Laborers for JUSTICEŠ 1997-2006 All
Rights reserved.
Not for republication on the internet without permission.
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
x
UNITED STATES OF AMERICA,
Plaintiff,
-against- 90 CIV 5722
(CSH)
DISTRICT COUNCIL OF NEW YORK CITY
AND VICINITY OF THE UNITED
BROTHERHOOD OF CARPENTERS AND
JOINERS OF AMERICA, et.al.,
Defendants.
x
Independent Investigator Deposition
September 14, 2005
2:25 p.m.
DEPOSITION OF MICHAEL MITCHELL, taken
by Walter Mack, Esq., pursuant to Notice, 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
ORIGINAL York.
TANKOOS REPORTING COMPANY, INC.
305 Madison Avenue 142 Willis Avenue
Suite 449 P.O. BOX 347
New York, N.Y. 10165 Mineola, N.Y. 11501
(212)349-9692 (516)741-5235
1 2
APPEARANCE S:
2
3 DOAR RIECK & MACK, ESQS.
217 Broadway - 7th Floor
4 New York, New York 10007-2911
5 BY: WALTER MACK, ESQ.
6
7 KOEHLER & ISAACS, LLP
Attorneys for Witness
8 61 Broadway - 25th Floor
New York, New York 10006
9 BY: STEVEN ISAACS, ESQ.
10
11
12
13
ALSO PRESENT:
14
Donald Sobocienski
15
16 * *
17
18
19
20
21
22
23
24
25
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2 MR. MACK: On the record.
3 Mr. Mitchell, I want to go over a
4 number of things with you, and I would
5 like you to listen carefully to what I
6 have to say, and then you or Mr. Isaacs
7 will be able to ask any questions you
8 have in mind. I want to bring you
9 up-to-date as to what's going on, and
10 respond to your questions.
11 I know one of the things in your
12 mind is what I am doing, although I'm no
13 longer the Independent Investigator. I
14 want to answer that question. I am no
15 longer the Court-appointed Independent
16 Investigator; that person is Mr. William
17 Callahan. However, I'm operating under
18 his request and the direction of the
19 Court with respect to working through
20 investigations and trying to complete
21 investigations that have begun under my
22 watch. I sent a Notice to you, because
23 I wanted to see you directly and tell
24 you what I'm going to tell you today; I
25 was the Independent Investigator, I had
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1 4
2 the authority to do so, and I'm
3 operating today with Mr. Callahan's
4 authority and request that I proceed on
5 a number of investigations, one of which
6 concerns On Par Construction.
7 Now, the reason that I wanted to
8 talk to you directly, is that when you
9 testified before me back a year ago, in
10 August, I went at considerable length to
11 ask you questions about my concerns, and
12 indicated to you that there was an
13 ongoing investigation, and that if there
14 was anything that you felt needed to be
15 corrected, that you would have the
16 opportunity to come in and provide or
17 correct your testimony. I mentioned
18 that indirectly to Mr. Isaacs several
19 times. I'm quite sure he communicated
20 my ever-increasing skepticism and doubt
21 as to the accuracy of what you told me
22 under oath.
23 I would say within the last four
24 to five months, we have obtained, I
25 don't want to overstate it, but very
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2 direct proof that On Par has failed to
3 pay the Benefit Fund in excess of $10
4 million for the carpenters, and we are
5 going through thousands and thousands of
6 On Par checks, which are paid in cash
7 amounts; in other words, known
Collective Bargaining Agreement amounts,
9 without benefits being paid. And we
10 are, I would say, maybe a quarter of the
11 way through of bringing in those
12 carpenters who were paid in these
13 amounts.
14 On virtually every jobsite in
15 which you were the shop steward, there
16 are witnesses who swear that you carded
17 them, you checked their cards, or
18 facilitated their membership; and yet
19 did not record them on your shop steward
20 reports on every jobsite. That's the
21 evidence that will be submitted to the
22 Court.
23 Basically, what I wanted to say,
24 I want to do this, I want to reach out
25 to you -- let me deal with one reason,
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2 the reason that the District Council is
3 not here is because I have decided that
4 certain witnesses, many witnesses,
5 especially on this On Par investigation,
6 have indicated to me that they do not
7 wish the District Council to be aware of
8 what they are saying, even though I tell
9 them eventually they will hear what they
10 are saying. Whether you want to
11 disclose to them that you were here --
12 have you told anybody that you're here
13 today, Mr. Mitchell?
14 MS. MITCHELL: Have I told
15 anyone --
16 MR. MACK: That you are here
17 answering questions for me today?
18 MR. MITCHELL: Yes.
19 MR. MACK: Whom have you told;
20 anyone at the District Council?
21 MR. MITCHELL: No.
22 MR. MACK: I'm going to follow up
23 with those questions, but the way I have
24 looked at it, and the way a number of
25 people, and I would say I talk to shop
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2 stewards and eventually I will talk to
3 all shop stewards and all of the foremen
4 who are on primarily these On Par
5 jobsites as to which I am focusing my
6 attention at this time. Many of them
7 have not appeared before me before, most
8 of them, I won't say every one, here by
9 counsel, have acknowledged what has
10 happened on the jobsites in which they
11 worked.
12 What I say to them, and I'm going
13 to say it to you, is that I have
14 referred On Par to the U.S. Attorney's
15 Office for criminal investigation. As I
16 say, the numbers that Mr. Sobocienski
17 and I are estimating, recognizing we've
18 only seen perhaps half, two-thirds of
19 the checks for all the various
20 nonpayroll accounts that were being used
21 by On Par, it is going to be in excess
22 of $10 million of defrauding the Benefit
23 Fund, which is a major federal crime, if
24 proven, and carries with it very severe
25 sanctions for Mr. Murray and the various
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2 people associated with On Par.
3 The position I'm taking, and I
4 want to take it with you, you are in a
5 slightly different position, that if the
6 stewards and the foremen on these sites
7 on which these carpenters worked and
8 were paid nonappropriate collective
9 bargaining rates, cooperate and tell me
10 the truth, my referral -- and again I
11 want to reiterate, I'm not a prosecutor
12 here, things would be different if I
13 were a prosecutor. I'm simply a
14 fact-gatherer and a report-writer and a
15 person who makes recommendations. My
16 recommendation will be, for those
17 individuals who cooperate and tell me
18 the truth and acknowledge what happened,
19 and help me write an accurate report
20 about the amount of funds and what
21 happened on the sites, who were the
22 people responsible and how it went on,
23 those people I will not include in my
24 recommendation for criminal prosecution.
25 For those people who lie to me,
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2 don't tell me the truth, or seek to void
3 my ability to find out what the facts
4 are, and those people who engineered or
5 participated directly in permitting this
6 to occur, those people will be included.
7 And the reason I wanted to speak
8 to you directly, is because I went at
9 considerable length when I talked to
10 you, asking you questions to which you
11 were giving me answers, which I now
12 believe to be untrue, and I think I have
13 important, valuable, reliable, credible
14 evidence to that fact; and I think that
15 will only continue. Because basically
16 during the time period of all the On Par
17 jobsites you were at, with possibly one
18 exception, the carpenters working at
19 those sites were paid by check, and
20 those checks are available to me, and
21 those carpenters are coming in, I would
22 say virtually every one of them, and
23 indicating to me who the shop stewards
24 were, conversations they had with them;
25 you are in this category, the fact that
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2 even when they became members, you would
3 check their cards to make sure that
4 their dues were paid, even though they
5 were not on the shop steward reports.
6 In addition, in your situation, I
7 think we talked about this when you
8 testified, it was very clear to me that
9 there were efforts to get you at On Par
10 jobsites, for whatever reasons, I can
11 speculate.
12 So what I am basically doing here
13 is saying, this is your decision, and,
14 you know, maybe the U.S. Attorney, maybe
15 the judge could care less what I have to
16 say and completely discount the evidence
17 that will be coming in in very detailed,
18 accurate fashion.
19 My plea to you is this: That by
20 leaving the record where it sits, and
21 not providing me what in my view is
22 accurate information, you are exposing
23 yourself to criminal prosecution. It is
24 not going to be my decision, that
25 prosecution would be for lying to me
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1 11
2 under oath, and specifically denying
3 that these events occurred; two,
4 obstructing justice, because I went out
5 of my way when I read the testimony, and
6 I read it this afternoon, I said, I need
7 your help, need you to help me get
through this information.
9 Finally, by your taking those
10 steps, which some day a criminal trial
11 jury may have to conclude, and I never
12 predict what a criminal jury would do,
13 you helped Mr. Murray by not cooperating
14 with me, and telling me the truth, by
15 submitting shop steward reports which
16 left carpenters on your sites off the
17 sheets, which resulted in benefits not
18 being paid; you agreed with or permitted
19 On Par Construction to avoid paying
20 benefits for those carpenters on your
21 sites, and therefore, you bear some
22 responsibility for defrauding the
23 Benefit Fund.
24 Whether a prosecutor would agree
25 with that theory or not, my own feeling
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1 12
2 is, having been a prosecutor, that if
3 you act in such a way to permit a fraud,
4 or a person to withhold payments, you
5 have conspired and agreed with that
6 person to permit him to do so, for
7 whatever reason.
8 That .decision will not be made by
9 me. By not helping and by submitting
10 false shop steward reports, you
11 permitted Jim Murray to defraud the
12 Benefit Funds of sums of money, and also
13 fellow union members were not paid the
14 appropriate wage under the Collective
15 Bargaining Agreement.
16 That's the theory, and that
17 theory is based on what is now
18 increasing evidence of documents which
19 are very, very accurate. And human
20 beings who are in a situation say what
21 they did and didn't do. You may say
22 that's a lot of crap. That's fine. You
23 can persist in that view. All I would
24 be able to say is that I did my level
25 best to convince you that you are at
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1 13
2 risk, and ask you to assist me to write
3 an accurate report. You can decide for
4 whatever reason.
5 One of the reasons I didn't
6 invite the District Council today, many,
7 many carpenters and shop steward have
8 said: I want to tell you the truth, but
9 I want to be in some type of
10 relationship directly to the Court. I'm
11 acting an as agent of the Court here,
12 and that's an important thing.
13 So, you had a chance to read your
14 testimony, you have Mr. Isaacs here. I
15 want to make this as clear as I possibly
16 can; and what I'm saying to you, you are
17 in jeopardy, based upon the evidence
18 I've collected and what's there. And
19 what I basically beseech you to do, you
20 know what the truth is, and you know
21 what happened, and you know how it went
22 on, is to ask you to tell me what really
23 happened here; and to do so, I will be
24 able to hold those people primarily
25 responsible.
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2 The person most responsible for
3 this is Jim Murray and the other people
4 at On Par who generated this situation.
5 Those are the people who should face
6 criminal exposure, and they do. There's
7 an ongoing investigation, Mr. Murray has
8 asserted his Fifth Amendment, he has
9 made admissions. He has a very big
10 problem, criminal problem. And so the
11 reason I wanted to see you about this is
12 because I think you have a criminal
13 problem at the moment; because of the
14 evidence that's here. And basically
15 what I'm saying is, at least I know that
16 I will have taken the steps necessary to
17 reach out to you and say, with counsel,
18 that I would like you to assist me in
19 finding out what the facts are. That's
20 basically what's going on here today.
21 What I intend to do is make sure
22 that you understand you have all the
23 same rights you had before. You read
24 your transcript. You have a Fifth
25 Amendment right; you can simply say,
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2 hey, what I said before, I stand by it.
3 And my conscience will be clear that I
4 have done my level best to give you some
5 idea of the risk you face; and you're an
6 intelligent person, and you make your
7 decisions, you live by them.
8 You can take the risk that
9 whatever I have to say is meaningless
10 and a waste of time, and nobody is going
11 the pay any attention to it. I think
12 that would be a big, big risk.
13 Having said all of that, let me
14 first ask you, do you have any questions
15 that you would like to ask me, yourself?
16 MR. MITCHELL: No.
17 MR. MACK: Mr. Isaacs?
18 MR. ISAACS: No; no questions,
19 thank you.
20 MR. MACK: Mr. Sobocienski and
21 I -- I want to ask you -- let me ask you
22 several basic questions. This will be
23 short, or I'm willing to take whatever
24 time is needed to make sure I have an
25 accurate record. It is your choice.
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1 Michael Mitchell 16
2 MICHAEL MITCHELL, the
3 witness herein, being duly sworn by Stewart
4 Nissenbaum, a Notary Public of the State of
5 New York, was examined and testified as
6 follows:
7 EXAMINATION BY
8 MR. MACK:
9 Q Have you had an opportunity to
10 read your transcript when you testified here
11 on August 2, 2004?
12 A Yes.
13 Q Is there anything in that
14 testimony which you believe was or is
15 inaccurate?
16 A No.
17 Q I just want to cover a couple of
18 other areas. Do you swear that the shop
19 steward reports that you have submitted to
20 the District Council, record accurately the
21 names and hours of the carpenters who worked
22 on those jobsites?
23 A To the best of my knowledge.
24 Q As you sit here today, they are
25 accurate shop steward reports?
(212) 349-9692 TANKOOS REPORTING COMPANY (516) 741-5342 Laborers for JUSTICEŠ 1997-2006 All Rights reserved. Not for republication on the internet without permission.
1 Michael Mitchell
2 A To the best of my knowledge.
3 Q With respect to the hours that
4 you have recorded for yourself, do they in
5 fact record the hours that you spent on the
6 jobsite?
7 A Probably not accurately.
Q Would you explain your answer,
9 please?
10 A I stated before, there would be
11 times I would be paid for the day, and woulc
12 have left early, or something to that effect
13 So I won't say that for every 40 hours, that
14 I was actually on the job for 40 hours.
15 Q Is there any way that I can
16 determine how many hours you actually spent
17 on the jobsite? In other words, did you cal
18 the BA?
19 A I don't know that.
20 Q On an average of a 35- or 40-hot
21 workweek for which you were paid, how many
22 hours would you not be on the jobsite?
23 A That would have varied.
24 Q From what to what, approximately
25 A I don't know. From full 40 to
(212) 349-9692 TANKOOS REPORTING COMPANY (516) 741-5
1 Michael Mitchell 18
2 something smaller. I couldn't say.
3 Depending what was going on in my personal
4 life; if I was doing something at home, you
5 know. It would depend on several things, the
6 size of the job, your foreman. Some jobs you
7 have to be there the full 40 hours; sometimes
8 you wouldn't. .
9 Q I'm trying to get some idea.
10 Going back to your On Par jobs, can you give
11 me some estimate of how many hours you were
12 actually on the jobsite?
13 A I couldn't.
14 Q Would you ever be on the jobsite,
15 shall we say, less than three-quarters of the
16 time?
17 A I can't recall, you know,
18 specifically what weeks I was there or for
19 how many hours.
20 Q Are there any periods of time
21 which you can identify, that you weren't
22 there for, let's say, a period more than an
23 hour a day, based on illness or a family
24 situation, or a period that you were doing
25 something else and you weren't serving as a
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1 Michael Mitchell 19
2 shop steward?
3 A Not at this moment, no.
4 Q Is there any way, in other words,
5 is there any way, either by a record or by
6 having called concerning your absence or
7 where you were at the time, that we can
8 determine what hours you actually worked,
9 were present on these On Par jobsites?
10 A I wouldn't think so.
11 Q Other than your lawyer and your
12 family, who else have you told about your
13 presence here today?
14 A I don't see the relevance of
15 that.
16 Q It is relevant; it's certainly
17 relevant. The question is, it may not mean
18 anything, but it is certainly relevant. Have
19 you discussed your presence here with anybody
20 who works at On Par?
21 A No.
22 Q Have you discussed your presence
23 here with anybody who is assigned to 608 or
24 is a member of 608?
25 A I may have.
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1 Michael Mitchell 20
2 Q You know, you can say: I'm not
3 going to answer.
4 A I'll answer the question.
5 Q Who might you have discussed it
6 with?
7 A I don't know; but I've met some
8 of my business agents the last week or two; I
9 probably did say I was called down to Walter
10 Mack's office again.
11 Q Do you remember the business
12 agents you discussed this with?
13 A No. I met a bunch of them one
14 evening; don't know who I may or may not
15 have said it to.
16 Q You know they were business
17 agents from 608?
18 A I have met business agents from
19 608 in the last couple of weeks. Whether or
20 not I told them about it, I'm not sure.
21 Q You're not sure whether you
22 discussed your coming down here today?
23 A I more than likely did. I'm not
24 going to say definitely I remember telling
25 them, or whatever.
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1 Michael Mitchell 21
2 Q Did you discuss your appearance
3 here today and what the topic was?
4 A No, no. I may have mentioned I
5 was called down here again; but I didn't know
6 what the topic would be, so I couldn't be at
7 liberty to discuss that.
8 Q You know, my hope was that I
9 communicated that it would have to do with On
10 Par. You didn't discuss with them that it
11 had to do with On Par Construction?
12 A No.
13 Q Were you given any advice, other
14 than by your lawyer or by a family member,
15 about what you should do when you are down
16 here?
17 A No.
18 Q Let me ask you, on any On Par
19 jobsite that you worked on, did anyone ask
20 you to do something which you knew to be
21 either a violation of the law or a violation
22 of your obligation as a carpenter shop
23 steward?
24 A Could you repeat that?
25 Q Sure. On any On Par jobsite or
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1 Michael Mitchell 22
2 at any time in which you were a steward on an
3 On Par jobsite, did anyone ask you to do
4 something, to take an action or not take an
5 action, which you knew either to be a
6 violation of the law or a violation of your
7 obligation as a union shop steward?
8 MR. ISAACS: Before you answer
9 that question, come with me.
10 MR. MACK: Sure.
11 (Mr. Isaacs and the witness left
12 the room, then returned.)
13 MR. MACK: Did you have enough
14 opportunity to consult?
15 THE WITNESS: Yes.
16 A I believe I answered that
17 question before.
18 Q You did. It doesn't make any
19 difference. I'm asking it again because I
20 have reason to believe that you didn't answer
21 it truthfully. I want to make sure I've
22 asked it again, and I asked it a little bit
23 differently.
24 A I have nothing to alter my last
25 statements to you.
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1 Michael Mitchell 23
2 Q It is broader than that. I
3 looked at it, and I actually changed it to be
4 broader.
5 A Okay.
6 Q My feeling is, I want to make
7 sure you answer the question I ask you today.
8 A. Could you repeat the question?
9 Q Sure. On any jobsite in which
10 you were acting as an On Par shop steward,
11 did anyone ask you to do anything which you
12 knew or believed to be a violation of the law
13 or to be a violation of your obligation as a
14 Carpenter's Union carpenter shop steward?
15 A I think I told you before,
16 members had asked me on different occasions
17 to leave them off the sheet.
18 Q You said only two had, and you
19 couldn't remember who they were; and there
20 were other things, but I'm asking -- that's
21 all there was?
22 A Other than that, no.
23 Q Nothing else?
24 A No.
25 Q Did anyone, outside of being an
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1 Michael Mitchell 24
2 operator of the job referral system, act in
3 any way to increase the likelihood of your
4 being assigned as a shop steward to an On Par
5 jobsite?
6 A Repeat that. I'm sorry.
7 Q Sure. Did anyone, other than an
8 operator of the District Council job referral
9 system, ever act in any way, that means give
10 you suggestions, give you an idea of what
11 skills to add or delete, with the purpose of
12 increasing the likelihood of your assignment
13 as a shop steward to an On Par jobsite?
14 A Not that I can recall, no.
15 Q Other than that, you're standing
16 on your testimony of before; is that correct?
17 A Yes.
18 MR. MACK: Anything you would
19 like to ask, Mr. Sobocienski?
20 MR. SOBOCIENSKI no.
21 Q I wish you luck, Mr. Mitchell.
22 My feeling is this: That
23 notwithstanding your views here today, and
24 what you've said, that if at some time you
25 would like to perhaps reconsider or find some
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1 Michael Mitchell 25
2 way to overcome my perception, which I don't
3 think is wrong, but I'm wrong frequently, I
4 would suggest you talk to Mr. Isaacs about
5 it, and I hope things work out for you, one
6 way or the other.
7 I can't predict what the judge or
8 prosecutors would do; I think you've taken
9 some risk, and for reasons that I perhaps can
10 speculate as to, but I'm not going to
11 speculate as to. I'm going to gather my
12 facts and submit my report and see what the
13 result is. And I wish you luck in the
14 future.
15 Let's conclude.
16 (Time noted: 2:55 o'clock p.m.)
17
18 *
19
20
21
22
23
24
25
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1 26
2 CERTIFICATE
3
4 STATE OF NEW YORK )
5 COUNTY OF ROCKLAND ) ss:
6
7 I, STEWART NISSENBAUM, a Shorthand
8 Reporter and Notary Public within and for the
9 State of New York, do hereby certify:
10 That the within is a true and
11 accurate transcript of the testimony taken on the
12 14th day of September, 2005.
13 I further certify that I am not
14 related to any of the parties to the proceeding by
15 blood or marriage, and that I am in no way
16 interested in the outcome of this matter.
17 IN WITNESS WHEREOF, I have hereunto
18
19
20
21 set my hand this 20 day of September, 2005.
22
23
24 STEWART NISSENBAUM
25
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2 ERRATA SHEET
3 WITNESS:
4 TESTIMONY DATE :
5 PAGE LINE FROM 0
6
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25 By: Name Date
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