Laura J. Portiss
4 - 44 King Street West
Dundas, Ontario
L9H 1T7

(905) 627-5100

March 15,1999


VIA FAX

Attention:

Mr. Arthur Coia
905 16th Street N.W.
Washington, D.C.

Re: The matter of Robert Leone v. William Nixon


Dear Mr. Coia,

I am receipt of your correspondence to Mr. Rick Vani, President of Local 1089 dated February 18, 1999.

In the above mentioned correspondense you suspended the charges in the matter of Leone v. Nixon, further you stated you were giving Robert Leone an opportunity to prove what Mr. Nixon did to violate the LIUNA Constitution.

As clearly stated Mr. Nixon did not violate the LIUNA Constitution, therefore taking into consideration the timeliness of Mr. Leone’s charge I ask you to dismiss the charges against Mr. Nixon immediately. Mr Leone has had more than reasonable time to submit any evidence supporting his charges, however I don’t believe Mr. Leone can submit evidence of a violation as the violation does not exist.

I further request you order Mr. Leone to make full disclosure of his evidence against Mr. Nixon, as to ensure Mr. Leone’s actions were not unfounded and a form of retalition against Mr. Nixon.

Also, Mr. Leone and the Local 1089 Executive Board have taken great effort to discredit and embarrass Mr. Nixon by not only making verbal statements at the Local 1089 Membership meetings but also placing an advertisement in the newspaper which stated paid for by Local 1089.

In light of these actions I request a public apology be made to Mr. Nixon both verbally at the next membership meeting, including a reading of your correspondense dated February 18,1999 and further a written apology be published at Mr. Leone’s expense in the newspaper. I request the written advertisement be of the same size and print as the one published against Mr. Nixon.

Mr. Coia I am sure that you will find my requests reasonable as I know you are not going to facilitate any form of retaliation against a LIUNA member and if in fact retaliation was Mr. Leone's motive for bringing the charges against Mr. Nixon I am sure you will see that appropriate disciplinary proceedings are taken.

Also when responding please do so at the above address or fax number as I noticed on February 18,1999 you sent a copy of your correspondense to Mr. Nixon in care of Local 1089 of which was never given to Mr. Nixon.

I look forward to your speedy response in hope that this matter will be cleared up once and for all.

Sincerely,

Laura J. Portiss


cc:

Robert Luskin

W. Douglas Gow

William Nixon

Robert Leone

Local 1089 Executive Board

Mr. Joseph Mancinelli