UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
SECOND AMENDED COMPLAINT FORM
GARY R. WALL,
CASE NO: 3:97-CV02502 (JCH)
WILLIAM COOKSEY SR,
STEPHEN MANOS
Plaintiffs
-v-
ROBERT LUSKIN
VERE O HAYNES
MICHAEL S. BEARSE
LABORERS LOCAL 230
LABORERS INTERNATIONAL UNION DATED:
AUGUST 30, 1999
DOMINICK LOPREATO
JOHN PEZZENTE
CHARLES LECONCHE
ROBERT CHEVERIE
HARRIET ROMAN
FRANK FREEMAN
LUSKIN/COIA/LOPREATO GROUP "L.C.L.' THE ENTERPRISE 18 U.S.C. 1961(4)
A. PARTIES PLAINTIFFS
1. Plaintiff Gary R. Wall is a citizen of Connecticut who presently resides
at 60 Carriage Hill Drive, Wethersfield, Connecticut 06109
2. Plaintiff William Cooksey Sr is a citizen of Connecticut who presently
resides at 1097 Maple Avenue, Hartford, Connecticut 06114
3. Plaintiff Stephen Manos is a citizen of Connecticut who presently resides
at 77 Hale Road, Glastonbury, Connecticut 06033
A. PARTIES DEFENDANTS
1. Defendant Robert Luskin is a citizen of Washington, D. C. who's title is
General Executive Board Attorney Laborers' International Union. Mr. Luskin
is also an in-house prosecutor per agreement with the Department of Justice.
His place of business is 1025 Thomas Jefferson Street, N. W. Suite 420, East
Washington, D. C. 20007-5243.
2. Defendant Vere O. Haynes is a citizen of Connecticut. He is a third
Vice
President Laborers International Union of North America. His place of
business is 475 Ledyard Street, Hartford, Connecticut.
3. Defendant Michael S. Bearse is a citizen of Washington, D.C. and Rhode
Island. His title is General Counsel, Laborers International Union of
North
America, 905-16th Street, N. W. Washington, D.C. 20006.
4. Defendant Laborers Local 230 is a "legal entity"
"Corporation" 18 U.S.C.
1961 (3). It is also an enterprise 18 U.S.C. 1961 (4) in the District and
Commonwealth of Connecticut. It's place of business is 475 Ledyard Street,
Hartford, Connecticut.
5. Defendant Laborers' International Union of North America is a "Legal
entity" " Corporation" 18 U.S.C. 1961 (3). It is also an
enterprise 18
U.S.C. 1961(4) in the District and Commonwealth of Connecticut. It has two
legal addresses 475 Ledyard, Hartford, Connecticut and 905-16th Street, N.
W., Washington, D. C. 20006.
6. Defendant Dominick Lopreato was the Business Manager of Local 230 at
pertinent times in the complaint. He is a citizen of the State of
Connecticut. He has just recently been released from prison and his
attorney
did not know his address in Connecticut but told me over the phone they would
except service Mr. Lopreato has held different officer positions since
October 15, 1970 until his incarceration.
7. Defendant John Pezzente is a citizen of Connecticut who's business address
is 475 Ledyard Street, Hartford, Connecticut. Mr. Pezzente has held
different officer positions of Local 230 since October 15, 1970.
8. Defendant Charles LeConche is a citizen of Connecticut who's business
address is 475 Ledyard Street, Hartford, Connecticut. Mr. LeConche is
presently Business Manager of Local 230 and has held officer positions since
October 15, 1970.
9. Defendant Attorney Robert M. Cheverie is a citizen of the State of
Connecticut. His business address is Cheverie & Associates, Commerce
Center
One, 333 East River Drive, East Hartford, Connecticut 06108-4201. He has
been General Counsel for Local 230 for about 14 years.
10. Defendant Harriet Roman is a citizen of the State of Connecticut. Her
business address is 475 Ledyard Street, Hartford, Connecticut. Ms. Roman
has
been Mr. Lopreato Secretary and presently is Mr. LeConche's secretary. The
allegations lodged against her are in her capacity of dispatcher.
11. Defendant Frank Freeman is a citizen of the State of Connecticut. He
presently resides at 24 Lee Court, Colchester, Connecticut 06415. He has
held the position of Sergeant At Arms Local 230 and is presently Vice
President Local 230.
12. The Enterprise: "Luskin/Coia/Lopreato Group 'L.C.L.'" 18
U.S.C. 1961(4)
is an active effective date enterprise in the District and Commonwealth of
Connecticut since February 13, 1995 the L.C.L has maintained and controlled
the existence of this effective date enterprise. Its primary address not
its
exclusive address is 475 Ledyard Street, Hartford, Connecticut.
B. JURISDICTION
The jurisdiction of this Court is invoked pursuant to 18
U.S.C. 1964(c )
for violation of 18 U.S.C. 1962 (b) (c) (d) and violations of 18 USC 1961
(1)(5). Venue and process invoked pursuant to 18 U.S.C. 1965 (a).
C. NATURE OF THE CASE
This action is against an enterprise 18 U.S.C. 1961 (4) and
the entities
that are part of the enterprise 18 U.S.C. 1961 (3) and the defendant person's
18 U.S.C. 1961 (3) that are associates of said enterprise. For substantive
violations of 18 U.S.C. 1962 (b)(c)(d), 18 U.S.C. 1961 (1)(5) from October
15, 1970 "effective date RICO enterprise". Racketeering injury's
in the
meaning of 18 U.S.C. 1961 (5) starting 1985 and continuing on by and through
the "Operational Agreement" February 13, 1995 to present day, with no
determinable completion date.
D. CAUSE OF ACTION
The plaintiff allege that the following constitutional right
and
privileges have been violated. Our intangible property rights, LMRDA
membership rights, our employment rights, our rights to self-determination,
as provided by the LMRDA and our constitutional right of due process.
CLAIM 1: The plaintiffs allege that the following Federal
Statutes have
been violated 18 U.S.C. 1962 (b)(c)(d), 18 U.S.C. 1961 (1)(5), 18 U.S.C.
1951, 18 U.S.C. 1951(b)(2), 18 U.S.C. 1341, 18 U.S.C. 1341, 18 U.S.C. 1343,
18 U.S.C. 2, 18 U.S.C. 1512, 29 U.S.C. 411, 29 U.S.C. 401, 29 U.S.C. 530, 29
U.S.C. 501, 29 U.S.C. 1959 in the Control and Maintenance of 18 U.S.C. 1961
(4).
SUPPORTING FACTS
OF
D. CAUSE OF ACTION
The following is how each defendant is involved without
citing legal
authority or arguments in accordance with the complaint instructions.
Defendant Robert Luskin GEB Attorney/In-house Prosecutor per agreement with
the Department of Justice, Mr. Luskin from February 13, 1995 has facilitated,
consciously avoided facts, and conspired with criminal acts of the
Coia/Lopreato Group, [Now the "Luskin/Coia/Lopreato Group] for violations
of
Federal Statutes committed by International representatives, a signatory to
the Operational Agreement with the Department of Justice [Vere O. Haynes]
Local 230 Officers, Executive Board members and associates in the District
and Commonwealth of Connecticut.
Defendant Vere O. Haynes about 10-13 years ago, Mr. Haynes was appointed to
the Eighth Vice Presidency of the International by Arthur Coia, Sr. He is
presently the Third Vice President of the International. Mr. Haynes has
facilitated the extortion of the three named plaintiffs membership rights at
union meetings Executive Board meetings by the officers of Local 230 and
international representatives since he became a vice president to the present
day; And, in doing so knowingly maintained and facilitated the
racketeering
activity of the "Coia/Lopreato Group" named now as the
"Luskin/Coia/Lopreato
Group". On July 30, 1997, Mr. Haynes facilitated serious violations
of
Federal Statutes that Congress intended to deter and stop violence in unions.
Mr. Haynes is a signatory to the Operational Agreement with the Department
of Justice. Also worth mentioning, Mr. Haynes, Third Vice President job is
a
part time job. His full time job is a janitor.
Defendant Attorney Michael S. Bearse is the General Council Laborers'
International Union. About 14 years ago, Arthur Coia Sr hired Mr. Bearse
as
the regional attorney. Mr. Bearse at the time was working for Shipman and
Goodman a law firm. There were very substantial legal bills being
submitted
by the firm because of the legal attack by this plaintiff, so Mr. Coia, Sr.
hired him directly. Mr. Bearse is being charged with multiple counts of
mail
fraud, the extortion of Plaintiff Wall and Plaintiff Cooksey's membership
rights, the exact dates of all the frauds we are not able to give yet because
of the fraudulent concealment of the protective order issued by the N.L.R.B.
were Mr. Cooksey and I were winning plaintiffs. We do have enough dates
for
the RICO threshold.
Defendant Local 230 is an entity Corporation involved in Interstate Commerce;
Local 230 is a "captive labor organization" for three (3) decades,
maintained
and controlled by the named defendants. Arthur Coia, Sr. acquired control
of
Local 230 through the fraudulent filings of LM 15 and LM 16 form in 1970.
Three of the present day defendants were involved in that fraud Lopreato,
LeConche and Pezzente.
Defendant Laborers International Union has been a "captive labor
organization" for three decades. It was the target of two Presidents
Crime
Commissions when both Coia, Sr. and Coia Jr. held position of power in the
international. Mr. Luskin in his position as in-house prosecutor is
facilitating its captive status in the District and Commonwealth of
Connecticut since February 13, 1995 to present day with no definable
termination date.
Defendant Dominick Lopreato: Mr. Lopreato was the Business Manager of
Local
230 from October 15, 1970 until he went to prison in 1995 for excepting a
bribe where union funds were embezzled [5,000,000.00, five million]. He is
now out of prison and is no longer an officer pursuant to the Honorable Judge
Daley's ORDER, but still has an influence as the Lopreato of the
"Coia/Lopreato Group" Now Known as the "Luskin/Coia/Lopreato
Group".
Since October 15, 1970, Mr. Lopreato has committed multiple
predicate
acts of extortion of the plaintiffs Membership Rights, bribery, embezzlement,
mail fraud and wire fraud of those rights and pension rights in the
furtherance of an enterprise.
Defendant John Pezzente: Mr. Pezzente has held different officer positions
of Local 230 prior to and since October 15, 1970. Mr. Pezzente is an
effective date enterprise conspirator Mr. Pezzente has made extortion
collections on construction jobs for Dominick Lopreato, Arthur Coia, Sr,
Arthur Coia, Jr. and Charles LeConche. In the form of a pattern of
racketeering since October 15, 1970. Mr. Pezzente has been and still is a
key associate in fact of the "Coia Lopreato Group" now the
"Luskin/Coia/Lopreato Group". Since 1985 Mr. Pezzente has
participated in
one on going racketeering scheme against Plaintiff Wall and Cooksey using the
mail and wire fraud to extort the plaintiffs membership rights [Police Report
1985, April 9th letter 1996]. In a pattern of other frauds committed
against
Plaintiff Wall and Cooksey by Mr. Pezzente.
Defendant Charles LeConche: Mr. LeConche has been an officer in local 230
since October 15, 1970. Mr. LeConche has extorted the membership right of
all three plaintiff in separate schemes. Mr. LeConche has used the mail to
defraud the U. S. District Court and has used the United States District
Court in Hartford to tamper with a witness.
Defendant Attorney Robert Cheverie: Mr. Cheverie has been General Counsel
to
Local 230 for about 14 years. Mr. Cheverie has been an associate in fact
of
the Coia/Lopreato Group now the "L.C.L." for the same amount of time.
He to,
just like Mr. Bearse was hired away from his law firm, Ashcraft and Gerell by
Arthur Coia Sr to hide the legal bills generated by the plaintiff.
Mr. Cheverie actions go beyond that of legal counsel through
the
commission of multiple predicate acts of extortion of membership rights, wire
and mail fraud including but not limited to the April 9, 1996 letter.
Defendant Harriet Roman: Ms. Roman has been employed by Local 230 as
Dominick Lopreato's secretary and Charles LeConche's secretary for about 7-9
years for about the last 6 years she has performed the duties in the
unconventional position for a secretary of a dispatcher. It is in that
position that she has extorted membership rights of the plaintiffs and
committed mail fraud through perjurious affidavits entered in U. S. District
Court in a relevant LMRDA case Wall Cooksey -v- Local 230 3:97CV9402 (JCH).
In doing so, she maintained and participated in the furtherance of a pattern
of extortion of Plaintiff Wall and Cooksey's membership rights.
Defendant Frank Freeman: Mr. Freeman was the Sergeant at Arms when on July
30, 1999, he assaulted Mr. Manos for the purpose of maintenance and control
of the enterprise. Mr. Freeman increased his position in the enterprise by
committing the act and now as of June 20, 1998 is now the Vice President of
Local 230.
The Enterprise October 15, 1970 Coia/Lopreato/ February 13, 1995 "L.C.L."
"Luskin/ Coia/Lopreato Group": From October 15, 1970 LeConche,
Lopreato,
Pezzente, Coia Sr agreed to acquire and maintain, both directly and
indirectly, an interest and control of Local 230 Enterprise, through the
commission of various racketeering offenses. From in or about 1986,
Defendant Cheverie and Defendant Bearse participated in the maintenance and
control of Local 230 Enterprise through various racketeering offenses, to
present day. From in or about 1991, Ms. Roman to present day, participated
in the maintenance of Local 230 enterprise. From in or about 1990,
Defendant
Freeman participated in the maintenance and control of Local 230 enterprise.
>From in or about 1986, Defendant Haynes participated in the maintenance and
control of Local 230 the enterprise and the Laborers' International
enterprise. From February 13, 1995, Defendant Luskin participated in the
maintenance and control, both directly and indirectly of Local 230 enterprise
and LIUNA enterprise, through facilitating and the conscious avoidance of
facts and in some cases conspiracy to hide the racketeering facts, all for
the purpose of hiding the enterprise. All of these defendants understood
the
scope of this agreement and had knowledge that others were performing tasks
related to the accomplishment of their purpose, the collective impact of
which has directly and substantially contributed to the existence of the
climate of fear and intimidation in Local 230 with no definable termination
date.
Claim 2: The plaintiffs allege that Defendant Luskin through the authority
entrusted in him by the Department of Justice through the Operational
Agreement with the Department of Justice an agency of the United States, has
violated the procedural due process clause of the fourteenth amendment of the
United States Constitution violating the constitutional right of the
plaintiffs in the District and Commonwealth of Connecticut.
E. REQUEST FOR RELIEF
Pursuant to 18 U.S.C. 1964 (c) any person injured in his business or property
by reason of a violation of section 1962 may sue therefore in any appropriate
United States District Court and shall recover threefold the damages he
sustains and the cost of the suit; Including a reasonable attorney fee.
Therefore, the plaintiffs claim the recovery of wages, benefits and
membership rights.
The plaintiffs also request the Court after hearing the evidence and if the
defendants are found guilty of the allegations to: Pursuant to 18 U.S.C.
1964 (a) the District Courts of the United States shall have jurisdiction to
prevent and restrain violations of section 18 U.S.C. 1962 by issuing
appropriate orders. To order dissolution and reorganization of Local 230.
F. JURY DEMAND
6 The plaintiffs request trial by jury.
................
GARY R. WALL, PRO SE
60 Carriage Hill Drive
Wethersfield, Connecticut 06109
860-529-2651 860-563-5915
.................
WILLIAM COOKSEY SR, PRO SE
1097 Maple Avenue, Hartford, CT 06114
.................
STEPHEN MANOS, PRO SE
77 Hale Road, Glastonbury, CT. 06033
DECLARATION UNDER PENALTY OF PERJURY
The undersigned declares under penalty of perjury that they
are the
plaintiffs in the above action, that they have read the above complaint and that
the
information contained in the complaint is true and correct 28 U.S.C. 1746; 18
U.S.C. 1621
Executed At____________________ ON_________________________________
GARY R. WALL, PRO SE
60 Carriage Hill Drive
Wethersfield, Connecticut 06109
WILLIAM COOKSEY SR PRO SE
1097 Maple Avenue, Hartford, CT. 06114
STEPHEN MANOS
77 Hale Road, Glastonbury, CT. 06033
The Laborers Network