United States District Court
District of Connecticut
Plaintiff Civil Case 4 398 CV 00489 AWT
Stephen Manos Date: March 19, 1999
Defendant's Discovery Plan Proposal
The accompanying list of Discovery witnesses outlines the reasons for their
The Defendant will not dwell on any personal questions but will, instead,
ask questions regarding the incident that took place on July 30, 1997 along
with other related actions.
These depositions will show that only union business, & not LeConche's
personal business, was discussed.
All of the deposed individuals listed were present at the July 30, 1997
assault, with the exception of Mr. Nobili.
1. Charles LeConche. Business Manager [Local 230 & Ct, Laborers'
District Council, Laborers' International Union of North America]
Discovery will show the deprivation of Defendant Manos' Rights under the
Labor Management Reporting Disclosure Act [LMRDA] & violation of 18
USC 1951 [The Hobbs Act].
Discovery will also show that LeConche's personal business was never
Discovery will also show that the entire conversation of 7/30/97 was
union business which included Hobbs Act violations & a 29 USC 530
2. John Pezzenti, Secretary-Treasurer/ Rep- [local] 230J
Discovery will show that Pezzenti is an associate-in-fact of a captive labor
organization & in that capacity gave false statements & conspired to hide
the truth in regard to facts.
3 Leonard Granell Jr., Recording Secretary/Field Rep. [Local] 230]
Discovery will show that Granell is an associate-in- fact of a captive labor
organization & in that capacity falsified union records, manipulated the
minutes of meetings, & gave false statements concerning the 7/30/97 assault.
4. Vere Haynes, Third Vice-President [LIUNA]
Discovery will show that Haynes, who is a signatory to the operational
agreement with the Department of Justice, facilitated federal law violations
in the furtherance of a racketeering scheme.
5. Frank Freeman Vice President [Local 230]
Discovery will show that Freeman (then Sergeant-at-arms of Local 230] is a
associate-in-fact of a captive labor organization &, in the furtherance of
LeConche's Hobbs act violations, Freeman actually committed an assault
[29 USC 5301 upon Defendant Manos.
6. Ronald Nobili Business Manager, Laborers' Local 665, Bridgeport, CT
Discovery will show that Mr, Nobili was physically assaulted, on October 6,
1997, for asking questions about the same subject matter as did Defendant
Manos [namely questionable expenditures] while attending a Connecticut
Laborers' District Council meeting headed by LeConche.
The facts will show clearly, once extracted from the above depositions,
that the Defendant was protecting himself in the use of the tape recorder
from the culpability of being an associate-in-fact of a captive labor
organization in the meaning of the Executive Board of Local 230.
Background on Discovery Status
Charles LeConche & John Pezzenti are named as "Effective Date [October
15, 19701 RICO Conspirators" in the Bridgeport division concerning the
same facts in this instant matter,
Robert Luskin is the General Executive Board Attorney [GEB} for LIUNA
Luskin is a signatory to the operational agreement with the U.S. Justice
Department & [as the Justice Departments appointee] acts in the capacity of
an overseer of that same agreement.
His responsibilities are policing & reporting violation of federal statutes
which include predicate act violations of 19 USC 1961 [RICO].
Luskin is also a Defendant in Case # 397 CV 02502 JCH, being charged
with facilitating a racketeering conspiracy.
Defendant Manos has subpoenaed the following items relative to the assault
taking place on July 30, 1997 & which are in the possession of Luskin
1. Notes taken by the Inspector General's Office of LIUNA
2. Enhanced audio-tape of the 7/30/97 Local -130 Executive Board meeting.
3. Written transcript of the 7/30/97 audio-tape.
Defendant Manos aided LIUNA IG Investigator Sheryl McLaughlin on
diverse occasions in transcribing the audio-tape into text.
The facts in this instant case are congruent with the facts in a Racketeer
Influence & Corrupt Organizations [RICO ] civil case in the Bridgeport, Ct.
Division in which Charles LeConche is a defendant & Stephen Manos has
standing as a Plaintiff. [Case 4 397 CV 02502 JCH]
Six days after Plaintiff LeConche filed this action, this instant case was
identified for what it is, namely, Witness Tampering [Docket # 29, 397 CV
02502 JCH] which has been entered as a charge in the Bridgeport Division.
If Defendant Manos had to hire an attorney, as was expected by Plaintiff
LeConche, Defendant Manos would now be in a personal & financial
position which would force the defendant to settle.
Defendant Manos must go forward in both the capacity as a union member
& former officer in order to exonerate himself.
Defendant Manos takes this matter very seriously,
Defendant Manos has not only been physically assaulted, threatened & sued
by Plaintiff LeConche but also accused of giving false statements to the
FBI, U.S. Attorney & U.S. Congress-
Because of the nature of this action & for what the Defendant Manos has
experienced thus far, Defendant Manos requests the following :
1. Defendant Manos requests a court monitor to oversee the depositions.
2. Defendant Manos also requests a use of a room in the federal building.
3. Defendant Manos will pay all associated costs.
Submitted By :
77 Hale Road
Glastonbury, CT 06033
This is to certify that a copy of the fore-going Defendant's Discovery Plan
Proposal was sent by certified mail this 19th day of March to the following
attorney for the Plaintiff :
433 S. Main Street
West Hartford, CT 06110
77 Hale Road
Glastonbury, CT 06033
Laborers for JUSTICE © 1999 All Rights Resevered