Non-interference agreement with Executive Board

May 26, 1999

VIA HAND DELIVERY & FACSIMILE

Mr. James D. Montgomery
111 W. Washington Street
Suite 823
Chicago, IL 60602

RE: Local 2, LIUNA

Dear Mr. Montgomery:

As discussed in our telephone conversation, if the undersigned former Members of Local 2’s Executive Board agree to the following, we will withdraw the pending Application for a Temporary Restraining Order.

The former officers, employees and Executive Board Members of LIUNA, Local 2, as indicated by their signatures below, agree, warrant and represent that they collectively, and each of them, do hereby:

1. Acknowledge as of Monday, May 24, 1999, all Executive Board Members of Local 2 were relieved of their Trust pursuant to Article IX, Section 7 of the International Union Constitution;
2. Recognize that the Temporary Trustee is the lawfully appointed Temporary Trustee of LIUNA, Local 2 and has full authority to conduct the affairs of that entity until such time as his authority is resolved under the provisions of the LIUNA Constitution or by Order of a Court of competent jurisdiction;
3. Cooperate in the delivery of all property, funds, books, records and assets of any kind in their position to LIUNA and/or the Temporary Trustee or his designee;
4. Not represent themselves as the authorized officers and/or representatives of LIUNA, Local 2 or take any action as the authorized or acting representative, managers, agents or officers of LIUNA, Local 2 other than those specified by the Temporary Trustee or his designee;
5. Not interfere with the implementation of the Temporary Trusteeship or the functions of the Temporary Trustee or his designee;

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Mr. James Montgomery
Page Two of Three
May 26, 1999

6. Not interfere with the operations of LIUNA, Local 2
   under the Temporary Trustee, including interference with the collective bargaining process, employer relations, employee relations and inter-union relationships;
7. Not interfere with the transfer of signatory status on all bank accounts from the former officers of LIUNA, Local 2 to the Temporary Trustee of his designee;
8. Provide a complete accounting of the financial condition of LIUNA, Local 2 to the Temporary Trustee or his designee or refuse to provide any and all financial records and an explanation for all receipts, disbursements and financial transactions of any kind related to LIUNA, Local 2;
9. In no manner or fashion destroy, remove, or otherwise alter the books, records, accounts and other financial documents relating to LIUNA, Local 2; and
10. Not refuse to provide access or turn over the keys to the facilities, automobiles, and other assets of LIUNA, Local 2.

Pursuant to your representations that you will obtain the required signatures below, LIUNA and the Temporary Trustee agree to enter and continue its previously filed Motion for a Temporary Restraining order until tomorrow at a time set by the Court. In the event you are able to provide us with original signatures to this document by close of business today, we will withdraw our Motion for a Temporary Restraining Order. Obviously, in the event you are unable to obtain all of the required signatures, we will be required to proceed. We would appreciate your verbal confirmation of this agreement prior to the scheduled 2:30 p.m. Hearing.

Mr. James Montgomery
Page Three of Three
May 26, 1999

AGREED AND ACCEPTED
_______________________________________
Officer and/or Executive Board Member
_______________________________________
Officer and/or Executive Board Member
_______________________________________
Officer and/or Executive Board Member
_______________________________________
Officer and/or Executive Board Member
_______________________________________
Officer and/or Executive Board Member
_______________________________________
Officer and/or Executive Board Member
_______________________________________
Officer and/or Executive Board Member
s/James Montgomery_____________________
Attorney for Local 2
_______________________________________
Attorney for John Matassa, Jr.

Laborers for JUSTICE � 1999 �Published as a free service to members of local 2 and the public

Laborers for JUSTICE

2615 W Peterson Av.
Chicago, Il 60659
773-878-1002 (tel)
773-409-1503(fax)