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EXHIBIT A

From: John Musumeci [mailto:jmusumeci157@gmail.com] Sent: Monday, February 25, 2013 6:36 AM To: Santo Barravecchio; Carol Moran; Barbara Deinhardt Cc: Dennis Walsh; Michael Bilello; James Murphy; Josh Leicht Subject: 5.f. Arbitration

Dear Trial Committee Co-Chairs: Please accept this email as my official request for arbitration pursuant to Paragraph 5.f of the NCYDC Bylaws. Below are five questions to be decided by the arbitrators and the remedy sought and a reference to paragraph 5.f. for your convenience. If you need any further information, I can be reached either by email jmusumeci157@gmail.com or telephone 646-812-3527. Thank you, John Musumeci Local 157 Delegate to the District Council Questions to be decided: 1. Did NYCDCC EST Michael Bilello, in violation of the laws of the UBC, engage in a concerted effort and targeted pattern of harassment, threats, coercion, bullying & intimidation carried out by his assistant and/or others, in a year long campaign which culminated at a July 25, 2012 delegate meeting at approximately 7:30 pm, whereby Bilello, directly engaged in a course of vexatious, personal and indecorous comments or conduct that is known or ought reasonably to be known to be unwelcome, which incited UBC members to publicly harass, intimidate and humiliate Delegate John Musumeci by threatening to file; and by filing bogus charges against him, in direct retaliation for exercising his First Amendment freedom of speech, LMRDA & NLRA Section 7 rights as a union member with regard to his having raised multiple serious questions relative to the conduct and handling of the MWA Arbitration? 2. Did NYCDCC EST Michael Bilello, in violation of the laws of the UBC, intentionally fail to keep accurate, and/or caused the July 25, 2012 delegate body meeting minutes to be altered in a way that omitted the vexatious, personal and indecorous comments and appalling failure of decorum and procedure? 3. Did NYCDCC EST Michael Bilello, in violation of the laws of the UBC, abuse his authority and/or cause/prevent the Director of Human Resources from investigating a compliant of harassment by Delegate John Musumeci? 4. Did NYCDCC EST Michael Bilello, in violation of the laws of the UBC, withhold vital information from the delegate body, by unilaterally making the decision to go forward and take the MWA to arbitration without first seeking or having delegate body approval?

5. Did NYCDCC EST Michael Bilello, in violation of the laws of the UBC, cause and/or failed to provide information about the District Council (e.g., MWA arbitration, contract negotiations, etc.) to the membership by not effectively maintaining the District Council website? Remedy Sought: For serious violations of the laws of the UBC, Michael Bilello, is banned from holding elected office, a $75,000 fine imposed, and mandatory training on parliamentary rules and procedures for all District Council Officers. Section 5.f. states: No Delegate of the Council Delegate Body shall be subject to any adverse employment action, harassment, intimidation, threats, or coercion by the District Council, the Council Delegate Body or any Officer thereof for exercising, in good faith, the authority of, or fulfilling the duties of, a Council Delegate as provided for in these Bylaws. Any Delegate that believes that he or she has been subject to a violation of this section may file a complaint with the Chief Compliance Officer and the Inspector General, who shall conduct a joint investigation of the merits of such complaint. Upon completion of that investigation, no later than ninety (90) days following receipt of the complaint, either the Chief Compliance Officer or the Inspector General may refer the matter to the Trial Committee, the Review Officer (to the extent such a Review Officer is in place), or the United States Attorney, as appropriate. The foregoing shall not limit any Delegates right to also file a complaint with the Gen eral President of the United Brotherhood, as provided for under Section 53(G) of the UBC Constitution. In addition to the foregoing, any District Council Delegate may file a complaint with the Trial Committee Chairman and thereby initiate an arbitration to be conducted before a three-member panel consisting of the Trial Committee Chairman, Trial Committee Vice Chairman, and a third arbitrator to be chosen by the Trial Committee Chairman and Trial Committee Vice Chairman. All decisions of said panel must be supported by substantial evidence and any party to the proceeding may seek review of a decision with the District Court.

-John's mobile: 646-812-3527

EXHIBIT B

EXHIBIT C

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