Protest Decisions

OFFICE OF THE ELECTION SUPERVISOR

for the

INTERNATIONAL BROTHERHOOD OF TEAMSTERS

IN RE: LUCIO REYES,                               )           Protest Decision 2011 ESD 281

                                                                        )           Issued: June 18, 2011

             Protestor.                                           )           OES Case Nos. P-221-031411-FW               

____________________________________)

            Lucio Reyes, member of Local Union 601, filed a protest pursuant to Article XIII, Section 2 of the Rules for the 2010-2011 IBT International Union Delegate and Officer Election (“Rules”).  The protest alleged Hoffa-Hall 2011 and the No Mas Lucio slate in Local Union 601’s delegates election received impermissible contributions of union resources to assist their campaigns.

 

            Election Supervisor representatives Rochelle Goffe and Michael Miller investigated this protest. 

Findings of Fact

 

            Local Union 601 is a seasonal agricultural local union based in Stockton, California, with a membership that fluctuates between approximately 3,000 members and nearly 7,000 members due to an influx of seasonal members working during the July-October agricultural season.  Roughly half of its members speak Spanish as their primary language.  At the time of the events described here, protestor Reyes was principal officer of the local union. 

Local Union 601 held its nominations meetings for the delegates election on August 18, 2010.  Ballots were mailed September 24 and counted October 18, 2011.  The No Mas Lucio slate of candidates led by local union president Maria Ashley Alvarado defeated Reyes and his slate of candidates for all positions.  One month later, Alvarado defeated Reyes in the local union officers election, ending Reyes’ continuous service as principal officer of the local union that dated to 1992.  Reyes supports and has supported Fred Gegare and his slate of candidates for International office, while Alvarado and the No Mas Lucio slate supports the Hoffa-Hall 2011 slate, which includes Rome Aloise, a candidate for IBT vice president at large.

 

            Reyes’ protest alleged the following as violations of the Rules:

a.       Targeting of Lucio Reyes.  Reyes claimed that Aloise and both slates “discriminated against” him when Reyes decided to support the candidacy of Fred Gegare.  The protest further described a meeting where supporters of the No Mas Lucio slate discussed the possibility of oversight or trusteeship of Local Union 601 by the IBT.

b.      Campaign use of union facilities.  The protest stated that the charged parties held planning meetings, including a dinner, for the delegates campaign at the nearby Stockton, California offices of Teamsters Local Union 439 and did not pay for use of the facility.

 

c.       Campaign use of union resources.  Reyes claimed that Sam Rosas, principal officer of Local Union 439, supplied food and beverage purchased by Local Union 439 to members of the No Mas Lucio slate at a dinner meeting at the local union hall and, on another occasion, met with members of the slate in a hotel room that had been rented by the union for the conduct of union business.  Reyes also alleged that Rosas made multiple copies of Alvarado slate campaign literature on a Local Union 439 copying machine and that Local Union 439 staff members translated Alvarado campaign literature from English to Spanish.

d.      Illegal contributions.  The protest alleged additional improper contributions to the Alvarado slate by Sam Rosas, including payment for two meetings held at restaurants, and the manufacture of t-shirts and stickers imprinted with the “No Mas Lucio” slogan.

            While the protest allegations concern events that occurred many months before the protest was filed, Reyes first learned of the allegations when he spoke with Chris Wilson, a retired member of Local Union 601, on March 10, 2011.  Reyes filed this protest the next day.  When interviewed, Reyes stated that he had no first-hand knowledge of the alleged violations and directed the OES investigator to Wilson and to Raul Madera as witnesses.

            Before retiring, Chris Wilson worked in canneries under Local Union 601’s jurisdiction and as a business agent and organizer for the local union; during that time, Reyes was principal officer.  In her interview with our investigator, Wilson stated that she was recruited to work for the No Mas Lucio slate and her husband, Dave, was elected as a delegate on that slate.  After she participated in initial planning activity, she became disenchanted when she learned that Alvarado was to head the slate because she believed she had been forced into retirement when Alvarado, then her business agent, failed to act on her behalf.  Wilson nevertheless continued to attend campaign strategy sessions, although she said she did so more as an observer than as a participant.

            According to Wilson, a number of strategy sessions for the No Mas Lucio slate were held, with all of them involving Sam Rosas, principal officer of Local Union 439.  The first meeting Wilson knew of occurred at Perko’s Café near the Stockton airport in nearby Manteca, California.  The other meetings, however, were held at the Local Union 439 office in Stockton, less than a mile from Local Union 601’s hall.  A couple of months after the original Perko’s Café meeting and after several meetings at Local Union 439’s hall, Wilson said the group met in the Stockton Marriott Hotel.  She stated that the group moved its meeting site to the Marriott because they understood that using the local union hall for a campaign purpose without paying for it violated the Rules. 

Wilson claimed that Rosas paid for the meal at the original meeting at Perko’s Café.  Wilson also stated that a barbecue dinner was held for the slate at Local Union 439, with the meat for the meal provided by Rosas and the soft drinks taken from the local union refrigerator.  She could not specify if the food and beverages were purchased by the local union or provided at Rosas’ expense, nor could she estimate the value of the items supplied.

            In addition to the uncompensated use of Local Union 439’s hall, Wilson also told our investigator that at one meeting she complained about the lack of campaign literature supporting her husband’s candidacy.  Wilson said Rosas responded to this complaint by leaving the meeting room and making copies of a campaign flyer using local union copying equipment.  In addition, Wilson stated that when she noted aloud that the campaign literature was not translated into Spanish, Rosas said he would have the translation done by “the girls in the office.”  Wilson acknowledged that she never received the translated materials, but claimed that Rosas did provide translation services for other campaign materials using his office staff.  According to Wilson, Alvarado was present and heard Rosas’ statement that the translation service would be provided by local union office staff, but did not object.

            Raul Madera, a rank-and-file member of Local Union 601, was elected as a delegate on the No Mas Lucio slate in October 2010.  Madera told our investigator that he was recruited to work on an anti-Reyes slate of candidates at about the same time as Wilson was approached.  According to Madera, Alvarado, with the support of IBT vice president Aloise and Local Union 439 principal officer Sam Rosas, began planning during the summer of 2010 to run against Reyes in the delegates election and to unseat him as local union principal officer. 

Madera stated that he attended at least six strategy meetings held in the office of Local Union 439 between July and September 2010 to discuss strategy for campaigning against Reyes. He told our investigator he did not know whether any payment was made for use of the hall.  He also stated that he attended a dinner at Local Union 439 hosted by Rosas, with the stated purpose of expressing support for Alvarado and her attempt to defeat Reyes.  Madera confirmed Wilson’s report of the meetings at Perko’s Café and the Stockton Marriott.  Again, he could not identify how the food or facilities were purchased but stated, as to the Perko’s breakfast, that neither he nor his wife paid for their meal.

            Madera supported Wilson’s statement that Rosas used Local Union 439’s photocopier to make copies of campaign literature.  Madera said the photocopying occurred during a meeting of the planning group on July 3, 2010.  He said that Rosas left the meeting room and used the copying machine to make about 300 flyers for distribution by the slate.  He stated that he did not know if Rosas or Alvarado paid the local union for the use of the copy machine.  

            Rosas told our investigator that, as an active supporter of Aloise and Hoffa-Hall 2011, he favored Alvarado’s No Mas Lucio slate of candidates in the delegates election at Local Union 601, as they also were Hoffa supporters.  Concerning use of the Local Union 439 hall for campaign purposes, Rosas stated that he made his facility available to both the Hoffa and Gegare slates and produced a letter dated August 16, 2010 outlining the availability of the hall to all campaigns and the fees for use.  Rosas admitted, however, that the Alvarado planning group used the Local Union 439 hall on “three or four” occasions, and never paid the $25.00 usage fee or the $250.00 deposit listed in his August 16 letter.

            Rosas admitted attending the breakfast at Perko’s Café, but denied paying for the meal, stating they “had a collection.”  He also admitted to having a meeting with the Alvarado group in a meeting room at the Stockton Marriott Hotel.  He explained that the room had been reserved by the local union to hold arbitration hearings, which he attended in his capacity as principal officer.  When he received a call from Alvarado asking for a meeting, he agreed to do so and suggested  using the room, as the scheduled arbitrations had been completed and the room was no longer in use.

            Rosas denied that the Local Union 439 copying machine was ever used to photocopy any Alvarado campaign literature or that Local Union 439 office staff ever translated Alvarado campaign material into Spanish.  He denied attending any dinner given for the Alvarado slate or holding such a dinner at the Local Union 439 premises.  Finally, he denied any involvement in the production or distribution of No Mas Lucio stickers or t-shirts.

            Maria Ashley Alvarado told our investigator that her slate met to discuss the campaign at Local Union 439’s hall only “a couple of times.”  She admitted that she never paid for the use of the hall.  She denied any knowledge of a breakfast meeting at Perko’s Café or that there was a barbecue or steak dinner where Rosas provided food.  She did recall one meeting at the Local Union 439 hall where someone other than Rosas invited the group to eat some food said to have been left over from another event.   Further, she stated that she met with Rosas only in the public lobby of the Stockton Marriott Hotel.  However, when our investigator told her that Rosas had already said that slate members met with him in a hotel conference room, Alvarado changed her account and admitted meeting Rosas in the conference room.

            Alvarado conceded that at the Marriott meeting, a quantity of t-shirts and stickers imprinted with “No Mas Lucio” were delivered.  While she claimed that the slate had not ordered or paid for the campaign materials, she did not identify Rosas as the source of the clothing and stickers, stating when first interviewed that “some guys” whom she did not know brought the boxes of printed items in to the meeting room.  In a subsequent interview, she maintained that she did not know who paid for the shirts and stickers and “didn’t care” who did so, as she was just happy to have the support.  During this same interview, Alvarado finally stated that she understood the shirts and stickers had been purchased by the Hoffa campaign.  Contrary to her initial statement on this subject in which she said she did not know the identity of the person(s) who delivered the material, she stated during the second interview that Bill Motter delivered them.  She provided our investigator with contact information for Motter from memory and identified him as a friend, further undermining the credibility of her initial statement that the shirts were delivered by person(s) unknown to her.

            Motter, a member of Local Union 439, told our investigator that he picked up the shirts from the garage in Modesto, California of Ormar Locklear, a retired Teamster.  Motter brought the shirts into the conference room at the Stockton Marriott where Rosas, Alvarado and others were meeting. 

Locklear told our investigator that he retired some ten years ago after about thirty years as a Teamster.  He said he has worked on every Hoffa campaign since 1995 and makes his garage available as a storage site for campaign merchandise.  He stated that the shirts were purchased by Aloise from a shirt-printing operation in Berkeley, California and delivered to his garage, from which Motter picked them up in early August.  Counsel for the Hoffa-Aloise campaign provided our office with an invoice from Lil’s Embroidery in Denver, Colorado dated July 14, 2010 for 96 t-shirts at a total cost of $640.57.  The space on the invoice reserved for the purchase order number reads simply “Lucio.”  The Hoffa-Aloise CCER report for the second reporting period shows an expenditure with Lil’s Embroidery on July 16, 2010 for t-shirts; this entry is consistent with the invoice. 

Alvarado denied that Local Union 439 provided translation services to her campaign; instead, she stated that she and one of her volunteer campaign assistants translated all campaign materials for the No Mas Lucio slate.

 

Analysis

The delegates and officers elections in Local 601 were contentious, with candidates on both sides making numerous charges and counter-charges.  In the delegates election, the primary participants in the events described here were involved in the filing of twenty pre-election protests, with allegations that included candidate ineligibility, improper use of union resources, campaigning on union time, improper contributions, coercion, retaliation, intimidation and attempted ballot collection. 

            We first examine whether the protest was timely filed.  Article XIII, Section 2(b) of the Rules requires that pre-election protests “must be filed within two (2) working days of the day when the protestor becomes aware or reasonably should have become aware of the action protested or such protests shall be waived.”  Reyes first learned of the alleged Rules violations at issue here some five months after the delegates election concluded, when a member and a retiree, both affiliated with the No Mas Lucio slate, told him of the behavior on March 10, 2011.  The next day, March 11, Reyes faxed his protest to our offices in Washington, D.C.  Accordingly, his protest was timely filed from the date he became aware of the alleged violations. 

Because the conduct complained of occurred in July and August 2010, we also must examine whether Reyes reasonably should have become aware of the actions protested before March 10, 2011.  We find it was reasonable for Reyes to have filed at the time he did, and not earlier.  Reyes learned of the alleged violations from members or former supporters of the slate that competed against his in the delegates election.  The alleged violations did not involve Local Union 601 facilities or occur in places where Reyes might have learned of the conduct.  It is expected that candidates would not divulge their own alleged Rules violations to their opponents.  Where all the witnesses were also participants in the Rules violations, we find that Reyes could not reasonably have learned of the violations until and unless he was told of them.  Accordingly, we find the protest timely.

            Turning to the merits, we find that the Hoffa-Aloise campaign funded t-shirts and stickers for the No Mas Lucio slate in Local Union 601’s delegates election.  This action did not violate the Rules.  To achieve nomination to the union-wide ballot for International office, a candidate for IBT vice president at large such as Aloise must obtain the secret ballot support of at least five percent of the delegates to the IBT convention.  The Rules permit candidates for International office to support candidates aligned with them who are competing in local union delegates election.  The Alvarado slate candidates supported the Aloise candidacy, and the Hoffa-Aloise campaign therefore was permitted by the Rules to support the Alvarado slate campaign in the delegates election.  Within the range of permissible support for those delegate candidates was funding t-shirts and stickers for the No Mas Lucio slate. 

Similarly, Rosas, a supporter of Aloise, was also permitted to assist Alvarado and the No Mas Lucio slate by providing campaign advice and strategy on how to defeat Reyes and his slate.  Rosas had the right under Article VII, Section 12(a) “to participate in campaign activities, including the right … to support or oppose any candidate, [and] to aid or campaign for any candidate.”[1]  Accordingly, Rosas had the right – and he exercised it – to assist candidates in another local union’s delegates election. 

            Support Rosas provided to Alvarado and her slate went beyond allowable support, however, and violated Rules that prohibit the use of union resources to assist a candidate.  Specifically, Article VII, Section 12(c) prohibits use of union funds, facilities, equipment and personnel, among other things, to “assist in campaigning unless the Union is reimbursed at fair market value for such assistance and unless all candidates are provided equal access and are notified in advance, in writing, of the availability of such assistance.”  Rosas violated this provision on several occasions.  Thus:

• Although he gave notice to the Hoffa and Gegare campaigns of the availability of Local Union 439’s hall for campaign rental at the rate of $25 per occasion, Rosas admits he did not bill the Alvarado slate or collect the fee for its use.
• He used copying equipment owned and supplied by Local Union 439 to produce campaign flyers for the Alvarado slate.
• He held a strategy meeting with Alvarado slate members in a conference room at the Stockton Marriott that was paid for with local union funds.
• He used food and beverage belonging to Local Union 439 to feed members of the Alvarado slate.[2]

Just as the Rules prohibit unions from assisting candidates, they also prohibit candidates from receiving assistance from unions.  We find that Alvarado and her slate violated Article XI, Sections 1(a), 1(b)(13), and 1(b)(15) by accepting the prohibited assistance and contributions without insuring that they were permissible contributions under the Rules and indeed knowing that they were prohibited contributions.  We find that Alvarado’s statement to our investigator that she “didn’t care” where the assistance came from, that she was simply glad to have it, concisely stated her attitude about use of union resources to assist her campaign.  Alvarado was a principal witness against Reyes when the allegation was made, which we sustained, that Reyes used union resources to assist his campaign for International office.  Aloise, 2010 ESD 22 (August 27, 2010), aff’d, 10 EAM 6 (September 3, 2010).  Despite Alvarado’s claimed ignorance with respect to permitted and prohibited acts of campaigning, we find that Alvarado well knew that the use of the union facilities, funds and services violated the Rules.  Her receipt of contributions that she knew were prohibited therefore constituted willful misconduct.

In reaching these conclusions, we credit the members and supporters of the Alvarado slate who provided information concerning the improper use of union resources that Rosas directed to support the Alvarado slate’s campaign.  Their statements against interest, based on first-hand knowledge, were persuasive.  In contrast, Rosas’ and Alvarado’s denials were unconvincing.  In particular, Alvarado’s evasive responses concerning the number of times the slate members met at Local Union 439’s hall, the location within the Stockton Marriott where the meeting there occurred, and the initial ignorance she claimed concerning the identity of the person who delivered the campaign t-shirts to the hotel conference room cause us not to credit her denials of improper activity.

            Accordingly, we GRANT the protest.

Remedy

 

When the Election Supervisor determines that the Rules have been violated, he “may take whatever remedial action is deemed appropriate.” Article XIII, Section 4. In fashioning the appropriate remedy, the Election Supervisor views the nature and seriousness of the violation as well as its potential for interfering with the election process.

            We order Rosas to cease and desist from using union funds, facilities, equipment, and personnel to support or oppose any candidate for any office under the Rules.          

            We further order Rosas to pay Local Union 439 the sum of $500 for all the union resources and services found in this ruling to have been used in violation of the Rules.  We impose this reimbursement order to return to Local Union 439 the value of the resources Rosas diverted to assist Alvarado’s campaign.  We further order Rosas to pay a fine of $500 to the Office of the Election Supervisor (“OES”) as a consequence of his having used union resources for campaign purposes after being expressly instructed that such use violated the Rules.  In Reyes, 2010 ESD 12 (August 4, 2010), Reyes accused Rosas of using union resources to assist Alvarado’s campaign activities.  We denied the protest then for lack of evidence.  However, we cautioned that “a member of one local union may permissibly provide campaign assistance to a member of another, provided neither uses union resources to do so.” (Emphasis supplied.)  Rosas’ subsequent actions in providing his local union’s resources to assist Alvarado directly contravened this instruction.  Accordingly, we impose the fine here to reinforce the instruction previously made.  Such payments shall be made within two days of receipt of this decision, and shall be paid solely from Rosas’ personal funds.  Within two days after payment has been received by and deposited in Local Union 439’s account, Rosas shall supply a sworn affidavit demonstrating that Local Union 439 received payment of the ordered sum.  The affidavit shall further state that the reimbursement to Local Union 439 and the fine to OES are paid solely from his personal funds, that no other person, IBT member, candidate, slate, or campaign has transferred or contributed any funds to him for the purpose of paying all or part of the fine, and that he will refuse any such offer, transfer, or contribution.  Failure of Rosas to make payment to and prove its receipt by Local Union 439, to make payment to OES, and to supply the sworn affidavit shall result in the withholding of his delegate identification badge for the IBT convention until such time as he complies. 

            We further order Local Union 439 to post on all worksite bulletin boards under the jurisdiction of the local union the notice attached to this decision entitled “Notice to All Members of Local Union 439,” in English and Spanish.  The notice shall remain posted until September 30, 2011 and shall not be defaced or covered up.

            With respect to Alvarado, we order her to cease and desist from using, accepting or receiving union funds, facilities, equipment, and personnel to support or oppose any candidate for any office under the Rules.

            As with Rosas, we further order Alvarado to pay Local Union 439 the sum of $500 for all the union resources and services found in this ruling to have been used in violation of the Rules, and to pay a fine of $500 to the Office of the Election Supervisor (“OES”) as a consequence of her having intentionally violated the Rules after being involved in protests that found her opponent to have committed that type of conduct, and having lengthened this investigation by her initial responses to our investigator.  Such payments shall be made within two days of receipt of this decision, and shall be paid solely from Alvarado’s personal funds.  Within two days after payment has been made to Local Union 439, Alvarado shall supply a sworn affidavit demonstrating that she paid Local Union 439 the ordered sum.  The affidavit shall further state that the reimbursement to Local Union 439 and the fine to OES are paid solely from her personal funds, that no other person, IBT member, candidate, slate, or campaign has transferred or contributed any funds to her for the purpose of paying all or part of the fine, and that she will refuse any such offer, transfer, or contribution. 

            We further order Local Union 601 to post on all worksite bulletin boards under the jurisdiction of the local union the notice attached to this decision entitled “Notice to All Members of Local Union 601,” in English and Spanish.  The notice shall remain posted until September 30, 2011 and shall not be defaced or covered up.

            We further order that Maria Ashley Alvarado is disqualified from her elected position as delegate to the IBT convention and that her credentials to sit as such are revoked.  The circumstances of this protest and investigation justify imposing this extraordinary remedy. 

            We return to an earlier ruling relating to the Local Union 601 delegates election.  The ruling in Aloise, 2010 ESD 22 (August 27, 2010), aff’d, 10 EAM 6 (September 3, 2010), resolved protests alleging Rules violations by Lucio Reyes.  Among the evidentiary submissions was a four-page letter on Local Union 601 letterhead, dated July 15, 2010 and signed by Alvarado, that described the protested conduct including the use of union resources (local union staff, in particular) to support the Reyes campaign.  Alvarado stated that she was raising these matters “to save the reputation and effectiveness of our Local and . . . to preserve the integrity of the upcoming general election campaign for the International.”  Alvarado addressed that letter to General President Hoffa and asked that the International consider placing an overseer in Local Union 601.  We granted the protest and ordered Reyes to cease and desist from using union resources to campaign.  We further ordered that Local Union 601 post a notice to advise its members that Reyes had violated the Rules by using union resources to campaign.  Finally, we ordered Reyes, at the time a candidate aligned with the Gegare campaign, to pay ninety percent of the costs of campaign mailings for the Hoffa and Pope campaigns to level the playing field within Local Union 601 among the candidates for IBT General President.  These were significant remedies and their imposition was a matter of record in the delegates election. 

            At the very time she was pursuing the protest against Reyes, however, Alvarado readily and gratefully accepted the union-funded support for her campaign against Reyes.  She “didn’t care” where her support came from and apparently “didn’t care” that she was making use of union resources in conducting her campaign.  The only time she evinced any care over that issue was when she was pursuing her political adversary for engaging in similar conduct.  Alvarado was president of Local Union 601 at the time this conduct occurred.  She identified the use of union resources as a Rules violation when Reyes did it.  She had to know that her own campaign broke the same rules. 

            Although Alvarado violated rules against using union resources for campaign purposes, the conduct (other than copying several hundred flyers) did not involve public campaigning among the membership.  We cannot establish “a definitive and causal link” between Alvarado’s violation and her defeat of Reyes in the delegates election.  Richards, 01 EAM 63 at 5 (May 14, 2001).  Nevertheless, we conclude that Alvarado should be disqualified as a delegate.  Conduct evincing flagrant disrespect for election rules and the protest process warrants disqualification.  Richards, 01 EAM 63 at 6 (“[a]lthough Jimmy Payne’s election in the Local 728 balloting was, in light of the foregoing, valid, he is disqualified from taking his seat at the convention because I am satisfied that the Election Administrator properly concluded that he obstructed the investigation and gave conspicuously unbelievable and false statements in the course of his interviews by investigators”).  Alvarado’s conduct here is similar.  She willfully used union resources to campaign after providing detailed and credible accusations of the same misconduct against her opponent, Reyes, and because she provided conspicuously false and misleading responses to our investigator in this matter.[3]

            Local Union 601 elected four delegates and two alternate delegates.  In the calculation of final delegate strength, the local union’s representation increased by one delegate and the first-ranked alternate delegate became the fifth-ranked member of the delegation.  Alvarado was the first ranked delegate.  As a consequence of Alvarado’s disqualification, the other delegates move up one rank and the remaining alternate delegate, Richard L. Casey, will be the fifth-ranked member of the delegation.  See Berg, 2006 ESD 278 (May 30, 2006), aff’d, 06 EAM 46 (June 20, 2006).

            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 Supervisor 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

885 Third Avenue, Suite 1000

New York, NY  10022

Fax: (212) 751-4864

Copies of the request for hearing must be served upon the parties, as well as upon the Election Supervisor for the International Brotherhood of Teamsters, 1801 K Street, N.W., Suite 421 L, Washington, D.C.  20006, all within the time prescribed above.  A copy of the protest must accompany the request for hearing. 

 

                                                                        Richard W. Mark

                                                                        Election Supervisor

cc:        Kenneth Conboy

            2011 ESD 281

Bradley T. Raymond, General Counsel

International Brotherhood of Teamsters

25 Louisiana Avenue, N.W.

Washington, D.C. 20001

braymond@teamster.org

David J. Hoffa

Hoffa Hall 2011

1100 Connecticut Avenue, N.W., Ste. 730

Washington, D.C. 20036

hoffadav@hotmail.com

Ken Paff

Teamsters for a Democratic Union

P.O. Box 10128

Detroit, MI 48210-0128

ken@tdu.org

Barbara Harvey

1394 E. Jefferson Avenue

Detroit, MI 48207

blmharvey@sbcglobal.net

Fred Gegare

P.O. Box 9663

Green Bay, WI 54308-9663

kirchmanb@yahoo.com

Scott D. Soldon

3541 N. Summit Avenue

Shorewood, WI 53211

scottsoldon@gmail.com

Fred Zuckerman

3813 Taylor Blvd.

Louisville, KY 40215

fredzuckerman@aol.com

Robert M. Colone, Esq.

P.O. Box 272

Sellersburg, IN 47172-0272

rmcolone@hotmail.com

Carl Biers

Box 424, 315 Flatbush Avenue

Brooklyn, NY 11217

info@SandyPope2011.org

Julian Gonzalez

Lewis, Clifton & Nikolaidis, P.C.

350 Seventh Avenue, Suite 1800

New York, NY 10001-5013

jgonzalez@lcnlaw.com

Lucio Reyes

301 Tuxedo Court

Stockton, CA 95201

lreyes601@sbcglobal.net

Maria Ashley Alvarado

Teamsters Local Union 601

745 E. Miner Ave.

Stockton, CA 95202

europeartmuseum@yahoo.com

Sam Rosas, Secretary-Treasurer

Teamsters Local Union 439

P.O. Box 1611

Stockton, CA 95201

srosas@teamsters439.com

Christine Mrak

2357 Hobart Avenue, SW

Seattle, WA 98116

chrismrak@gmail.com

Rochelle Goffe

1234 22^nd Avenue, E

Seattle, WA 98112

rochellegoffe@gmail.com

Michael J. Miller

1611 Granville Ave., #8

Los Angeles, CA 90025

miller.michael.j@verizon.net

Maria S. Ho

Office of the Election Supervisor

1801 K Street, N.W., Suite 421 L

Washington, D.C. 20006

mho@ibtvote.org

Kathryn Naylor

Office of the Election Supervisor

1801 K Street, N.W., Suite 421 L

Washington, D.C. 20006

knaylor@ibtvote.org

Jeffrey J. Ellison

214 S. Main Street, Ste. 210

Ann Arbor, MI 48104

EllisonEsq@aol.com