July 11, 1996
VIA UPS OVERNIGHT
Richard Volpe, et al.
July 11, 1996
Page 1
Richard Volpe, Secretary-Treasurer
Teamsters Local Union 550
6 Tuxedo Avenue
New Hyde Park, NY 11040
Archie Cook
4508 Balmoral Drive
Richton Park, IL 60471
James P. Hoffa
2593 Hounds Chase
Troy, MI 48098
Nancy DeLong
834 Golf Drive #101
Pontiac, MI 48341
Russ Roberts
4121 Dale Road #40
Modesto, CA 95356
Linda Olson
1703 W. Noble Avenue
Visalia, CA 93277
Gayhart Silvola
878 Estes Street
Gurnee, IL 60031
Michael Haffner
1113 S. Carey Drive
McHenry, IL 60050
Paul Hanson
3932 4th Avenue #B
East Moline, IL 61244
Ron Carey, General President
International Brotherhood of Teamsters
25 Louisiana Avenue, N.W.
Washington, DC 20001
John Sullivan, Associate General Counsel
International Brotherhood of Teamsters
25 Louisiana Avenue, N.W.
Washington, DC 20001
Bradley T. Raymond
Finkel, Whitefield, Selik, Raymond
Ferrara & Feldman, P.C.
32300 Northwestern Highway, Suite 200
Farmington Hills, MI 48334
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July 11, 1996
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Richard Volpe, et al.
July 11, 1996
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Re: Election Office Case Nos. P-828-IBT-MGN
P-830-IBT-MGN
P-833-IBT-MGN
P-837-IBT-MGN
P-840-IBT-MGN
P-841-IBT-MGN
P-842-IBT-MGN
P-844-IBT-MGN
P-845-IBT-MGN
P-848-IBT-MGN
Gentlemen:
Related pre-election protests were filed pursuant to Article XIV, Section 2(b) of the Rules for the IBT International Union Delegate and Officer Election (“Rules”) against the IBT and General President Ron Carey. The protests were filed by Richard Volpe (P-828), secretary-treasurer of Local Union 550 and a candidate for International vice president;
Archie J. Cook (P-830), a member of Local Union 705; James P. Hoffa (P-833), a candidate for general president; Nancy DeLong (P-837), a member of Local Union 414; Linda M. Olson (P-841), a member of Local Union 94; Gayhart Silvola (P-842), a member of Local
Union 301; Michael Haffner (P-844), vice president of Local Union 301; and Paul Hanson
(P-845), a member of Local Union 371. Each protester alleges that union-financed publications, specifically the June 21, 1996 issue of the Teamster Leader and the July/August issue of Teamster, support or attack candidates, in violation of the Rules at Article VIII, Section 8(a). The cases were consolidated due to the identity of the issues raised.
In her protest (P-841), Ms. Olson further objected on the basis of Article VIII,
Section 8(a) of the Rules, to a union-financed document entitled, “Fighting For The Future - Constitutional Package” (“Package”). This document, she states, was mailed to her by the IBT with a copy of the Teamster Leader. Russ Roberts (P-840) and Mr. Hoffa (P-848) filed pre-election protests solely over the production and distribution of the Package. Because a segment of the Teamster Leader summarizes the text of the Package, these protests were also consolidated with these cases for resolution.
The protests were investigated by Regional Coordinator Bruce Boyens and Regional Coordinator William Wertheimer.
1. The June 21 Issue of the Teamster Leader
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July 11, 1996
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The Teamster Leader is regularly distributed to local union officials, stewards, organizers and other union leaders within the IBT. The June 21, 1996 issue of the Teamster Leader begins with an article carrying the headline, “Members To Be Affected By Major Convention Decisions.” The first segment of the article advises that the Convention delegates will have the opportunity to decide the future funding of certain services maintained by the IBT. Training for stewards, the production of certain media materials for use by local unions, the implementation of standards for national contract negotiations, and the continuance of consolidated assistance to local unions on organizing campaigns are specifically mentioned. Under the subtitle “Actions of Past Four Years Being Challenged,” a review of certain activities of the IBT General Executive Board is set forth. These include the decisions to eliminate the Area Conferences, the constitutional propriety of the 1994 membership vote on strike benefits and appeals from adverse action by Frank Wsol (Local Union 710),
Ernest Tusino (Local Union 170), Scott Hendries (Local Union 988) and Steve Croyle
(Local Union 597). The article also reports on other determinations of the General Executive Board which will be considered by the delegates, such as the decision concluding that dues obtained from various local unions and joint councils by the Real Teamster Caucus must be returned, a decision prohibiting Local Union 745 from depositing union funds with its attorneys to protect against possible trusteeship actions, a pay dispute involving Local
Union 992, and several other disciplinary actions. Five challenges of decisions relating to violations of local bylaws are also listed.
At page 3, an article appears entitled, “Teamsters Fighting For the Future.” It catalogs 13 proposals for action at the 1996 IBT Convention which Mr. Carey deems “key” and which he asks the delegates to adopt. They are summarized below:
1. Maintain current services with no increase in dues.
2 Establish a committee to report the options on strike benefits.
3. Install the Ethical Practices Committee as a permanent part of the IBT Constitution with an impartial administrator.
4 Let local unions choose whether business agents are to be appointed or elected.
5. Encourage organizing and political action committees.
6. Commit employee benefit fund trustees to a Code of Ethics.
7. Cap excessive salaries and pensions.
8. Establish standards of conduct for all union officials.
9. Preserve the secret ballot vote for International officers and Convention delegates.
10. Require that a member work two-years in a rank-in-file job in order to be eligible as a candidate for International office.
11. Require national negotiating committees to inform the membership of their activities.
12. Require a membership vote prior to local union mergers, with certain exceptions.
13. Recognize the special needs of Canadian members.
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A two-page article, beginning at the top of page 4, is entitled, “A Teamster’s Guide to International Union Finances.” Written in question and answer form, the article provides facts relating to such subjects as members dues, the state of the International budget, International expenditures and payroll, a comparison to past spending, and the status of International assets. Additional information explains the value of the International’s dues income in today’s market, the effect of new strategies on the organization of members and a comparison of the current IBT dues levels to other International unions.
Page 6 contains a “bulleted” summary of the areas in which the IBT has cut costs since 1991. The areas referenced are salaries and pensions, health care savings, reductions in employee benefits, the installation of competitive bidding and the implementation of controls on travel costs.
An article advocating the removal of a trustee from the Central and Southern States pension fund also appears on page 6. The accompanying report from Mr. Carey to the trustees of these employee benefit funds giving the reasons for his request is also featured. These stated reasons include the improper use of trust funds and the fact that the trustee was not an active IBT member. Mr. Carey’s name is mentioned four times in connection with this article. A segment of the article reports on Mr. Carey’s proposal to the Convention regarding trustee accountability.
The last two pages of the publication contain certain miscellaneous articles relating to activities of the U.S. Congress. In these articles, the IBT calls for the prevention of the Republican Congress from passing laws which restrict organizing, reports on efforts to block the passage of the minimum wage and decries the expansion of NAFTA to the point where it might allow “poorly maintained Mexican trucks” on our highways driven by “low-paid” workers. Other articles announce the schedule for classes at the Teamster Leadership Academy and the availability of IBT organizing materials.
2. Teamster for July/August 1996
Much of the July/August issue of Teamster is comprised of the “Officers’ Report to the 25th International Union Convention (“Report”).” This summary begins with an open, introductory letter, signed by General President Carey and General Secretary-Treasurer
Tom Sever, which outlines its contents. The Report itself is divided into five parts, termed respectively: (1) “Fighting corruption,” (2) “Taking on employers,” (3) “Building power for working families,” (4) “Organizing for everyone’s protection;” and (5) “Making members’ money work for members.”
A feature entitled, “Building Unity For The Future” is placed immediately after
Mr. Carey’s introductory letter. It lists several proposed changes to the IBT Constitution which the current administration supports including many of the issues reviewed and referenced in the Teamster Leader - the Ethical Practices Committee proposal, the two-year rank-in-file requirement, the employee benefit trustee Code of Ethics, the cap on multiple salaries and pensions, protection of the secret ballot vote for International officers and Convention delegates, establishment of political action and organizing committees, and the permitting of a membership vote on future strike benefits.
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Under the category of “fighting corruption,” the magazine contains an article entitled, “Cleaning Up Our Own House.” It refers to the efforts to eliminate corruption within the IBT, the benefits of doing so, the role of the Ethical Practices Committee in assisting with this endeavor, and further lists the types of improper activities targeted.
The section entitled, “Taking on Employers” contains references to the ban on inviting employers to this year’s Convention, the strengthening of the trade division and new bargaining strategies. Specific goals are detailed, including better pensions, more training for stewards, improved grievance rights, additional coordination with local unions and public employees, and combating discrimination in the workplace.
The information relating to the heading “Building Power For Teamster Families” is prefaced with the title “Political Action.” It reviews the IBT’s efforts to provide members with political information and to organize demonstrations to “put the heat on all politicians.” It also addresses the beneficial effect of building coalitions with various community groups and details specific acts of Congress which are of great interest to the membership, including attempts to eliminate the Davis-Bacon laws, remove programs which protect job related safety, reduce appropriations to Medicare, implement adverse overtime laws and allow unsafe trucks into the United States under the North American Free Trade Agreement. There is also a short piece on the issue of a proposed amendment to the IBT Constitution regarding Canadian “sovereignty.”
The “organizing” section reviews various strategies the IBT applies in its new member organizing campaigns including worker-to-worker contact, assistance to local unions, as well as community and corporate approaches. The article also examines several successful organizing campaigns of both public and private sector employees.
By far, the largest section of the Report scrutinizes the subject of IBT finances under the title “Making Members’ Money Work for Members.” The piece begins with several paragraphs which evaluate the IBT’s financial condition as of 1991, when the last Convention occurred. It states that IBT expenses exceeded its income and assets by $39 million and gives reasons for the negative outflow of funds. It further cites various ways in which the IBT has balanced its budget in the subsequent five years, including the cutting of high salaries, a decrease in payroll and pension expenses, the elimination of the Area Conferences, the reduced cost of government intervention and the reversal of a stated and documented trend toward membership decline. The article also provides detailed information on the manner in which the IBT derives its income, its historical and present asset status and other dues information. Special attention is paid to the strike fund and proposals for the funding and future level of strike benefits. Certain other proposed changes, such as caps on salaries, financial controls and limits on travel expenses are discussed.
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Several other major articles appear in the July/August issue of Teamster in addition to the Report. In one, an “historic” agreement with a European grocery retailer is reviewed, achieved in cooperation with a Dutch trade union. Another article concerns an organizing effort in North Carolina. There is an article stating how several local unions successfully challenged unfair production standards. The activities of a recently formed Grocery Council in New York and New Jersey are examined in another segment. A special feature on the CEO of the Union Pacific Railway appears under the headline, “This Executive Make$ More In One Day Than The Workers Make In A Whole Year.” Several organizing efforts are also reviewed including activities in California, Maryland and Wisconsin. The Farmland Dairy strike in New Jersey is the subject of an article. An item appearing under the title, “Now Showing: Teamster Unity,” is about the recent activities of the IBT’s Movie Division. The issue ends with several short articles which concern retiree health coverage, new IBT publications, and certain other government related activities in which the IBT has been engaged.
Germane quotations from various union members appear throughout various sections of the magazine. The issue contains two small pictures of Mr. Carey, the first printed on the same page as his introductory letter and the other depicting a meeting with construction members to “keep the heat on Congress not to repeal Davis-Bacon rights.” International Vice President Aaron Belk is pictured once in connection with his acceptance, on behalf of the IBT, of this year’s American Red Cross National Labor Award. No other pictures of any other International officers or candidates appear. There is no mention of the pending election for International officers. No candidate for International office is either attacked or praised. Many of the subjects discussed in both publications deal with matters that are also treated as campaign issues by all candidates.
3. The “Constitutional Package”
The Package begins with a letter dated June 24, 1996 from Mr. Carey. It states:
Enclosed are proposals which, as the General President, I have submitted to the Constitution Committee for the upcoming 25th International Convention.
These proposals are designed to help Teamster members fight for the future by taking on employers, rooting out corruption, protecting members’ rights, making members’ money work for the members, and building Teamster clout for working families. If you have any comments on these proposals, please forward them to my office.
Also, I have enclosed answers to some commonly-asked questions about Teamster finances, as well as a list of appeals of General Executive Board decisions which are being brought before the Convention.
I look forward to seeing you in Philadelphia.
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July 11, 1996
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The Package contains the exact text of the 18 amendments to the IBT Constitution proposed by Mr. Carey as the IBT general president. Included are all of the proposed amendments summarized in the Teamster Leader, plus the following:
1. An amended oath of office emphasizing certain “fundamental” goals of the IBT including ridding the IBT of corruption, maintaining democratic principles and protecting the interests of the members.
2. An amended preamble reflecting the same goals.
3. An amendment to change the name of the IBT.
4. An amendment requiring the expulsion of any member who engages in corrupt behavior.
5. An amendment which eliminates the “periodic rest” provisions for the general president and general secretary-treasurer.
6. An amendment which adds collusive employer blackballing as grounds for intra-union discipline.
7. An amendment which adds unlawful work-referral and hiring hall discrimination as grounds for intra-union discipline.
A separate page of the Package is made up of exactly the same summary of constitutional proposals that appears in the Teamster Leader. There is a separate summary of the strike benefits issue. A four-page synopsis under the title “A Guide To International Union Finances” pertains to the same issues and transmits the same information as the corresponding article in the Teamster Leader, including the list of areas in which costs are claimed to have been cut. A three-page document enclosure entitled, “Appeals Being Brought Before the International Union Convention” repeats the same data set forth in the Teamster Leader under the headline “Actions of Past Four Years Being Challenged.”
4. Application of the Rules to the Teamster Leader, the Teamster Magazine and the “Constitutional Package”
Article VIII, Section 8(a) of the Rules states that a union-financed publication or communication may not be “used to support or attack any candidate or the candidacy of any person.” In reviewing union-financed communications for improper campaign content, the Election Officer looks to the tone, content and timing of the publication. Martin, P-010-
IBT-PNJ, et al. (August 17, 1995) (decision on remand), aff’d, 95 - Elec. App. - 18 (KC) (October 2, 1995). The Election Officer also considers the context in which the communication appeared.
In Martin, the Election Officer recognized that union officers and officials have a “right and responsibility to exercise the powers of their office and to advise and report to the membership on issues of general concern” (quoting Camarata v. International Bhd. of Teamsters, 478 F. Supp. 321, 330 (D.D.C. 1979), aff’d, 108 L.R.R.M. (BNA) 2924 (D.C. Cir. 1981)). The Election Officer also recognized in Martin that:
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. . . an otherwise acceptable communication may be considered campaigning if it goes on to make a connection with the election or election process, if it involves excessive direct or indirect personal attacks on candidates, or, alternatively, involves lavish praise of candidates. Otherwise, legitimate coverage of the activities of a union official running for office may constitute campaigning if it is excessive.
The Election Appeals Master has stated that “[A]bsent a political endorsement or attack, as established by the communication’s tone, content, and timing, the Election Rules do not empower me to intrude upon the journalistic process of a union publication.” In Re: Lamy, 95 - Elec. App. - 53 (KC) (January 11, 1996).
Virtually all of the topics discussed in the various articles and features of the July/ August issue of The Teamster and the Teamster Leader have been determined to be of legitimate interest to union members. Martin, supra (review of IBT finances, organizing the unorganized, imposition of trusteeships, corruption within the union); Hoffa, P-126-IBT-EOH (October 4, 1995) (strike benefits); Hoffa, P-126-IBT-EOH (October 4, 1995) (IBT political action and lobbying); Young, P-722-IBT-EOH (May 6, 1996) (Convention issues, failure to invite employers to the Convention); Hoffa, P-733-IBT-SCE (May 1, 1996) (consideration of Canadian sovereignty within the IBT); Hoffa, P-808-IBT-SCE (June 28, 1996) (appeal pending) (advocacy of reforms by IBT, summarizing achievements since last Convention, discussion of Convention issues); In Re: Hoffa, 96 - Elec. App. - 97 (KC) (February 23, 1996) (efforts to free the IBT of corrupt influence); In Re: Hoffa, 96 - Elec. App. - 199 (KC) (March 11, 1996) (cutting waste, making the union more efficient); Hoffa, P-202-IBT-EOH (November 17, 1996), aff’d, 95 - Elec. App. - 39 (KC) (November 30, 1995) (IBT activities for civil rights); Hoffa, P-315-IBT-SCE (February 28, 1996), aff’d, 96 - Elec. App. - 119 (KC) (March 11, 1996) (IBT’s opposition to NAFTA); Stephens, P-757-IBT-SCE (May 16, 1996) (informing the membership of the imposition of trusteeships and the discipline of union officers); Ruscigno, P-069-LU247-SCE (July 31, 1995) (elimination of the Area Conferences); Local Union 745, P-247-IBT-SCE (January 22,1996), aff’d, 96 - Elec. App. - 74 (KC) (February 6, 1996) (constitutional interpretations).
Since the beginning of the campaign period, most of these subjects have become issues in the pending International officer election. Unless a nexus exists with the election, however, the mere identification of a campaign theme with a subject contained in a union-financed publication is not sufficient to establish a Rules violation. “Union funds and resources used to produce communications of a union officer are not impermissible merely because the same messages are utilized in the campaign, as long as the union-financed communication is neutral with regard to the election.” Young, P-722-IBT-EOH (May 6, 1996). See also, Faulkner,
P-293-IBT-CLE (March 25, 1996), aff’d, 96 - Elec. App. - 159 (KC) (April 4, 1996).
These consolidated protests fall into several recognizable categories in terms of the nature of the allegations made. Mr.Volpe, Ms. DeLong, Mr. Silvola, Mr. Haffner and
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Mr. Hanson all take the position that either or both of these union-financed publications constitute a “gross misuse” of members’ dues money. The assertions of Mr. Cook and
Ms. Olson are represented in the protest filed by Mr. Roberts, who states that “[I]f the IBT had mailed a copy of all proposed Constitutional amendments submitted by all candidates and not included any explanation or commentary, the material would not seem so biased.”
Mr. Hoffa, argues that the “IBT has used this and other publications to repeat, over and over, Mr. Carey’s convention agenda, in a manner that could have no other conceivable purpose than to promote his candidacy.” “This ongoing drumbeat of uncritical reporting on Mr. Carey’s Convention platform,” according to Mr. Hoffa, “constitutes improper campaigning.” Both Hodgson v. Mine Workers, 344 F. Supp. 17 (D.D.C. 1971) and Yablonski v. Mine Workers, 305 F. Supp. 868 (D.D.C. 1969) are cited by Mr. Hoffa to support his position.
Each of the subjects in the June 21 issue of the Teamster Leader and the July/August issue of Teamster reviews a matter previously held to be of legitimate interest to the membership under Article VIII, Section 8(a) of the Rules. Martin, citing to Camarata, emphasized that elected union officials are entitled to use union-financed publications to express their views and report their activities. The Officer’s Report which appears in Teamster is a valid exercise of the “right and responsibility” of union officers to “advise and report to the membership.” Reports of these activities and an analysis of these viewpoints do not violate the Rules because they are presented on the eve of the Convention. To the contrary, the timing of these articles is appropriate since they are disseminated at a time that consideration of these matters must necessarily take place. Similarly, the contents of the Teamster Leader, encompassing the future of union services, the pending challenges to the past four years’ activities, the list of constitutional amendments proposed by the IBT and the summary of its past performance in the areas of finances, intra-union discipline, political action and union operations, fits within the purview of this right.
The writing style utilized by both communications is generally neutral and non-partisan. No candidate is attacked, praised or even referenced in the context or the capacity of the ongoing campaign. See Hoffa, supra, (P-808) (mere statement that reform efforts could be countermanded does not, in and of itself, attack any candidate). Coverage in neither publication focuses on any one or group of union officials or candidates, but remains faithful to the issues previously deemed suitable. The two pictures of Mr. Carey and the photograph of Mr. Belk contained in The Teamster are appropriate to the matters reported and are not excessive.
Several of the protesters object because all points of view are not represented in these publications. However, a union-financed communication does not violate the Rules merely because it fails to treat opposing ideas or opinions. In Martin, supra, the following quotation was quoted with approval from Camarata:
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Elected union officials . . . are not ordinarily required to give space therein to the expression of contrary views. . . So long as such coverage is addressed to the regular functions, policies and activities of such incumbents as officers involved in matters of interest to the membership and not as candidates for reelection, there is not a violation of [Section] 401(c) [of the LMRDA].
Whatever actual advantage may be gained by the publicity and attention inherent in such communications is offset by the realities of the political process. As Martin further explains at page 12:
Incumbency, however, is a two-edged sword. Mr. Carey is subject to blame when union policies fail or when negotiations result in a less advantageous collective bargaining agreement. [citing cases] Moreover, just as the incumbent may conduct union business without having it labeled as campaigning, potential rivals are also free to criticize the policies of the incumbent without having such conduct automatically be labeled campaigning.
The cases cited by Mr. Hoffa are not to the contrary. In Hodgson, the United Mine Workers Journal was determined to have been used as the incumbent’s “campaign tool” because the publication failed to respect the line “between the use of the Journal to report the activities of defendant Boyle as President, which is permissible and the use of the Journal in such a way in reporting such activities as to promote the candidacy.” Hodgson, supra at 23. The court specifically referred to “items which extolled the extraordinary leadership capabilities of Mr. Boyle” and a “literal saturation” of the publication with his “day-to-day accomplishments” and “great leadership potential.” No similar partisan rhetoric is noted either in the Teamster Leader or the Teamster magazine. Those same union-financed publications are reviewed in Yablonski, an earlier case, concerning the same election.
The disputed issues of the Teamster Leader and Teamster discuss only legitimate issues and do so in a non-partisan manner. Therefore, there is no basis upon which to conclude that the publications are in violation of the Rules.
The “Constitutional Package” sets forth Mr. Carey’s proposals for constitutional amendments and was sent directly to the delegates. In objecting to the dissemination of the Package, the protesters in P-840 and P-841 indicate that they would not have asserted a violation if the IBT had mailed copies of all proposed constitutional amendments--not only those proposed by the Administration--to the delegates. Such a claim is similar to the assertion that union-financed publications must give equal time and space to dissenting views. As noted above in Martin, the Election Officer addressed this issue and found, consistent with federal labor law, that an incumbent union administration is not required to utilize union resources or publications to disseminate opposing views.
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The Election Officer has previously noted that each of the issues addressed in the amendments are issues of ongoing policy debate within the IBT. In Hoffa, P-733-IBT-SCE (May 1, 1996), the Election Officer reviewed a similar issue when a candidate for International office sent a letter at union expense promoting the passage of the Canadian sovereignty amendment to the IBT Constitution. There, the Election Officer denied the protest, stating:
Mr. LaCroix’s letter does not contain any direct or indirect attacks on any candidate. Nor does it support or praise any contestant for office. The letter is devoid of reference or connection whatsoever to the pending International delegate and officer election. Standing alone, it is a clear and proper exercise of the right of Mr. LaCroix, as a union officer, to communicate, advise and report to the membership on an issue of general concern and an ongoing debate within the IBT . . .
* * *
[T]he communication in question is directly and facially connected to legitimate union business: the resolution on Canadian sovereignty which will be put to a vote at the International Convention in July 1996. It is proper and necessary for there to be debate on important policy issues in union-financed publications, so long as the discussion of such issues is not then linked to the election process or campaign of a particular candidate. Moreover, there is nothing about the communication that links it, implicitly or explicitly, to the election for International officers.
Here, the Package is a proper exercise of Mr. Carey’s duty to advise the delegates of important items that will come before the Convention. The communication does not constitute campaigning just because the same subjects may also be referred to by Mr. Carey in his campaign or in his campaign literature.
Accordingly, the protests are DENIED.
Any interested party not satisfied with this determination may request a hearing before the Election Appeals Master within one day of receipt of this letter. The parties are reminded that, absent extraordinary circumstances, no party may rely upon evidence that was not presented to the Office of the Election Officer in any such appeal. Requests for a hearing shall be made in writing and shall be served on:
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Kenneth Conboy, Esq.
Latham & Watkins
885 Third Avenue, Suite 1000
New York, NY 10022
Fax (212) 751-4864
Copies of the request for hearing must be served on the parties listed above as well as upon the Election Officer, 400 N. Capitol Street, Suite 855, Washington, DC 20001, Facsimile
(202) 624-3525. A copy of the protest must accompany the request for a hearing.
Sincerely,
Barbara Zack Quindel
Election Officer
cc: Kenneth Conboy, Election Appeals Master
Bruce Boyens, Regional Coordinator
William A. Wertheimer, Regional Coordinator