Gary Wall et al.
Plaintiffs

Case # 397 CV 02502 JCH

v.

Robert Luskin et al.
Defendants

Date : January 10, 2000

1. I am over the age of eighteen & understand & believe in the obligation of an oath.

2. My name is Stephen Manos & I reside at 77 Hale Road, Glastonbury, Connecticut.

3. In April of 1996, I was a foreman on the same job-site where Thomas Olbrias was a steward appointed by Defendant LeConche.

4. For many years it was common knowledge that Olbrias was known as a steward appointed by either Defendant Lopreato or Defendant LeConche.

5. I was also aware of Olbrias having a reputation for criminality & violence, & I did see Olbrias acting in a threatening, abusive & frightening manner toward Julian on the same night that Olbrias threatened Julian.

6. Prior to that incident, I had taken note of the fact that, while working on the job site & on diverse occasions, Olbrias acted in an impaired manner.

7. As a direct result of the Olbrias threat, I had two meetings with Defendant LeConche.

8. I initiated these meetings in my capacity as union Vice-president/member, & foreman.

9. In the first meeting [not mentioned in either affidavit] I met with Defendant LeConche & union officer Butch Granell on the morning after the incident .

10. I explained that Olbrias had made a murderous threat towards foreman Julian the previous night & that I was there to report the incident.

11. My employer [Tony Luiz] later related to me that Defendant LeConche consequently called him & proceeded to threaten & intimidate him, saying, among many other things, that my employer should drop out of being a union contractor.

12. My employer also related to me that he was fearful of retaliation from Defendant LeConche.

13. Union officers John Pezzenti & Butch Granell visited the job-site on different occasions in a blatant attempt to coerce foreman Julian into keeping Olbrias.

14. Because of Defendant LeConche's abusive actions, I initiated a second meeting with Defendant LeConche at the Hartford union offices.

15. Also present at that second meeting were Defendant Pezzenti, Butch Granell & Olbrias.

16. Olbrias, admitted, for the first time, that he had made a murderous threat against Julian.

17. Olbrias made no excuse or apology & immediately was told to leave the meeting by Defendant LeConche.

18. The meeting continued with myself & Defendant LeConche who immediately politicized the meeting by making it known that he was well aware that both myself & Gene Julian had, on different occasions, spoken openly about the union & its officers.

19. Defendant LeConche continued to be accusatory, belligerent & threatening concerning Julian & I speaking out [on the job-site] about the leadership of Local 230.

20. I left this second meeting with nothing resolved.

21. I have reported the aforementioned facts to LIUNA General Executive Board Attorney Robert Luskin, LIUNA Inspector General Douglas Gow, & the U.S. Justice Department.

22. After that incident & during the years of 1996,1997, & 1998, Julian, myself & my employer were subjected to chronic retaliation & harassment by LeConche-appointed stewards [& other union officials who are subject to the LIUNA Operational Agreement].

23. At union meetings & under LeConche's direction, Julian & I were booed, threatened & shouted down, & on some occasions, members were directed to walk out when we spoke.

24. Many of these acts are enumerated in previous affidavits filed by myself & Julian.

25. I was served with the Olbrias/LeConche affidavits [Docket #'s 127 & 128].

Quoting The Olbrias Affidavit & Responding:

26. Quoting Olbrias: [6.] " ... I threatened to shoot Mr. Julian in the head six times. ... There is no connection between the incident involving this unfortunate threat & the Local Union leadership."

Fact: The Local Union leadership condoned Olbrias's actions after the incident by their intimidating tactics aimed towards myself, foreman Gene Julian & our employer Antonio Luiz & with the express purpose of keeping Olbrias on the job.

27. Quoting Olbrias: [7.] " I worked the next day following the incident & then, at Mr. LeConche's direction, I was removed from the Babbidge Library Project job."

Fact: The incident occurred at the beginning of the work week & Olbrias was laid off at the end of the week after a steady pattern of threats, harassment & intimidation by Defendant LeConche, Defendant Pezzenti, & union officer Butch Granell.

Fact: Olbrias was terminated from the job by the employer despite the extortive tactics of Defendant LeConche & his associates-in-fact.

28. Quoting Olbrias: [8.] ".... the Union's Business Manager relieved me as steward & removed me from the job. I apologized for my actions."

Fact: Olbrias was not removed by Defendant LeConche & never apologized for his actions.

Fact: Olbrias, under the supervision of Defendant LeConche, was immediately appointed as either a steward or foreman on another job.

Fact: This action by Defendant LeConche was a clear indication to the union membership that he condoned threats & intimidation by Olbrias & is direct evidence of a captive labor organization.

Quoting The "LeConche Affidavit" & Responding:

29. Quoting LeConche: [9.]" During the month of April, 1996, Steve Manos & Tom Olbrias came to the Local Union office to discuss [the] incident ... ."

Fact: I initiated the meeting with Defendant LeConche to discuss his abusive actions toward Julian, myself & my employer. [Olbrias showed up at the behest of Defendant LeConche]

30. Quoting LeConche: 10. "Mr. Olbrias apologized & said it was an idle threat expressed out of frustration & with no intent to carry out the threat. ... I immediately informed Mr. Olbrias that he was out of line & would be removed from the job. Mr. Olbrias ... at my direction, was removed from the job."

Fact: I was present at the whole meeting & none of this happened.

Fact: The only thing remotely related to this purely fictional account is Defendant LeConche saying to Olbrias: "So you threatened to shoot him in the head six times !!!" [with no answer from Olbrias]

31. Quoting LeConche: [11.] "Mr. Olbrias's temper flare ... was not authorized or condoned by the Local Union or any of its officers."

Fact: Defendant LeConche & his associates never spoke out against Olbrias's murderous threat, thereby giving validity to Olbrias's actions.

32. Quoting LeConche: [12] " ... Mr. Olbrias was removed from the job at my direction the day following the incident."

Fact: Olbrias was laid off several days after the incident & definitely not at Defendant LeConche's direction.

Fact: Olbrias was given a lack-of-work layoff slip because of fear of retaliation from the union by my employer.

Fact: Olbrias was replaced the following week with another laborer.

33. Quoting LeConche: [14.] " at no time during the year of 1996 was it evident, as claimed by Mr. Julian ...that he was a known political opponent."

Fact: Political opposition encompasses more that announcing a candidacy.

Fact: Prior to the threat, Julian was recognized as an ally of Manos with all the attendant political implications.

34. Quoting LeConche: [15.]" No Local union representative ever requested Capitol concrete to lay off Steve Manos"

Fact: My employer directly expressed to me that he feared retaliation from the union & on at least one occasion refused to rehire me.

35. Quoting LeConche: [16.] 'No Local Union representative ever threatened Mr. Julian or Mr. Manos because of any political opposition to the officers of the local union, ...

Fact: Manos & Julian were threatened by union officers [which will be proved in discovery].

Fact: At the 07/30/97 Local 230 Executive Board meeting, Manos asked questions about suspicious expenditures by Defendant LeConche.

Directly Quoting LeConche: "Steve, you are about this F*****n' close to me coming over there & ripping your F*****n' throat out."

Fact: Under the supervision of Defendant LeConche, Manos was viciously physically assaulted by Defendant Frank Freeman at that same Local 230 Executive Board meeting.

Fact: Julian was threatened with retaliation by other union officers & members.

36. Quoting LeConche: [16.] "... & no "false internal charges" were ever brought against Mr. Julian or Mr. Manos."

Fact: Julian was brought up on false manipulated, internal charges at the direction of Defendant LeConche. [Union Trial Board Hearing, 03-25-98]

Fact: Defendant LeConche & associate-in-fact Butch Granell gave false testimony at this hearing.

Fact: Julian was exonerated, with the hearing officer finding laborer Antonio Osman [the LeConche-instigated "Plaintiff'] to have "no credibility".

Fact: Manos was brought up on false, manipulated, internal charges at the direction of Defendant LeConche when associates-in-fact Pezzenti & Granell coerced & used laborer David Blatter to file a contrived & fabricated complaint. [Discovery will prove these & other facts.]

37. Quoting LeConche: [17.] "Mr. Julian's assertion that he has been "forced to pursue another occupation because of both economic deprivation & fear" is a self-serving deception."

Fact: Number 17. Is willfully taken out of context & fails to identify "The Enterprise". Page 4, paragraph 26., [Affidavit of Gene Julian In Support Of Motion Requesting Pro SE Plaintiff Status In This Instant RICO Action, 12-06-99] In its entirety, reads as follows:

" 26. Because of fear of both economic deprivation & fear for my physical safety as a result of the actions of the Enterprise as identified in The RICO complaint, as of September, 1999 I have been forced to pursue another occupation thereby abandoning over 15 years of accredited service in the union."

38. I am giving witness to this statement by Gene Julian.

Submitted By:

_______________________________

Stephen Manos

State of Connecticut

County of Hartford

Subscribed & Sworn to before me this _______ day of ___________ 2,000

Subscribed & sworn to before me on this ______ day of __________