United States District Court
District of Connecticut
Gary Wall et al.
Plaintiffs
Case # 397 CV 02502 JCH
v.
Robert Luskin et al.
Defendants
Date : January 10, 2000
Affidavit of Stephen Manos in Reply to
Affidavits of Charles LeConche & Thomas Olbrias As Included In "Defendants'
Opposition To Plaintiffs' Motion For Leave To Amend Second Amended Complaint",
[01-04-00]
1. I am over the age of eighteen & understand & believe in
the obligation of an oath.
2. My name is Stephen Manos & I reside at 77 Hale Road,
Glastonbury, Connecticut.
3. In April of 1996, I was a foreman on the same job-site where
Thomas Olbrias was a steward appointed by Defendant LeConche.
4. For many years it was common knowledge that Olbrias was known
as a steward appointed by either Defendant Lopreato or Defendant LeConche.
5. I was also aware of Olbrias having a reputation for criminality
& violence, & I did see Olbrias acting in a threatening, abusive & frightening
manner toward Julian on the same night that Olbrias threatened Julian.
6. Prior to that incident, I had taken note of the fact that,
while working on the job site & on diverse occasions, Olbrias acted in an impaired
manner.
7. As a direct result of the Olbrias threat, I had two meetings
with Defendant LeConche.
8. I initiated these meetings in my capacity as union
Vice-president/member, & foreman.
9. In the first meeting [not mentioned in either affidavit] I met
with Defendant LeConche & union officer Butch Granell on the morning after the
incident .
10. I explained that Olbrias had made a murderous threat towards
foreman Julian the previous night & that I was there to report the incident.
11. My employer [Tony Luiz] later related to me that Defendant
LeConche consequently called him & proceeded to threaten & intimidate him, saying,
among many other things, that my employer should drop out of being a union contractor.
12. My employer also related to me that he was fearful of
retaliation from Defendant LeConche.
13. Union officers John Pezzenti & Butch Granell visited the
job-site on different occasions in a blatant attempt to coerce foreman Julian into keeping
Olbrias.
14. Because of Defendant LeConche's abusive actions, I initiated a
second meeting with Defendant LeConche at the Hartford union offices.
15. Also present at that second meeting were Defendant Pezzenti,
Butch Granell & Olbrias.
16. Olbrias, admitted, for the first time, that he had made a
murderous threat against Julian.
17. Olbrias made no excuse or apology & immediately was told
to leave the meeting by Defendant LeConche.
18. The meeting continued with myself & Defendant LeConche who
immediately politicized the meeting by making it known that he was well aware that both
myself & Gene Julian had, on different occasions, spoken openly about the union &
its officers.
19. Defendant LeConche continued to be accusatory, belligerent
& threatening concerning Julian & I speaking out [on the job-site] about the
leadership of Local 230.
20. I left this second meeting with nothing resolved.
21. I have reported the aforementioned facts to LIUNA General
Executive Board Attorney Robert Luskin, LIUNA Inspector General Douglas Gow, & the
U.S. Justice Department.
22. After that incident & during the years of 1996,1997, &
1998, Julian, myself & my employer were subjected to chronic retaliation &
harassment by LeConche-appointed stewards [& other union officials who are subject to
the LIUNA Operational Agreement].
23. At union meetings & under LeConche's direction, Julian
& I were booed, threatened & shouted down, & on some occasions, members were
directed to walk out when we spoke.
24. Many of these acts are enumerated in previous affidavits filed
by myself & Julian.
25. I was served with the Olbrias/LeConche affidavits [Docket #'s
127 & 128].
Quoting The Olbrias Affidavit & Responding:
26. Quoting Olbrias: [6.] " ... I threatened to shoot Mr.
Julian in the head six times. ... There is no connection between the incident involving
this unfortunate threat & the Local Union leadership."
Fact: The Local Union leadership condoned Olbrias's actions after
the incident by their intimidating tactics aimed towards myself, foreman Gene Julian &
our employer Antonio Luiz & with the express purpose of keeping Olbrias on the job.
27. Quoting Olbrias: [7.] " I worked the next day following
the incident & then, at Mr. LeConche's direction, I was removed from the Babbidge
Library Project job."
Fact: The incident occurred at the beginning of the work week
& Olbrias was laid off at the end of the week after a steady pattern of threats,
harassment & intimidation by Defendant LeConche, Defendant Pezzenti, & union
officer Butch Granell.
Fact: Olbrias was terminated from the job by the employer despite
the extortive tactics of Defendant LeConche & his associates-in-fact.
28. Quoting Olbrias: [8.] ".... the Union's Business Manager
relieved me as steward & removed me from the job. I apologized for my actions."
Fact: Olbrias was not removed by Defendant LeConche & never
apologized for his actions.
Fact: Olbrias, under the supervision of Defendant LeConche, was
immediately appointed as either a steward or foreman on another job.
Fact: This action by Defendant LeConche was a clear indication to
the union membership that he condoned threats & intimidation by Olbrias & is
direct evidence of a captive labor organization.
Quoting The "LeConche Affidavit" & Responding:
29. Quoting LeConche: [9.]" During the month of April, 1996,
Steve Manos & Tom Olbrias came to the Local Union office to discuss [the] incident ...
."
Fact: I initiated the meeting with Defendant LeConche to discuss
his abusive actions toward Julian, myself & my employer. [Olbrias showed up at the
behest of Defendant LeConche]
30. Quoting LeConche: 10. "Mr. Olbrias apologized & said
it was an idle threat expressed out of frustration & with no intent to carry out the
threat. ... I immediately informed Mr. Olbrias that he was out of line & would be
removed from the job. Mr. Olbrias ... at my direction, was removed from the job."
Fact: I was present at the whole meeting & none of this
happened.
Fact: The only thing remotely related to this purely fictional
account is Defendant LeConche saying to Olbrias: "So you threatened to shoot him in
the head six times !!!" [with no answer from Olbrias]
31. Quoting LeConche: [11.] "Mr. Olbrias's temper flare ...
was not authorized or condoned by the Local Union or any of its officers."
Fact: Defendant LeConche & his associates never spoke out
against Olbrias's murderous threat, thereby giving validity to Olbrias's actions.
32. Quoting LeConche: [12] " ... Mr. Olbrias was removed from
the job at my direction the day following the incident."
Fact: Olbrias was laid off several days after the incident &
definitely not at Defendant LeConche's direction.
Fact: Olbrias was given a lack-of-work layoff slip because of fear
of retaliation from the union by my employer.
Fact: Olbrias was replaced the following week with another
laborer.
33. Quoting LeConche: [14.] " at no time during the year of
1996 was it evident, as claimed by Mr. Julian ...that he was a known political
opponent."
Fact: Political opposition encompasses more that announcing a
candidacy.
Fact: Prior to the threat, Julian was recognized as an ally of
Manos with all the attendant political implications.
34. Quoting LeConche: [15.]" No Local union representative
ever requested Capitol concrete to lay off Steve Manos"
Fact: My employer directly expressed to me that he feared
retaliation from the union & on at least one occasion refused to rehire me.
35. Quoting LeConche: [16.] 'No Local Union representative ever
threatened Mr. Julian or Mr. Manos because of any political opposition to the officers of
the local union, ...
Fact: Manos & Julian were threatened by union officers [which
will be proved in discovery].
Fact: At the 07/30/97 Local 230 Executive Board meeting, Manos
asked questions about suspicious expenditures by Defendant LeConche.
Directly Quoting LeConche: "Steve, you are about this
F*****n' close to me coming over there & ripping your F*****n' throat out."
Fact: Under the supervision of Defendant LeConche, Manos was
viciously physically assaulted by Defendant Frank Freeman at that same Local 230 Executive
Board meeting.
Fact: Julian was threatened with retaliation by other union
officers & members.
36. Quoting LeConche: [16.] "... & no "false
internal charges" were ever brought against Mr. Julian or Mr. Manos."
Fact: Julian was brought up on false manipulated, internal charges
at the direction of Defendant LeConche. [Union Trial Board Hearing, 03-25-98]
Fact: Defendant LeConche & associate-in-fact Butch Granell
gave false testimony at this hearing.
Fact: Julian was exonerated, with the hearing officer finding
laborer Antonio Osman [the LeConche-instigated "Plaintiff'] to have "no
credibility".
Fact: Manos was brought up on false, manipulated, internal charges
at the direction of Defendant LeConche when associates-in-fact Pezzenti & Granell
coerced & used laborer David Blatter to file a contrived & fabricated complaint.
[Discovery will prove these & other facts.]
37. Quoting LeConche: [17.] "Mr. Julian's assertion that he
has been "forced to pursue another occupation because of both economic deprivation
& fear" is a self-serving deception."
Fact: Number 17. Is willfully taken out of context & fails to
identify "The Enterprise". Page 4, paragraph 26., [Affidavit of Gene Julian In
Support Of Motion Requesting Pro SE Plaintiff Status In This Instant RICO Action,
12-06-99] In its entirety, reads as follows:
" 26. Because of fear of both economic deprivation & fear
for my physical safety as a result of the actions of the Enterprise as identified in The
RICO complaint, as of September, 1999 I have been forced to pursue another occupation
thereby abandoning over 15 years of accredited service in the union."
38. I am giving witness to this statement by Gene Julian.
Submitted By:
_______________________________
Stephen Manos
State of Connecticut
County of Hartford
Subscribed & Sworn to before me this _______ day of
___________ 2,000
Subscribed & sworn to before me on this ______ day of
__________