Protest Decisions

IN RE: KRIS TAYLOR and HOFFA UNITY SLATE,
Protest Decision 2000 EAD 75
Issued: December 29, 2000
OEA Case Nos. PR110302NA, PR110303NA and PR110801NA

See also Election Appeals Master decision 01 EAM 16 (KC)

Kris Taylor, a member of Local 745, and the Hoffa Unity Slate (the "Hoffa slate") filed pre-election protests pursuant to Article XIII, Section 2(b) of the Rules for the 2000-2001 IBT International Union Delegate and Officer Election ("Rules") against Teamsters for a Democratic Union ("TDU"), the Teamster Rank and File Education and Legal Defense Foundation ("TRF") and the Leedham Rank and File Power Slate (the "Leedham slate"). The protests allege that these entities violated their obligations under Article IX and/or XI of the Rules in a number of related respects. We have consolidated these protests for decision.

Election Administrator representatives Michael Nicholson and Bruce Dubinsky investigated the protests. We address the allegations of the protests seriatim.

1. Both protests allege that the initial Campaign Contribution and Expenditure Reports ("CCERs") filed by TDU and TRF violate Article XI, Section 2(d)(1)(i) of the Rules, which requires that the "first CCER must include all requested information retroactive to the first contribution and the first expenditure for the 2000-2001 International Union Delegate and Officer Election…" and through May 31, 2000. Both protests note that TDU's and TRF's initial disclosures state that they cover only the period from May 1 through May 31, 2000, and note activity by these entities before May 1, 2000 that the protestors assert was reportable campaign activity. The activities noted by the protestors include the November 1999 TDU convention, at which, as we held in Pope, 2000 EAD 4 (August 1, 2000), pp. 4-9, Tom Leedham made clear that he was a candidate for International office in the 2000-2001 election (the "Election"), as well as pre-May 1, 2000 publication of articles favoring and opposing candidates in the Election, and other activities.[1]

TDU does not claim that it made no Election-related expenditures during the period before May 1, 2000. Instead, as a matter of its own internal bookkeeping, TDU allocated 22 per cent of its expenditures for the period before May 1, 2000 as presumptively electoral. This presumptive figure was TDU's actual percentage of electoral expenditures during the first sixth months of 1999, during the period of the Southern re-run campaign.

TDU tested that figure by applying it to the issues of its publication Convoy Dispatch from the time of the 1999 TDU convention until May 1, 2000, and its staff found that the campaign-related content of these issues was well below 22 per cent, and was, according to TDU, negligible.

Taylor asserts in his protest that "a review of TDU's Convoy Dispatches created and published prior to May 31, 2000, show an abundance of endorsements and material intended to both promote and oppose known candidates."

We have examined carefully each issue of Convoy Dispatch published since the Fall 1999 TDU convention and before May 2000. It is true that a number of the articles mention and praise or criticize individuals who hold and/or are now candidates for International office, or who are or have run for delegates positions for the IBT 2001 convention. However, very few of these articles do so in the context of the Election. Instead, most articles that concern those who are delegate or International officer candidates in the Election concern their performance of other responsibilities they have as officers of their local unions or of the International, outside of the context of the Election. Our examination satisfies us that, at most, five (5) per cent of the editorial content of these Convoy Dispatch issues constitutes campaign-related expenditures that should have been reported for the period from TDU's Fall 1999 convention until May 1, 2000.[2]  TDU should accordingly amend its initial CCER to reflect these campaign expenditures for the pre-May 1, 2000 period.[3]

Our investigation revealed other expenditures for the pre-May 1, 2000 period that must be reported by TDU on an amended CCER. These include the expense of that portion of the January 2000 meeting of TDU's international steering committee referred to in the March/April 2000 issue of Convoy Dispatch that concerned candidate endorsements for the Election, and any related expenses for such purposes. In addition, TDU should report on an amended initial CCER the costs associated with Tom Leedham's speech at the Fall 1999 TDU convention.

As to pre-May 1, 2000 contributions, TDU should amend its CCER to reflect contributions from permitted sources sufficient to cover such pre-May 1, 2000 expenditures. If insufficient funds were received from permitted sources, such expenditures must be covered by post-May 1, 2000 contributions, with interest from the time of the expenditure at a commercially reasonable rate.

Accordingly, this aspect of the protests is GRANTED, and TDU is ordered to amend its initial CCER in a manner consistent with the foregoing.

2. The protests assert that TDU failed to report expenditures in its initial CCER related to the supervision of Les Cadman for election related clerical services, and that it failed to report staff expenditures for the purchase of software from Cardservice International. In the initial TDU CCER, expenditures for Cadman himself and Cardservice International software itself are reported. The protests challenge the failure to report any cost of supervising Cadman or of negotiating the Cardservice software purchase. In addition, the Hoffa slate faults TDU CCER No. 2 in that it lists "credit card fees and interest" paid totaling $384.21 and uncleared checks payable to the card issuer in the amount of $700.33 (actually $700.83).

TDU asserts that these allegations reflect a misapprehension about the nature of its accounting system. TDU operates on a cash basis accounting system, which is a normal method of accounting for non-profit organizations, and in fact many labor organizations. Under this basis of accounting, an expenditure is reported when the debt accrued related to that expenditure is paid, rather than when it is accrued (as would be the case if an accrual accounting method were followed). Thus, under the cash basis accounting method, an expenditure may appear on a report, such as the initial CCER, before other expenditures related to that expenditure appear, with the difference as to reporting dates reflecting the fact that the amounts were paid on separate dates, and in separate reporting periods. Similarly, a payment may be recorded to a payee while other expenditures to that payee are the subject of future check payments in a subsequent CCER period. Our investigation revealed that that is precisely the case here, and that the expenditures that the protestors allege are missing were reported by TDU in its subsequent CCER. Further, with regard to the allegations involving the lack of any cost of supervising Cadman, by the nature of the accounting system that is utilized by TDU, it allocates a portion of salaries and related expenses based upon a breakdown of time by its personnel. (See discussion hereinafter.) Accordingly, the expense related to said salaries are recorded on the CCER for the period when paid, consistent with the treatment of other expenses. Therefore, while the expense related to Cadman was paid in one CCER period, the payroll related costs of supervising Cadman appeared on the subsequent CCER vis-a-vis the allocation of time and corresponding payment of those salaries.

This aspect of the protests is accordingly without merit, and it is DENIED.

3. The Taylor protest challenges the reporting of Convoy Dispatch expenditures in TDU CCER No. 2, which covers the period June 1 through September 30, 2000. Thus, Taylor notes that "an itemized expenditure … of $5,835.98 to Grand Blanc Printing Company…" is reported on this CCER. This company prints Convoy Dispatch. Taylor alleges that in each issue of Convoy Dispatch in this reporting period, "TDU has made contributions through endorsements of candidates and promotional articles … [and that] TDU has not included in its report the entire expense of printing of those editions of the Convoy Dispatch and it has not, therefore, accurately submitted its CCER or accurately represented the actual expense of its contribution to the Leedham campaign.

We have obtained the underlying invoices for the printing expenses. They accurately reflect the printing costs for the challenged issues of Convoy Dispatch. This aspect of the protest is DENIED.

4. The Taylor protest next challenges TDU's reported payment of $11,425.67 in its CCER No. 2, which is represented as an allocable expense for Election-related activities as discussed in our earlier decision in Taylor, 2000 EAD 40 (October 24, 2000). Taylor contends that "TDU's description of this expense as 'rent, allocation of expenses' is not a sufficient "clear and concise description' as is required by the reporting form and the Election Rules.[4]  Much greater detail should be required so that an examination of the report will indicate whether TDU is in fact in compliance with the allocation accounting discussed in Taylor."

This item of reporting was created by TDU for purposes of its adoption of the accounting system previously approved and known as the Huddleston system. Thus, since the decision in Gully, 91 EAM 158 (June 12, 1991), aff'g, Sargent, P249 (May 21, 1991), TDU has thus been required to segregate IBT member funds used for campaign activities from other revenues, and to allocate its costs between permitted campaign activities and other non-campaign activities. Under this system, pursuant to Election Officer/Administrator direction, TDU periodically determines the percentage of overhead and time spent by shared staff on campaign activity and reimburses TRF (with which it shares space and staff) for this amount from permitted campaign contribution sources. The proper maintenance of this system assures that no improper funds are spent to campaign in the IBT election, this resource sharing arrangement does not violate the Rules. Hoffa, PR39 (March 10, 1998), aff'd, 98 EAM 341 (April 9, 1998).

Halberg, 95 EAM 20 (October 3, 1995), teaches that the keystone of this system is assurance that "TDU receives funding for … all [its] campaign activities derives from union members." Id., p. 3. It falls to the Election Administrator to assure that this is so, and the primary purpose of the CCER reports is to enable the Election Administrator to verify compliance with Article XI of the Rules with respect to campaign contributions by those parties that are required to file such reports.

In Halberg, the Election Appeals Master addressed the tasks to be undertaken by the Election Officer in order to assure compliance with the election rules in this regard:

[In Sargent, P249], Mr. Holland determined that the relationship between TDU and TRF did not violate the Rules because both organizations had adopted the "Huddleston System" of accounting, whereby expenses were allocated between campaign and non-campaign categories, and all campaign activities, and the expenses associated with those activities, were paid for by TDU. Id. at 21.

Mr. Holland's decision in Sargent, issued on May 21, 199[1], is thoroughly investigated and comprehensive. However, that decision, which addressed the relationship between TDU and TRF more than four years ago, cannot, standing alone, support the factual findings made by the Election Officer in the instant case concerning the present relationship between TDU and TRF. The Election Officer must make at least a preliminary inquiry into the current relationship between TDU and TRF in order to determine whether both organizations still utilize the "Huddleston System" for allocating campaign expense.

Id. at 4-5.

In Halberg on remand, P19 (December 14, 1995), the Election Officer described her review of the sharing of resources between TDU and TRF. Her investigation examined whether the sharing of resources between these entities followed the Huddleston system, in order to accomplish the proper allocation of campaign and non-campaign activities and resources. Thus, on remand the Election Officer required TDU to show in detail the manner in which this allocation was accomplished, in order to show that its system comported with the requirements set forth in the Sargent decision.

The Halberg remand investigation revealed that in the immediate aftermath of the 1991 election, TDU and TRF institutionalized the allocation system that had been in effect during the 1991 election campaign. Allocation through December of 1994 was based upon the percentages between campaign and noncampaign categories from the 1991 election. In January 1995, TDU implemented a refinement of the allocation system to utilize for the upcoming election period.

Under the election period allocation system, each staff member maintained and submitted daily time sheets that were tabulated to determine total time spent in various categories. Weekly summaries were prepared and compiled. Each month these reports were closed out and allocation figures were determined. TDU-related time was percentaged against total time to establish a "TDU percentage" for each staff person. Salaries, benefits, and overhead were paid by the respective organizations based on this percentage.

During the course of the Halberg remand investigation, the Election Officer reviewed samples of current activity reports of the TDU/TRF staff. A narrative instruction sheet that clearly defined the activities to which staff must allocate their time accompanied the reporting forms. The classification of activity was found to properly distinguish between campaign and non-campaign activity. The Election Officer's investigation also revealed that the staff time charged to TDU was more inclusive than that used and approved in 1991. All membership meetings and organizing activities were paid for by TDU, even though many of these would not involve electoral activity.

The Election Officer in Halberg reviewed examples of staff activity reports indicating that each member of the TDU/TRF staff was keeping such reports. The organization's bookkeeper reviewed these reports on a monthly basis to ensure accuracy and correct any entries that he believed were in error. He then calculated the allocation fraction and the portion of staff time associated with campaign activities.

In the Halberg remand investigation, the Election Officer concluded after review that the Huddleston system continued to be properly applied. This review included an examination of TDU's classification of activities, its reports of staff activities, its auditing system, and the advances made to TRF to address any interest accrual. This finding did not relieve TDU or TRF from any future Election Officer determination that the approved practices were not followed and that TRF funds, or funds from other impermissible sources, were used to support TDU's campaign-related activity. Based upon the further investigation undertaken by the Election Officer pursuant to the remand in Halberg, no such impermissible funding was found to exist at the time the remand decision was issued.

The Election Administrator has continued to monitor TDU's compliance with the Huddleston system, and finds continued compliance for the time covered by CCER No. 2. In doing so, the Election Administrator has found that the category complained of by Taylor adequately describes TDU's allocation under Huddleston. In so stating, however, it must be remembered that the Election Administrator has full audit access to TDU's underlying allocation data, and this data was provided by TDU in a fully cooperative manner. By examining this data, the Election Administrator is satisfied that TDU continues to follow the Huddleston system appropriately.

It is not the purpose of the CCER reports required by the Rules to provide a line-item disclosure of TDU's (or any other entity's) day-to-day operations. Instead, the CCER reports form a baseline from which the staff of the Election Administrator, including its forensic accountant, may (and has) subject the entity to full audit scrutiny. This audit scrutiny was fully discussed in Taylor, supra, and our conclusions there as to TDU continue to hold.[5]

For the foregoing reasons, this aspect of the protests is DENIED.

5. The Taylor protest challenges TDU CCER No. 2 in its "allocation of less than $3000.00 per month to the campaign…" for June, July, August and September 2000. In reliance on its allegation that this reported amount understates TDU Election-related expenses, Taylor relies upon the discussion in Taylor, supra, where we found that TRF "reported that it received $2,400 in rent reimbursement from TDU for 1998 and $117,960 for 'Reimbursement of costs based on time allocations of staff activity between TDU and TRF.'" According to Taylor, "this tends to indicate that TDU's record keeping of its activities in (sic) not being accurately done."

The amounts reported by TDU in its CCER No. 2 were verified by Election Administrator forensic account Bruce Dubinsky. That form indicates that eight payments for the reporting period, totaling $11,425.67, were made by TDU to TRF in conformance with the Huddleston allocation system. The payments, and the allocations upon which they are based, were verified and appear in all respects to be accurate.[6]

Accordingly, this aspect of the protests is DENIED.

6. The protests challenge TRF's Supplemental Forms No. 1 to its CCER Nos. 1 and 2 in their reporting of $9,624.45 as legal expenditures and $37,000.45 as accounting expenditures for time spent by TRF staff who are not legal and accounting professionals. We sever these protest allegations for further investigation.

7. The Hoffa slate alleges that TRF improperly reported in-kind legal services donated by attorneys Barbara Harvey and Paula Alan Levy. Thus, its initial CCER Supplemental Form No. 1 reported that it received a contribution of services from Levy valued at $3,000.00, and on its second such filing it reports a contribution of services from him valued at $2,000.00, while reporting a "total amount received to date of $2,000.00.

In addition, in its second CCER Supplemental Form No. 1, TRF reports receipt of in-kind donation of legal services from Harvey valued at $1,000.00 and a "total amount received to date" from her in the amount of $4,000.00, even though no in-kind contributions from Harvey are reported in TRF's initial report.

TRF acknowledges the inaccuracy of its filings in the manner alleged. It has agreed to file supplemental reports with the Election Administrator. Accordingly, this aspect of the Hoffa slate challenge is deemed RESOLVED.

8. Both Taylor and the Hoffa slate challenge the manner in which certain local unions have subsidized the attendance of delegates to TDU's November 2000 convention, based upon Election-related activity occurring at that convention. The protestors also allege that the Leedham slate is a party to this violation. Both protestors challenge not only the receipt by TDU of convention registration fees paid by local unions, but local union payments for travel to and lodging and meals at the convention. Both protests also assert that these expenditures by local unions constitute improper union contributions to the Leedham campaign.

On October 25, 2000, I wrote Steve Richmond of Local 1149 and TDU in response to Richmond's letter of September 19, 2000 requesting that I determine whether the local would be in violation of the Rules by paying the lodging, travel and registration expenses of Local 1149 members attending the 2000 TDU convention. In that letter, I noted my decision in Taylor, supra, holding that TDU is continuing to properly allocate and segregate its income and expenditures to assure that its campaign-related expenditures are made only from sources permitted under the Rules. I also noted that Election Officer Cherkasky determined that at the 1997 TDU convention less than 14% of the activity was campaign-related. Hoffa, PR 39 (March 10, 1992), aff'd, 98 EAM 341 (April 9, 1998).

In this context, I informed Richmond and TDU that "it would be proper for the local to pay the lodging, travel and meal expenses of members [attending the convention] assuming the percentage of campaign related activity at the convention is similar to 1997 [and that] I would view any such campaigning as incidental to legitimate union business." In so stating, I recognized that "[u]nion funds may be utilized to pay the expenses of a trip undertaken for union business even if incidental campaign activity occurs during the period of travel. See, e.g., Del Pizzo, P727, p. 5 (July 18, 1991)."

I further informed Richmond and TDU that "TDU should promptly refund to the local that portion of any registration fee used to pay for the program itself which it determines were campaign related. Otherwise, union funds would be being used for campaign purposes in violation of Article IX, Section 1(b)(6) of the Rules." I noted that TDU had "verbally advised me that it w[ould] comply" with this.

Subsequently, on October 31 and November 1, 2000, counsel for the IBT and the Hoffa slate requested that I withdraw from the position announced in the Richmond letter. The IBT enclosed pages from the October/November 2000 issue of Convoy Dispatch concerning the upcoming TDU convention, arguing that these pages make it "quite clear that IBT partisan politics are a principal component of the official convention agenda, and it will be unlikely that campaign related activity occurring at the convention will be merely 'incidental.'" IBT counsel further noted that in 1997 the IBT legal department advised against local union subsidization of TDU convention attendance. Counsel for the Hoffa slate reiterated these concerns, and stated that the "raison detre (sic) of the [TDU] Convention is to promote Mr. Leedham and the Rank & File Power Campaign.

I have not withdrawn the Richmond letter.

In its protest, the Hoffa slate renews its claims, and the Taylor protests adopts similar arguments. Each protestor asserts that the level of campaign related activity at the TDU convention argues against the incidental campaigning rationale of the Richmond letter. Each relies upon the pre-convention issue of Convoy Dispatch, and claims, as stated in the Hoffa slate protest, that campaign activities "are inextricably intertwined with the event and constituted the clearly dominant activity of the event. In addition, the Hoffa slate urges that I rule that TDU has now forfeited its status as an independent committee because it "is the Leedham campaign" (emphasis in original), supporting this claim with only a general statement that this is warranted by "a comparison of the CCERs filed by the Leedham slate and TDU…"

TDU responded to the protest by a providing an extensively detailed review of activities at the convention, its 25^th annual, which was held on November 3-5, 2000 in Cleveland. While it would unduly lengthen this decision to spell out in detail the extent of TDU's submission, it is important to note that TDU analyzed each event at the convention for campaign related content, including all 36 breakout meetings (including 23 workshops), a number of jurisdictional meetings (airline, freight, UPS, etc.) and special meetings (Teamster women's network, Black caucus). Five of these thirty-six meetings were campaign related. In addition, campaign related content of other portions of the convention was determined by an analysis of the nature of the event. Thus, in the case of each general session and breakout session, activities were divided into 15 minute segments in order to assure increased accurate content analysis. Breakout and session leaders we interviewed to determine content. Workshops were fractionally weighted if they were conducted simultaneously. If podium speakers were candidates for office or if podium speakers' remarks were "campaign" in nature, those speakers were allocated as campaign related. This was the same allocation methodology used to compute campaign content at the 1997 and 1998 TDU conventions.

Based on this methodology, 20.5% of TDU's 2000 convention was determined to be campaign related, and 79.5% was determined to be non-campaign related. This compares with 14% and 21% campaign related results using this methodology for the 1997 and 1998 conventions. This places the result of this analysis well within the range of past determinations.

In accordance with the Richmond letter, TDU's refund to IBT local unions that paid the $160.00 convention registration fee is $13.11 per person. This latter sum represents 20.5% of the non-meals, programmatic portion of the registration fee, which totals $63.95.

I adhere to my determination in the Richmond letter that this approach is consistent with the Rules, and precludes any improper use of union finds to subsidize campaign-related activity. Thus, expenditure of union funds to pay the travel, hotel and meal expenses of a trip undertaken for legitimate union purposes is permitted under the Rules, regardless of incidental campaigning at such an event. See Del Pizzo, supra. As provided in Article VII, Section 11 of the Rules, incidental campaigning is not a violation of the Rules. The protestors have offered insufficient evidence to counter the significant evidence offered by TDU that such campaigning as did occur at the 2000 TDU convention was incidental to the legitimate union business conducted there concerning the non-electoral affairs of the union and activists involved in it.[7]

The decision in Hoffa, P43 (January 9, 1998), aff'd, 98 EAM 339 (January 30, 1998), cited by the IBT, is not to the contrary. Instead, the decision did not address the issue presented here, since no local union funds were used there to pay for travel to TDU's convention. Instead, the decision merely notes the opinion of IBT's legal department that such use of union funds should be avoided.

For the foregoing reasons, this allegations stated in this aspect of the protests is DENIED.

9. The Hoffa slate protests TDU's failure to report any expenditure for its web site on its CCER. Our investigation revealed that TDU has never paid any costs for its website, and instead has received it on a free basis from its website provider, IGC. TDU does, however, pay a monthly fee for its email account. At the time TDU established its website, and today, it is not unusual for internet service providers to provide free, limited capacity websites to their customers. TDU does, however, pay for the maintenance of its website, which is performed by its staff, and whose time for such activity is allocated under the Huddleston system. Accordingly, this aspect of the protest is DENIED.

10. Finally, the Hoffa slate argues that all of TRF's contributors that are not IBT members must be identified on TRF's CCER forms, and further argues that TRF has failed to disclose in its CCER reports the contributions of foundations or other charitable sources from which it has received donations during the reporting periods established by Article XI of the Rules. TRF's unredacted reports do, however, continue to disclose the identity of TRF's contributors, and those reports do disclose donations to TRF from foundations and other charitable sources. The identity of these contributors, however, is not provided to any parties other than the Election Administrator and his staff.

Contrary to the Hoffa slate, this limitation on disclosure of such contributor information is consistent with the Rules. Thus, Article XI, Section 2(e) of the Rules provides for:

limited disclosure to candidates from independent committee CCERs, but only to the extent that the identity of the contributors or their Local Unions not be revealed. With respect to contribution information reported by independent committees, only the total amount of contributions and total amount of contributors should be released to candidates.

Consistent with the foregoing, TRF's unredacted CCERs report its receipt of the total amount of contributions for each reporting period and the total number of contributors. Thus, for example, TRF CCER No. 2 reports $29,348.50 in monetary contributions from 97 contributors. This information is the limit of what may be disclosed to the Hoffa slate or any other candidate by the Election Administrator.

Article IX, Section 2(e) of the Rules makes no distinction regarding the disclosure of the identity of IBT member and non-IBT member contributors. Instead, all contributors to independent committees are protected from having their names disclosed to any party except the Election Administrator. Nor is any distinction made regarding disclosure of the identity of contributors to independent committees that are legal and accounting funds and those that are not. Disclosure other than to the Election Administrator is barred in each instance.

This rule for independent committees reflects the rulings of the Second Circuit that "TDU and TRF were not adequately represented by the IBT leadership with respect to the Consent Decree, and cannot be bound by its provisions," and that the Election Officer lacked authority, "as an officer of the district court … to compel TDU and TRF to disclose 'to the union leadership … forms bearing the names of their supporters and associate[s]…" United States v. IBT, 968 F.2d 1506, 1509, 1511, 1512 (2d Cir. 1992)(emphasis supplied); accord, United States v. IBT, 981 F. Supp. 222, 231 (S.D.N.Y. 1997). The U.S. Attorney took the position that the current rules should require independent committees to reveal their contributors only to the Election Administrator, and the Department of Labor accepted that argument, as reflected in the text of Section 2(e). See DOL letter of April 21, 2000, at 10; see Election Administrator letter of September 15, 2000, at 4.

For the foregoing reasons, this aspect of the protests is DENIED.

Any interested party not satisfied with this determination may request a hearing before the Election Appeals Master within two (2) working days of receipt of this decision. The parties are reminded that, absent extraordinary circumstances, no party may rely upon evidence that was not presented to the Office of the Election Administrator in any such appeal. Requests for a hearing shall be made in writing, shall specify the basis for the appeal, and shall be served upon:

Kenneth Conboy

Election Appeals Master

Latham & Watkins

Suite 1000

885 Third Avenue

New York, New York 10022

Fax: 212-751-4864

Copies of the request for hearing must be served upon all other parties, as well as upon the Election Administrator for the International Brotherhood of Teamsters, 727 15^th Street NW, 10^th Floor, Washington, DC 20005, all within the time period prescribed above. A copy of the protest must accompany the request for hearing.

 

William A. Wertheimer, Jr.

William A. Wertheimer, Jr.

Election Administrator

cc: Kenneth Conboy

2000EAD75

 

DISTRIBUTION LIST VIA FAX AND UPS NEXT DAY AIR:

Patrick Szymanski

IBT General Counsel

25 Louisiana Ave. NW

Washington, DC 20001

 

Bradley T. Raymond

Finkel, Whitefield, Selik, Raymond,

Ferrara & Feldman

32300 Northwestern Highway

Suite 200

Farmington Hills, MI 48334

 

J. Douglas Korney

Korney & Heldt

30700 Telegraph Road

Suite 1551

Bingham Farms, MI 48025

 

Barbara Harvey

645 Griswold

Penobscot Building

Suite 1800

Detroit, MI 48226

 

Tom Leedham c/o Stefan Ostrach

110 Mayfair

Eugene, OR 97404

 

Betty Grdina

Yablonski, Both & Edelman

Suite 800

1140 Connecticut Ave. NW

Washington, DC 20036

 

Public Citizen Litigation Group

1600 20^th Street NW

Washington DC 20009

 

Teamster Rank and File Education and Legal Defense Foundation

c/o Alan Jacobson

7437 Michigan Avenue

Detroit, MI 48210

 

Bruce Dubinsky, CPA

Klausner, Dubinsky & Associates, P.C.

Suite 640

4520 East West Highway

Bethesda, MD 20814

 

James L. Hicks, Jr.

Suite 1100

2777 N. Stemmons Freeway

Dallas, TX 75207

 

Kris Taylor

2825 Foxglen

Mesquite, TX 75150