LABORERS' LOCAL UNION 665, et al.
DISTRICT COUNCIL OF
THE LABORERS' INTERNATIONAL
UNION OF NORTH AMERICA
AUGUST 16, 1996
My name is Ronald Nobili. I am making this statement to the
best of my knowledge and belief and under
penalty of perjury:
1. I am a plaintiff in this case.
2. I am a member of LIUNA, the Connecticut
District Council of LIUNA, and Local 665.
3. I am the principal executive officer of
4. The main functions of a local union organization
are to negotiate collective bargaining agreements, enforce the
agreements, process grievances, and organize new bargaining units
among other things. Those are all tasks that used to be performed
by the locals in Connecticut until the defendant gradually usurped
the locals' responsibilities.
5. The defendant now operates essentially
as state-wide local union for the LIUNA members who work in construction.
It performs nearly all the tasks associated with a local union.
It negotiates the collective bargaining agreements. It enforces
the agreements. It processes grievances. It is engaged in organizing.
There is very little that local business
managers do in the bargaining area except insofar as we are agents
of and members of the district council. To put it another way,
the Laborers now operate in the same way as do other construction
unions, such as the Operating Engineers and Plumbers which have
6. I have examined the LM-2 reports of the
district council and of all the locals. Most of the money that
is taken in by the defendant and by the locals goes to pay the
salaries and benefits of union officials, and employees. The leading
officials of the district council include Charles LeConche, business
manager and secretary-treasurer, Anthony Varbero, president. In
1995, LeConche received more than $138,000 from the defendant
and his local, according to the 1995 LM-2; Varbero received more
7. Anthony Varbero is currently the president
of the district council. He is business manager or Local 146,
based in Norwalk. Local 146 has approximately 245 members, about
half the size of Local 665. There is very little construction
work within Local 146's territory, and very little work for Varbero
to do. Local 146 has taken in a number of members who reside in
Bridgeport, and who ordinarily would be members of Local 665,
by artificially reducing their dues paid to Local 146, but making
it up in hourly dues paid to the defendant, than passed on to
In 1993, Varbero was vice president of the
defendant and paid $2400 from the defendant; he was paid $100,000
from Local 146, for a total of more than $102,400. His union car
is a Cadillac Seville. He wears a handgun on his ankle. He owns
real estate in or near Vagas and spends large amounts of time
out of state. In 1993, Varbero reduced his salary from Local
146 to $93,000, but his income at the district was increased
8. Officers and delegates to the district
council are frequently treated to expensive meals and trips which
in my opinion have little or nothing to do with promoting the
welfare of union members. I am familiar with the all allegations
in the complaint, and they are accurate.
9. The start of my official appeal through
internal union channels was October 14, 1993, when I wrote to
Regional Manager Armand B. Sabitoni to complain about the dues
allocations. It ended on August 24, 1994 when the General Executive
Board decided against us.
10. I never envisioned the possibility of
winning an official internal appeal, and the fact that I lost
proves it. Moreover, the appeal which I did take was bound to
fail, and all internal remedies are futile. The father of the
president of LIUNA is the person who created the hourly dues system
when he was regional manager in New England. Over the years, Arthur
I participated personally in decisions allocating
the money. To my knowledge, there has never been anyone who has
ever prevailed by trying to take advantage of an internal remedy.
11. The defendants and its officials are
extremely intimidating, and there is no democratic content to
its meetings or votes. No votes are by secret ballot. Except for
me, there is virtually no dissent at the district council, even
though I know there are some delegates to the council who know
that I am right.
At district council meetings, since I filed
this law suit, no delegates will sit with me or socialize with
me. The message is very clearly given that if anyone opposes the
defendant's leaders, he and his members will have to pay the consequences
by not being given sufficient money to operate, and by having
employment opportunities taken away. I would have opposed the
defendant's illegal conduct earlier including filing a law suit
if necessary except that as a consequence of mobility, I was
afraid for my members and my physical well-being and at one time,
my life. The reason I was able to do so starting in 1993 is because
the U.S. Justice Department took Dominick Lopreato out of commission
and then it took over oversight of LIUNA. This gave me enough
confidence to proceed.
12. The members of Local 665 pay out more
money to the defendant than they receive back, and they consistently
pay out a higher percentage of dues than do the members of the
locals controlled by Varbero. As a result, the members of Local
665 are forced to subsidize the large salaries of the defendant's
officers, though the members never had an opportunity to vote
on it. Over the past several years, Local 665's treasury has been
bled by the defendant so badly, that it had to lay off a field
representative whose job was to help me protect the rights of