Seventh Interim Report of the Review Officer

7/27/2019 Seventh Interim Report of the Review Officer

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UNITED STATES DISTRI T COURT

SOUTHERN DISTRICT OF N W YORK

UNITED STATES OF AMERICA,

laintiff

against

DISTRI T COUNCIL OF N W YORK ITY

AND VICINITY OF THE UNITEDBROTHERHOOD OF CARPENTERS AND

JOINERS OF AMERICA, t al.

X

Defendants. X

9 Civ. 5722 RMB)

THE SEVENTH INTERIM REPORT OF THE REVIEW OFFICER

Dennis M. alsh

Review Officer

The Law Office ofDennis M. alsh

415 Madison Avenue Flo or

New York New York 10017

646.553.1357

[email protected]



TABLE OF CONTENTS

Page,

INTRODUCTION 1

I THE DISTRICT COUNCIL 1

A. Full Mobility CBAs nd the Compliance Requirement 2

B. Information Technology and Business Practices 4

C. Business Representative Interview Project

1. Background: The Job of he Business Rep

2. Business Reps' Views 9

a. Cross-Training of usiness Reps 9

b. Rotation of usiness Reps 10

c. Morning and Afternoon Debrief essions 10

d. Two-Person Teams 11

3. Other Issues Raised and Solutions Contemplated 11

D RO evelopment and Implementation of ilot Program for Business

Representatives 12

1. Current Workflow 12

2. Pilot Program Workflow 14

E. Review Officer Time Sheets 14

F. Hiring of Counsel to Deal with the RO 15

G The OW epartment and its Many Hats 15

H Special Election for Executive Secretary-Treasurer 16

I An mperfect Approach to Negotiating CBAs 17

J. Confidential Organized Crime Investigations 18

K The Heart Scan Affair 19

L. The District Council Compliance Function 19

M. The Inspector General s Office 19

N Governance and the Delegate Body 20

O District Council Invocation of rivilege and a Requested Protocol 22

P. District Council Policy on Steward Certifications and Bylaw Sec. 39 22

Q. Working Dues and Assessments System and the Dues Check Off rogram 24

R. MW rbitration Award and Related Matters 24

S. On site Review of ocal Unions 25

1. Local Union Hall Access 26

2. Dues Payments 26

3. Professional Engagements 26

4. Insurance 27

5. Financial Matters 27

a. Trustees Training and Meetings 27

b. Membership Meetings 28

c. Bank Accounts 29

d. Scholarship Fund Accounts 29

e. Credit/Debit Cards 30

f Petty Cash 31



g. Review of ental Insurance Programs 31

6. Business Records 32

a. Bylaws 32

b. Local Union Employee Policies 32

T. Local Union Monthly Meetings 32

U. The Trial Committee 33V. Man Hour Totals Organizing and the Non-union Incursion 33

W The Out-o f-Work List 33

X. Review Officer Letter to Douglas McCarron Regarding William Walsh 35

Y. Hurricane Sandy Contribution Review 35

Z. The Review Officer Hotline 36

AA Review Officer Costs 36

II THE BENEFITFUNDS 36

A. The First Six Months Under the Executive Director 36

B. The Benefit Funds ChiefCompliance Officer 39

C. Outside Auditor40

D. IT Infrastructure 41

E. Overall Condition of he Funds 42

1. The Pension Fund 43

2. The Welfare Fund 44

F. Collections 45

1. Collection of elinquent Contributions 46

2. Specific Litigation/Settlement Matters 47

G. A Note on Outside Counsel Fees 48

H. 395 Hudson: The Renovation Project 48

CONCLUSION 49



You never change things by ighting the existing reality. To change something, build a new

model hat makes the existing model bsolete.

-Buckminster Fuller

INTRODUCTION

I submit this seventh semi-annual report pursuant to paragraph 5.m of he Stipulation and

Order entered on June 3,2010, n United States v District Council, et al.,90 Civ. 5722 RMB)

(the Stipulation and Order ). It endeavors to inform the Court and the parties of he scope and

substance of my ctivities for the past six months and convey my mpressions of ertain aspects

of he undertaking.

My esponsibilities encompass review, investigative and oversight functions relating to

the New York City District Council of Carpenters (the District Council or the Council )and

its Taft-Hartley fringe benefit funds the Benefit Funds r the Funds ).

I.

THE DISTRICT COUNCIL

Though aspects of he administration of he District Council have improved over the last

three years I cannot say the same about its governance or fundamental business practices. The

fiduciaries responsible for the care and improvement of this organization -- and for insuring

compliance with the orders of this Court (which approved collective bargaining agreements

featuring full mobility on the premise that compliance provisions would be ironclad) -- have to o

often been content to ignore these imperatives and in some cases even failed to recognize them

as such. Too many people associated with the District Council are frustrated by the zeal, even

the very presence, of he RO's office, and by the pendency of Court orders. They yearn merely

for political power, the homage of constituents, and the day when they can run the District



Council as they please. This despite that they have not engaged in any objective, cr itical

thinking about the changes that must be made if this institution is to survive.

A. Full Mobility CBAs nd the Compliance Requirement

The District Council has entered into collective bargaining agreements this year with five

major contractor associations, which, in exchange for increased wages and benefits, grant the

employer the right to select the carpenters(from local unions ffili ted with the District Council)

who will work on a ob. Each of he contracts had to be submitted to and approved by the Court

because a May 2009 order of he Court established a formula by which no more than two-thirds

of he carpenters on a job could be selected by the employer. My ffice, the government and,

most importantly, the Court conditioned their ap proval of he contracts on the implementation of

a historic compliance program whereby shop stewards would promptly enter into a District

Council database all hours worked via a tablet provided by the District Council or via

computer. The entered time is then made available to the contractor via email notice. The

contractor is then obliged to accept or dispute the time entered by the steward within five

business days. Once accepted, the contractor is obliged to remit to the Benefit Funds the

associated amount of contributions for fringe benefits. The linchpin of he system provides for

members to have the bility to log into the database and read the amount of time entered by the

steward and report any errors or suspicions of raud. The reli bility and success of he system

depends on stewards complying with their obligations and entering the time (within 48 to 72

hours)and on the District Council having a thorough and efficient method to insure the accuracy

and timeliness of he hours entered.

The District Council is required by the Court s orders approving the contracts to submit

progress reports on the compliance program every 3 days. To date, five such 30-day Reports



have been submitted. s is evident from the data provided in the reports and as has been

discussed in conferences with the Cour t, the District Council has failed to deliver a thorough and

efficient method insuring the accuracy and timeliness of he hours entered. Accordingly, some

six months after implementation, the compliance program is still not reliable. See Fifth 30-day

Report (Docket no. 1431); see also Transcripts of Status Conferences on September 30 and

November 18, 2013. The Court has scheduled a conference for December 4, 2013 on this

serious issue. See Court s Order ofNovember 25,2013 Docket no.1434).

In addition to the aforementioned problems, the District Council has not set a date by

which the submission of ll paper steward reports will end. If the District Council had a

disciplined approach and firm commitment o reform in such matters, one would expect that such

a date could easily be set for the very near future, perhaps 30 to 6 days hence. The District

Council also needs to immediately (i) implement a procedure for promptly resolving disputes

with employers about electronically entered time and for swiftly moving to grievance and

arbitration proceedings, if necessary; ii) end the telephonic reporting of work hours by stewards

on jobs with three or more members unless extraordinary circumstances warrant such a method,

which sho uld rarely occur); and iii) implement a simple method whereby st eward s can record

electronically that a ob has ended(whether temporarily or permanently).

Finally, at y rging, the District Council and Benefit Funds have agreed on a temporary

protocol whereby each week the Funds will be provided with the record of time entered by

stewards on the2

largest District Council work sites

(by man hours . The data will then be

compared to the records kept by the Funds of hours and fringe benefit payments remitted by the

employers through the recently installed i-Remit system). Until a method is implemented where

l l such District Council data is automatically sent to Funds computers for cross-checking

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(which I understand cannot occur until at least the spring of 014), his interim method will serve

as a hedge against incorrect reporting and fraud on the largestjobs.

B. Information Technology and Business Practices

On September 16, 2013, filed a motion with the District Court with the goal of equiring

the District Council to adopt my recommendations regarding the improvement of the District

Council information technology ( IT ) systems and its business practices. I was l f t with no

choice but to do so after both the District Council Executive Committee and delegate body voted

to reject the recommendations.

I view both parts of he recommendations -- using technology and best business practices

-- as imperative steps in insulating the District Council from corruption and racketeering. The

District Council will realize many other benefits from these improvements, including

accountability of employees and departments, efficiency in operations, the creation of earchable

databases through which data can be us ed in a variety of ways to benefit the District Council and

its membership, and the elimination of paper reporting and record keeping. These have been

standard practices in the modern American business community for m ny years. The Benefit

Funds started a similar process approximately two years ago and it is nearly complete.

After rejecting my recommendations, and without rational explanation, the Executive

Committee and delegate body then voted to hire new couns el to deal with my motion and my

office but also then voted shortly thereafter to form an IT committee, hire an IT consultant to

assist the committee, and ultimately issue a request for proposals from IT consultants to

implement a broad upgrade of he current antiquated systems and practices the precise result I

originally recommended).



I have met frequently with Barbara Jones the attorney engaged by the District Council

and various District Council managers to discuss the goal of achieving what is best for the

District Council and bring about the changes necessary. Though these continuing discussions

have been productive the pace of progress has been modest. y motion has been held in

abeyance to dete rmin e if my goals can be achiev ed in this manner. The specifics of my

recommendations and related correspondence follow.

Email from the RO o General Counsel James Murphy sent on July 23, 2013:

As I sai d in the large group meeting last Wednesday the 7 h, I would like to begin

assembling the terms of a stipulation and order governing D business practices,

procedures and systems which would be executed by and between the DC RO and the

government.

The document, in my view should state, among other things, that the parties recognize

that the D eeds to reconstruct ts business practices, IT infrastructure and personnel

needs in order to successfully perform ts function and also achieve the eradication of

corruption and racketeering and meet ts remedial obligations as contemplated by the

Stipulation and Order See Paragraph 4. .

The D would enter the agreement to avoid potentially protracted and expensive

litigation with the Review Officer over enforcement of a range of formal

recommendations.

The document should establish a ramework through which the Court can decide, in the

absence of greement, what needs to be done by the D n regard to:

-hiring more employees office workers as well as business representatives) and

efficiently using and dep lo ying them;

-acquiring a modern computer system and tailored software to begin growing and using

an interactive business database asI iscussed in the meeting; basically, the D rain);

-writing and ublishing detailed business procedures and rotocols.

The document should establish a schedule for all of he milestones as well as a

means of alculating costs and establishing budgets or each ca tegory which will require

the D o spend money it currently has sitting in savings accounts and which currently

brings very little benefit).

5



Email from the RO o Mr. Murphy sent on July 26, 013:

I hereby formally recommend to the District Council pursuant to Paragraph 5. . ii i of

the Stipulation and Order that t conceive acquire and implement the business

te chn ology systems practices and procedures and hire appropriate personnel of hich

I spoke in the meeting on July 17 2013, at ten ded by you, the EST Pro Tem, VicePresident, Director of Operations the IG and CCO managers of the representative

center, and members ofmy taff among others.

In the absence of he stipulation I equested in my email of uly 23rd being executed by

August 16 2013, I ntend to move swiftly to seek an order from the District Court

requiring adoption of my ecommendations.

In sum, and as I said in the large group meeting on the 7 , the recommendations

concern modernizing and ameliorating District Council business practices, procedures

and systems. The District Council needs to reconstruct it s business practices, IT

infrastructure and personnel needs in order to successfully perform its function and alsoachieve the eradication of orruption and racketeering and meet ts remedial obligations

as contemplated by the Stipulation and Order. See Paragraph 4. .

The District Council must as quickly as feasible establish and implement the new

business structure, including by

-hiring more employees office workers as well as business representatives) and

efficiently using and deploying them and documenting their assignments and

undertakings in a manner which minimizes the likelihood of orruption;

-acquiring a modern computer system and tailored software to begin growing and using

an interactive business database as the repository of all District Council business

information and which will serve as the principal toolfor all business practices as I

discussed in the meet ing; basically, the D rain); and

-writing and publishing detailed business procedures and protocols consistent with the

foregoing.

Email from the RO o Mr. Murphy sent on July 29,2013

To urther refine what I will be see king in the absence of greement, I recommend that

there be a

categ ory of representatives called client representatives or account

representatives, as well as a basic category line rep. Line representatives will be

dispatched tojobs electronically. They will for example, respond to a ob site after being

dispatched perform the duty assigned by the DC and report back electronically on the

handling of he assignment. A standard report form should be used. This will be the

official record of he rep dispatch and report. Multiple authorized D ersons will have

access to the information. If he employer wishes to dispute or refine anyt hing discussed

by the line rep, he can then do that by communicating with the account representative.

6



The account rep should never vis it the job by himself. Email should be used bu t if

telephone contact is made or received the account rep must make a short timely entry

into the D business system on the subject and the outcome. If necessary a meeting

should be held at the D ith the emp loyer account rep line rep and business center

lead to resolve any remaining issue expeditiously and n a compliant manner.

Briefing and debriefing meetings should be held sparingly. Green sheets will be

supersededand bolished.

Specialty reps will also be in a line rep cat egory and dispatched to non-specialty jobs as

needed. There will be specialty account reps assigned to handle specialty employers in

the same manner as described abov e.

One s access to the D atabase will be determined by ob description and will of ourse

be bypassword and username to insure an electronic trail and ccountability.

s of he time of his report the District Council has agr ee d to implement apilot program

whereby a small number of usiness representatives will receive their assignments electronically

and report back the same way), ill no t be required to attend morning and afternoon debriefings

at the District Co uncil and will be exempted from submitting time and task records to my ffice.

The District Council has recently formed an IT Committee that has met wice. Proposals

have been received from five technology consulting companies to provide assistance to the

committee in reviewing the current use of echn ology conceive ll necessary improvements and

draft and issue an R P o vendors by March 28, 014),one ofwhom will be selected to engineer

and install ll necessary upgrades. The entire process will likely extend into 2015.

Even if the District Council were to agree today to adopt every recommendation I have

made, there would still need to be an Order entered by the Court documenting the associated

undertakings and commitments, o guaranteeameans of enforcement should the District Council

f il to accomplish the results required on a specific schedule.



C. Busine ss Representative Interview Project

In June of his year, RO taffbegan to interview District Council business representatives

to ascertain how they view their job responsibilities, as well as the manner in which they are

currently required to perform them, and to solicit their opinions on specific procedural changes

that might help improve efficiency. RO taff interviewed 21 of he 7 business representatives

( reps, as they are called at the District Council). RO taff also interviewed the lead regional

manager and the two regional managers of he bu siness rep enters.

1. Background: The Job of he Business Rep

District Council business reps are responsible for policing the entire jurisdiction of the

Council -- a craft jurisdiction that includes general carpentry, woodwork, dock building,

millwork, cabinetry, scaffolding, floor covering, and millwrights and a ge ographi c jurisdiction

that includes New York City s five boroughs,and, or some crafts, Long Island, certain counties

in upstate New York and parts of New Jersey. The business reps are in the front line of anti-

corruption efforts at the Council. Vigorous policing of the Union's jurisdiction includes

obtaining information on ll job sites to assist the Council in enforcing the collective bargaining

agree ment s.

There are two business rep centers, one located in Manhattan and the other in Queens, o

which the business reps report twic e a day. regional manager oversees each rep center,

reporting up to the lead regional manager. Each rep center is divided into a number of

geographical zones. Busin ess reps are assigned to either a geographical zone or a specialty trade

or to assist with the implementation of electronic reporting of hours and other administrative

matters.



A typical daily routine for a business rep starts with going to the rep center for the

morning briefing to receive assignments. New ob starts and shop steward dispatches drive the

assignments. Business reps receive up to 30 new job start notifications a day The business reps

use the daily job starts and shop st ewar d dispatches to dete rm ine what job sites to vi si t which

st ewards to contact, what members to call about electronic reporting of hours, and what other

matters need their attention. The business reps are also required to ill out detailed time sheets

referred to as RO imesheets ) and send an email to their managers after every third job site

visit listing the jobs visited and the contractor on sit e.

All of he business reps reported that they were busy and, t times, overloaded with work.

any reported that they could not perform all of he assignments given to them in a particular

day Common themes as to w y th ey could not complete all assignments include too much

paperwork and, specially for those assigned to zones in Manhattan, bein g responsible for too

many ob sites.

2 Business Reps' Views

My staff discussed a number of specific issues and possible procedural changes with

business reps during the interview project.

a. Cross-Training of usiness Reps

The business reps unanimously support cross-training of business reps in all craft

jurisdictions. The Council has implemented cross-training and has conducted training sessions

in millwright, dockbuilder, floor coverer, timbermen and interior systems jurisdictions. The

District Council also intends to conduct cross-training for other craft jurisdictions. The training

sessions are in-person seminars conducted by subject matter experts and include visual aids.

Business reps assigned to certain zones in Manhattan can be responsible for well over 100 obs, while those

assigned to certain zones outside Manhattan are responsible for significantly fewer obs.

9



Some business reps reported that they have used the training to assist them in identifying and

rectifying some issues onjob sites.

b. Rotation of usiness Reps

Most of he business reps support rotating business representatives on a regular basis and

agree that a on e-year rotation schedule is appropriate (though in y view, the time should be

shorter .

c. Morning and Afternoon Debrief essions

Until recently, there was a morning debrief' at the beginning of each work day that the

bus reps were required to attend at their rep center. The business reps found them to be

unhelpful and the regional managers have, for the most part, stopped holding the meetings.

However, he regional managers till require with limited exceptions, that business reps to report

to their rep center each morning before beginning their work day. This results in some business

reps driving by job sites that they are supposed to vi si t then circling back to those sites after

reporting to the rep center a situation that is inefficient and frustrating to the reps who have to do

t

Additionally, the regional managers require business reps to attend an afternoon debrief

at approximately 2:00 p.m. any business reps end their job site visits immediately after lunch

in order to get to the rep centers in time for the afternoon debrief even though job sites are

typically active until 3:30 p.m. Thus, business reps spend many hours commuting to and

attending meetings, rather than visiting job sites.2

The regional managers tested using telephone conferencing rather than physical attendance at the afternoon

debriefs. The test was said to be unsuccessful due to a lack of a protocol for con duc ti ng such conferences.

10



d. wo-Person Teams

All of the business reps except one thought that having a team of two business reps

perform their duties together was inefficient would require the hiring of many more business

reps and would no t necessarily limit corruption. Additionally, the business reps and their

managers pointed out that when there are indications of ossible corruption or other major issues

at a ob site the Council sends two business reps to the sit e.

3. Other Issues Raised and Solutions Contemplated

With the candid cooperation of the business reps, my staff identified these additional

changes for the Council to consider: (1) here should be formal, structured training for business

reps and documentation of hat training. The current practice is to pair a newly hired business

rep with a veteran one for on the job raining that can range from a few weeks to months. This

ad hoc process creates inconsistencies in the training;(2) There should be standardized written

policies and procedures governing the business reps job responsibilities. Currently, the Council

has no such policies and procedures or none of which the business reps are aware; (3) Daily

morning and afternoon meetings should be eliminated. The sessions take too much time away

from the business reps performing job site visits and other important tasks; (4) The Council

should immediately increase administrative resources to perform some of the tasks w

performed by the business reps, such as updating job folders tracking shop ste ward compliance

with electronic reporting requirements, addressing working dues assessment issues collecting

dues check off cards, and tracking tablets used

by shop stewards. Using business reps to pe rform

such tasks limits the number and thoroughness of heir job site visits an essential anti corruption

tool.

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I note a few additional observations made by the business reps: 1) ech nology should be

utilized more extensively, especially for processing job profile sheets ( green sheets ); and 2)

District Council leadership shoul d communicate better with business reps, who often irst learn

importa nt information from rank-and file carpenters.

D RO evelopment and Implementation ofa ilot Program for Business Representatives

s noted, one importa nt tool in the District Council's anti-corruption efforts is visiting as

many job sites as possible on a regular basis and obtaining and maintaining current information

about employers shop stewards, carpenters and the job si tes.

My taff and I have used information gathered from the business rep interview project,

Out-of-Work List ( OWL ) taff, District Council officers and RO timesheets to develop and

implement a pilot program, gr eed to by the Council, that uses technology to create a system that

will afford business reps more time to visitjob sites and to track and document heir vis it s. The

objective of he pilot program is simple: to develop and use technology in business processes.

To assist in the implementation of the pilot program my staff documented the current

business workflow, attached as Exhibit 1, and an accompanying pilot program business

workflow, attached as Exhibit 2. Two business reps reporting to the Queens rep center were

selected to participate in the pilot program. They are implementing the pilot program workflow.

1. Cur rent Workflow

The current workflow for business reps relies heavily upon the receipt of documentsfrom

the OW epar tme nt. Each night, theOW

department sends to eachrep center documents

including green sheets, shop stewa rd dispatch records, non-shop steward dispatch records and

one- and two-person job st arts. Examples of these documents are attached as Exhibit 3. The

business reps are required to process these documents every day.

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The gree n sheet is used by the Council to drive many of ts business rep functions. It is

used to document new job starts job site visits by business reps and the progress of a job.

Typically, a green sheet is created by the OW department when an employer requests a job

number for a new job and a steward to be dispatched. o dispatch a steward a member of he

OW department hand writes certain information received from the employer, including the

employer s name and the job site location. The green sheet is then used to dispatch a steward to

the job. The name of he steward and the steward s telephone number are handwritten onto the

green sheet. At the end of the night all of the green sheets are sent to the appropriate rep

centers.

The next morning, he regional managers sort the green sheets and other documents from

the OW department into the various zones the Council has created for business reps. The

business reps report each morning to their rep center to receive the documents for their zone.

Business reps use the green sheets to deter mine which job sites to vi sit and in what order.

After each job site vi sit the business rep handwrites information gathered from the visit onto the

green sheet. At the end of he day, the business rep returns to the rep center for the afternoon

debrief and hands in the updated gr een sheets. While the Council maintains a database of

information recorded on the green sheets since the green sheets are handwritten, a Council

employee must manually enter the information into the database. Though the Queens rep center

generally upd ates it s database in a timely manner, the Manhattan rep center is app roximately

seven months behind in its data entry. This delay severely limits the Council s knowledge of ob

sites assigned to the Manhattan rep center.

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2. Pilot Program Workflow

o minimize disruption in the rep centers the pilot program will mimic the current

workflow except for specific changes designed to free up time for business reps to visit job sites

by creating a workflow that is electronic and not dependent on handwritten forms and manual

data entry.

The specific changes in the pilot program flow from the current workflow are: 1) reen

sheets for the business reps assigned to the pilot program are created in an electronic form and

maintained electronically; 2) the business reps are sent an email containing electronic pre-

populated green sheets; 3) he business reps will not be required to attend the morning debrief

and will begin their work day by reporting directly to ajob site 4) he business reps will fill out

the green sheets electronically on their iPads and email them to the rep center immediately after

each job site visit; 5) he electronic gr een sheets will be filed and maintained, with appropriate

safeguards, on the Council s network hard drive; 6) usiness reps will not have to fill out RO

timesheets or email the rep center managers after every threejob site visits; and 7) usiness reps

will not report to the rep center for the afternoon debrief

My taff will monitor the pilot program and share the findings with the District Council

to assist it in improving ts business practices by utilizing technology.

E. Review Officer Time Sh eets

Each week (since the first year of my tenure) all business reps, organizers and their

supervisors have been required to submit written reports to m documenting what they do in

each 30-minute increment of heir work day. ell done example is attached as Exhibit 4. The

time reports have been very helpful in the areas of accountability and assessing productivity.

The best reports written by business representatives who clearly document what they

14



encountered and did at site visits -- serve as the prototype for what such reports should say. The

electronic reporting of usiness representatives should be consistent with this model.

F. Hiring of Counsel to Deal with the RO

On September 12, 2013, the delegate body passed a motion to deal with the RO....

Exhibit 5. An dvertisement was placed in the New York aw ournal. See Exhibit 6. Despite

that the District Council's Chief Compliance Officer ( CCO ) was directly involved in the

interview process, the Council violated the Stipulation and Order by failing to give my office

notice of he delegate body's vote (via email) o retain the attorney in question or the terms of he

retention agreement. My office was similarly not provided with adequate appropriate prior

notice of the interviews conducted by the District Council's General Counsel, CCO (who

scheduled the interviews) and Vice President. I was presented with the retainer agreement after

t was executed.

The delegate body was not presented with the proposals presented by other law firms(a

violation of ection 5(B)7 of he District Council Bylaws). The email sent to the delegate body

to consider the recommendation of he above-referenced committee is attached as Exhibit 7.

G. The OW epartment and ts Many Hats

The breadth and quality of work accomplished by the Out of Work List department,

managed by Aaron Gh olston, deserves to be specifically recognized. In addition to

administering the many facets of he OW nd dispatching members to jobs from the OWL, ts

chief responsibilities include maintaining records of skill sets and certifications held by

members, receiving written and telephonic notice of new jobs from contractors, dispatching

st ewards to new obs, processing written steward reports (via scanning), and receiving telephone

reports of time worked on one- and two-man jobs it is also receiving telephone reports from

15



stewards on jobs with three or more members, something that should only occur in rare

circumstances but is inappropriately being condoned by District Council executives). The

department also telephonically attempts to communicate wi th timekeepers and contractors on

two- and one-man jobs, respectively) who have not reported work hours within the expected

reporting time to determine the hours in question.

The department accomplishes it s principal tasks by fax, telephone, using three non-

Windows systems and programs ULTRA, S4 and LIBERTY nd via hand-written records.

Logically, as the beginning point for record-keeping relating to ll new obs, the functions of he

OW hould be converted to modem lectronic methods as soon as possible.

H. Special Election for Executive Secretary-Treasurer

In August 2013, he Court issued an Order granting my equest to hold a special election

with modified election rules) or the remainder of he term of he Executive Secretary-Treasurer,

which expires on January 11, 2015. See Court s Order of August 15, 2013 Docket no. 1365).

On September 24, 2013, after completing the review of petitions and candidate interviews, I

issued a statement which was sent as an att achment to a le tte r to the Court) regarding the

candidate approval process required by Paragraph 5.k.iv of the Stipulation and Order. See

Endorsed Letter of Dennis M. alsh to Court with Enclosure Docket no. 1421). The statement

(in which approved the candidacy of Greg Kelty) set forth the reasons why declined to

approve the candidacies of at Nee,Steven McInnis and James Noonan. A motion filed with the

Court by Mr. Noonan requesting that my finding regarding his candi

dacy be set aside was

denied. See Court s Dec ision and Order ofOctober 23,2013 Docket no. 1425).

In order to have a contested election providing members wi th a choice, the election

schedule was e-set to allow for additional candidates to circulate petitions and seek approval and

16



nom in atio n Notice of the new schedule was sent on November 8th to al l members. This

process has resulted in two additional members having completed the petition process. The

interviews of these men will be concluded this week and approval decisions regarding the two

additional candidates will be made by December 11 . Ballots will be mailed by the American

Arbitration Association on Jan uary 6, 2014 and will be counted by the on January 24,

2014. The winner will be installed at the first delegate meeting thereafter.

I n mpe rfect Approach to Negotiating CB s

The District Council currently invites al l eight Ex ecutive Committee members to attend

al l collective bargaining sessions. s een in the following email, I expressed my oncern about

the inequality and waste associated with this practice:

Having received on July 15t notice of a collective bargaining session(with officials from

the Javits Center , I asked if the entire executive committee would be attending.

Mr. McInnis replied as follows:

The entire Executive Committee as per the Bylaws is the Negotiating Committee and are

invited. Attendance at all negotiations has varied due to individuals schedules. Myself

Mike Cavanaugh, Chris Wallace, Ray Harvey, Rob Villalta have answered yes to the

invite. Paul Tyznar has a sch eduling conflict and will not be in attendance. We have not

heard back rom the others. Rob Stul bu rg and avits Steward John Diodato will also be

there. Sal Tagliafero President of ocal 9 6 and Delegate requested to attend I ill be

calling him today denying that request.

To which I replied:

The recise language of he Bylaws is as ollo ws:

I) The Executive Committee shall have the primary responsibility for negotiating, and

recommending to the Council Delegate Body for approval, all Collective Bargaining

Agreements.

Attendance of he entire Executive Committee is not require d and when certain of ts

members are D epresentatives, actually creates an issue. The negotiation of CB s s

not in thejob description ofD epresentatives, yet under the DC s current policy, they

will draw ull pay. Alternatively, it is not economically prudent or a working member to

17



give up hisjob to attend negotiating session and thus must often forego attending in

order to make iving

Based on your email, you expect at least three D eps to be in attendance at the Javits

negotiation. They will no t be in thefield checking jobs or otherwise be doing what they

are actually getting paid to do.

The approach of he D s inequitable. The D eeds to consider an efficient and even

handed approach to such negotiations that insures fair compensation and does not

deprive the membership of esources in the ield.

In sum, a better policy for the District Council would be for the Executive Committee to

meet regularly at a time when ll members could attend and determine substantive negotiating

points, as well as which informed and prepared team of negotiators an appropriately sized

subset of he full committee)would attend a specific session. The team would be authorized by

the Executive Committee to negotiate a range of points and terms approved by the Executive

Committee and report back. Such a policy and practice would also foster consistency in

substantive terms set by the Executive Committee) from one industry association to another.

Members of he Executive Committee who do not have a specific role to fill in a session shoul d

not attend the session, particularly when they are Council representativeswho should instead be

performing their daily duties in that regard.

J. Confidential Organized Crime Investigations

y office continues to investigate the attempts of racketeers to infilt r t e and exercise

influence over this Union. We outinely share information learned from such investigations with

prosecutors and appropriate investigative agencies. I am particularly grateful for the ongoing

assistance of the Organized Crime Investigations Division of the New York City Police

Department.

18



K. The Heart Scan Affair

Certain of the top fiduciaries of the District Council (and two who are trustees of the

Benefit Funds) eceived free heart scans earlier this year from a vendor who sought to be named

as a provider by the Benefit Funds. The fair market value of he procedure is $300 according to

the vendor). I attach as Exhibit8 he email inquiry I sent to each of he men in question and their

responses.

L. The District Council Compliance Function

The two quarterly reports presented to the delegate body by the District Council s CCO

during the last six months are attached as Exhibit 9. In my view, hey demonstrate that the CCO

has not been adequately involved in the District Council s compliance with orders of he Court.

The CCO must also take a firmer approach in his dealings with the senior executives of the

District Council and strongly establish the independence of he office from management. urther,

the CCO at the District Council and at the Benefit Funds) should at all times refrain from

performing any management ask.

M The Inspector General s Office

The quarterly reports by the Inspector General( IG ) presented to the delegate body in

the last six months are attached as Exhibit 10. have recommended to the IG that the reports

should contain more substance, particularly in describing the types of investigations being

undertaken and the types of esources being applied. Case numbers appear to serve more as a

reference tool for slight matters orcommunications from members or third parties, rather than as

an indication that a substantive investigation has been opened.

Most importantly, the Inspector General should regularly confirm his views via email to

responsible District Council executives when he has reason to believe that any policy or bylaw of

19



the District Council is being violated and that any order of he Court is being, or even may be,

violated. The IG has described to me ircumstances when he has communicated such views to

responsible managers, but has not confirmed his views in writing. The District Council Bylaws

give the IG (and the CCO trong protection from be ing terminated neither can be released

wi thout the consent of he Review Officer and the United States Attorney s office . The IG must

always aggressively strive to enforce the bylaws and policies of the District Council and his

actions should always be memorialized with a written record.

N. Governance and the Dele gat e Body

Previous reports have documented concerns about the democratic process at the District

Council and what must be accomplished for an acceptable, racketeering-resistant paradigm to be

achieved. My oncerns have not abated. s a democratic institution, the Council has made ittle

progress in the last two years. Though usually provided with ample pre-read material before

meetings, the delegate body remains a capricious, ill-prepared and under-informed group too

easily manipulated by agendists who care nothing about critical thinking and the necessity of

constructive change. In an effort to see what effect my absence from meetings would have, I

have not observed a delegate meeting since September 12 (though the recordings of the

meetings are always reviewed). The meetings remain crude, overly long, torturous affairs;

profanity and theatrics reign and issues of eal importance(such as the urgent need to grow man

hours and the deep flaws in the Union s business model) get short sh rift Specialty collective

bargaining agreements sought by the effected members of specialty local unions have been

rejected. Motions are often poorly conceived and worded and debate is marred by bluster and ad

hominem volleys. The apportioning of delegates based on the size of local unions means that

many local unions have scant influence in the affairs of the Council and that one grossly-

20



oversized local union dictates the direction being taken by the Council. The starkest

transgression against common sense was the rejection of my recommendations regarding

information technology and business practices, the hiring of ounsel to deal with me, and the

subsequent vote to pursue everything I recommended regarding IT in the first place. Plainly,the

results of he democratic process have been and continue to be discouraging. On ts current path,

the greatest threat to a successful democratic system at the Council is democracy tself

For many years, and particularly since January 11, 2012, the District Council has

functioned as a business due to the yeoman efforts of employees who labor, in middle office

and back office roles. It functions in spite of the vagaries of politics and usual lack of

experience and business training of executives, who too often rely on tradition and dogma,

receive no rigorous business training and manage with seat of he pants methods. Well-reasoned,

standard operating procedures incorporating modern technology have not been prepared for key

departments such as the business rep center. The lack of such formal procedures in critical

respects forces too much business to be accomplished by inefficient methods. Time and

resources are wasted and accountability is not certain.

A business model incorporating a philosophy of constant, rigorous analysis and

improvement of the business practices of the Union needs to be accepted and instituted. The

reform accomplished at the District Council over the last three years has most often been the

product of he progressive District Council Bylaws negotiated by me and the UBC nd other

initiatives of this office. In order for the Unionto succeed on its own, he impetus for reform

must come from within.

21



O. District Council Invocation of rivilege and a Requested Protocol

The correspondence relating to the District Council's first invocation of attorney client

privilege under the Stipulation and Order which occurred at the October 9 2013 delegate body

meeting s attached as Exhibit 11 (sign-in sheets omitted).

P. District Council Policy on Steward Certifications and Bylaw Sec. 39

Section 39 of he District Council Bylaws requires that stewards of he District Council

obtain and keep current certifications of ypes of pecial training. Further, the District Council

has for over seven years promulgated in a series of announcements in The Carpenter the official

policy of the Union regarding the necessity of stewards obtaining and keeping current

certifications. Every major collective bargaining agreement held by the Union contemplates that

the Union will send a certified steward to a ob.

On October 18 2013 I received the following message from District Council General

Counsel James Murphy:

See the attachedfrom Aaron Gholston in which he requests an extension [from]

October 31, 2013 to March 31, 2014 or therecertifications

ofhe various skills required

for Shop Stewards for them to retain their Shop Steward certification for dispatch

through the OWL For the reasons described by Aaron Steve and Mike have no

objections. Do ou have a problem with this request and such an extension?

I elieve that this should be considered a one-time temporary measure because of he

specific circumstances described by Aaron and the extension limited to March 31, 2014.

I believe that this request should also be reviewed and approved by the Executive

Committee at its next meeting under Bylaws section 12(C), with at leasta report of his to

the Delegate Body.

The referenced attachment is attached hereto as Exhibit 12. I did not agree with the proposal, bu t

did consent to a 30-day grace period on the condition that the District Council immediately

communicate to ll stewards the necessity of keeping the required certifications current and on

file with the OW department. The District Council endeavored to inform stewards of the

22



imperative of eeping certifications current and on il and a few hundred attempted to comply.

Those that did not, a published statement of he District Council said, would not be referred off

the OW s stewards.

On November 26, 2013, I received the following request via email from a colleague of

Mr. Murphy,Adrian Healy:

This is to follow up on your prior agreement to an extension of he deadline for

shop steward re-certifications. The deadline for all necessary steward certifications to

be updated was extended rom October 31, 2013 to November 30, 2013. Thus, starting

next week, stewards that did not obtain the necessary re-certifications will lose their

certified status and become ineligiblefor dispatch.

However, the Union has learned that the 30-day lag rovision under Section V of heOW rules has prevented stewardsfrom updating their OW rofiles to show the re-

certifications they ve obtained. OW rule 7 rovides that al y request by a shop

steward for a change of kills listed in his or her personal profile on the Job Referral

List will not go into effect until thirty(30)days after the request is made. This rule has

prevented a ubstantial number of hop stewards 100+) who have re-certified during the

extension period rom updating their profiles.

Under these circumstances, the Union would like to waive application of he 3 -day lag

provision and permit those stewards who have earned their re-certifications during the

period from November 1, 2013 to December 31 , 2013 to upd ate their profiles

immediately and remain eligible for dispatch. In other words, as soon as all necessarysteward requirements are satisfied they would be eligiblefor dispatch.

We believe that this proposed waiver should also be reviewed and confirmed by the

Executive Committee at it s next meeting under the authority granted by Section 12 of he

Bylaws with a report to the Delegate Body to ollow.

Please let us know your thoughts on this as soon as you can.

I replied as follows:

The Union has been well aware of ule7

inceits

inception.

My osition is that all applicable rules must be applied, whether set orth in the District

Council Bylaws or OW Rules and that District Council policy, in some cases

promulgated years ago, must be enforced. Any proposed change in policy must be

reviewed by the RO nder the plain terms of he Stipulation and Order.

The problems you describe have resulted from the negligence of District Council

23



management and the failure ofmembers who want to serve as stewards rom ollowing

the requir ement of eeping their certifications current.

The net effect of the situation is that the District Council will be unable to follow ts

policy and comply with ts Bylaws (which in this regard are clearly intended to serve as a

deterrent to unqualified, racketeer-influenced persons serving as stewards), as t apparently will

have no choice but to have stewards on jobs who either do not have current certifications or who

will not be in compliance with Rule 27.

Q. Working Dues and Assessments System and the Dues Check Off rogram

The District Council st l l collects the lion's share of working dues and assessments from

members through check or credit card payments to the District Council. The ending of he blue

card program necessitated this method. Statistics regularly reported by the District Council s

Chief Accountant show that, on average, app roximat ely 95% of he monies owed by members

are received each quarter. The new collective bargaining agreements between the District

Council and the various employer associations provide for a dues check-off system, whereby,

with the written consent of a member, an employer wi thholds a portion of a member's pay for

forwarding to the District Council. The program is currently sc hedu led to begin this week.

R. MW rbitration Award and Related Matters

s previously reported, an arbitrator has issued a Me rits Award and a Remedy Award

with respect to a claim brought by the Manufacturing Woodworkers Association of Greater New

York ( MWA ) gainst the District Council, alleging that a trade show contractor, Gilbert

Displays ( Gilbert ), was a competitor of the MW employers and that the MW employers

were entitled to the more favorable contract rate given to Gilbert. See Fifth Interim Report at 13;

Sixth Interim Report at 11. The Merits Award, ssued in May 2012, ound in the MWA's avor,

a decision I disagree with principally because the MW employers and Gilbert are not

24



competitors. The emedy Award, ssued in January 2013, was or approximately 8.3 million in

damages to the MWA. The emedy Award did not address benefit contributions which the

MW ad unilaterally begun paying at the Gilbert rate but to the Benefit Funds rather than the

Hollow Metal Fund, ollowing the Merits Award.

The award has no t yet been confirmed in court and the money awarded has not yet been

paid. Instead, since Spring 2013, the District Co uncil, MWA nd Benefit Funds have been

engaged in global negotiations in an attempt to resolve all issues and potential issues between

and among them. t is my understanding that the parties are focused on reaching an agreement

addressing the shortfall of benefit contributions to the Benefit Funds and that progress is being

made in the settlement negotiations. Upon finalization of that agreement, the District Council

and MW ill enter an agreement resolving the remaining issues that exist including entry of a

successor collective bargaining agreement.

I have a number of concerns. Negotiations have been going on for a lengthy period of

time, a time period during which the MW mployers have been making benefit contributions at

the lower Gilbert rate and during which health coverage for the MW employees has been

harmed the employees benefits were suspended June 30, 013). I am also concerned about the

potential total sum of money the District Council will pay the MW o satisfy the award and to

recompense the Benefit Funds for the gap in contributions between the MW nd Gilbert rates.

I will continue to monitor this and will contemplate what steps might be ta ken under the

Stipulation and Order ifa resolution is not imminent and reasonable.

S. n-site Review of Local Unions

Beginning in ay 2013,my ffice conducted an on-site review of ach of he eight Local

Unions. We provided advance notice to the Locals, including a checklist of documents to be

25



reviewed. See Exhibit 13. staff member then visited each Lo cal reviewing the documents

and, ypically interviewing the office manager. Overall, the Locals appear to be functioning in

accordance with the Stipulation and Order. Findings, and any related suggestions for

improvement, re set forth below.

1. Local Union Hall Access

Access to the Local Union halls seems appropriately limited with only the office

manager and the president treasurer and financial secretary typically having keys. Where a

Local has only one or two employees, hose employees also have access.

2. Dues Payments

All of the Locals accept checks and money orders in payment of dues. any of the

Locals also accept credit cards with two doing so online via the Local s website. Appropriately,

none of he Locals accept cash.

ome of he Locals deposit checks and money orders electronically eliminating the need

to make in-person deposits at a bank. The Locals that do not fol low this procedure store the

checks and money orders in a desk drawer until a deposit is made, ypically one or two times a

week. The checks and money orders were not always being adequately secured by the Locals,

bu t this has been addressed with them and remedied.

3. Professional Engagements

The Locals appear to be seeking professional assistance where appropriate. A11 of the

Locals have hired an accountant to assist with periodic and annual audits -2 and 990

(Scholarship Fund ilings and bank account reconciliations. All but two of the Locals have

engaged, r are in the process of engaging, egal counsel. Most of he Locals have retained the

26



services of an IT company to assist with their computer needs, as well as developing and

maintaining a website.

4. Insurance

Each of he Locals have surety bonds covering their officers and employees, as required

by the UBC In addition each Local maintains current disability coverage for its employees, s

well as worker s compensation and li bility coverage.

5. Financial Matters

A Local Union s oversight of ts finances is the responsibility of ts three trustees; its

Executive Committee, which is composed of the Local s president vice president recording

secretary, financial secretary treasurer, conductor, and warden (or officers ), as well as the

trustees; and it s membership. The duties of Local Union officers are set forth in the UBC

Constitution.

a. Trustees Training and Meetings

Each Local has trustees whose responsibilities include reviewing financial records of he

Local and who report to the Executive Committee and to the members regarding whether those

records are in order. To assist them in fulfilling these im portant duties, the UBC provides

financial training for the trustees, which the trustees are required to take. See UBC onstitution

Sections 3 A and 31B. Not ll Local Union trustees have attended the training.

Trustees from some Locals have not met consistently each month. Trustees of some of

the Locals meet immediately before, or even during, the Executive Committee meeting, allowing

insufficient time to properly review documents. Additionally, officers of some Locals were

attending trustees' meetings, which ran the risk of the officers unduly influencing the trustees

with respect to their evaluation of the financial records they are charged with reviewing. We

7



have advised the officers not to attend the trustees meetings and have been assured that they

have ceased doing so.

I suggest that each trustee who has not already done so should attend the financial

training provided by the UBC aking every effort to attend one of he earlier training sessions

provided in 2014. A rustees meeting should take place every month and at least two trustees

should attend those meetings). No one other than the Local s trustees, office manager and

accountant should attend a Local s trustees meeting. A rustees report should be presented at

every monthly membership meeting , including whether the financial records are in order.

b. Membership Meetings

The Locals do not have a standard method of reporting financial information to their

members nor do they ll report the same ty pe of nformation at membership meetings. There is

only one Local currently using both a profit oss statement and a balance sheet to present bank

account information, expenses, and overall financial health. Additionally, while the Locals

present information on their General and Contingency Fund ac counts (provided for in Section 54

of the UBC Constitution , some Locals do not present information on other accounts that they

may have, t least not on a consistent basis.

In addition, despite the requirement set forth in Section 54 of he UBC onstitution that

members approve bills before there are paid, many of the Locals are paying their regularly

recurring monthly bills prior to monthly membership meetings and without membership

approval. ome Locals were also

paying recurring expenses without 5.b notification to the RO

but that has been remedied.

I suggest that as a general matter and as I have previously said), ll Locals should use

some form of audio/visual aids for presentation of information to the members during their

28



monthly meetings. It would be a more clear and efficient way to present sometimes complicated

infoi llatio n. Only one Local is using audio/video aids PowerPoint presentations and the rest

should begin doing so.

hen making it s financial report at the monthly membership meeting, a Local should

present a profit and loss statement as well as a balance sheet for each account. Additionally, al l

bills even regularly recurring ones, must be presented to y ffice for 5.b review and must be

reviewed by the membership. If a Local prefers to pay its regularly recurring monthly bi lls prior

to the monthly membership meeting, it should submit to me and it s membership a list of

regularly recurring bills for approval. If the Local obtains both approvals, it may pay the bills

but should advise its membership of the payments that have been made at the membership

meetings and give notice of amendments to the list of ecurring bi ll s.

c. Bank Accounts

Each of he Locals has not only General and Contingency Fund bank accounts, but other

accounts. None of he Locals appear to have written guidelines regarding who has access to their

accounts, what transactions including transfers may be conducted, and any monetary limits on

the transactions. Additionally, Locals are not consistently reporting on these accounts at the

membership meetings.

I suggest that Locals should create written guidelines governing access to authorized

uses of and any monetary limitations applicable to use of heir bank accounts. Locals should

review the status of each of heir bank accounts at every monthly membership meeting.

d. Scholarship Fund Accounts

Seven Locals have Scholarship Fund accounts. All seven of the Scholarship Funds

appear to have been established as not-for-profit entities with IRS 501 c) 3) forms and

9



formation documents (articles of incorporation or trust agreements). However not al l of the

Funds have current formation documents and there are instances of non-compliance with the

requirements set forth in the documents. In addition, not all of the Locals have written

guidelines for qualification for, and selection and administration of, Scholarship Fund awards.

Another notable issue is the continuing existence of cholarship Funds for Locals that no

longer exist, fter having been merged into other Locals. y ffice has been in communication

with the District Council or Locals into which the former Locals were merged regarding

addressing this issue.

Finally on this issue, the Locals are not reporting the financial status of he Scholarship

Funds to their membership on a regular basis, if at all. y office has informed some of the

Locals and will inform the others that their Scholarship Fund accounts should be reviewed and

audited, like al l others, to safeguard against irregular actions, and that they should regularly

update members about the accounts.

I suggest that Locals follow through with retaining and consulting with counsel to ensure

that their Scholarship Fund documents meet ll legal requirements. Additionally, Locals should

engage professionals, with the selection process and standards for awarding scholarships

contained in contracts with the professionals. The officers or trustees monthly reports at Local

membership meetings should also cover their Scholarship Fund accounts.

e. Credit/Debit Cards

Seven of the Locals have a credit/debit card that is used periodically and for recurring

monthly bil ls. These Locals had not notified my ffice of his practice. pon becoming aware

of t w dvised the Locals to develop policies and procedures regarding the usage and security

30



of hese cards. Si x of he Locals have developed and implemented these policies and procedures

and w are currently reviewing the policies and procedures from the other Local.

f Petty Cash

While checks, money orders and electronic transfers appear to be the preferred

instruments for conducting Local Union business, the Local s financial secretary or treasurer is

permitted to maintain a petty cash fund. See U C Constitution, Section 40B. The Local s

trustees are required to audit the books and records of ll acc ounts and provide a report to the

membership. See id. Section 40C.

Two of the Locals conduct some transactions in cash but do not maintain books and

records reflecting the transactions. Essentially,they write checks to cash as they see fit

I suggest that the use of cash to conduct Local business should be ended. If the two

Locals in question continue conducting cash transactions, they should set up petty cash funds and

maintain appropriate books and records. They should have policies on the us e of etty cas h and

a limit to the amount in their petty cash funds. The trustees should review the records of the

funds and report on them to the membership.

g. Review of ental Insurance Programs

My ffice also devoted resources to assisting certain Local Unions in establishing dental

insurance programs for their members and in reviewing the propriety of arious steps taken by

Local Unions officers and third parties engaged in the process, as well as the associated

contracts.

31



6. Business Records

a. Bylaws

All Locals are required by the U C o have bylaws. In May of his year, the Locals were

advised of a change in the approval process for their bylaws and reminded by the U C hat their

bylaws must conform to a specific format. To date, one Local has conformed its bylaws to the

format and two others are in the process of doing so. The others still need to make the UBC

required changes in order to be in compliance. Locals that have not conformed their bylaws to

U C equirements should do so immediately, as they were instructed to do by the U C n May.

b. Local Union Employee Policies

Three Locals have personnel and sexual harassment policies and one is in the process of

drafting these policies for presentation to it s membership in January 2014. Three Locals advised

my taff that they basically rely on the District Council s policies and procedures manual, which

they maintain a copy of t their offices. One Local does not have any employee policies.

I suggest that each Local should develop and implement personnel and anti-h arassment

policies and train their employees on the policies. This may be as simple as formalizing the fact

that that they are ad opting the District Council s employee policies and training their employees

on those policies.

T. Local Union Monthly Meetings

In April of his year, ll Locals were asked to include the number of ttendees at monthly

membership meetings in their meeting minutes, to allow for more accurate tracking. With the

exception of Local 740 with an average turnout of ppro ximately 2 percent , the Locals appea r

to have an av erag e turnout of between one and four percent, based on the number of attendees

compared to the total number of members n their Per Capita Reports.

32



U. The Trial Committee

New ules for the Trial Committee were recommended by my ffice on July 15,2013 and

adopted by the delegate body on August 28, 2013. The new rules are attached as Exhibit 15.

The new rules, which were adapted from Section 54 of the UBC Constitution in consultation

with the Trial Committee chairpersons and the District Council's CCO ive enhanced authority

to the Trial Committees' presiding officer and eliminate the Exe cuti ve Committee's ministerial

functions performed at the first reading of harges, went in to effect on October 10, 2013. On

September 13, I had vetoed an attempt by the delegate body to rescind the new rules. The veto

statement is attached as Exhibitl . Si nce their implementation,48 cases have been he ard and no

complaints from any quarter have been received by this office. The cost of he Trial Committee

Chairpersons since June 1, 2013 has been only approximately 30,000.

V. an Hour Totals, Organizing and the Non-union Incursion

Man-hour totals obtained from the Benefit Funds show that the District Counc il has been

unable to significantly increase job opportunities for its members. Exhibit 17. The sta ti sti cs

show that hours are flat and on a pace to merely match or only slightly exceed the totals in each

of he last two years

ne must conclude that the Organizing Department, despite it s diligent implementation

of its Area Standards campaign (which seeks to inform the general public about certain

employers' failure to pay fair wages to workers), must be authorized to employ new methods if

carpenters now with non-union employers are to be unionized and man-hours increased.

W. The Out-of-Work List

Co ntrary to the predictions of some, the advent of full mobility has not significantly

decreased the rate of eferrals from the out-of-work list Members are being referred off of he

33



OW t a pace to match previous periods. Further the three dispatch rule has achieved t

intended effect of nding the over stating or puffing of kills when registering to be placed on the

OWL s well as the quitting of obs before completion in order to take a chance that one's next

referral will be for a job of onger duration. The slight decrease in dispatches is likely due to

companies no longer making requests for members from the OWL hich counted as dispatches

and companies keeping apprentices.

The following summarizes recent membership,OW nd dispatch trends:

Journeymen in good standing 10/31/13 13,226

Journeymen in good standing 4/ 30/13 13,122

Increase injourneymen 104Reduction since 12/3/10 2,068

Members n arrears 801

Numbers of ersons on the OW n 11/22/13:

Local 157 4,346

Local 2287 250

Local 1556 Scaffolding 169

Local 1556 Dockbuilders 284

Local 740 144Local 2790 83

Total 5,276 compared to 5,500 as of 12/2010)

Dispatch Statistics

October 2013 April 2013 October 2012

Apprentices 320 483 438

Requests 19 182 236

Shapes 307 346 293

Denied Requests 10 31

Pure Dispatche s 1,075 1,308 952Totals 1,731 2,365 1,950

The October 2013 dispatch figures include 83 trade show dispatches.

Total activity from June 2013 through September 2013 follows:

June 2013: 1,561

34



July 2013: 1,681

August 2013: 1, 825

September 2013: 1,517

X. Review Officer Letter to Douglas McCarron Regarding William Walsh

y letter dated October 9, 2013, U C General President Douglas McCarron dec ided a

protest filed with him by a Local Union 157 member regarding the eligibility of nother member,

William Walsh, o run for a delegate seat representing Local 157). Mr. McCarron ruled that Mr.

Walsh was not eligible to run, finding that he was not depending on the trade for a livelihood as

required by Section 3 D of the U C Constitution. Understanding that Mr. Walsh had been

un able to work due to a knee replacement, but that he had returned to work as quickly as he was

able and that he had been thus limited in his income to a disability pension paid by the Benefit

Funds, I wrote to Mr. McCarron to seek guidance on the proper interpretation of Section 31D.

The letter of he General President dated October 9,2013 and my etter ofNovember 7, 2013, re

attached as Exhibit 18.

In deciding the protest Mr. McCarron directed Local 157 to rerun it s delegate election

for 48 seats in the District Council delegate body) eld in June. The Local also sent a le tter to

Mr. McCarron seeking, among other things further consideration of he Walsh disqualification

and clarification on proper interpretation of ection 31D. That letter is attached as Exhibit 19.

Local 157 has not yet held the rerun election or sent notice of such an election. ts delegates

remain in service in the District Council delegate body.

Y. Hu rricane Sandy Contribution Review

My office reviewed the applications for and awards of 3,000 made by the District

Council to some 6 members who suffered economic loss as a result of Hurricane Sandy.

Though the application process did require basic proofof oss such as verified insurance claims

35



and photographic evidence we did not feel that ll claims were equally situated and suggest that

if such donations are made in the future a more rigorous pr ocedure should be employed to

prevent marginal and unmerited claims from being paid.

Z. The Review Officer Hotline

In the last six months, he Review Officer Hotline has only received a total of 10 calls

none of which reported serious matters relating to corruption.

AA Review Officer Costs

The last six bills submitted by this office to the District Council are attached as Exhibit

20. All have been at the low end to median of he range of otal monthly costs contempla ted by

paragraph 8.b of he Stipulation and Order.

THE BENEFIT FUNDS

A The First Si x Months Under the Executive Director

Under the leadership of ts new Executive Director Ryk Tierney and wi th the support

and engagement of ts Board of Trustees the Benefit Funds is being run professionally and a

number of mportant improvements are being made.

During his fi rs t six months of service the Executive Director has made a significant

commitment of time and energy to improving both the operation of the Benefit Funds and the

morale of Funds' taff. e has familiarized himself wi th ll facets of he Funds' operations and

administers the Funds knowledgeably and pragmatically. e holds bi-weekly senior staff

mee tings establishing goals to be met. e holds monthly meetings with staff at which training

is provided. e has staff working in committees on specific Funds' projects such as the new

website discussed below. e has helped the trustees avail themselves of ppropriate conferences.

36



Overall, there appears to be improved communications at the Funds and a more constructive

work environment

The Exe cutive Director has made a number of ritical hires. Importantly, he has hired a

Human Resources Director filling a void that was created with the departure of the in itial R

Director over a year ago. mong he responsibilities of he new R irector who brings over

2 years of elevant experience to this position is fine-tuning and administering the R lan.

She is currently preparing to conduct the first annual performance reviews since coming on

board. In this regard, she has worked on modifying the evaluation form to reflect core

competencies and on revising the ratings system She has also participated in training directors

managers and staff regarding the review process. In addition to these responsibilities the R

Director will serve as someone who staff may come to with questions and concerns. t is my

hope that this will further improve morale as well as serve as a hedge against corruption.

The Executive Director has also hired a Records Retention Coordinator, who s rev iewi ng

and organizing the mass of documents that have been stored or, perhaps more accurately piling

up) at the Funds office for years. This includes ascertaining those documents that must be

maintained on site at the Funds and those that may be shipped off site and maintained in storage.

In her relatively short tenure, she has already catalogued the Funds records and moved over

3,000 boxes of ecords off ite to a leased facility. Her next project is reviewing and organizing

the records of he Hollow Metal Funds. She will have continuing responsibility for overseeing

records management, as well as following destruction guidelines. The importance of this

function which enhances transparency, fosters efficiency creates price savings and facilitates

meeting regulatory requirements, cannot be overstated.

37



The Executive Director appears to work well with the Funds' Chief Compliance Officer

( CCO ). The Executive Director has worked with the CCO o address audit findings of the

outside auditor S&P. e has fostered an environment where the CCO can develop and

implement internal controls discussed below). t is critical that this commitment by the

Executive Director as well as the trustees continue. As have stated since the beginning of my

tenure in communications to the trustees and in my nterim reports, a robust compliance function

is among the most mportant components of unds' governance.

The Exe cutive Director has overseen a number of major projects, including the switch

from ADP o I-Remit for employer remittances of enefit contributions to the Funds; heroll

-out

of the new IT system ( URBAN ), which is to become operational in February 2013; and the

renovation of the Funds' office space, which is ongoing. URBAN and the renovation are

discussed in greater depth below).

To better serve the Funds' participants, the Executive Director has demonstrated a

commitment o improving the service provided by the call center to carpenters and their families.

Additionally, he has spearheaded development of a state-of-the rt Funds' website that will

enable participants to readily access information at their convenience; the website will go live

when URBAN does in Fe bruary. Finally with respect to membership service, he is developing a

quarterly newsletter, which will be distributed beginning in January 2014.

One of the next major projects the Executive Director will undertake is developin g

standard operating procedures for Funds' operations. The CCOhas already made progress in

this respect, as discussed below.

38



B. The Benefit Funds' Chief Compliance Officer

Under the leadership of ts Chief Compliance Officer Julie Block, the Benefit Funds is

building a robust compliance program, develop ing and implementing internal controls

conducti ng audits serving as an important resource with respect to the records retention project

and providing compliance and ethics training.

The CCO ecently gave her second semi-annual report at the November 21,2013 Board

of Trustees meeting. The CCO is continuing her assessment of Funds' operations and has

developed and implemented policies and procedures and internal controls including

procurement procedures for the Benefit Funds and the Labor Technical College( LTC ); a fixed

asset inventory and capitalization policy; procedur es for voiding outside pension checks and

notification of deceased pensioners; procedures for reviewing charity and relief requests;

procedu res for handling subpoenas and document requests; and procedures related to the LTC

sales tax exemption. The CCO has also developed check processing procedures for pension,

disability and supplemental checks to be implemented when the Funds bring the process in-

house with the roll out of the URB N system discussed below). Additionally, the CCO has

conducted a number of udits including of ravel and expense reports the LTC logo wear store

and URB N ser security.

Other notable efforts have been dev eloping a vendor integrity check l st to be used in

connection with procurement, a no gift policy in advance of he holidays, and, ith the assistance

of outside counsel, an ERIS

411 certification form in connection with the prohibition of

individuals convicted of ertain crimes serving employee benefits funds. The CCO has also

distributed Conflict of nterest forms to Funds' taff and provided training on this topic.



Upcoming projects include continuing to draft internal controls, with a focus on the

accounting department; auditing accounting procedures, to assess compliance with the

procedures; having some departments do self-audits and following up on them as indicated by

the findings; reviewing servicer provider agre ements, to assess compliance with the terms of he

agreement; onducting the annual employee survey and working with the Executive Director and

HR irector to revise the Compliance and Ethics Program( CEP ) dopted back in April 2012.

With respect to the CEP have a few observations. When he CEP was developed and

ad opted, two Funds' employees who held other senior positions were designated compliance

chiefand deputy chief That was he best solution available at the time. I was concerned that the

responsibilities borne by those two employees might be too great or that compliance would not

be their priority. I believe that turned out to be the case. Having an outside compliance

professional like Ms. Block serve as CCO has been ve ry effective and shou ld be the model going

forw ard. Ideally, compliance should always be an independent unction.

C. Out side Auditor

In addition to working on the audit for the fiscal year ending June 30, 2013, he Benefit

Funds' utside auditing firm, Schultheis anettieri( S&P ), has been conducting two projects

at the request of the trustees: an audit of the finances associated with management of the

physical building at 395 Hudson Street and an expense allocation study.

Earlier this Fall, S P completed the expense allocation study, which was designed to

determine the appropriate allocations of shared expenses among thevarious separate funds

(Welfare, Pension, Annuity, Apprenticeship, and Relief and Charity , and other related entities

e.g., District Council and local unions . mong he expenses reviewed were employee payroll,

40



occupancy costs payroll audits data processing and support computer ex penses legal expenses

consulting expenses postage fiduciary insurance and administrative expenses .

The expense allocation study confirmed that in large measure, the Benefit Funds have

been properly allocating expenses. There will be a decrease of pp roximately 6 n the Welfare

Fund s share of projected expenses and nominal decreases with respect to the Pension and

Annuity Funds. Decreases will be largely absorbed by the District Council LTC ollow Metal

Funds and Reliefand Charity Fund.

At ts Administrative Committee meeting on November 19 2013, he Trustees gave their

formal approval to the expense allocation study and ts findings will be implemented

retroactively to July 1 2013.

S P has also conducted an audit of 395 Hudson-associated finances for period from July

1 2012 through March 31, 2013 and is working on finalizing ts report. To that end, S P s

liaising with the building s QPAM and we xpect that process to be completed by year-end.

D IT Infrastructure

By July 1 2013, the Funds successfully transitioned ts collection of employer benefit

contributions from outside provider ADP o ts internal i-Remit system. Eight hundred employers

are using i- Remit to make their benefit contributions and staff has been reaching out to

employers who st ll manually remit to encourage them to use i-Remit. Additionally as of his

month, -Remit is being used to accomplish member dues remittance.

With i-Remit fully operational since July, the Funds have been focused on preparing for

the roll-out of ts overarching IT upgrade referred to as URBAN. On October 1 the Funds

began parallel testing of ts current system and URBAN, ntering the same information into both

systems. I understand that the Executive Director and Project Manager are communicating on a

41



weekly basis with each department regarding any issues spotted. With respect to preparing

Funds' staff, the focus has shifted to training Funds' staff one-on-one at their desks as the time

for roll-out approaches. URBAN s scheduled to go live on February 3, 2014.

The Funds' contract wi th the service provider for it s current system Standard Data

Corporation ( SDC ), ends in March 2013. I note that SDC has sued the Benefit Funds for

money it claims to be owed for efforts to develop a new computer system for the Funds, alled

Benefits Management System or BMS, he Funds have answered and counterclaimed for the

money it paid toward that project and SDC has answered the counterclaim. See Standard Data

Corporation v. New York City District Council of arpenters Pension Fund, et al. Docket No.:

HUD-L- 783 3.

E. Overall Condition of he Funds

At the November 18, 2013 court conference, the Executive Director provided a

presentation on the state of the Pens ion, We lfare, Annuity and Apprentice Funds, showcasing

their currently healthy condition. As the Execu tiv e Director reported, the Pension Fund has

recently been certified as bein g in the Green Zone. Under the Pension Protection Act of2006,

the Green Zone is a designation indicating that a pension fund is over 80 funded and is not

expected to have a funding deficiency for the next six years. As of July 1, 2013, he funding

percentage for the District Council s Pension Fund is 89.4 percent . The Exe cu tive Director also

reported that the Welfare Fund has a reserve of 11.8 months meaning that it co uld pay benefits

for that period of time wi thout receiving any contributions . The Executive Director reported

that the rate of eturn on inves tme nts for the Pension and Welfare Funds is favorable compared

to the relevant policy indices. e did not report any concerns wi th respect to the Annuity or

Apprenticeship Funds. e not ed that the Trustees are reviewing alternatives to the

4



Apprenticeship Fund's assets bei ng in a money marke t. See, generally, Transcript of November

18,2013 at 3-11.

Below is a snapshot of he current condition of he Pension and Welfare Funds, ba sed on

the most ecent presentations by ts consultants.

1. The Pension Fund

According to the report of it s investment advisor at the November 19, 2013

Administrative Committee meeting, as of October 31, 2013, he assets of he Pension Fund had a

market value of approximately 2,424,955,000. ome indicia of ow the Fund is performing

include that: Performance for January 1 through October 31,2013 was up 15.67% compared to

the policy index of 13.26%; performance for the 12 months ending October 31, 2013 was

18.36% compared to the policy index of 15.97%; and performance for July through October

31, 2013 the current fiscal year to date) is up 6 , ompared to the policy index of 7.14%.

Looking at the Fund's recent historical performance as a further source of comparison as of

September 30,2012, he assets of he Pension Fund had a market value of app rox ima tel y 2.09

billion and, as of April 30, 2013, the assets of the Pension Fund had a market value of almost

2.3 billion. See Fifth Interim Report of he Review Officer at 34; Sixth Interim Report of he

Review Officer at 34.

Clearly, the value of the Pension Fund's assets has increased over the six-month and

approximately on e-y ear periods, although the past few months reflect a positive performance that

is lower than the benchmark.It

also sho uld be noted

that the value of he Fund's assets includes

the appraised value of he building at 395 Hudson, which is in large part owned by the Pension

Fund and has been an especially strongly performing asset, and that performance percentages are

net of ees.

43



2. The Welfare Fund

a. Condition of he Fund

According to the report by its investment advisor at the November 19, 2013

Administrative Committee meeting, as of October 31,2013, he assets of he Welfare Fund had a

market value of approximately 221,001,083. Performance for January through October 31,

2013 was up 3.58% compared to the policy index of 3.12%; performance for the 12 month

period ending October 31, 2013 was up 4.69% compared to the policy index of 3.91%; and

performance for the current fiscal year to date is up 3.31% compared to 2.95% for the policy

index. Looking at the Welfare Fund's recent historical performance as a further source of

comparison, as of September 30, 2012, the assets of the Fund had a market value of

approximately 203 million and, s of pril 30,2013, he assets of he Fund had a market value

of pproaching 208 million. See Fifth Interim Reportof he Review Officer at 35; ixth Interim

Report of he Review Officer at 35.

As noted in my previous reports, the most important indicator of the Welfare Fund's

health and stability is man hours. For the year ending July 2013, man hours for the Welfare

Fund were slightly below a disappointing 16 and a half million and thus similar to the hours

reported last fiscal year. On the positive side, the Welfare Fund continues to experience

improved performance of its investments. Additionally, a number of new CB s have been

entered that include an allocation increase of over 2 per hour payable by the employers to the

Welfare Fund, further supportingthe health of the Fund. Another positive is that the plan

changes made in June 2012 are having an effect (as explained by the Funds' consultant at the

November 21 Board of rustees' meeting).

44



b. Litigation Initiated y etirees

As previously noted in anticipation of he imposition of etiree premiums effective June

2012, on May 25, 2012, a number of etirees sued the Welfare Fund in the Southern District of

New York. See Patrick Enright et al . v. New York City District of arpenters Welfare Fund, 12

CV 4181 (JPO). The plaintiffs challenged the retiree premium requirement for Welfare Fund

coverage essentially alleging that retirees are entitled to free coverage for life as well as the now

discontinued blue card deduction program. Up until June 2012, he blue card program was the

means by which working dues were collected from union members, basically by the Funds

deducting the dues from the members' vacation benefits based on authorization cards and then

forwarding the dues to the District Council. The blue card program was challenged because the

Funds were not compensated by the District Council for its role. In February of his year, the

District Council reimbursed the Funds app roximately 1.7 million for the cost of administering

the dues deduction program and interest. See id(docket 3 at 4-5).

Since the Sixth Interim Report on July 10 2013, he Court ruled on the parties motions

for summary judgment. The Funds prevailed in defen din g the retiree premium requirement.

With respect to the blue card program, the Court found that there had been a prohibited

transaction under ERISA but the only remaining issue is whether the 1.7 million in

administration fees paid to the Welfare Fund by the District Council is sufficient. See id. at 35.

It is our understanding that discovery was to be completed in December, but may be extended

until Fe bruary 2014.

F. Collections

The Benefit Funds has continued it s efforts to maximize collection of employer

contributions and other monies owed, s detailed below.

45



1. Collection of el inquent Contributions

Virginia mbinder( V&A ) as now been collections counsel for the Funds for over

two years. V&A continues to handle a very heavy collections workload, including 53 active

litigations 136 arbitration matters 21 bankruptcies, 45 matters without pending legal

proceedings, 215 judgment enforcement matters and 38 audit referrals as of he monthly status

report that V&A rovided to the trustees on November 4, 013.

As of he Delinquency Committee meeting held on November 13, 2013, V A's fforts

have resulted in total recoveries of almost 12 million ( 11, 934,218), with associated legalfees

of pproximately 1.65 million and costs of pp roximatel y 175,000. Taking into account audit

fees of 1.7 million that is a net positive of ver 8 million. t is my nderstanding that the net

positive is understated because a significant portion of the audit fees was for time-consuming

anti-corruption audits before V A's enure.

The trustees and V&A are appropriately focused on re ducing audit fees in a way that

does not adversely impact collections and they continually evaluate the costs that are bei ng

incurred. The trustees regularly ask questions regarding audit costs and V&A undertakes to

review costs and makes policy recommendations. That focus is appropriate and sho uld continue.

The rustees should also move forward with finalizing the Revised Collection Policy.

Going forward , additional attention should be gi ven to ways to ways to minimize

delinquencies onthe front end. t is our expectation that the use of i-Remit and URBAN will

enable early identification and remediation of delinquencies, although that remains to be

confirmed. Thought should be given to whether there are any additional efforts that can be

undertaken to av oid delinquencies in the fir st place (be it through increased due diligence

6



bonding requirements, employer guarantees or otherwise) or to enable early detection. This

would seem to require coordination with the District Council and is likely somewhat dependent

on the District Council's IT modernization efforts.

2. Specific Litigation/Settlement Matters

a. Civil RICO Case against Former EST Michael Forde and Others

s oted in prior reports, the Benefit Funds brought a civil RICO ction against a former

EST of he District Council, Michael Forde, and others to recover millions of ollars embezzled

from the Funds by the defendants, who conspired and engaged in a scheme to enrich themselves

at the expense of the rank-and file union members and thousands of other beneficiaries of the

Funds. Third Interim Report of he Review Officer at 51 (quoting Ex. 44 to that report at 2),

Sixth Interim Report of the Review Officer at 38. Following the denial in March 2013 of

motions to dismiss by some of the defendants, even though there has not yet been a

determination of iability the ca se has been in the asset discovery phase.

b. Lawsuit against O'Dwyer ernstein

As noted in the Sixth Interim Report of he Review Officer, in January 2013, he Benefit

Funds brought a legal malpractice case against O'Dwyer ernstein in connection with ODB s

handling of ollections matters. See Sixth Interim Report of he Review officer at 39 and Exhibit

19 hereto. The case is in the discovery phase. In October, the Funds iled a Request for Judicial

Intervention based on ODB failure to respond to discovery demands.

c. Settlement with Stuart GraBois

In June 2013, a former Executive Director of the Benefit Funds who retire in 2011,

Stuart GraBois, entered a settlement agreement with the Funds of fiduciary cl aims the Funds

47



believed they co uld maintain but which Mr. GraBois denied and asserted were without legal or

factual basis. In September, he settlement amount 99,000 - was paid.

G. A Note on Outside Counsel Fees

I have periodically commented on co unsel fees in these interim reports with a particular

interest in economies achieved. Fees of he Benefit Funds outside counsel Kauff McGuire

Margolis LLP KMM ), have decreased over ti me and notably so in the past few months. This

appear s to be due to capable management by the Exec utive Director and his new team of

professionals as well as to the guiding hand of MM

H 395 Hudson: The Renovation Project

The renovation project at 395 Hudson is ongoing. As previously reported the building at

395 Hudson that houses the District Council and the Benefit Funds, among other tenants is

owned by the Pension Fund and the Apprenticeship Fund. Renovation was undertaken to

facilitate operation of he Funds in less space and enable leasing of reed up space. The Benefit

Funds, which previously occupied the tn Floor and part of he 9 Floor of 395 Hudson, will be

located exclusively on the 9 Floor. At he November 21 meeting of he Board of rustees the

Executive Director reported that the renovation of the ninth floor is 90 co mpl ete with

millwork and finishing remaining to be done; he renovation is now expected to be completed by

January 14, 2014. The eighth floor is to be entirely vacated by the Funds (of property and a

couple remaining staff members) by the end of December and demolition work will commence

so that tenants can build out the space to suit their needs.

48



ON LUS ON

Relationships of wnership, they whisp er in the wings

To those condemned o act accordingly and wa it or succeeding kings

And ry to harmonize with songs, the lonesome sparrow sings

There are no kings inside the Gates of den

Bob Dylan

Niccolo Machiavelli wrote many men have imagined republics and princip lities that

never really existed at all Yet the way men live is so far removed from the way they ought to

live that anyone who abandons what is for what sh ould be pursues his downfall rather than his

preservation; for a man who strives fter goodness in all his acts is sure to come to ruin, since

there are so many men who are not good. Machiavelli thus concluded that it is necessary that

a prince who is interested in his survival learn to be other than good, making use of his capacity

or refraining from t according to need.

The history of the District Council has never included a period when it s leaders have

risked ruin to abandon what is for what should be. If that does not change immediately, al l

imaginings of a better day will have been for naught, and a period of protection and

enlightenment wasted.

The walls will suffer no breach. The doors will be opened to scoundrels forced to the

hinterlands for a spell but served well by their minions in the interregnum. It will be no solace

that their reign will be short, for in the absence of what should be, there will one day be ittle le ft

to covet.

49



Dated: New York New York

December 3 2013

Bridget M ohde

Of ounsel

Mintz Levin Cohn Ferris Glovsky and Popeo PC

666 Third Avenue


cc:

AUSAs enjamin Torrance and Tara LaMorte

U.S. Attorney s Office, Southern District of New York

86 Chambers Street, 3` Floor


Barbara S. Jones,Esq.

Zuckerman Spaeder P

1185 Avenue of he Americas 1sr Floo r

New York New York 10036-2603

James M urphy sq.

Spivak Lipton, P

1700 Broadway loo r 21


q.

Respectfully submitted,

Gik/

Dennis M alsh

Review Officer

The aw ffice of Dennis M alsh

415 Madison Avenue 11 Floor


646.553.1357

[email protected]

Documents

Seventh Interim Report of the Review Officer