC officers and delegates including Vincent Solano, James Caporale, John Matassa, FRANK CARUSO and others.

Charge 14 - LEO CARUSO
Barred Conduct - Permitting LCN Influence

    LEO CARUSO has permitted members and/or associates of the LCN to exercise control or influence over the affairs of the Chicago District Council and certain of its affiliated entities by permitting those with ties to the LCN to hold positions of trust and to exercise those positions to further LCN influence. LEO CARUSO participated in a pattern of organized crime influence over the Chicago District Council resulting in a failure of democratic process and the selection of member ' s and associates of the Chicago Outfit to top positions within the Chicago District Council and certain of its affiliated entities.

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Charge 15 - LEO CARUSO
Violation of Constitutional Duties of LIUNA Members and Officers

    In permitting the LCN to exercise control or influence over the Chicago District Council and certain of its affiliated entities as alleged more specifically in Charge 14, LEO CARUSO failed to honor his obligations as a LIUNA member to refrain from interfering with the proper conduct of LIUNA business in violation of Article III, Section 3(d) of the Uniform Local Constitution and Ws duty as an Executive Board member of a LIUNA Local to see to it that the affairs and business of the Local are being properly conducted in violation of Article IV, Section 4(H)(9) of the Uniform Local Constitution.

Charge 16 - JAMES DiFORTI
 Barred Conduct - Membership in the Chicago Outfit

    JAMES DiFORTI is, or has been, an associate of the 26' Street crew of the Chicago Outfit and, by virtue of this status, he has committed barred conduct under the EDP.

 

Charge 17 - JAMES DiFORTI
Barred Conduct - Knowing Association with Chicago Outfit Members and Associates

    JAMES DiFORTI has committed barred conduct under the EDP by knowingly associating with various members and associates of the Chicago Outfit, including:

Charge 18 - JAMES DiFORTI
Violation of Duty of Loyalty

    JAMES DIFORTI has violated the obligation of undivided loyalty incumbent upon all union members, officers and employees of LIUNA, including but not limited to, those duties set forth in the LIUNA Ethical Practices Code and those duties of union officials set forth in 29 U.S.C. §501(a), to wit: JAMES DIFORTI failed to take any steps to investigate or eradicate organize crime influence within the Chicago District Council and some of its affiliated locals. Specifically, JAMES DIFORTI failed to inform his fellow officers and CDC delegates of the ties that BRUNO CARUSO, FRANK CARUSO, LEO CARUSO and others had to the Chicago Outfit and he failed to take any steps to investigate publicized reports of organized crime

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influence and violations of law by certain CDC officers and delegates including Vincent Solano, James Caporale, John Matassa, FRANK CARUSO and others.

Charge 19 - JAMES DiFORTI
Barred Conduct - Permitting LCN Influence

    JAMES DiFORTI permitted members and/or associates of the LCN to exercise control or influence over the affairs of the Chicago District Council and certain of its affiliated entities by permitting those with ties to the LCN to hold positions of trust and to exercise those positions to further LCN influence. JAMES DiFORTI participated in a pattern of organized crime influence over the Chicago District Council resulting in a failure of democratic process and the selection of members and associates of the Chicago Outfit to top positions within the Chicago District Council and certain of its affiliated entities.

Charge 20 - JAMES DiFORTI
Violation of Constitutional Duties of L11UNA Members and Officers

In permitting the LCN to exercise control or influence over the Chicago District Council and certain of its affiliated entities as alleged more specifically in Charge 19, JAMES DiFORTI failed to honor his obligations as a LIUNA member to refrain from interfering with the proper conduct of LIUNA business in violation of Article III Section 3(d) of the Uniform Local Constitution and his duty as an Executive Board member of a LIUNA Local to see to it that the affairs and business of the Local are being property conducted in violation of Article IV, Section 4(H)(9) of the Uniform Local Constitution.

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