10/07/1998 05:04 8606334283 STEVE MANOS PAGE 10

continues to be through the actions of the Coia/Lopreato Group and the individual
defendants, who are associates in fact of that group. The Laborers InternationaJI Union
is party to contract with companies engaged in interstate commerce.

DEFENDANT LOCAL 230 475 Ledyard Street, Hartford, Connecticut has been and
will continue to be a captive Labor Organization. Through the criminal actions of the
individual defendants wrongdoers executive board, wrongdoer "Operational
Agreement" all associates in fact either facilitating or conspiring with the Coia/Lopreato
Group, Local 230 became a Captive Labor Organization October 15, 1970, through an
documented LM 15 & 16 act of fraud against the United States, committed by the
Coia/Lopreato Group. The Act of Fraud against the United States continues today in
the form of the Operational Agreement. Extortion of membership rights dates back to
October 15, 1970 to date its money has been embezzled document by the government
three (3) times by the Coia/Lopreato Group. The three named plaintiffs membership
rights, employment rights have been extorted by the Coia/Lopreato Group, who
control Local 230 including the Operational Agreement. Plaintiff Cooksey's pension
has been short changed and Plaintiff Wall's pension has been stolen through acts of
mail and wire fraud and actual pension fraud itself. Laborers Local 230 is party to
contracts with companies engaged in interstate commerce.
Submitted By:

860-529-2651 860-563-5915

• William Cooksey, Sr.
  1095 Maple Avenue, Hartford, CT.
  860-956-8334
  
  Stephen Manos
  77 Hale Road, Glastonbury, CT. 06033
  860-659-4266

• 
  10/07/1998 05:04 8606334283 STEVE MANOS PAGE
  
  ATTACHMENT TO AMENDED COMPLAINT
  
  Explanation of Phrases
  
  "Extortion of Membership Rights"
  
  "Extorted Membership Rights"

• 
  
  In accordance with the Courts instructions in ruling dated September 24, 1998
  (Docket No. 58] the explanation is as follow:
  
  (Extortion of Intangible property rights, 18 USC 1951 (b)(2).
  
  Extortion of membership right is both statutory and contractual and is in the the
  meaning of the Hobbs Act, 18 USC 1951, which pruhibits obstruction or intellerence
  with commerce by use of threats or extortion and protects intangible as well as
  tangible property, See United States v. Local 560 780 F. 2d 267 ID 268. Other circuits
  which have considered this question are unanimous in extending the Hobbs Act to
  protect intangible as well as tangible property, See United States v Zemek 634 F, 2d
  1159, United States v Santoni 585 F. 2d 667, to cite a couple of examples.
  
  (Commerce 18 USC 1951 (b)(3)), The Court in United States v Malinsky (1956
  D. C.N.Y.) 19 FRD 426 found that the use of the key words in 1951 (b)(3) "In anyway or
  degree" that Congress itself had concluded that any effect upon interstate commerce
  in any degree caused by extortion or conspiracy contemplating extortion was in itself
  substantial.
  
  The Court concluded that it was not necessary to allege that a person from
  whom property was extorted was engaged in interstate commerce nor was it
  necessary that the Act of Extortion was itself of an interstate character, but that all that
  was required was that the extortion or the conspiracy to extort be of such a nature that

• 
  10/07/1998 05:04 8606334283 STEVE MANOS PAGE 12
  
  it effects interstate commerce in some degree.
  
  In Carbo v United States 314 F. 2d 718, the Court found that the element of a
  Hobbs Act violation necessitating that commerce be affected by the proscribed acts of
  extortion required only that trade or commerce be affected by the extortion "in any way
  or degree". Distinguishing from that which is required under the Sherman Act, where it
  is necessary that the subject of the extortion itself constitute commerce.
  
  

See United States v Dale 223 F. 2d 181, in Dale the Court pointed out that the
term "fear" as used in 18 USC 1951 (b)(2) in defining extortion, should be given its
ordinary meaning, including fear of economic loss. "Fear" of economic loss was also
defined and affirmed in Callanan v United States 223 F. 2d 171, in Callanan the Court
found the issue in extortion cases under the Hobbs Act is not so much the cause of the
victim's fear, as it is whether or not the defendants played upon that fear made use of
that fear to extort money or property, and that the issues determinative of quilt are
whether the victim was fearful, whether that fear was reasonable, and whether the
defendants made use of that fear. In the instant case the requirements of "fear" of
economic loss goes beyond all the cited cases even United States v Local 560. The
violence in Local 560 was greater than Local 230 but even so Local 560 did not meet
the level of fear of economic loss that exists in Local 230. There have been many
victims of "racketeering injuries7 who have left the union since October 15, 1970 and
the evidence will show a clear "pattern" of "wrongful use" of fear and violence, and that
interstate commerce has been adversely "effected".

To give some examples contractors for all three of the named plaintiffs were
threaten not to hire the plaintiffs all separate contractors over a prolonged period of
time showing a paJtern. A-Iso, it was and is common knowledge it a laborer was seen
talking to any of the named pl-aintiffs, they would be threaten with the loss of their jobs,
labors at union meetings were visibly directed to boo and yell when any of the named

10/07/1998 05:04 8606334283 STEVE MANOS PAGE 13

plaintiffs tried to speak out about issues at union meetings. The laborers in Local 230
are in so much fear that they never questioned any contract. Proportionately far more
than any other trade union, the laborers work at a market recovery rate and would not
dare to ask a question at a meeting about this fact, No laborer would ever question the
forced collections on job sites knowing the penalty. Neither Mr. Wall, Mr. Cooksey nor
Mr. Manos was allowed to speak about issues at union meetings, this pattern of not
allowing us to talk occurred separately over a ten to thirteen year period of time. In
some cases rather than let the plaintiffs speak, the Officers and Executive Board would
stop the meeting. No laborer will ever question the unions expenditures when they
are read at the union meeting for fear of what will happen to them. Many laborers
have a fear of even attending meetings, and that fact carries over to elections also.
Many laborers are afraid to attend,

When Dominick Lopreato was indicted in 3-94-CR-001 90, neither the Executive
Board nor any laborer at the general meetings would bring the matter up. To this day
a laborer can not question the five million dollar loss. Since October 15, 1970, the
Executive Board and its Officers have consisted of a convicted rapist, a convicted drug
trafficker, a convicted bookmaker, a convicted bank robber, and other criminal
element.

In United States v Local 560 780 F. 2d 267 Id. 274, the District Court held that
extortion of the memberships democratic rights in violation of the Hobbs Act, 18 USC
1951, was accomplished by fostering a general climate of intimidation within Local
560. The District Court stated that the failure to develop any political opposition to the
leadership of Local 560 during the past twenty years demonstrated this climate of
intimidation.

For the laborers who have either experienced or have knowledge of
government agents covering the federal statute violations of the leadership of Local
230, the level of fear goes beyond that of Local 560, and now the same is so with the

10/07/1998 05:04 8606334283 STEVE MANOS PAGE 15

CERTIFICATION

This is to certify that service has begun on this 6th day of October, 1998 on the

following defendants, service includes a copy of the Amended Complaint dated

October 6, 1998, and a copy of the Courts Ruling dated September 24, 1998, and the

Attachment to the Amended Complaint:

Mr. Robert Luskin
General Executive Board Attorney
Laborers' International Union of North America
1025 Thomas Jefferson Street, N. W. , Suite 420
East Washington, D. C. 20007-52431

Mr. Vere 0. Haynes
Third Vice President
Laborers' International Union of North America
475 Ledyard Street
Hartford, Connecticut 06114

Mr. Dominick Lopreato
RD #5
Federal Prison
Lewisburg, PA. 17834
Fed # 11939-014

Mr. John Pezzente
Laborers Local 230
475 Ledyard Street
Hartford, Connecticut 06114

Laborers' International of North America
1025 Thomas Jefferson Street, N. W, , Suite 420
East Washington, D. C. 20007-52431

Laborers' Local 230
475 Ledyard Street
Hartford, Connecticut 06114

• 
  10/07/1998 05:04 8606334283 STEVE MANOS PAGE 16
  
  Page 2 of Cerfification
  
  Mr. John T. Fussell
  Robert M. Cheverie Associates
  Commerce Center One
  333 East River Drive
  East Hartford, Connecticut 06108
  Attorneys for Defendants
  Defendants:
  Robert M. Cheverie
  Charles LeConche
  Harriet Roman
  
  

Submitted By:

s/Gary Wall

Gary Wall , Pro Se.
60 Carriage  Hill Dr
Wether ield, Connecticut 06109
860-529-2651 860-563-5915

William Cooksey, Sr., Pro Se
1097 Maple Avenue,
Hartford, Connecticut
860-956-8334

Stephen Manos, Pro se
77 Hale Road
Glastonbury, Connecticut 06033
860-659-4266