4-11-13 DDS (11pgs) to RMB Doc. 1306

7/28/2019 4-11-13 DDS (11pgs) to RMB Doc. 1306

1/11

11206

l\I" t .1.1.\",'- SO ORDERED: ____Il-"'l- __- --

Demian D. Schroeder14 Meadow StreetBrooklyn, NY CHAMBERS OFRICHARD M. BERMANU.S.D.J.April 11, 2013Honorable Richard M. Berman ,U.S. District Judge,U.S. District Court (SDNY)Daniel Patrick Moynihan United States Courthouse500 Pear) Street, Courtroom 12New York, NY 10007

RICHARD M. BERMAN U.S.D.J."f/.,/. ]. USDC SDNYDOClI!ViENTELf:CTRONICALLY FILEDDC"-' l i .--' \..,- '- ,DATE FlLED: Lf 13

SUbject:U.S. v. District Council ofNew York and Vicinity ofthe United Brotherhoodof Carpenters & Joiners ofAmerica, et al; (Index No. 90 Civ. 5722) (RMB)Reference: February 13,2013 Order, Doc. No. 1255Responsive Filings, Status ofUnion approval and ratification of the DistrictCouncillWall-Ceiling CBA dated March 12,2013

Dear Judge Berman,We are in receipt ofthe Wall-Ceiling and Carpentry Industries of New York, Inc. collectivebargaining agreement (CBA) dated/executed on March 12,2012.As Your Honor is aware, the contracts are complex legal documents effecting members rights.The executed contract (CBA) was not properly or timely submitted to the Council Delegate Body(CDB) or Executive Committee or rank and file member, for proper dissemination, review,debate or contract ratification, per the past practice under the new by-laws as established by theCouncil Delegate Body (CDB) and the follow-through March 27,2012 vote by the rank & file,on 5-CBA's which were supervised & counted by the American Arbitration Association (AAA).N.L.R.A. Section 8(1) verses 9(a):The District Council and the Wall-Ceiling & Carpentry Industries of Ne w York have presented tothe Court an untenable & false claim within the proposed contract, where on the one hand TheContractor Association and the Union offer a Non-Exclusive HiringlReferral Hall; and, on theother the Union waives its responsibilities to represent all of its members equally upon collectionand receipt of dues and working assessment monies - yet, refuses to perform said duty andawards the Contractor Association 100% control of all hiring under their joint and false claim ofexclusive and majority status.WALL-CEILING CBA at ARTICLE II, SECTION 2. Page 2 & 3 states:"Section 2. The Association and any employer that may hereafter become a signatory to thisCollective Bargaining Agreement hereby acknowledge tha t the Union has claimed and

Case 1:90-cv-05722-RMB-THK Document 1306 Filed 04/11/13 Page 1 of 11

7/28/2019 4-11-13 DDS (11pgs) to RMB Doc. 1306

2/11

demonstrated. and the Association of signatoty employers is satisfied and acknowledges. that theUnion represents a majority of the Association members' Carpenters Of said signatory employer'sCarpenters in an appropriate bargaining unit for the purposes of collective bargaining.The Association and its members, as well as said signatory employer, accordingly recognize theUnion as the exclusive bargaining agent under Section 9(a) of the National Labor Relations Actfor all employees within the contractual bargaining unit (Carpenters) with respect to wages,hours and working conditions. The Association and any employer that may hereafter become asignatory to this Collective Bargaining Agreement by becoming a member of the Associationfurther agree that any dispute concerning its obligation to recognize the Union as sole andexclusive bargaining agent for the Carpenters will be resolved solely under Article herein."The employer recognizes the Union as the exclusive bargaining representative for all itsCarpenter employees who ar e performing covered work as herein defined."There are multiple issues with res.pect to this Section.

1) None of the language was presented to the Council Delegate Body (CDB) prior to thealleged contract ratification & vote ofAugust 22, 2012; thus, by with-holding criticalinformation, any & all alleged agreements and/or alleged votes taken upon an incompleteMemorandum ofUnderstanding (M.O.U.) are void ab-initio.2) The UBCJA International and the NYCDCC via the first Restructuring Plan in 1999under Judge Haight or in the 2011 Restructuring Plan within Your Honor's tenure havenever proven majority status, nor held the required representation election required byFederal Law(s). Through the never ending barrage of McCarron lawsuits across thecountry, they have evaded this simple requirement, albeit illegally while simultaneouslydestroying the Local Unions' autonomy, seizing assets and tangible & intangible property

which does not belong to them and eliminating and shredding every Federal law on thebook relative to rank & file member voting and property rights.In Ladies'Garment Workers l!. NLRB (Bernhard-Altmann), 366 U.S. 731 (1961) the SupremeCourt stated:In the bona fide but mistaken belief that a majority of the employees in the appropriatebargaining unit had authorized petitioner union to represent their interests, the union and theemployer entered into an agreement under which the employer recognized the union as theexclusive bargaining representative of certain of its employees, although in fact only a minorityof those employees had authorized the union to represent their interests. The National LaborRelations Board found that, by extending such recognition, the employer interfered withthe organizational rights ofits employees in violation of 8 (a) (1) ofthe National LaborRelations Act and gave unlawful support to a labor organization in violation of 8 (a) (2),and that the union violated 8 (b) (1) (A) by its acceptance of exclusive bargaining authority.The Board ordered the unfair labor practices discontinued an d directed th e holding of arepresentation election. The Court ofAppeals granted enforcement of the Board's order.

2


7/28/2019 4-11-13 DDS (11pgs) to RMB Doc. 1306

3/11

Held: The Board and the Court of Appeals correctly held that such extension and acceptance ofrecognition constituted unfair labor practices; the remedy provided was appropriate; and thejudgment is afDnned. pp. 732-740.(a) A different conclusion is not required by the fact that the union subsequently obtainedauthorization from a majority of the employees to represent their interests, since kearlier recognition of the minority union was a fait accompli dxgriving the majority ofthe employees oftheir guaranteed riabt to choose their own representative. P. 736.(b) The agreement Was void in its entirety. and it cannot be held valid and enforceable asto those employees who consented to it. pp. 736-737.(c) By granting exclusive bargaining status to a union selected by a minority of itsemployees, thereby impressing that union upon [366 U.S. 731, 732] the nonconsenting majority, the employer violated both 8 (a) (1) and 8 (a) (2). pp. 737-738.(d) The employer's bona fide belief in the majority status of the union is no defense. Pp.738-739.(e) The remedy provided by the Board's order was proper. pp. 739-740.108 U.S. App.D.C. 68, 280 F.2d 616, affirmed.The NYCDCC and the Wall-Ceiling & Carpentry Industries ofNew York, Inc. have violatedNLRA Sec. 8(aXl), 8{a){2) and 8{b)(l)(A) via the unlawful support and acceptance of exclusivebargaining authority and via NLRA Sec. 9(a) by:

o Failing to prove majority supporto Failing to hold the required Representation Election as mandated by the NLRA and longsettled law

Items (a) through (e) in Justice Clark's majority opinion are fully applicable to the Wall-Ceilingand BCA proposed CBA's, and, any/all remaining contracts yet negotiated with the NYCDCC.Said parties have colluded directly, by and through and with the assistance of the UBCJAInternational's legal counsel Latham & Watkins, through a former Federal Judge, KennethConboy via direct coercion, intimidation, fraud and by violating the two primary prongs of theCivil RCID Consent Decree to end racketeering and to restore democracy, and have engaged in alengthy extortionate Hobbs Act scheme to defraud members of tangible and intangible property,and the rights according thereto, all in a continued pattern of racketeering in violation ofU.S.C.Section 1861. NYCDCC in house counsel Murphy's March 29, 2013 letter (Doc. No. 1290)evinces noting more than a campaign of distraction, diversion and deception.Voluntruy recognition based on support that was induced by either union or employer coercion isunlawful. as is the coercion. See, e.g., Windsor Castle Health Care Facilities, 310 NLRB 579,580 (1993), enfd. 13 F.3d 619 (2d Cir. 1994).In 358 NLRB No. 15 (2011), International Brotherhood of Teamsters, Local 25 andDeniseAvallon at pg. 11 The Supreme Court has upheld the legality of hiring hall referral systems,acknowledging that ''the very existence of a hiring hall encourages union membership," butholding that ''the only encouragement or discouragement ofunion membership banned by the

3


7/28/2019 4-11-13 DDS (11pgs) to RMB Doc. 1306

4/11

Act is that which is "accomplished by discrimination."45 Teamsters Local 357 v. NLRB, 365U.S. 667, 674-676 (1961) (quoting Radio Officers v. NLRB, 347 U.S. 17,43 (1954)).But, since a union has such comprehensive authority vested in it when it acts as the exclusiveagent of users of a hiring hall and because the users must place such dependence on the union,there necessarily arises a fiduciary duty on the part of the union no t to conduct itself in anarbitrary, invidious, or discriminatory manner when representing those who seek to be referredout for employment by it. Iron Workers Local 111 (Steel Builders), 274 NLRB 742,746 (1985).No specific intent to discriminate need be shown to support a finding of an unfair labor practicein the improper operation of a hiring hall. Carpenters Local 25 v. NLRB, 769 F.2d 574, 580 (9thCir. 1985). Such fiduciary duty requires a union to employ objective standards for the referral ofemployees. Operating an exclusive hiring hall without reference to such is violative of Section8(b)(1)(A) of the Act. Laborers Local 394 (Building Contractors Assn. o/New Jersey), 247NLRB 97 fn. 2 (1980).Granting 100% exclusive control (FULL MOBILITY) of all hiring/referrals to the Wall-CeilingContractor Association violates the NYCDCC's Fiduciary duties, is arbitrary, capricious anddiscriminatory as the case law above requires "'the union" to employ objective standards andnowhere within the body, text or legislative history of the NLRA do the laws discuss ContractorAssociations running the unions referral or hiring halls and dominating/interfering with thisrelationship, while the Union does nothing more than hold its hand out and collect money fordoing absolutely nothing for the rank& file member. This is reminiscent ofwhat street gangs,drug dealers and the mob do via typical shakedowns and racketeering schemes via fear,intimidation, coercion & fraud.Immediately prior to the alleged negotiation of the MOU with the Wall-Ceiling & CarpentryIndustries ofNew York, Inc. ("Wall-Ceiling") in July 2012, the Review Officer, rather than vetothe new Benefit Funds Director Mr. Epstein, whom he championed prior, instead directed theTrustees to terminate his employment for "inappropriate & unauthorized expenditures" on creditcards, business transactions with a vendor whom he reported to law enforcement authorities andfor acquisition of furniture purchased through a printing company as well as mis-allocation offunds totaling $450k dollars for 1 quarter ofprinting work without issuing a request for proposal(RFP) or without affording the Council Delegate Body (CDB) the opportunity to review sameand decline the expenditure in whole or in part as required by its inherent plenary power &authority vested to it by the by-laws. Reference the 5th Interim Report of the R.O. at pg. 2, Item2; and, pg. 26, items 28 & 29.During July and August of2012 both before and after the August 22, 2012 MOU, the ReviewOfficer had been investigating the District Council President William Lebo for incidentsoccurring on July 25,2012 Delegate Meetings for harassment o f D ~ l e g a t e s which facilitatedExecutiye control of the agenda in continuance of racketeering, which subsequently led to theNotice OfPossible Action on September 19,2012 and the resignation of the D.C. Presidentshortly thereafter. Reference Sth Interim Report of the Review Officer at pg . 1, Item 1 and pg. 3-Democracy and District Council Delegate Meetings.At page 7, the Review Officer stated:

4


7/28/2019 4-11-13 DDS (11pgs) to RMB Doc. 1306

5/11

" I have always felt the great scope of authority granted to the EST as conceived by the UBCConstitution presents a risk in the New York District Council. That is one of the reasons that theoffice is different here, for instance, arguably fettered by the unique hiring process for businessrepresentatives required by the District Council Bylaws. The Bylaws endeavored to strike aproper balance between the authority of the EST, the Delegate Body and mandatory process allwith oversight of an Inspector General and a compliance overlay4. I would not presentlyrecommend that any offices be eliminated or created. In my view, the governance is still afledgling. Despite some growing pains, I think the system will not only work, but serve theDistrict Council well. Much will depend on the commitment of all to take it seriously, master theBylaws, study issues and engage in collegial debate."The obvious should not escape this honorable Court - that being, The District Council's ESTusurped his proper balance and authority by facilitating Executive control of the agenda incontinuance of racketeering throughout the course of the alleged contract negotiations,presentation of the MOU and the alleged vote on what was, is and remain nothing more thannotes kept relative to basic discussions during a period where the racketeering continuedunabated in direct violation of Prong I of the Consent Decree (Elimination of Racketeering).The D.C. & Contractor Associations now wish to insult the rank & file member and the Court'sintelligence via the

7/28/2019 4-11-13 DDS (11pgs) to RMB Doc. 1306

6/11

violation of Paragraph 7 of the Stipulation and Order; to wit:

(a) from on or about July 1. 2012. through March 12.2013, you failed to abide by Section 21 ofthe District Council Bylaws and caused or attempted to cause employer compensation formembers to be directed to the New York City District Council of Carpenters Welfare Fund;(b) on March 22,2013, you directed a business representative of the District Council attemptingto properly enforce the collective bargaining agreement at the Javits Center to let a suspendedmember work at the Javits Center knowing that the person had been suspended as a member;(c) on March 13.2013. you refused to answer questions about your report to the Delegatesproperly posed to you by a delegate at a meeting of the Delegate Body ofthe District Council;(d) on July 25. 2012, you engaged in indecorous and undemocratic behavior in a debate wi th adelegate at a meeting of the District Council Delegate Body;(e) from on or about September 2012, to the present, you failed to continue the development ofthe business representative cross-training program recommended by the Review Officer andbegun by the former District Council President and Assistant to the EST;(f) from on or about August 22,2012, through October 2012, you failed to take reasonable andprudent measures to implement the terms of the Memorandum ofAgreement between theDistrict Council and the Association ofWall-Ceiling and Camentry Industries of New York. Inc.;(g) from on or about January 11,2012, to the present, you failed to review minutes of themeetings ofthe Board ofTrustees of the Benefit Funds with the District Council ExecutiveCommittee;(h) on March 22,2013, you failed to cooperate with an investigation of the Review Officer byfalsely stating, in sum and substance, that a certain business representative "suggested to me thatI give [a suspended member] to the end of the week [working at Javits Center], like we are doingfor others."Pursuant to procedures promUlgated by the Review Officer to supplement the record in suchmatters (enclosed), and as provided for herein, you may deliver a written submission to thisoffice via email stating any facts, law or arguments (and appending any exhibits) which mightbe, in your view, relevant to consideration of this matter. Said submission must be delivered bynoon on April 9, 2013. A pre-action conference will be scheduled to occur at a later date. Pleaseemail anysubmissionorothercommunicationsrelevanttothisnoticetodmwfw@verizon.net.with copies [email protected] Bill O'Flaherty at [email protected]: March 26, 2013Dennis M. Walsh Review Officer

6

mailto:anysubmissionorothercommunicationsrelevanttothisnoticetodmwfw@verizon.netmailto:[email protected]:[email protected]:[email protected]:anysubmissionorothercommunicationsrelevanttothisnoticetodmwfw@verizon.netmailto:[email protected]:[email protected]

7/28/2019 4-11-13 DDS (11pgs) to RMB Doc. 1306

7/11

Charge (f) by the Review Offic.er Dennis Walsh states: (f) from on or about August 22,2012,through October 2012, you failed to take reasonable and prudent measures to implement theterms of the Memorandum ofAgreement between the District Council and the Association ofWall-Ceilin& and Carpentty Industries ofNew York. Inc.;The failure to implement the MOU between those dates and through to the present day issignificant. The MOU was not a contract rather it was a mere update to the Council DelegateBody of4-pages of EST Bilello's personal notes culled from ongoing collective bargainingnegotiations.As recognized by the All Writs Act-which permits "courts established by Act of Congress" toissue "all writs necessary or appropriate in aid of their respective jurisdictions," 28 U. S. C.1651(a)--a court's power to issue any form ofrelief, extraordinary or otherwise, is contingenton its subject-matter jurisdiction over the case or controversy. Such jurisdiction is determined byCongress. Bowles v. Russell, 551 U. S. 205, 212.The New York City & Vicinity District Council of Carpenters and the Wall-Ceiling & CarpentryIndustries ofNew York, Inc. contractor association have converted the former illegal Blue Card(reference attachment in Doc. No. 1-7) to the White Card and are now attempting to coerce thesame illegalities by forcing members to sign said cards as a vehicle or means to demonstratemajority support for the District Council, but without offering one scintilla ofproof. As it standsnow, the contract proposal being foisted upon this honorable Court is by a minority Union whichpurports to act for the majority of its members. Said practices have long settled and held to beillegal under Federal Labor laws.Accordingly, the only way to remediate this would require;

o An Order from the Court directing the District Council to furnish proof of MajoritySupport, or;o An Order from the Court directing the District Council to hold the mandatory NLRA Sec.9(a) Election via secret balloto Sustaining the R.O.'s veto of the EST,o Voiding the Wall-Ceiling Contract in its entirety

In the SUPREME COURT OF THE UNITED STATES No. 10-179, Stem v. Marshall (2011)at page 1 the court stated: 'This "suit has, in course of time, become so complicated, that . . . notwo . . . lawyers can talk about it for five minutes, without coming to a total disagreement as toall the premises. Innumerable children have been born into the cause: innumerable young peoplehave married into it;" and, sadly, the original parties "have died out of it." A "long procession of[judges] has come in and gone out" during that time, and still the suit "drags its weary lengthbefore the Court." Those words were not written about this case; see C. Dickens, Bleak House, in1 Works of Charles Dickens 4-5 (1891), but they could have been.At page 15 - We have recognized "the value of waiver and forfeiture rules" in "complex" cases,Exxon Shipping Co. v. Baker, 554 U. S. 471, 487-488, n. 6 (2008), and this case is no exception.In such cases, as here, the consequences of "a litigant . . . 'sandbagging'the court-remaining

7

http:///reader/full/Offic.erhttp:///reader/full/Offic.er

7/28/2019 4-11-13 DDS (11pgs) to RMB Doc. 1306

8/11

silent about his objection and belatedly raising the error only if the case does not conclude in hisfavor,"In accordance with the above case, the NYCDCC & the WC & C are trying to sandbag the Courtvia their intentional with-holding of the required proofof majority status and their willful failureto hold the required 9(a) Representation Election to remedy their failure to furnish the Court withproof of Majority status, notwithstanding the fact that both the International & the DistrictCouncil and Contractor Associations(s) have executed waivers under the Consent Decree.At pg's 16-18, Stem v. Marshall, the court stated "Article III, 1, of the Constitution mandatesthat "[t]hejudicial Power of the United States, shall be vested in one supreme Court, and in suchinferior Courts as the Congress may from time to time ordain and establish." The same sectionprovides that the judges of those constitutional courts "shall hold their Offices during goodBehaviour" and "receive for their Services[] a Compensation[] [that] shall not be diminished"during thei r tenure. As its text and our precedent confirm, Article III is "a n inseparable elementof the constitutional system of checks and balances" that "both defines the power and protectsthe independence of the Judicial Branch." Northern Pipeline, 458 U. S., at 58 (plurality opinion).Under "the basic concept of separation of powers . . . that flow[s] from the 17 Cite as: 564 U. S.(2011) scheme of a tripartite government" adopted in the Constitution, "the 'judicial Powerof the United States' . . . can no more be shared" with another branch than "the Chief Executive,for example, can share with the Judiciary the veto power, or the Congress share with theJudiciary the power to override a Presidential veto." United States v. Nixon, 418 U. S. 683, 704(1974) (quoting U. S. Const., Art. III, I).In establishing the system of divided power in the Constitution, the Framers considered itessential that "the judiciary remain[] truly distinct from both the legislature and the executive."The Federalist No. 78, p. 466 (C. Rossiter ed. 1961) (A. Hamilton). As Hamilton put it, quotingMontesquieu, '''there is no liberty if the power of judging be not separated from the legislativeand executive powers.'" /bid (quoting 1 Montesquieu, Spirit of Laws 181).We have recognized that the three branches are not hermetically sealed from one another, seeNixon v. Administratoro/General Services, 433 U. S. 425, 443 (1977), bu t it remains true thatArticle III imposes some basic limitations that the other branches may not transgress. Thoselimitations serve two related purposes. "Se.paration-of powers principles are intended. in part. toProtect each branch of government from incursion by the others. Yet the dynamic be tween andamong the branches is not the only object of the Constitution's concern. The structural principlessecured by the separation of powers protect the individual as weI!." Bond v. United States, 564U. S. -- ' _ (2011) (slip op., at 10). Article III protects liberty no t only through its role inimplementing the separation of powers, bu t also by specifying the defining characteristics ofArticle III judges....If our decision today does no t change all that much, then why the fuss? Isthere really a threat to the separation of powers where Congress has conferred the judicial poweroutside Article III only over certain counterclaims in bankruptcy? The short bu t emphatic answeris yes. A statute may no more lawfully chip away at the authority of th e Judicial Branchthan it may eliminate it entirely... .At pg. 38 "Slight encroachments create new boundariesfrom which legions of power can seek new territory to capture." Reidv. Covert, 354 U. S. 1,

8


7/28/2019 4-11-13 DDS (11pgs) to RMB Doc. 1306

9/11

39 (1957) (Plurality opinion). Although "[i]t may be that it is the obnoxious thing in its mildestand least repulsive form," we cannot overlook the intrusion: "illegitimate and unconstitutionalpractices get their first footing in that way, namely, by silent approaches and slight deviationsfrom legal modes ofprocedure." Boydv. United States, 116 U. S. 616,635 (1886).EST Bilello's purported execution of this contract which the Council Delegate Body, thelegislative branch ofthe D.C. never reviewed or voted upon cannot be sustained.In the SUPREME COURT OF THE UNITED STATES No. 06-856 JAMES L. ARUE,PETITIONER v. DEWOLFF, BOBERG & ASSOCIATES, INC., ET AL. ON WRIT OFCERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FOURTHCIRCUIT [February 20, 2008], JUSTICE STEVENS delivered the opinion of the Court:htt,o:llwww.sypremecourlgoylopinionsl07pdf706-856.pdf

The second question--whether Varity's deception violated ERISA imposed fiduciary obligations-calls for a brief, affirmative answer. ERISA requires a "fiduciary" to "discharge his duties withrespect to a plan solely in the interest of the participants and beneficiaries." ERISA 404(a). Toparticipate knowingly and significantly in deceiving a plan's beneficiaries in order to save theemployer money at the beneficiaries' expense, is not to act "solely in the interest of theparticipants and beneficiaries." As other courts have held, "[l]ying is inconsistent with theduty ofloyalty owed by all fiduciaries and codified in section 404(a)(l) of ERISA," PeoriaUnion Stock Yards Co. v. Penn Milt. Life Ins. Co., 698 F. 2d 320,326 (CA7 1983). See alsoCentral States, 472 U. S., at 570-571 (ERISA fiduciary duty includes common law duty ofloyalty); Bogert & Bogert, Law of Trusts and Trustees 543, at 218-219 (duty ofloyaltyrequires trustee to deal fairly an d honestly with beneficiaries); 2A Scott & Fratcher, Law ofTrusts 170, pp. 311-312 (same); Restatement (Second) of Trusts 170 (same). Because thebreach of this duty is sufficient to uphold the decision below, we need not reach the question ofwhether ERISA fiduciaries have any fiduciary duty to disclose truthful information on their owninitiative, or in response to employee inquiries.http://www.1aw.comell.edu/supct/html/94-1471 ,ZO.htmlEST Bilello cannot usurp the Council Delegate Body's (CDB) plenary power and authoritygranted via Section 5, 12 and 20 of the bylaws and violate his fiduciary obligations and duties bylying to the R.O., the Court and the rank & file members ofthis Organization, the NYCDCC.The R.O. and/or the Court should veto his employment, issue an order to hold an interim electionfor a new EST via the hybrid procedures and past practice of the court appointed Review OfficerDennis Walsh and hold this and all other contracts in abeyance until such election is completeand this honorable Court can set a Conference date for all matters presented for review fromFebruary 27,2013 throughApriI41h, notwithstanding the EST's belated response to the chargesduly filed and served upon him.Respectfully, 0 D _" ,/ } ~ J!J. J $ C f V ~ l /Demian D. Schroeder

9

http://www.1aw.comell.edu/supct/html/94-14http://www.1aw.comell.edu/supct/html/94-14

7/28/2019 4-11-13 DDS (11pgs) to RMB Doc. 1306

10/11

7/28/2019 4-11-13 DDS (11pgs) to RMB Doc. 1306

11/11

ADDmONAL SERVICE via E-Mail:Robert F. Makowski,Sterling Dadone,Norman Saul,Raynier Gamboa,Veronica Session

11


4-11-13 DDS (11pgs) to RMB Doc. 1306

Documents

Transcript of 4-11-13 DDS (11pgs) to RMB Doc. 1306