UNITED STATES DISTRICT COURT
LABORERS' LOCAL UNION 665, et al.
V.
CONNECTICUT LABORERS'
DISTRICT COUNCIL OF
THE LABORERS' INTERNATIONAL
Defendant
NO.: 395CV02372(AVC)
AUGUST 16, 1996
AFFIDAVIT OF RONALD NOBILI
My name is Ronald Nobili. I am making this statement to the
best of my knowledge and belief and under penalty of perjury:
1. I am a plaintiff in this case.
2. I am a member of LIUNA, the Connecticut District Council of
LIUNA, and Local 665.
3. I am the principal executive officer of Local
665.
4. The main functions of a local union organization are to
negotiate collective bargaining agreements, enforce the agreements, process grievances,
and organize new bargaining units among other things. Those are all tasks that used to be
performed by the locals in Connecticut until the defendant gradually usurped the locals'
responsibilities.
5. The defendant now operates essentially as state-wide local
union for the LIUNA members who work in construction. It performs nearly
all the tasks associated with a local union. It negotiates the collective bargaining
agreements. It enforces the agreements. It processes grievances. It is engaged in
organizing.
There is very little that local business managers do in the
bargaining area except insofar as we are agents of and members of the district council. To
put it another way, the Laborers now operate in the same way as do other construction
unions, such as the Operating Engineers and Plumbers which have state-wide locals.
6. I have examined the LM-2 reports of the
district council and of all the locals. Most of the money that is taken in by the
defendant and by the locals goes to pay the salaries and benefits of union officials, and
employees. The leading officials of the district council include Charles LeConche,
business manager and secretary-treasurer, Anthony Varbero, president. In
1995, LeConche received more than $138,000 from the defendant and his local, according to
the 1995 LM-2; Varbero received more than $97,000.
7. Anthony Varbero is currently the president of the district
council. He is business manager or Local 146, based in Norwalk. Local 146 has
approximately 245 members, about half the size of Local 665. There is
very little construction work within Local 146's territory, and very little work for
Varbero to do. Local 146 has taken in a number of members who reside in Bridgeport, and
who ordinarily would be members of Local 665, by artificially reducing their dues paid to
Local 146, but making it up in hourly dues paid to the defendant, than passed on to Varbero
In 1993, Varbero was vice president of the defendant and paid
$2400 from the defendant; he was paid $100,000 from Local 146, for a total of more than
$102,400. His union car is a Cadillac Seville. He wears a handgun on his ankle. He owns real estate in or near Vagas and spends large amounts of time out of state.
In 1993, Varbero reduced his salary from Local 146 to $93,000, but his income at the
district was increased to $6,620.
8. Officers and delegates to the district council
are frequently treated to expensive meals and trips which in my opinion have little or
nothing to do with promoting the welfare of union members. I am familiar with the all
allegations in the complaint, and they are accurate.
9. The start of my official appeal through
internal union channels was October 14, 1993, when I wrote to Regional Manager Armand B.
Sabitoni to complain about the dues allocations. It ended on August 24, 1994 when the
General Executive Board decided against us.
10. I never envisioned the possibility of winning an official
internal appeal, and the fact that I lost proves it. Moreover, the appeal
which I did take was bound to fail, and all internal remedies are futile. The father of
the president of LIUNA is the person who created the hourly dues system when he was
regional manager in New England. Over the years, Arthur A. Coia
I participated personally in decisions allocating the money. To my
knowledge, there has never been anyone who has ever prevailed by trying to take advantage
of an internal remedy.
11. The defendants and its officials are extremely intimidating,
and there is no democratic content to its meetings or votes. No votes
are by secret ballot. Except for me, there is virtually no dissent at the district
council, even though I know there are some delegates to the council who know that I am
right.
At district council meetings, since I filed this law suit, no
delegates will sit with me or socialize with me. The message is very clearly given that if
anyone opposes the defendant's leaders, he and his members will have to pay the
consequences by not being given sufficient money to operate, and by having employment
opportunities taken away. I would have opposed the defendant's illegal conduct earlier
including filing a law suit if necessary except that as a consequence of mobility, I was
afraid for my members and my physical well-being and at one time, my
life. The reason I was able to do so starting in 1993 is because the U.S. Justice
Department took Dominick Lopreato out of commission and then it took over oversight of
LIUNA. This gave me enough confidence to proceed.
12. The members of Local 665 pay out more money to the defendant
than they receive back, and they consistently pay out a higher percentage of dues than do
the members of the locals controlled by Varbero. As a result, the members of Local 665 are
forced to subsidize the large salaries of the defendant's officers, though the members
never had an opportunity to vote on it. Over the past several years, Local 665's treasury
has been bled by the defendant so badly, that it had to lay off a field representative
whose job was to help me protect the rights of my members.