Gary Wall et al.
Case # 397 CV 02502 JCH
Robert Luskin et al.
Date : January 11, 2000
1. I am over the age of eighteen
& understand & believe in the obligation of an oath.
2. My name is Gene Julian &
I reside in Stafford Springs, Connecticut.
3. Many statements in the aforementioned
affidavits are lies to the court in order to shield the criminal
intent of the Enterprise.
4. In April, 1996, LeConche
steward Thomas Olbrias threatened to "shoot [me] in the head
5. Olbrias was both drunk &
belligerent when he made this murderous threat to me.
6. On the following day, Defendant
LeConche was informed of this incident by then-Local 230 Vice-President
7. Defendant LeConche was also
informed by my employer, Tony Luiz, who gave LeConche 48 hours
notice as required by the union contract.
8. Despite this fact, I was
subjected to brutal pressure, from Defendant LeConche, Defendant
Pezzenti, & LeConche-associate-in-fact Leonard Granell Jr.
to keep Olbrias.
9. Quoting Defendant Pezzenti:
"Don't be the first one to say no to the Business Manager."
10. Quoting union representative
Granell: "Just keep him."
11. I exhausted the remedies
pursuant to the LIUNA Operational Agreement & demanded that
this matter be investigated as covered by the LIUNA Ethics &
12. I was under the impression
that the LIUNA Operating Agreement would remedy all the abuses
perpetrated against Luiz, Manos & myself.
13. I took all the steps necessary
including two personal interviews & several phone conversations
with LIUNA Inspector General investigator Sheryl McLaughlin.
14. Through their inspector,
I informed LIUNA General Executive Board [GEB] Attorney/In House
Prosecutor Robert Luskin, LIUNA Inspector General [IG] W. Douglas Gow, & LIUNA Independent
Hearing Officer [IHO] Peter Vaira of my situation.
15. However, after repeated
efforts on my part, I was never informed as to the outcome of
16. The violation of my intangible
property rights began with the murderous threat & continued
through my last contact with IHO Vaira.
17. Defendant LeConche swears
in # 16.of the his affidavit that " ... no 'false internal
charges' were ever brought against Mr. Julian or Mr. Manos."
18. The non-existent charges
that Defendant LeConche refers to were brought by replacement
steward Antonio Osman, a willing pawn directed by Defendant LeConche.
19. Osman physically threatened
me on August 29, 1997 in front of a witness.
20. [Quoting the findings of
IHO Trial Board]:
Office of The IHO, LIUNA Local 230 Trial Board [Osman
v. Julian] Docket # 97-50TB
"This order addresses
trial board charges brought by Antonio Osman ["Osman"],
a member of Local 230 of Hartford, Connecticut ["Local 230"],
against Gene Julian ["Julian"], also a member of Local
"By order dated January
15, 1998, the IHO appointed Jeffrey H. Simcox, a member of the
Pennsylvania bar & of the IHO's law firm, to act as a special
hearing master for the IHO in this matter & to conduct an
on site evidentiary hearing in Hartford. That hearing was held
on March 25, 1998 ["Hearing']."
Quoting IHO Special Hearing
Master Jeffrey H. Simcox:
"The testimony of Julian,
Luiz & other witnesses at the hearing was, however, both consistent
& credible ..."
"Osman's own testimony
in this regard was imprecise, bordering on the evasive. Osman's
testimony is not credible."
21. Both Executive Boards of
the captive labor organizations known as Local 230 & The
Connecticut Laborers' District Council were excluded by order
of GEB Attorney Luskin from holding trial boards addressing the
false, manipulated charges.
22. Luskin made sure that this
trial board stayed under the purview of the Operational Agreement.
23. I am also aware that Plaintiff
Manos too has been brought up on false, manipulated charges making
the related statement in LeConche's affidavit a lie.
24. I would like to add that
this complaint against me went to trial while the murderous threat
against me did not.
25. Also, I had a very good
reputation with my former employer, Tony Luiz, but Mr. Luiz hesitated
to rehire me because of his fear of retaliation from the union.
State of Connecticut
County of Hartford