263
          1
          2                        SEALED EXCERPT
          3    OFFICE OF THE GENERAL EXECUTIVE BOARD ATTORNEY
          4    LABORERS' INTERNATIONAL UNION OF NORTH AMERICA
               - - - - - - - - - - - - - - - - - - - - -x
          5
          6              In the Matter of
          7
          8               TRUSTEESHIP PROCEEDINGS
          9               LOCAL 734
         10               NEWARK, NEW JERSEY
         11
         12    - - - - - - - - - - - - - - - - - - - - -x
         13
         14
         15                        November 23, 2004
                                   10:00 o'clock a.m.
         16
         17                        Hilton Gateway
                                   Newark, New Jersey
         18
         19
         20    B E F O R E:
         21              PETER F. VAIRA,
         22                        Independent Hearing Officer.
         23
         24
         25



                                                                   264
          1
          2                        THE HEARING OFFICER:  I am
          3                going to ask Mr. Slevin to give me his
          4                offer of proof as to what Mr. Limberg
          5                would testify to.  Go ahead.
          6                        MR. SLEVIN:  Mr. Limberg had
          7                spoken with a detective, I believe on
          8                Squad C5 which my understanding is
          9                devoted to the investigation of the
         10                Genovese organized crime family.
         11                        This detective was on at least
         12                five surveillances in the Year 2000 in
         13                which he saw Mr. Augie Vergallito and
         14                Mr. Peter Rizzo appear at the Soho
         15                Hotel in Manhattan to have meetings
         16                that lasted approximately one hour
         17                with two individuals.
         18                        The first individual is a
         19                gentleman by the name of Pepe LaScala
         20                who is acting capo of the Genovese
         21                family.  The second was the acting
         22                boss of the family at that time was
         23                Dominick Cirillo, a/k/a Quiet Dom.
         24                        When they appeared at the
         25                hotel they did a check on the



                                                                   265
          1
          2                automobile and it checked out as being
          3                owned by Rose's Taxi or Rose's
          4                Limousine which we will attempt to
          5                demonstrate later was an entity that a
          6                Fund employee by the name of Isaac
          7                Barocus --
          8                        THE HEARING OFFICER:  I am
          9                coming to the conclusion the best way
         10                to handle this is that I will take
         11                this testimony in camera and at the
         12                end you guys can argue whether I
         13                should accept it or not.  I will take
         14                it in camera and it will be sealed and
         15                if I don't accept it it will be gone.
         16                        If I put it in, then I will
         17                make a decision to put it in.  You can
         18                tell me.  I don't know what to do with
         19                the crowd.  Should we just bring
         20                everybody up here and have him testify
         21                or should we just bring the witness a
         22                little bit closer.
         23                        MR. LEDER:  I think you have
         24                to clear the room.
         25                        THE HEARING OFFICER:  Let's go



                                                                   266
          1
          2                back on the record.
          3                        I have cleared the hearing
          4                room and I am going to put the
          5                following testimony in camera and then
          6                I will ask you to seal it and make no
          7                further disclosure outside of this to
          8                anyone except your clients and at the
          9                end, not at this moment but at the end
         10                of this hearing I will make a decision
         11                whether or not it should be in.  I
         12                will even consider it, all right?
         13                        MR. SLEVIN:  If I could just
         14                put something on the record.
         15                Mr. Elko, I think I said that we
         16                wanted him just to talk about
         17                Mr. Vergallito.
         18                        There are other things we
         19                would want him to talk about that
         20                don't have to do with Mr. Vergallito's
         21                La Cosa Nostra background.
         22                        THE HEARING OFFICER:  All
         23                right.
         24                        MR. LEDER:  I would comment,
         25                too, I want to put on the record that



                                                                   267
          1
          2                I believe the tie-in to this is that
          3                there is an attempt being made to say
          4                that the Funds were controlled and
          5                therefore that is why there was
          6                reluctance on the part of the union to
          7                follow the directions of the
          8                supervisor.
          9                        Well, if the Funds were
         10                controlled, then how could they
         11                possibly take the action they took
         12                which is set forth in Exhibit 72,
         13                Mr. Calastro's letter to Mr. Pocino
         14                where he outlines a whole laundry list
         15                of the changes in the Fund.
         16                        THE HEARING OFFICER:  What
         17                recommendation did he follow and said
         18                a number of them.
         19                        MR. LEDER:  And a whole bunch
         20                of people were terminated at the high
         21                salaries that were complained about by
         22                the audit report and those other
         23                supposedly where I guess we are
         24                getting the inference that the Funds
         25                are being controlled as you people



                                                                   268
          1
          2                call it by connected people and as if
          3                they are being controlled how did the
          4                Fund terminate all these people.
          5                        THE HEARING OFFICER:  I see
          6                the argument.  That is why I am
          7                wrestling with this issue.
          8                        If this was a disciplinary
          9                matter I wouldn't touch this unless
         10                there was some direct connection.
         11                This happens to be a trusteeship,
         12                whether the Trustee should continue,
         13                but let me hear what there is.
         14    T H O M A S     L I M B E R G,    called as a
         15           witness, having been first duly sworn by
         16           Tina DeRosa, a Notary Public within and for
         17           the State of New Jersey, was examined and
         18           testified as follows:
         19    DIRECT EXAMINATION
         20    BY MR. SLEVIN:
         21            Q     Mr. Limberg, can you state your name
         22    for the record?
         23            A     Thomas Limberg.
         24            Q     How are you presently employed?
         25            A     As an inspector for the Inspector



                                                                   269
          1                           Limberg
          2    General Office of LIUNA.
          3            Q     How long have you been employed in
          4    that capacity?
          5            A     September of 2002.
          6            Q     Do you have a background in law
          7    enforcement?
          8            A     Yes, I do.
          9            Q     Could you just briefly summarize the
         10    history of your involvement in law enforcement?
         11            A     Yes.  I originally was hired as a
         12    New York City Transit police officer in 1981.  In
         13    1983 I became a New York City police officer
         14    working uniform details, patrol.
         15                  In 1985 I was assigned to the New
         16    York City Police Department Organized Crime
         17    Investigation Division, specifically the
         18    investigation analysis section.
         19                        THE HEARING OFFICER:  You then
         20                became a plainclothes man?
         21                        THE WITNESS:  Yes.  At that
         22                point I came out of uniform, worked
         23                background investigations and
         24                background checks on organized members
         25                and associates.



                                                                   270
          1                           Limberg
          2            A     In early '86 I was assigned to the
          3    Luchese desk for the investigation analysis
          4    section.  I was a Luchese coordinator.
          5                  In December of '86 I was assigned to
          6    an FBI Squad C17 which is a squad with the FBI
          7    Brooklyn-Queens office.  The main purpose was to
          8    investigate crimes committed by Luchese LCN
          9    family.
         10                  The squad was made up by both FBI
         11    agents and New York City detectives.  I worked
         12    there until my retirement in 2002.
         13                        THE HEARING OFFICER:  You
         14                worked there 14 years?
         15                        THE WITNESS:  Yes.
         16            Q     In your time on that squad did you
         17    have occasion to investigate other Cosa Nostra
         18    families?
         19            A     Yes.  We investigated any crimes
         20    committed by the Luchese family and in that many,
         21    many times, in many cases those crimes were
         22    committed in concert with organized crime families
         23    and, in fact, with all five New York families and
         24    the Calcanti family based mainly in New Jersey.
         25                  As part of that task force I was



                                                                   271
          1                           Limberg
          2    also assigned as the organized crime coordinator
          3    for the squad.  The sole purpose being I was
          4    responsible for the maintenance and upkeep of all
          5    intelligence on the family and responsible for
          6    disseminating intelligence to other squads within
          7    the FBI.
          8                  Also I have testified as an expert
          9    in organized crime in the Federal court in the
         10    Eastern District of New York.
         11            Q     Did your investigations involve
         12    labor racketeering?
         13            A     Among others, yes.
         14            Q     What forms of labor racketeering?
         15            A     Cases that have involved the Hobbs
         16    Act.  Extortion in many different industries, the
         17    freight industy, construction industry, garment
         18    industry.
         19            Q     Turning your attention to this case,
         20    did you have occasion to learn of any information
         21    concerning any employees of Local 734 affiliated
         22    benefit fund?
         23            A     Yes, I have.
         24            Q     Who?
         25            A     Specifically Peter Rizzo.



                                                                   272
          1                           Limberg
          2            Q     Did you have occasion to learn any
          3    information about any individuals that were
          4    formally associated with 734 or its affiliated
          5    benefit funds?
          6            A     Yes.  August Vergallito.
          7            Q     What information have you learned
          8    about Mr. Vergallito?
          9            A     In approximately the Year 2000 that
         10    there were a number of meetings that took place at
         11    the Soho Hotel in Lower Manhattan I believe on
         12    West Broadway in the bar area, at least five
         13    meetings.
         14                  They would occur on Wednesday
         15    afternoon at 2:00 p.m. and these meetings would
         16    include Mr. Vergallito, Mr. Rizzo, a man named
         17    Pepe LaScala and man named Dom Cirillo.
         18                        MR. LEDER:  Did you observe
         19                this?
         20                        THE HEARING OFFICER:  I am
         21                going to get to that.  Remember, we in
         22                our brief little offer of proof he had
         23                mentioned something about speaking to
         24                a detective or something.  So give us
         25                the source of your knowledge.  Start



                                                                   273
          1                           Limberg
          2                with that.
          3                        MR. SLEVIN:  If we could it
          4                lay out first.  It will not take long
          5                to state the facts and then we will
          6                get to the basis of his testimony.
          7                        MR. LEDER:  I don't think it's
          8                appropriate.
          9                        MR. SLEVIN:  What I don't
         10                think is appropriate is the attempt to
         11                interrupt the testimony.
         12                        THE HEARING OFFICER:  I assume
         13                he did not see this person.
         14                        THE WITNESS:  No.
         15                        MR. LEDER:  I object.  That is
         16                hearsay.
         17                        MR. SLEVIN:  That shows your
         18                unfamiliarity with the process because
         19                hearsay can come in this proceeding.
         20                        MR. LEDER:  Hearsay except
         21                when you are trying to prove a fact
         22                and you can't rely upon it.
         23                        MR. SLEVIN:  Before you object
         24                you should understand the rules.
         25                        THE HEARING OFFICER:  Time



                                                                   274
          1                           Limberg
          2                out.  I assume he is going to say
          3                somebody else told him in some
          4                fashion.  That hearsay, is it
          5                credible, reliable, that is for me to
          6                determine.
          7                        MR. SLEVIN:  That is right.
          8                        THE HEARING OFFICER:  I assume
          9                that he is going to tell us this
         10                occurred.  You want to go in reverse
         11                order.  I am still the guy you have to
         12                convince and I am not going to be
         13                convinced by hearing something
         14                shocking and find out it has no
         15                source.
         16                        I am an old prosecutor.  I
         17                understand hearsay and what is
         18                corroborating and what is not.
         19                        You may go in the order we are
         20                going and we will figure out if it is
         21                reliable.
         22    BY MR. SLEVIN:
         23            Q     Who is Pepe LaScala?
         24            A     In 2000 at the time he was acting
         25    capo of the Genovese crime family, specifically



                                                                   275
          1                           Limberg
          2    acting for Angelo Prisco who was a captain, who
          3    was incarcerated at the time.
          4            Q     Who is Dominick Cirillo?
          5            A     In 2000 he was the acting boss of
          6    Genovese crime family.
          7                        THE HEARING OFFICER:  Do you
          8                want to tell me where Pepe is, where
          9                he is or who he is.  You have to tell
         10                me what basis you are relying on.
         11            Q     What basis are you relying on?
         12            A     At this time I was still a member of
         13    C17 with the FBI squad and had access specifically
         14    to know that Dom Cirillo, also known as Quiet Dom,
         15    was the acting boss of the Genovese crime family
         16    from my work on the joint task force.
         17                  And my knowledge of LaScala's
         18    position at this time is basically the same basis
         19    as I learned the information.
         20            Q     What is that basis?
         21            A     From a detective Andy Varga,
         22    V-A-R-G-A, who conducted, was on some of those
         23    surveillance and personally identified the
         24    individuals.
         25                        THE HEARING OFFICER:  I want



                                                                   276
          1                           Limberg
          2                to know who Pepe LaScala is.
          3                        THE WITNESS:  He was according
          4                to Detective Varga an acting capo in
          5                the Genovese crime family.
          6                        THE HEARING OFFICER:  Is there
          7                any other source of information that
          8                could tell me that?
          9                        THE WITNESS:  I don't have it
         10                at this time.
         11            Q     Explain to the Hearing Officer what
         12    attempts may have been made to corroborate
         13    Mr. Varga's statements to you.
         14            A     These meetings were surveilled by
         15    Squad C5, is a task force out of 26 Federal Plaza,
         16    New York.
         17                        THE HEARING OFFICER:  Federal
         18                task force.
         19                        THE WITNESS:  They
         20                specifically talked with the Genovese
         21                crime family.  My understanding is
         22                they have surveilled these meetings on
         23                about five occasions and a
         24                surveillance report and some
         25                surveillance photos exist.  We have



                                                                   277
          1                           Limberg
          2                made requests for those.
          3            Q     Did Mr. Varga tell you or Detective
          4    Varga tell you how long these meetings lasted
          5    approximately?
          6            A     I think approximately one hour.
          7            Q     Did he have any information
          8    regarding Mr. Vergallito's vehicle?
          9            A     Yes.  He remembered that
         10    Mr. Vergallito would normally arrive at these
         11    meetings in a car that was registered to White
         12    Rose Limo.
         13                        MR. LEDER:  Could you repeat
         14                that?
         15            A     White Rose Limousine, a company that
         16    the registration was under.
         17            Q     If you could for the Hearing Officer
         18    explain Mr. Varga's background.  What you know of
         19    him.
         20            A     I have known Detective Varga for
         21    about ten years.  I guess I first met him when he
         22    was assigned to the Genovese squad and worked with
         23    the Genovese family.
         24                  He was also tasked with gathering
         25    and documenting just basic intelligence on the



                                                                   278
          1                           Limberg
          2    Genovese family when he was assigned to the
          3    Genovese squad.
          4            Q     What is the name of that squad?
          5            A     C5.
          6                  In the last year he has left the FBI
          7    Federal task force.  He is now assigned to the
          8    investigation analysis section of the Organized
          9    Crime Investigation Division for the New York City
         10    Police Department.  The sole purpose he is the
         11    head analyst for organized crime matters.
         12            Q     Did Detective Varga eyewitness the
         13    meetings that you just described?
         14            A     I am not sure how many.  I know he
         15    was personally there.  He observed some of the
         16    meetings.  I am not sure he was there every time
         17    the meetings were covered.
         18            Q     How does he know this was
         19    Mr. Vergallito?
         20            A     Specifically I don't -- I can't say.
         21    I know that there was no hesitation that he would
         22    be Mr. Vergallito.  Immediately my guess is
         23    through informative information or other
         24    surveillances concerning Mr. Vergallito.  I can't
         25    say for sure.



                                                                   279
          1                           Limberg
          2            Q     Based on your background is there
          3    any significance to the fact that when an
          4    individual would meet with an individual like
          5    Dominick Cirillo?
          6            A     Absolutely.  Organized crime, La
          7    Cosa Nostra, especially the New York families go
          8    to great lengths to insulate the administration of
          9    the family.
         10                  My history of working organized
         11    crime cases or cases involving Genovese crime
         12    family they are one of very, very strict with
         13    security involving the administration.  As an
         14    example, specifically going back years ago when
         15    Mr. Vincent Gigante whose nickname was the Chin
         16    was the boss of Genovese family, no one was ever
         17    allowed to say Vincent or the Chin, to say his
         18    name.  He would only be referred to by pointing to
         19    his chin.
         20                  They went to great lengths to keep
         21    the administration arm's length from everybody
         22    excepting for the higher-ups of the family.  So
         23    that it was only on very rare occasions, generally
         24    very important reasons for the boss of the family
         25    to meet with people who were not boss, the



                                                                   280
          1                           Limberg
          2    consigliere or trusted capos.
          3            Q     What is the significance to you of
          4    this meeting that Mr. Varga's witnessed?
          5                        MR. LEDER:  Let me object.
          6                They met with them and now we are
          7                getting with why they met with him.  I
          8                am not sure no matter what this
          9                witness says in response to that it is
         10                probative of anything and I assume
         11                what he is going to say is that there
         12                was some business dealings being
         13                discussed.
         14                        He is not even telling us that
         15                he was there to see the surveillance,
         16                plus he is not telling us that Varga
         17                told him what they are talking about.
         18                What was the significance of the
         19                meeting, what were they talking about.
         20                        THE HEARING OFFICER:  I don't
         21                think so.  I am well aware in the
         22                world of organized crime there is no
         23                such thing as social events with
         24                outsiders.  The proof is did he meet
         25                with him and was he with him for a



                                                                   281
          1                           Limberg
          2                length of time.  That is sufficient.
          3                I don't need to know from him what he
          4                thinks they talked about.
          5                        MR. SLEVIN:  And counsel is
          6                anticipating testimony that wasn't
          7                going to come and is using the context
          8                of a supposedly evidentiary argument
          9                to make closing argument.
         10                        What we are trying to elicit
         11                the significance of meeting with the
         12                boss of the Genovese family, not what
         13                was discussed.
         14                        THE HEARING OFFICER:  I want
         15                to know who was there.  I still don't
         16                know.
         17                        August Vergallito; right?
         18                        THE WITNESS:  Yes.
         19                        THE HEARING OFFICER:  Peter
         20                Rizzo?
         21                        THE WITNESS:  Yes.
         22                        THE HEARING OFFICER:  Who
         23                else?
         24                        THE WITNESS:  An acting capo
         25                by the name of Pepe LaScala.



                                                                   282
          1                           Limberg
          2                        THE HEARING OFFICER:  Who
          3                else?
          4                        THE WITNESS:  Dominick
          5                Cirillo, also known as Quiet Dom.
          6                        THE HEARING OFFICER:  Those
          7                are the four individuals.  Based upon
          8                your information and be specific if
          9                you know this, how many times did they
         10                meet?
         11                        THE WITNESS:  I believe that
         12                the meetings were surveilled at least
         13                on five occasions.  Detective Varga
         14                cannot recall specifically how many
         15                more times or how long they were going
         16                on before I guess they realized --
         17                        THE HEARING OFFICER:  Just how
         18                many, approximately.
         19                        THE WITNESS:  I think they
         20                were covered five times.
         21                        THE HEARING OFFICER:  Once a
         22                week?
         23                        THE WITNESS:  The meetings
         24                always occurred on Wednesday afternoon
         25                at 2:00 p.m.



                                                                   283
          1                           Limberg
          2                        THE HEARING OFFICER:  What
          3                period of time are you talking about?
          4                        THE WITNESS:  Circa the Year
          5                2000.  I don't have specifics.
          6                        THE HEARING OFFICER:  Where is
          7                Detective Varga now?
          8                        THE WITNESS:  He is assigned
          9                to Police Headquarters, Organized
         10                Crime Division.
         11                        THE HEARING OFFICER:  This
         12                information, you were still in the
         13                government or the Police Department
         14                when this information came to you?
         15                        THE WITNESS:  No.
         16                        THE HEARING OFFICER:  You were
         17                outside the government working for the
         18                Inspector General?
         19                        THE WITNESS:  Yes.
         20    BY MR. SLEVIN:
         21            Q     When did you have your conversation
         22    with Detective Varga?
         23            A     About a week and a half ago, I
         24    believe.
         25            Q     And he had spoke to you knowing you



                                                                   284
          1                           Limberg
          2    are no longer in the law enforcement?
          3            A     Yes.  Knowing my current position,
          4    yes.
          5                        MR. SLEVIN:  As Mr. Limberg
          6                said, there are efforts being made to
          7                track down information related to the
          8                surveillances.
          9                        THE HEARING OFFICER:  Who made
         10                these?
         11                        MR. SLEVIN:  Information such
         12                as photographs and any kind of reports
         13                that have been made.
         14                        THE HEARING OFFICER:  All
         15                right.  That is sufficient.
         16                        MR. SLEVIN:  That is the
         17                extent of it.
         18                        THE HEARING OFFICER:  You may
         19                ask him some questions.
         20                        MR. LEDER:  Thank you.
         21    CROSS-EXAMINATION
         22    BY MR. LEDER:
         23            Q     Where were you when you spoke to
         24    Detective Varga?
         25            A     I was on the telephone.



                                                                   285
          1                           Limberg
          2            Q     The telephone, okay.
          3                  How did you start, how did you get
          4    to the point of August Vergallito?
          5            A     Specifically I asked whether
          6    Mr. Rizzo -- I asked about Peter Rizzo.
          7            Q     What did he say in response?
          8            A     He says he knows Peter Rizzo very
          9    well and surveilled him a number of times with
         10    Mr. Vergallito and he discussed what I testified
         11    to.  He told me about the meetings.
         12            Q     Immediately it came to his
         13    recollection what happened in 2002?
         14            A     2000.
         15            Q     Four years ago.  Had he indicated
         16    how he knew Peter Rizzo or August Vergallito?
         17            A     From my time back with the task
         18    force I know he had a wide ranging case in the
         19    Genovese family's involvement in the construction
         20    industry.
         21            Q     Was Peter Rizzo ever employed in the
         22    construction industry?
         23            A     I don't know.
         24            Q     Was August Vergallito ever employed
         25    in the construction industry?



                                                                   286
          1                           Limberg
          2            A     Specifically I am not sure.
          3            Q     With regard to the five meetings in
          4    2000, the Hearing Officer asked you if you knew
          5    the spacing in between those meetings.
          6            A     I do not.
          7                        MR. LEDER:  I have nothing
          8                further.
          9                        THE HEARING OFFICER:  When you
         10                spoke to the detective, did he know
         11                that you were really going to utilize
         12                this information in a hearing?
         13                        THE WITNESS:  Yes, he did.
         14                        THE HEARING OFFICER:  Did you
         15                tell him he were going to testify to
         16                what he told you?
         17                        THE WITNESS:  Yes, I did.
         18                        THE HEARING OFFICER:  That is
         19                fine.  Thank you.
         20                        Take that out and put it in a
         21                separate booklet.
         22                        (End of sealed portion.)
         23
         24
         25


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