UNITED STATES DISTRICT COURT
DISTRICT
OF CONNECTICUT

Gary R . Wall
William Cooksley, Sr.
Stenhen Manos

Plaintiffs

CIVIL ACTION#3:97 CV-02502(JC4)

v

Robert Luskin,
Laborer International Union at al

Defendants

Dated: November 23,1998

PLAINTIFFS' PETITION FOR COURT APPLICATION AND SERVICE OF A
'WRIT OF MANDAMUS" TO BE SERVED ON-THE ACTING CHIEF OF THE
DEPARTMENT OF JUSTICE ORGANIZED CRIME AND RACKETEERING
SECTION. MOTION IN ACCORDANCE WITH F.R.C.P. 1 AND F.R.C.P. 81
(b) JURISDICTION AND CAUSE OF ACTION PURSUANT TO 28 U.S.C.
1361 SERVICE PURSUANT TO 28 U.S.C. 1391 (e) APPLICABLE TO RICO
UNDER 18 U.S.C. 1965 (a)

Submitted by:
s/Gary Wall
Gary R. Wall
60 Carriage Hill Drive
ORAL ARGUMENT
REQUESTED
s/William Cooksley
William Cooksey, Sr
1097 Maple Avenue
Hartford, Connecticut 06114
860-956-8334
s/Stephen Manos
Stephen Manos
77 Hale Road
Glastonbury, Connecticut 06033
860-659-4266




PRESENTATION AND CONSTRUCTION OF FEDERAL RULES AND
STATUTES

    This action comes pursuant to the construction of the following rules, statutes and facts.

Rule 1-F.R.-C.P. Scope of and Purpose of Rules

   "These rules govern the procedure in the United States District Courts in all suits of a
civil nature whether cognizable as cases at law or in equity or in admiralty with the exceptions
states in Rule 81 - They shall be construed "and administered" to secure the just, speedy, and
inexpensive determination of every action."

   RULE I was amended in 1993 by the addition of the words "and administered" in the
final sentence. The amendment was intended to emphasize the Courts duty to ensure that the
litigation is resolved without undue cost or delay.

    The clear intention of Rules 1 and 81 was to apply Civil Rules to all District Court
proceedings unless expressly excepted. Rule 81 contains several express exceptions to the
general applicability of the Civil Rules to civil actions. Those exceptions include copyright
actions, bankruptcy actions, and prize proceedings in admiralty. Other actions are governed by
the civil rules, but only insofar as those rules are not inconsistent with other rules or statutes
governing those actions. In the instant petition they are not inconsistent, under the liberal
provisions of the RICO venue statute 18 USC 1965 (a) Subsection (a) provides that "(a) any
civil action or proceeding under this chapter [18 USCS 1-961 at seq]-against-any-person may
be instituted in the District Court of the United States for any district in which such person

(1)

resides, is found, has an agent, or transacts his affairs".

JURISDICTION AND VENUE

    28 U.S.C. 1361 Action to compel an officer of the United States to perform his
duty

    The District Courts shall have original jurisdiction of any action "in the nature of
mandamus to compel an officer or employee of the United States or any agency
thereof to perform a duty owed to the plaintiff".

    28 U.S.C. 1361 added a venue and service of process provision 28 U.S.C.
1391 (e) which is applicable not only to mandamus actions but also generally to all
actions in which the defendant is a government officer or employee acting in his official
capacity, or an agency of the United States. In addition 1391 (e) provides that the
summons and complaint in such an action may be served on the officer or agency by
certified mail beyond the territorial limits of the district in which the action is brought.
Also, no new liabilities or causes of action against the government are created by the
statute; rather it is to facilitate review by the federal courts of administrative actions
[Department of Justice would still hold status as Wrongdoer #7 page 11 Docket #521
See Sen Rep No. 1992, 87 Cong, 2d Sass, to accompany HR 1960, 2 US Code Cong
and Adm News (1962) 2784,

CONSTRUCTION OF FACTS, AND CASE LAW IN SUPPORT OF FACTS
    First the Pro Se Litigants acknowledge and realize that a mandamus action is
an extraordinary remedy which should be utilized only under exceptional
circumstances and its issuance is dependent largely upon judicial discretion. Plaintiffs
also realize that an assumption of mandamus jurisdiction is inappropriate where
alternative remedies exist. Therefore, the plaintiffs will show that a mandamus action
is an appropriate remedy under these unprecedented and extraordinary
circumstances and that the Department of Justice is acting contrary to law and should

2

be compelled by mandamus to perform duty owed to the plaintiffs.

    Construction and application of 28 USCS 1361 confers on Federal District
Courts original jurisdiction of actions in nature of mandamus to compel federal officer,
employee, or agency to perform duty owed Plaintiff 13 ALR Fed 145

RELIEF SOUGHT
    Relief sought is to compel Department of Justice to perform a non-discretionary
administrative action which the existence of a duty is owed by a federal agency to the
plaintiffs, See: Carey v Local Board No. 2 (1969, DC Conn) 412 F2d 71. "Id. 252
Mandamus: "Draft registrant could maintain mandamus proceeding against draft board
to compel board to classify him I-S under statute providing that Federal District Courts
shall have jurisdiction of any action in nature of mandamus to compel an officer or
employee of the United States or any agency thereof to perform a duty owed to
plaintiff,

EXPLANATION OF RELIEF SOUGHT IN INSTANT PETITION
    Relief sought is primarily for Plaintiff Manos as a witness /victim pursuant to the
Federal Guidelines for Fair Treatment of Crime Victims and Witnesses in Criminal
Justice Systems Act P. L. 97-291 Oct- 12, 1982. A violation of governmental agency's
own regulations may be basis for 28 USCS 1361 jurisdiction see.- Andujar v
Weinberger (1976 SO NY) 69 FRD 690.

    On March 17, 1998 Charles LeConche brought a tort action in the Hartford
Division 3:98-CV00489 (AWT) see. in this instant case 3-.97-CV02502 (JCH),
attachment to Dkt. #29 civil cover sheet and complaint filed in Hartford Division
claiming $50,000 in damages. Mr. LeConche on May 12, 1998 amended said
complaint and added among other counts, count #26 stating that Mr. Manos "appeared
before a congressional subcommittee alleging a barrage of entirely unfounded

3

allegations of criminal conduct".

    In order for Mr. Manos to exonerate himself from this tort action which in reality
was and is a violation of 18 USCS 1512 witness tampering, Mr. Manos served two
subpoenas, one on Inspector Sheryl McLaughlin served September 11, 1998, the
other on Mr. Luskin served September 17, 1998. Ms. McLaughlin is a former FBI
Agent now working for Mr. Luskin's Inspector General's Office as an investigator. In
that capacity Ms. McLaughlin took statements from the persons present at the July 30th
E. Board Meeting held at Capriccio Restaurant and turned them over to Mr- Luskin.
Subpoena attachment attached as Exhibit A of instant petition. Mr. Luskin has refused
to turn over the statements to Mr- Manos on Mrs. McLaughin's behalf and his own,- See
two letters to Mr. Manos one dated September 23, 1998 and the other dated
September 29, 1998 from Mr. Luskin attached as Exhibit to instant petition. In said
letters the Court will notice that Mr. Luskin claims privilege in direct contradiction to Mr.
Luskin's own statements before Senator William McCollum Subcommittee on Crime,
July 25, 1996, in which he portrayed himself as an outside attorney and not a criminal
defense attorney: See exerpts from hearing filed in Dkt #52 amendment to Standing
Order #20. These exceptional circumstances give rise to plaintiff's request for
mandamus relief. The Department of Justice meets monthly and bimonthly with Mr.
Luskin and exchanges information and evidence gathered by Mr. Luskin's IG Office.
Therefore, the Department of Justice is in possession of the statements needed by Mr.
Manos. If they claim they are not in possession they have the ability to be in
possession through the Operational Agreement. This right is therefore a duty owed to
Plaintiff Manos pursuant to the Fed. Guidelines of the Crime Victim and Witness Act P L
97-291.

RELIEF SOUGHT JOY FOR PLAINTIFFS Wall, MANOS & COOKSEY
    There are preliminary question of law that will be addressed at preliminary

4

hearings in this instant case concerning the Executive Board of Local 230 in the meaning of
18 USC 1961(4) and the "Operational Agreement" in the meaning of 18 USC 1961 (4)
before facilitating and conspiracy to violate RICO can be addressed.

    These statements given to the Inspector Generals Office will give the Court a clear
view in making judgments on preliminary questions of law, and the plaintiffs consider Mr.
Luskin's response to the subpoenas an unnecessary and costly delay.

    The plaintiff therefore take the position that the Department of Justice has a "ministerial
duty" to the plaintiffs to release said statements. see: White v Matthew (1976 DC Conn) 434 F.
Supp, 1252 Affd. (CA 2 Conn) 559 F 2d 852,
O The United States District Court for the District
of Connecticut 434 F. Supp. 1252 T- Emmett Clarie, Chief Judge, found that delays in
administrative hearings on entitlement to disability insurance benefits violated Social Security
Act, and Department of Health, Education and Welfare appealed. The Court of Appeals,
Feinberg, Circuit Judge held in its pertinent part that: (1) Social Security Act did not preclude
mandamus review with respect to speed of proceedings".

   In addition, holding again jointly to Andugiar v Weinberger (976, SD NY) 69 FRD 690,
"violation of governmental agency's own regulations maybe basis for 28 USCS 1361
jurisdiction. The plaintiff jointly take the position that the "Operational Agreement" is a violation
of the principles of Federal prosecution. See: United States Attorney's Manual-Chapter 110-9-110

110-401
Page 5, "Inclusion of a RICO count in an indictment solely or even primarily to create
a bargaining tool for later plea negotiations on lesser counts would not be appropriate and
would violate the principles of Federal prosecutions"

. Previous cited by plaintiff page #5 Dkt#52.
  Andujar v Weinberger also addressed due process ID 691 "allegations of lengthy delays in
delivery of social security benefits state constitutional claims of denial of property without due
process giving Federal District Court mandamus jurisdiction with

5

respect to plaintiffs' suits alleging violation of constitutional duties owed to plaintiffs
because of such delays. Plaintiffs have alleged precisely the same violation of clue
process see in instant case Dkt- #52 page #13 Amendment to Standing Order #18,
"The plaintiffs allege that defendant Luskin through the authority entrusted in him by
the Department of Justice and through the Operational Agreement violated the
procedural due process clause of the Fourteenth Amendment of the United States
Constitution, violating the plaintiffs natural rights In the District and Commonwealth of
Connecticut."

   For the purposes of showing the Court the exceptional circumstances in this
instant matter the plaintiffs enter Exhibit C " Communications Release and Warning
Letter from United States House of Representatives, Honorable Harris W. Fawell,
Chairman of Subcommittee tc Mr. Arthur Coia, General President LIUNA, CC to the
Honorable Donald M- Payne Ranking Minority Member Subcommittee on Employer
Employee Relations, Mr. Charles LeConche, Business Manager, LIUNA Local 230,
The Honorable Janet Reno, Attorney General and Robert D. Luskin, Esq. LIUNA GEB
attorney.

   The Plaintiffs believe they have clearly demonstrated their entitlement to relief
under 28 USCS 1361 and that if relief is granted it will clarify questions of law In the
District of Connecticut, see the 1948 "all writs" statute (28 USCS 1651) which provides
in part that Federal Courts may issue all writs necessary or appropriate in aid of their
respective jurisdictions, since the purpose of the statute was to provide mandamus in
situations where jurisdiction a!ready existed on Independent grounds as in this instant
RICO action.

   Therefore, if the Court grants relief pursuant to 28 USCS 1361 the Plaintiff
request from the Department of Justice:

   All statements, notes and transcripts taken from interviews conducted by LIUNA
Inspector General's Office from the following people who were present July 30, 1998

6

at Capriccio Restaurant, Hartford, Connecticut

Vere 0. Haynes, Vice President, LIUNA and signatory to Operational Agreement
Charles LeConche, Business Manager Local 230
Thaddeus Grabowski, President Local 230
Wayne Silva, Auditor
Frank Freeman, Sergeant -At-Arms/Presently, VIce President
William LeConche, Laborer
Leonard Granell, Recording Secretary
John Pezzente, Secretary-Treasurer
James Lawson, Auditor
Donald Douville, Auditor
Lloyd Lecky, Auditor
William DelGaizo, Auditor
Thomas Brockett, Attorney [Cheverie & Associates)

   Plaintiffs assert that this is a non discretionary ministerial duty not intended to direct or
influence the exercise of discretion of the Department of Justice- Plaintiff assert this is a right
of entitlement especially for plaintiff Manos under 28 USCS 1361

   Plaintiffs also assert it relief is granted it will save the Court time and thousands of
dollars in cost.

Submitted   By:
s/Gary Wall_
Gary wall
60 Carriage Hill Drivec_

Wetersfield, Connecticut 06109 _
s/William Cooksey
William Cooksey, Sr, Pro Se
1097 Maple Avenue
Hartford, Connecticut
860-956-8334
s/Stephen Manos
Stephen Manos, Pro Se.
77 Hale Road
Glastonbury, Connecticut 06033
860-659-4266

 

 

7

 


 

EXHIBIT A


MR. LUSKIN'S SUBPOENA ATTACHMENT

 

 

 

8



 

United States District Court
District of Connecticut

Charles LeConche
Plaintiff

v

Case # 398 CV 00499 AWT
Stephen Manos
Defendant
 

        Supoena Attachment

Robert Luskin. GEB Attorney, LIUNA


You am commanded to produce the following documents -

All statements, notes, & transcripts taken from interviews conducted by the LIUINA 1nspector
General's Office from the following people who were present at the Local 230 Executive Board
meeting held on July 30, 1998 at Capriccio Restaurant,Hartford, Ct.

Charles LeConche, Business Manager
Thaddeus Grabowski, Preesident
Wayne Silva, Auditor
Frank Freeman, Sergeant-at-Arms
William LeConche, Laborer
Leonard Granell, Recording Secretary
John Pezzenti, Secretary-Treasurer
James Lawson, Auditor
Donald Douville, Auditor
Lloyd Lecky. Auditor
WIlliam Del Gaizo, Auditor
Thomas Brockett, Attorney [Chaverie & Associates)
Vere Haynes, Vice-President [LIUNA]
The Fuschi Brothers, Co-Owners, Capricccio Restaurant

If any of these individuals, in fact, were not interviewed, please state the reasons as to
why.

      Submitted By:



Stephen
MANOS Pro Se
960/659-4266


 


EXHIBIT B


TWO LETTERS FROM MR. LUSKIN TO STPEHEN MANOS ONE DATED

SEPTEMBER 23, 1998, THE OTHER DATED SEPTEMBER 29,1998


 

COMEY BOYD & LUSKIN
A PROFESSIONAL CORPORATION

Of  COUNSEL

EUGENE J COMEY 1025 THOMAS JEFFERSON STREET N.W

SHARON L 0 GRADY'

DAVID R. BOYD SUITE 4O EAST

ROBERT M. THOMAS JR

ROBERT D LUSKIN WASHINGTON D C. 20007-5201

'NOT ADMITTED IN DC

DWiGHT P BOSTWICK TELEPHONE 1202) 626-4200

-------

TELCOPIER~ (2021 625-1230
DANIEL A BRAUN
MATTHEW E. PAUL
KATHLEEN MURPHY RING
SHARON . SCHROER
PATRICK J BLEVIN
 

 

September 23, 1998

VIA FAX AND FEDERAL EXPRESS

Stephen Manos
77 Hale Road
Glastonbury, CT 06033

Re: LeConche v. Manos
No. 398 CV 00489 AWT

Dear Mr. Manos:

    I am writing with reference to the subpoena that was served upon Inspector Sheryl
McLaughlin on September 11, 1998. Because the subpoena was addressed to Ms. McLaughlin in her
official capacity as an Inspector in the Office of the Inspector General of LIUNA, I am responding on
her behalf.

    Pursuant to Rule 45(c)(1)(B), Fed. R. Civ. P., please treat this letter as an objection to
inspection or copying of the materials that you requested be produced in the attachment to the
subpoena. If we are required, LlUNA will move on Ms. McLaughlin's behalf to quash or modify the
subpoena on the grounds set forth in Rule 45(c)(3) and will oppose any motion to compel production.
More specifically, and without waiving the right to raise any matter under Rule 45, the interviews
conducted by the Inspector General, in accordance with LIUNA Ethics and Disciplinary Procedure, are
treated as highly confidential and subject to various privileges, including the attorney-client privilege.
The Independent Hearing Officer has declined to order them produced in any matter pending before
him; and no Court required their production in any matter challenging a disciplinary action. As you are
aware, the guarantee that these materials will be treated as confidential is vital to the ability of the
Inspector General to fulfill his important responsibilities.


COMEY BOYD & LUSKIN
A PROFESSIONAL CORPORATION

 

-2

    Let me emphasize that our position in this matter does not reflect any position on the
merits of the suit that was filed against you, which I deplore, but is based upon concern for the
integrity of the disciplinary
process.

   Finally, I very much regret your unwillingness to agree to a two-week extension of the return date. My
request was a matter of common courtesy, based upon our many prior dealings, and I did not expect it would be
refused

Yours sincerely,

Robert D. Luskin


cc: W. Douglas Gow, inspector General


Robert D. Luskin 0ffice of the GEB Attorney
Laborers' International Union of North America
____________________________________________________
GEB Attorney 1025 Thomas Jefferson Street, N.W.
Suite 420 East
Washington D.C. 20007-5243
Phone: (202) 625-1200
Fax: (202) 625-1230
September 29, 1998
Stephen Manos
77 Hale Road
Glastonbury, CT 06033
Re: Le Conche v. Manos
No- 398 CV 00489 AWT (D.Conn.)
Dear Mr. Manos:

   I am writing in response to your letter of September 28, 1998, regarding the subpoena to Sheryl
McLaughlin as well as a similar subpoena on your behalf that was served on me yesterday.

  Please treat this letter as my objection to your subpoena to me on the same grounds set forth
in my letter of September 23, 1998, concerning the subpoena to Ms. McLaughlin. I have enclosed a
copy for your benefit. By this response, we do not waive any grounds that might be asserted in
response to the subpoena, including, in this instance, that the subpoena was served outside the
territorial limits provided for in Rule 45 and is otherwise procedurally defective.

   With regard to your demand that I provide a privilege log, please be advised that in accordance
with Rule 45, an objection to a third-party subpoena excuses the subpoenaed party from compliance
pending consideration of a motion to compel production. If you elect to file such a motion, we will
move to quash the subpoena and, at that time, file a privilege log or other designation of documents as
may be required by the Federal Rules of Civil Procedure, local rules, or by the court.
Yours sincerely,
Robert D. Luskin
Enclosure
cc: W. Douglas Gow

                         

                         

 


EXHIBIT C


RELEASE AND WARNING LETTER TO ARTHUR COIA FROM THE HONORABLE

HARRIS W. FAWELL CHAIRMAN OF SUBCOMMITTEE DATED MAY 27,1998

 

 

 


COMMITTEE ON EDUCATION--AND-THE--WORKFORCE-

UNITED STATES HOUSE OF REPRESENTATIVES

346 Rayburn Office Building

Washington. DC 20515-6100



For Release

May 27. 1998

        Contact: Bill McCarthy or Jay Diskey at (202) 225-4527

FAWELL WARNS ORGANIZED LABOR AGAINST RETALIATION AIMED AT "UNION

DEMOCRACY" WITNESSES

Witnesses report threatening phone calls and amended lawsuit alleging defamation


WASHINGTON. DC_ The chairman of a house subcommittee examining union
abuses against rank and file members today released a letter to Arthur
Coia.president of the Laborer International Union of North America,
warning him against acts of retaliation against individuals testifying
before the subcommittee.

"We've had two union members subjected to harassment as-a-result-of coming
to Congres and telling their stories
, "-said-Rep. Harris W Fawell(R-IL),
whose Subcommittee on Employer-Employee Relations began May 4 a series of
hearings looking into the democratic rights of the rank and file within
their unions. "Republicans and Democrats on the subcommittee are working
together to find ways to protect the rights of union members. We cannot. and
will not, tolerate any retaliation against any witness and we will take
every step necessary and possible to protect them."

Stephen Manos, vice-president of Hartford(CT)--Laborers' Local 230 of
Coia's L
IUNA told the subcommittee last week that his testimony has
"further exacerbated" acts of harassment, intimidation and retaliation
against him. These included a May 12 complaint in a Connecticut
Federal District Court filed by Local 230's business manager accusing
Manos of defaming him before the subcommittee. Manos had testified May
4 that the business manager physically assaulted him and threw him out
of a Local 230 executive board meeting for asking questions regarding
the union expenditures.

Fawell today also sent a copy of his le
tter tn Coia to Attorney
General Janet Reno. Fawell sent a similar warning letter on May 8 to
Charles W. Jones, president of the Boilermakers National Transient

Lodge after Ernest- "Skip" Patterson, the local-elected president of
the Boilermakers National Transient
Lodge reported to the
subcommittee that his Congressional testimony prompted numerous
threatening phone calls.

The subcommittee's "union democracy, hearing are reviewing the


Labor-Management Reporting and Disclosure Act of 1959, which protects. among
other rights of union members to vote at meetings,to express
any arguments of opinions, and to voice views upon union candidates
and union business.

 

      Attachment: Chairman Fawell's letter




                COMMITTEE ON EDUCATION AND THE WORKFORCE

                  UNITED STATES HOUSE OF REPRESENTATIVES

                      346 Rayburn Office Building

                      Washington, DC 20515-6100

                            May 27, 1998



      Mr.Arthur Coia
      General President
      Laborers International Union of North America
      905 16th Street, N-W.
      Washington, D.C. 20006-1765

      Dear Mr. Coia:

      As you may be aware. the Subcommittee on Employer-Employee Relations

      (Subcommittee) of the Committee on Education and the Workforce held the

      first in a series of hearings on union democracy on May 4. 1998, We hope

      these hearings will aid in determining whether legislative remedies to the

      Labor-Management Reporting & Disclosure Act of 1959 are needed or whether

      the existing laws simply need improved enforcement. I look torw3rd to

      working with you and many other in an effort to address these issues in

      the coming months.

       

      One of the witnesses who testified oat the Subcommittee's May 4, 1998

      hearing is the popularly elected Vice President of Local Union 230, Mr.

      Steve Manos. It is entirely possible that the Subcommittee will call other

      witnesses froin the Laborers International Union of North America (LIUNA) in

      the course of these hearings. Since Mr. Manos reports that he has already

      received threats as a result of his congressional testimony and since a

      previous lawsuit filed against Mr. Manos by Business Manager Charles

      LeConche has been amended to include a defamation claim involving his

      congressional testimony, I find it necessary to contact you in these regard.

      I am certain that you agree that it is essential that citizens are free from

      retaliation when exercising their right of free speech. In the context of

      these hearings on union democracy. it is even more critical that we work

      together to ensure witnesses are tree from retaliation.

       

      I and the other members of the Subcommittee. wish to state in the clearest

      possible terms that the Subcommittee will not tolerate any retaliation

      against Mr. Manos or any other witness who testifies before Congress and

      that the Subcommittee will take every step necessary and possible to

      protect these witnesses should there be any hint of retaliation. I enlist

      you, other officials and the


     

    rank-and-file members of the union to join in ensuring union democracy and an

    environment free from retaliation . I trust that you understand the

    Subcommittee's position on this matter and that no such action will be

    taken against any present or future witness,

    I appreciate you attention to this matter and look forward to working with

    you.



Sincerely,

HARRIS W. FAWELL

Chairman Subcommittee on Employer-Employee Relations

cc:

The Honorable Donald M. Payne, Ranking Minority Member
Subcommittee on Employer Employee Relations

Mr. Charles LeConche. Business Manager
LIUNA Local 230

The Honorable Janet Reno
Attorney General

Robert D. Luskin. Esquire
LIUNA GEB Attorney

 


 

CERTIFICATION

This is to certify that a copy of Plaintiffs Petition for Court Application and service
of a "Writ of Mandamus" to be served on the Acting Chief of the Department of Justice
O.C.R.S. with exhibits, has been mailed first class and postage prepaid this 23rd day
of November 1998 to.

Terrance Reed, Esquire
Reed & Hortage P. C
1025 Thomas Jefferson Street, N_ W.
Suite 455 West
Washington, D.C_ 20007
Attorney For Robert Luskin & Laborers
International Union, Defendants

John T. Fussell, Esquire
Robert M. Cheverie Associates
333 East River Drive Suite 101
East Hartford.Connecticut 06108-4201
Attorneys for Defendants,Dominick Lopreato,
Vere 0. Haynes, Laborers Local 230,
John Pezzente, Charles LeConche, Harriet Roman
and Robert Cheverie.

Additional -Certification.
This is to certify that a copy of Plaintiffs Motion for a Writ of Mandamus with
exhibits and a copy of Docket #29 and Docket #52 for purposes of reference have been
mail certified mail to:

Acting Chief,
Department of Justice
Organized Crime and Racketeering Section
1001 G. Street-, N. W.
Suite 300
Washington, D-C. 20538

 


Also for the purpose of a factual update Plaintiff Manos is mailing a copy separately to the
District Court in Hartford. Connecticut w
here he is a defendant 3-.98-CV0048 (AVVT) and a
copy to Attorney in that action

    Submitted By

    ___________________
    Gary B. Wall, Pro Se
    Carriage Hill Drive
    Wetherfield, Connecticut 06109
    860-563-5915

    __________________________
    William Cooksey,
    1097 Maple Avenue
    Hartford, Conn"icut
    860-956-8334

    ___________________
    Stephen Manos, Pro Se.
    77 Hale Road
    Glastonhury, Connecticut 06033
    860-659-4266

 


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