UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

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UNITED STATES OF AMERICA, Plaintiff, 90 Civ. 5722 (RMB) -against­ DISTRICT COUNCIL OF NEW YORK CITY and VICINITY OF THE UNITED BROTHERHOOD OF CARPENTERS and JOINERS OF AMERICA, et aI., Defendants.

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CSDNY DOCUMENT ELECTRONICALLY FILED DOC #' ___________ DATE FILED:..J[(..?7/(S

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Zero tolerance for impropriety (actual or potential) in Union affairs applies no less to the lawyers than to other union officials. It is very surprising to the Court that Government and other counsel copied on the Government's August 26,2013 letter failed to prevent the obvious potential conflict presented here. The AUSA is requested forthwith to seek out the facts and information it needs to ensure there is no conflict problem or issue with respect to all counsel, investigators, accountants, consultants, etc. representing the Benefit Funds and the District Council and to report back to the Court by September 10, 2013.

Dated: New York, New York August 27, 2013

RICHARD M. BERMAN, U.S.D.J.

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