UNITED STATES
DISTRICT COURT
NORTHERN
DISTRICT OF ILLINOIS
EASTERN
DIVISION
UNITED
STATES OF AMERICA, and )
LABORERS’
INTERNATIONAL UNION )
OF
NORTH AMERICA by and through )
ROBERT
LUSKIN, in his official capacity as )
General
Executive Board Attorney, )
)
Plaintiffs, )
)
v. ) 99 C 5529
) Judge Gettleman
CONSTRUCTION
& GENERAL LABORERS’ )
DISTRICT
COUNCIL OF CHICAGO AND )
VICINITY,
an affiliated entity of the Laborers’ )
International
Union of North America, )
)
Defendant. )
MONITOR’S FIRST
QUARTERLY REPORT TO THE COURT
Pursuant to Section 18 of the Consent Decree, the Monitor is required to file a Quarterly Report describing the actions he has taken toward achieving the objectives and purposes of the Consent Decree. This First Quarterly Report describes the Monitor’s actions from the period August 29, 1999 to November 29, 1999.
Organizational
Activities
Because of the potentially
vast scope of the Monitor’s jurisdiction, the limited time frame and budget
available to accomplish the assignment, prudent choices must be made as to the
focus of the investigative efforts. Additionally, in light of the
investigations, disciplinary and trusteeship proceedings previously conducted
by the LIUNA GEB Attorney and the rulings of Independent Hearing Officer Peter
Vaira in those matters, it has been necessary to carefully review their work in
order to identify relevant evidence and avoid duplication of efforts.
Toward this end, I and/or my
designees have met and conferred with the following people[1]:
1.
Robert
Luskin, GEB Attorney
2.
Dwight
Bostwick, Office of GEB Attorney
3.
Matthew
Paul, Office of GEB Attorney
4.
Peter
Vaira, Independent Hearing Officer
5.
Seymour
Simon, Independent Hearing Officer
6.
Douglas
Gow, LIUNA Inspector General
7.
William
Rice, LIUNA Deputy Inspector General
8.
Quest
International Consulting (private investigative firm retained by the LIUNA
Inspector General: Robert Scigalski, Joseph Griffin, Jack O’Rourke, Leone
Flosi)
9.
Vincent
Connelly, Counsel to Bruno Caruso
10.
Ed
Hogan, Counsel to Local 1
11.
George
Leighton, Counsel to Local 1001
12.
John
Mallul, FBI
13.
Dave
Buvinger, United States Attorneys Office
14.
Craig
Oswald, United States Attorneys Office
15.
Robert
Bloch, CLDC Trustee
16.
Peter
Dowd, Counsel to various Taft-Hartley funds administered by the CLDC
17.
Various
former delegates to the CLDC
18.
Manny
Ramirez, United States Department of Labor
19.
Tom
Moriarty, Criminal Investigation Division, Internal Revenue Service
20.
Thomas
M. Bourgeois, FBI
21.
Ernest
Luera, FBI
Document
Review
Document review of the evidentiary and litigation materials possessed by the LIUNA Inspector General and GEB Attorney has been conducted in Washington D.C. In addition, selective transcripts from the CLDC trusteeship hearings and disciplinary hearings of members of CLDC – affiliated LIUNA locals and various rulings of Hearing Officer Peter Vaira have been reviewed.
Investigative Plan
An investigative plan has
been formulated which identifies the individuals and entities that will be the
focus of the investigation. The list is subject to revision based on a variety
of factors, including new leads and development of evidence as our work
progresses. Because of the confidential nature of the investigative plan, it is
not disclosed in this Report. Upon request, a copy will be provided to the
Court in camera.
Subpoenas
The
Monitor has issued eleven subpoenas to date.
The subpoenas have been directed both to LIUNA - affiliated entities and
to third parties. The entities to which
subpoenas have been directed are not disclosed herein because public
dissemination at this time will not advance the objectives of the Consent
Decree, may compromise the Monitor’s investigation or prematurely subject
certain people or entities to unfair criticism simply by virtue of subpoenas
having been issued. The subpoenas are
available for the Court’s in camera review.
In
lieu of a subpoena, a comprehensive letter request for documents from the CLDC
has been served upon its Trustee.
Witness Interviews
Interviews
of individuals with possible knowledge of actions constituting violations under
the Consent Decree have commenced. Because disclosure of the interviewees at
this time will not advance the objectives of the Consent Decree and may pose
security issues, the names are omitted from this Report, but will be disclosed
to the Court in camera upon request.
The
Monitor reserves the right to disclose items treated confidentially in this
Report at a later date, when in his Judgment, it will advance the objectives of
the Consent Decree.
DATED: November 29, 1999
Respectfully
Submitted,
_________________________________
Steven
A. Miller
Monitor
Steven
A. Miller
SACHNOFF
& WEAVER, LTD.
30
South Wacker Drive
Suite
2900
Chicago,
IL 60606
(312)
207-1000
288100
Laborers
for JUSTICE © 1999 web published as a service to DOJ and LIUNA members.
Not
for republication on the internet without permission. Not for publication on
laborers.org
Jim
McGough, Director
55
S. Northwest Highway
Palatine,
Il 60067
847-202-3838