UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT

Laborers' Local Union 665, et al. DOCKET NO. 395CV02372(AVC)

Plaintiffs.

V.

Connecticut Laborers District Council of the Laborers' International

Union of North America

Defendant

November 2.1998



SETTLEMENT AGREEMENT


Whereas, plaintiffs Local 665 of the Laborers' International Union of North America

("LIUNA"), Ronald Nobili, Edward P. Smith, Byron Gibbons, Thomas P. Nilan, Joe Dias. Roger Reid and Jerry McKeon brought this action in U.S. District court on November 1, 1995; and

Whereas, the cut was assigned to Judge Alfred V. Covello, and later to Magistrate Judge
Thomas P. Smith, who facilitated settlement negotiations; and

Whereas, the plaintiffs claimed the defendant, The Connecticut Laborers' District Council of
LIUNA, improperly raised dues and spent it for improper purposes; and

Whereas, the plaintiffs believe working dues should not be paid directly to The District
Council; and

Whereas, the defendant denies that it improperly raised dues and that the dues were spent
for improper purposes; and

Whereas, the defendant believes that working dues should be paid directly to the
District Council; and

Whereas, the parties wish to conclude this matter to avoid the time, expense and
uncertainty involved in trying this matter to conclusion, and, further, to promote unity and harmony within LIUNA,

Wherefore, the plaintiffs and defendant agree as follows:

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I. WITHDRAWAL OF SUIT

The plaintiffs will cause this lawsuit to be withdrawn with prejudice.


II. WORKING DUES

Working dues paid by Connecticut members of LIUNA (known variously as "working dues,"
" hourly dues," and "administrative dues") will continue at the present rate of 43 cents per hour,

The working dues will continue to be collected by The Connecticut Laborers' Fund from
employers. The dues will be deposited in an interest bearing account. The Fund will send this money, with accumulated interest, to The Connecticut Laborers' District Council on a monthly basis. (The Fund may hold back payout of checks for a period of time not to exceed one month to ensure the checks do not bounce.) The District Council will receive this money on behalf of itself and the affiliated construction locals and will distribute the money to the affiliated construction locals in amounts proportionate to the number of hours worked by the members of the respective locals after retaining its share of the working dues. The Connecticut Laborers' Fund will prepare monthly reports specifying for each working member the hours worked, the employer, and the local to which the member belongs. The Connecticut Laborers' District Council will utilize this report in apportioning the working dues.

This report will be provided to each of the affiliated locals so the local can verify collection and distribution of the dues. In the event that there are dues paid on account of members whose local membership cannot be determined the District Council, after retaining its share, will divide the dues equally among the affiliated construction locals.

Future increases in working dues, if any, will be put to a secret ballot vote. The vote will be
conducted by each affiliated local in a manner conducive to the greatest possible participation by union members. and conforming to the LMRDA. Increases will not be implemented unless a majority of voting members state-wide vote in favor of the increase.

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Working dues payable by locals to the district council will be proportionate to each local's share of working dues


This agreement shall not impair or compromise the rights or claims of any person or entity not a
party to this lawsuit. Nor shall this Agreement impair or compromise the right or ability of any person or entity to challenge The District council's receiving more than 20% of working dues.

III. NON-RETALIATION

The Connecticut District Council will not sue, bring charges or retaliate in any way against the
Plaintiffs or their employees. representatives and supporters, or against members of Local 665. on account of this law suit and the issues related to it. Nor will The Connecticut District Council support, countenance, or encourage in any fashion any other person or union body to sue, bring charges at retaliate in any way.

The Executive Board of LIUNA will execute the statement contained in Appendix A. This
agreement is contingent upon such execution.

The Connecticut District Council will defend this agreement in any internal challenge
.

IV. ATTORNEYS' FEES AND COSTS

The District Council will pay $100,000 to Leon M. Rosenblatt for litigation costs. The District
Council will bear its own costs and counsel fees in connection with this suit.

V. DISSEMINATION OF THIS AGREEMENT

A letter in the form of Appendix 8 will be sent within 10 days by The Connecticut District Council to every Connecticut member of LIUNA. It will be sent unaccompanied by any other material.

11/2/98

Date

s/Leon Rosenblatt

for the Plaintiffs


11/2/98

Date

s/Charles Leconche

For the Defendant

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APPENDIX A


On behalf of The Laborers' International Union of North America and its Executive Board,
I hereby declare under penalty of perjury that LIUNA will not retaliate against Local 665 or any of its members or officers for any conduct taken in connection with this lawsuit.

____________________________

Date






___________________________

For the Executive Board of the Laborers' International Union of North America


APPENDIX B

[DATE)




RE: SETTLEMENT OF LAWSUIT


(SALUTATION]

We are writing to inform you that the lawsuit brought by Local 665 and its members has been
settled.

There will be changes in the way in which working dues are collected and distributed. The
working dues will continue to be collected by the Connecticut Laborers' Fund from employers. The dues will be deposited in an interest bearing account. The Fund will send this money, with accumulated interest to the Connecticut Laborers' District Council on a monthly basis. The District Council will receive this money on behalf of its affiliated construction locals and will distribute the money to the locals in amounts proportionate to the number of hours worked by the members of the respective locals. The Connecticut Laborers' Funds will prepare monthly reports specifying for each working member the hours worked, the employer, and the local to which the member belongs. The Connecticut Laborers' District Council will utilize this report in apportioning the working dues. This report will be provided to each of the affiliated locals so the local can verify collection and distribution of the dues. In the event that there are dues paid on account of members whose local membership cannot be determined, the dues will be divided evenly among the locals.

Future increases in working dues, if any, will be put to a secret ballot vote. The vote will be
conducted by each affiliated local in a manner conducive to the greatest possible participation by union members, and conforming to the LMRDA. Increases will not be implemented unless a majority of voting members state-wide vote in favor of the increase.

Working dues payable by locals to the district council will be proportionate to each local's share
of working dues.


Ronald Nobili
For Local 665



Charles LeConche
For the District Council


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