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Office of the Election Supervisor for the International Brotherhood of Teamsters

IN RE: PATRICK GLEASON, Protestor.
Protest Decision 2006 ESD 370
Issued: November 9, 2006
OES Case No. P-06-347-101006-HQ

(See also Election Appeals Master decision 06 EAM 79)

Patrick Gleason, member, secretary-treasurer and convention delegate from IBT Local Union 26, filed a pre-election protest pursuant to Article XIII, Section 2(b) of the Rules for the 2005-2006 IBT International Union Delegate and Officer Election ("Rules"). The protest alleged that Gleason was improperly required by Local Union 26 to return his convention per diem payment of $130 per day and was granted reimbursement only for expenses charged to his local union credit card and other expenses for which he could provide receipts. The protest further alleged that Gleason was removed from his position as a local union business agent for attempting to collect a per diem.

Election Supervisor representative Steven R. Newmark investigated this protest.

Findings of Fact

Local Union 26 completed its election of IBT convention delegates at the January 7, 2006 meeting when only one candidate was nominated for each open position. Local Union President and principal officer Garry Collett, Secretary-Treasurer Patrick Gleason, and Trustee James Cross were elected as convention delegates, and Trustee Tim Donovan was elected as alternate delegate. These individuals were certified as elected by the Office of the Election Supervisor ("OES") on February 10, 2006.

On February 11, 2006, the Local Union 26 executive board adopted a resolution concerning delegate expenses for upcoming IBT convention. The minutes of the executive board meeting record the following:

A motion was made by Vice President Helbling and seconded by Recording Secretary Dukes to approve expenses to attend and participate in the Teamsters Convention in Las Vegas, June 25, 2006 through July 1, 2006[.] Local 26 Delegates, President Collett, Secretary-Treasurer Gleason and, Trustee Cross plus Alternate Delegate, Trustee Donovan. Motion unanimous (see form attachment)

A form attached to the minutes read as follows:

EXECUTIVE BOARD MEETING MINUTES
EXPENSE APPROVAL

A motion was made by V.P. Helbling and properly seconded by Rec. Sec. Dukes to approve all reasonable expenses to include travel, transportation, lodging, meals and all business related expenses for Garry Collett, Jim Cross and Pat Gleason, Tim Donovan to attend Teamsters Convention held in Las Vegas, NV. Travel days are 6/25/06 to 7/1/06.

On March 24, 2006, we issued our Advisory Regarding Payment of Expenses For Convention Delegates and Alternate Delegates to the 27th International Convention of the International Brotherhood of Teamsters ("Advisory"). Pursuant to the Advisory, "Local Unions are obligated to cover four categories of Convention expenses: (A) travel expenses to and from Las Vegas and local transportation costs while in Las Vegas during the week of the convention; (B) per diem; (C) hotel costs; and (D) wages or salary." Advisory, Section III, preamble.

The Advisory described the "per diem" obligation in the following terms:

The per diem allowance is for daily incidental expenses delegates and alternates incur as a consequence of attending the Convention, such as meals, tips, and the like. The per diem allowance is an obligation in addition to the Local Union's obligation to pay for travel and hotel accommodations. Local Unions must provide the per diem allowance in advance to those delegates and alternates being sent to the Convention.

The minimum, required per diem allowance for delegates attending the Convention (and alternates, if applicable) is $75.00. Delegates and alternates are not required to submit receipts to the Local Union to document their daily expenses in order to receive the $75.00 per diem, and will not be required to return any part of the $75.00 to their locals.

Local Unions may provide a per diem of more than $75.00, but must not provide a per diem amount of greater than $130.00. If a local provides more than the minimum $75.00 per diem, it can place restrictions on the additional amount, such as requiring receipts to document expenditures and the return of any unspent monies.

***

In the last week in March, OES mailed the Advisory to each convention delegate certified as of that date, including Collett, Gleason, and Cross.

Apparently in response to the Advisory, Collett contacted OES before the convention to inquire whether Local Union 26 could reimburse actual expenses of its delegates and alternate delegate rather than pay a per diem. Collett said he made that inquiry because the local union was in financial distress. Collett stated that he was advised by Paul Dever of our office that expense reimbursement in lieu of per diem was permitted.

Dever told our investigator that, although he had no specific recollection of speaking with Collett or anyone else from Local Union 26, he received several calls from local unions before the convention asking whether expense reimbursement could be substituted for per diem. Dever stated that he gave the same response to all such callers: payment of the per diem was required and the per diem amount belonged to the delegate or alternate delegate who attended the convention. However, if the delegate or alternate delegate wished to return part or all of the per diem to the local union, he/she could do so voluntarily but could not be required to do so by directive, policy or resolution.

Although the Advisory was mailed to each certified convention delegate, Gleason told our investigator that he did not learn of the Advisory before the convention. Gleason also told our investigator that he did not learn of Collett's conversation with Dever prior to the convention.

Local Union 26 did not advance the convention per diem to its delegates and alternate delegate as the Advisory required. However, Collett also served on the IBT's convention resolutions committee. In that capacity, he traveled to Las Vegas a week before the convention started. For the duration of his stay in Las Vegas, including the week of the convention, Collett was paid a per diem of $130 by the IBT. The Advisory prohibits the payment of duplicate expenses, and Collett was not eligible to receive reimbursement of convention expenses from Local Union 26 because the IBT was covering them.

In addition to his duties as elected delegate, Gleason is the elected secretary-treasurer of the local union and until September 2006 was a full-time business agent. As a full-time employee of the local union, Gleason was issued a credit card on which he could charge union expenses. Gleason told our investigator that he and other delegates assumed they would be permitted to charge their incidental convention expenses such as meals directly to their union-issued credit cards.

Gleason stated that on the first day of the convention, June 26, he learned from the president of another local union that all local unions were required to pay their delegates and alternate delegates a per diem for their days at the convention and that such payment was to be advanced by each local union to the members of its delegation before they traveled to Las Vegas. At this, Gleason contacted Dick Bell of the IBT to confirm the information. Bell is an assistant to General Secretary-Treasurer C. Thomas Keegel. According to Gleason, Bell told Gleason on Saturday, July 1 (after the convention adjourned), that Local Union 26 should have paid a per diem to delegates and alternates, and that using the local union's credit card to cover daily expenses incurred at the convention could cause audit problems.

Immediately after the convention, Collett was suspended from office by Joint Council 65. On July 7, during Collett's suspension and without Collett present, Gleason told the other members of the local union executive board about Bell's statement that the local union's delegates and alternate delegate should have been paid a per diem for meals and incidental convention expenses, rather than use union-issued credit cards. On Gleason's motion, the executive board adopted a resolution to pay a retroactive per diem of $130 dollar per day for each day at the convention, provided that the delegates and the alternate delegate assumed responsibility for any expenses they had charged to their union-issued credit cards. Each agreed and received a total per diem payment of $910 for seven days. Gleason told our investigator that he made the motion for the $130 per diem because that was the daily amount the IBT had paid Collett for his time in Las Vegas. Payment was made by checks dated July 10, 2006. Because they received the per diem, Gleason and the others reimbursed to the local union the incidental expenses they had placed on their respective union-issued credit cards that were billed on the June statements of those credit cards.

Shortly after the local union executive board meeting, Collett's suspension was stayed by General President Hoffa and he was permitted to resume his duties as local union principal officer. When he learned of the executive board action granting a per diem, Collett apparently reported the action to Leo Carroll, who had been appointed General President Hoffa's personal representative to the local union. On July 27, Carroll wrote the following to Collett:

While my appointment as General President Hoffa's Personal Representative to your Local Union does not give me the authority to order you to take any action, there are two items that have come to my attention that needs to be addressed by you as the Principal Officer of the Local Union. They are as follows:

1. The payment of the $910.00 to each delegate and alternate that was authorized at the special board meeting of July 7, 2006 must be reversed and the money returned to the Local's treasury. The Local then should reimburse these people for their expenses as per the previous policy established at your February 11, 2006 Executive Board Meeting.

2. Your Local Union is losing approximately $8,500.00 per month since January 1st of this year. If this continues, your Local will be in severe financial distress in less than four years, as this equates to $102,000.00 per year, or approximately 25% of your liquid assets.

In my opinion, it would be in the best interests of your Local and Membership to explore different avenues to decrease your expenses and increase your income. I have no recommendations as to what avenue you pursue; however, I feel strongly that you have a fiduciary duty to get your financial house in order.

The same day Collett received the Carroll letter, he wrote Gleason as follows:

Per correspondence received in the Danville office by President Garry J. Collett from Leo Deaner, Executive Assistant to IBT President Jim Hoffa, I have been informed that you will need to reimburse to Teamsters Local 26 the per diem check in the amount of $910.00, that was inappropriately issued by Executive Board action taken at the July 7, 2006 Executive Board meeting.

Once received in this office the Local will reimburse you your actual costs for attending the IBT Convention in the amount of $207.20.

This action needs to be done immediately. If you have any questions please contact me.

Collett's letter included a space for Gleason to sign. Gleason responded to Collett's July 27 letter the next morning, first by speaking with him and then in writing. Gleason's letter stated in part as follows:

This letter is to confirm our conversation of this date regarding:

1. Per Diem reimbursement

Be advised that I am not refusing to reimburse the Local Union for Per Diem. I will do so after having consulted personally with General Secretary Keagel [sic] and Sick [sic] Bell if I am so instructed.

2. Signature letter regarding Per Diem dated July 27, 2006 signed by yourself.

I refuse to sign this letter in the current format indicating any inappropriate action of the Local 26 Executive Board at the July 27, 2006 meeting.

On August 3, 2006, General Secretary-Treasurer Keegel wrote Collett the following, in relevant part:

[I]t appears that two of the delegates and the alternate who represented the Local Union at the 27th International Convention have, in essence, improperly authorized the payment of additional compensation to themselves. (It is acknowledged that you also served as an elected delegate, but that your Convention per diem was paid by the International Union in recognition of your assignment to serve on the Resolutions Committee.) It has been determined that the Local Union took actions to establish an expense policy whereby the delegates and the alternate representing the Local Union at the 27th International Convention would be paid for actual expenses incurred. In fact, my Executive Assistant was contacted by telephone after the conclusion of the Convention and was advised of the Local Union's policy wherein he was advised that the per diem was the recommended expense by the Election Supervisor; however, he further advised that it would be doubtful that the Election Supervisor would overturn the policy of the Local Union on a retroactive basis.

It has now been determined that when the delegates and alternate returned from Las Vegas, at an Executive Board meeting at which you were not present, the delegates and alternate, as members of the Local Union Executive Board, then decided that they would issue to themselves retroactive per diem checks in the amount of $910 each, representing the seven maximum days of per diem of $130 as established by the Election Supervisor. Upon receipt of Brother Carroll's letter, you advised each of the delegates and the alternate that they must return the per diem paid to them, as it is the opinion of this office that it constitutes unauthorized compensation, as clearly the amount of expenses incurred were far less than the total of the per diem.

It is acknowledged that this is a timing issue as if the per diem checks had been processed prior to the Convention, the delegates and alternate could have incurred the same amount of expenses and would have been taxed on the amount that was not used. However, again, as the Local Union chose to employ an actual expense incurred policy, it is clear that the per diem that exceeds expenses incurred constitutes income to the recipients.

Gleason reimbursed the total per diem of $910.00 to the local union by check dated August 14, 2006. The other delegate and the alternate delegate similarly reimbursed the local union for the total per diem amounts issued them, on August 11 and July 28, respectively. Collett held these checks until the local union's accountants verified the expenses each delegate and the alternate delegate incurred at the convention. On September 22, the local union deposited the returned per diem checks and issued reimbursements to the delegates and alternate delegate for their actual convention expenses.

On September 28, 2006, Collett discharged Gleason from his full-time business agent position. The discharge letter read as follows:

Effective immediately, you are discharged from your position as appointive Business Agent for Teamsters Local 26.

I am compelled to take this action for the following and other reasons. It is my constitutional duty and responsibility to discharge an employee whose conduct does not best serve the interests of Local 26 membership. International Brotherhood of Teamsters General Secretary-Treasurer C. Thomas Keegel recently wrote to me that you improperly paid yourself additional compensation in connection with the July 2006 Teamsters International Convention. Prior to the Convention, the Local Union Executive Board authorized payment of your actual Convention expenses. But following your return from the Convention, as the appointed Principal Officer, you retroactively awarded yourself, Tim Donovan and Jim Cross each $910.00 for Convention "expenses." This amount exceeded your actual Convention expenses by $577.29. You did not inform the Executive Board Officers who approved this payment that you were advised by Secretary-Treasurer Keegel's Executive Assistant that it would be doubtful the Election Supervisor would overturn the policy of the Local Union on a retroactive basis. This misconduct occurred without my knowledge or participation.

General Secretary-Treasurer Keegel discovered this misconduct and demanded the return of these improper payments, which you did only after receiving my written demand. My demand letter noted that "further investigation into this matter may include disciplinary action up to and including discharge." This misrepresentation of facts to the Executive Board and gross negligence of your fiduciary duty as an Officer of the Local is disturbing and unacceptable. I have now concluded my investigation and determined that your continued employment endangers the Local Union treasury and the Local Union membership.

This protest followed. The protest "charges Local 26 President Garry Collett with violation of Article VII, Section 12(g) of the 2005-2006 Election Rules by discharging me from my employment as a Local 26 Business Representative in retaliation for taking action to bring Local 26 into compliance with Article III, Section 3(d) of the Election Rules as spelled out in Section IIIB. of the March 24, 2006 Advisory Regarding Payment of Expenses for Convention Delegates, etc."

Although the discharge letter stated that the dismissal was because of the per diem issue "and other reasons," Collett identified only the per diem issue as the motivation for Gleason's discharge. Further, local union trustee and elected delegate Jim Cross stated that Collett advised him of Gleason's dismissal on September 29. According to Cross, "Garry told me the reason he fired Pat Gleason was over the per diem issue for the 2006 IBT Convention at Las Vegas, NV. Garry Collett told me he should probably fire me over the same per diem issue, but he said he could not bring himself to terminate me."

The protest was dated October 4, 2006, although it was not received by our office until October 10. October 4 was 6 days after Gleason's discharge. In the transmittal letter that accompanied the protest, Gleason stated the following with respect to the timeliness of the protest:

I am aware there may be a timeliness issue regarding the filing of these charges. I am Secretary Treasurer of Local 26 but was not made aware of the Election Rules booklet by President Collett. I first became aware of and in possession of the rules on October 3, 2006. The rules provided me by Illinois Conference of Teamsters President Keith Gleason.

In addition to the protest, Gleason filed an internal union "Charge Against Garry Collett." The charge alleged that Collett violated various provisions of the IBT constitution by discharging Gleason because Gleason "took action to bring Local 26 into compliance with its legal obligation under the election rules." The charge is dated October 2, one day before the date Gleason claimed first to have received the Rules. The relief the charge seeks is "to be reinstated as a business representative of Local 26, to be made whole for all losses, including but not limited to wages and benefits."

Analysis

Article XIII, Section 2(b) of the Rules states that "[e]xcept as otherwise provided in Article III, Section 5(n) of the Rules, all other pre-election protests … must be filed within two (2) working days of the day when the protestor becomes aware or reasonably should have become aware of the action protested or such protests shall be waived." Precedent establishes that the protest time limit is a prudential restriction rather than a jurisdictional requirement. Ruscigno, P144 (October 4, 1995), aff'd, 95 EAM 25 (October 18, 2005). Accordingly, we may, in the exercise of discretion, waive the time limit if circumstances warrant that we do so.

We find that Gleason did not act with the promptness the Rules require to ascertain and seek to enforce his rights under the Rules. As an elected delegate, Gleason knew or should have known his rights and obligations under the Rules. For that reason, if the limitations period for filing protests were deemed to be jurisdictional, we would have no compunction in denying this protest as untimely filed, for Gleason either knew or should have known that he had to act with dispatch to protest his dismissal from his business agent position. However, this case illustrates the policy that underlies the principle, repeated in every election cycle, that the protest time limit is a prudential one. Because of the heightened scrutiny the Rules apply to cases of alleged retaliation and the particular circumstances of this case, we decide the matter of Gleason's discharge on its merits. Although no contemporaneous protest was filed concerning the reversal of the local union executive board's grant of a per diem, we have authority to investigate and remedy Rules violations that we discover while investigating other matters.

The Rules and the IBT Constitution require each local union to send to the convention all the delegates allocated to it, and to pay the expenses of those delegates or to make arrangements for such payment by agreement with other subordinate bodies. Article III, Section 3(a); IBT Constitution, Article III, Sections 2 and 4. Our Advisory on convention expenses emphasizes that the per diem allowance "is an obligation in addition to the Local Union's obligation to pay for travel and hotel accommodations. Local Unions must provide the per diem allowance in advance to those delegates and alternates being sent to the Convention." (Emphasis supplied.) A minimum per diem is set to encourage full participation by delegates as envisioned in the IBT constitution, and to remove discretion from local unions and eliminate any opportunity for political discrimination in handling reimbursements. Accordingly, Local Union 26 was required to pay the minimum per diem allowance to each delegate and alternate delegate it sent to the convention.

We reject Collett's argument that the February 11 action of the local union executive board validly substituted an expense-reimbursement scheme for the per diem required by the Advisory. First, the plain language of the executive board resolution stated merely that the board "approve[d] all reasonable expenses to include travel, transportation, lodging, meals and all business related expenses." The resolution did not state that the local union was declining to pay a per diem allowance.

Further, for several reasons, the resolution cannot be construed as a waiver of the per diem allowance required by the Advisory. The resolution was adopted more than a month before the Advisory issued and therefore could not serve to waive a requirement that was not yet in place. Moreover, the resolution language does not state a waiver expressly by its terms. Finally, a waiver of a per diem allowance can be made effective not by local union policy or resolution but only by the individual decision of each delegate or alternate delegate to refund to the local union all or part of the per diem allowance that the local union has already paid that member.

Therefore, we find that the local union failed to comply with the Rules by not issuing a per diem allowance to the local union's delegation in advance of the convention. We further find that the action of the local union executive board taken July 7 effectively corrected this failure as it relates to the decision to grant a per diem but not as to the amount of the per diem. As the local union was required to grant a per diem allowance ($75 per day at minimum; $130 per day at maximum with the right to limit reimbursement in excess of $75 to actual expense), the executive board performed the ministerial act required of it to grant the per diem allowance, even though it was after the fact.

While the executive board's decision to set the per diem allowance at $130 per day would have been within its discretion had it acted "in advance" of the convention, as the Advisory required (see Sexauer, 2006 ESD 303 (June 19, 2006), aff'd, 06 EAM 52 (June 22, 2006)), we find that the post-convention award of the maximum per diem amount without restriction, just because that was the per diem amount Collett received from the IBT, is an abuse of discretion under the circumstances presented here. The Advisory allowed local unions to pay a per diem greater than $75, but also allowed them to restrict such an increased award to actual expense incurred in excess of the minimum. There is no dispute that Gleason understood the February 11, 2006 resolution as limiting convention reimbursement from Local Union 26 to the delegates' actual expense. Local Union 26 was entitled to put an actual expense limitation on reimbursement in excess of $75 per day for convention expenses covered by the per diem. Reading the February 11, 2006 resolution together with the Advisory, we conclude that Gleason was entitled to reimbursement from Local Union 26 for expenses covered by the per diem in the amount of $75 per day or the actual expense incurred, whichever was greater. The record shows that Gleason's expenses in categories covered by the per diem were less than the minimum per diem allowance of $525.00. Gleason is entitled to the difference.

The effort Collett made to recover the per diem allowance for Local Union 26 after it was paid to each delegate and the alternate delegate violated the express terms of the Advisory only to the extent that he recovered the full per diem instead of the amount that exceeded $75. Further, his decision to discharge Gleason for correcting the local union's failure to grant the per diem allowance required by the Rules constituted a violation of Article VII, Section 12(g), which prohibits "retaliation … against a Union member, officer or employee for exercising any right guaranteed by this or any other Article of the Rules."

Accordingly, we GRANT the protest.

Remedy

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

We issue the following relief:

1. The local union shall give effect to the resolution of the local union executive board adopted July 7, 2006 granting a per diem allowance of $75 day for the 7 days at the convention site. Accordingly, the local union shall pay this per diem allowance to Patrick Gleason, Jim Cross and Tim Donovan, less any amount for reimbursement of convention-related expenses to be covered by the per diem (as set forth in the Advisory) that the local union has already paid them that has not been reimbursed to the local union.
2. Patrick Gleason shall be reinstated to his former position as full-time business agent for Local Union 26, retroactive to the date of discharge, with no break in service or seniority. The local union shall pay Gleason all wages, salary and benefits he would have earned but for the improper discharge, less any wages, salary or benefits Gleason earned in interim employment. If Gleason was paid unemployment compensation benefits following his discharge, the local union may offset such compensation against its backpay liability unless Gleason is required to refund the unemployment compensation to the State of Illinois, in which case no offset may be taken. At Gleason's option, he may recover all or part of his vacation bank by repaying to the local union some or all of the net amount of vacation pay he received from the local union following his discharge. The local union shall expunge from Gleason's personnel file all documents referring to his discharge or the per diem allowance matter that led to his discharge. Should any matters arise with respect to implementation of this remedy, the aggrieved party is directed to notify the Election Office promptly.
3. The local union shall post the notice attached to this decision on all union bulletin boards under the jurisdiction of Local Union 26 and shall maintain that posting for 30 consecutive days.

All relief we order here shall be accomplished within 3 working days of receipt of this decision. The local union shall submit an affidavit of compliance within 2 days of completing all aspects of the remedy.

Although we do not take action to dismiss the internal union charge that Gleason has brought against Collett arising from Gleason's discharge, we note that this decision grants the full relief that Gleason sought with that charge and effectively moots it.

Any interested party not satisfied with this determination may request a hearing before the Election Appeals Master within two (2) working days of receipt of this decision. The parties are reminded that, absent extraordinary circumstances, no party may rely upon evidence that was not presented to the Office of the Election Supervisor in any such appeal. Requests for a hearing shall be made in writing, shall specify the basis for the appeal and shall be served upon:

Kenneth Conboy
Election Appeals Master
Latham & Watkins
885 Third Avenue, Suite 1000
New York, New York 10022
Fax: (212) 751-4864

Copies of the request for hearing must be served upon the parties, as well as upon the Election Supervisor for the International Brotherhood of Teamsters, 1725 K Street, N.W., Suite 1400, Washington, D.C. 20006-1416, all within the time prescribed above. A copy of the protest must accompany the request for hearing.

Richard W. Mark
Election Supervisor

cc: Kenneth Conboy
2006 ESD 370

NOTICE TO ALL MEMBERS OF LOCAL UNION 26 FROM
IBT ELECTION SUPERVISOR RICHARD W. MARK

The Rules for the 2005-2006 IBT International Union Delegate and International Officer Election ("Rules") and an Advisory Regarding Payment of Expenses For Convention Delegates grant convention delegates and alternate delegates entitlement to a minimum per diem payment for each day they attended the IBT convention in Las Vegas, Nevada. The Rules prohibit the union from retaliating against any member who seeks to recover the per diem payment to which he is entitled.

The Election Supervisor has found that Local Union 26 failed to grant per diem payments to its delegates and alternate delegates, as required by the Rules and the Advisory. The Election Supervisor has further found that Patrick Gleason sought to enforce his right to the per diem payment and was discharged from his employment as a full-time business agent of Local Union 26 for seeking that payment.

The Election Supervisor has ordered Local Union 26 to pay the per diem required by the Rules and to reinstate Gleason to his full-time business agent position with full back pay, benefits and seniority.

Any protest you have regarding your rights under the Rules or any conduct by any person or entity which violates the Rules should be filed with the Election Supervisor. The Election Supervisor can be contacted by mail at 1725 K Street, Suite 1400, Washington, D.C. 20006; by telephone at 888-IBT-2006; by fax at 202-454-1501; and by email at electionsupervisor@ibtvote.org.

__________________________________
Richard W. Mark
IBT Election Supervisor
Dated:

This is an official notice prepared and approved by Richard W. Mark, Election Supervisor for the International Brotherhood of Teamsters. It must remained posted for 30 consecutive days and must not be defaced or covered up.

DISTRIBUTION LIST (BY EMAIL UNLESS OTHERWISE SPECIFIED):

Bradley T. Raymond, General Counsel
International Brotherhood of Teamsters
25 Louisiana Avenue, NW
Washington, DC 20001-2198
braymond@teamster.org

David J. Hoffa
Hoffa 2006
30300 Northwestern Highway, Suite 324
Farmington Hills, MI 48834
david@hoffapllc.com

Barbara Harvey
645 Griswold Street
Suite 3060
Detroit, MI 48226
blmharvey@sbcglobal.net

Ken Paff
Teamsters for a Democratic Union
P.O. Box 10128
Detroit, MI 48210
ken@tdu.org

Daniel E. Clifton
Lewis, Clifton & Nikolaidis, P.C.
275 Seventh Avenue, Suite 2300
New York, NY 10001
dclifton@lcnlaw.com

Stefan Ostrach
1863 Pioneer Parkway East, #217
Springfield, OR 97477-3907
saostrach@gmail.com

Patrick Gleason
9477 Deer Ridge Road
Bloomington, IL 61704

Garry Collett
President, Local 26
P.O. Box 42
Danville, IL 61834

Steven R. Newmark, Esq.
Office of the Election Supervisor
1725 K Street, NW, Suite 1400
Washington, DC 20006
snewmark@ibtvote.org

Jeffrey Ellison
510 Highland Avenue, #325
Milford, MI 48381
ellisonesq@aol.com