United States District Court

District of Connecticut




    Charles LeConche

    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


    being called.


    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.





Deposition List


    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.



    Settlement Status


    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-



    Defendant's Request


    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 :


s/Stephen Manos

Stephen Manos,

Pro-Se Defendant

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 :


    Patrick Tomasiewicz

    433 S. Main Street

    West Hartford, CT 06110


          Submitted By:


Stephen Manos

Pro-Se Defendant

77 Hale Road

Glastonbury, CT 06033



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