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LABORERS UNION GUYS OF CHICAGO -SOME - DOA - SOME CRUISING

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EXHIBIT K
99C 5229

In re BRUNO CARUSO )
FRANK CARUSO )
LEO CARUSO ) No._________________
JAMES DiForti )

DISCIPLINARY CHARGES

Pursuant to Sections 3 and 5(a) of the LIUNA Ethics and Disciplinary Procedure, the General
Executive Board Attorney ("GEB Attorney") hereby commences disciplinary proceedings
against BRUNO CARUSO, FRANK CARUSO, LEO CARUSO and JAMES DIFORTI through
the charges set forth below, The GEB Attorney alleges as follows:

INTRODUCTION

The Charged Persons

1. BRUNO CARUSO is an associate of the Chicago Outfit, BRUNO CARUSO currently


holds the positions of President and Business Manager of Local 1001 and is a delegate to the
Construction & General Laborers' District Council of Chicago and Vicinity ("Chicago District
Council" or "CDC"). BRUNO CARUSO has held the following union positions, among others:
President and Business Manager of the Chicago District Council, Trustee of the CDC's affiliated
Welfare Fund and Chairman of the CDC's affiliated Political Action League.

2. FRANK "TOOTS" CARUSO is an associate of the Chicago Outfit. FRANK CARUSO


resigned as a LIUNA member in April of 1995 but retains his right to reinitiate his LIUNA
membership. FRANK CARUSO has held the following union positions, among others: President
and Business Manager of Local 1006, Sergeant at Arms for the Chicago District Council,
delegate to the Chicago District Council,, Trustee of the CDC's affiliated Laborers' Fund, and
Director of the Chicago District Council's affiliated Pension Fund.

3. LEO CARUSO is an associate of the Chicago Outfit. LEO CARUSO currently holds the
position of President/Business Manager of Local 1006 and is a delegate to the Chicago District
Council. LEO CARUSO has held the following union positions, among others: Sergeant at Arms
of the Chicago District Council, Executive Board Member and Secretary-Treasurer of Local
1006, and Trustee to the CDC's affiliated Pension Fund,

4, JAMES DiForti ("DiForti") is an associate of the Chicago Outfit and is currently under
indictment for murder. DiForti resigned as a LIUNA member in July of 1997, but retains his
right to reinitiate his LIUNA membership. DfFORT1 has held the following union positions,
among others: Business Agent for Local 1002, Business Agent for Local 1006, Secretary-
Treasurer of Local 5, Coordinator of Committees of the Chicago District Council, and delegate
to the Chicago District Council.

The Structure and Operations of the Chicago Outfit

5. La Cosa Nostra (the "LCN" also referred to as the "Mob" or the "Mafia", is a criminal
organization operating in various cities throughout the United States. It Is in the business of
profiting from illegal activity. The LCN is divided into units, each of which is called a "family".
The Chicago family of the LCN is commonly referred to as the "Chicago Outfit" or the "Outfit".

6. The Chicago Outfit conducts illegal activities through entities known as "crews". Each
crew is headed and supervised by a person generally referred to as a "crew boss" and consists of
"made members." A "made member" is an individual who has been formally initiated into an
organized crime family and shares in the profits of the criminal enterprise. Crews also

consist of "associates", individuals who work on behalf of made members and/or who facilitate
mob activities through their participation in illegal or legitimate enterprises.

The 26' Street Crew

7, The 266 Street Crew (sometimes referred to as the "Southside" or "Chinatown" crew) of
the Chicago Outfit operates out of the 26' Street or Chinatown area of Chicago Over the past
three decades, the 26' Street Crew has been involved in gambling, chop shop operations,
extortion, political corruption, union corruption and other forms of criminal activity.

8. Frank "Skids" Caruso was the boss of the 26' Street Crew from sometime in the 1950's
through the 1970's. Angelo "The Hook" LaPietra became the boss of the 26' Street Crew W_ in
or around the early 1980's until his conviction in the mid- I 980s on charges of conspiracy to
illegally control gambling operations in Las Vegas and Teamsters Pension Fund operations in
Chicago. Joseph "Shorty" LaMantia was a member and a supervisor of the 26' Street Crew for a
number of years prior to his conviction on charges of racketeering conspiracy, gambling and
extortion in or around 1996. Fred Roti was an Alderman for the I" Ward in Chicago who was
involved in political corruption for a number of years until his conviction on charges of
racketeering, bribery and extortion in or around 1993 John "Apes" Monteleone is the current
boss of the 26' Street Crew and has been for a number of years.

9. Some other members or associates of the 26" Street Crew and/or the Chicago Outfit at
various times over the past three decades are: Pat Marcy, James LaPietra, Richie "The Cat"
Catazone, Donald "Captain D" DiFazio, Larry Pusiteri, Marco D'Amico, Robert "Bobby"
Abbinante, Ken Eto, Frank Caruso, Joe Granata, James Peter "Duke" Basile, Leonard Patrick,
James LaValley, William Jahoda, Richard Mara, Robert Cooley, Charles Francis ("Guy") Bills,
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"Dirge" Imperato and Michael Corbitt.

BRUNO CARUSO's Connections to The Chicago Outfit

10, BRUNO CARUSO is the son of former 26' Street Crew boss Frank "Skids" Caruso, the
brother of mob associate FRANK CARUSO, the cousin of mob associate LEO CARUSO and
the nephew of convicted felon and former I" Ward Alderman Fred Roti.

11. BRUNO CARUSO has admitted connections to the following bosses, members and/or
associates of the Chicago Outfit, among others: Angelo "The Hook" LaPietra, James LaPietra,
John "Apes" Monteleone, Larry Pusiteri, Richie "The Cat" Catazone, "Dirge" Imperato, Donald
"Captain D" DiFazio, and Joseph "Shorty" LaMantia.

12, Beginning in the late 1960's BRUNO CARUSO attended illegal dice games in the 26'
Street Area run by members and associates of the 26' Street Crew including Joseph "Shorty"
LaMantia, Larry Pusiteri, Donald "Captain D" DiFazio and Richie "the Cat" Catazone.

13. BRUNO CARUSO has been observed on a number of occasions with Pat Marcy, a I"
Ward politician who received large sums of money from the Chicago Outfit, On approximately
two occasions, BRUNO CARUSO was seen passing envelopes to Pat Marcy.

14. On a number of occasions, BRUNO CARUSO has been observed meeting with former
2601 Street boss, Angelo LaPietra and current 26' Street boss, John Monteleone.

15. In or around March of 1994, BRUNO CARUSO was observed meeting with Joseph
"Shorty" LaMantia, John "Apes" Monteleone, FRANK CARUSO and DiForti.

16. On June 16, 1997, BRUNO CARUSO was served with the Complaint for Trusteeship in
the Chicago District Council matter. Approximately one hour after receiving the
Complaint, BRUNO CARUSO traveled to the home of convicted felon and former I` Ward
Alderman, Fred Roti

17, A number of individuals closely associated with the Chicago Outfit 'identify BRUNO
CARUSO as an associate of the 26' Street Crew.

FRANK CARUSO's Connections to the Chicago Outfit

18. FRANK CARUSO is the son of former 26' Street Crew boss Frank "Skids" Caruso, the
brother of mob associate BRUNO CARUSO, the cousin of mob associate LEO CARUSO and
the nephew of convicted felon and former 1st Ward Alderman Fred Roti.

19. FRANK CARUSO has associated with at least the following members or associates of
the Chicago Outfit;
Robert "Bobby" Abbinante, Marco D'Arnico, Charles Francis "Guy" Bills, Richie "the Cat"
Catazone, Larry Pusiteri, Joseph "Shorty" LaMantia.

20. Beginning in the late 1960's FRANK CARUSO attend ed illegal dice games in the 26'
Street Area run by members and associates of the 26' Street Crew including Joseph "Shorty"
LaMantia Larry Pusiteri, Donald "Captain D" DiFazio and Ritchie "the Cat" Catazone

21. In the late 1960s, FRANK CARUSO was observed with Paul "The Walter" Ricca.

22. At various times from the early 1960s to the early 1980s, FRANK CARUSO socialized
and participated in illegal activities such as burglaries, robberies, bookmaking and chop shop
activities with mob associate Charles Francis "Guy" Bills, Richie Mara and others.

23. In or around March of 1994, FRANK CARUSO was observed meeting with Joseph
"Shorty" LaMantia, John "Apes" Monteleone, BRUNO CARUSO and DiForti.

Frank "Toots" Caruso


24. In or around April of 1995, FRANK CARUSO resigned from LIUNA the day he5
received a notice of deposition from the GEB Attorney's Office.

25. A number of individuals closely associated with the Chicago Outfit identify FRANK
CARUSO as an associate of the 261h Street Crew

LEO CARUSO's Connections to the Chicago Outfit

26, LEO CARUSO is the nephew of former 26' Street Crew boss Frank "Skids" Caruso and
the cousin of mob associates BRUNO CARUSO and FRANK CARUSO.

27. LEO CARUSO has admitted connections with the following members or associates of
the Chicago Outfit, among others: Donald "Captain D" DiFazio, Richie "the Cat" Catazone,
Larry Pusiteri, Joseph "Shorty" LaMantia.

28. Beginning in the late 1960's LEO CARUSO attended and, at times held a financial
interest in, illegal dice games in the 26' Street Area run by members and associates of the 26'
Street Crew including Joseph "Shorty" LaMantia, Larry Pusiteri, Donald "Captain D" DiFazio
and Richie "the Cat" Catazone.
29. At various times, LEO CARUSO has held a no-show job with the City of Chicago. In
1991, LEO CARUSO resigned from his street sweeping job during the pendency of an
investigation of city workers who were not on duty during work hours,

30. A number of individuals closely associated with the Chicago Outfit identify LEO
CARUSO as an associate of the 261h Street Crew.6

JAMES DiForti's Connections to the Chicago Outfit

31, JAMES DiForti has associated with at least the following members or associates of the
Chicago Outfit:

John "Apes" Monteleone, Joseph "Shorty" LaMantia, Vince Solano, Angelo


LaPietra.
32. In the 1970s and 1980s, DiForti was involved in "juice loans" for the Chicago Outfit.
DiForti also participated in burglaries during this period.

33. In or around 1988, DIFORTI murdered Bill "the Pallet Man" Benham in a dispute over
a $100,000 "juice loan".

34. In or around March of 1994, DIFORTI was observed meeting with Joseph "Shorty"
LaMantia, John "Apes" Monteleone, BRUNO CARUSO and FRANK CARUSO.

35. DiForti resigned from all of his positions in LIUNA in July of 1997, just a few days
prior to the hearing on the GEB Attorney's Complaint for trusteeship against the Chicago District
Council and the day he was arrested for murder.
3 6. A number of individuals closely associated with the Chicago Outfit identify DIFORTI
as an associate of the 26' Street Crew.

Manifestations of Mob Corruption within LIUNA.

37. BRUNO CARUSO, FRANK CARUSO, LEO CARUSO and DiForti have played
significant roles in the corruption of the Chicago District Council and certain of its affiliated
locals since the 1980s. For decades, the participation of these respondents, and others with ties to
organized crime, has resulted in a breakdown of democratic practices within the Chicago District
Council, its affiliated funds and certain of its affiliated locals. Decisions regarding the transfer of
official positions within the Chicago District Council and certain affiliated unions have been
made by officials with mob ties. A strong mob presence in the CDC, its affiliated funds and
certain affiliated locals has been perpetuated, and democratic, constitutional selection of officers
has been prevented, through a pattern of abuse that has resulted in: the avoidance of election.5
through uncontested nominations, repeated transfers of authority through power of appointment
between elections, appointments or uncontested nominations of unqualified or marginally
qualified individuals and the longstanding failure of LIUNA officials in Chicago to address
allegations of mob connections, no-show jobs or criminal arrests, indictments or convictions.

38. BRUNO CARUSO, FRANK CARUSO, LEO CARUSO and DiForti are aware of, and a
part of, this organized crime corruption of LIUNA. These respondents have failed to take action
or to investigate allegations of organized crime influence within LIUNA that they were aware of,
a part of, or should have been aware of through publicized reports and allegations. Respondents
themselves have obtained and retained various positions of power through undemocratic
practices and have permitted others to do the same. Through the following examples, among
others, some or all of the respondents have violated their duties of loyalty, the constitutional
duties of LIUNA members and have permitted LCN influence within the union: (a) the
appointment of FRANK CARUSO as a Sergeant at Arms of the Chicago District Council while
he was under arrest for extortion; (b) the failure to hold a proper election in 199T, (c) the transfer
of the coordinator of committee position at the Chicago District Council to made members and
associates during the 1990s; (d) the appointment of BRUNO CARUSO to various positions of
power within LIUNA in 1994; (e) the appointment of DiForti to a position of

power in Local 5 in 1994; (f) the appointment of LEO CARUSO to various positions of power in
1995; (g) the retention of FRANK CARUSO in an affiliated pension fund in 1995.

Charge 1 - BRUNO CARUSO


Barred Conduct - Membership in the Chicago Outfit

BRUNO CARUSO is, or has been, an associate of the 26h Street crew of the Chicago Outfit
and, by virtue of this status, he has committed barred conduct under the EDP.

Charge 2 - BRUNO CARUSO


Barred Conduct - Knowing Association with Chicago Outfit Members and Associates-

BRUNO CARUSO has committed barred conduct under the EDP by knowingly associating
with various members and associates of the Chicago Outfit, including:

Angelo "The Hook' LaPietra, James LaPietra, John "Apes" Monteleone, Larry Pusiteri,
Richie "The Cat" Catazone, "Dirge" Imperato, Donald "Captain D" DiFazio, and Joseph
"Shorty" LaMantia.

Charge 3 - BRUNO CARUSO


Violation of Duty of Loyalty

BRUNO CARUSO has violated the obligation of undivided loyalty incumbent upon all union
members, officers and employees of LIUNA, including but not limited to, those duties set forth
in the LIUNA Ethical Practices Code and those duties of union officials set forth in 29 U,S,C.
§501(a), to wit: BRUNO CARUSO failed to take any steps to investigate or eradicate organize
crime influence within the Chicago District Council and certain of its affiliated locals.
Specifically, BRUNO CARUSO failed to inform his fellow officers and CDC delegates of the
ties that FRANK CARUSO, LEO CARUSO, DiForti and others had to the Chicago Outfit and he
failed to take any steps to investigate publicized reports of organized crime influence or
violations of law by certain CDC officers and delegates including Vincent Solano, James
Caporale, John Matassa, FRANK CARUSO and others.

Charge 4 - BRUNO CARUSO


Barred Conduct -- Permitting LCN Influence

BRUNO CARUSO has permitted members andJor associates of the LCN to exercise control
or influence over the affairs of the Chicago District Council and certain of its affiliated entities
by permitting those with ties to the LCN to hold positions of trust and to exercise those positions
to further LCN influence. BRUNO CARUSO participated in a pattern of organized crime
influence over the Chicago District Council resulting in a failure of democratic process and the
selection of members and associates of the Chicago Outfit to top positions within the Chicago
District Council and certain of its affiliated entities.

Charge 5 - BRUNO CARUSO


Violation of Constitutional Duties of LIUNA Members and Officers
In permitting the LCN to exercise control or influence over the Chicago District Council and
certain of its affiliated entities as alleged more specifically in Charge 4, BRUNO CARUSO
failed to honor his obligations as a LIUNA member to refrain from interfering with the proper
conduct of LIUNA business in violation of Article III, Section 3(d) of the Uniform Local
Constitution, Ws duty as an Executive Board member of a LIUNA Local to see to it that the
affairs and business of the Local are being properly conducted in violation of Article IV, Section
4(H)(9) of the Uniform Local Constitution, and his duty as an Executive Board member of the
Chicago District Council to see to it that the-affairs and business of the Chicago District Council
are being properly conducted in violation of Article VU, Section 7(i), of the Uniform District
Council Constitution.

Charge 6 - FRANK CARUSO


Barred Conduct - Membership in the Chicago Outfit

FRANK CARUSO is, or has been, an associate of the 26' Street crew of the Chicago Outfit
and, by virtue of this status, he has committed barred conduct under the EDP.

Charge 7 - FRANK CARUSO


Barred Conduct - Knowing Association with Chicago Outfit Members and Associates
FRANK CARUSO has committed barred conduct under the EDP by knowingly associating
with various members and associates of the Chicago Outfit, including.-

Robert "Bobby" Abbinanti, Marco D'Amico, Charles Francis "Guy" Bills, Richie "the Cat"
Catazone, Larry Pusiteri, Joseph "Shorty" LaMantia.

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Charge 8 - FRANK CARUSO


Violation of Duty of Loyalty

Johnny Matassa
FRANK CARUSO violated the obligation of undivided loyalty incumbent upon ail union
members, officers and employees of LIUNA, including but not limited to, those duties set forth
in the LIUNA Ethical Practices Code and those duties of union officials set forth in 29 U.S.C.
§501 (a), to wit: FRANK CARUSO failed to take any steps to investigate or eradicate organize
crime influence within the Chicago District Council and certain of its affiliated locals.
Specifically, FRANK CARUSO failed to inform his fellow officers and CDC delegates of the
ties that BRUNO CARUSO, LF-0 CARUSO, DIFORTI and others had to the Chicago Outfit and
he failed to take any steps to investigate publicized reports of organized crime influence or
violations of law by certain CDC officers and delegates including Vincent Solano, James
Caporale, John Matassa and others.

Charge 9 - FRANK CARUSO


Barred Conduct - Permitting LCN Influence

FRANK CARUSO permitted members and/or associates of the LCN to exercise control or
influence over the affairs of the Chicago District Council and certain of its affiliated entities by
permitting those with ties to the LCN to hold positions of trust and to exercise those positions to
further LCN influence. FRANK CARUSO participated in a pattern of organized crime influence
over the Chicago District Council resulting in a failure of democratic process and the selection of
members and associates of the Chicago Outfit to top positions within the Chicago District
Council and certain of its affiliated entities.
Charge 10 - FRANK CARUSO

Violation of Constitutional Duties of LIUNA Members and Officers

In permitting the LCN to exercise control or influence over the Chicago District Council and
certain of its affiliated entities as alleged more specifically in Charge 9, FRANK CARUSO
failed to honor his obligations as a LIUNA member to refrain from interfering with the proper
conduct of LIUNA business in violation of Article III, Section 3(d) of the Uniform Local
Constitution and his duty as an Executive Board member of a LIUNA Local to see to it that the
affairs and business of the Local are being properly conducted in violation of Article IV, Section
4(14)(9) of the Uniform Local Constitution.

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Charge 11 - LEO CARUSO


Barred Conduct - Membership in the Chicago Outfit

LEO CARUSO is, or has been, an associate of the 26' Street Crew of the Chicago Outfit and,
by virtue of this status, he has committed barred conduct under the EDP.

Charge 12 - LEO CARUSO


Barred Conduct - Knowing Association with Chicago Outfit Members and Associates

LEO CARUSO has committed barred conduct under the EDP by knowingly associating with
various members and associates of the Chicago Outfit, including:

Angelo "The Hook" LaPietra~ James LaPietra, John "Apes" Monteleone, Larry Pusiteri,
Richie "The Cat" Catazone, "Dirge" Imperato, Donald "Captain D" DiFazio, and Joseph
"Shorty" LaMantia,

Charge 13 - LEO CARUSO


Violation of Duty of Loyalty

LEO CARUSO has violated the obligation of undivided loyalty incumbent upon all union
members, officers and employees of LIUNA, including but not limited to, those duties set forth
in the LIUNA Ethical Practices Code and those duties of union officials set forth in 29 U,S,C.
§50 1 (a), to wit: LEO CARUSO failed to take any steps to investigate or eradicate organized
crime influence within the Chicago District Council and certain of its affiliated locals.
Specifically, LEO CARUSO failed to inform his fellow officers- and CDC delegates of the ties
that FRANK CARUSO, BRUNO CARUSO, DIFORTI and "others had to the Chicago Outfit
and he failed to take any steps to investigate publicized reports of organized crime influence or
violations of law by certain CDC officers and delegates including Vincent Solano, James
Caporale, John Matassa, FRANK CARUSO and others.
Charge 14 - LEO CARUSO
Barred Conduct - Permitting LCN Influence
LEO CARUSO has permitted members and/or associates of the LCN to exercise control or
influence over the affairs of the Chicago District Council and certain of its affiliated entities by
permitting those with ties to the LCN to hold positions of trust and to exercise those positions to
further LCN influence. LEO CARUSO participated in a pattern of organized crime influence
over the Chicago District Council resulting in a failure of democratic process and the selection of
member ' s and associates of the Chicago Outfit to top positions within the Chicago District
Council and certain of its affiliated entities.

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Charge 15 - LEO CARUSO


Violation of Constitutional Duties of LIUNA Members and Officers
In permitting the LCN to exercise control or influence over the Chicago District Council and
certain of its affiliated entities as alleged more specifically in Charge 14, LEO CARUSO failed
to honor his obligations as a LIUNA member to refrain from interfering with the proper conduct
of LIUNA business in violation of Article III, Section 3(d) of the Uniform Local Constitution
and Ws duty as an Executive Board member of a LIUNA Local to see to it that the affairs and
business of the Local are being properly conducted in violation of Article IV, Section 4(H)(9) of
the Uniform Local Constitution.

Charge 16 - JAMES DiForti


Barred Conduct - Membership in the Chicago Outfit

JAMES DiForti is, or has been, an associate of the 26' Street crew of the Chicago Outfit and,
by virtue of this status, he has committed barred conduct under the EDP.

Charge 17 - JAMES DiForti


Barred Conduct - Knowing Association with Chicago Outfit Members and Associates
JAMES DiForti has committed barred conduct under the EDP by knowingly associating with
various members and associates of the Chicago Outfit, including:

John "Apes" Monteleone, Joseph "Shorty" LaMantia, Vince Solano, Angelo "The Hook"
LaPietra.
Jimmy DiForti
Charge 18 - JAMES DiForti
Violation of Duty of Loyalty

JAMES DIFORTI has violated the obligation of undivided loyalty incumbent upon all union
members, officers and employees of LIUNA, including but not limited to, those duties set forth
in the LIUNA Ethical Practices Code and those duties of union officials set forth in 29 U.S.C.
§501(a), to wit: JAMES DIFORTI failed to take any steps to investigate or eradicate organize
crime influence within the Chicago District Council and some of its affiliated locals.
Specifically, JAMES DIFORTI failed to inform his fellow officers and CDC delegates of the ties
that BRUNO CARUSO, FRANK CARUSO, LEO CARUSO and others had to the Chicago
Outfit and he failed to take any steps to investigate publicized reports of organized crime

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influence and violations of law by certain CDC officers and delegates including Vincent Solano,
James Caporale, John Matassa, FRANK CARUSO and others.

Charge 19 - JAMES DiForti


Barred Conduct - Permitting LCN Influence
JAMES DiForti permitted members and/or associates of the LCN to exercise control or
influence over the affairs of the Chicago District Council and certain of its affiliated entities by
permitting those with ties to the LCN to hold positions of trust and to exercise those positions to
further LCN influence. JAMES DiForti participated in a pattern of organized crime influence
over the Chicago District Council resulting in a failure of democratic process and the selection of
members and associates of the Chicago Outfit to top positions within the Chicago District
Council and certain of its affiliated entities.

Charge 20 - JAMES DiForti


Violation of Constitutional Duties of L11UNA Members and Officers

In permitting the LCN to exercise control or influence over the Chicago District Council and
certain of its affiliated entities as alleged more specifically in Charge 19, JAMES DiForti failed
to honor his obligations as a LIUNA member to refrain from interfering with the proper conduct
of LIUNA business in violation of Article III Section 3(d) of the Uniform Local Constitution and
his duty as an Executive Board member of a LIUNA Local to see to it that the affairs and
business of the Local are being property conducted in violation of Article IV, Section 4(H)(9) of
the Uniform Local Constitution.

s/Robert D. Luskin by MEP


Robert D. Luskin
GEB Attorney
Date: March 1999

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