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LAW OFFICES |
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SCHIPPERS
& BAILEY |
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TWENTY NORTH CLARK
STREET SUITE 3600 |
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CHICAGO,
ILLINOIS 60602 |
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DAVID
P. SCHIPPERS |
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TELEPHONE (312) 263-1200 |
May 26, 1999
VIA HAND DELIVERY & FACSIMILE
Mr. James D. Montgomery
111 W. Washington Street
Suite 823
Chicago, IL 60602
RE: Local 2, LIUNA
Dear Mr. Montgomery:
As discussed in our telephone
conversation, if the undersigned former Members of Local 2's Executive Board
agree to the following, we will withdraw the pending Application for a
Temporary Restraining Order.
The former officers, employees and
Executive Board Members of LIUNA, Local 2, as indicated by their
signatures below, agree, warrant and represent that they collectively, and each
of them, do hereby:
1.
Acknowledge as of Monday, May 24, 1999, all
Executive Board Members of Local 2 were relieved of their Trust pursuant to
Article IX, Section 7 of the International Union Constitution;
2.
Recognize that the Temporary Trustee is the lawfully
appointed Temporary Trustee of LIUNA, Local 2 and has full authority to conduct
the affairs of that entity until such time as his authority is resolved under
the provisions of the LIUNA Constitution or by Order of a Court of competent
jurisdiction;
3.
Cooperate in the delivery of all property, funds,
books, records and assets of any kind in their position to LIUNA and/or the
Temporary Trustee or his designee;
4.
Not represent themselves as the authorized officers
and/or representatives of LIUNA, Local 2 or take any action as the authorized
or acting representative, managers, agents or officers of LIUNA, Local 2 other
than those specified by the Temporary Trustee or his designee;
5.
Not interfere with the implementation of the
Temporary Trusteeship or the functions of the Temporary Trustee or his
designee;
.EXHIBIT
0
Mr. James Montgomery
Page Two of Three
May 26, 1999
6.
Not interfere with the operations of LIUNA, Local 2
under the Temporary Trustee, including interference with the collective
bargaining process, employer relations, employee relations and inter-union
relationships;
7.
Not interfere with the transfer of signatory status
on all bank accounts from the former officers of LIUNA, Local 2 to the
Temporary Trustee of his designee;
8.
Provide a complete accounting of the financial
condition of LIUNA, Local 2 to the Temporary Trustee or his designee or refuse
to provide any and all financial records and an explanation for all receipts,
disbursements and financial transactions of any kind related to LIUNA, Local 2;
9. In no manner or fashion destroy, remove, or otherwise alter the books, records, accounts and other financial documents relating to LIUNA, Local 2; and
10.
Not refuse to provide
access or turn over the keys to the facilities, automobiles, and other assets
of LIUNA, Local 2.
Pursuant to your
representations that you will obtain the required signatures below, LIUNA and
the Temporary Trustee agree to enter and continue its previously filed Motion
for a Temporary Restraining order until tomorrow at a time set by the Court. In
the event you are able to provide us with original signatures to this document
by close of business today, we will withdraw our Motion for a Temporary Restraining
Order. Obviously, in the event you are unable to obtain all of the required
signatures, we will be required to proceed. We would appreciate your verbal
confirmation of this agreement prior to the scheduled 2:30 p.m. Hearing.
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Sincerely |
Sincerely, |
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s/Dwight Bostwick |
s/David P. Schippers |
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Dwight Bostwick |
David P. Schippers |
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Office of the GEB Attorney |
Temporary Trustee |
Mr. James Montgomery
Page Three of Three
May 26, 1999
AGREED AND ACCEPTED
_______________________________________
Officer and/or Executive Board Member
_______________________________________
Officer and/or Executive Board Member
_______________________________________
Officer and/or Executive Board Member
_______________________________________
Officer and/or Executive Board Member
_______________________________________
Officer and/or Executive Board Member
_______________________________________
Officer and/or Executive Board Member
_______________________________________
Officer and/or Executive Board Member
s/James Montgomery_____________________
Attorney for Local 2
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Attorney for John Matassa, Jr.
Laborers for JUSTICE © 1999 Published as
a free service to members of local 2 and the public
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