United States District Court
District of Connecticut

Gary Wall et al.

Case # 397 CV 02502 JCH


Robert Luskin et al.

Date : January 11, 2000

Affidavit of Gene Julian In Reply to Affidavits of Charles LeConche & Thomas Olbrias

1. I am over the age of eighteen & understand & believe in the obligation of an oath.

2. My name is Gene Julian & I reside in Stafford Springs, Connecticut.

3. Many statements in the aforementioned affidavits are lies to the court in order to shield the criminal intent of the Enterprise.

4. In April, 1996, LeConche steward Thomas Olbrias threatened to "shoot [me] in the head six times".

5. Olbrias was both drunk & belligerent when he made this murderous threat to me.

6. On the following day, Defendant LeConche was informed of this incident by then-Local 230 Vice-President Stephen Manos.

7. Defendant LeConche was also informed by my employer, Tony Luiz, who gave LeConche 48 hours notice as required by the union contract.

8. Despite this fact, I was subjected to brutal pressure, from Defendant LeConche, Defendant Pezzenti, & LeConche-associate-in-fact Leonard Granell Jr. to keep Olbrias.

9. Quoting Defendant Pezzenti: "Don't be the first one to say no to the Business Manager."

10. Quoting union representative Granell: "Just keep him."

11. I exhausted the remedies pursuant to the LIUNA Operational Agreement & demanded that this matter be investigated as covered by the LIUNA Ethics & Disciplinary Code.

12. I was under the impression that the LIUNA Operating Agreement would remedy all the abuses perpetrated against Luiz, Manos & myself.

13. I took all the steps necessary including two personal interviews & several phone conversations with LIUNA Inspector General investigator Sheryl McLaughlin.

14. Through their inspector, I informed LIUNA General Executive Board [GEB] Attorney/In House Prosecutor Robert Luskin, LIUNA Inspector General [IG] W. Douglas Gow, & LIUNA Independent Hearing Officer [IHO] Peter Vaira of my situation.

15. However, after repeated efforts on my part, I was never informed as to the outcome of the investigation.

16. The violation of my intangible property rights began with the murderous threat & continued through my last contact with IHO Vaira.

17. Defendant LeConche swears in # 16.of the his affidavit that " ... no 'false internal charges' were ever brought against Mr. Julian or Mr. Manos."

18. The non-existent charges that Defendant LeConche refers to were brought by replacement steward Antonio Osman, a willing pawn directed by Defendant LeConche.

19. Osman physically threatened me on August 29, 1997 in front of a witness.

20. [Quoting the findings of IHO Trial Board]:

Office of The IHO, LIUNA Local 230 Trial Board [Osman v. Julian] Docket # 97-50TB

"This order addresses trial board charges brought by Antonio Osman ["Osman"], a member of Local 230 of Hartford, Connecticut ["Local 230"], against Gene Julian ["Julian"], also a member of Local 230. ..."

"By order dated January 15, 1998, the IHO appointed Jeffrey H. Simcox, a member of the Pennsylvania bar & of the IHO's law firm, to act as a special hearing master for the IHO in this matter & to conduct an on site evidentiary hearing in Hartford. That hearing was held on March 25, 1998 ["Hearing']."

Quoting IHO Special Hearing Master Jeffrey H. Simcox:

"The testimony of Julian, Luiz & other witnesses at the hearing was, however, both consistent & credible ..."

"Osman's own testimony in this regard was imprecise, bordering on the evasive. Osman's testimony is not credible."

21. Both Executive Boards of the captive labor organizations known as Local 230 & The Connecticut Laborers' District Council were excluded by order of GEB Attorney Luskin from holding trial boards addressing the false, manipulated charges.

22. Luskin made sure that this trial board stayed under the purview of the Operational Agreement.

23. I am also aware that Plaintiff Manos too has been brought up on false, manipulated charges making the related statement in LeConche's affidavit a lie.

24. I would like to add that this complaint against me went to trial while the murderous threat against me did not.

25. Also, I had a very good reputation with my former employer, Tony Luiz, but Mr. Luiz hesitated to rehire me because of his fear of retaliation from the union.

Submitted By:


Gene Julian

State of Connecticut
County of Hartford

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