UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA,

Plaintiff,

-against-

DISTRICT COUNCIL OF NEW YORK CITY AND VICINITY OF THE UNITED BROTHERHOOD OF CARPENTERS AND JOINERS OF AMERICA, et.al.,

Defendants.

Independent Investigator Deposition

90 CIV 5722 (CSH)

x

x

December 10, 2004 4:00 o'clock p.m.

DEPOSITION of GREGORY DUHIG, taken by

the Independent Investigator, Walter Mack, Esq.,

pursuant to letter subpoena, at the offices of Doar, Rieck & Mack, Esqs., 217 Broadway, 7th

Floor, New York, New York 10007-2911, before Stewart Nissenbaum, a Shorthand Reporter and Notary Public of the State of New York.

1   Gregory Duhig   224

2   Q   Well, the time you appeared with

3   me here was, I think, April 6, 2004, and you

4   violated your oath. I just want to make sure

5   I have all of the reasons you made that

6   choice intentionally. One was because when

7   you had told the truth before or provided

8   information, you had been laid off and you

9   felt the company had gone out of business?

   10   A   Yes.

   11   Q   Second is, you didn't want to

   12   lose your job at Boom; why? Why did you feel

   13   that way, if the word got out that you told

   14   me the truth, you felt you would be laid off

   15   at Boom, too?

   16   A   Yes.

   17   Q   Had you asked anybody, when you

   18   received the notice from me to appear, as to

   19   what you should do or how you should do it?

   20   A    No.

   21   Q   The decision not to tell me the

   22   truth was yours and yours alone?

   23   A   Yes.

   24   Q   Was there any other reason, you

   25   know, did it occur to you that, for instance,

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