1

1

2   UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

3

UNITED STATES OF AMERICA,

4

PLAINTIFF,

5

-against-

6

DISTRICT COUNCIL OF NEW YORK CITY AND

7   VICINITY OF THE UNITED BROTHERHOOD OF

CARPENTERS AND JOINERS OF AMERICA, et al.,

8

DEFENDANTS.

9      X

10

11   DATE: November 25, 2003

12   TIME:   10:10 a.m.

13

14

15   DEPOSITION of JOHN P. CORRIGAN, taken by the

16   Independent Investigator, Walter Mack, pursuant to subpoena,

17   held at the office of Doar, Reick and Mack, 217 Broadway, New

18   York, New York 10007, before Daniel Rodriguez, a Notary

19   Public of the State of New York.

20

21

22

23

24

25

BENJAMIN REPORTING   (212)374-1138 DOYLE REPORTING   (212)867-8220

A VERITEXT COMPANY

2

1

2   APPEARANCE S:

3

4   DOAR, REICK & MACK

Attorneys for Independent Investigator

5   217 Broadway

New York, New York 10007

6   BY: WALTER MACK, ESQ.

7

8   DIENST & SERRINS, LLP

Attorneys for Employee

9   233 Broadway - 18th Floor

New York, New York 10279

10   BY: RICHARD A. DIENST, ESQ.

11

12   O'DWYER & BERNSTEIN, LLP

Attorneys for District Council

13   52 Duane Street

New York, New York 10007

14   BY: GARY ROTHMAN, ESQ.

15

16   ALSO PRESENT:

17   DONALD SOBOCIENSKI - Investigator

18   EDWARD SCARVALONE - Assistant United States Attorney

19

*   *   *

20

21

22

23

24

25

BENJAMIN REPORTING   (212)374-1138   DOYLE REPORTING   (212)867-8220

A VERITEXT COMPANY

145

1   John P. Corrigan

2   Q.   Are you familiar with a procedure that sometimes

3   might be known as the special request procedure or the lawful

4   referral procedure, for a contractor to pick carpenters by

5   name or by specific request out of the out-of-work list?

6   A.   There might be a better terminology, like a company

7   man or a union man or a request guy.   That's how we call it.

8   That system is a joke right now.

9   Q.   What about it is a joke?

10   A.   Because you're not giving the guy who doesn't know

11   anybody or the guy who just came to the business a fair

12   opportunity, compared to the guys who know people.   I don't

13   think it's a fair system.

14   If a guy working for a company for years, I don't

15   think he's as loyal to the union as he should be.   I think

16   you need more guys loyal to the union.   I think there's lot

17   of hanky-panky on some of these companies.   It's on the

18   street.   A lot of it has to do with how the list is set.

19   It's not set up for the good of the members.   It's set up for

20   the good of the contractors.

21   My father was there for 35 years.   He died in good

22   standings.   I'm trying to follow his name.   I think you take

23   ten non-business agents, ten non-political facets, you would

24   get some good ideas.

25   Q.   So just so I can have some idea of how commonplace

BENJAMIN REPORTING   (212)374-1138 '   DOYLE REPORTING   (212)667-8220

A VERITEXT COMPANY

146

1   John P. Corrigan.

2   it is, at Seven World Trade you have about 34 carpenters, how

3   many of them, if you know, were referred to the job as a

4   result of specific request by the contractor?

5   A.   There's 20 there that are good young men.   20 guys

6   that are loyal more to the union than they are to the

7   company.   There are 16 probably more loyal to the company.

8   There are 20 guys that are more loyal to the union, I mean

9   that go to union functions, show up at union meetings.   Then

10   the 16 guys who work for the company steady.

11   Q.   These 16 guys, do you know how they got assigned?

12   A.   They put their name on the list.   The company

13   requested them.

14   Q.   How common is that?

15   A.   Common all throughout New York City.   That's the

16   way the system is set up.

17   MR. SCARVALONE:   I have no further questions.

18   MR. MACK:   Let me ask the Chief.

19   MR. SOBOCIENSKI:   Just one question.

20   EXAMINATION BY

21   MR. SOBOCIENSKI:

22   Q.   Before this month, in terms of the ten-hour OSHA

23   training, is it your recollection that you had had a ten-hour

24   OSHA card similar to that 30 that you cannot locate?

25   A..   I was under the assumption that I have it.

BENJAMIN REPORTING   (212)374-1138   DOYLE REPORTING   (212)867-8220

A VERITEXT COMPANY