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WEINER (SBN 240155) 4 GILBERT & SACKMAN, A LAW CORPORATION 3699 Wilshire Boulevard, Suite 1200 5 Los Angeles, California 90010-2732 6 Tel: (323) 938-3000 Fax: (323) 937-9139 7 Attorneys for Plaintiffs 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28


DECLARATION OF MICHAEL Mc(ARRON 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21


1, Michael McCarron, say and declare as flullows: 1. I am over 1 8 and am a party to this action. I have personal knowledge of the

fuels stated herein and, if called as a witness 1 could and would testify competently to those Cacts. 2. 1 am the Executive Secretary-Treasurer of the Southwest Regional Council

of Carpenters (Regional Council) and a member of its Executive Committee. I was elected to this position in 1999 and re-elected in 2003, 2007 and 2011. 1 also am the democratically elected President of Carpenters Local Union 1506, United Brotherhood of Carpenters and Joiners of America (Local 1506) and a democratically elected delegate to the Regional Council from Local 1 506. 3. My older brother Douglas McCarron (Doug) is General President of the

United Brotherhood of Carpenters and Joiners (Carpenters). He has held this office since 1995. Prior to being elected as General President of the Carpenters, Doug was the Executive Secretary-Treasurer of the Regional Council. Doug was and still is an elected officer and Regional Council delegate of Local 1506. 4. The Regional Council is an intermediate body within the Carpenters and is

chartered by and subordinate to the Carpenters. Approximately 33 local unions with 65,000 members located primarily in Southern California, but also in Nevada, Arizona, Utah, Colorado, New Mexico and West Texas, including Local 1506, are affiliated with and subordinate to both the Regional Council and the Carpenters.

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THE START OF THE FEUD BETWEEN DOUG AND ME 5. The relationship between me and my brother, Doug, has been strained since

December 16, 2011. On the morning of that day, I had breakfast with Doug. I discussed



By way of an analogy to our own system ofgovernment, the Carpenters is like the federal government, regional councils are like state governments, and local unions are like municipal governments.

a situation regarding 1)ougs long time girlfriend, Sandy Maloney. Ms. Maloney works


for Carpenters Southwest Administrative Corporation (CSAC), which is an

administrative corporation formed by Southwest Carpenters Pension Trust (Pension

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Fund), Southwest Carpenters Health & Welfare Trust (Health Fund), Southwest
Carpenters Training Fund (Training Fund) and other trust funds (collectively, the Trust Funds) to run the day-to-day affairs of the Trust Funds (ranging from making benefit

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payments to collecting delinquent contributions from employers). The Trust Funds are sponsored by the Regional Council to provide health, retirement, training and other benefits to its members pursuant to Section 302(e)(5) ofthe LMRA, 29 U.S.C.


Doug and I are trustees of all of these Trust Funds. In fact, Doug is still a chairman or co chairman of each one, dating back to the time he was Executive Secretary-Treasurer of the Regional Council. 6. The Trust Funds, the Regional Council as well as the law offices of DeCarlo

& Shanley (DeCarlo Finn) maintain their principle offices at 533 S. Fremont Avenue, Los Angeles, CA 90071, in a building which I believe is owned indirectly by the Pension Fund. The DeCarlo Firm is general counsel to the Carpenters, to the Regional Counsel and to Local 1506. The DeCarlo Firm is also co-counsel to all of the Trust Funds and to many other entities related to the Carpenters. Given that I am a Trustee of each of the Trust Funds and the Trust Funds are located in the same building as the Regional Council, I am
very familiar with their day-to-day operations. 7. Ms. Maloney has had many positions within CSAC, and was transferred from


position to position because she allegedly is difficult to work with and does not follow the rules. In spite of her less than stellar work record, I discovered that Ms. Maloney had just received a $66,000.00 raise, from $60,000 per year to $126,000. I told Doug that a raise more than doubling her salary was unmerited, and that the position she was currently in did not warrant a $126,000 a year salary. Doug told me, shell just never get another raise, and then told me to mind my own business. Until this time, I had generally done whatever my brother told me to do.

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During the evening of that same day (December 16, 2011), at a member

appreciation function at Local 209 in Sylmar, Calitbrnia, I again approached Doug in the parking lot about the $66,000 raise and other issues at the union. The discussion quickly degenerated into an argument. During this argument, Doug told me that he was going to kick

ass. After the December 16,2011 argument, Doug called and told me he was going

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to resign as General President. On or about December 19, 2011, he tendered letters of resignation to me (as President) for his offices at Local 1506. During the next several weeks, Doug sent me text messages and left voice-mail messages saying he was sorry and that he loved me. But alternating between the texts and messages, Doug would start another argument with me. I tried to stay away from him, because I was not sure what was going on with my brother. 10. A few weeks later, in early 2012, Doug and I called a truce. I did not approve

his resignation as an officer and delegate to Local 1506. But our relationship as brothers was non-existent and our professional relations was very tense. Since this time, Doug has excluded me from Carpenters business meetings and functions.

OUR MOTHERS ESTATE 11. Our mother, Eileen McCarron (Eileen), passed away on May21, 2013. She

was 91 years old. For a year prior to her death, Eileen had been living with my sister, Janet. 12. In late April 2013, my daughter and her family moved into Eileens house,

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which had been sitting vacant for about a year. Prior to that, I, my sister, Janet, and our older brother, Walt, had discussed the situation and agreed that my daughter and her family should move into our mothers home so that it would not continue to be uninhabited. 13. My brother Walt is somewhat of a hoarder. Over the past year, he had been

storing part of his collection of stuff in our mothers house. When it came time to clean out the house so that my daughter could move in, Walt became distraught, because it meant

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that his collection would have to be removed from the home. In an effort to stop the
move, Walt called the family attorney demanding inftrmation about our mothers family

trust. The attorney informed Walt that he could not give Walt any information, because only Eileen, I and my wife were trlLstees and his 2 clients. When Walt was informed he could not stop the cleaning out of our mothers home and his collection, he had a very difficult time dealing with this fact and called Doug. 14. Walt told Doug that my daughter was moving into our mothers house,

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purportedly against our mothers wishes. There was a lot of back and forth fighting between Janet and me on one side and Doug and Walt on the other. Eventually, Doug and Walt reluctantly agreed to let my daughter move into the home. Nevertheless, the family fight continued.

Our mother fell on May 11, 2013, and broke her hip, pelvis, shoulder and had

massive bruising all over her body and face. She passed away from complications from thefallonMay2l,2013. I/I

My wife and I have been trustees ofmy mothers estate since 2004. That year, I came across a manila envelope at my mothers home, which contained information for a front loaded annuity. I asked my mother what it was, but she was not sure and did not remember buying an annuity. My wife and I determined that the documents were various agreements that my mom had signed to invest in a front loaded annuity that would not have matured until her birthday, which I believe was not a very smart retirement investment. In addition, my mother owned rental properties and had un-deposited rent checks, and one tenant was not paying rent at all. My wife, Kathy, took it upon herself to figure everything out and put my mothers finances in order. Together, we were able to recover about $90,000.00 of my mothers money. When I told my siblings (Walt, Doug and Janet) about our mother and her finances, we scheduled a meeting with the family attorney on June 10, 2004. The attorney suggested that we could add co-trustees to our mothers family trust to watch over her spending. Everyone agreed that my wife and I should be co-trustees since we lived two miles away and saw Eileen just about every day. The new trust arrangement naming my wife and me as trustees was finalized on August 6, 2004.

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16. believed that

In spite ofthe actual facts, when our mother passed away, both Walt and Doug

wife and I had taken them off the trust as trustees. Actually, Doug and

Walt were never trustees. Around the time of our mothers death, Doug called me and, when I asked how he was, said, 1 was doing alright until this morning. Im gonna ask you one question. Did you and Kathy remove me and Walt as trustees? I told Doug that we did not. Doug then called me a liar, made a disparaging remark about my wife, and went on to accuse my wife of stealing from our mothers estate. Doug also demanded that I and my wife immediately liquidate our mothers family trust. 17. On May 25, 2013, we held funeral services for our mother. I was outside the

church and my daughter was standing next to me. I was grieving the loss my mother and was in no mood for Doug and his vile allegations made about my wife. 18. Doug arrived and walked up along the side of the church. Doug walked right

between my daughter and me and forcibly grabbed the upper portion of my right arm. Doug then leaned in and got his face very close to mine while he said, Hey Mike, how ya doing. I didnt respond, and instead broke free of Dougs grip on my arm and told him to back up. Doug refused to back up, so I told him, Get the fuck away from me. Doug, who was still very close to me, said in a low, menacing voice, Youre done. 19. Things were so bad at Eileens funeral that Doug and Walt did not come to

Janets house with the rest of the family (including our mothers relatives from the East Coast) to mourn Eileens passing and to celebrate her life. 20. After the funeral, my wife started to go through Eileens financial records and

put everything in order for the family attorney. My wife came across documents and information relating to an investment in Union Labor Life Insurance Company, a privately held insurance company domiciled in Maryland (ULLICO), in which Doug apparently had gotten our mother involved in approximately 1998 or 1999. 21. According to the documents my wife discovered, Eileen had advanced

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approximately $117,000 to buy ULLICO stock. The stock, however, was issued in Dougs name. But for some reason, a check for $400,000.00 for the purchase of the ULLICO stock


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was made out to Eileen. During 2001 and 2002, the documents showed that Eileen had written checks to Doug totaling over $100,000.00. Im not sure of the exact facts, but our mother had to pay somewhere between $200 and $400 thousand back to ULLICO because of Dougs insider trading. Given what I had learned from my mothers document at hand, 1 wanted to learn all of the facts concerning this investment.

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1 recalled that some time between 2002 and 2004, John DeCarlo (DeCarlo),

the named partner in the DeCarlo Firm, had told me that my mother had to pay some money back to ULLICO. I also remembered that my wife and I (who either were trustees of Eileens family trust or just helping her out) had to get a lot of money together so that my mother could pay back ULLICO. I didnt understand what the problem was, but DeCarlo told me that Eileen had to pay this money back or she could get in trouble. Given that my brother (Doug) was involved, I didnt question it any further at the time. 23. I also recalled that, in 2005, DeCarlo had given me a box and bag of

information. DeCarlo told me to hold on to it and that it was information about Doug and Eileen and their investment in ULLICO. I asked what the information was, but DeCarlo didnt tell me. DeCarlo left the box and the bag in my office. The documents stayed in my office, where I forgot about until the week after Eileen died and my wife came across ULLICO information in my mothers paperwork. I then looked through the information in the box, but could not understand any of it. 24. On or about May 28, 2013, I asked DeCarlo about the ULLICO transaction.

I reminded him that I had the ULLICO boxes he had left with me and that there may be evidence of crime in there. My then chief of staff, Justin Weidner, was present at this meeting.

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THE INTERNAL UNION CHARGES AGAiNST ME 25. Either the next day, May

or May 30, 2013, DeCarlo told me that, if I

didnt back off on the 1.JLLICO matter, Doug was going to go after me for the lease agreements between the Regional Council and the Training Fund that are explained in


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greater detail in the Verified Complaint. 26. On or about June 28, 2013, internal union charges pursuant to Section 14,

Paragraph D of the Carpenters Constitution (14D Charges) were filed against me by Michael Draper, a regional Vice President of the Carpenters who sits on the General Executive Board of the Carpenters with Doug. I received the 14D Charges on Monday July 1, 2013. As DeCarlo had promised, the 14D Charges primarily related to the Training Fund leases. Verified Complaint, Exhibit C. 27. The delegates to the Regional Council meet every quarter, and a quarterly

meeting of the delegates was scheduled to take place on July 25, 2013. I planned to discuss the 14D Charges against me at the July 25t meeting. 28. Also, given that the 14D Charges arose out of my purported mis-handling of

the Training Funds leases with the Regional Council, that DeCarlo was counsel to both institutions and had never advised me that there may be an issue with the leasing agreements his office had drafted, that DeCarlo had been Dougs attorney since the time he was the Executive Secretary-Treasurer of the Regional Council and was clearly acting on his behalf and for other reasons, I came to believe to believe that DeCarlo and his firm were not acting in the best interests of the Regional Council or of the Trust Funds, including the Training Fund. Accordingly, I caused a request for proposal for new counsel to be sent on behalf of the Trust Funds and had a meeting scheduled with some prospective attorneys on Monday, July 22, 2013. It was my intent to also interview the firm for the Regional Council. 29. After the 14D Charges were filed, Doug began lobbying my closest friends

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and advisors. For example, I was informed by Michael Olds that on the afternoon of July 13, 2013, Doug had met with him. Olds is a member of the Regional Councils Executive Committee. According to Olds, Doug told him that I needed to resign. He also informed Mike Olds that my intention to discuss the 14D Charges and the personal family history leading up to them at the July /1/


delegates meeting was a bad idea.

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On July 13, 2013, at a meeting at my home, Justin Weidner (who was then

functioning as my chief of staff) told me that DeCarlo wanted me to call Charles Devant, Esq., an attorney with the firm of Williams & Connicy in Washington, D.C., to work out a settlement with Doug. According to Weider, he had met with DeCarlo on July 11,2013, and that DeCarlo told him (Weidner) that I needed to resign because I was a fiduciary with respect to the lease agreements. DeCarlo also told him that I needed to resign and that he [Weidner] and I could go to federal prison. DeCarlo neglected to mention to Weidner that Doug also was a fiduciary with respect to these leases and that ifWeidner and I were going to prison, so was he. 31. I was informed that Doug even met with the Regional Councils political

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consultant, Bill Luddy. I was informed by many people who spoke with Doug that I need to resign and that it wasnt a big deal because I had a good pension. I did not resign. 32. On the evening of July 14, 2013, Weidner called me and informed me that he

had met with Doug earlier that day, that he was resigning from the Regional Council as my chief of staff, and that he was going to work for the Carpenters as Dougs chief of staff.

THE SUPERVISION OF THE REGIONAL COUNCIL 33. In Carpenters jargon, a trusteeship is called a supervision. I was not able

to address the delegates to the Regional Council July 25th or to meet with prospective new counsel July 22 as I had planned. Instead, on Monday July 22, 2013, a purported emergency supervision of the Regional Council was imposed by the General Vice President ofthe Carpenters (and not by Doug) and I was removed by the supervisor/trustee from all ofmy elected positions in the Regional Council and as a Trustee of all of the Trust Funds that morning. Verified Complaint, Exhibit D. 34. The hearing on the 14D Charges against me was held during the week of

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September 9, 2013. In spite of what I believe to be tampering by Doug with a witness of mine and his falsification of a document presented in evidence against me, I presented a spirited defense, including 630 pages of documents and the testimony of nine witnesses

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in support of my case.

In the middle of the hearing, on September 11, 2013, and claiming a

dispensation presumably from the provisions ofits Constitution, the Carpenters General Vice President notified members ofLocal Unions affiliated with the Regional Council that he had reason to believe that the emergency supervision/trusteeship he had improperly imposed upon the Regional Council should be continued and had appointed a hearing committee to determine the issue. Verified Complaint, Exhibit E. 36. The purported reasons for believing that the supervision should be

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continued are slightly different than the purported reason for imposing the emergency trusteeship. Using his access to the Regional Councils records not only to comb through them but also to destroy them, Doug has now come up with some new charges against mc and the Regional Council. A few brief words about these latest charges against the Regional Council (and primarily me). Lines of Credit 37. Lines of credit are very difficult for contractors and construction companies

to obtain. Thus, for many years going back to when Doug was its Executive SecretaryTreasurer, it has been a standard operating procedure for the Regional Council to use its assets to guarantee lines of credit for signatory employers. Unfortunately, not all

contractors repay their lines of credit, and the Regional Council has suffered losses from time to time. However, Doug repeatedly has said that even if a contractor does not repay the money, the loan has paid the Union back ten fold, because it keeps union contractors competitive and union carpenters employed. On this point, I agree with Doug. 38. Among the lines of credit guarantees mentioned as possible reasons for

extending the supervision of the Regional Council, those of Santa Clarita Interiors and Best Interiors were inherited from my predecessor and Dougs successor as Executive Secretary-Treasurer, Jim Bemson. As to the line of credit to John Jory, I am informed and believe that it originally had been an unsecured loan of approximately $1 M from the Carpenters, not a line of credit. About a year and a half ago, Doug told me that the

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Regional Council had to take over the debt because John Jory operated in the Regional Councils territory. DeCarlo drafted the necessary papers, and John Jory now has a loan from the Regional Council that is secured by real property. Receipts for Expenses 39. It always has been my practice to turn in my receipts to my former chief of

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staff, Justin Weidner, who now works for Doug. Although Doug now claims that I failed to provide back-up receipts for credit card expenses for fiscal years ending June 30, 2010 and 2013, that is simply not true. I also note that an LM-2 form for 2010 was prepared by the Regional Councils certified public accountants and was filed with the United States Department of Labor as required by federal law. Presumably, the accountants saw the receipts for that year, which seemingly have disappeared now that Weidner has gone to work for Doug. No Investment/Real Estate Adviser of Manager 40. The Regional Council did not hire an investment management firm because

it did not invest any of the Regional Councils assets in the stock market. Instead, the Regional Councils $95 million dollars in marketable securities primarily consists of CDs and T-bills. To the extent advice on these securities was necessary, the Regional Council relied upon Lori Zisky, the financial controller for the Carpenters. As a direct result of its conservative investment strategy, the Regional Council was the only council in the Carpenters that did ,iot loose money when the market crashed in the late 2000s. Indeed, the Carpenters, which Doug had heavily invest in the stock market, lost approximately $200 million in a single year. 41. For real estate investments, the Regional Council has relied on the Carpenters

Director ofReal Estate, Randy Sowell, and DeCarlo, whose firm prepared the leases that are now one of the primary charges against me. Lease Agreements between the Training Fund and the Regional Council 42. While the leasing arrangement may have resulted in the overcharging of the

Training Fund by the Regional Council, I fail to see how that reflected poorly on my


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running of the Regional Council (which purportedly received the benefit of the overpayments). And while it may have been a prohibited transaction under ER ISA, my duties as a Fiduciary under ERISA were to the Training Fund, not to the Regional Council. And Doug (as well as five other union trustees) were subject to the same fiduciary duties

under ERISA. And once again, for all of these leases, the Regional Council relied on the Carpenters Director of Real Estate, Randy Sowell, and DeCarlo. Improper Personnel Practices 43. 1 am informed and believe that vacation pay is classified as wages under

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California law and that the California Labor Code prohibits the forfeiture of accrued vacation pay. Thus, payouts of earned by unused vacation pay have been the standard procedure in place at the Regional Council since at least the time Doug was its Executive Secretary Treasurer. Indeed, in 1995 (when he was elected as the Carpenters General President), Doug received a vacation payout of approximately $50,000.00 (in 1995 dollars); it remains the largest vacation payout in the Regional Councils history. To avoid similar massive payouts, the Regional Council has begun paying off vacation pay accruals when they become too high. Inadequate Review of the Regional Councils Finances by its Trustees 44. One of the major problems with Dougs internal charges against me is that the

Executive Secretary-Treasurer is not in charge of the Regional Councils property, and therefore is not in charge of its leases. Rather, under the Regional Councils Bylaws, the Regional Councils three Trustees shall have supervision of all funds and properties of the Council subject to such instructions from the Executive Committee [not the Executive Secretary-Treasurer] as they may receive from time to time. The Regional Councils Trustees are carpenters, not MBAs. If(and it is a very big if) they have failed to do their jobs properly over the past several years, I submit that a refresher course by the Carpenters would have been far more useful, far more democratic and a lot cheaper than a trusteeship. And whatever they have been doing incorrectly, they have been doing it for years.


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Lack of [)ocumcntation/Procedures for Work Preservation Program The Work Preservation Program is a long-standing practice in the

Carpenters for assisting signatory contractors and keeping them competitive on projects. The contractor in Denver mentioned but unnamed in the trusteeship notice (Exhibit E)is ENK Drywall. At the time its participation in the Program started, Colorado (including Denver) was part of the Kansas City Regional Council of Carpenters, not my Regional Council. When it was part of the other regional council, Doug caused the Carpenters to pay approximately $1 million dollars a year to ENK for work preservation. In 2010, the Regional Council received the state of Colorado through a merger. In 2013 (in the middle of my fight with him), Doug told me that the Regional Council had to foot the bill for the ENK work preservation program because it was now in the Regional Council jurisdiction. Long Term Parking 46. As previously noted, the geographic jurisdiction of the Regional Council

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covers all of Southern California, Nevada, Arizona, Utah, Colorado, New Mexico and West Texas. To service its members throughout this vast territory, the Regional Council has 130 vehicles, of which a few were strategically situated in various locations for use by me and the Regional Councils staff. Certain vehicles were taken from the fleet and left at locations for Regional Council staff use. On occasion, someone (including myself) may have left a vehicle in long term parking at an airport where it was forgotten. Although the procedures for leaving cars may need improvement, it is hardly a basis for a trusteeship. Chief of Staff Carried Dozen of pre-signed Blank Checks 47. Justin Weidner (Dougs new chief of staff and my old one) did not have

dozens of pre-signed blank checks. However, the fact remains that the individuals authorized to sign checks for the Regional Council (including myself) were often traveling on Regional Council business. In order to ensure that funds would be available for anything that would arise, it was a practice for Weidner to have a couple (less than five) pre-signed checks on hand. While this may not have been the safest practice, it is a


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practice in use throughout the Carpenters and I am unaware of any problems that have arisen as a result of it. Monthly Flower Bills 48. Underthe Regional Councils Bylaws,! was responsible forthe management

and supervision of the field activities, business office(s), and for conducting the daily business of the Council. Verified Complaint, Exhibit B. Put bluntly, I always was too busy to worry about flowers, and never directed that they be sent anywhere. 49. 1 am aware, however, of a monthly bill to the Regional Council from a florist.

The bills generally covered two things: i. It has been a long standing practice for the Regional Council to send flowers to a funeral for a member, an employee, a major signatory employer and others. If someone died, Justin Weidner (Dougs new chief of staff and my old one) would make sure that flowers were sent. ii. The Regional Council has a lot of live plants as part of its decor. To keep them alive and looking good, the Regional Council has retained a florist to water, feed and do whatever else is necessary for the live plants. 50. I did not personally direct[] that $1,300 dollars [sic] worth of flowers be

ordered and sent to [my] sisters house and for [my] mothers funeral, nor did I direct[] that the costs be paid for by the Southwest Council. In the days of and following my mothers death, I was not directing anyone to do anything. Rather, I was attending to my mothers funeral and burial as well as having to deal with the fight with Doug over her estate. During this period, Justin Weidner (Dougs new chief of staff and my old one) called and asked where services were being held for my mother, and I told him at my sister Janets house. That was the full extent of our conversation. Improper Trust Fund Actions 51. The delinquency list is a list of contractors signatory to a collective

bargaining agreement with the Regional Council which have not made the contributions


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to one or more of the Trust Funds in a timely manner. It is prepared by CSAC, where Dougs $126,000 girl friend works, and I have and had no control over its content. Doug, on the other hand (who is the chairman or co-chairman of every Trust Fund), has chastised members of CSAC staft demanding that certain contractors be kept off the delinquency list.

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With respect to the remainder of my purportedly improper actions, I did

decide that the security in the building was lax and went about improving it. The panic buttons originally were installed only on the tenth floor (the Regional Councils offices), but were later extended to the rest of the building when the women working there asked for them. Improper Intimidation and Threats of Violence

I never threatened violence against the Carpenters Director of Real Estate,

Randy Sowell, although what I did say to him could be viewed as being intimidating. Specifically, I had received information from Yatsmin Aguil lar, a receptionist who worked for the DeCarlo Firm for thirteen years. Ms. Aguillar informed me that DeCarlo and SowelI were shredding documents that may have been relevant to the real estate transactions between the Regional Council and the Training Fund. 54. When I heard this, I went down to see Mr. Sowell, and Ms. Aguillar

accompanied me. I did not threaten him; I merely told him that evidence destruction is a felony, and that he should not to get in trouble for my brother Doug. DeCarlo has since fired Ms. Aguillar, and Doug is smearing her name because of some ugly circumstances involving her husband and brother. All of the problems with her husband and brother occurred years ago, but DeCarlo didnt fire her then and Doug didnt raise her family problems until she told me about the document shredding. Failure To Assure Performance of Collective Bargaining Agreements 55. The Regional Councils has hundreds ofcollective bargaining agreements with

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scores of employer associations and individual employers that are serviced by scores of representatives on my staff. I have not received a complaint from any member that any of



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the staff was not properly servicing any agreement. In my opinion, Doug just made this
up. And although it is true that, from time to time I have moved business agents around,

including business agents servicing the Pile L)rivcr and Millwright agreements, in order to assist in the Regional Councils organizing efforts. The reason Doug took the

Carpenters out of the AFL-CIO was because, in his opinion, the AFL-CIO was spending too much money in servicing its members and not enough on organizing. Put simply, 1 was merely following Dougs policies and dictates.

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On the evening of Friday, August 16, 2013, Local 1506 was scheduled to have

its regular meetings of its Executive Board and of its membership. As President of Local 1506, it is my duty to chair these meetings. However, through the use of armed security guards hired by Draper for the Regional Council, Doug barred me from presiding over the meetings of the Executive Board and of the membership of Local 1506. He did this again at the meetings held on September 20, 2013. 57. Doug has caused the locks on Local 1506s doors to be changed and had his

staff threaten me with arrest if I entered Local 1506s building again. 58. Before taking control of Local 1506, Doug did not declare and emergency or

determine cause to conduct a hearing on placing Local 1506 under supervision.

I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct and that this declaration was executed by me in

,California on September



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Michael McCarron