Transcript of Trusteeship Hearing for laborers Local 734 on December 07, 2004


                                                                   867
          1
          2    OFFICE OF THE GENERAL EXECUTIVE BOARD ATTORNEY
          3    LABORERS' INTERNATIONAL UNION OF NORTH AMERICA
               - - - - - - - - - - - - - - - - - - - - -x
          4
          5              In the Matter of
          6
          7               TRUSTEESHIP PROCEEDINGS
          8               LOCAL 734
          9
         10    - - - - - - - - - - - - - - - - - - - - -x
         11
         12
         13                        December 7, 2004
                                   10:30 o'clock a.m.
         14
         15                        Hilton Gateway
                                   Newark, New Jersey
         16
         17
         18    B E F O R E:
         19              PETER F. VAIRA,
         20                        Independent Hearing Officer.
         21
         22
         23
         24
         25


                                                                   868
          1
          2    A P P E A R A N C E S:
          3
                         Messrs. PATTON BOGGS, LLP
          4                    Attorneys for Office of the General
                                 Board Attorney
          5                    2550 M Street, N.W.
                               Washington, D.C.  20037-1350
          6
                         BY:   PATRICK J. SLEVIN, Esq., of Counsel
          7
          8              Messrs. COHEN LEDER MONTALBANO & GROSSMAN
                               Attorneys for Michael Rosado
          9                    1700 Galloping Hill Road
                               Kenilworth, New Jersey  07033
         10
         11              BY:   BRUCE LEDER, Esq., of Counsel
         12
         13
         14
         15
         16
         17
         18
         19                            Tina DeRosa,
                                         Reporter.
         20
         21
         22
         23
         24
         25



                                                                   869
          1                           Rosado
          2                        P R O C E E D I N G S
          3                        THE HEARING OFFICER:  You are
          4                going to put on Mr. Rosado this
          5                morning?
          6                        MR. LEDER:  Yes.
          7    M I C H A E L     R O S A D O,   called as a
          8           witness, having been first duly sworn by
          9           Tina DeRosa, a Notary Public within and for
         10           the State of New Jersey, was examined and
         11           testified as follows:
         12    DIRECT EXAMINATION
         13    BY MR. LEDER:
         14            Q     Mr. Rosado, would you state your
         15    full name for the record, spelling your last name?
         16            A     Michael A. Rosado, R-O-S-A-D-O.
         17            Q     Try to keep your voice up for the
         18    reporter.
         19            A     There is no microphone.
         20                  (A short recess was taken.)
         21            Q     Mr. Rosado, did you graduate high
         22    school?
         23            A     Yes.
         24            Q     And did you attend college?
         25            A     Some.



                                                                   870
          1                           Rosado
          2            Q     How long did you attend college?
          3            A     Approximately two years.
          4            Q     Where did you go to college?
          5            A     Englewood Cliffs College in
          6    Englewood Cliffs, New Jersey.
          7            Q     After your college experience what
          8    did you do?
          9            A     I moved to Puerto Rico for a year
         10    and a half and worked in the hotel down there in
         11    public relations and all, and then I relocated
         12    back here I believe it was 1975 and worked
         13    construction, plumbing supplies and labor.
         14            Q     Is there any point in time when you
         15    got a union job?
         16            A     Yes.
         17            Q     When was that?
         18            A     It was 1985.  '85 I would think is
         19    my entry date.
         20            Q     Were you a member of the labor
         21    union?
         22            A     Yes.
         23            Q     What labor union was that?
         24            A     Local 31, Hudson County.
         25            Q     Local 31 is a local of what



                                                                   871
          1                           Rosado
          2    International?
          3            A     LIUNA.
          4            Q     How long were you employed as a
          5    union laborer?
          6            A     At different times.  I mean from '85
          7    until I started working at Local 734.  I mean six
          8    years, but at different times.
          9                  I mean I was laid off for six months
         10    in the wintertime, you know, different companies
         11    and all that.  That is the way the structure is.
         12    It was not one company for six years.
         13            Q     Right.  Were you ever a shop
         14    steward?
         15            A     Once, yes.  Once or twice.
         16            Q     For approximately how long?
         17            A     As long as the job took, a couple of
         18    months.
         19            Q     Now, after that I believe you
         20    indicated you went to work for Local 734?
         21            A     Yes, I did.
         22            Q     Which entity?
         23            A     Pension and Orphan.
         24            Q     Do you recall what year that was?
         25            A     April '91.



                                                                   872
          1                           Rosado
          2            Q     Do you recall who you interviewed
          3    with?
          4            A     George Wilkins.
          5            Q     Was he employed at that time?
          6            A     Yes.
          7            Q     Who was he employed by?
          8            A     Local 734.
          9            Q     Do you know what his title was?
         10            A     At the time I just knew he was a big
         11    boss, but then subsequently after I got hired I
         12    found out, I found out he was the Business
         13    Manager.
         14            Q     Was he also Trustee to the Welfare
         15    and Pension Funds?
         16            A     I don't recall.  I was a young guy
         17    and it was my first -- I didn't go around asking
         18    who is who.
         19            Q     Did you know what a Trustee to a
         20    Pension Fund was?
         21            A     No.
         22            Q     What was your job at the Welfare
         23    Fund in 1980?
         24            A     Clerical, medical claims, PCS, CPT
         25    codes.  I was training to process the medical



                                                                   873
          1                           Rosado
          2    claims.
          3            Q     What was your salary then?
          4            A     I believe it was like $400 because I
          5    remember compared to what a laborer was making it
          6    was like a salary cut, but it was full-time.
          7            Q     I assume when you say $400 it was
          8    $400 a week?
          9            A     Right.
         10            Q     Did your functions and duties ever
         11    change from being in the medical claim department?
         12            A     Yes.
         13            Q     When did they change?
         14            A     Maybe soon after that.  Maybe within
         15    the same year or approximately a year.  The girl
         16    that was doing the dues and initiation and per
         17    capita reports, she either got fired or quit or
         18    whatever.  But I was asked to train for that job
         19    which I was trained for almost a year.
         20                  It was inputting check-off sheets,
         21    dues, initiation for membership, preparing monthly
         22    upper capita reports.  So I took over the Dues and
         23    Initiation Department.
         24            Q     Do you know who trained you?
         25            A     It might have been Evelyn Bazarnicki



                                                                   874
          1                           Rosado
          2    who was one of the part-timers and there was
          3    another part-timer who at the time was the office
          4    manager.
          5                  No, it wasn't, Evelyn was gone.
          6    There was a battery of other women around me that
          7    were trained.  I remember Evelyn and Fran Cirone.
          8    She was the office manager.
          9            Q     Do you know how Fran spells her last
         10    name?
         11            A     Cirone, C-I-R-O-N-E.
         12            Q     How long did you stay at that
         13    function?
         14            A     Approximately two years.
         15            Q     What job did you then assume?
         16            A     During that time I was doing a lot
         17    of other different things around there, and
         18    assisting Fran Cirone who was the office manager,
         19    with no title.  I was just helping out a lot.
         20                  She had to resign her position in
         21    '93 I think it was or a couple years after I was
         22    hired and I was offered that position and I took
         23    it as office manager and I was still doing the
         24    dues and initiation and per capita and then
         25    running the daily activities of Local 734's office



                                                                   875
          1                           Rosado
          2    and staff.
          3            Q     Approximately how many people was
          4    the office staff?
          5            A     At that time it was considerably
          6    more than now.  I mean I would say approximately
          7    maybe anywhere from 15, maybe even 20.
          8            Q     Those people were clerical types?
          9            A     Yes.  All clerical.
         10            Q     During this period of time were you
         11    involved with the union side of things?
         12            A     Mostly on the translation end.
         13    There was another business rep, Carlos Tate who
         14    spoke Spanish, but mostly in '93 it was mostly
         15    with the office.
         16                  And then like a year or so after
         17    that I started assisting like at nighttime if they
         18    were, if the business reps was going out on an
         19    organizing drive and it was predominantly
         20    Spanish-speaking or whatever, I would go out at
         21    nighttime with them.
         22                  If it was some type of grievance
         23    hearing or whatever, they would ask me to leave
         24    the office for an hour, but I wasn't doing any
         25    business rep duties, just assisting mostly on a



                                                                   876
          1                           Rosado
          2    translation and mostly on --
          3            Q     You are fluent in Spanish?
          4            A     Yes.
          5            Q     Are you fluent in any other
          6    language?
          7            A     English.
          8            Q     That was going to be my next
          9    question.
         10                  How long did you stay as office
         11    manager?
         12            A     About three and a half years.
         13            Q     What was your job then?
         14            A     To the best of my recollection in
         15    late '96 Carlos Tate who again was serving as
         16    President on the Executive Board, I don't know if
         17    he was a Trustee at the time.
         18                  I know he wasn't.  He was a business
         19    rep and also the only Spanish-speaking rep that we
         20    had.  He took a job with the FMCS and he resigned
         21    his duties and at the time, you know, and again I
         22    was pretty much, you know, acclimated with the
         23    whole structure of the office, the dues, the
         24    membership.
         25                  I had a relationship with companies



                                                                   877
          1                           Rosado
          2    because of the dues situation.  I was always on
          3    the phone with, you know, owners and managers and
          4    stuff.
          5                  So the Executive Board again
          6    approved me and asked me, you know, they said you
          7    are fit for this.  We would like you to come on
          8    board as a business rep and also take over the
          9    duties as President or whatever of the Executive
         10    Board.  I think that that was late '96.
         11            Q     How is it that you were appointed
         12    President?
         13            A     Through the Executive Board and then
         14    through -- I know there is a letter out there from
         15    the International because they said they had to
         16    clear it through the International I think.
         17                  There is a letter I think, but that
         18    is my recollection that somebody came down and
         19    interviewed me.  I don't know if it was Mr. Elko,
         20    but I think so.
         21            Q     At the time of your appointment as
         22    President.
         23            A     Yes.
         24            Q     Did you ever run for the position of
         25    President?



                                                                   878
          1                           Rosado
          2            A     Yes.
          3            Q     Do you recall when?
          4            A     That would have been in -- no, I am
          5    sorry, I am counting backwards because 2001 was
          6    the last -- three years -- that would have been
          7    May of '98.
          8            Q     You were elected as President?
          9            A     Yes.
         10            Q     As President did you have any other
         11    responsibilities besides being President of the
         12    union?
         13            A     Well, really the way it was I was a
         14    business rep with the President's title.
         15            Q     What did a business rep do in --
         16    well, what were a business rep's duties in 1998
         17    and even in 2000, is it --
         18            A     I still do the same.
         19            Q     What does business rep do?
         20            A     We are out there servicing our shops
         21    that are appointed to us.  Mandatory on a monthly
         22    basis, if not at one time we were doing it twice a
         23    month especially with troublesome shops, we
         24    handled the grievances and more importantly than
         25    anything the collective bargaining agreements.



                                                                   879
          1                           Rosado
          2                  We negotiate the collective
          3    bargaining agreements and basically maintain a one
          4    on one relationship with the membership,
          5    especially shop stewards.
          6            Q     You said that it was mandatory once
          7    a month and at a time it was twice a month?
          8            A     Yes.  We have what we call, this
          9    goes way back before me, shop reports.  So in
         10    other words, if I am out in the field, you know,
         11    it's not like I can come in on a staff meeting or
         12    any time and say, well, I went to five shops
         13    today.
         14                  And not only for a sense of
         15    monitoring, you know, because you don't want to
         16    put anybody -- like I am baby-sitting or anything
         17    like that, but as a sense of I am a proponent of
         18    paper trails and documenting everything and I make
         19    sure that everything gets documented as far as you
         20    visit a shop and you ask the shop steward what is
         21    going on, everything is quiet, fine, no problems
         22    or grievances.
         23                  You document the things because if
         24    you have 30 shop, 30 shop stewards, maybe 800
         25    members out there, somebody will hold you to



                                                                   880
          1                           Rosado
          2    something and say I told you the last time you
          3    were here last month.  So I make sure that
          4    everything is documented in that sense.
          5            Q     Since 1996 it has been the procedure
          6    of documenting your monthly meetings?
          7            A     No, before that.
          8            Q     Are those records maintained by the
          9    union?
         10            A     Yes.
         11            Q     Are those documents maintained by
         12    the union?
         13            A     Yes.
         14            Q     And are they kept at the union
         15    office?
         16            A     Yes.
         17            Q     Returning to your election in 1998,
         18    did you stay as President?
         19            A     Until the end of the year.
         20            Q     Until the end of 1998?
         21            A     Yes.
         22            Q     What happened in the end of 1998?
         23            A     The Business Manager at the time was
         24    Dan Castiglione, I believe it was November,
         25    December of 1998 was going through some personal



                                                                   881
          1                           Rosado
          2    problems and which subsequently resulted in his
          3    resigning or I believe at first he took a leave
          4    for some time or whatever until some type of
          5    investigation that was going on to clear things
          6    up.
          7                  And he resigned his position and
          8    again it was put in my lap by the Executive Board
          9    to come on board as Business Manager which if I am
         10    not mistaken was January '99.
         11            Q     Is the Business Manager also the
         12    business rep?
         13            A     Yes.  I don't know what other -- I
         14    know of other Business Managers that are in that
         15    function are at my place, yes.
         16            Q     What was different about the
         17    Business Manager's position versus the
         18    President's?
         19            A     Again like any time that I took a
         20    position I would open up, you know, what I call
         21    the manual or the bible and that would be the
         22    constitution in this capacity anyway and, you
         23    know, till this day I don't know verbatim, but I
         24    know the Business Manager oversees the day-to-day
         25    operations of the local, the field reps, appoints



                                                                   882
          1                           Rosado
          2    shop stewards, amongst other things.  Sits on the
          3    Executive Board of course and is the automatic
          4    delegate to the convention.  It is just different
          5    aspects of it.
          6            Q     Did the International have to
          7    approve your appointment as a Business Manager?
          8            A     Yes, I believe so, especially in
          9    this situation here.
         10            Q     Is the Business Manager an elected
         11    position?
         12            A     Yes.
         13            Q     Did you stand for election after
         14    November of 1998?
         15            A     2001.
         16            Q     That was for --
         17            A     And 2004.
         18            Q     So it is a three-year term?
         19            A     Yes.
         20            Q     You are reelected again in 2004?
         21            A     Yes.
         22            Q     I want to turn your attention to the
         23    early part of this century, 2000, 2002.  Was the
         24    local experiencing any problems?
         25            A     Yes.



                                                                   883
          1                           Rosado
          2            Q     What were those problems?
          3            A     Well, they were more concerns back
          4    then.  They turned into problems.  First of all,
          5    prior -- prior to me becoming a Business Manager
          6    my predecessor or whatever, the local and I want
          7    to use the words that were used yesterday, it's
          8    sort of like autonomous the local.  It's basically
          9    has a lot of industrial contracts, a lot of
         10    residential cleaning.
         11                  It is not your normal trades local.
         12    We were like autonomous in the background with
         13    being involved with the regional, the
         14    International in any aspect.
         15                  And when I came on as Business
         16    Manager I found out about political CAPS meetings.
         17    I found a lot about conferences.  We really -- my
         18    predecessor never went to any of these and never
         19    got involved and I wanted to get the local more
         20    involved with the International.
         21                  And I was told the way to do that
         22    would be through the regional office.  So I
         23    started attending some conferences and gathering
         24    up some information and the first time I ever
         25    heard words like market share, increasing market



                                                                   884
          1                           Rosado
          2    share was our General President and all that.
          3                  You know, I was just really
          4    interested and I in hindsight and still to this
          5    day it's a local.  You can organize anybody.  It's
          6    a catch-all local in our eyes.  You grab in to
          7    increase membership.  In my eyes I would sit there
          8    and say we could do a lot in here as far as
          9    increasing membership.  So I had some insight on
         10    that.
         11                  Around 2000, 2001 I was the business
         12    rep handling the Jersey City area which they call
         13    that strip right there like Gold Coast.  We have
         14    always done our own organizing.  You take your
         15    suit jacket off at night and put a windbreaker on
         16    and chase these little buses and organize.
         17            Q     What do you mean little buses?
         18            A     They transport people from locations
         19    like, you know, on gitneys or whatever.  And you
         20    see them on the highway a lot now.  They transport
         21    workers from different shops home.
         22                  We would actually ride some of the
         23    buses with fliers and stuff like that.  It wasn't
         24    unusual for me to buy a bus driver a coffee and a
         25    sandwich and ask him what time this shift gets out



                                                                   885
          1                           Rosado
          2    and ask if I could ride with him or whatever and
          3    have one of my guys follow me.
          4                  Going back to the Jersey City area,
          5    I always told the reps you know what, if you are
          6    driving, you see a crane in the background, get
          7    off the highway, find out where that crane is
          8    because that is a building going up.
          9                  What we do we clean, we have
         10    cleaning contracts.  So we will do the fine
         11    cleaning.  We will do the cleaning on commercial
         12    or residential.
         13                  I always had this mantra or whatever
         14    follow the crane, follow the crane.  In Jersey
         15    City there were cranes all over the place.  We had
         16    a relationship with the Lefrak organization which
         17    is a big developer out in New York City, and he
         18    was over here doing his thing building and we had
         19    one, two, three, four, five, six buildings with
         20    him with more to come.
         21                  So I think it was the latter part of
         22    2000, maybe beginning 2001 there was a meeting
         23    arranged at the regional office.  Pat was in
         24    attendance.  Pat Byrne.  David Grossman, myself
         25    and Mike Fishman who had, I think he just took



                                                                   886
          1                           Rosado
          2    over as 32BJ President.
          3            Q     Who is 32BJ?
          4            A     They are the SEIU.  We are looked at
          5    as a small 32BJ compared to them.  They are a big
          6    service and maintenance local out of New York City
          7    and traditionally as I just said they were in New
          8    York City.  They never came over here.
          9                  And this guy, I mean he had the
         10    courtesy to come over and meet with me and he told
         11    me straight out, he told me listen, I am going to
         12    come to New Jersey.  I just want to tell you about
         13    we are not going to raid your shops because it's
         14    an Article 20.  We have to respect the AFL-CIO
         15    banner.  The unorganized, we are going to organize
         16    the unorganized.
         17                  He actually asked me if I went to
         18    the racetracks, especially the Meadowlands.  I was
         19    speaking on behalf of myself and I am sure
         20    membership.  I was a little concerned when he said
         21    to me we have a war chest organizing.  Our
         22    resources are in the millions.
         23                  He mentioned like maybe we have
         24    $5 million allocated for organizing and 50
         25    full-time organizers.  So then I am sitting there



                                                                   887
          1                           Rosado
          2    saying to myself I have myself and three other
          3    guys and pocket change in my pocket.  I didn't say
          4    this to him, but I was like, you know, what do I
          5    got.
          6                  It was sort of like David and
          7    Goliath situation.  That is the way I felt.  He
          8    was courteous.  I have a lot of respect for the
          9    guy.  He told me straight out I am coming in here,
         10    so move over.  That stayed with me and I told my
         11    reps, I said listen, you have to be diligent out
         12    there.  Make sure your shops are happy.  Don't get
         13    comfortable and you feel they can't raid you
         14    because they are out there, look around and so
         15    forth and so on.
         16                  So I always had the SEIU in the back
         17    and then on top of that we started getting the
         18    independent -- this independent local, Local 971
         19    started coming in and asking questions around the
         20    Jersey City area.
         21                  At the time I was, experiencing, me
         22    personally as a rep was experiencing a couple of
         23    problems with one member.  I had gotten him his
         24    job back.  There was a lot of internal fighting
         25    between some members and it stemmed back to their



                                                                   888
          1                           Rosado
          2    neighborhoods at home and they were bringing this
          3    back to work.  There was like a lot animosity on
          4    the job and I was trying to mediate some things,
          5    but I know there were one or two guys that went
          6    out talking to this Local 971 which eventually it
          7    got back to me.
          8                  Hey, Mike, some of these guys are
          9    meeting, this guy is buying them beer and meeting
         10    them after work and taking them out for a couple
         11    of beers, so watch.  I was like I can't stop that.
         12                  So the letters started on my end.  I
         13    started, you know, trying to do some what you
         14    might call damage control.  I was trying to spin
         15    things around with some letters.  Don't forget
         16    what you have, your pensions, the collective
         17    bargaining.  You have been with the local maybe at
         18    the time 12 years.  We have a relationship with
         19    the men.
         20                  A couple of them their attitude was
         21    very militant.  It was like screw this.  They
         22    always had an attitude.  One of my biggest fears
         23    is that they are right on the Hudson River and
         24    there is New York right there.  Their attitude was
         25    they get $16 an hour over there.  I would say see



                                                                   889
          1                           Rosado
          2    that body of water over there, the demographics,
          3    everything, everything changes on this side of the
          4    river.  If I can get you $16 I would be the first
          5    one to get you $16.
          6                  So, you know, there was a lot of
          7    militant stuff with that and whose cousin worked
          8    for 32B over there and they sit down for dinner
          9    and it is like well, I open the same door for the
         10    same tenants or I mop the same floors, whatever
         11    and they get more money over there.  But again
         12    they couldn't understand the economics.
         13                  So I went through this for a few
         14    months and I wasn't getting too far.  At the time
         15    I was writing letters I believe it was to
         16    Mr. Byrne, maybe a few more to Mr. Pocino
         17    informing him about the SEIU, keeping him abreast
         18    that I was a little concerned about what was going
         19    on in Jersey City here, sort of like what is our
         20    next move or so forth and so on.
         21            Q     Did you get any assistance through
         22    the regional office?
         23            A     Well, first, can I go back to the
         24    conferences that I said earlier that I was
         25    starting to attend.



                                                                   890
          1                           Rosado
          2                  You know, I don't know if it was
          3    General President, I believe it was General
          4    President O'Sullivan.  At one point, I don't know
          5    where we were, but it was a hotel in a lobby and I
          6    had just heard this really like inspirational
          7    market share speech and all.
          8                  I approached him and told him a
          9    little bit about our local.  We have an
         10    opportunity to do stuff with this local.  He says
         11    the protocol, go through your region, go through
         12    your region which again there were some letters
         13    out there to Ray and I had told Ray and met with
         14    Ray about it.
         15                  I had asked Ray, which Ray was
         16    instrumental in setting up a meeting with me and
         17    some of the other Business Managers because if I
         18    am a Business Manager for the trades and I am
         19    putting up a few buildings, residential buildings,
         20    when I am getting ready to pull my guys out of
         21    there, if I put a call in to Mike and give him
         22    some heads up.
         23                  I don't know who is bidding on these
         24    jobs, but if you got one of your contractors or if
         25    I want to come in here and look around.



                                                                   891
          1                           Rosado
          2                  So I figured that would be helpful
          3    and I met with some of the Business Managers to
          4    talk about letting me know when those cranes are
          5    up there, let me know when they are leaving
          6    because I will be right there.
          7                  And also I believe at the time I met
          8    Dave Johnson who was in charge of that organizing
          9    arm of LEROF and in the summer of 2001 I believe
         10    myself, Dave Johnson, Ana Taveras, I had met them
         11    in the Jersey City area and we drove around Jersey
         12    City.
         13                  As a matter of fact, I took some
         14    pictures.  I was showing them the different
         15    buildings telling them of my concept of following
         16    cranes around and telling them what buildings were
         17    ours.  We took a half a day and drove around
         18    Jersey City and all.  Just to get some feedback.
         19    They are organizers.  They are the professionals.
         20                  And Dave brought up some ideas about
         21    the voice training program that they offer to
         22    membership and all.  So I had a little excitement
         23    in me thinking that would help.  Then it was
         24    brought to my attention, I don't know if it was
         25    Pat, Ray or -- it had to be either Pat or Ray or



                                                                   892
          1                           Rosado
          2    maybe even Dave Johnson because he was the
          3    director of LEROF.  But it was brought to my
          4    attention we didn't contribute to LEROF.  So
          5    naturally, which made common sense to me, we
          6    weren't a priority.
          7                  I brought this back to the Executive
          8    Board.  Everything I would bring back to the
          9    Executive Board from conferences and I would tell
         10    the Executive Board I want to go to this
         11    conference, I want us to be more involved with the
         12    International and regional.
         13                  The LEROF thing I brought back to
         14    the Executive Board and told these guys I think we
         15    would get a lot more feedback, a lot more
         16    contribution if we contributed to LEROF which we
         17    subsequently became contributors to the Fund after
         18    some time, but it was something that I thought
         19    would be prudent on our end to do.
         20            Q     After you became contributors did
         21    the assistance from LEROF increase, decrease, stay
         22    the same?
         23            A     No.  Basically it's just been the
         24    same.  You see, we went into supervision.  So now
         25    we are going into two different areas.



                                                                   893
          1                           Rosado
          2                  In the beginning before the
          3    voluntary supervision which was in late 2002 there
          4    was some voice training that was offered out there
          5    for membership.
          6            Q     What is voice training?
          7            A     It's really like a history.  I never
          8    took the course.  I have sat in.  It's like a
          9    four-hour history thing of organizing, the history
         10    of unions.  They get into your family, how unions
         11    work and this and that.  They get into the
         12    industry, your end, whether it's construction or
         13    whatever.
         14                  Actually, the first time I sat in
         15    they gave a construction one and there were shop
         16    stewards, guys like Jerry who works in GTK.  He is
         17    a shop steward at one of our industrial companies
         18    over here in Bayonne and other shop stewards are
         19    sitting there and looking at me, concrete.
         20                  So I brought it up to the guy that
         21    was doing the voice training.  I brought to his
         22    attention you have to change it around.  These
         23    guys have no clue what we are talking about when
         24    you start talking about building and concrete.
         25    You have to make it more focused.



                                                                   894
          1                           Rosado
          2                  Again, you know, they offered it out
          3    and we were trying to get people to come.  Guys
          4    work hard.  They are not high paying members.  So
          5    a lot of it is not unusual for somebody to get out
          6    of work at 3:00 and go to a second job at 3:30.
          7    It is not unusual at all with our membership.
          8            Q     Prior to voluntary supervision did
          9    Mr. Pocino request that the local change
         10    attorneys?
         11            A     That was December of 2001.  Ray
         12    called me down at a meeting.  I met with Ray and
         13    we were talking about this stuff, you know,
         14    organizing, this, that and so forth.
         15                  And he brought to my attention that
         16    Al Kroll's firm, mentioned the name and all and
         17    they work along with other locals.  I believe
         18    maybe even the regional, but other locals and all
         19    and in a sense of being consistent and, you know,
         20    they are a labor law firm.  I had never heard of
         21    them at the time, nor did I ever hear of
         22    Mr. Kroll.
         23                  He said maybe it's time for change.
         24    I would like you to go back to the Executive Board
         25    and talk to them and see if they would consider



                                                                   895
          1                           Rosado
          2    that maybe it would be good to have a change and
          3    stuff.  I said absolutely.  And I went back to the
          4    Executive Board.
          5            Q     What did the Executive Board say?
          6            A     They weren't favoring it due to the
          7    fact that the firm that we had was with us for 25
          8    years or maybe more or maybe less, but for a long
          9    time and they handled the local.
         10                  They handled the Welfare and Pension
         11    and they were doing just their normal good job.
         12    There were no problems or anything.  Plus our shop
         13    stewards, our members, they all knew these guys
         14    from guys that have been in arbitrations.  They
         15    knew the attorneys and all that.  So it was sort
         16    of like if it's not broke don't fix it type thing.
         17                  So the Executive Board said, you
         18    know what, go back to Mr. Pocino and say you maybe
         19    will look at this in another year, but we are
         20    really comfortable with these guys.
         21            Q     During that year prior to
         22    supervision was the local served any
         23    decertification petitions?
         24            A     Yes, the summer of 2002.
         25            Q     Do you recall how many there were?



                                                                   896
          1                           Rosado
          2            A     It was one site, one site.  It is
          3    one complex, the same.  There are four different
          4    buildings in the complex and it's called NC
          5    Housing.
          6            Q     Was that one contract?
          7            A     It was one contract for -- okay.
          8    Let me retract that.  There is two buildings
          9    across the street here and four building here.
         10    These two building here and these buildings it is
         11    the same owner for all six buildings, the same
         12    guys.
         13                  These two building here with one
         14    contract, they started a decertification process
         15    first.  After that was over, a couple of months
         16    later, that is when the process started in all
         17    these four buildings and that would be
         18    approximately 75 men throughout the local.
         19            Q     Seventy-five employees in the six
         20    buildings?
         21            A     Yes.
         22            Q     What was the membership of Local 734
         23    at that time?
         24            A     Approximately 3,000.
         25            Q     Was Local 734 unsuccessful in those



                                                                   897
          1                           Rosado
          2    two decertification --
          3            A     Yes.
          4            Q     So those members went to another
          5    union?
          6            A     Yes.  Can I make a point going back
          7    to 2000, 2001 with this organizing.  I also want
          8    to go on record and say that Local 734 at one
          9    time, maybe '99, 2000, I am not sure was 45, 4,400
         10    strong.
         11                  Our membership, we lost
         12    approximately anywhere from a thousand to 1,200
         13    members due to three to four big companies that
         14    closed down.  Companies that had approximately 300
         15    employees in each one.  Maybe 250 here, 400 there.
         16    Maybe another one had 500.  But due to economics,
         17    outsourcing and moving across the sea we lost
         18    anywhere from a thousand to 1,200 members because
         19    of that.
         20                        THE HEARING OFFICER:  These
         21                jobs that you lost, were these
         22                cleaners?
         23                        THE WITNESS:  Industrial.  One
         24                was United Sweater, a mill.  One was
         25                tapes, VCR tapes.  They packaged



                                                                   898
          1                           Rosado
          2                tapes, GTIS.  HUP Jacobson in Altoona,
          3                Pennsylvania.  All Fasteners,
          4                Industrial.
          5                        Due to economics, due to
          6                closedowns and all for maybe a period
          7                of four years we just experienced a
          8                downsizing.  We lost 1,200 members and
          9                it wasn't due to any type of
         10                decertification or anything like that.
         11                        These guys were 75 as opposed
         12                to 1,200 that did not want to leave.
         13                        THE HEARING OFFICER:  The 75
         14                that you lost in decertification, you
         15                say they did not go non-union, but
         16                that they went to someone else.  Who
         17                did they go to?
         18                        THE WITNESS:  That is why the
         19                raid came in.  971, an independent
         20                local.
         21                        THE HEARING OFFICER:  You have
         22                had some problems with 911, too.
         23                        THE WITNESS:  Us?
         24                        THE HEARING OFFICER:  Yes.
         25                        THE WITNESS:  No.



                                                                   899
          1                           Rosado
          2    BY MR. LEDER:
          3            Q     Where are the members of Local 734
          4    located?
          5            A     The members.
          6            Q     Where do they live?
          7            A     Throughout.  I mean in New York
          8    City.  Throughout the whole State of New Jersey.
          9    Pennsylvania.  I would say that is it.
         10    Pennsylvania, New York, and New Jersey.
         11            Q     Is there a concentration in any one
         12    area or are they spread out all over?
         13            A     Spread out all over.
         14            Q     Did there come a time in 2002 where
         15    Mr. Pocino requested a meeting with you and the
         16    Executive Board?
         17            A     Yes.
         18            Q     Do you recall when that meeting was?
         19            A     That would be late September.  Late
         20    September, early October, 2002.
         21            Q     Where was that meeting held?
         22            A     At the Regional Office.
         23            Q     Did your entire Executive Board show
         24    up?
         25            A     Yes.



                                                                   900
          1                           Rosado
          2            Q     Who else was there?
          3            A     Mr. Pocino and Mr. Byrne.
          4            Q     What happened that day?
          5            A     I received a call from Pat Byrne
          6    earlier in the week requesting for myself to get
          7    the Executive Board to come down.  That Ray wanted
          8    to meet us and it would be at night after office
          9    hours and we had to discuss Local 734 and
         10    organizing and that is all and of course it was
         11    not a problem and we went down.
         12            Q     When you got there who did you meet
         13    with?
         14            A     When we got there I remember Pat
         15    asked me to come inside first with him and Ray and
         16    I did and everybody stayed outside.  And I sat
         17    down and met with Pat and Ray.
         18            Q     What did you discuss?
         19            A     Well, at the time I never heard of
         20    voluntary supervision.  I heard the word
         21    Trusteeship before, but I just never heard or knew
         22    what this was all about.
         23                  At the time Mr. Pocino said to me we
         24    are going to ask you guys to go into voluntary
         25    supervision tonight and I knew it didn't sound



                                                                   901
          1                           Rosado
          2    good.  So I said what is that.  Sort of like the
          3    same way I am doing it now.
          4                  He started to explain to me the way
          5    it is in the constitution and stuff and then I
          6    asked, well, why.  And he referred to the raiding
          7    and some of the problems that we are having in
          8    Jersey City area and he just thought it would be
          9    in the best interest if we do this exactly as it's
         10    written, to protect our jurisdiction and increase
         11    our market share and so forth.
         12            Q     Was there a meeting with the rest of
         13    the members of the Executive Board?
         14            A     Yes.  Right after at the time
         15    Mr. Pocino gave me the courtesy -- he knew I was a
         16    little like in shock at the time.  I didn't know
         17    what was going to happen.
         18                  He said, Mike, do you want to go in
         19    and talk to your guys or do you want me to go in
         20    and tell them.  Do you want to give them a heads
         21    up.  I said let me go in and tell them what we are
         22    facing there.
         23                  I went into the conference room.
         24    The guys were sitting there.  As soon as I walked
         25    in I had a face on and they knew it wasn't



                                                                   902
          1                           Rosado
          2    anything good and I told them what was going on.
          3    Mr. Byrne and Mr. Pocino came in a little while
          4    after.
          5            Q     Was it your understanding that the
          6    Executive Board was voluntarily agreeing to
          7    supervision?
          8            A     That night we were being told about
          9    it.  In fact, Mr. Vaira on the phone, there was a
         10    hearing about this sometime later where we went
         11    into it, yes.  But at that night at that meeting
         12    none of us really knew -- I mean we had a sense of
         13    what it was, but we never been through this
         14    before.  Not me, anyway.
         15            Q     Did you understand that the
         16    Executive Board was going to voluntarily consent
         17    to the supervision?
         18            A     Yes.
         19            Q     Did anyone inquire as to what
         20    happened if they didn't consent?
         21            A     Yes, there was a question asked.  I
         22    believe it was Recording Secretary John Fritzsch
         23    that inquired what happens if we don't go into it
         24    or whatever, and Mr. Pocino says because of the
         25    consequences that are happening in Jersey City and



                                                                   903
          1                           Rosado
          2    what is going on that he would have no alternative
          3    but to ask for Trusteeship.
          4            Q     Was there a discussion about the
          5    differences between Trusteeship and voluntary
          6    supervision?
          7            A     No.  We just knew it wasn't good on
          8    either end.
          9            Q     Was it considered a Trusteeship was
         10    worse than voluntary supervision?
         11            A     Yes.
         12            Q     Did the Executive Board voluntarily
         13    sign off on the supervision?
         14            A     Yes.
         15            Q     There was a hearing?
         16            A     Yes.
         17            Q     By telephone?
         18            A     Yes.
         19            Q     The members of the Executive Board
         20    agreed, though, to voluntarily enter the
         21    supervision?
         22                        MR. SLEVIN:  Is there a
         23                response to that?
         24            A     I am sorry, yes.
         25            Q     Did you get any indication about how



                                                                   904
          1                           Rosado
          2    long the supervision was going to last?
          3            A     No.  I mean when Mr. Pocino was
          4    talking to us about supervision at the meeting I
          5    mean he made reference to the fact that hopefully
          6    we could straighten all this out with the raiding
          7    and organizing and all and who knows, maybe we
          8    could even be out of this, be done with this
          9    within six months or so.  And, if not, you know,
         10    it's an 18-month period.
         11            Q     All right.  At the end of six-month
         12    period under supervision did you have any
         13    discussion with Mr. Pocino and Mr. Byrne?
         14            A     No, I don't recall any.
         15            Q     So you never had a discussion?
         16            A     No.
         17            Q     At the end of 18 months did you have
         18    a discussion?
         19            A     I don't recall, no.  No.
         20            Q     You say you do not recall.  Does
         21    that mean it could have happened?
         22            A     No.  I don't think on my end, no.
         23            Q     You do not recall a conversation as
         24    to why it was extended six months or why it
         25    extended past 18 months?



                                                                   905
          1                           Rosado
          2            A     No.
          3            Q     During the period of the supervision
          4    were you ever advised things were not going right
          5    and therefore it had to be fixed?
          6            A     Yes.
          7            Q     Right after supervision did the
          8    assistance from LEROF change?
          9            A     Yes.  It got turned up a notch.  We
         10    were having these STAR meetings which I think were
         11    monthly right off the bat.  It's an acronym for
         12    something, but had to do with organizing, market
         13    share and all.
         14                  Deputy Supervisor Ana Taveras, she
         15    was I believe chief organizer or whatever.  She
         16    was out there with some organizers Spanish and
         17    English-speaking doing house calling.
         18                  They tried to, right around October
         19    there were maybe two more buildings Tower America
         20    buildings that were still -- by this time three
         21    buildings, if I am not mistaken, three buildings
         22    decertified by this time.
         23                  But right around that time, maybe
         24    September, October when they were around there
         25    were still two more buildings that still hadn't



                                                                   906
          1                           Rosado
          2    made the decision and they went out house calling
          3    to the membership and all and had some meetings
          4    and all.  So they got involved.
          5            Q     Were they able to get back the
          6    decertification?
          7            A     No.
          8            Q     That decertification was filed?
          9            A     Yes.
         10            Q     Is that one of two contracts you
         11    spoke about before?
         12            A     Yes.
         13                        THE HEARING OFFICER:  Members,
         14                you are losing members to this SEIU or
         15                the independent?
         16                        THE WITNESS:  The independent.
         17            Q     The same situation you described
         18    before between the two building and four
         19    buildings?
         20            A     Yes.
         21            Q     Were there any decertifications
         22    besides those two?
         23            A     At the time or throughout?
         24            Q     At that time.
         25            A     No.



                                                                   907
          1                           Rosado
          2            Q     Were the representatives of LEROF
          3    excluding Ana Taveras organizing any others?
          4            A     There were some drives put together,
          5    some targets at the STAR meetings.  You had some
          6    overhead projector.
          7                  There is one company called
          8    Lambert's Furniture that I know was organized if I
          9    am not mistaken maybe almost a year ago.  But they
         10    are still not in.  They were organized, the cards
         11    were signed.  They won the election, but we don't
         12    have a contract with them and they currently
         13    aren't members.  They are not paying dues.
         14            Q     Is it unusual in your experience
         15    that it takes 11 months to negotiate a contract?
         16            A     No, not in this instance.  I have
         17    gone through a long period of negotiating a
         18    contract, but with an already established company.
         19            Q     You do not require newly organized
         20    to pay dues prior to the execution of first
         21    contract?
         22            A     No.
         23            Q     Besides the change in the assistance
         24    of LEROF, were there any other changes that were
         25    implemented by the Supervisor?



                                                                   908
          1                           Rosado
          2            A     Changes?
          3            Q     Were there changes in the attorney?
          4            A     Yes.
          5            Q     What happened there?
          6            A     Well, as a result of supervision I
          7    kept getting hammered by my Executive Board and
          8    they were the ones that made the decision a year
          9    earlier and they were all under the same
         10    consensus.  You know, Mike, in hindsight we should
         11    have just switched the attorneys a year ago, maybe
         12    we wouldn't be in this problem today, but that is
         13    just -- that is assumption.  That is an opinion.
         14                  I said listen, it is what it is,
         15    whatever.  What do you guys want to do and I
         16    recommended, I remember at the time I stood up and
         17    told these guys, you know what, whether we did it
         18    then or we do it now, again I have been telling
         19    you guys for the last couple of years I want to in
         20    the vein of being like so autonomous you guys are
         21    always moaning and groaning that nobody ever pays
         22    attention to us, this, that.
         23                  I wanted to get us more involved
         24    with the regional, with the International on that
         25    level.  I wanted a relationship.  My predecessor



                                                                   909
          1                           Rosado
          2    never had anything like that.  Again nothing
          3    against him but he was never involved.
          4                        THE HEARING OFFICER:  What was
          5                objection to the old law firm?
          6                        THE WITNESS:  What was the
          7                objection?
          8                        THE HEARING OFFICER:  Why did
          9                you want to change?
         10                        THE WITNESS:  We didn't want
         11                to change.  I don't know.
         12            A     So anyway I asked the guys what do
         13    you want to do here and they followed my lead.
         14    They said go talk to Ray and get it done and I
         15    did.
         16            Q     When you are talking about the guys,
         17    you are talking about the Executive Board?
         18            A     The Executive Board.
         19            Q     They are the ones that felt they
         20    should have switched attorneys back when it was
         21    first asked?
         22            A     Now they felt that way, not then.
         23    It was hindsight.
         24            Q     Did you go to Ray and tell him you
         25    were going to change attorneys?



                                                                   910
          1                           Rosado
          2            A     Yes.
          3            Q     And the attorney was Al Kroll?
          4            A     Lynch Martin.
          5            Q     Lynch Martin was the name of the law
          6    firm?
          7            A     Yes.
          8            Q     Was Al Kroll associated with that
          9    law firm?
         10            A     I believe so, yes.
         11            Q     That was when?
         12            A     Right after supervision, so it would
         13    have to be late 2002.
         14            Q     Did Al Kroll become associated with
         15    the Pension and Welfare function?
         16            A     Lynch Martin did.
         17            Q     Was Al Kroll a member of that firm?
         18            A     I believe so, yes.
         19            Q     Do you know when that occurred?
         20            A     That would have been in 2003.  I
         21    don't know if it was maybe the spring of 2003 by
         22    some type of the association, and then I think at
         23    first the association was on a special counsel
         24    basis or whatever and then maybe eight months
         25    later, sometime later, maybe beginning of 2004 or



                                                                   911
          1                           Rosado
          2    the end of 2003 they came on full-time and the
          3    other law firm was out.
          4            Q     You said full-time.  They did not
          5    work for the Pension and Welfare Funds on a
          6    full-time basis?
          7            A     No.
          8            Q     They were the sole counsel?
          9            A     Yes, for Pension and Welfare.
         10            Q     Why was there a switch to Lynch
         11    Martin as the attorneys for the Pension and
         12    Welfare Fund?
         13            A     Well, first of all, it was also
         14    recommended to me, once they came on to the local
         15    it was recommended to me by Mr. Pocino and
         16    Mr. Heineman, at the time Ray Heineman was the
         17    attorney and whether you want to call it solicited
         18    or whatever, he spoke to me and said we could also
         19    work on, you know, your Pension and Welfare.
         20                  I said that is another hat.  It is
         21    not this hat.  I will bring it to their attention
         22    and so forth, and then Ray Pocino had also
         23    mentioned it to me you might want to talk to your
         24    Trustees about taking them on.
         25            Q     Did you follow that recommendation



                                                                   912
          1                           Rosado
          2    of Mr. Pocino?
          3            A     Yes, absolutely.
          4            Q     Did you recommend them, did you
          5    recommend the law firm to take on the
          6    responsibilities for the Pension and Welfare
          7    Funds?
          8            A     Yes.
          9            Q     Was that approved by the Trustees?
         10            A     Yes.
         11            Q     From the beginning of supervision in
         12    October of 2002, how many business representatives
         13    were there besides yourself?
         14            A     Four including myself.
         15            Q     What were the names of the other
         16    three individuals?
         17            A     Myself.  This is 2002?
         18            Q     Yes.
         19            A     Myself, Tim Fritzsch, Joe
         20    Gambardella, Frank Pernice, and at the time Peter
         21    Rizzo who had been a business rep throughout the
         22    '90's was more involved in the Pension and Welfare
         23    and with Pension investigations and other Pension
         24    and Welfare duties.  He was handling maybe like
         25    all of five shops by that time I believe.



                                                                   913
          1                           Rosado
          2            Q     Okay.
          3            A     It was Joey, Timmy, myself, and
          4    Frank Pernice.
          5            Q     At the beginning of the supervision
          6    did the Supervisor or his representatives indicate
          7    to you there should be a change in any of the
          8    Business Agents in 2002?
          9            A     Not at that time, no.
         10            Q     Did they implement changes regarding
         11    personnel, but non-business representatives?
         12            A     Yes.  But that was 2003 as a result
         13    of survey that was sent out.
         14            Q     Who was running the day-to-day
         15    operation of the union under supervision in
         16    October of 2002?
         17            A     In October of 2002?
         18            Q     Yes.
         19            A     I was.  Under Pat and Ana.
         20            Q     Pat Byrne?
         21            A     Pat Byrne and Ana Taveras.
         22            Q     Did you still conduct Executive
         23    Board meetings?
         24            A     Yes.
         25            Q     Did Deputy Supervisor attend to any



                                                                   914
          1                           Rosado
          2    of those meetings?
          3            A     Ana Taveras came to a few in the
          4    beginning.
          5            Q     Did she make any recommendations for
          6    changes that should be implemented?
          7            A     Yes.  At staff meetings, not at
          8    Executive Board meetings, sure.
          9            Q     Did you still conduct general
         10    membership meetings?
         11            A     Yes.
         12            Q     Did the Supervisor or Deputy
         13    Supervisor attend any of these Board meetings?
         14            A     Ana Taveras was there a few times.
         15            Q     Did there come a time when
         16    suggestions or recommendations were made to change
         17    Business Agents?
         18            A     Yes.
         19            Q     Do you recall when that happened?
         20            A     Probably right after.  There was a
         21    survey that was sent out right after we started
         22    the supervision process, an anonymous survey to
         23    membership.  We had no input into it, no part of
         24    it.
         25                  I believe Pat Byrne and Ana Taveras



                                                                   915
          1                           Rosado
          2    were doing it and it was, you know, general survey
          3    questions on membership like are you happy with
          4    your service, tell us what you feel about the
          5    union, your agent, what don't you like.
          6                  They were general good questions, a
          7    survey and all and it was sent out anonymously
          8    with confidentiality and stuff.
          9                  You could either have a choice -- I
         10    believe you had a choice to either sign or not
         11    sign it, but at the time I think it was spring of
         12    2003 and we had a meeting.  Pat Byrne brought to
         13    our attention that the survey results were back
         14    and at the time he brought a graph which was pie
         15    type graph and showed like good, bad, indifferent,
         16    whatever.
         17                  And I believe at the time maybe our
         18    membership was anywhere in the range of 3,000 and
         19    if I am not mistaken approximately 325, right
         20    around there came back and out of 325 maybe 120 or
         21    125 were unfavorable.
         22                  So when we had the meeting I
         23    remember Pat said to me we have problems.  I was
         24    like what is wrong.  Your membership is unhappy.
         25                  I was like, you know -- when I heard



                                                                   916
          1                           Rosado
          2    the numbers I was like there is 125 unhappy.  Out
          3    of the 125 unfavorable I believe the majority of
          4    them had to do with medical claim forms not
          5    getting processed on time or my bill is not being
          6    paid, and of course the usual some of us getting
          7    slammed which is natural.
          8                  You know, like somebody has a
          9    grievance you didn't do the right thing in their
         10    eyes, you didn't resolve it the way they wanted
         11    to, so naturally.
         12                  But my point being the numbers when
         13    I looked at it, I was like trying to do the pie in
         14    my mind and it just showed 325 here.  So when it
         15    was broken down it was like 125 looked big in my
         16    mind.  I am doing a pie of 3,000 members and the
         17    slice of pie that came back was this big and out
         18    of that the slice was this.
         19                  The way I looked at it, we have
         20    always had membership problems.  We have them
         21    today.  That is the name of the game with this.  I
         22    mean you have 105 different collective bargaining
         23    agreements, 3,000 different members.  It is
         24    diversified throughout.
         25                  So anyway, naturally we wanted to



                                                                   917
          1                           Rosado
          2    address the unfavorable situation and the
          3    so-called problems that we were having and I don't
          4    know if it was at this meeting, but I know another
          5    time meeting in his office and he brought to my
          6    attention that Frank got slammed in the survey.
          7            Q     Who is Frank?
          8            A     Well, it was Frank Pernice, but
          9    those were the words.  I said what happened.  He
         10    said, well, they were unfavorable, everybody was
         11    unfavorable on his end and he got slammed with
         12    some of the members and stuff.
         13            Q     You did not see any of the members'
         14    responses?
         15            A     No.
         16            Q     You just saw the report?
         17            A     Yes.
         18            Q     What the responses were?
         19            A     Yes.
         20            Q     What happened with Frank Pernice?
         21            A     Well, I think it was like I said
         22    spring, early summer.  Frank, I don't know what
         23    his age was at the time, whether he was 64 or he
         24    was 65 already.
         25                  Pat had asked me, said he is close



                                                                   918
          1                           Rosado
          2    to retirement, maybe he should look into putting
          3    his papers in or why don't you check with, I don't
          4    know if he said Fritzsch or whatever or the
          5    Trustees, but why don't you check and see because
          6    Frank used to work for the Funds at one time.
          7                  Why don't you check with the Funds
          8    and see if maybe he can go back and work with the
          9    Funds, take a job with the Funds until he retires
         10    because he was getting close and I think Frank had
         11    mentioned sooner or later he would put his papers
         12    in.
         13            Q     What did you do with that
         14    suggestion?
         15            A     Well, Frank being one of my guys,
         16    the first person I talked to was Frank.  I didn't
         17    talk to the Executive Board Trustees, John
         18    Fritzsch or anybody.  I wanted to give him the
         19    courtesy of saying, Frank, we have to talk.
         20            Q     What did Frank say?
         21            A     He wasn't happy with the situation.
         22    He especially wasn't happy with the choices.
         23    Frank is a proud guy.  I have known him for a long
         24    time.
         25                  I met Frank in the labor unions in



                                                                   919
          1                           Rosado
          2    Local 31 at one time and it was more like Frank
          3    was more preoccupied hearing the words, you know,
          4    the membership slammed you.  After that I said we
          5    have to get down to business here.  How do you
          6    feel about this and all.
          7            Q     Did he indicate a willingness to
          8    retire?
          9            A     That was like back and forth for a
         10    couple of weeks.  Yes, I am.  No, I am not.  F
         11    this, I am out of here, and then the next day, you
         12    know what, I think I will wait a week or two or
         13    whatever.
         14                  And then to the best of my
         15    recollection the thing about going to work for the
         16    Funds was still looming in the air.  I had thrown
         17    that option out at both him and John at the same
         18    time.
         19            Q     What happened with the Welfare and
         20    Pension position?
         21            A     Well, subsequently he resigned and
         22    he went to work for Pension and Welfare.  I
         23    believe in the capacity as the Pension
         24    Investigator and other odd jobs with Welfare,
         25    handing out educational stuff or Welfare material.



                                                                   920
          1                           Rosado
          2            Q     Did that create a vacancy in the
          3    ranks of the business reps?
          4            A     Yes, it did.
          5            Q     Was that position filled?
          6            A     Yes.
          7            Q     Who hired that business
          8    representative?
          9            A     I did.  The Executive Board and
         10    myself.
         11            Q     Well, who was hired?
         12            A     Rhina Molina.
         13            Q     How did you find Rhina Molina?
         14            A     Rhina Molina was an organizer.  I
         15    believe her title was organizer with LEROF.
         16            Q     Who recommended her to you?
         17            A     That would have been Pat Byrne.
         18            Q     Was anyone else considered?
         19            A     Not on that side, on my side, and
         20    the Executive Board said yes because
         21    traditionally, historically we have always -- any
         22    time like this I have always have shop stewards,
         23    guys that work on contracts that are really
         24    like -- because we have a tough time having people
         25    get involved, but there are guys out there, a



                                                                   921
          1                           Rosado
          2    couple of them were here this past hearing,
          3    yesterday and the other time.
          4                  One guy in particular, Bobby Perez
          5    was always saying to me, Mike, if there is ever an
          6    opening I know the scope of union, I have been
          7    around here for 20 years, I have been a shop
          8    steward 20 years.
          9                  I have been on numerous contract
         10    negotiations and he has even voluntarily helped
         11    out on organizing drives in the past in the
         12    translation end of it because he speaks Spanish
         13    and all.
         14                  I had brought that, I believe I even
         15    mentioned it to Pat.
         16            Q     What did Pat say about Bobby Perez
         17    versus Rhina Molina?
         18            A     It wasn't going to work.  I don't
         19    know what he said directly.  It wasn't yes.
         20            Q     Why was Rhina Molina hired?
         21            A     I never asked.  I just did what I
         22    was instructed.
         23            Q     You were instructed by whom?
         24            A     Pat Byrne.
         25            Q     You hired Rhina Molina?



                                                                   922
          1                           Rosado
          2            A     Yes.
          3            Q     Did you hire anybody else?
          4            A     No.  In fact, we had a full-time
          5    secretary at the time that was not working out and
          6    we had budget problems, concerns, and still to
          7    this day and we thought it would be in the best
          8    interest of eliminating her job.
          9            Q     So her job was eliminated?
         10            A     The secretary's job, yes.
         11                  And I want to add it was the work,
         12    the secretary's work was delegated over to Barbara
         13    Brown who is the office manager who would have and
         14    has in the past trained anybody that comes in.  So
         15    she knows everything on our end.
         16                  So I had suggested to Pat why don't
         17    we pay Barbara some type of weekly stipend to do
         18    some of our work and all.  I think it was prudent
         19    and a good idea.
         20            Q     How often did you see Pat Byrne at
         21    the local?
         22            A     Periodically.
         23            Q     Were there any regularly scheduled
         24    meetings?
         25            A     Staff meetings on Monday.  Well,



                                                                   923
          1                           Rosado
          2    they changed.  Staff meetings used to be -- they
          3    changed several times, so let me think.
          4                  I believe at one time they were on a
          5    Wednesday at 4:00 o'clock down at the Regional
          6    Office.  So we would see Pat there unless he had
          7    something else and maybe Ana would take over that
          8    day.
          9                  Then at other times they have been
         10    at the local at different dates also.  Maybe
         11    Wednesday at 9:00 or whatever.  Currently right
         12    now they are Mondays at 9:00 a.m.
         13            Q     Were there weekly staff meetings?
         14            A     Weekly staff meetings, yes, there
         15    were weekly staff meetings.
         16            Q     Did Pat Byrne attend every one of
         17    them?
         18            A     Not every one.
         19            Q     A majority of them?
         20            A     I would say enough of them, sure.
         21            Q     Did Ana Taveras attend every one of
         22    them?
         23            A     Not every one.
         24            Q     Did she attend a majority?
         25            A     Yes, a majority.



                                                                   924
          1                           Rosado
          2            Q     At those weekly staff meetings did
          3    Pat Byrne or Ms. Taveras make suggestions?
          4            A     Sure.
          5            Q     Were those implemented?
          6            A     Absolutely.
          7            Q     Did you ever get any indication when
          8    that the Executive Board was failing to follow the
          9    advice of Pat Byrne or Ana Taveras?
         10            A     Regarding?
         11            Q     Anything going on with the union.
         12            A     No.
         13            Q     Did the local have to pay Pat
         14    Byrne's salary?
         15            A     No.
         16            Q     Did it have to pay Ana Taveras'
         17    salary?
         18            A     No.
         19            Q     Now, are you aware if the
         20    International has a policy regarding auditing
         21    local unions?
         22            A     Yes.
         23            Q     Do you know what that policy is?
         24            A     I don't know what the policy is per
         25    se, but I do know that the International auditor,



                                                                   925
          1                           Rosado
          2    you know, made frequent visits to the local.
          3            Q     Can you tell me when he made those
          4    visits?
          5            A     Well, the International auditor
          6    would be John Conneley from my experience since I
          7    have been there, and I would say in my capacity as
          8    Business Manager -- let's go back.  My capacity as
          9    coming on the Executive Board in '96 to current I
         10    have had to see John Conneley there at least a
         11    half dozen times.
         12            Q     So from 1996 to 2004 he has been in
         13    the unit six times?
         14            A     I don't know if that was the exact
         15    number.  I would say that is the ballpark, if not
         16    annually.
         17            Q     Are you aware what he looked at?
         18            A     Books.
         19            Q     Books and records of the local?
         20            A     Yes, of the local union and made
         21    recommendations.
         22            Q     Were his recommendations
         23    implemented?
         24            A     Sure.  Variances.
         25            Q     Did he ever tell you that there was



                                                                   926
          1                           Rosado
          2    something wrong?
          3            A     Not wrong, recommendations.
          4    Throughout at various times he would tell us
          5    recommendations that you should be doing this and
          6    that.
          7                  You need to write the International
          8    for a variance for this.  You need to back
          9    yourself up with this and all, but not in the
         10    words as you are doing something wrong, no, not in
         11    that vein.
         12            Q     Did he review the salaries of all
         13    the employees in the union?
         14            A     Yes.
         15            Q     Did he review the accounting
         16    statements that were prepared by the union's
         17    accountants?
         18            A     Yes.
         19            Q     He found nothing wrong?
         20            A     Not in those words.
         21            Q     Has any other agency came in and
         22    looked at books and records of the union and/or
         23    the Funds?
         24            A     Early on.  I was not on the
         25    Executive Board.  This is during the period where



                                                                   927
          1                           Rosado
          2    I was maybe just hired in '93 -- well, I was maybe
          3    I was office manager or in the dues department,
          4    but during that period I do remember that the
          5    Department of Labor was in, the Department of
          6    Justice, the IRS, even the Post Office for
          7    whatever reason at one time.  I remember a Post
          8    Office Agent or whatever, but, yes, at different
          9    times.
         10                  In fact, I don't know this for a
         11    fact, but I would imagine with all these agencies
         12    coming in I think the Inspector General's office
         13    also.
         14            Q     Do you know if they looked at the
         15    union's books and records?
         16            A     I would imagine.  The only thing I
         17    could say is they looked at everything.
         18            Q     Did they look at the Pension and
         19    Welfare records?
         20            A     Yes.
         21            Q     Do you know if they found any
         22    wrongdoing?
         23            A     I know one of the agencies, I
         24    remember we had all hands on deck.  We were
         25    working day and night making copies.  One of the



                                                                   928
          1                           Rosado
          2    agencies removed every single original out of
          3    there.
          4                  We handed everything over.  They had
          5    trucks and hand trucks and they occupied the
          6    office upstairs.  The Local 734 is in a two-story
          7    office building and we had allocated an office
          8    upstairs, a room for them where they had boxes of
          9    stuff.
         10                  And I know that myself and the
         11    office staff were copying originals, making
         12    duplicates of everything and handing it over.
         13                  So I know that at one point, and
         14    again I don't know what agency it was, I would bet
         15    it would probably be the Department of Justice or
         16    Labor.  They had removed everything out of there.
         17            Q     Do you know if there were any
         18    charges, be it civil or criminal were brought
         19    against any individual who worked for the union?
         20            A     Yes, one individual in the early
         21    '90's.
         22            Q     As a result of this audit?
         23            A     No.  It was not as a result of that.
         24    It was something else.
         25            Q     As a result of the investigation of



                                                                   929
          1                           Rosado
          2    the Department of Labor, the Department of
          3    Justice, the Post Office, the IRS, the Inspector
          4    General, were there any wrongdoings found?
          5            A     No.
          6                        THE HEARING OFFICER:  Could
          7                you tell me the demand for the
          8                examination of the records what year
          9                are you talking about?
         10                        THE WITNESS:  I would say
         11                maybe like '92 to '95.  Around there.
         12                        THE HEARING OFFICER:  I
         13                thought it was more recent.
         14                        THE WITNESS:  No.  '92 to '95.
         15                In fact, I would say early to
         16                mid-'90's.
         17                        THE HEARING OFFICER:  Okay.
         18                        (A short recess was taken at
         19                this time.)
         20                        (The deposition resumed with
         21                all parties present.)
         22    M I C H A E L     R O S A D O,      resumed, and
         23           testified further as follows:
         24    BY MR. LEDER:
         25            Q     Mr. Rosado, besides the Lambert



                                                                   930
          1                           Rosado
          2    Furniture organizing campaign, have there been any
          3    other successful organization of members during
          4    the supervision?
          5            A     No.
          6                  I just want to reiterate Lambert was
          7    not an organizing campaign.  It was a location
          8    they solicited.  It was workers at a plant that
          9    solicited a union and somebody else handed it over
         10    to us and we just -- not us, but the organizers
         11    went there and got the cards signed.
         12                  It wasn't an active campaign, but
         13    outside that venue not to my knowledge, no.
         14            Q     Were the Local 734 Business Agents
         15    able to organize any employees during the
         16    supervision?
         17            A     Yes.  Tim Fritzsch organized a shop
         18    known as Jersey Digital.
         19                  I organized a fine cleaning shop
         20    known as Kyle Construction, approximately seven
         21    full-time members and we have been actively doing
         22    that throughout our supervision.
         23                  We didn't stop doing anything that
         24    we were doing prior to supervision and that is
         25    and, you know, we always file organizing reports



                                                                   931
          1                           Rosado
          2    as backup.
          3                  I was stringent on that, that you
          4    have backup on targets and all, but our focus and
          5    we were instructed by Pat to focus more of the
          6    agents to focus more on small shops.  20 and under
          7    and so and, you know, the organizers or LEROF
          8    would handle big venues which was fine with us
          9    because we were balancing our normal day job
         10    duties.
         11                        THE HEARING OFFICER:  What is
         12                a smallest shop you would go for?
         13                        THE WITNESS:  What would I
         14                consider a small job?
         15                        THE HEARING OFFICER:  Yes.
         16                        THE WITNESS:  Fifteen and
         17                down.
         18                        THE HEARING OFFICER:  What is
         19                your cutoff?
         20                        THE WITNESS:  With us?
         21                        THE HEARING OFFICER:  Yes.
         22                        THE WITNESS:  We have had
         23                shops with three people, two people.
         24            Q     Were you able to organize the shop
         25    you were trying to organize?



                                                                   932
          1                           Rosado
          2            A     Was I able to, yes.
          3            Q     Jersey Digital, was Mr. Fritzsch
          4    able to negotiate a contract with them?
          5            A     Yes.
          6            Q     How many members were there?
          7            A     Seven to ten.  I know the venue is
          8    not a big venue.
          9            Q     I am going to turn your attention to
         10    the issues regarding the Pension and Welfare.
         11                  Did Mr. Pocino come to you
         12    concerning the Trustees on the Pension and
         13    Welfare?
         14            A     In what regard?
         15            Q     About the composition of the
         16    Trustees.
         17            A     Yes.
         18            Q     That was in?
         19            A     December of '03, I believe.
         20            Q     What did Mr. Pocino tell you?
         21            A     You know, I met with Ray throughout
         22    supervision.  I have always met with Ray, several
         23    times at his office just to update him on things
         24    and vice versa and this was not out of the
         25    ordinary.



                                                                   933
          1                           Rosado
          2                  Ray requested I come down to see him
          3    and I did and like I said, I believe this was
          4    December of '03.  We met in his office and we were
          5    talking about supervision, amongst other things,
          6    and the conversation turned toward the addition of
          7    an extra Trustee on both ends, on the employer end
          8    and on the employee end, on the union end.
          9            Q     Did he tell you why he wanted an
         10    additional Trustee?
         11            A     I didn't ask Mr. Pocino.  I was
         12    ready to take instructions and he did give me a
         13    reason and the best of my recollection was that
         14    coming out of supervision sometime in the future,
         15    which would be October of '04, we want to make
         16    sure that everything is running on the up and up
         17    and, you know, again it would be in the best
         18    interest of everybody.
         19            Q     He did not tell you who the
         20    additional Trustee would be?
         21            A     On the union end, Pat Byrne.
         22            Q     Did he tell you who would be the
         23    additional Trustee on the employee end?
         24            A     No.
         25            Q     Was that discussed?



                                                                   934
          1                           Rosado
          2            A     I had some comments on that.
          3    Historically it's always been a difficult spot to
          4    fill.
          5            Q     Why was that?
          6            A     Well, it comes before my time or
          7    maybe the beginning of my time, but I was told
          8    usually nobody wants the responsibility, the
          9    fiduciary responsibility, the time, but I think
         10    that it's more on the responsibility end than
         11    anything.
         12            Q     Besides talking about the additional
         13    Trustees, did any other matters come up?
         14            A     At that time not to my recollection,
         15    no.
         16            Q     Was there discussion about the
         17    operational audit in December of 2003?
         18            A     I don't recall. I don't recall if
         19    there was any mention of the audit.  I don't
         20    recall.
         21            Q     What did you do after your meeting
         22    with Ray concerning the additional Trustees?
         23            A     Well, what I did with everything
         24    else.  It was a request and I brought it back.
         25    You know, that would be the Fund Administrator,



                                                                   935
          1                           Rosado
          2    the Trustees.  I brought it back to everyone and
          3    the Executive Board.
          4            Q     When did you first discuss it with
          5    the Executive Board?
          6            A     That would have been at the
          7    Executive Board meeting of January or possibly, I
          8    am sorry, the Executive Board meeting of December
          9    because I believe we met in early December.
         10                  So it would probably be the
         11    Executive Board meeting of December and with the
         12    Trustees I am sure it was just a phone call.
         13                  Usually anything to do I would
         14    address it with John Fritzsch, the Fund
         15    administrator, and then he would make proper phone
         16    calls or whatever to either Sal Salerno, Lou
         17    Calastro.
         18            Q     What was the Executive Board's
         19    reaction to adding one Employee Trustee and
         20    Employer Trustee?
         21            A     A shrug of the shoulder, okay.
         22            Q     Did you indicate to the Executive
         23    Board that Pat Byrne would be the Trustee?
         24            A     Yes.
         25            Q     Traditionally who has been the Union



                                                                   936
          1                           Rosado
          2    Trustee.  Who has been the Union Trustees?
          3            A     Myself and Joe Gambardella.
          4            Q     Both of you were elected officers?
          5            A     Yes.
          6            Q     Both of you were Business Agents,
          7    business representatives?
          8            A     Yes.
          9            Q     Has that traditionally who have been
         10    the Union Trustees?
         11            A     What I have seen, yes.
         12            Q     Did you get a reaction from the
         13    Board of Trustees concerning the additional
         14    Trustees?
         15            A     Yes.
         16            Q     What was that reaction?
         17            A     Questioning the why of it.  What is
         18    the purpose of this.  You guys have nothing to do
         19    with us type of thing.
         20            Q     Did that discussion take place at a
         21    meeting of the Board of Trustees?
         22            A     Well, I mean, yes, but prior to that
         23    I know I had heard of it from John Fritzsch.
         24            Q     Did you ever speak to Mr. Calastro
         25    or Mr. Salerno about it?



                                                                   937
          1                           Rosado
          2            A     Yes.
          3            Q     What was their reaction?
          4            A     Mike, why do you need this done, and
          5    I said that it's a request from my Regional
          6    Office.
          7            Q     Did you ever discuss it with
          8    Mr. Gambardella?
          9            A     Yes.
         10            Q     What was his reaction?
         11            A     Okay.
         12            Q     Did there come a time in April when
         13    you reported to Mr. Pocino about the resistance to
         14    adding the Trustee on each side?
         15            A     Well, it was brought to my attention
         16    that, I believe there was a Trust Agreement.
         17    There were certain parameters in it, that it would
         18    have to be amended and modified and the easier,
         19    softer way to go about this might be, hey, listen,
         20    why don't you go back and talk to Ray and just see
         21    if Joey will step down and Pat will take his place
         22    and then we will keep it two and two and life goes
         23    on.
         24                        THE HEARING OFFICER:  Who said
         25                that?



                                                                   938
          1                           Rosado
          2                        THE WITNESS:  The Trustees.
          3                        THE HEARING OFFICER:  Who said
          4                take it back to Ray and Gambardella
          5                will step down, was that Calastro?
          6                        THE WITNESS:  That would be
          7                John Fritzsch, Lou Calastro and Sal
          8                Salerno, and I would have to say
          9                myself also.
         10                        THE HEARING OFFICER:  But they
         11                are the management that said that we
         12                don't need this?
         13                        THE WITNESS:  They were
         14                questioning the why.  What is the
         15                reason for this.  You guys, the local
         16                is under supervision.  Were you told
         17                what the reason for this would be.
         18                        And my answer was just as it
         19                was presented to me, just it is in the
         20                best interest of everyone, the local
         21                membership, everyone.
         22                        THE HEARING OFFICER:  You
         23                mentioned Mr. Fritzsch.  That John
         24                Fritzsch, the Administrator of the
         25                Fund and this was,I assume was at some



                                                                   939
          1                           Rosado
          2                meeting.
          3                        THE WITNESS:  Yes.  It was
          4                brought to my attention, again I don't
          5                know whether it was the January
          6                Trustee meeting.  It probably was the
          7                January Trustee meeting.  It was
          8                brought to my attention, Mike, don't
          9                forget the Trust Agreement would have
         10                to be amended or modified and it calls
         11                for just two and two.
         12                        Wouldn't it be simpler and I
         13                even chimed in because I don't know if
         14                it was my idea or whatever, I am not
         15                going to lay claim to that, but I know
         16                I was on board with just getting this
         17                done.  It was like I don't care how we
         18                do it, let's just do it.
         19    BY MR. LEDER:
         20            Q     Did you report that to Mr. Pocino in
         21    April of 2004?
         22            A     I don't know if it was in April of
         23    2004.  I am sure it was -- I don't think I would
         24    wait until April, but I am sure it was sometime
         25    after that.



                                                                   940
          1                           Rosado
          2            Q     What was Mr. Pocino's reaction?
          3            A     It was favorable.
          4            Q     Did there come a point in time when
          5    Lou Calastro indicated that he wanted to meet with
          6    Mr. Pocino?
          7            A     Yes.
          8            Q     Did you convey that to Mr. Pocino?
          9            A     Yes.
         10            Q     Do you know if, in fact, that
         11    occurred?
         12            A     Yes.
         13            Q     Do you recall that meeting was in
         14    May of 2004 on the 26th?
         15            A     Yes.
         16            Q     After that meeting between Ray and
         17    Lou Calastro, did you speak to Mr. Pocino about
         18    what went on in that meeting?
         19            A     No, not in detail.
         20            Q     Did you speak to Mr. Byrne about
         21    what went on in that meeting?
         22            A     No.
         23            Q     Did you speak to Mr. Calastro about
         24    what went on in that meeting?
         25            A     Yes.



                                                                   941
          1                           Rosado
          2            Q     What did Mr. Calastro tell you?
          3            A     I remember Mr. Calastro saying they
          4    met because I was the one that requested they both
          5    get together.  He called me up afterwards, whether
          6    it was the same day or the day after, said I had a
          7    very good meeting, a good lunch.
          8                  Ray is a good guy, an honorable man.
          9    They just talked about their families and talked
         10    about business, first of all.
         11            Q     Did there come a time when you
         12    talked about Pat coming to a meeting?
         13            A     Not during this conversation, no.
         14            Q     Subsequently did Pat indicate that
         15    he was going to come to a meeting?
         16            A     Absolutely.
         17            Q     Do you recall what meeting he was
         18    going to