NO.: 395CV02372(AVC)

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 Local 665.

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 state-wide locals.

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 than $97,000.

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 Varbero

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 to $6,620.

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 A. Coia

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 my members.

Ronald Nobili

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