Gary Wall et al.
Case # 397 CV 02502 JCH
Robert Luskin et al.
Date : January 10, 2000
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
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
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
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
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
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: 
" ... 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
Fact: Olbrias was given a lack-of-work
layoff slip because of fear of retaliation from the union by my
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
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
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.
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 __________