Mccarron Complaint

7/27/2019 Mccarron Complaint

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I JOSEPH L PALLER JR. (SBN 82613)[email protected]. CAINfrORE (SBN 127462)rac@ cs1aw .org3 MIC1AEL D. WEINER (SBN 240155)mweiner gs a . g4 GILBERT SACKMAN, A LAW CORPORATION FtLED3699 Wilshire Boulevard, Suite 1200Los Angeles, California 900 10-27326 Tel:(323)938-3000 \ tTFax: (323) 937-9139

Attorneys for Plaintiffs9 UNITED STATES DISTRICT COURT10 CENTRAL DISTRICT OF CALIFORNIA11 V13r1J\J2 MICHAEL McCARRON, an individual, ) Case-No. .MICHAEL OLDS, an individual, and13 LINDSEY MALDOON, an individual, ) VERIFIED COMPLAINT FO14 ) DECLARATORY AND INJUNCTIVPlaintiffs, ) RELIEF AND DAMAGES FO15 ) VIOLATIONS OF LABO) MANAGEMENT REPORTING AN16 v. ) DISCLOSURE ACT AND FO

) BREACH OF CONTRACT17 )UNITED BROTHERHOOD OF) DEMANDFORJURYTRIAL18 CARPENTERS AND JOINERS OF)AMERICA, an unincorporated association,19 DOUGLAS J. McCARRON, an individual,DOUGLAS BANES, an individual, and20 MICHAEL V. DRAPER, an individual,21 Defendants.222324 Plaintiffs, complaining of defendants, aver as follows:2526 JURISDICTION AND VENUE27 1. Jurisdiction of this Court is based on the jurisdiction of the district courts28 hear civil ac tions brought by a member of a labor organization pursuant to Section 304

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1 the Labor Management Reporting and Disclosure Act of 1959 (LMRDA), 29 U.s.c2 464, to redress an y violation of Section 302 of the LMRDA, 29 u.s.c. 462.3 2. Jurisdiction of this court also is based on Section 30 1(a) of the Labo4 Management Relations Act, 1947 (LMRA), 29 U.s.C. 185(a), which grants the distric5 courts original jurisdiction over suits for violations of contracts between labo6 organizations in an industry affecting commerce, without regard to the amount i7 controversy and the citizenship of the parties.8 3. Jurisdiction of this court also is based on the Declaratory Judgment Act, 29 u.s.c.2201.

10 4. Venue in this district is proper pursuant to 28 u.s.c. 139 1(b) and (c) an11 29 u.s.c. 464(b)(2) because this is the district in which plaintiffs and defendants resid12 and/or conduct business, and in which the affairs of the trusteeship are being conducte13 by defendants and their officers and agents.1415 INTRODUCTION16 5. This is an action by members of an international labor organization agains17 the labor organization and its principal officers for improperly imposing a trusteeship upo18 two of its subordinate bodies in violation of its own constitution and Title IV of th19 LMRDA, 29 u.s.c. 461, et seq. The trusteeships were imposed as a result of a famil20 squabble between defendant Douglas J. Mccarron (Doug), who heads defendantUnite21 Brotherhood of caenters and Joiners ofAmerica (caenters), and other members o22 his family, including his brother, plaintiff Michael Mccarron (Mike). The family feu23 was precipitated in part by the death ofDougs and Mikes mother, and a dispute over th24 disposition of her estate.25 6. Because ofMikes and other familymembers refusals to bow to his demands26 Doug caused the caenters to impose an emergency trusteeship over the Southwes27 Regional council of carpenters, United Brotherhood ofcarpenters and Joiners ofAmeric28 (Regional council) in order to removeMike from his democratically-elected position a

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1 the Regional Councils elected Executive Secretary-Treasurer and chief executive officer2 For the same reason, Doug caused the Carpenters to impose an illegal defacto trusteeshi3 over Carpenters Local Union 1506, United Brotherhood of Carpenters and Joiners o4 America (Local 1506), and to use force and threats of force to take over Local 15065 building and bar Mike from performing his duties as Local 1506s democratically-electe6 President and chief executive officer.7 7. As averred, below, the trusteeships not only were imposed for imprope8 motives, they are also unlawful because (i) there was no emergency at the t ime they wer9 imposed without a fair hearing on the trusteeships and (ii) they were imposed by th

10 General Vice President of the Carpenters, who lacks the authority to do so.1112 THE PARTIES AND RELEVANT NON-PARTIES13 8. Defendant United Brotherhood of Carpenters and Joiners of Americ14 (Carpenters) is, and at all times mentioned in this complaint was, an unincorporate15 association maintaining its principal place of business at 101 Constitution Ave., NW16 Washington, D.C. 20001. The Carpenters is an international labor organization a17 defined in Section 3(i) of the LMRDA, 29 U.S.C. 402(i), and as defined in Sectio18 50 1(3) of the LMRA, 29 U.S.C. 142(3), and represents employees in industries affectin19 commerce.20 9. Non-party Southwest Regional Council of Carpenters, United Brotherhood21 of Carpenters and Joiners of America (Regional Council) is, and at all times mentione22 in this complaint was, an unincorporated association maintaining its principal place o23 business at 533 S. Fremont Ave., 10th Fl., Los Angeles, CA 90071, within the jurisdictio24 of this Court. At all times relevant, the Regional Council was and is an intermediate labo25 organization as defined in Section 3(i) of the LMRDA, 29 U.S.C. 402(i), and as defined26 in Section 50 1(3) of the LMRA, 29 U.S.C. 142(3), and represents approximately 65,00027 employees in industries affecting commerce. At all times relevant, the Regional Counci28 was and is chartered by and affiliated with the Carpenters and a subordinate body to the

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1 Carpenters.2 10. Non-party Carpenters Local Union 1506, United Brotherhood of Carpenter3 and Joiners ofAmerica (Local 1506) is, and a t a ll times mentioned in this complaint was4 an unincorporated association maintaining its principal place of business at 5164 Sant5 Monica Boulevard, Los Angeles, CA 90029, within the jurisdiction of this Court. At al6 times relevant, the Local 1506 was and is a local labor organization as defined in Sectio7 3(i) of the LMRDA, 29 U.S.C. 402(i), and as defined in Section 501(3) of the LMRA8 29 U.S.C. 142(3), and represents employees in industries affecting commerce. At al9 times relevant, Local 1506, as well as over thirty other local unions, was and is chartere

10 by and affiliated with the Carpenters, affiliated with the Regional Council and11 subordinate body to the Carpenters and the Regional Council.12 11. Defendant Douglas J. McCarron (Doug) is, and at all times mentioned i13 this complaint was, a resident of Las Vegas, Nevada. A t all times relevant, Doug was an14 is the General President and the chief executive officer of the Carpenters. Doug also is th15 former Executive Secretary-Treasurer and chief executive officer of the Regional Counci16 and, at all times relevant, is and was a member of Local 1506.17 12. Plaintiffs ar e informed and believe and on the basis of such information an18 belief aver that DefendantDouglas Banes (Banes) is, and at al l times mentioned in thi19 complaint was, a resident of Illinois. A t all times relevant, Banes was and is the Genera20 Vice President of the Carpenters.21 13. Plaintiffs are informed an d believe and on the basis of such information an22 belief aver that Defendant Michael V. Draper (Draper) is, and at all times mentioned i23 this complaint was, a resident of Oregon. At all times relevant, Draper was and is th24 District Vice President, Western District of the Carpenters.25 14. PlaintiffMichael McCarron (Mike) is, and at all times mentioned in thi26 complaint was, a resident of Los Angeles, California, within the jurisdiction of this Court27 At all times relevant, Mike was and is a member of the Carpenters and of Local 1506. A28 all times relevant, Mike also was an d is the democratically elected Executive Secretary



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1 Treasurer and chief executive officer of the Regional Council and member of its Executiv2 Committee, the democratically elected President and chief executive officerofLocal 1503 and a democratically elected delegate to the Regional Council. Mike is Dougs young4 brother. Mike brings this action on his own behalf and on behalf of the two lab5 organizations of which he is the duly elected chief executive officer, the Regional Counc6 and Local 1506.7 15. Plaintiff Michael Olds (Olds) is, and at all times mentioned in th8 complaint was, a resident ofGarden Grove, California, within the jurisdiction of this Cour9 At all times relevant, Olds was and is a member of the Carpenters and of Local Unio10 2361, United Brotherhood of Carpenters and Joiners of America (Local 2361),11 subordinate body of the Carpenters and of the Regional Council. At all times relevan12 Olds also was and is the democratically elected Financial Secretary of Local 2361,13 democratically elected delegate to the Regional Council and a democratically electe14 member of the Executive Committee of the Regional Council. At all times relevant, Old15 also was employed as an Administrative Assistant by the Regional Council. Olds bring16 this action on his own behalf and on behalf of the Regional Council of which he is17 member.18 16. PlaintiffLindsey Maldoon (Maldoon) is, and at a ll times mentioned in th19 complaint was, a resident of Simi Valley, California, within the jurisdiction of this Cour20 At all times relevant, Maldoon was and is a member of the Carpenters and of Local 15021 and is an elected delegate to the Regional Council. A t all times relevant, Maldoon als22 was employed as a Special Representative of the Regional Council working out of th23 offices of Local 1506. Maldoon brings this action on his own behalf and on behalf of th24 Regional Council and Local 1506, both of which he is a member.2526 THE REGIONAL COUNCILS TRUST FUNDS27 17. As the exclusive bargaining representative for approximately 65,0028 employees, the Regional Council, together with certain signatory employers, ha



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1 established certain jointly trusteed trust funds to provide health, retirement, training an2 other benefits to covered employees pursuant to Section 302(c)(5) of the LMRA, 29 U.S.C3 186(c)(5).4 18. Among the trust funds so established is the Southwest Carpenters Trainin5 Fund (Training Fund), which provides apprenticeship and other forms of training to th6 Regional Councils members and potential members. The Training Fund is an employe7 welfare benefit plan within the meaning of Section 3( 1)(A) of the Employee Retiremen8 Income Security Act of 1974, as amended (ERISA), 29 U.S.C. 1002(1)(A). Th9 Training Fund maintains its principle place of business at 533 South Fremont Avenue

10 Suite 401, Los Angeles, CA 90071, within the jurisdiction of this Court. The seve11 employee-representative (i.e., union) trustees of the Training Fund include Doug, who12 Co-Chairman, and Mike.13 19. The RegionalCouncil a lso has established the Southwest Carpenters Pensio14 Trust (Pension Fund). The Pension Fund maintains its principle place of business at 5315 South Fremont Avenue, Los Angeles, CA 90071, within the jurisdiction of this Court. Th16 PensionFund is an employee pension benefit plan within the meaning of Section 3(2)(A17 of the ERISA, 29 U.S.C. 1002(2)(A). The seven employee-representative (i.e., union18 trustees of the Pension Fund include Doug, who is Chairman, and Mike.19 20. The Regional Council also has established the Southwest Carpenters Healt20 & Welfare Trust (Health Fund). The Health Fund is an employee welfare benefit plan21 within the meaning of Section 3(1)(A) of ERISA, 29 U.S.C. 1002(1)(A). The Healt22 Fund maintains its principle place of business at 533 South FremontAvenue, Los Angeles23 CA 90071, within the jurisdiction of this Court. The seven employee-representative (i.e24 union) trustees of the Health Fund include Doug, who is Chairman, and Mike.25 21. John T. DeCarlo (DeCarlo) of DeCarlo & Shanley (DeCarlo Firm) is26 California attorney and General Counsel to the Carpenters, to the Regional Counsel, t27 Local 1506 and to many other entities related to the Carpenters. DeCarlo also is co28 counsel to the Training Fund, the Pension Fund and the Health Fund (collectively, Trus



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1 Funds), having been designated as such by the employee-representative (i.e., union2 trustees of the respective Trust Funds. The DeCarlo Firm maintains its principle place o3 business at 533 S. Fremont Ave., 9th Fl., Los Angeles, CA 90071.4 22. The Trust Funds are employee benefit plans as defined in Section 3(3) o5 ERISA, 29 U.S.C. 1002(3). Doug, Mike and the other employee-representative trustee6 of the Trust Funds are fiduciaries with respect to the Trust Funds on which they serv7 within the meaning of Sections 402(a), 404,406 and 407 of ERISA, 29 U.S.C. 1102(a)8 1104, 1106 and 1107.9 23. The Carpenters, the Regional Council, DeCarlo and the DeCarlo Firm ar

10 parties in interest with respect to each of the Trust Funds and each Trust Fund is a part11 in interest with respect to the other Trust Funds as that term is defined in Section 3(1412 of ERISA, 29 U.S.C. 1002(14), and within the meaning of Section 406 of ERISA, 2913 U.S.C. 1106.1415 FACTS COMMON TO ALL CLAIMS FOR RELIEF16 24. As an international labor organization, the Carpenters are governed by th17 Constitution of the United Brotherhood of Carpenters and Joiners of America and Rule18 for SubordinateBodiesUnder its Jurisdiction (Constitution), a true, correct and complet19 copy of which is attached hereto as Exhibit A. The Constitution is a contract between th20 Carpenters and the Regional Council, between the Carpenters and Local 1506 and betwee21 the Carpenters and its members, including Plaintiffs. The Constitution is a contract22 between any such labor organizations within themeaning ofSection 301(a) of the LMRA23 29 U.S.C. 185(a).24 25. Pursuant to Section 6, Paragraph D of its Constitution, the Carpenters:25 . . . shall have the right to establish supervision [i.e., a26 trusteeship] over and to conduct the affairs of any subordinate27 body (including the removal of any or all officers of such28 subordinate body) to correct financial irregularities or to assure



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1 the performance of collective bargaining agreements and the2 responsibility of the subordinate body as a bargaining agent or3 to protect the interests and rights of the members or whenever4 the affairs of the subordinate body are conducted in such a5 manner as to be detrimental to the welfare of the members and6 to the best interests of the [Carpenters].7 26. Section 10, Paragraph H of the Constitution then provides as follows:8 Whenever it appears to the satisfaction of the General9 President that any Local Union or member thereof, or any10 Council is acting contrary to the welfare of the United11 Brotherhood of Carpenters and Joiners of America, or that12 supervision should be established over the conduct of the affairs13 of any subordinate body as set forth in Section 6D, the General14 President may appoint a committee to hold a hearing, after due15 notice to such subordinate body ormember. Upon completion of16 the hearing, the committee shall report its findings and17 recommendations to the General Executive Board and to the18 member or subordinate body involved. The General Executive19 Board is empowered to take such action as is necessary and20 proper for the welfare of the United Brotherhood of Carpenters21 and Joiners of America, subject, however, to the right of appeal22 to the next General Convention, to the extent permitted by23 Section 53G. If the General President determines that an24 emergency situation exists, the General Presidentmay appoint25 a representative to assume supervision over any Local Union26 or Council pending the holding of a hearing and the27 completion of the proceedings as providedfor in this Section.28 (Emphasis added).



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1 27. As an intermediate labor organization, the Regional Council is governed b2 its Bylaws and Trade Rules (Bylaws), a true, correct and complete copy of which i3 attached hereto as Exhibit B. Pursuant to Section 8 of its Bylaws,4 The Executive Secretary-Treasurer shall be the ChiefExecutive5 Officer of the Council. The Executive Secretary-Treasurer shall6 be responsible for the management and supervision of the field7 activities, business office(s), and for conducting the daily8 business of the Council.9 Pursuant to Section 10 of the Bylaws,10 Between meetings [of the delegates to the Regional Council],11 the Executive Committee shall have supervision of such Council12 business as has not otherwise been granted to officers of the13 Council.14 And pursuant to Section 11 of the Bylaws,15 The Trustees [of the Regional Council, not of any Trust Fund]16 shall have supervision of all funds and properties of the Council17 subject to such instructions from the Executive Committee as18 they may receive from time to time. The title to all property of19 the Council shall be held in the name of the Trustees of the20 Council and/or their successors in office.21 28. On May 11, 2013, Eileen McCarron (Eileen), the elderly mother of Dou22 and Mike, fell and was hospitalized; she died on May 21 , 2013. Mike and his wife hav23 been the co-trustees of Eileens family trust since August 6, 2004.24 29. Shortly after Eileens death, Doug demanded that Mike and his wif25 immediately liquidate Eileens family trust. Doug then accused Mike and his wife o26 removing him as a co-trustee of their mothers family trust and accused Mikes wife o27 stealing from the trust. Mike denied the accusations; Doug was never a co-trustee of th28 family trust. Doug became furious. At Eileens funeral onMay 24, 2013, Doug toldMike

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1 Youre done.2 30 . On May 28, 2013, Mike approached DeCarlo about an investment in Unio3 Labor Life InsuranceCompany, a privately held insurance company domiciled in Marylan4 (ULLICO), that Doug and Eileen had made in the early 2000s, partially with family tru5 assets. DeCarlo did not provide Mike with any information. On or about May 29 or 306 2013, DeCarlo informed Mike that, if he did not back down over ULLICO and the famil7 trust, his brother [Doug] was going to go after him for certain lease agreements betwee8 the Regional Council and the Training Fund discussed below.9 31. At approximately the same time, Doug, Mike and their siblings sought t

10 arrange a meeting with the attorney for Eileens family trust. During a telephon11 conversation among Doug, Mike, and their siblings, Doug again demanded that Mik12 liquidate the trust and Mike confrontedDoug concerning the money Eileens trust had lo13 as a result of the ULLICO investment. As a direct result of the animosity between Dou14 and Mike, the meeting with the attorney never took place.1516 THE IMPROPER EMERGENCY TRUSTEESHIP17 OF THE REGIONAL COUNCIL18 32. On June 28,2013, Doug caused Draper to bring internal union charges agains19 Mike pursuant to Section 14, Paragraph D of the Constitution. A true, correct an20 complete copy of the internal union charges against Mike is attached hereto as Exhibit C21 The internal charges essentially allege that Mike breached his fiduciary duty to th22 Regional Council by causing the overcharging of the Training Fund for rent.23 33. Since long before Mike was elected as its Executive Secretary-Treasurer an24 including times when Doug was its Executive Secretary-Treasurer, the Regional Counc25 has owned certain real property throughout the Southwest. From time to time during thes26 many years, the Regional Council has rented some of these properties to the Training Fund27 34. Although the record owner of the property is CPT/SC Title Holdin28 Corporation (CPTISC), Plaintiffs are informed and believe and on the basis of suc



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1 information and belief aver that the Pension Fund is the beneficial owner of the rea2 property and improvements located at 533 S. Fremont Ave., Los Angeles, CA 900713 CPT/SC, on behalf of and for the benefit of the Pension Fund, rents office space to th4 Regional Council, the DeCarlo Firm, the Pension Fund, the Training Fund and the Healt5 Fund.6 35. Each of the rental arrangements described above is and was a prohibite7 transaction between a plan and a party in interest within the meaning of Sectio8 406(a) of ERISA, 29 U.S.C. 1106(a).9 36. Each of the rental arrangements described above is and was subject to th

10 statutory exemptions from prohibited transactions provided in Section 408(b)(2) o11 ERISA, 29 U.S.C. 1 108(b)(2), and the Prohibited Transaction Exemption (PTE) 76-1(4112 FR 12740, March 26, 1976, as corrected by 41 FR 16620, April 20 , 1976), issued by th13 Secretary of Labor pursuant to Section 408(a) of ERISA, 29 U.S.C. 1108(a).14 37. Beginning in or around 2011, other training funds related to the Carpenter15 began being audited by the United States Department of Labor (DOL).16 38. At a meeting of the trustees of the Training Fund held on December 16, 201117 at whichboth Doug andMike were present, DeCarlo recommended that the Training Fun18 engage the services of an auditor, Bernard Kotkin (Kotkin), to analyze transactions o19 the Training Fund. Kotkin was so engaged. Prior to this meeting, neither DeCarlo nor an20 other professional retained by the Training Fund had ever recommended performing a21 analysis of any transactions of the Training Fund while Mike was a trustee.22 39. At a meeting of the trustees of the Training Fund held on March 16, 2012 a23 which both Doug and Mike were present, auditor Kotkin recommended that the Trainin24 Funds building leases and appraisals be updated. Prior to this meeting, neither DeCarlo25 nor any other professional retained by the Training Fund had ever recommende26 performing an appraisal of the Training Funds leases while Mike was a trustee. In May27 2012, John M. Griffin, a consultant retained by the Training Fund to review its entir28 operation, also recommended that values of the Training Funds leases be determined by



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1 independent appraisers.2 40. At a meeting of the trustees of the Training Fund held on June 15, 2012 a3 which both Doug and Mike were present, a motion was made, seconded and unanimousl4 adopted to authorize the Director of the Southwest Carpenters Training Fund to updat5 appraisals or obtain new appraisals of all real property owned by the Fund and to mak6 recommendations to the Board regarding the possible renewal or revision of lease7 between the Southwest Regional Council of Carpenters and the Southwest Carpenter8 Training Fund.9 41. By approximately March 2013, the final appraisals regarding most of th

10 Training Funds leases were known to the Carpenters, the Regional Council, the Trainin11 Fund, Mike and Doug. The appraisals showed that the Training Fund was paying abov12 market value for many rental properties owned by the Regional Council and other entities13 including local unions affiliatedwith the Carpenters and the Regional Council and entitie14 totally unrelated to the Carpenters. At a meeting of the Executive Committee of th15 Regional Council held in March 2013, Mike reported the possible overpayments to th16 Executive Committee and the Committee authorized the repayment to the Training Fun17 of any such overpayments. Mike further reported that the Training Fund hired a qualifie18 professional asset manager (QPAM) and the QPAM would determine the rent overag19 amount owed to the Training Fund.20 42. In May 2013, the final appraisals regarding all of the Training Funds lease21 were completed and fully analyzed by the Carpenters, the Regional Council, the Trainin22 Fund, Mike and Doug. By letter dated May 31, 2013, the Training Fund, by its propert23 manager, requested a total refund due to the [Training] Fund from the [Regional] Counc24 of $4,736,970.52 for the period from January 1, 2008 to December 31, 2012. On Upo25 receipt of the request, Mike caused his chief of staff to poll the Executive Committe26 regarding payment of the refund due to the Training Fund. The Training Fund wa27 refunded the entire overpayment, including interest, that same day. The Executiv28 Committee officially ratified the payment at its June 2013 meeting.



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1 43. Plaintiffs are informed and believe and on the basis of such information an2 belief aver that no appraisal of the leases to the Regional Council, the DeCarlo Firm, th3 Training Fund and the Health Fund at 533 S. FremontAve., Los Angeles, CA 90071, hav4 been performed sinceMike becameExecutive Secretary-Treasurerof the Regional Counc5 and a Trustee of the Pension Fund.6 44. No internal union charges have been brought against any other unionmembe7 who had served as a trustee of the Training Fund, including Doug. No internal unio8 charges have been brought against any Trustee of the Regional Council, who ha9 supervision of all funds and properties of the Council.

10 45. On July 19, 2013, Banes placed the Regional Council into a so-calle11 emergency trusteeship and appointed Draper as the Regional Councils trustee. A true12 correct and complete copy of Banes letter notifying the Regional Council and Mike of th13 trusteeship and of the appointment ofDraper is attached hereto as Exhibit D. The primar14 purported basis for the emergency trusteeship were the internal charges against Mike.15 46. On July 22, 2013, and acting in his purported authority as trustee of th16 Regional Council, Draper removed Mike from his elected positions as Executiv17 Secretary-Treasurer of the Regional Council and a member of its Executive Committee18 Draper subsequently changed the locks on the Regional Councils offices.19 47. On August 6, 2013 and acting in his purported authority as trustee of th20 Regional Council, Draper removed Olds from his appointed position as an Administrativ21 Assistant of the Regional Council and from his elected position as a member of th22 Executive Committee, questioning Olds loyalty to the Brotherhood. The only loyalt23 actually in question was Olds loyalty to Doug.24 48. The trusteeship was imposed upon the Regional Council as a result of th25 family feud between Doug and Mike and not for any of the reasons authorized by Section26 302 of the LMRDA, 29 U.S.C. 462.27 49. No emergency existed in the Regional Council at the time the trusteeship wa28 imposed upon it.



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1 50. No fair hearing within the meaning of Section 304(d) of the LMRDA, 22 U.S.C. 464(d), and Paragraph H of Section 10 of the Constitution had been held befor3 the trusteeship was imposed over the Regional Council.4 51. Pursuant to Paragraph H of Section 10 of the Constitution, only the Genera5 President is authorized to determine that an emergency situation exists and suspend th6 democratic rights of a subordinate body. Nothing in the Constitution authorizes th7 General President to delegate such authority to the General Vice President, who pursuan8 to Paragraph A of Section 11 of the Constitution may only render such assistance to th9 General President as may be required. (Emphasis added). Under the Constitution, Bane

10 had no power to impose the emergency trusteeship upon the Regional Council.1112 THE BELATED AND IMPROPER NOTICE OF HEARING ON13 THE TRUSTEESHIP OF THE REGIONAL COUNCIL14 52. On September 11, 2013, and claiming a dispensation presumably from th15 provisions of the Constitution, Banes notified members ofLocal Unions affiliated with th16 Regional Council that B anes had reason to believe that the emergency trusteeship he ha17 improperly imposed upon the Regional Council should be continued and had appointed18 hearing committee to determine the issue. A true, correct and complete copy of Banes19 letter notifying the membership of the appointment of the hearing committee and of th20 hearing on the trusteeship is attached hereto as Exhibit E. Plaintiffs are informed an21 believe and on the basis of such information and belief aver that, as late as September 2022 2013, many members of Loca l Unions affiliated with the Regional Council had no23 received Banes letter.24 53. Pursuant to Paragraph H of Section 10 of the Constitution, only the Genera25 President is authorized to determine that any Council is acting contrary to the welfare o26 the United Brotherhood of Carpenters and Joiners of America, or that supervision shoul27 be established over the conduct of the affairs of any subordinate body as set forth i28 Section 6D and only the General President may appoint a committee to hold a hearing

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1 after due notice to such subordinate body. Nothing in the Constitution authorizes an2 person or body to dispense with its provisions for any reason.3 54. Although most of the Regional Councils membership resides and works i4 Southern California, the hearing improperly noticed by Bane is scheduled to take plac5 beginning on October 16, 2013, in Las Vegas, Nevada, which is where Doug resides.67 THE DE FACTO TRUSTEESHIP OF LOCAL 15068 55. On the evening ofFriday, August 16, 2013, Local 1506 was scheduled to hav9 its regular meetings of its Executive Board and of its membership.

10 56. Through the use of armed security guards hired by Draper for the Regiona11 Council, Doug barred Mike from presiding over the meetings of the Executive Board an12 of the membership of Local 1506. Doug has caused the locks on Local 1506s doors to b13 changed and Mike has been threatened with arrest if he enters Local 1506s building.14 57. On August 20, 2013, Doug caused Maldoon to be terminated as a Specia15 Representative of the Regional Counsel for causing Local 1506s gates to be locked ope16 so that members could park their cars and attend the August 16h meeting.17 58. By denying Mike his right and his duty as the democratically electedPresiden18 of Local 1506 to preside over meetings of the Executive Board and of the membership, b19 changing Local 1506s locks and denying Mike access to Local 1506s offices and b20 firing Maldoon for allowingmembers ofLocal 1506 to attend their ownmeeting, Doug ha21 placed Local 1506 into a defacto trusteeship without any fair hearing or declaration o22 emergency.2324 FIRST CLAIM FOR RELIEF (RELATING TO THE TRUSTEESHIP25 OF THE REGIONAL COUNCIL): VIOLATION OF LMRDA 30226 59. Plaintiffs repeat and reaver each and every averment contained in paragraph27 1 through 58 above as if repeated here in full.28 III



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1 60. By having the General Vice President impose a trusteeship upon the Regiona2 Council without a fair hearing and without an emergency, Defendants did not act i3 accordance with the Constitution and thereby violated Section 302 of the LMRDA, 24 U.S.C. 462.5 61. By imposing an emergency trusteeship upon the Regional Council without6 fair hearing for reasons other than stated therein, Defendants violated Section 302 of th7 LMRDA, 29 U.S.C. 462.8 62. By having the General Vice President notice a hearing for a trusteeship of th9 Regional Council in Las Vegas, Nevada and appoint a hearing committee, Defendants di

10 not ac t in accordance with the Constitution and thereby violated Section 302 of th11 LMRDA, 29 U.S.C. 462.12 63. By virtue of Defendants violations of Section 302 of the LMRDA describe13 above, Plaintiffs are entitled to appropriate declaratory and injunctive relief. Plaintiffs an14 the membership of the local unions affiliated with the Regional Council have suffered an15 are likely to continue to suffer severe and irreparable harm. Unless Defendants ar16 restrained by a temporary, preliminary and permanent injunction, Plaintiffs and th17 membership of the local unions affiliated with the Regional Council will continue to suffe18 severe, irreparable harm, in that they will continue to be deprived of their democratic right19 under the LMRDA. Plaintiffs have no adequate remedy at law because monetary damage20 will not afford adequate relief for the denial of federally protected democratic rights.21 64. By virtue ofDefendants violations of Section 302 of the LMRDA describe22 above, Plaintiffs and the Regional Council are entitled to be made whole for any losses o23 additional costs they have incurred as a result of the improper emergency trusteeship.24 65. By virtue of Defendants violations of Section 302 of the LMRDA describe25 above, Plaintiffs are entitled to an award of their reasonable attorneys fees and costs o26 suit.27 III28 III



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1 SECOND CLAIM FOR RELIEF (RELATING TO THE TRUSTEESHIP2 OF THE REGIONAL COUNCIL): BREACH OF CONTRACT3 66. Plaintiffs repeat and reaver each and every averment contained in paragraph4 1 through 65 above as if repeated here in full.5 67. By having the General Vice President impose an emergency trusteeship upo6 the Regional Council without a hearing and without an emergency, Defendants breache7 the terms of the Constitution.8 68. By imposing an emergency trusteeship upon the Regional Council without9 hearing for reasons other than stated therein, Defendants breached the terms of th10 Constitution.11 69. By having the General Vice President notice a hearing for a trusteeship of th12 Regional Council in Las Vegas, Nevada and appoint a hearing committee, Defendant13 breached the terms of the Constitution.14 70. By removing Mike, O lds and Maldoon from their elected and appointe15 offices and jobs, Defendants breached the terms of the Constitution.16 71. As a direct result of the breaches of the Constitutions described above17 Plaintiffs and the Regional Council have suffered damages.18 72. By virtue of breaches of the Constitutions described above, Plaintiffs ar19 entitled to appropriate declaratory and injunctive relief. Plaintiffs and the membership o20 the local unions affiliated with the Regional Council have suffered and are likely t21 continue to suffer severe and irreparable harm. Unless Defendants are restrained by22 temporary, preliminary and permanent injunction, Plaintiffs and the membership of th23 local unions affiliated with the Regional Council will continue to suffer severe, irreparabl24 harm, in that they will continue to be deprived of their democratic rights under the25 Constitution. Plaintiffs have no adequate remedy at law because monetary damages wi26 not afford adequate relief for the denial of democratic rights.27 73. By virtue of breaches of the Constitution described above, Plaintiffs and th28 Regional Council are entitled to damages in amounts to be proven at trial .



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1 74. By virtue of breaches of the Constitution described above, Plaintiffs ar2 entitled to an award of their reasonable attorneys fees and costs of suit.34 THIRD CLAIM FOR RELIEF (RELATING TO THE DE FACTO5 TRUSTEESHIP OF LOCAL 1506): VIOLATION OF LMRDA 3026 75 . Plaintiffs repeat and reaver each and every averment contained in paragraph7 1 through 58 above as if repeated here in full.8 76 . By having the General President impose a defacto trusteeship upon Loca9 1506 and thus depriving its membership of their democratic rights without a hearing an

10 without declaring an emergency, Defendants did not act in accordance with th11 Constitution and thereby violated Section 302 of the LMRDA, 29 U.S.C. 462.12 77 . By imposing a defacto trusteeship upon Local 1506 without a fair hearing fo13 reasons other than stated therein, Defendants violated Section 302 of the LMRDA, 214 U.S.C. 462.15 78. By virtue ofDefendants violations of Section 302 of the LMRDA describe16 above, Plaintiffs are entitled to appropriate declaratory and injunctive relief. Plaintiffs an17 the membership ofLocal 1506 have suffered and are likely to continue to suffer severe an18 irreparable harm. Unless Defendants are restrained by a temporary, preliminary an19 permanent injunction, Plaintiffs and the membership ofLocal 1506 will continue to suffe20 severe, irreparable harm, in that they will continue to be deprived of their democratic right21 under the LMRDA. Plaintiffs have no adequate remedy at law because monetary damage22 will not afford adequate relief for the denial of federally protected democratic rights.23 79 . By virtue ofDefendants violations of Section 302 of the LMRDA describe24 above, Plaintiffs are entitled to an award of their reasonable attorneys fees and costs o25 suit.26 III27 III28 II



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I FOURTH CLAIM FOR RELIEF (RELATING TO THE DE FACTO2 TRUSTEESHIP OF LOCAL 1506): BREACH OF CONTRACT3 80. Plaintiffs repeat and reaver each and every averment contained in paragraph4 1 through 58 and 75 through 79 above as if repeated here in full.5 81. By having the General President impose a defacto trusteeship upon Loca6 1506 and thus depriving its membership of their democratic rights without a fair hearin7 and without an emergency, Defendants breached the terms of the Constitution.8 82. By imposing a defacto trusteeship upon Local 1506 without a fair hearing fo9 reasons other than stated therein, Defendants breached the terms of the Constitution.

10 83. By virtue of breaches of the Constitutions described above, Plaintiffs ar11 entitled to appropriate declaratory and injunctive relief. Plaintiffs and the membership o12 Local 1506 have suffered and are likely to continue to suffer severe and irreparable harm13 Unless Defendants are restrained by a temporary, preliminary and permanent injunction14 Plaintiffs and the membership of Local 1506 will continue to suffer severe, irreparabl15 harm, in that they will continue to be deprived of their democratic rights under th16 Constitution. Plaintiffs have no adequate remedy at law because monetary damages wi17 not afford adequate relief for the denial of these democratic rights.18 84. By virtue of breaches of the Constitutions described above, Plaintiffs ar19 entitled to an award of their reasonable attorneys fees and costs of suit.2021 WHEREFORE, PLAINTIFFS PRAYS FOR JUDGMENT AGAINST22 DEFENDANTS AS FOLLOWS:23 a. On the first claim for relief:24 i. A declaration by this Court that:25 (1) Under the Carpenters Constitution, only the General Presiden26 of the Carpenters may impose an emergency trusteeship upon27 subordinate body, including the Regional Council;28 III



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1 (2) Under its Constitution, the General President of the Carpenter2 may not delegate his authority to impose an emergenc3 trusteeship upon a subordinate body, including the Regiona4 Council, to the General Vice President;5 (3) Whether or not the General President of the Carpenters coul6 delegate his authority to impose an emergency trusteeship upo7 a subordinate body, including the Regional Council, n8 emergency existed at the time the trusteeship was imposed upo9 the Regional Council;

10 (4) The emergency trusteeship of the Regional Council was no11 imposed for the purpose of correcting corruption or financia12 malpractice, assuring the performance of collective bargainin13 agreements or other duties of a bargaining representative14 restoring democratic procedures, or otherwise carrying out th15 legitimate objects of such labor organization;16 (5) The emergency trusteeship over the Regional Council impose17 by Defendants was in violation of the provisions of Title III o18 the LMRDA (29 U.S.C.A. 461, et seq.) and was withou19 effect;20 (6) The actions of Defendants in removing Mike as the electe21 Executive Secretary-Treasurer of the Regional Council and22 member of its Executive Committee, removing Olds as a23 appointedAdministrative Assistant and as an electedmember o24 the Executive Committee and removing Maldoon as a25 appointed Special Representative of the Regional Council wer26 likewise in breach of the terms of the Constitution and thereb27 violated Section 302 of the LMRDA, 29 U.S.C. 462; and28 III



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1 (7) Under the Carpenters Constitution, only the General Presiden2 of the Carpenters may determine cause to hold a trusteeshi3 hearing regarding a subordinate body, including the Regiona4 Council, and appoint a hearing committee;5 ii. A temporary, preliminary and permanent order by this Court:6 (1) Enjoining and restraining Defendants and the officers, agent7 employees, attorneys, and all persons in active concert o8 participation with them from continuing the emergenc9 trusteeship imposed upon the Regional Council;

10 (2) Directing Defendants to restore all property, rights, privilege11 and power of autonomy otherwise available to the Regiona12 Council under the Constitution;13 (3) Directing Defendants to reimburse the Regional Council for a14 expenditures and disbursements made by them under th15 trusteeship for salaries and expenses ofDefendants or any othe16 officer or agent of the Carpenters, and all other imprope17 expenditures of the Regional Councils funds made by them18 including but not limited to changing the locks of the Regiona19 Council and retaining security guards;20 (4) Directing Defendants to make Plaintiffs whole for the21 wrongful removals from their elected offices and/or appointe22 positions;23 (5) Directing Defendants to reinstate Plaintiffs to their electe24 offices and/or appointed positions; and25 (6) Enjoining and restraining Defendants and the officers, agents26 employees, a tto rneys, and all persons in active concert o27 participation with the Carpenters from imposing any trusteeshi28 or otherwise interfering with the power of autonomy availabl



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1 to the Regional Council under the Constitution until such tim2 as it has fully complied with the procedural requirements of th3 Constitution and a trusteeship is authorized after a fair hearing4 in accordance with the Constitution.5 b. On the second claim for relief:6 i. A declaration by this Court that:7 (1) Under the Carpenters Constitution, only the General Presiden8 of the Carpenters may impose an emergency trusteeship upon9 subordinate body, including the Regional Council;

10 (2) Under its Constitution, the General President of the Carpenter11 may not delegate his authority to impose an emergenc12 trusteeship upon a subordinate body, including the Regiona13 Council, to the General Vice President.14 (3) Whether or not the General President of the Carpenters coul15 delegate his authority to impose an emergency trusteeship upo16 a subordinate body, including the Regional Council, n17 emergency existed at the time the trusteeship was imposed upo18 the Regional Council;19 (4) The emergency trusteeship of the Regional Council was no20 imposed for the purpose of correcting corruption or financia21 malpractice, assuring the performance of collective bargainin22 agreements or other duties of a bargaining representative23 restoring democratic procedures, or otherwise carrying out th24 legitimate objects of such labor organization; and25 (5) The emergency trusteeship over the Regional Council impose26 by Defendants was in breach of the terms of the Constitution27 and,28 III



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1 (6) The actions of Defendants in removing Mike as the electe2 Executive Secretary-Treasurer of the Regional Council and3 member of its Executive Committee, removing Olds as a4 appointed Administrative Assistant and as an elected member o5 the Executive Committee and removing Maldoon as a6 appointed Special Representative of the Regional Council wer7 likewise in breach of the terms of the Constitution.8 ii. A temporary, preliminary and permanent order by th is Court:9 (1) Enjoining and restraining Defendants and the officers, agent10 employees, attorneys, and all persons in active concert o11 participation with them from continuing the emergenc12 trusteeship it has assumed over the Regional Council;13 (2) Directing Defendants to restore all property, rights, privileges14 and power of autonomy otherwise available to the Regiona15 Council under the Constitution;16 (3) Directing Defendants to reimburse the Regional Council for al17 expenditures and disbursements made by them under th18 trusteeship for salaries and expenses of Defendants or any othe19 officer or agent of the Carpenters, and all other imprope20 expenditures of the Regional Councils funds made by them21 including but not limited to changing the locks of the Regiona22 Council and retaining security guards;23 (4) Directing Defendants to reinstate Plaintiffs to their electe24 offices and/or appointed positions; and25 (5) Enjoining and restraining Defendants and the officers, agents26 employees, attorneys, and all persons in active concert o27 participation with the Carpenters from imposing any trusteeshi28 or otherwise interfering with the power of autonomy availabl



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1 to the Regional Council under the Constitution until such tim2 as it has fully complied with the procedural requirements of th3 Constitution and a trusteeship is authorized after a fair hearin4 in accordance with the Constitution.5 iii. Damages in amounts to be proven at trial.6 c. O n the third claim for relief:7 i. A declaration by this Court that:8 (1) Under the Carpenters Constitution, the General President of th9 Carpenters may not impose a trusteeship upon a subordinat

10 body, including Local 1506, without first declaring a11 emergency or conducting a hearing;12 (2) Whether or not the General President of the Carpenters coul13 impose an emergency trusteeship upon a subordinate body14 including Local 1506, without first declaring an emergency, n15 emergency existed at the time the de facto trusteeship wa16 imposed upon Local 1506;17 (3) The defacto trusteeship of Local 1506 was not imposed for th18 purpose of correcting corruption or financial malpractice19 assuring the performance of collective bargaining agreements o20 other duties of a bargaining representative, restoring democrati21 procedures, or otherwise carrying out the legitimate objects o22 such labor organization; and23 (4) The de facto trusteeship over Local 1506 imposed b24 Defendants was in violation of the provisions of Title III of th25 LMRDA (29 U.S.C.A. 461, et seq.) and was without effect26 and,27 (5) The actions of Defendants in removing Mike as President o28 Local 1506 was likewise unlawful and without effect.



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1 ii. A temporary, preliminary and permanent order by this Cou rt:2 (1) Enjoining and restraining Defendants and the officers, agents3 employees, attorneys, and all persons in active concert o4 participation with them from continuing the emergenc5 trusteeship it has assumed over Local 1506;6 (2) Directing Defendants to restore all property, rights, privileges7 and power of autonomy otherwise available to Local 1506 unde8 the Constitution;9 (3) Directing Defendants to reimburse Local 1506 for a

10 expenditures and disbursements made by them under th11 trusteeship for salaries and expenses ofDefendants or any othe12 officer or agent of the Carpenters, and all other imprope13 expenditures of Local 1506s funds made by them;14 (4) Directing Defendants to reinstate Mike as President of Loca15 1506; and16 (5) Enjoining and restraining Defendants and the officers, agent17 employees, attorneys, and all persons in active concert o18 participation with the Carpenters from imposing any trusteeshi19 or otherwise interfering with the power of autonomy availabl20 to Local 1506 under the Constitution until such time as it ha21 fully complied with the procedural requirements of th22 Constitution and a trusteeship is authorized after a fair hearin23 in accordance with the Constitution.24 d. On the fourth claim for relief:25 i. A declaration by th is Court that:26 (1) Under the Carpenters Constitution, the General President of th27 Carpenters may not impose a trusteeship upon a subordinat28 body, including Local 1506, without first declaring a



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1 emergency or conducting a hearing;2 (2) Whether or not the General President of the Carpenters coul3 impose an emergency trusteeship upon a subordinate body4 including Local 1506, without first declaring an emergency, n5 emergency existed at the time the trusteeship was imposed upo6 Local 1506;7 (3) The trusteeship of Local 1506 was not imposed for the purpos8 of correcting corruption or financial malpractice, assuring th9 performance of collective bargaining agreements or other dutie

10 of a bargaining representative, restoring democratic procedures11 or otherwise carrying out the legitimate objects of such labo12 organization; and13 (4) The actions of Defendants in removing Mike as President o14 Local 1506 was likewise in breach of the terms of th15 Constitution.16 ii. A temporary, preliminary and permanent order by th is Court:17 (1) Enjoining and restraining Defendants and the officers, agents18 employees, attorneys, and all persons in active concert o19 participationwith them from continuing the defacto trusteeship20 it has assumed over Local 1506;21 (2) Directing Defendants to restore all rights, privileges, and powe22 of autonomy otherwise available to Local 1506 under the23 Constitution;24 (3) Directing Defendants to reimburse Local 1506 for al25 expenditures and disbursements made by them under the26 trusteeship for salaries and expenses ofDefendants or any othe27 officer or agent of the Carpenters, and all other imprope28 expenditures of Local 1506s funds made by them;



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1 (4) Directing Defendants to reinstate Mike as President of Loca2 1506; and3 (5) Enjoining and restraining Defendants and the officers, agents4 employees, attorneys, and all persons in active concert o5 participation with the Carpenters from imposing any trusteeshi6 or otherwise interfering with the power of autonomy availabl7 to Local 1506 under the Constitution until such time as it ha8 fully complied with the procedural requirements of th9 Constitution and a trusteeship is authorized after a fair hearin

10 in accordance with the Constitution.11 iii. Damages in amounts to be proven at tr ial .12 e. For reasonable attorneys fees and costs of suit; and13 f. For such other and further relief as the Court may deem just and equitable.1415 DATED: October 4, 2013 Respectfully submitted,16 Joseph L. Paller Jr.Robert A. Cantore17 Michael D. WeinerGILBERT & SACKMAN18 A Law Corporation

Attorneys for Plaintiffs22232425262728



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1 VERIFICATION2 I, Michael McCarron, am a plaintiff in the above captioned matter. I have read th3 foregoing complaint and know the contents thereof. The same is true of my ow4 knowledge, except as to those matters which are therein averred on information and belief5 and as to those matters, I believe them to be true.6 I declare under penalty of perjury under the laws of the United States of Americ7 that the foregoing is true and correct.

: Executed on October, 2013.

_______________________________

10 Michael McCarron11121314151617181920212223242526

Complaint Final.wpd28

VERWffiD COMPLAINT 28


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1 DEMAND FOR JURY TRIALPlaintiffs hereby demand a trial by jury of all issues triable of right by jury.

34 Dated: October 4, 2013 Respectfully submitted,5 Joseph L. Paller Jr.Robert A. Cantore6 Michael D. WeinerGILBERT & SACKMAN7 A Law Corporation

: BY7z/L0 Attorneys for Plaintiffs

111213141516171819202122232425262728



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55/154

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56/154

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57/154

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Mccarron Complaint

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