VISIT IPSN.

ORG for background of individuals

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,

"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

4
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 he

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.

10

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.

11

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.

12

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