Page 1 1 IN THE MATTER OF THE PRE-TRUSTEESHIP HEARING BETWEEN 2

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					1     IN THE MATTER OF THE PRE-TRUSTEESHIP HEARING BETWEEN
2
     SEIU INTERNATIONAL PRESIDENT ANDREW L. STERN )
3                              )
     and                           )
4                             )
     SEIU UNITED HEALTHCARE WORKERS-WEST.       )
5    _____________________________________________)
6
7
           REPORTER'S TRANSCRIPT OF PROCEEDINGS
8
               SAN MATEO, CALIFORNIA
9
             SATURDAY, SEPTEMBER 27, 2008
10
                DAY TWO, VOLUME 2
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21
     ATKINSON-BAKER, INC.
22   COURT REPORTERS
     www.depo.com
23   (800) 288-3376
24   REPORTED BY: MARYANN P. COSTA RPR, RMR, CSR NO. 5820
25   FILE NO.: A2081E8


                                                             Page 1
                                                        Page 2                                                        Page 4
1      IN THE MATTER OF THE PRE-TRUSTEESHIP HEARING BETWEEN      1               INDEX
                                                                 2 REPORTER'S TRANSCRIPT OF PROCEEDINGS
2
                                                                                                   PAGE
      SEIU INTERNATIONAL PRESIDENT ANDREW L. STERN )             3
                                                                      MORNING SESSION                           6
3                              )                                 4
      and                        )                                    SEIU WITNESSES:
4                              )                                 5
                                                                      WALTER ZELMAN
      SEIU UNITED HEALTHCARE WORKERS-WEST.       )               6
 5    _____________________________________________)                  DIRECT EXAMINATION                    PAGE
                                                                 7
 6                                                                       BY MR. ROTHNER                     8
 7                                                               8
                                                                      CROSS-EXAMINATION                     PAGE
 8
                                                                 9
 9                                                                       BY MR. CHATTERJEE                  34
10                                                               10
                                                                      UNITED HEALTHCARE WORKERS-WEST WITNESSES:
11                                                               11
12                                                                    JOHN BORSOS
                                                                 12
13                                                                    DIRECT EXAMINATION                    PAGE
14                                                               13
                                                                         BY MR. CHATTERJEE                  55
15
                                                                 14
16                                                                    CROSS EXAMINATION                     PAGE
17                                                               15
                                                                         BY MR. DAYAN                     148
18                                                               16
19                                                                    EXAMINATION
                                                                 17
20            Transcript of Proceedings taken at San                  DANIEL MARTIN
   Mateo Event Center, 2495 South Delaware, Fiesta Hall, San     18
                                                                         BY MR. HARRIS                    203
21 Mateo, California, commencing at 9:00 a.m., Saturday,         19
   September 27, 2008, before Maryann P. Costa RPR, RMR,              MEMBER STATEMENTS                         205
22 CSR No. 5820.                                                 20
                                                                 21
23                                                               22
24                                                               23
                                                                 24
25                                                               25

                                                        Page 3                                                        Page 5
1           APPEARANCES                                           1                 I N D E X (CONTINUED)
2 THE HEARING OFFICER:
3 SECRETARY RAY MARSHALL                                          2     SEIU EXHIBITS:
     The University Of Texas at Austin
4 2315 Red River
                                                                  3     NUMBER                             ID  IN EV.
     P.O. Box Y                                                   4     76-   Unity Magazine Issue - Summer 2007 158
5 Austin, Texas 78713-8925
     (512) 471-6242
                                                                  5     77-   Unity Magazine Issue - Fall 2007 158
6                                                                 6     78-   Unity Magazine Issue - Winter 2007 158
     FOR THE CATHOLIC HEALTHCARE WORKERS-WEST:
7                                                                 7
     MORRISON & FOERSTER, LLP                                     8
8 BY: SOMNATH RAJ CHATTERJEE, ESQ.
        GEORGE HARRIS, ESQ.                                       9
9 425 Market Street                                              10
     San Francisco, California 94105-2482
10 (415) 268-7537                                                11
11 FOR SERVICE EMPLOYEES INTERNATIONAL UNION:
12 ROTHNER, SEGALL & GREENSTONE
                                                                 12
     BY: GLENN ROTHNER, ESQ.                                     13
13 510 South Marengo Avenue
     Pasadena, California 91101-3115
                                                                 14
14 (626) 796-7555                                                15
15 FOR INTERNATIONAL PRESIDENT ANDREW L. STERN:
16 BREDHOFF & KAISER, PLLC                                       16
     BY: LEON DAYAN, ESQ.                                        17
17 805 Fifteenth Street, N.W.
     Washington, D.C. 2005                                       18
18
19 FOR SERVICE EMPLOYEES INTERNATIONAL UNION, CTW, CLC:
                                                                 19
20 SEIU:                                                         20
   BY: ORIN BAIRD, ESQ.
21    DEIRDRE C. FITZPATRICK, ESQ.
                                                                 21
      BOB HAUPTMAN                                               22
22 1800 Masachusetts Avenue, N.W.
   Washington D.C. 20036
                                                                 23
23 (202) 730-7451                                                24
24
25                                                               25
                                                                                                     2 (Pages 2 to 5)
                                                         Page 6                                                               Page 8
 1   SATURDAY, SEPTEMBER 27, 2008                      9:00 a.m.   1       MR. ROTHNER: Secretary Marshall, one of the
 2             P-R-O-C-E-E-D-I-N-G-S                               2    threatened members wrote an account of it that I'd like
 3                 --oOo--                                         3    to have you take a look at it.
 4      SECRETARY MARSHALL: Good morning. Let me remind            4       SECRETARY MARSHALL: All right. We will continue
 5   you, all, that there will be no video or flash bulb           5    where we left off yesterday. The counsel for the
 6   picture-taking. The Sergeant at Arms will ask people who      6    international president had not finished making his
 7   are doing this to stop; so, don't give them too much work     7    presentation, so, we'll let him resume now.
 8   to do.                                                        8       MR. ROTHNER: Yes. Our next witness is Walter
 9       As I mentioned to you, we will reserve some time, at      9    Zelman.
10   the end of the session, today -- at least an hour -- I        10
11   don't know exactly how much time we'll have, but, it will     11                   WALTER ZELMAN,
12   be at least an hour -- for people to speak. If you            12             called as a witness on behalf of
13   signed up yesterday, we have your card; and, therefore,       13           SEIU, having been placed under oath,
14   you need not sign up again. We have a larger number of        14                 testified as follows:
15   people sign up than we're going to have time for, so,         15
16   what I would like to urge you to do, if you don't get a       16                 DIRECT EXAMINATION
17   chance to speak, today, to send me a written statement of     17      BY MR. ROTHNER:
18   whatever you wanted to say; and, if you do it within the      18      Q. Would you state your name and spell it, for the
19   next 30 days, in your seat, on the green sheet of paper,      19 record, please?
20   is my address where you can send things. And I would          20    A. My name is Walter Zelman. Z-E-L-M-A-N.
21   very much like to hear from you if you have some things       21    Q. Walter, put the mic' as close to you as
22   you'd like to say to me about the matters that we're          22 possible. There you go.
23   covering in this hearing.                                     23    A. My name is Walter Zelman. Z-E-L-M-A-N.
24        Let me also remind you that it will be very              24    Q. Mr. Zelman, were you present during the
25   difficult for us to have an orderly, fair, and thorough       25 testimony of any other witness in this proceeding?

                                                         Page 7                                                               Page 9
 1   hearing unless we have quiet, so that the attorneys and       1       A. No.
 2   witnesses and the -- so that we could all hear what's         2       Q. Would you take a look in the binder to your
 3   going on. So, let me urge you to be as quiet as you can       3    left, the very last exhibit before the tag that says
 4   in order to permit us to do that.                             4    "UHW-W Minutes" --
 5       In addition, the Sergeant at Arms would like to make      5       THE WITNESS: Which binder are you referring to?
 6   a statement about some things that happened yesterday.        6       MR. ROTHNER: Our first binder.
 7   Go ahead.                                                     7       THE WITNESS: Which exhibit?
 8       SERGEANT AT ARMS: Okay, so, yesterday, Dan Martin         8       MR. ROTHNER: 73.
 9 came over to a group of members that are here and he said       9       SECRETARY MARSHALL: 73.
10 to them:                                                        10    MR. ROTHNER: Q. And, Mr. Zelman, is that your
11     "Fuck you mother-fuckers. I'm going to fuck you             11 C.V.?
12 up."                                                            12    A. Yes, that is.
13     And they felt very threatened by that.                      13    Q. Is it an accurate reflection of your
14    And, then, today, he came over and glared at them;           14 professional expertise, activities, professional
15 and, again, they felt intimidated -- the members that           15 experience, activities, and education?
16 reported that to me.                                            16    A. Yes, it is.
17      SECRETARY MARSHALL: They're having trouble hearing.        17   Q. Thank you.
18      SERGEANT AT ARMS: Should I say it again?                   18   I'm not going to cover all of the items on it,
19      SECRETARY MARSHALL: Speak louder.                          19 but -- I'm going to hit a few that are relevant, but --
20     SERGEANT AT ARMS: Okay, the members that told me            20 you can go ahead and close that up and testify from your
21 were Yvette, Sophia, and Michelle.                              21 own memory at this point.
22     SECRETARY MARSHALL: You don't know. Whoever said            22   What is your current occupation?
23 that doesn't know if it's a lie unless you were a               23    A. I'm a professor and chair of the Department of
24 witness, so, let's keep it as cordial as you can in order       24 Health Science at California State University Los
25 to prevent disruption of this hearing.                          25 Angeles.

                                                                                                         3 (Pages 6 to 9)
                                                             Page 10                                                              Page 12
1       Q. All right.                                                  1   advocacy groups for the uninsured in California;
2       Do you have any special projects or research that              2       I serve as vice-chair of the Board of Los Angeles --
3    you are involved with, currently?                                 3   of L.A. Care -- which is the medical plan for -- the
4       A. Yes. I'm just completing two studies, both                  4   public medical plan for -- Los Angeles;
5    funded by foundations.                                            5       And, now, as a professor, I continue to teach health
6       The first was an in-depth study of the policies of             6   policy, special emphasis on the uninsured.
7    the recent Schwarzenegger-Nunez effort to create                  7       I've taught at UCLA, USC, and, now, at California
8    near-universal coverage in California, which began in              8 State University Los Angeles, all on the issue of health
9    early 2007 through early 2008.                                     9 policy with a special focus on the uninsured.
10      The second is a five-state study looking at                    10     Q. Earlier in your career, did you have an active
11 California, New York, Massachusetts, Illinois, and                  11 role in political reform as opposed to healthcare reform?
12 Pennsylvania, and the efforts of those states to achieve            12    A. Yes.
13 universal coverage -- or near-universal coverage -- over            13    For about 12 years, I was the Executive Director of
14 the last year.                                                      14 California Common Cause, which is -- was, certainly, and
15      Q. For better or worse, I think everyone knows the             15 may be, still, is kind of the leading organization in the
16 name Schwarzenegger, but, it's possible that not everyone           16 nation and California dedicated, primarily, towards
17 knows the name Nunez.                                               17 political reform -- ethics reform -- campaign financing,
18      Who is Mr. Nunez?                                              18 etc.
19      A. Mr. Nunez was the Speaker of the California                 19    Q. Would you describe, very briefly, your
20 State Assembly and the author of, and leading proponent             20 educational background?
21 of, the universal coverage proposal that was before the             21    A. I have a Bachelor's Degree in Political Science
22 State Legislature during 1977 and early very early 19 --            22 from the University of Michigan, one year of which was
23 I'm sorry -- 2007 -- and early 2008.                                23 spent at the London School of Economics;
24      Q. Okay, I'm going to get back to your study and               24    I have a Masters from UCLA in International
25 the legislation, shortly. I just want to get a little               25 Relations;

                                                             Page 11                                                              Page 13
 1   bit more information about your background.                1               And a Ph.D. from UCLA in American Politics.
 2       Do you have background on the subject of health        2               Q. Have you published in the field of healthcare
 3   policy issues prior to your arrival at Cal State Los       3           policy?
 4   Angeles and involvement with the legislation you just 4                   A. Yes. I published a number of articles over the
 5   mentioned?                                                 5           years on various aspects of health policy, including, you
 6       A. Yes, going back to -- I've been active in the       6           know, outlines and descriptions of the ill-fated Clinton
 7   issue of health insurance and, particularly, the issue of  7           plan, and descriptions of why it lost, that had been
 8   the uninsured since the early 1990's.                      8           published, mostly, in Health Affairs, which is, probably,
 9       I worked for then-Insurance Commissioner               9           the leading national journal on health policy and
10   Garamendi -- John Garamendi -- in California, and,        10           politics;
11   developed a proposal for universal coverage in California 11               And I've just completed, as I mentioned earlier, two
12   which was, effectively -- caught the eye of the incoming  12           articles, which, one will be published -- both expected,
13   Clinton administration -- and, after working in           13           probably, to be published -- by the end of the year on
14   California for two years on this, I went to Washington in 14           the two studies I just completed.
15   1993 and 1994 and worked on the Clinton healthcare reform 15              Q. Well, tell me about the two studies.
16   effort to achieve universal coverage in the United        16              What, specifically, is the title of each?
17   States. I stayed in Washington. I wrote two books on      17                A. I think the title is still to be debated a
18   health policy.                                            18           little bit, but, the study on California is tentatively
19       After that, I came back to California;                19           titled "Swimming Upstream" implying how difficult it is
20       I worked for the Association of Health Plans for      20           to get a state to approve universal coverage; but, the
21   about five years;                                         21           focus of the study is on the relationships between the
22       I worked at USC for a few years;                      22           systemic environment, the politics and the policy of
23       All this time, keeping an eye on this issue;          23           efforts to expand coverage in California.
24       And I'm also on the board of a group called Insure    24               And, the essence of the study is that, while I
25   the Uninsured Project, which is one of the leading        25           looked at all the public records and monitored the debate

                                                                                                       4 (Pages 10 to 13)
                                                          Page 14                                                                Page 16
 1   in California, publicly, I interviewed -- I conducted          1    ended with the end of the regular legislative session in
 2   over 100 interviews, most of them at least 35 minutes,         2    September of 2007.
 3   beginning in early January 2007, when the governor first       3        That bill was also authored by Speaker Nunez, so,
 4   introduced his proposal, through the end of January --         4    when the regular session ended, they had to introduce the
 5   actually, through early February, 2008.                        5    new bill -- the bill, again, in the Extraordinary
 6       And so the heart of the research is, really, the           6    Session.
 7   information gleaned from all those interviews which I did      7       Q. Was Governor Schwarzenegger associated with any
 8   with people who were officials in the administration,          8    of these bills as a key proponent?
 9   people from the Legislature, staff people, lobbyists,          9        A. No, because -- not at first, because, his
10   foundation people, professors.                                 10 proposal, which never was actually put into a bill, never
11      Q. And the other publication will address what?             11 had a bill number on it -- his proposal was somewhat
12      A. The other publication kind of took off from              12 different from -- it was certainly different from AB 8
13   that and added to the study of politics and policy that I      13 and it was also different from ABXI-I; although, by the
14   did in California for other states -- more cursory review      14 end of 2007, ABXI-I had been changed enough to get the
15   of the other states.                                           15 governor's endorsement so that, by about Christmastime
16       I didn't go anywhere near the depth that I went in         16 2007, the governor was now a supporter of ABXI-I.
17   California, but, that involved looking at all the public       17      Q. And, by then, what had happened to AB 8?
18   record materials about universal coverage efforts in           18       A. AB 8 was kind of legally and officially dead
19   Massachusetts, which has had some partial success, at          19 because it was a regular session bill; and the regular
20   least -- Massachusetts, New York, Pennsylvania, Illinois,      20 session, the two-year session of the Legislature, was
21   and, California -- and, again, we reviewed the public          21 over as of early September 2007; so, AB 8 was history and
22   materials that were available; and also did, in that           22 ABXI-I was its successor.
23   case, maybe four or five interviews with people in those       23      Q. All right, so, we're going do discuss, only,
24   states to try to dig a little bit below the surface as to      24 ABXI-I now.
25   the politics of what happened in those states.                 25   A. Okay.

                                                          Page 15                                                                Page 17
1       So, that is tentatively titled, "The Intersection of         1       Q. Was that a package, complete, in itself, or,
2    Politics and Policy - A Five-State Study of Universal           2    did it require some additional action of the state in
3    Coverage".                                                      3    order for it to be implemented?
4       Q. What is ABXI-I?                                           4       A. ABXI-I was linked to an initiative which had
5       A. That's the number given the bill authored by              5    not yet been circulated. It had been filed and approved
6    Speaker Nunez in the Extraordinary Session, generally,          6    and was ready for circulation, but, the ABXI-I would not
7    called a Special Session, that began in the fall of 2007.       7    take effect without the passage of an initiative which
8       Q. And "AB" signifys Assembly Bill?                          8    they hoped to put on the November 2008 ballot.
 9    A. Assembly Bill; and the number is always                     9       Q. And, in California, is it -- an initiative -- a
10 confused, and people get it wrong all the time.                  10    means by which the people, as distinct from the
11    The "ABX" -- the "X" is for the Extraordinary                 11    Legislature, can enact legislation?
12 Session. The "I" is for the First Extraordinary Session;         12       A. Yes. The initiative covers various different
13 and the second "I" is for the Bill No. I in the First            13    types of initiatives. This, in fact, was a
14 Extraordinary Session.                                           14    constitutional amendment, but -- yes, you would need to
15    Q. Does the fact that the "X-1" signifies that it             15    get a certain number of specified number of signatures --
16 was the First Extraordinary Session mean, necessarily,           16    valid signatures -- collected in 150-day period;
17 that there was a Second Extraordinary Session?                   17        And then, the Secretary of State would approve that
18    A. Yes. There was a Second Extraordinary Session,             18    the signatures were valid;
19 concurrently, with the First Extraordinary Session.              19       And then it would go on the ballot;
20    And Extraordinary Session has to be called for a              20       And, in this case, the initiative that would have
21 purpose -- a specific purpose.                                   21    been put on the ballot -- in other words, they had hoped
22    Q. All right, now, ABXI-I addressed healthcare                22    for and intended to put on the ballot in November of '08,
23 reform?                                                          23    this coming November, would have been linked to ABXI-I;
24    A. ABXI-I was, in effect, the successor to AB 8,              24    so, neither would really have any value without the
25 which was the regular session bill that had, in effect,          25    other.

                                                                                                        5 (Pages 14 to 17)
                                                             Page 18                                                           Page 20
1       Q. What piece of the package was addressed by the              1    you have?
2    proposed initiative?                                              2       A. I don't believe so. There have been a few
3       A. The money -- those of you familiar with                     3    articles published by people who I would call
4    California politics know we have a rule in California             4    intellectuals or academics or think tank-type people who
5    that says, we can't raise new taxes -- this is going way          5    have written articles; but, most of those were more
6    back to the Jarvis days -- you can't raise any revenues           6    narrowly focused on the policy components of the issue.
7    or taxes without a two-thirds vote. It was ruled a                7       And I was looking at the much broader intersection
 8 number of the issues -- a number of the revenue                      8 of politics and policy. I don't know anyone who has
 9 sources -- in the legislation required a two-thirds vote.            9 engaged in the kind of comprehensive research that I
10    Republicans, frankly, were not willing to provide                10 engaged in in this.
11 any votes; and you need some Republican votes to get a              11    Q. What happened to ABXI-I?
12 two-thirds vote in the California Legislature.                      12    A. It was defeated in the Senate Health Committee
13    So, it was determined that the only way they could               13 on January 28, 2008.
14 get the revenues from the employers and from the                    14    Q. All right. I want to ask you to take a look in
15 hospitals to fund this measure was to get the voters to             15 the binder again. This is the International President's
16 approve it; because you couldn't get a two-thirds vote in           16 Binder No. 1. And, if you would take a look, please --
17 the Legislature.                                                    17 I'm sorry -- it's No. 2. Let me help you here. The page
18    Q. All right, so, getting back to your study, you                18 I'd like you to turn to is under the tab "ABI-XI,
19 said you conducted 100 or more interviews.                          19 LegHis" -- which is Legislative History -- and, Secretary
20    And, who were you interviewing?                                  20 Marshall, for your benefit, I just wanted to point out
21    Not by name, so much, as by affiliation or                       21 that that entire tab consists of legislative history
22 constituency.                                                       22 analysis that we commissioned, and, it is preceded -- on
23    A. I interviewed some legislators;                               23 the first page, the content, by declaration, from the
24    Many legislative staff;                                          24 representative of the Legislative Temp Service who
25      I attended, virtually, all the public hearings about           25 performed the analysis -- but, on page 851, there is a

                                                             Page 19                                                           Page 21
1    AB 8 and then ABXI-I;                                              1   page that is entitled "Complete Bill History" --
2       I interviewed many, many lobbyists or association               2      A. What page is that, sir?
3    leaders that were actively engaged on one side or the              3      Q. 851 in the lower right.
4    other;                                                             4      A. 851?
5       I interviewed Democrats;                                        5      Q. Now, the second entry from the top, under,
6       I interviewed Republicans;                                      6   "Bill History", is January 28th.
7       I interviewed some healthcare foundation people who             7      Is that the meeting that you're referring to?
8    were either intelligent observers of the process, or, in           8      A. Correct.
 9 some way, actively engaged themselves;                               9      Q. Before you talk about that meeting, the entry
10    I interviewed representatives of the Schwarzenegger              10   just below that is for January 24th, and, it says, "In
11 administration;                                                     11   Committee".
12    I interviewed some professors who were knowledgeable             12     Are you familiar with that Committee Meeting?
13 about the issue.                                                    13     A. Yes. I was there.
14    Q. And what about representatives of the business                14      Q. And what branch of the Legislature are we
15 community and organized labor?                                      15   talking about?
16    A. I meant including lobbying organizations.                     16      Which committee was it?
17     I interviewed representatives from organized labor.             17      A. That was the Senate -- the State Senate Health
18     Representatives from various different business                 18   Committee.
19 organizations -- and consumer groups. There are a number            19     Q. Okay, what happened on January 24th in the
20 of consumer groups that were actively involved in them,             20   State Senate Health Committee?
21 too.                                                                21      A. Well, that was the original hearing at which we
22     Q. This may be an unfair question for you, but, is              22   expected a vote to be taken on ABXI-I; and, the bill, to
23 there anyone in California who has studied the                      23   be clear, had been approved by the Assembly at the end of
24 legislative and political process regarding the recent              24   2007, so, this was the Committee and the Senate -- that
25 efforts to enact healthcare reform in as much depth as              25   was going to hear the bill. If they approved it, it

                                                                                                       6 (Pages 18 to 21)
                                                           Page 22                                                                  Page 24
 1   would go to the floor of the Senate for final passage.          1    hearing for the bill, and, it was not likely to get the
 2      So, in the Senate Health Committee, there was an             2    six votes. You couldn't be certain; but, as of the day
 3   11-hour hearing that day and they heard every -- many --        3    prior to that hearing, they needed seven Democratic --
 4   aspects of the bill. Witnesses from both sides came up,         4    six votes. The chairperson of the committee, Sheila
 5   gave their arguments pro and con, advocated for and             5    Kuehl, had already, clearly, said she wasn't supportive;
 6   against. And members of the committee asked questions,          6    so, that left six votes. They had to get them all.
 7   sometimes, expressed views, and, about midday through           7       And, the day before the hearing, an Assemblyman from
 8   that hearing, it was announced that the Committee would         8    this area had announced that he wasn't supportive and he
 9   not be voting that day, and, that they would have another       9    wasn't going to vote for it.
10 meeting a few days after it -- this hearing -- at which           10     So, it appeared, even as of the 24th, as of the time
11 they would actually vote. And it was made clear there             11 of this hearing, that, at most, there were five
12 would be no testimony that day other than to allow                12 Democratic votes for the bill -- and they needed six --
13 members to -- members of the Senate Committee to -- make          13 so, it looked uphill.
14 statements.                                                       14     Although, people thought maybe we can turn the
15     So, on the 24th of January, they had this 11-hour             15 Assemblyman from around here around or maybe -- maybe --
16 hearing. They went through the bill, everybody                    16 somehow or another get one of the Republicans; but, it
17 commented, said what they wanted to say, and then that            17 looked difficult at that point.
18 hearing ended with no vote.                                       18     Q. All right, so, they put it over, after 11
19    Q. Was that an unusual circumstance in a                       19 hours, to January 28th.
20 legislative committee that was scheduled to vote?                 20   What was the vote on January 28th?
21    A. What was unusual was the length of the hearing.             21     A. On January 28th, one member of the committee,
22 11 hours on one bill was absolutely extraordinary. But,           22 Mark Ridley Thomas of Los Angeles, voted for the bill.
23 usually, a committee will vote at the end of the                  23     As I recall, there were seven votes against it and
24 discussion of the bill. Occasionally, it will get                 24 three Democrats abstained.
25 postponed -- an author will ask for a postponement and            25     Q. In the legislative process, where does the bill

                                                           Page 23                                                                  Page 25
1    ask to bring it back.                                           1    go from that point with a failure in the Senate
2        In this case, it was the decision of the committee,         2    committee?
3    at the request, as I understand, of the Senate leader, to       3       A. Well, as was the case in this circumstance,
4    not vote that day; to come back and vote a few days             4    unless you're up against a legislative deadline, which
5    later.                                                          5    says your bill must be out of this committee by this
6       Q. How many votes were needed to pass that bill              6    date -- and that wasn't the case here -- the proponent of
7    out of committee?                                               7    the bill -- the author -- is usually given an opportunity
8        A. It's an 11-member committee. Six votes were              8    for what they call reconsideration; in other words, if he
9    needed -- six positive votes -- not a majority of those         9    requests it, he can bring the bill back.
10 voting -- six actual votes -- six people had to vote yes.         10      Speaker Nunez, the author of the bill, was asked, do
11    Q. Okay, and, were there six Democrats and five                11 you want reconsideration? And, seeing the writing on the
12 Republicans on the committee?                                     12 wall, he said no; so, it was, effectively, dead at that
13     A. No. There were seven Democrats and four                    13 point.
14 Republicans.                                                      14    Q. Are you familiar enough with the political
15     Q. Were any of the Republicans supporting ABXI-I?             15 process to know what Joint Legislative Rule 62A is?
16     A. No. There was some outside hope from some                  16      A. Not off the top of my head.
17 people they might get one Republican, but, it was,                17      Q. Okay, we'll leave that. It's addressed in the
18 generally, assumed none of the Republicans would support          18 Legislative History.
19 it.                                                               19      In the Legislative History package on the next page,
20     Q. From what went on that day, January 24, 2008,              20 page 852, there is a downloaded version of a San
21 were the watchers of the healthcare reform political              21 Francisco Chronicle article that was published on Speaker
22 process, such as yourself, able to determine whether the          22 Nunez's official website on or about January 30th.
23 six votes were there to pass that bill out of committee           23   Do you see that article?
24 in the hope that it would be adopted by the full Senate?          24      A. Yes.
25     A. I think most people thought it was a difficult             25      Q. What I would like you to pay attention to is

                                                                                                         7 (Pages 22 to 25)
                                                                Page 26                                                              Page 28
1    the first paragraph which begins with the words, "It's               1    for children's -- expansion of kids' coverage via a
2    over" and continues then with the next sentence:                     2    cigarette tax. That was considered for a little while
3       "The State Senate Health Committee's Decision Monday              3    and then dropped for timing factors and an inability to
4    to shoot down the Governor's painstakingly-prepared                  4    raise the money.
5    universal healthcare proposal is dooming any chance for              5       There was also thought given in the Legislature to
6    reform and not just for this deficit-ridden year.                    6    what elements of ABXI-I can be salvaged and approved by
7    Californians probably won't see another universal                    7    the Legislature that don't require any money -- which,
8    healthcare plan for years to come."                                  8    really, meant that don't require any coverage expansions,
9       Do you disagree with any of that first paragraph                  9    but, might have dealt with things like prevention
10 that the Speaker posted on his official Assembly                       10 programs or electronic medical records or other reforms
11 Speaker's website following that Senate Committee defeat?              11 of that nature -- but, nothing that would have,
12      A. Well, if I were to have written it, I would                    12 significantly, expanded the number of people with
13 have been more definitive.                                             13 insurance. That was dead.
14    In the first sentence I wouldn't have said, it looks                14     Q. And were any of those non-money issues being
15 all but dead; it was dead -- at least for that year.                   15 discussed in terms of an initiative measure?
16      And the last sentence probably won't see another                  16     A. No. The time had just about, literally, run
17 universal health reform for years to come I personally                 17 out; indeed, most of the proponents of the legislation
18 would like to hope to see one in a year or two.                        18 realized that, if they didn't get Senate approval,
19   Q. But, what, realistically, is the next                             19 immediately, in that January hearing, and then by the
20 opportunity?                                                           20 full Senate, immediately, afterwards, the clock on the
21      A. Well, the next opportunity, realistically, is                  21 initiative process would run out. There's a certain
22 probably that California gets some form of universal                   22 amount of time you have and it was getting very short
23 healthcare through national legislation with a new                     23 already.
24 president next year; that's probably what's most                       24    Q. Could you explain that -- in brief terms
25 realistic.                                                             25 that -- clock and why that was the view held by the

                                                                Page 27                                                              Page 29
1        Or, conceivably -- I think it's highly unlikely,                  1   participants?
2    but, it's conceivable -- Democrats could come back with               2       A. You're going to tax me on making it brief,
3    another proposal next year, 2009, after the elections in              3   but -- because the clock works backwards from the
4    November. I think that's highly unlikely, given what                  4   election date on which you want the initiative to appear;
5    happened over the last period of time.                                5   so, they were thinking about November 2008, this coming
6        I mean, there will always be proposals for universal              6   election.
7    coverage in the Legislature. Someone will put it in.                  7       In order to get a measure on the November 8th(sic)
8    They'll fight for it; but, with no apparent willingness,              8   ballot measure, you have to go backwards from that time
9    with so much difficulty on the money side, now, and no                9   to allow the Secretary of State to:
10 Republican willingness to support it, everybody will know              10       Get all the ballot pamphlet materials together;
11 the purpose of it is to keep the issue alive rather to,                11       Get all the pro-con materials together;
12 realistically, have a chance of passing it.                            12       Get them published in the State pamphlet;
13    Q. So, you have expressed a fairly strong opinion                   13       Get all that mailed to the California voters.
14 that it was dead as of January 28th in connection with                 14      So, that means the Secretary of State has to approve
15 that Senate Committee defeat.                                          15   the measure by a certain date in order. In order for the
16    Among the participants that you've interviewed for                  16   Secretary of State to approve the measure by a certain
17 purposes of your articles, was it -- was there consensus               17   date, you have to go back and forth to say, when does --
18 about that?                                                            18   in this case -- she -- have to actually validate the
19     A. Yes.                                                            19   signatures -- or get the signatures?
20     Q. Was there anyone who expressed a different view                 20       And, working back from that, the Secretary of
21 that, for example, following January 28, 2008, there was               21   State's website would say that the final date for turning
22 still hope?                                                            22   in signatures would have been April 21 of 2008. We were
23     A. To be clear, there were some advocates for                      23   already at January 28, 2008, and, it hadn't yet passed
24 children -- children's initiative -- that, after January               24   the Senate.
25 28th, contemplated trying to get together an initiative                25       So, let's assume they could have passed it then and,

                                                                                                          8 (Pages 26 to 29)
                                                              Page 30                                                                 Page 32
1    maybe, passed it in the Senate in early February. They             1    the death of the ABXI-I in the Senate, would it have been
2    would have had less than three months to collect and turn          2    possible to draft, obtain approval, qualify, an
3    in the signatures; and the normal time is 150 days. And,           3    initiative for the November ballot?
4    the shorter the time gets, the harder it gets, and the             4        A. Theoretically, it could be done; practically, I
5    more expensive it gets.                                            5    don't think anybody contemplates trying to write, get
6       Q. Well, but, it died in the Senate?                            6    approval of an initiative, and, get that many signatures
7       A. Yes.                                                         7    in two months. It would have been extraordinarily
8       Q. So, let's say that hope springs eternal and                  8    difficult.
9    some of the participants decided, we could put together a          9        Q. Some people are idealistic.
10 package to take to the voters and, completely, bypass the            10       Was anyone you interviewed in any constituency
11 Legislature; and, we'll include financing and all the                11 discussing such a plan?
12 reform elements we need.                                             12       A. I mentioned that some were discussing a much
13    What would they have had to do beyond what you've                 13 more limited proposal to expand coverage for children. I
14 already described in the time clock?                                 14 believe they already had an initiative; and they might
15      A. They would have had to go to the Attorney                    15 have been able to move a little more quickly.
16 General with their initiative and get what's called a                16    But, no one was discussing, to the best of my
17 Title and Summary; and, as I recall, that takes, usually,            17 knowledge -- and I spoke to everybody in every
18 at least 30 days, so, it would have been well into March             18 organization -- nobody was contemplating putting a
19 before that -- assuming they had it all written and ready            19 comprehensive coverage initiative on the ballot in 2008.
20 to go on February 1.                                                 20       Q. Did you attend a conference on February 6, 2008
21     They would have had to write an initiative;                      21 among the interest groups and participants who had been
22      Figure it all out;                                              22 active in trying to find a legislative compromise for
23      Give it to the Attorney General;                                23 universal healthcare in California?
24      That would have taken, maybe, 30 days or so.                    24    A. Yes. On February -- the evening of February
25      So, it would have been early March or so before                 25 6th and the conference was -- I'm sorry -- evening of

                                                              Page 31                                                                 Page 33
 1   anyone could have started to circulate petitions to get             1   February 6th and the conference on February 6th -- was an
 2   something on the November ballot.                                   2   organization named Insure the Uninsured Project, which is
 3      That would have left them, literally, about two                  3   a kind of foundation-funded organization aimed at
 4   months to collect the requisite number of signatures for            4   universal coverage. They held a conference on February
 5   putting a Constitutional amendment on the ballot.                   5   6th; and, they hold it annually and it draws all the
 6       I don't believe anyone's ever done it that quickly.             6   supporters of universal coverage and some others.
 7       Q. By the way, do you have personal experience                  7      Q. What was the subject under discussion at that
 8   with promoting initiative measures in California?                   8   conference on February 6, 2008?
 9      A. Yes, I do.                                                    9     A. Given the fact that the bill had died a week
10      Q. And what experience is that?                                 10 before, the subject of the conference was, essentially,
11       A. I was the -- and, when I -- well, actually,                 11 what had happened.
12   I've had several.                                                  12     Why did we fail? And what might be done in the
13       When I was head of Common Cause in California, we,             13 future to move the issue forward -- the issue being
14   actually, put on the ballot and promoted a measure that            14 universal coverage.
15   would have changed the way redistricting is done in                15    Q. And did you take the opportunity, at that
16   California. That was way back in 1982.                             16 conference, to interview the key participants in that
17      And, then, in 1986, when I was still at Common                  17 legislative process?
18   Cause, we led an effort and, successfully, qualified a             18    A. Yes. Given that everything was so fresh in
19   measure, and then tried to pass it, relating to campaign           19 everyone's minds, and I was still working on my research
20   finance reform and public financing of California                  20 on this, I took the opportunity with everybody in the
21   elections.                                                         21 same room, or, so many people in the same room, to talk
22       And I was the kind of Director of Common Cause and,            22 to probably 20 to 30 people, many of whom had been key
23   ultimately, the manager of the campaign for that                   23 participants, and asked them all the same question;
24   proposition which, as I recall, was Proposition 68.                24     Why do you think reform died?
25       Q. All right, so, as a practical matter, following             25     And they all answered -- gave me their different

                                                                                                          9 (Pages 30 to 33)
                                                           Page 34                                                            Page 36
1    answers.                                                        1    actually, took an oppose position.
2       Q. Whether in response to your questions or in               2       Q. You agree that healthcare issues is important;
3    connection with other discussions, that day, did you ever       3    correct?
4    hear anyone say, what do you mean died? There's still           4       A. Yes.
5    hope?                                                           5       Q. And you agree that public discussion of
6       A. No.                                                       6    healthcare issues is important?
7       Q. And were some of the participants                         7       A. Publishing discussion?
 8 representatives of the Governor's office?                         8       Q. Yes.
 9     A. I hesitate, because, everybody I spoke to, I               9       A. Yes.
10 told that I would not say names.                                  10   Q. And you agree that public discussion of
11    But, I think it's fair to say, at this conference,             11 healthcare reform is important; correct?
12 everyone who had been involved in the reform effort was           12   A. I'm having a little difficulty because of the
13 there; and, in one way or another, I talked to                    13 echoes in here.
14 representatives of all the participating groups.                  14    Q. Oh, sure. The acoustics are difficult.
15    MR. ROTHNER: I have no further questions.                      15    You agree that public discussion of healthcare
16    SECRETARY MARSHALL: All right.                                 16 reform is important?
17                                                                   17    A. Yes.
18               CROSS-EXAMINATION                                   18    Q. And public discussion of healthcare is
19      BY MR. CHATTERJEE:                                           19 important today?
20      Q. Thank you, Secretary Marshall.                            20    A. Yes.
21      Good morning, Dr. Zelman. My name is Raj                     21     Q. And it was important the day after ABXI-I
22 Chatterjee. I'm going to ask you a few questions.                 22 failed to pass; correct?
23   According to your C.V., you were the president and              23     A. It's always valuable.
24 CEO of the California Association of Health Plans from            24     Q. Mr. Zelman, on January 29, 2008, Governor
25 1998 to to 2002; is that correct?                                 25 Schwarzenegger gave a press conference with Speaker

                                                           Page 35                                                            Page 37
1       A. That's correct.                                           1    Nunez; is that correct?
2       Q. And, in fact, is it true that you were a                  2       A. As I recall, it was Senator Perata, but, it
3    lobbyist for the California Association of Health Plans?        3    could be.
4       A. I represented them. Technically, I was not a              4       Q. You're not sure?
5    registered lobbyist, because I did not directly lobby the       5       A. As I recall, it was Senator Perata who was
6    Legislature or go over the threshold which would require        6    doing that, but, it may have been -- that was probably
7    me to lobby.                                                    7    the 28th. The 29th, he may have given a press conference
8       So, no, I was not, technically, a lobbyist; but,             8    with Nunez. I don't recall.
 9 yes, I represented them.                                          9       Q. Can we provide the witness with a copy of UHW's
10    Q. And did you represent the interests of HMO's?               10 exhibits, please?
11     A. That's correct.                                            11      Mr. Zelman, could you take a look at the exhibits
12    Q. And is it true that the California Association              12 with the purple page on top? It's marked UHW's exhibits.
13 of Health Plans opposed healthcare reform legislation,            13 I believe it's to your right, sir.
14 both AB 8 and ABXI-I?                                             14    Sir, could you turn to Exhibit 40, please?
15    A. The California Association of Health Plans, of              15      A. 40?
16 which I was not leading, obviously, at the time of AB 8           16      Q. Yes.
17 and ABXI-I, as I recall, did not take an official                 17      Exhibit 40 is a printout from the Office of the
18 position on that legislation because it was split,                18 Governor that describes the Governor's remarks on
19 internally.                                                       19 Tuesday, January 29, 2008.
20     Some of the health plans, including Kaiser, Blue              20   Do you see that?
21 Shield, Healthnet, were supportive of the                         21      A. Yes.
22 Schwarzenegger-Nunez reform and worked, fairly, hard to           22      Q. And, in fact, it was a conference where
23 approve it. Blue Cross, especially, was opposed.                  23 Governor Schwarzenegger was joined by Speaker Nunez.
24     Most of the others didn't have a clear visible                24      Do you see that?
25 position, so, I don't believe that the Association,               25      A. That's what it says, yes.

                                                                                                    10 (Pages 34 to 37)
                                                       Page 38                                                            Page 40
1       Q. Do you have any reason to disagree with that?         1    to a particular proposal, that particular year. There
2       A. No.                                                   2    are always organizations fighting for this, and, there
3       Q. And, at the conference, Governor Schwarzenegger       3    are organizations fighting to defeat this, and, they go
4    stated about healthcare issues. "Everyone said they're      4    on.
5    going to continue working" --                               5          Q. If you could turn to page 3 of Exhibit 40, in
6       A. Excuse me. Excuse me.                                 6    the second to last paragraph, below, there's comments
7       Where were you reading, so I can follow you?             7    from a person named Dean Tipps.
 8      Q. It's on page 7 of Exhibit 40.                         8          Sir, do you know who Dean Tipps is?
 9      A. Page 7, yes.                                          9          A. Yes.
10      Q. The fourth paragraph, the last sentence,              10    Q. And he was a member of the State Council;
11 Governor Schwarzenegger stated:                               11 correct?
12    "Everyone said they're going to continue working           12    A. I don't know what his official title was. I
13 together on this. We're not going -- we're going to add       13 know he was a leader in the Sacramento office of SEIU.
14 to this coalition."                                           14    Q. And he stated -- and, did you interview Dean
15    Do you see that?                                           15 Tipps?
16     A. Yes.                                                   16     A. As I said, I prefer not to talk about,
17    Q. And that's what the Governor said about                 17 specifically, who I interviewed. If I say if -- I were
18 healthcare reform after the Senate failed to pass ABXI-I;     18 to say I didn't interview Dean Tipps, and I had obvious
19 correct?                                                      19 references in my paper to SEIU positions, some people
20     A. Yes.                                                   20 would have assumed, well, then, you must have interviewed
21     I'm not questioning that these are the words he           21 this person; so, I would prefer not to say who,
22 said, yes.                                                    22 specifically, I did or did not interview.
23    Q. And, on the first page of Exhibit 40, we can            23     Q. Let me make sure I understand.
24 see that Governor Schwarzenegger, on the fourth               24    You've testified, today, about conclusions you've
25 paragraph, stated:                                            25 drawn from people you've interviewed; correct?

                                                       Page 39                                                            Page 41
1       "Basically, as I have said, this is a bump in the         1         A. Yes.
2    road. This is not over for healthcare reform. We're          2         Q. And you say you've interviewed, basically, a
3    going to regroup again bring everyone togetherin the         3   lot of people in California; correct?
4    State Senate and the Assembly, all the State coalition,      4       A. Correct.
5    together, to get this done."                                 5      Q. But, you're not going to tell us anyone you
6       That's what the Governor said about healthcare            6   interviewed; correct?
7    reform after ABXI-I failed to pass the Senate; correct?      7       A. I told people, when I interviewed them, in
8       A. Yes, that's what this says.                            8   effect, interviewing them as a journalist, that I would
 9     Frankly, if I may, I don't think he was suggesting         9   not use what they said; or, I would not even say that I
10 we're going to bring back ABXI-I in its form and pass it      10   had talked to them, because, I wanted them to give me the
11 this year.                                                    11   best information they could give me -- and the most
12     He was talking about the general goal of healthcare       12   honest information they could give me -- and, since,
13 reform -- and that never dies -- so, he was implying          13   especially, I was looking at the politics of this rather
14 here, we're going to keep fighting.                           14   than just the technical policy pieces.
15     And I think all the proponents would agree; we're         15      Q. But, sir, aren't you using what they've told
16 going to keep fighting. I don't think he's referring          16   you in giving your testimony here, today, about
17 here to saying, we're going do get this done this year --     17   conclusions you've drawn based on that?
18 this initiative -- this bill -- anymore.                      18      Isn't that true?
19     Q. And, by saying, we're going to continue to             19      A. Yes.
20 fight, that means we're going to need public discussion       20      And, just as I have, you have to, in that sense,
21 about healthcare reform; isn't that correct?                  21   view me, in this case, though, as a reporter for a
22    A. Yes. He might be implying that we're going to           22   newspaper.
23 need -- we're going to keep trying. That was the              23      If you were asking me, did you talk to so-and-so,
24 conference on February 6th. He said, we're going to keep      24   and, so-and-so, and, so-and-so, the reporter would say,
25 trying into the future. I don't think he was tying that       25   no, I guaranteed anonymity.

                                                                                               11 (Pages 38 to 41)
                                                       Page 42                                                              Page 44
 1      I told people I wouldn't say who I talked to, so, I      1       Q. On page 3, where you referred to Mr. Dean
 2   can't tell you who, specifically, I talked to or didn't     2    Tipps' comments?
 3   talk to. To me, that would be -- to me, that would be       3       A. Yes.
 4   violating a confidence that I gave to people.               4       Q. The day after -- before I ask that -- again,
 5      So, there are, just for example, in the case of          5    who is Dean Tipps?
 6   SEIU, just so many people who you would think I might       6       A. As I mentioned, Dean Tipps is -- I don't know
 7   have talked to at SEIU who were critical to this process    7    what his official capacity is at SEIU. He's, generally,
 8   I was reviewing. If I told you I didn't talk to this one     8 viewed as the kind of one of the heads of the Sacramento
 9   or didn't talk to that one and, yet, it was clear that I     9 office of SEIU, a political -- I don't think he's a
10   had talked to people at SEIU and had their views, I would   10 registered lobbyist. I think he's more the kind of
11   be narrowing the field as to who I had talked to, and, in   11 political leader of the office.
12   that way, maybe giving that person away; and, I promised    12    Q. Sir, the day ABXI-I failed to pass the Senate,
13   not to do that.                                             13 Mr. Tipps stated:
14      Q. Did you talk to Beth Koppell?                         14    "Our union made healthcare reform its number one
15       A. The same answer. I know Beth Koppell very            15 priority this year and, actually, the year before..."and
16   well. I told whoever I talked to about this, I will not     16 said, "...this is our" -- I believe it's "...our goal.
17   say that I talked to you; so, if I would answer that        17 We will not stop until we achieve comprehensive
18   question, now, I would be violating that confidence.        18 healthcare reform. That is our position now. That is
19      MR. ROTHNER: Secretary Marshall, I have a                19 our position until we achieve comprehensive healthcare
20   suggestion, because we're spending an awful lot of time     20 reform."
21   on this and it's becoming --                                21    He said that; didn't he?
22       SECRETARY MARSHALL: Be quiet and let me hear what       22    A. I wasn't there. I trust that this is an
23   he has to say. Go ahead.                                    23 accurate reflection of what he said. I don't question
24      MR. ROTHNER: I don't think the witness has any           24 that.
25   objection to describing what the unidentified               25      Q. And that position from Mr. Tipps requires

                                                       Page 43                                                              Page 45
 1   representative or representatives of SEIU told him. I       1    public education and public discussion about healthcare
 2   think we can move on to that rather than spend so much      2    issues to push healthcare reform forward; correct?
 3   time on whether --                                          3       A. I would assume that, if an organization was
 4      SECRETARY MARSHALL: I think that's right. Go             4    pursuing healthcare reform, one of their goals might be
 5   ahead. Please, be quiet.                                    5    to educate their members and, ultimately, educate the
 6       MR. CHATTERJEE: Q. Sir, did you have a substantive      6    public.
 7   discussion with Beth Koppell, or anyone at SEIU, about      7       Q. Sir, it's true that, in February of 2008, nine
 8   your testimony here today?                                  8    separate healthcare bills were introduced or
 9       A. Did I have discussion with them about my             9    re-introduced in the Legislature.
10   testimony here today?                                       10    MR. ROTHNER: I'm sorry. I didn't hear the
11      Q. Yes.                                                  11 question.
12      A. No.                                                   12    SECRETARY MARSHALL: Repeat the question.
13      Q. Did you have a discussion with -- did you             13    MR. CHATTERJEE: Sure.
14   interview anyone at SEIU in terms of coming to the          14    Q. Isn't it true that, in February, 2008, nine
15   conclusion that you've testified about here today?          15 separate healthcare bills were introduced or
16      A. Again, sir, with all due respect, if I were to        16 re-introduced into the Legislature?
17   say that I talked to people at SEIU, specifically,          17     A. They were probably many more bills than nine in
18   everybody would know that I had talked to those             18 terms of health, in general. It's a huge piece of the
19   only-a-few people that could have been there.               19 California economy. There are always dozens of bills
20       And, soon, it would become clear who I may have         20 about health reform in every legislative session.
21   talked to, and that would, to me, be violating a            21    Q. And those healthcare bills require public
22   confidence that I gave to people to whom I talked.          22 discussion; right?
23      Q. Sir, if we could just turn back to Exhibit 40,        23    A. In some cases, organizations may not want
24   please?                                                     24 public discussion of them; in many cases, they do.
25       A. Yeah.                                                25    Q. After January 2008 SB981, the balancing bill,

                                                                                                12 (Pages 42 to 45)
                                                          Page 46                                                          Page 48
1    was moving forward in the Legislature; isn't that true?        1    there was an electricity deregulation measure on that
2       A. I'm not familiar with SB981. Unless you tell             2    ballot, yes.
3    me the subject matter -- maybe I would, but -- I don't         3       Q. Are you aware that the initiative was filed on
4    know the number.                                               4    March 17,2005 for November 2005 ballot?
5       Q. The subject matter was balanced billing?                 5       A. No.
6       A. Oh, balanced billing?                                    6       Q. Are you aware that, regarding Proposition 76,
7       Yes, there was legislation proposed on balanced             7    the paperwork to gather signatures was filed on
 8 billing.                                                         8    February 8, 2005 for a November ballot of 2005?
 9      Q. And that's related to healthcare; right, sir?            9       A. No.
10      A. That's what?                                             10     But, as I suggested, it's conceivable that one can
11      Q. Related to healthcare?                                   11 do it in a very short period -- in a period of time --
12      A. Yes.                                                     12 but, it gets very very difficult and very, very
13      Q. And, after January 2008, AB2967, regarding the           13 expensive.
14 transparency of cost quality, was a bill moving through          14     And that's filed in 2005? You mean filed with the
15 the Legislature; isn't that true?                                15 Attorney General?
16     A. I'm not sure whether that was a bill; but, I              16    Q. Correct.
17 have no reason to believe it wasn't. There are                   17    Are you aware that for Prop 89 regarding the Clean
18 frequently bills along these lines.                              18 Money and Fair Elections, the paperwork to gather
19    Q. And, after January 2008, SB1527, individual                19 signatures was filed with the Attorney General on
20 insurance reform, was moving through the Legislature?            20 February 7, 2006 for a November 2006 ballot?
21     A. Yes. There are always bills about individual              21    A. No.
22 insurance reform.                                                22    Q. Sir, we're going to mark a new exhibit that is
23    Q. And, after January 2008, SB14440, regarding                23 going to go at the end of your purple binder; and, if we
24 medical loss ratio, was moving through the Legislature?          24 can just get a number for that exhibit --
25      A. I believe that's true also.                              25    MR. ROTHNER: Before you examine the witness on the

                                                          Page 47                                                          Page 49
 1       Q. And all these bills concern healthcare issues?           1   exhibit, I'd appreciate a copy.
 2       A. Yes, they all concern healthcare issues.                 2      MR. CHATTERJEE: We'll get you a copy. I'm sorry.
 3       None of the ones you mentioned suggest universal            3       Sir, this will be UHW Exhibit 174.
 4   coverage or expansion of coverage. That was the essence         4       MR. DAYAN: 174? What's 173? We only have a 172.
 5   of ABXI-I and the Schwarzenegger proposal.                      5       MR. CHATTERJEE: I think we had 173 yesterday.
 6       These are all different pieces of healthcare                6       MR. DAYAN: Pardon?
 7   legislation. Most of these things come up, literally,           7       MR. CHATTERJEE: I think we marked 173 yesterday.
 8   every year, and they're debated every year on                   8       MR. DAYAN: The Trister article was 172.
 9   legislation, and laws are tweaked or rejected.                  9       MR. CHATTERJEE: Okay, then, this will be 174.
10       But, none of these involve the kinds of major              10       MR. DAYAN: Pardon?
11   expansions of healthcare coverage that were involved in        11       MR. CHATTERJEE: This will be 173.
12   AB 8 or ABXI-I.                                                12       MR. DAYAN: Okay. I just want a complete record.
13      Q. Sir, are you familiar with Prop 80?                      13             (UHW Exhibit No. 173 marked
14       A. Prop 8 on this year's ballot?                           14              for identification)
15       Q. 2005 ballot.                                            15      MR. CHATTERJEE: Q. Sir, before we get to Exhibit
16       A. 2005 ballot?                                            16   173, are you aware that, on or about April 30, 2008,
17       Q. Yes.                                                    17   Governor Schwarzenegger said, regarding healthcare
18       A. Which measure was that?                                 18   reform:
19       The numbers -- would you repeat the numbers? So            19       "Now, we'll try again. We will continue on keeping
20   often --                                                       20   the stakeholders together, fine tuning it, and see if we
21       Q. Regarding electricity deregulation.                     21   can improve on it since we have the time now than be back
22       A. Regarding what?                                         22   again. We feel confident."
23       Q. Electricity deregulation.                               23        MR. ROTHNER: Don't answer the question, please. I
24       Are you familiar with that bill?                           24   still don't have a copy.
25       A. I wasn't involved in that; but, I remember              25       SECRETARY MARSHALL: Let's hear what he has to say.

                                                                                                 13 (Pages 46 to 49)
                                                               Page 50                                                               Page 52
1           MR. ROTHNER: I still don't have a copy of the                1   question. There are always discussions about healthcare
2    exhibit.                                                            2   reform. It's, you know, the biggest piece of the
3           MR. CHATTERJEE: I'm not asking about the exhibit,            3   California economy, along with education. There are
4    sir.                                                                4   always people thinking about it on all sides.
5           MR. ROTHNER: I don't know that until I see a copy            5       MR. CHATTERJEE: Sir, thank you. I don't have any
6    of the exhibit.                                                     6   further questions at this time, subject to re-cross.
7           MR. CHATTERJEE: Just for the record, my last                 7       MR. ROTHNER: May we have a moment before we release
8    question doesn't pertain to Exhibit 173.                            8   the witness?
9           SECRETARY MARSHALL: What?                                    9       No further questions.
10          MR. CHATTERJEE: My question is not in connection             10      SECRETARY MARSHALL: All right. Thank you.
11 with Exhibit 173.                                                     11      MR. ROTHNER: That concludes our testimony on the
12          Q. Sir, my question to you is, are you aware that,           12 first two issues. We do want to have a discussion,
13 on or about April 30, 2008, Governor Schwarzenegger                   13 whenever, Secretary Marshall, it's appropriate, about the
14 stated:                                                               14 documentary evidence. We just want to make sure that
15          "Now, we'll try again. We will continue on keeping           15 that it is considered a part of the record.
16 the stakeholders together, fine tuning it, and seeing if              16     And we do have one other document --
17 we can improve on it, since we have the time now than be              17     MR. CHATTERJEE: We'll make it easy. We'll just
18 back again. We feel confident."                                       18 strike that for the record.
19   Are you aware of that?                                              19     SECRETARY MARSHALL: Is there an issue with the
20          A. I'm not aware of that particular statement on             20 documents?
21 that particular date; but, I know that he has made                    21     MR. ROTHNER: Well, we don't -- we had a preliminary
22 comments to that effect.                                              22 discussion about it and we agreed that in this
23          Q. He's made comments to that effect --                      23 proceeding, generally speaking, there would be no need to
24          A. Yes.                                                      24 establish the authenticity of every item.
25          Q. -- in the April 30th time frame. You agree                25     We do have a couple of specific objections to

                                                               Page 51                                                               Page 53
1    with that?                                                          1   exhibits they have offered. I don't know that we need to
2           A. I don't want to be pinned to a time frame at              2   take a lot of time discussing it, but, I just want to
3    this point. I know that he's made statements to that                3   make sure that at an appropriate time --
4    effect since the death of ABXI-I.                                   4       SECRETARY MARSHALL: Why don't I suggest this? Why
5           Q. I just want to be clear.                                  5   don't you all get together --
6           You're aware that the Governor has made statements           6       MR. HARRIS: I would suggest this, if I can down.
7    to that effect after ABXI-I --                                      7   It was announced at the beginning of the hearing the
8           A. Yes.                                                      8   rules of evidence don't apply. On that basis, we haven't
9           Q. -- failed to pass the Senate?                              9 been making objections -- you know, we haven't been
10          The answer is yes?                                           10 making challenge to reference to documents.
11          A. Yes.                                                      11    We provided binders of exhibits; they provided
12    Q. Are you also aware that, on or about April 4,                   12 binders of exhibits. Both sides are continuing to do so.
13 2008, Governor Schwarzenegger's spokesman, Sabrina                    13 I would think, Secretary Marshall, you would receive them
14 Lockhart, stated that:                                                14 all and whatever weight should be given to them depends
15     "The Governor hasn't given up on healthcare                       15 on, you know, what they are; and both sides can make
16 initiatives and he's continuing to meet with business                 16 arguments to you as to what weight or no weight each
17 groups, insurers, and healthcare providers to talk about              17 should be given.
18 what steps are needed to achieve that goal."                          18     SECRETARY MARSHALL: Yeah, I'm very comfortable with
19     A. Again, I'm not familiar with the particular                    19 that. And, if you have objections --
20 statement or the particular date; but, the Governor had               20     MR. ROTHNER: That's fine with us. That's fine with
21 expressed those kinds of views.                                       21 us.
22    Q. And those statements are consistent with your                   22     SECRETARY MARSHALL: I said, if you have objections,
23 understanding of the state of discussion as of --                     23 just give me a note about it, and I'll note it.
24 regarding healthcare issues as of -- April 4, 2008?                   24     MR. ROTHNER: Thank you.
25    A. I'm not sure I know how to answer that                          25     MR. HARRIS: We'd like to take a short break before

                                                                                                         14 (Pages 50 to 53)
                                                      Page 54                                                       Page 56
 1   we call our first witness.                                  1      Q. Hasn't changed?
 2      MR. DAYAN: We have one more document --                  2      A. No.
 3      MR. HARRIS: Five minutes.                                3     Q. Mr. Borsos, could you, briefly, give me your
 4      SECRETARY MARSHALL: Five minutes. We'll take a           4   educational background?
 5   five-minute break.                                          5      A. Yeah.
 6                  (Recess taken)                               6      I have a Bachelor of Arts in American History from
 7       SECRETARY MARSHALL: All right, the hearing will         7   Walsh College in Canton, Ohio;
 8   resume now.                                                 8       I have a Master's Degree in American History from
 9       MR. HARRIS: We call as our first witness,               9   the University of South Carolina;
10 Mr. Borsos; and, Mr. Chatterjee will examine him.            10      And I have a Ph.D. in American Labor History from
11     MR. ROTHNER: I'm sorry, Secretary Marshall. I            11   Indiana University in Bloomington.
12 mentioned that we had a couple more exhibits.                12      SECRETARY MARSHALL: If you keep that up, he's not
13      Do you want me to do that now or later?                 13   going to be able to speak very much.
14      SECRETARY MARSHALL: What is it?                         14      MR. CHATTERJEE: Q. What was your Ph.D. about?
15      MR. ROTHNER: A couple more exhibits.                    15      A. I wrote my disseration on the history of my
16     Would you like me to distribute them now or later?       16   hometown, which was a small industrial city outside of
17     SECRETARY MARSHALL: Go ahead. While that's going         17   Cleveland, next to Akron, Ohio, focusing on the emerging
18 on, we have a couple of administrative announcements we'd    18   industrial unions in the 1930's through the
19 like to make.                                                19   de-industrialization of the 1980's.
20               (Off the record)                               20      Q. After you finished your Ph.D., did you join the
21     SECRETARY MARSHALL: All right. Mr. Harris --             21   labor movement?
22     MR. ROTHNER: So, just for identification, the            22      A. Yeah, I taught for a while, and, had the
23 exhibit which consists of the resume of Arthur Fox,          23   opportunity to begin working with SEIU in Pennsylvania.
24 published on his firm's website, would be Exhibit 74.        24   You know, that was a time when it was hard to get jobs in
25    And the next exhibit, which is about the Association      25   the labor movement; and, at the time, that one was

                                                      Page 55                                                       Page 57
1    for Union Democracy on whose Board Arthur Fox serves,       1   available. I took advantage of that and began working
2    would be Exhibit 75; and the members of the Board are       2   for SEIU, what was then 1199-P in Pennsylvania.
3    referred to on the second page.                             3       Q. And when was that?
4       SECRETARY MARSHALL: All right. They have been            4       A. 1993.
5    marked.                                                     5      Q. And, at some point, did you join Local 250?
6       Can you hear me in the back? All right, everybody        6      A. Yeah. I started with local -- what was then
7    speak up, then, so the people in the back can hear.         7   Local 250 -- on January the 15th, 1996.
8       MR. CHATTERJEE: Q. Good morning, Mr. Borsos.             8      I had met Sal and other leaders from Local 250 at
 9      Could you, please, state your name, for the record?      9   SEIU meetings and came out to California in 1996.
10      A. John Borsos.                                         10      Q. And are you still working for UHW?
11      Q. Mr. Borsos --                                        11      A. Yes, I am.
12     SECRETARY MARSHALL: Wait a minute. We didn't swear       12      Q. And what's your position?
13 the witness.                                                 13       A. I'm Administrative Vice President, which is an
14                                                              14   elected office; and I also direct the union's hospital
15                  JOHN BORSOS,                                15   division.
16          called as a witness on behalf of                    16      Q. I should ask you:
17             United Healthcare Workers-West,                  17      What drew you to the labor movement?
18             having been placed under oath,                   18      A. I grew up in a strong labor household;
19                testified as follows:                         19     My father was the treasurer of his United Rubber
20                                                              20   Workers local;
21                 DIRECT EXAMINATION                           21     My mother was active in forming a clerical union
22      BY MR. CHATTERJEE:                                      22   with United Rubber workers in the 1940's;
23    Q. Okay. Now, could you please state your name            23      And was active in the AFSCME.
24 for the record?                                              24       I actually have an uncle who was a Flint Sitdown
25     A. Yes. It's still John Borsos.                          25   Striker.

                                                                                           15 (Pages 54 to 57)
                                                          Page 58                                                              Page 60
1       So, the labor movement is really part of what I grew        1       A. Yeah.
2    up with.                                                       2       I've written articles on the labor movement,
3       Q. What are your duties as Administrative Vice              3    generally, and, you know, publications like "The Nation"
4    President and a Director of Hospital Division for UHW?         4    and book reviews articles.
5       A. I oversee the collective bargaining and                  5       So, yeah, again, it's a question of time; but, I
6    representational work;                                         6    continue to actively participate.
7       Do some work on the organizing side;                        7       Q. Generally, what are your duties as a member of
8       A lot of negotiations with the hospitals that UHW            8 the UHW Executive Board?
9    represents.                                                     9     A. Well, the Executive Board is the governing body
10     There's about 42,000 members in the hospital                 10 of the local union; and, as I said, I'm one of 90 members
11 division. We have about somewhere between 75 to 80               11 of the Executive Board.
12 contracts, and we have a staff of about 65, and, it's            12     Q. How many members are on the Executive Board?
13 my -- I supervise the division.                                  13     A. About 90; about 75 of which are rank-and-file
14     Q. And what do your responsibilities for                     14 members of the union.
15 collective bargaining entail?                                    15     And there's a three administrative officers:
16     A. In some cases, directly, it's leading the                 16     The president, Sal Rosselli;
17 negotiations; in other cases, it's supervising the staff         17      The Executive Vice-President, Jorge Rodriguez;
18 as they go through negotiations.                                 18      The Secretary-Treasurer, Joan Emslie;
19      It could be as mundane as approving arbitrations;           19    And there's about 12 or so Administrative Vice
20      Day-to-day advice with other staff who supervise            20 President's, of which I'm one.
21 staff;                                                           21    Q. For the record, what do you mean by
22      Day-to-day relations with employers.                        22 rank-and-file member of the union?
23      I could, on any given day, be dealing with elected          23    A. It means like the folks who are sitting in the
24 officials, community partners, other union leaders;              24 audience. They're the UHW members whose job is, as a
25      Quite a variety.                                            25 healthcare worker, not employed by the union; and, the

                                                          Page 59                                                              Page 61
1       Q. As an Administrative Vice President, were you            1    Executive Board is a voluntary position that they've been
2    elected or appointed?                                          2    elected to.
3       A. I'm an elected officer.                                  3       Q. Does UHW have a particular focus?
4       Q. Elected by whom?                                         4        A. Yeah.
5       A. By the members.                                          5        We are an exclusively healthcare union. We're
6       Q. Do you serve on the Executive Board for UHW?             6    the -- our origins go back to the 1930's. Local 250 was
7       A. Yeah. By virtue of being an elected officer,             7    the oldest healthcare workers' union in the country,
8    I'm one of about -- I think it's close to -- 90 people         8    formed out of the San Francisco General strike;
 9 who are on UHW's Executive Board.                                 9     And Local 399 was a prominent healthcare workers'
10   Q. Do you hold any other positions in the labor                10 union from Los Angeles, starting in the 1940's;
11 movement?                                                        11     And the two Locals merged in 2004-2005 to become
12      A. Yeah.                                                    12 UHW.
13      I'm the president of Sacramento Central Labor               13    Q. How big is UHW right now?
14 Council;                                                         14     A. We represent 150,000 healthcare workers across
15     And, I'm also the treasurer of the SEIU                      15 the State of California.
16 International's strike fund.                                     16     SECRETARY MARSHALL: You're cutting into his time.
17   Q. Do you continue to teach about the labor                    17 You're not helping him at all. You're cutting into his
18 movement?                                                        18 time. So, I know you want to demonstrate your approval
19   A. Yeah.                                                       19 of what he's saying, but, please, be quiet, and let him
20     Periodically, I have taught classes at the City              20 say it. You know what he's going to say, probably. I
21 College of San Francisco.                                        21 don't; and, I need to hear it. So, don't make me have to
22     Really, it's been harder to do because of time; but,         22 come down there. Please, be quiet. Go ahead.
23 I have done it, periodically, since I've come to                 23     MR. CHATTERJEE: Thank you.
24 California.                                                      24    Q. Sir, how large is UHW compared to other Locals
25     Q. Do you also publish?                                      25 of SEIU?

                                                                                                   16 (Pages 58 to 61)
                                                             Page 62                                                               Page 64
1       A. We're the second largest SEIU in the country.               1    that's what members voted on when the approval of the
2       Q. You referred to it, but, could you describe, in             2    merger was voted upon.
3    a little more detail, how UHW came to be formed by the            3        Q. I think we heard some testimony, otherwise,
4    merger of Local 250 and 399?                                      4    yesterday, so, I want to be absolutely clear.
5       A. Yeah.                                                       5        Was Sal Rosselli elected by the members to be
6       In 2004, the Executive Boards of Local 250 and Local           6    president of UHW?
7    399, independently, voted to pursue a merger. We held             7        A. Yeah, it's part of what people voted on. When
8    hundreds of meetings across the state to talk about what           8 the election happened -- again -- it's right here -- what
9    a merger would look like. We had a number of meetings to           9 you have in the bylaws -- in the -- what you have in the
10 come together to create a new Constitution and bylaws.              10 binder is the document that people voted on.
11    And, as I recall, it was the fall of 2004, we had a              11    Q. Did the merger of Local 250 and 399 make sense?
12 vote to merge the two local unions, as well as to elect             12     A. Yeah.
13 the officers during that vote.                                      13     As you asked, earlier, UHW is an exclusively
14      Q. So, when Local 250 and 399 were merged, how was             14 healthcare union. Local 250 and Local 399 shared a
15 the person who was to be president of UHW determined?               15 number of common employers, like the Daughters of Charity
16    A. It was -- there was a discussion among both                   16 and Catholic Healthcare West and Kaiser. There were
17 Executive Boards -- there was a recommendation made by              17 places where we were at the bargaining table with the
18 both Executive Boards, and, that was put before both                18 same employer at the same time, and, it certainly made
19 local unions, when the vote happened.                               19 sense to have workers represented by the same union at
20      Also, each local union had to vote to approve the              20 the same bargaining table.
21 merger. Local 250 members voted to approve the merger,              21     We had also gone through a long history of working
22 and Local 399 members voted to approve the merger. The              22 together around organizing campaigns and political work;
23 numbers were somewhere in the high 90's of both                     23     Had the same agenda;
24 organizations.                                                      24     We represented the same kind of workers;
25    If one local had voted against the merger, the                   25       We really had the same leadership philosophy;

                                                             Page 63                                                               Page 65
 1   merger would not have gone through; and, both locals, at          1        It made sense to have the two organizations come
 2   the time, and the members, overwhelmingly, supported the          2    together;
 3   merger.                                                           3        And we did.
 4     Q. Was a president elected?                                     4       Q. What is UHW's annual budget?
 5      A. Yes.                                                        5        A. Our annual revenues are about $80 or $81
 6     Q. Let me refer you to Exhibit 2 in UHW's                       6    million --
 7   exhibits.                                                         7        MR. ROTHNER: I'm sorry? I didn't hear the answer.
 8      A. This is the purple binder?                                  8        THE WITNESS: $80 to $81 million.
 9       Q. It's the purple binder.                                    9        MR. ROTHNER: I didn't hear the first part.
10       A. Yeah.                                                      10       THE WITNESS: Repeat the question.
11      This is the Constitution and bylaws, the unification           11                     (Record read)
12   agreement. It's what people were voting on when they              12       MR. CHATTERJEE: Let's be clear, for the record, Dr.
13   voted for the merger.                                             13 Borsos.
14       And, if you look at -- one looks at -- the pages              14      Q. Do you know what UHW's annual budget is?
15   aren't marked, but, it's the last page in the document on         15       A. We have a budget of about -- well, we take in
16   the inside -- the Local Executive Officers -- it said:            16 $81 million and we spend $81 million, so, budget revenue,
17     Sal Rosselli shall be the president -- and the                  17 from my perspective, it's more or less the same thing.
18   members of the Executive Board of SEIU;                           18     I'm not an accountant and so there may be some
19     Jorge Rodriguez, shall be the second officer of the             19 difference that you're -- distinction that you're --
20   Local;                                                            20 making that I quite don't understand; so, I apologize.
21      And then it talks about Steve Matthews and Vicki               21   Q. Approximately how many contracts does UHW have?
22   Karbalos (sic);                                                   22       A. We have about 200 collective bargaining
23      Joan Emslie shall be the Executive Treasurer of the            23 agreements.
24   Executive Board.                                                  24      Q. Is that a lot.
25       So, it spells out, right in the document -- and               25       A. Yeah.

                                                                                                        17 (Pages 62 to 65)
                                                        Page 66                                                               Page 68
1       The collective bargaining agreements range from the       1       What we've done, over, really, the last 20 years or
2    Kaiser contracts, which UHW has 45,000 members -- part of    2    so, is to develop a set of standards that it's -- we try
3    about a 92,000 person contract -- I believe it's the         3    to hold every employer accountable to the same standards.
4    second largest private sector contract in the country --     4       So, it begins with wage scales for employees;
5    to -- we have some contracts that are as small as two or     5       Fully employer paid health insurance for employees,
6    three visiting nurse; and, Hospice, in Santa Cruz, I         6    spouses, dependents;
7    know, we have a two-person contract.                         7       Defined benefit pension plan;
8       So, we have all kinds of ranges of contracts from          8     Retiree health;
9    Master Agreements, like we have with Kaiser, that covers      9     A real voice in staffing, which has meant we have
10 45,000 of our members at, probably, 45 or 50 different         10 the ability to sit dune with the employers and jointly
11 work sites, to these very tiny contracts, and all ranges       11 determine what staffing levels are;
12 in between.                                                    12     If we can't reach agreements, we sit those guys
13   Q. Now, in all your years in the labor movement,             13 down, either at arbitration or have the right to strike
14 have you talked to presidents of other Locals at SEIU?         14 over them;
15    A. Yes.                                                     15     Successorship language that, if facilities get sold,
16    Q. And you've talked to other members --                    16 the contract goes with the successor;
17 rank-and-file members -- in other unions?                      17     Bans on subcontracting employment and income
18    A. Yes.                                                     18 security;
19    Q. And you've talked to other leaders in the labor          19     Again, the highlight is, really, the Kaiser
20 movement; is that fair?                                        20 contract, where our Kaiser contract prohibits lay-offs
21    A. Yes.                                                     21 during the term of the contract.
22    Q. Are you familiar with UHW's reputation in the            22    Q. What are some of the particular contract
23 labor movement?                                                23 standards that UHW has won for its workers that you are
24     A. I would say that UHW, proudly, has a reputation         24 proud of?
25 of being a militant, democratic, progressive union.            25      A. That I'm, personally, proud?

                                                        Page 67                                                               Page 69
 1      Q. How about UHW's reputation in establishing             1       Q. Yes.
 2   contract standards for its members?                          2       A. Yeah.
 3      A. Yeah, the -- particularly, the -- Kaiser               3       You know, first, the no-layoff language that we've
 4   contract, which is the gold standard for healthcare          4    been able to achieve at Kaiser is extraordinary. You
 5   contracts in the country. We have a recognized               5    know, if you're hired in a Kaiser tomorrow, you'd have a
 6   reputation of fighting very hard for contract standards      6    job at Kaiser for the duration of the contract and
 7   at the bargaining table, from the Kaiser contract through    7    beyond, which is unprecedented in healthcare.
 8   the Catholic Healthcare West contract, the acute care        8       Local 250 was the first union in the country to win
 9 hospital industry -- even, most recently, the settlement        9 a defined benefit pension plan. Local 250 was the -- and
10 that we reached with Mariner, about a month ago, which we      10 399 were the -- first unions in the country to win fully
11 believe is the best nursing home contracts that exist in       11 employer paid health insurance.
12 the entire country. We have a longstanding reputation of       12     It was in 2000, first, that I know of, in the
13 fighting for standards at the bargaining table.                13 country, that we were able to -- in what we call a full
14     Q. For the record, what do you mean by contract            14 voice in staffing -- that allows us to, again, jointly
15 standards?                                                     15 determine staffing levels in hospitals.
16     A. Well, we try to take wages and benefits out of          16     And, since, at least, the mid 90's, we began to
17 competition. What we really want employers to compete on       17 bargain in our contracts the ability to organize
18 is who provides the highest quality care; not who can          18 unorganized workers in hospital systems -- and now
19 provide services at the lowest cost.                           19 nursing homes -- without employer interference, so that
20     Healthcare is a labor-intensive industry. The              20 workers have a right to join a union without employer
21 primary costs in healthcare -- 50 to 60 percent of             21 interference.
22 primary costs are labor costs.                                 22     So, those are the ones that I'm proudest of.
23     So, there's a drive among employers to try to drive        23     Q. How has it been that UHW has affected the lives
24 down the contract standards, because it's such an              24 of its members?
25 enormous part of their costs.                                  25     MR. ROTHNER: Mr. Hearing Officer, we have no

                                                                                                  18 (Pages 66 to 69)
                                                        Page 70                                                       Page 72
 1   problem with a little bit more of this, but, there's no    1   At the time, we thought it was a huge undertaking. We
 2   dispute that UHW is effective at bargaining contracts.     2   had 12 hospital contracts expiring at one time. We
 3   That's not what the case is about.                         3   settled those contracts in 1996 for a four-year
 4       MR. CHATTERJEE: Secretary Marshall, if I may           4   contract -- or -- 2000.
 5   respond.                                                   5      In between that time, a number of workers, including
 6       Number one, we're trying to put on our case -- and     6   many folks in this room, worked without contracts, so
 7   we didn't interrupt their case.                            7   that our contracts could line up in 2000.
 8       Number two, they're trying to impose a trusteeship     8      We did the same thing in 2004;
 9   and it's going to affect the lives of these members.       9      We did the same thing in 2008;
10       We want you to know -- we want you to know --         10       So, that, by the time 2008 rolled around, we were at
11       SECRETARY MARSHALL: I'm willing to make you a deal. 11     the bargaining table for 75,000 healthcare workers at a
12   You help me keep the audience quiet, and, you go ahead    12   number of -- close to -- 200 different facilities,
13   and make your case. Go ahead.                             13   covering about 75 different contracts.
14       MR. CHATTERJEE: We're trying.                         14      And the advantage for us doing that -- it's an
15       Can you read back the last question, please?          15   incredibly challenging thing to pull off by being at so
16                   (Record read)                             16   many different bargaining tables, but -- allows us to
17       MR. BORSOS: So, the question was, how has UHW         17   bargain with the industry as an industry.
18   affected the lives of its members?                        18      And it's -- what we're trying to do is replicate
19       It's been pretty dramatic. The most powerful          19   pattern bargaining that you saw emerge in the 1930's and
20   example I can think of is the CHW situation, that I was   20   1940's in the steel and auto. We're trying to do that in
21   directly involved in, where, six or seven years ago, most 21   healthcare.
22   of CHW was completely non-union.                          22       So, our strategy is to take the best contract --
23       There were not wage scales;                           23   or -- the first contract -- set a pattern;
24       The hospitals did not have defined benefit pension    24     After we've set the pattern, we then hold the other
25   plans;                                                    25   employers to that same pattern;

                                                        Page 71                                                       Page 73
 1       There was absolutely no ability for healthcare        1       If they're not willing to agree to the pattern that
 2   workers to have any discussion with their employer about  2    we set, we then, usually, engage in, you know, fairly
 3   how staffing was delivered.                               3    significant strike activity.
 4      We fought for an organizing rights agreement out of    4        To be able to drive those kind of standards and the
 5   the West Bay -- contract workers in the West Bay struck   5    way that we develop these proposals is, we hold meetings,
 6   multiple times to win organizing rights outside of the    6    like this, where the leaders of work sites come together
 7   West Bay.                                                 7    and identify what the major proposals are going to be at
 8      We then, in the space of about 12 months, organized    8    the bargaining table.
 9   28 CHW hospitals. We sat down with CHW -- this is         9       We then go back into the facilities to develop those
10   Catholic Healthcare West -- at a single table. We were   10    proposals, to create the support for the proposals at the
11   able to win, in the first contract:                      11    bargaining table, which is then what people fight over.
12      Fully employer paid health insurance;                 12       Q. This synchronizing contracts to all terminate
13      Wage scales;                                          13    at the same time strategy, that you've describing, is
14      Defined benefit pension plan;                         14    2008 a particularly important year for that strategy?
15      The right to arbitrate over staffing;                 15       A. Yeah.
16      A ban on subcontracting;                              16       2008 is something that some of us have been working
17      All the standards that we talked about recently.      17    15 years, or longer, to get to this place.
18      MR. CHATTERJEE: Q. How was it that UHW has been 18              What I described in 1996 and 2002, 2004 was,
19   able to obtain such good contracts?                      19    primarily, in the acute care hospital side of the union.
20      A. We have, really, since the mid 1990's,             20        What we did in 2008 is, we got the nursing home
21   developed an increasingly larger coordinated contract    21    contracts to line up as well; so, when I describe being
22   campaign strategy.                                       22    at the bargaining table for 75,000 of our members, which
23      In 1996, when I started with what was then-Local      23    is about half of our union -- and it's almost all of the
24   250, we had lined up most of our contracts on the East   24    acute care and convalescent side of our union -- we saw
25   and West Bay in the Bay Area to expire at the same time. 25    2008 as a way to drive long-term care standards in the

                                                                                            19 (Pages 70 to 73)
                                                           Page 74                                                                  Page 76
 1   same way that we drove acute care standards.                    1    contracts terminating in 2008, and health care reform --
 2      As I said, there are folks in this room who worked           2    issues of the Legislature -- being a time right to foster
 3   two years or more without a contract to get these               3    public discussion and education and information about
 4   contracts lined up. We knew that 2008 was going to be a         4    healthcare and healthcare-related issues?
 5   critical year. It's a presidential election year; that's        5        A. Yeah, it was designed this way.
 6   why you'll notice that the years are 2004, 2000, 1996.          6       Q. Are you familiar with the United Healthcare
 7   We lined up our contracts to coincide with presidential         7    Workers Patients Education Fund?
 8   election years.                                                  8       A. Yes.
 9       As we heard the testimony, earlier, about healthcare         9      Q. What is it?
10   reform, we knew 2007, 2008 was going to be the year of          10       A. It is a -- it was a 501(c)(3) that United --
11   healthcare reform; and, as healthcare workers, we think         11 UHW -- Executive Board created in May of 2007.
12   that we have something to say about the healthcare              12   Q. What was it created in anticipation of?
13   crisis.                                                         13   A. 2008, as I just described it, all these, from
14       Q. Why was it important to line up the contract             14 our perspective, the stars were all lined up:
15   terminations with the presidential election year?               15    Presidential politics;
16      A. The contract campaigns, as we conduct them, are           16    All these contracts expiring the year of healthcare
17   more than the simple day-to-day back-and-forth of               17 reform;
18   collective bargaining.                                          18     We had -- and still have -- a legislative -- in
19       The way that we see contract campaigns, it's a way          19 fact, we just found out, today, that the Governor vetoed
20   to educate the broader community of what's going on in          20 our safe staffing bill -- we had a Legislative program --
21   hospitals and nursing homes.                                    21 what we're fighting for as part of this contract
22       So, if it's an election year, there's a number of           22 campaign -- and we saw the Patients Education Fund as
23   issues that are prominent. We knew, 2008, healthcare was        23 another tool -- another avenue -- to be able to highlight
24   going to be a prominent issue; so, there's a dove-tailing       24 these issues.
25   of the issues at the bargaining table with the issues           25      Q. What was the purpose of the "Fund"?

                                                           Page 75                                                                  Page 77
1    that are important to the public -- which are issues that       1       A. The "Fund" was to educate healthcare workers,
2    are important to the political process.                         2    patients, and the broader community, about issues that
3       And, like, we had a lock out on a number of -- we            3    were important to healthcare workers, including union
4    had a nursing home, two days ago, that went on strike and       4    democracy.
5    was locked out. Well, I don't know if folks noticed in          5       Q. Why was the fund created as a 501(c)(3)?
6    their hotel, there was newspaper reports on workers being       6       A. A 501(c)(3)?
7    on strike. What people were talking about was patient           7       Q. (c)(3)?
8    care and the healthcare crisis.                                 8       A. As I understand it, that, a 501(c)(3) allows a
9       Healthcare workers engaged in a struggle to win              9    union to -- it allows for activities that are different
10 advances at the bargaining table provide the perfect              10 than what a union can do.
11 opportunity to talk to issues about the healthcare                11      For example, we can raise money from foundations;
12 crisis.                                                           12      You can raise money from other partners or allies;
13     Most of the employers that we're dealing with are             13      You can do -- so, there's ways to be able to raise
14 multi-billion dollar corporations.                                14 money from foundations.
15    And we are, then, presented an opportunity to talk             15      There are state and federal government agencies that
16 about charity care practices;                                     16 can only contribute to 501(c)(3)'s; so, it opens up
17    The way that healthcare is delivered in hospitals;             17 another source of revenue.
18    To talk about healthcare financing;                            18      We also saw it as a way to, potentially, broaden
19    The crisis on the uninsured.                                   19 out, depending on how things progressed, to other
20    The fact that it coincides with a contract campaign            20 coalition partners who we might then be able to bring in
21 is something purposeful that -- we've designed it to be           21 and back part of the 501(c)(3); that we couldn't as a --
22 able to have healthcare workers, really, be the voice of          22 we couldn't under the function of a labor organization.
23 delivering high quality care in this country.                     23    Q. I want to take you to May 18 and May 19, 2007.
24     Q. So, you saw a confluence of these factors --               24      Did you attend an Executive Board meeting for UHW at
25 the presidential election, the contract campaign with the         25 that time?

                                                                                                      20 (Pages 74 to 77)
                                                          Page 78                                                               Page 80
1       A. Yes, I did.                                              1    fear in May of 2007 that we were going to be put into
2       Q. And, at that Executive Board meeting, was there          2    trusteeship.
3    a discussion about the Patients Education Fund?                3       Q. Was there a Board created, separately, for the
4       A. Yes, there was.                                          4    Patients Education Fund?
5       Q. What was the discussion about?                           5       A. There was.
6       A. It was a lot of what I described earlier;                6       Q. How was that Board created?
7       About how all these things in 2008 were going to            7       A. Well, as I recall it, Sal said -- Sal lead the
8    come together;                                                  8 discussion on this. There was a vote to create the
9       And we wanted to have an ability to educate the              9 Board, and then volunteers were asked, does anyone want
10 general public about these issues;                               10 to be on the Board? And several people raised their
11    And we had a discussion about it;                             11 hands and they became members of the Board. And anybody
12    And we, as I recall, voted to -- I don't know if              12 who raised their hand and said, yes, I want to be on the
13 there's --                                                       13 Board was placed on the Board.
14    Q. If you could turn to Exhibit 14, please.                   14    Q. So, the rank-and-file members of the Executive
15    A. Yeah, it's on the third page.                              15 Board were invited to serve on the Patients Education
16     We voted to approve up to $6 million -- up to -- to          16 Fund Board?
17 a newly created non-profit, United Healthcare Workers            17    A. It's entirely voluntary, whether they wanted to
18 Patients Education Fund "....for the purpose of educating        18 be on the Board, but -- yes.
19 Californians about healthcare reform initiatives and             19    Q. And, as you recall, any member of the Executive
20 related issues of concern..." as well as other issues of         20 Board who raised their hand had the opportunity to serve
21 importance to healthcare workers and their patients.             21 on the Patients Education Fund Board?
22    Q. And was the entire Executive Board, at least,              22      A. Correct.
23 invited to be there at that time?                                23      Q. Why was the Fund created in 2007?
24     A. Yeah -- well, the list of attendees is on the             24      A. Again, the -- while our contract campaign was
25 front page, and, you'll see there's some -- it looks like        25 2008, we do a lot of pre-work before the bargaining

                                                          Page 79                                                               Page 81
1    one person who was absent and -- oh, actually, the         1        starts.
2    "M/S/P" is those who were excused, so, that's whose        2            So, a number of our contracts expire in the early
3    absent, but -- there was a quorum held to be able to make  3        spring; to do the kind of activity that we described, we
4    that decision.                                             4        don't start three weeks before the contract negotiations
5       Q. Were all Executive Board members invited to          5        to do this. You want to have some lead-up to these
6    attend?                                                    6        things, as they progress; so, beginning to build a
7        A. Yes.                                                7        community coalition, partners, and, the idea of an
8       Q. Was there any discussion during that meeting         8        educational process around that.
9    about using this Patients Education Fund as a means to     9           Q. Could you turn to Exhibit 67, please?
10   address the potential trusteeship imposed by SEIU?        10           A. In our booklet?
11       A. No.                                                11          Q. Yeah. These are all our exhibits -- UHW's
12      Q. Was there any discussion that UHW wanted to         12        exhibits.
13   stash money away on this 501(c)(3) fund to keep aside in 13            A. Okay.
14   case a trusteeship is imposed?                            14            Q. Okay.
15       A. No.                                                15            Do you recognize that document?
16      Q. At the time, May 2007, were you aware of any        16            A. Yeah, the --
17   facts that might raise an issue of potential trusteeship  17            Q. What is it?
18   that SEIU might impose on UHW?                            18            A. It's a white paper that we did called:
19       A. No.                                                19           "California's Healthcare Crisis Industry Challenges
20       The reasons that a union can be put into              20        and Work Force Solutions April 2008."
21   trusteeship, as I understand it, is:                      21           Q. And how is that document important to the
22       Financial malfeasance;                                22        healthcare issues you were considering?
23       Failure to collectively bargain;                      23           A. It demonstrates how we frame our contract
24       And failure to adhere to democratic practices.        24        campaign, as part of a broader effort to address
25       We believe we're a model in all three; never had any  25        healthcare issues in California.

                                                                                                   21 (Pages 78 to 81)
                                                          Page 82                                                              Page 84
1        So, just looking at the introduction, we talk about:        1   healthcare, and what was happening in healthcare, around
2        The rising cost and decreasing access to healthcare;        2   healthcare reform.
3        Inadequate quality of care;                                 3      We were also about to start our contract
4        The turnover in work force;                                 4   negotiations, the contract campaign kickoff. The first
5        Shortages of caregivers;                                    5   event was on February 20th at Alta Bates Summit Medical
6        High turnover rate in healthcare facilities;                6   Center. We did a march from Alta Bates Summit to one of
7        Unsafe staffing;                                            7   the nursing homes. It was a way for us to call public
8        California's work force;                                    8   attention to the contract fight, consistent with the work
9        Soaring profits of the industry;                            9   around the white paper and the public forums.
10       Exorbitant pay for healthcare executives;                  10     Q. Did you see the healthcare issues continuing
11       Millions for administrative overhead.                      11   past through 2008 and beyond?
12       We see our collective bargaining as a way to address       12      A. Yes, we did. They still are.
13 all these. So, this is all, again, part of a campaign to         13       Q. How long was the Fund intended to last?
14 address these issues.                                            14       A. We saw it as an on-going -- that, if things
15      Q. Could you turn to Exhibit 85, please?                    15   sustained themselves, including we made -- and we still
16      A. Pardon me?                                               16   have on the table -- proposals at the bargaining table to
17      Q. Could you turn to Exhibit 85, please?                    17   compliment the 501(c)(3) with jointly administered
18      It's a document that's entitled:                            18   Taft-Hartley funds with employers that we have collective
19    "SEIU United Healthcare Workers West California               19   bargaining relationships -- they're still on the
20 Healthcare Crisis Industry Challenges and Work Force             20   bargaining table as we speak -- that we saw this,
21 Solutions."                                                      21   potentially, as being a foundation to talk about
22    A. Correct.                                                   22   healthcare, broadly, even if healthcare reform were
23    Q. What is this document?                                     23   passed or if healthcare reform weren't passed.
24     A. This is the agenda from a program that we did             24       Q. Turn to Exhibit 97, please.
25 in Oakland in -- April the 16th, 2008 -- that we held a          25       A. Okay.

                                                          Page 83                                                              Page 85
1    community forum to talk about this white paper and             1       Q. It's a "Resolution of the Executive Board
2    discuss these kind of issues; again, the kind of               2    United Healthcare Workers - West..."
3    outreach -- an educational program that we saw the Fund        3       What is this document?
4    playing a role in.                                             4       A. Some time in -- well, this is the decision --
5       Q. So, this outreach and this program is the type           5    this is the resolution that the Executive Board passed in
6    of program that you envision the Patients Education Fund       6    which the money from the UHW -- or the UHW Patients
7    could be used to foster and promote and to support --          7    Education Fund -- is returned to UHW. All unspent money
8       A. Correct. You know, I would point out that we             8    is returned to the union.
9    drew in community partners to be part of this forum:           9       Q. And why was that done?
10      The faith community;                                        10      A. Pardon me?
11      Elected officials;                                          11      Q. Why was that done?
12      Gray Panthers;                                              12      A. Actually, I can't didn't hear.
13      California Alliance for Retired Americans;                  13      Q. Why was the Patients Education Fund unwound?
14      The East Bay Alliance for a Sustainable Economy;            14      A. Well, we said -- it's in the resolution.
15     Again, the kind of coalition partners that we wanted         15     The political landscape had changed;
16 to have an on-going -- and do have an on-going --                16     Anticipated healthcare initiative had not been
17 relationship with, to make healthcare a top priority in          17 placed on the ballot;
18 the California economy.                                          18     And, as importantly, if not most importantly, it's
19    Q. Mr. Borsos, on or about February -- there's                19 become a source of unnecessary conflict between UHW and
20 been testimony that, on or about February 5, 2008, the           20 the SEIU International union diverting our attention from
21 UHW transferred about $2 million to the Patients                 21 our mission of promoting the interests and welfare of
22 Education Fund.                                                  22 the UHW membership by all means possible.
23      Were there any reasons for that?                            23    Q. And, in fact, monies from the Patients
24      A. Yeah.                                                    24 Education Fund were not used to support the conference
25      There was a fight going on around, you know,                25 that we discussed earlier; is that correct?

                                                                                                     22 (Pages 82 to 85)
                                                            Page 86                                                           Page 88
1       A. Correct.                                                    1      A. Yeah, that's what's called a take-away.
2       Q. Why was that?                                               2     Q. What is a take-away?
3       A. Because, by early April -- I don't remember the             3      A. A take-way is where the employer wants to take
4    exact date -- we had gotten a letter in which it was              4   away stuff that we have in our contract; and, it didn't
5    clear that the Patients Education Fund was a source of            5   end with merit pay.
6    dispute between us and the International union; and we            6       If you flip further into the document, you'll see
7    didn't want to spend anymore dollars and have it become a         7   St. Luke's proposal. It's about the fourth page in. For
 8 question of how we spent those funds.                               8   the first time, ever, in the history of the Daughters of
 9    Q. Are you in current bargaining, right now, with                9   Charity -- again, it's a proposal that's made on
10 employers?                                                         10 September the 18th of 2008 -- they propose that employees
11     A. Yes, we are.                                                11 would have to pay for health insurance -- part-time
12     Q. About how many contract negotiations are going              12 employees would have to pay for health insurance for
13 on right now?                                                      13 their spouses and dependents.
14     A. As I said at the beginning, we were bargaining              14     We've never had employees pay for contract -- or --
15 for 75,000. We recently settled the Kaiser. There was a            15 health insurance for their spouses and dependents; even
16 re-opener with Kaiser; that's about 45,000. So, we                 16 part-time employees. Our standard in the industry is, if
17 remain in bargaining for about 30,000 UHW members.                 17 you work 20 hours a week or more, it's fully
18    Q. Has the issue of possible trusteeship come up                18 employer-paid health insurance for you, your spouse, and
19 in your bargaining with employers?                                 19 your dependents.
20     A. Yes, it has.                                                20     We haven't had provisions like this in the core
21    Q. How has it come up?                                          21 contracts -- in the Bay Area, we haven't had provisions
22     A. It came up, most dramatically, when SEIU sent               22 like this in our contracts since the 1960's. These are
23 monitors to the bargaining. At CHW, having the presence            23 rollbacks to the 1960's; and it doesn't stop.
24 of International people at the bargaining table, when it           24     Sutter Health put on the table eliminating -- or
25 happened, the employer has begun asking us about the role          25 giving them -- the right to subcontract out work in

                                                            Page 87                                                           Page 89
 1   of the trusteeship is in bargaining; in some cases,               1   certain cases. That proposal was made on September the
 2   across the bargaining table at Sutter and the Daughters           2   23rd.
 3   of Charity, it's come up against the bargaining table.            3      They also propose to eliminate the right to the
 4      Q. Turn your attention to Exhibit 107.                         4   organizing rights section of our contract. That proposal
 5       A. Okay.                                                      5   was made on September the 23rd. There's been a dramatic
 6       Q. What is Exhibit 107?                                       6   shift in the bargaining since the Trusteeship notice was
 7       A. Well, this is probably the starkest                        7   received.
 8   demonstration of the effect of the threat of trusteeship          8       Q. Could you turn to Exhibit 122, please?
 9   at the bargaining table.                                          9    A. Yes.
10       If you look at the second page, September -- it's a          10    Q. It's a document that's entitled, ABSMC and
11   document that says:                                              11 SEIU-UHW negotiations.
12      "Seton Medical Center-Seton Medical Center Coastside          12    What are these series of documents?
13   Economic Counterproposal, September 18, 2007."                   13    A. Yeah, these are the -- it's about five pages --
14       The first page, the employer puts on the table, for          14 ABSMC is Alta Bates Summit Medical Center. Sutter Health
15   the first time ever, in the history of the Daughters of          15 is, probably, our worst employer in the entire -- in my
16   Charity -- we've never had it -- merit pay for folks.            16 opinion in the entire -- union.
17      People know that our contracts don't have merit pay,          17     And what you'll see here is -- there's a document --
18   which is pay per performance. That's one of the first            18 that's what the landscape is.
19   things that we eliminate from the contract when we               19     It says: Status of ABSMC and SEIU Negotiations.
20   bargain a new contract from an unorganized facility.             20     This is a document prepared by the employer. Page 3
21       It's a proposal. We've been in bargaining with the           21 the Election Agreement, which is the organizing rights
22   Daughters of Charity since March of 2008 and, on                 22 that I described, the employer's proposal is not to
23   September the 18th, 2008, three weeks after the Notice of        23 modify that language; it's to delete that language, so
24   Trusteeship, we get a proposal for merit pay.                    24 that would no longer be part of the contract; and that's
25       Q. Is that called a take-away?                               25 on top of other take-aways that were proposed at this

                                                                                                    23 (Pages 86 to 89)
                                                           Page 90                                                                 Page 92
1    bargaining session.                                             1       "Article 22/Subcontracting Counter to SEIU February
2       Q. How do you know these take-aways are connected            2    8, 2007."
3    with the threatened trusteeship?                                3       What is this document?
4       A. We're in bargaining with these employers for              4       A. Yeah, this is the tentative agreement that
5    six months. The bargaining proposals aren't on the              5    representatives of the International union signed -- and,
6    table. Trusteeship notice happens and, all of a sudden,         6    you'll see in the top middle, "O.K., MJC"; that's Mary
7    they come across the bargaining table.                          7    Joyce Carlson, who's in the legal department of SEIU,
 8    So, on top of that, there's discussions that certain            8 where she negotiated away the standard of a ban on
 9 management representatives, most recently, at the                  9 subcontracting in the contract with Tenet behind closed
10 Daughters of Charity, one of the H.R. representatives,            10 doors. We didn't know about it, where it says that:
11 whose at the bargaining table, spoke to one of our                11     The employer has the right to subcontract out all or
12 bargaining team members to say that they're being                 12 part of any work performed by employees represented by
13 counseled -- and they're counseled in their caucus to             13 the Union and covered by this agreement provided,
14 wait until the trusteeship is imposed because they know           14 however, in no event shall the employer subcontract out
15 they can get a better deal with the SEIU.                         15 more than 12 percent of the total number employees in the
16    Q. Do you think that a trusteeship is necessary to             16 SEIU bargaining unit.
17 protect the interest of UHW's members?                            17     Just to put that into perspective, we represent --
18     A. I think that a trusteeship is contrary to the              18 we and 121R.N. -- represent about 7,000 Tenet workers;
19 interests of the SEIU or UHW members.                             19 so, giving Tenet the right to subcontract out 12 percent,
20     Q. Why is that?                                               20 my math has it about 840 of our members. They just gave
21     A. If the interest of the union is to advance the             21 away the right -- or -- they tried to give away the right
22 wages, benefits, and working conditions for its members,          22 to subcontract to Tenet.
23 and, a trusteeship leads an employer to believe that they         23     Q. What does that mean that SEIU tried to give
24 can cut or work out a better deal with somebody else,             24 away the right for Tenet to subcontract 12 percent of its
25 and, it undermines the democratic process in the                  25 work force?

                                                           Page 91                                                                 Page 93
1    bargaining committees, who are, currently, meeting with         1       What does that mean to the workers?
2    those employers at the bargaining table, I don't know how       2       A. Well, the short version of a very long story is
3    anyone could argue that a trusteeship is the best thing         3    that our members at Tenet fought to stay in control of
4    for the members.                                                4    their bargaining, and, they rescinded this tentative
5       Q. I just want to be clear.                                  5    agreement and ended up negotiating a contract that had a
6       Is it your concern that, if a trusteeship is                 6    full and complete ban on subcontracting in the contract.
7    imposed, that the contract standards for UHW's members          7       Q. But, what would happen if Tenet subcontracted
8    will be reduced?                                                8    out 12 percent of the employees?
9       A. Yes.                                                      9       Does that mean they would get fired?
10   Q. Why do you think if SEIU imposes a trusteeship               10     A. Yeah, they would no longer be Tenet employees,
11 your members' contract standards will be reduced?                 11 and, their guarantee of having a position with a
12    A. We've experienced it.                                       12 subcontractor was not provided; and the wages and benefit
13   Q. And how have you experienced it?                             13 of that subcontractor were not guaranteed.
14    A. I directly experienced it in the negotiations               14     In situations where subcontracting has happened --
15 with Tenethealth -- Tenethealth Care -- where SEIU                15 and this is true of what Tenet did in 2001-2002 -- full
16 representatives from the International union,                     16 departments -- housekeeping, dietary, and other
17 purportedly, working on our behalf, signed away portions          17 departments -- were just eliminated and outside
18 of our contract that would have given Tenet the right to,         18 contractors were brought in to do that work.
19 for example, subcontract out 840 of our members' jobs             19    Q. And what did UHW do when it learned that SEIU
20 during the life of the contract.                                  20 was -- had agreed to give away Tenet the right to fire 12
21     Q. Can I turn your attention to Exhibit 8, please?            21 percent of the work force?
22     A. Eight? Okay.                                               22     A. We tried to raise it internally. Our members
23      Q. Do you see Exhibit 8?                                     23 of the Tenet bargaining team and in Tenet facilities
24      A. Yes.                                                      24 expressed their extreme displeasure at what had happened.
25      Q. It's entitled:                                            25     By the way, this wasn't the only thing that happened

                                                                                                    24 (Pages 90 to 93)
                                                            Page 94                                                                Page 96
1    in these negotiations. SEIU, implicitly, agreed with             1    called the renewal of the California Nursing Home
2    Tenet to a provision that would have prohibited giving           2    Alliance.
3    away our right to strike for ten years; would have agreed        3       In 2003 or 2004, there about, there was a effort on
4    to wages that did not guarantee wage scales; and we              4    the part of SEIU and Local 6434 in Southern California
5    fought back and, subsequently, were able to win, from our        5    and UHW, to develop a different kind of relationship with
6    perspective, an industry standard contract.                      6    the nursing home industry.
7       Q. Are there other examples of a track record that            7       We reached an agreement with a portion of the
 8 cause you concern that, if a trusteeship is imposed, that          8    industry called the Nursing Home Alliance that spelled
 9 it will not serve the interests of your members?                   9    out that SEIU-UHW and 6434 would work to improve medical
10     A. Yeah. We've been critical of -- speaking of                 10 funding for nursing homes, with the idea that the
11 subcontractors, we've been critical of the agreements              11 collective bargaining relationship would mature into a
12 that SEIU has reached in the -- with Aramark, etc. --              12 Kaiser-Catholic Healthcare West-type relationship as a
13 and, the best way I could describe it, to give an example          13 foot in the door.
14 from Redding, California:                                          14    The parties agreed, on a temporary basis, to what
15     UHW represents the housekeeping and dietary workers            15 were then called Template Agreements. That were
16 at Mercy Medical Center, Redding, which is a Catholic              16 stripped-down versions of the contract.
17 Healthcare West facility.                                          17    We went through the Nursing Home Alliance bargaining
18     Currently, the start rate for a housekeeper at Mercy           18 process;
19 Medical Center Redding is about $15 an hour;                       19      We agreed to lobby in Sacramento;
20     The employee has fully employer-paid health                    20      We've worked with the industry to generate close to
21 insurance for herself, her spouse, her dependents;                 21 $1 billion in new revenues for the nursing homes;
22    Working 20 hours a week or more, she's entitled to              22      And, then, we went to the bargaining table and had
23 that;                                                              23 to fight to get them to provide the appropriate share for
24    She would -- she has a fully defined benefit pension            24 the employees.
25 plan;                                                              25      At the bargaining table, in some cases, we had to

                                                            Page 95                                                                Page 97
1        She has retiree health;                                      1    threaten to strike.
2        There's a ban on subcontracting in the contract;             2       In 2006-2007, the Nursing Home Alliance was up for
3        There is a provision around staffing that's in the           3    re-negotiations. We thought that it did not work for
4    contract;                                                        4    nursing home workers in California and wanted to
5        There's language that protects the union if the              5    negotiate a different kind of arrangement, one that was
6    employer tries to sell the facility.                             6    not based on a transactional relationship that SEIU
7        Two miles down the street, there's a facility called         7    appeared to prefer.
8    Shasta Regional Medical Center where the workers are             8       And we ran into a disagreement and the disagreement
 9 subcontracted out and represented under what's called a            9    played out in a number of different ways to the point
10 Service Workers' United contract.                                  10 that the Nursing Home Alliance, in my opinion,
11    The wage rates in those contracts are less than $9              11 fortunately, fell apart because it was not able to put
12 an hour;                                                           12 together this kind of transactional relationship that
13    There's not fully employer-paid benefits;                       13 SEIU and 6434, certainly, favored.
14       The employer has the right to subcontract;                   14      Q. You mentioned different views between UHW and
15       There's a full-blown management's rights clause;             15 SEIU.
16       There's not retiree health insurance.                        16      Yesterday, we heard testimony about different views
17     So, two miles away, in the same city, you have                 17 in terms of where the labor movement should go between
18 people who are making half as much as what somebody                18 UHW and SEIU from one of the witnesses, Mr. Amado David?
19 covered by a UHW contract would make.                              19      A. Correct.
20     And, obviously, we have concerns that the same thing           20      Q. And are you familiar with that division in
21 would happen to the standards that we fought two years to          21 views?
22 get to this place.                                                 22      A. Yes.
23      Q. What is the Nursing Home Alliance?                         23      Q. What are the two divisions of where the labor
24       A. That's another example.                                   24 movement should go, as you see it?
25      Q. There's been an on-going dispute about what's              25      A. The simplest way to describe it is, I would say

                                                                                                      25 (Pages 94 to 97)
                                                      Page 98                                                          Page 100
 1   there are competing visions of what the labor movement       1   our differences are and conclude the letter by saying,
 2   should look like.                                            2   you know:
 3      Our vision is democratically-led, rank-and-file           3      The attacks, the criticisms, the way that debate is
 4   controlled, labor movement, in which members are             4   handled, have gone too far. Accordingly, we ask that you
 5   empowered to make decisions about their working              5   take this letter in the spirit of open criticism. We
 6   conditions and about their union.                            6   remain committed to working to build our union and the
 7      And, in contrast, is a vision that's been put             7   labor movement; to do that, we must create an environment
 8   forward by Andy Stern, the president of SEIU, that           8   where we can, constructively, work through our
 9   decisions are made in a much more centralized top-down       9   differences in our urgent efforts to be a voice for
10   way.                                                        10 unorganized workers, while not abandoning the vision and
11     Q. How about in terms of standard and growth?             11 democratic strings that have made us the largest and most
12      A. From our perspective, standards and growth can        12 successful labor union in the nation.
13   happen, simultaneously; in fact, they're part and parcel    13      Q. How did SEIU react?
14   of -- they're a part of -- to win -- to be able to          14      A. Well, they weren't happy about it.
15   achieve growth, you have to be able to win standards.       15      Q. Are you familiar with the California State
16   You can't achieve one without the other.                    16 Council?
17      What we've seen in SEIU is a drive of growth at all      17    A. I am.
18   costs to the detriment of standards and we believe,         18     SECRETARY MARSHALL: What was the question?
19   ultimately, to the detriment of growth.                     19     MR. CHATTERJEE: Q. Were you familiar with the
20       Q. Did UHW voice its view?                              20 California State Council?
21      A. Yes, we did.                                          21     What is the California State Council?
22      Q. Could you turn to Exhibit 16, please?                 22     A. The California State Council is the umbrella
23      A. I'm sorry? What was the number?                       23 organization in -- among the SEIU Locals in California,
24      Q. 16.                                                   24 primarily, for the purposes of coordinating political
25      A. Okay.                                                 25 work in Sacramento, so that SEIU Locals aren't taking

                                                      Page 99                                                          Page 101
 1      Q. 16 is a letter to Andy Stern and Anna Burger          1    opposite positions on points of public policy; and the
 2   from Mr. Rosselli.                                          2    State Council is the body that that work is coordinated.
 3      What is this document?                                   3       Q. And who was the president of the State Council
 4      A. Yeah, this is a letter from Sal to Andy from          4    in the second half of 2007?
 5   June 1, 2007, in which we begin -- this was an internal     5       A. In 2007, Sal Rosselli was the president of the
 6   document from Sal to Andy. We started raising issues        6    SEIU State Council.
 7   about our different visions, internally; and, when we       7       Q. Can you turn to Exhibit 49, please?
 8   began to raise our issues, internally, it became clear to   8       A. I can. I have it.
 9   us that there really wasn't a safe environment with          9    Q. What is Exhibit 49?
10   within SEIU to raise these issues.                          10    A. Exhibit 49 is an article from late February,
11      I would point to the third and fourth paragraphs:        11 2008 by Daniel Weintraub, who is a columnist with the
12      (Not verbatim) First, it seems self-evident that         12 Sacramento Bee.
13   SEIU has not provided a safe environment within SEIU        13    Q. And what does his article describe?
14   where we can raise and debate issues, disagree with one     14     A. The article describes that, in the fall of
15   another, and, constructively, resolve differences --        15 2008, that SEIU -- let's see -- that SEIU -- if you look
16   struggle, debate and disagree.                              16 at the seventh paragraph -- describes the billion dollar
17       Through such struggle, new ideas emerge and give        17 union's grandma's thoughts about childcare workers came
18   prize to a vision, program, and strategy beneficial to      18 up last year during discussions on healthcare reform.
19   the members of SEIU.                                        19     Andy Stern, the national leader of the SEIU, in
20       SEIU's history is rich with this process. It is         20 which it describes what was rumored to be a deal where
21   disappointing when the environment for such dialogue is     21 Stern made compromises on healthcare reform in exchange
22   not safe and, instead, is considered disloyal,              22 for the right to organize childcare workers in a
23   controversial, and destabilizing to offer constructive      23 different part of the economy -- different section of the
24   criticisms.                                                 24 economy.
25      And then we lay out a number of examples of where        25     Q. Can you turn to Exhibit 33, please?

                                                                                            26 (Pages 98 to 101)
                                                     Page 102                                                          Page 104
 1      A. Yes, I have it.                                        1      A. -- dated October 15, 2007.
 2      Q. 33 is an article entitled "Unhealthy Union" --         2      Q. And what is the effect of the president of the
 3      MR. ROTHNER: Mr. Hearing Officer, the union               3   State Council when the charter was revoked?
 4   articles are -- if I can -- I know rules of evidence         4      MR. DAYAN: I just want to raise a point of the
 5   don't apply, but, newspaper articles are like the classic    5   order of the proceedings. I know, at the beginning, we
 6   triple hearsay.                                              6   kind of put to the point where it became a real issue
 7      If he knows the events, like the last article, I          7   rather than abstract one about the order of proceedings.
 8   don't think there was even a question of whether Mr.         8       I think what we're getting into, right now, is the
 9   Borsos had personal knowledge. I thought -- I didn't         9   pure -- you know, I call it the retaliation issue. We're
10   object because I thought it might refresh your              10   now way away from the merits of the charge on PEF, which
11   recollection. There was no personal knowledge of Mr.        11   is the order of proceedings. We start with PEF. We're
12   Borsos putting in newspapers articles. It's just very       12   just getting very far afield here.
13   far afield.                                                 13      SECRETARY MARSHALL: Let's me ask you to keep it, if
14       MR. CHATTERJEE: Your Honor, it's a public               14   you can, to the issues; then, you can come back and make
15   discussion. We're not submitting it for hearsay             15   your other case.
16   purposes. And, we, certainly, didn't object when they       16      MR. CHATTERJEE: Well, your Honor, I think it's all
17   put in a San Francisco Chronicle article.                   17   very important.
18      Q. What is the topic of Exhibit 33?                      18       First, their witness, Mr. Amado David, got up on the
19      A. It's, again, another article describing the           19   stand and opened this whole debate; and he testified
20   deal that Stern is reported to have cut with the Governor   20   about the division and how he responded to the division.
21   in which he trades off compromises on healthcare reform     21       And, in essence, our proffer is his story was the
22   with the right to organize childcare workers. It was        22   retaliation against SEIU for this debate, just as this
23   such an unspoken secret that it was appearing in            23   trusteeship is an improper --
24   newspaper articles.                                         24      SECRETARY MARSHALL: Yeah, let me ask you to go
25      Q. So, these issues were in the public debate?           25   ahead and make your case on this point, but, to try to

                                                     Page 103                                                          Page 105
1       A. Correct.                                               1   respond to the first two charges; and then you can come
2       Q. How did UHW -- or -- did UHW voice its view as         2   back and make your -- relate this to the charges that are
3    to these issues?                                             3   that the International President's Council has made.
4       A. Well, we didn't know about these at the time.          4       And, then, later on, you can have as much time as
5       Q. Did UHW voice it's view with regard to                 5   you need to make your larger case.
6    healthcare issues in late 2007?                              6      MR. CHATTERJEE: One second, Secretary Marshall?
7       A. Yeah. There was a disagreement within SEIU,            7      SECRETARY MARSHALL: Yes.
8    actually, only, at the very end in October, November,        8      MR. CHATTERJEE: Your Honor, this -- this entire
 9 between compromises that should happen on the healthcare       9   line of questioning is directly related to the Patients
10 reform package being put forward by Schwarzenegger and        10   Education Fund and the trusteeship.
11 Nunez.                                                        11       The evidence will show that the -- there were a
12     And UHW believed that -- UHW and other SEIU Locals        12   series of events in which not only did SEIU retaliate
13 believed that -- there were certain provisions that           13   against the Local, but, also will show that the
14 needed to be part of the healthcare reform package that       14   trusteeship became an issue -- and it became a
15 Stern was pushing very hard on compromise.                    15   non-issue -- and the SEIU tried to dismantle UHW by other
16     Q. And did SEIU retaliate against UHW for that?           16   means.
17     A. Yeah. Stern pushed compromise by eliminating           17       And, once that became unwound, they resurrected the
18 Sal as president of the State Council.                        18   trusteeship on this Patients Education Fund charges.
19     Q. Could you turn to Exhibit 22, please?                  19       We believe this is all a part of the same line of
20     A. Yes.                                                   20   issues that goes directly to the Patients Education Fund,
21     Q. What is Exhibit 22?                                    21   and why we're here today.
22     A. It's the notice from Andy Stern to the officers        22       And, we believe our case needs to be told in a
23 and delegates of the California State Council revoking        23   chronological story for you to understand the
24 the charter of the California State Council --                24   circumstances of why we're here today.
25    Q. And --                                                  25      SECRETARY MARSHALL: Well, I want to understand all

                                                                                          27 (Pages 102 to 105)
                                                      Page 106                                                              Page 108
1    that, so, go ahead and make your case as succinct as you    1    defense?
2    can.                                                        2       This is now something that happened -- he's about to
3       MR. CHATTERJEE: Thank you.                               3    testify about events that have happened after all of
4       Q. Before we were interrupted, I think we were on        4    this, he just said he doesn't know about, and that he
5    Exhibit 22.                                                 5    read in the newspapers. I mean, this is way beyond what
6       A. Right.                                                6    any proceeding would go into.
7       Q. What was SEIU -- first of all, was there any          7       MR. CHATTERJEE: I don't understand. They raise the
 8 reason given why the State charter was revoked at that        8    Patients Education Fund five months after they knew about
 9 time?                                                         9    all the facts. This is -- we're just trying to tell our
10    A. It was in full -- by virtue of the authority            10 story, Secretary Marshall, and, we think you should hear.
11 contained in the SEIU Constitution and bylaws, I hereby       11 They're making a very, very poor decision.
12 revoke the charter of SEIU State council, effective           12     May I proceed?
13 October 17, 2007 period.                                      13     SECRETARY MARSHALL: What's the relevance?
14    Q. And, in October, was there any reasons provided         14     MR. CHATTERJEE: The relevance is that there's
15 for the revocation?                                           15 retaliation against Mr. Rosselli, CHW, for voicing its
16    A. No.                                                     16 views; and, we're going to tell the story how that
17    Q. What was the effect on Mr. Sal Rosselli being           17 happened, and, how that ties in, directly, with the
18 the president of the state Council by the revocation?         18 Patients Education Fund, as well as this trusteeship, as
19      A. It removed him from office.                           19 well as the testimony from Mr. Amado David, we heard
20      Q. Could you turn to Exhibit 24, please?                 20 yesterday.
21      A. Yes.                                                  21     And I don't understand why we're, constantly, being
22    Q. What's Exhibit 24?                                      22 interrupted by his objections.
23    A. This is the -- it's a letter from Andy Stern to         23     MR. DAYAN: Can I say one more thing about this?
24 Kim Evon -- E-V-O-N -- in which he establishes the new        24    Okay, what this line of questioning is about is, you
25 State Council, effective October 15, 2007, consistent         25 know, opening up a whole other hearing because, who knows

                                                      Page 107                                                              Page 109
 1   with his establishment of the new Council; and he names a    1   from the newspaper report whether Ms. Grajeda, or anyone
 2   new Executive Board of Directors. The letter is dated        2   else, is guilty or not guilty?
 3   November the 6th, 2007.                                      3      So, they want to try in a newspaper article, after
 4      Q. And how was the -- did anyone seek to run for          4   pressing this tribunal, properly, for due process, so,
 5   president of the State Council after the charter was         5   they want to put on facts that no conceivable notion of
 6   revoked?                                                     6   due process hearing from the witnesses with knowledge,
 7       A. Well, we weren't sure that the office had been        7   you know, would ever put on, would ever allow by having
 8   eliminated. It turned out that it was. Sal got a call        8   him say, I read in the newspaper that there's this
 9 from Annelle Grajeda saying that she was planning to run       9 controversy with Ms. Grajeda. It's way out of context.
10 as the president of the State Council, since it was now a     10 It has nothing to do with PEF.
11 new State Council, even though, a month earlier, she had      11    MR. CHATTERJEE: Your Honor, we're going to show a
12 talked to Sal about what a great job he was doing as the      12 document that establishes how the election for the State
13 president of the State Council.                               13 Council was, essentially, rigged and engineered by Tyrone
14    Q. Who is a Annelle Grajeda?                               14 Freeman of the Local union that they tried to move our
15    A. Annelle Grajeda has, recently, been in the              15 members into; and, hopefully, collapsed. And SEIU -- and
16 newspapers. She's one of the top six officers of SEIU.        16 that goes, directly, to the retaliation that's happening
17 She's an executive vice president of SEIU. She was            17 here.
18 appointed by Andy Stern as the president of Local 721.        18     SECRETARY MARSHALL: All right, you made your point
19    She's now under -- on administrative leave --              19 on that.
20    MR. DAYAN: Can I make an objection?                        20     Why don't you go ahead and proceed with the
21    Wait, wait, wait, wait. This is -- this is about to        21 discussion about your reaction to the first two charges
22 be about something that happened after even the theory        22 that were made against you?
23 that we think goes against the logical order of               23     We have that point.
24 proceedings.                                                  24     MR. CHATTERJEE: Q. I'm going to show you Exhibit
25      Are they guilty? And, if so, do they have a              25 27.

                                                                                            28 (Pages 106 to 109)
                                                  Page 110                                                         Page 112
 1      A. Okay. Okay, I have it.                              1       SECRETARY MARSHALL: We're going to resume the
 2      Q. Mr. Borsos, what is Exhibit 27?                     2    hearing. We have a couple of announcements to make.
 3      A. Stern declared that there was a new State           3       MR. BAIRD: I just wanted to remind everybody that
 4   Council. There was a question on how officers of the new 4     there's no videorecording or photographs of the
 5   State Council would be elected. There was a question      5    proceeding; and, if you do that, the Sergeant at Arms
 6   about whether Locals that were behind in the per capita   6    will ask you to stop.
 7   payments would be allowed to vote consistent with what    7       Someone has said that they have misplaced a blue
 8   the rules of the old State Council and the new State      8    shoulder bag. If you are aware of a blue shoulder bag,
 9   Council were.                                             9    you don't know who it belongs to, could you please take
10       Tyrone Freeman requested a waiver that would have    10    it to the lost and found in the back?
11   enabled his Local and Mike Garcia's Local to vote with   11                (Discussion off the record)
12   their full membership strength, even though they were    12         SECRETARY MARSHALL: All right. I'm going to make
13   $1.5 million behind in their per capita.                 13    some suggestions about how we finish up our work today.
14       And this E-mail is Andy Stern's E-mail back to the   14    It's very clear to me that we're not going to be able to
15   officers of the State Council saying that he is granting 15    finish everything we need to do today, so, we will
16   Tyrone Freeman's request to waive, that would allow      16    schedule another hearing some time after the election,
17   Locals that were not fully up to date on per capita's to 17    some time after, maybe, towards the middle of November.
18   the State Council, to vote based on their per capita     18    And I hope we'll all be in a good mood when that
19   payments to the International union rather than to the   19    happens -- about the election, I mean.
20   State Council.                                           20       Then, what I'd like to do today, to the extent that
21       MR. DAYAN: Can we make another objection to these 21       we can, is to finish up the -- I don't know how much more
22   lines of inquiry?                                        22    you all have to do on the International President's
23       These kind of disputes would have been the subject   23    charges -- and then I understand that your affirmative
24   of internal proceedings about whether that was a         24    defense is that the sole purpose for the trusteeship is
25   violation of the way that you elect officers or the way  25    retribution, and you need to be able to make that case,

                                                  Page 111                                                         Page 113
 1   that you elect delegates.                                  1   and so that's the thing we'll do when we have a new
 2       You know, we can't have a hearing here about things    2   hearing -- another hearing some time in November.
 3   that could have, actually, been complained about; and,     3       And, in the meantime, now, one of the reasons to do
 4   not just complained about because they were -- but, then,  4   that, now, is that I want to give members of the audience
 5   litigated back when they happened. I mean, this is -- I    5   at least two hours to say whatever you want to say; and,
 6   think I've got my point across. It has nothing to do       6   if you can do it in two minutes, that will test your
 7   with PEF.                                                  7   brevity. And being one whose brevity-challenged, I
 8        SECRETARY MARSHALL: All right. How much longer do     8   always admire people who can say what they got to say in
 9   you think you'll have with this witness?                   9   two minutes. But, in order to get as many people in as
10        MR. CHATTERJEE: Your Honor, I think we need to tell  10   we can, we want to try to do that. And what we'll do is
11   the story about how --                                    11   take the cards in the order that we collected them and
12        SECRETARY MARSHALL: I know that; but, that's not my 12    we'll line people up five at a time and in an orderly
13   question.                                                 13   process. And then, if you're getting ready to speak and
14        My question is, how much longer do you think you'll  14   you see that what you wanted to say has already been
15   have?                                                     15   said, then maybe, if you'd let somebody else speak, we
16        MR. CHATTERJEE: I estimate another 45 minutes.       16   can get more points of view across.
17        SECRETARY MARSHALL: How long?                        17      And, if we don't get to you, as I mentioned this
18        MR. CHATTERJEE: 45 minutes.                          18   morning, I welcome written comments from you; where to
19        SECRETARY MARSHALL: All right, well, why don't we    19   write them is in that green sheet that's on your seat --
20   break for lunch now --                                    20   or were -- and so that's the way we'll try to proceed
21        MR. CHATTERJEE: That's fine.                         21   with the rest of the day.
22        SECRETARY MARSHALL: -- because -- and then we'll     22       I will stop this proceeding at 3:30 so we need to be
23   come back and resume.                                     23   able to get to that point for you all to organize your
24        MR. CHATTERJEE: I appreciate that, sir.              24   cases in a way in order to be able to stop when we get to
25                  (Recess taken)                             25   that point. Mr.

                                                                                       29 (Pages 110 to 113)
                                                          Page 114                                                       Page 116
 1       Harris?                                                      1      MR. DAYAN: Objection.
 2       MR. HARRIS: Yeah, thank you, Secretary Marshall.             2      MR. BORSOS: -- in which he says that he is not
 3   And, you know, we will certainly reach a stopping point          3   putting -- he would not accept nomination for the
 4   at 3:30 because we agree that the members should be              4   president of the State Council because the process was
 5   allowed to speak here this afternoon. We think that's            5   flawed.
 6   very important. I don't know that -- I don't think that          6       "The idea that organizations like SEIU 6434 and 1877
 7   we can finish our presentation with regard to Counts 1           7   would be able to fully participate while owing more than
 8   and 2 before 3:30.                                               8   $1.5 million in back dues" -- can I finish?
 9      SECRETARY MARSHALL: Yeah, well, I understand that,            9       MR. DAYAN: This is -- we just --
10 and that's the reason that I have agreed to schedule as           10       MR. CHATTERJEE: It's extraordinary for counsel to
11 much time as we need after the election.                          11   interrupt the witness.
12    MR. HARRIS: Thank you. I appreciate that.                      12      MR. BORSOS: I'm right in the middle of trying to
13     SECRETARY MARSHALL: I think that's the best way to            13   answer the question.
14 do that. And everybody get busy for the election. I               14      I can't answer that question?
15 don't know if the International President's Council can           15       SECRETARY MARSHALL: What is the relevance of this
16 finish their case today or not, but, you figure out what          16   to the first two charges?
17 you want to do, you know, how much of that you want to            17       MR. CHATTERJEE: The relevance is that Mr. -- their
18 put in. You've already put in the first two charges;              18   sole evidence of anything to do improperly with the
19 right?                                                            19   Patients Education Fund was Mr. David came up here and
20     MR. ROTHNER: Yes.                                             20   told a story, yesterday -- and this goes directly to
21     SECRETARY MARSHALL: Yeah, now, how much of those              21   impeaching Mr. Amado David and it goes to laying the
22 other charges do you want to try get in?                          22   foundation for explaining the allegations for the PEF
23     MR. ROTHNER: Well, we'll get in as much as we can,            23   fund, now, are completely unfounded.
24 but, I'd like to keep open the discussion about when we           24      It will explain a series of events of the Patients
25 would reschedule for --                                           25   Education Fund was brought to the attention -- well,

                                                          Page 115                                                       Page 117
1       SECRETARY MARSHALL: Well, we'll do that.                      1   certainly, raised by SEIU. SEIU threatened a
2       MR. ROTHNER: Yeah.                                            2   trusteeship. They knew all the facts.
3       SECRETARY MARSHALL: Yeah, and, what we want to do,            3       SECRETARY MARSHALL: So, you're speaking to the
4    of course, is keep the testimony to these issues. If you         4   relationship of this to the PEF?
5    want to get into your affirmative defense, we'll do all          5       MR. CHATTERJEE: That's correct.
6    that at the next hearing.                                        6      SECRETARY MARSHALL: All right, well, keep it on
7       MR. ROTHNER: Yeah, I'd just like to preserve the              7   that, and then, when you get to your affirmative defense,
8    opportunity to discuss a quicker return to this hearing          8   you can put it in.
9    than after the election, but, we can discuss that.               9      MR. DAYAN: Mr. Hearing officer, I'm sorry. I think
10    SECRETARY MARSHALL: I will be glad to consider                 10   we need some understanding here, just for the sake of,
11 that. I don't know if I've got two or three days                  11   you know, orderly proceeding.
12 contiguously between now and then, but, we'll work that           12      What I heard and, you know, we're fine with it, we
13 out later in consultation with you all.                           13   argued against it, but, we're not going to keep arguing
14    MR. ROTHNER: Okay.                                             14   against it, is that there'll be another day of hearing at
15    SECRETARY MARSHALL: All right.                                 15   which evidence about improper motive or retaliation will
16    MR. CHATTERJEE: Q. Mr. Borsos, could we return to              16   be put on by UHW.
17 Exhibit 29, please?                                               17      Okay, the issue that is in the case wholly apart
18    A. Did you say 29?                                             18   from retaliation is that we have UHW denying that they
19    Q. Exhibited 29.                                               19   made an improper transfer of funds for an improper
20    A. Yes, sure. I have it.                                       20   purpose and that they weren't honest about it when the
21    Q. We were discussing the State Council and SEIU's             21   matter came to light.
22 conduct as to the State Council before we broke.                  22       You can separate out whether they made an improper
23    What is Exhibit 29?                                            23   transfer and whether they misrepresented about it from
24    A. Exhibit 29 is an E-mail from Sal Rosselli to                24   any of this back-and-forth dispute between SEIU and UHW
25 Andy Stern dated December 2, 2007 --                              25   and -- let me give an example --

                                                                                            30 (Pages 114 to 117)
                                                     Page 118                                                        Page 120
 1      MR. CHATTERJEE: May I respond, Mr. Hearing                1        SECRETARY MARSHALL: Well, you'll have a chance to
 2   Marshall?                                                    2   tell that story; but, what I'd like for you to do, right
 3      SECRETARY MARSHALL: Yeah, respond to that.                3   now, is simply assert it.
 4      MR. CHATTERJEE: Number one, we have limited time          4       MR. HARRIS: What I'm saying is, it goes directly to
 5   and I don't understand why, now, we're having this           5   their claims that there were false purposes for the Fund,
 6   objection from counsel for SEIU, who is trying to stop us    6   and what we said in the spring of 2008 is evidence of
 7   from telling our story of the PEF fund the way they want     7   false purposes of that Fund. I mean, they've put that
 8   to tell us. They want to impose their -- they had their      8   evidence on and we're just responding to it.
 9   chance and we would like to go forward and put our case      9       SECRETARY MARSHALL: And I think what you can do
10   on. There's additional testimony at the next hearing.       10   right now is to say that; simply assert it that this is
11   We'll go in that way.                                       11   what we're going to prove when we put on our full case
12      In addition, if the hearing is going to be               12   about that we believe the sole reason for establishing a
13   continued, there's no reason to cut off this witness,       13   trusteeship is retribution.
14   right now, who is here and willing to testify.              14       But, right now, what we need to do is try to resolve
15       MR. DAYAN: Yes, there is.                               15   those early issues; doesn't mean that you can't say that
16       MR. CHATTERJEE: I would like to have SEIU's             16   right now.
17   attorney stop interrupting our witness. I would like to     17       MR. HARRIS: No, I'm saying that this goes directly
18   have SEIU's attorney admonished to make their objections    18   to their evidence and their claim that we expressed a
19   for the record.                                             19   false purpose; not nothing to do with their intent.
20       SECRETARY MARSHALL: Let me urge you to do the           20       I mean, there's that, but, that this is in response
21   following:                                                  21   to them saying statements we were taking in this same
22       Make the case about whether or not the PEF Fund was     22   context in time were false and were not, you know,
23   properly established, or whether you disagree with their    23   reflecting, accurately, the purposes of the Fund, why we
24   charges; and, then, in your affirmative defense, you can    24   dissolved the Fund, and everything that happened that
25   make the argument that the sole reason for the              25   spring. So, it goes to -- not to their motivation, but,

                                                     Page 119                                                        Page 121
 1   trusteeship was retribution and had nothing to do with       1   to explain what we did when we did it.
 2   the arguments about the PEF or any other matter.             2       SECRETARY MARSHALL: I think that's perfectly
 3       But, it's very difficult for me to understand it if      3   appropriate for you to explain to counter what they have
 4   you mix them, so, let's try to keep it to the issue of       4   told you -- what they have claimed the purpose of the
 5   the charges made by the International President's counsel    5   Fund was -- and to show evidence what you think it was
 6   and the International President in his statement of          6   really set up for. That's perfectly legitimate.
 7   charges.                                                     7       MR. HARRIS: Well, that's what we're trying to do.
 8      We're not going to in any way limit your ability to       8       SECRETARY MARSHALL: Let's get away from -- what I'd
 9 make your affirmative defense. You'll have ample               9 like for us not to get into how -- no -- I want to hear
10 opportunity to do that; but, if you could keep it as          10 that argument.
11 relevant to those issues, right now, it would be helpful.     11     Is that your affirmative defense? That is, that the
12     MR. HARRIS: Secretary Marshall, if I may give an          12 sole purpose of this trusteeship proposal is retribution
13 example of why we think these things are so entwined?         13 against the local union for these reasons that you cite?
14     I mean, they've presented evidence that reasons were      14     So, any way, if you could keep it as close to those
15 given for the dissolution of the Fund in the spring of        15 issues as you can, I would appreciate it.
16 2008 that, presumably, showed that it had a false purpose     16     MR. HARRIS: All right, thank you.
17 and that this wasn't, you know, the real reasons for it.      17     MR. CHATTERJEE: Thank you.
18     And, you know, we've presented evidence and we'll         18     MR. BORSOS: So, I -- can I finish my answer --
19 continue to present evidence of exactly what was going on     19     SECRETARY MARSHALL: Go ahead.
20 in this time;                                                 20     MR. BORSOS: -- because, honestly, one of the
21     Why it was dissolved at that time -- one reason was       21 biggest frustrations we've had in this whole thing is,
22 to avoid unnecessary conflict to go forward with the          22 every time we try to tell our story, representatives of
23 bargaining campaign that would been planned and to put to     23 the International union try to shut us down; and we'd
24 use the resources of the union. We can't really tell          24 just like to tell our story. They cut me off in
25 this story in parts.                                          25 midsentence. I'd just like to be able to finish an

                                                                                         31 (Pages 118 to 121)
                                                   Page 122                                                            Page 124
 1   answer.                                                     1    the four areas that are alleged, which I understand to be
 2      SECRETARY MARSHALL: Yeah, well, I'll let you finish      2    grounds for putting a Local into trusteeship:
 3   the answer; but, first, we got to recall the question       3       Breaches of fiduciary duty;
 4   because we've had this intervention.                        4       Interference with collective bargaining;
 5       But, let me also say that, as I've mentioned, you       5       Practices of Financial irregularities;
 6   will be able to tell all your story. The real question      6       Unethical conduct;
 7   is when and in what sequence; and, in order to get an       7       And circumvention of internal union democratic
 8   orderly resolution of these matters, I think we need to     8    procedures.
 9   proceed with the issues that are before us and then come    9       Q. So, March 24, 2008, SEIU raised the issue of
10   back to that.                                            10 possible trusteeship because of the Patients Education
11      Now, you remember the question it was?                11 Fund?
12      MR. BORSOS: Yeah. We were talking about the State 12        A. Correct.
13   Council and the E-mail from Sal to Stern on December the 13    Q. And did UHW respond to this letter?
14   2nd in which he was saying he wasn't going to run or     14    A. We.
15   accept nomination for the president of the State Council 15    Q. And could you turn to Exhibit 74?
16   for the following reasons:                                  16      A. Okay. I have it.
17       That the idea that SEIU would allow organizations       17      Q. Exhibit 74 is the April 3, 2008 letter.
18   like 6434 and 1877 to participate in the election while     18      You see that?
19   owing more than $1.5 million in back dues defied            19      A. I do.
20   acceptable notions of fairness with regard to union         20      Q. And, by this letter, did UHW respond regarding
21   democracy; and, so, as a result, Sal took his name out of   21 these allegations of a possible trusteeship because of
22   the running.                                                22 the Patients Education Fund?
23      And Annelle Grejada, who has stepped down,               23    A. Yes, we did.
24   voluntarily, on paid administrative leave, became the       24    Q. What was UHW's response?
25   president of the State Council.                             25    A. We laid out the work of our union. We pointed

                                                   Page 123                                                            Page 125
 1                (Applause)                                 1        out to President Stern that UHW was a highly competent,
 2      SECRETARY MARSHALL: All right, go ahead.             2        functioning Local union which was operating in a lawful
 3       MR. CHATTERJEE: Mr. Borsos, could you turn to       3        way in every respect.
 4   Exhibit 59, please?                                     4           When it came to finances, we said our union is
 5       A. I'm sorry? 59 or 69?                             5        financially healthy and sound. We have a financially
 6       Q. 59.                                              6        sound and healthy strike fund with more than $5 million
 7       A. Okay.                                            7        in assets for -- we're the second largest performer in
 8       Q. Exhibit 59 is a letter dated March 24, 2008.     8        COPE in the entire union.
 9       Have you seen it before?                            9           Reports, financially, were made bi-monthly to our
10       A. I have.                                         10        Executive Board, and every single check that the union
11       Q. And what is it?                                 11        writes was available for every member's inspection.
12       A. This is a letter from Andy Stern to Sal         12            We said, with regard to performance of collective
13   Rosselli in which he asserts a number of so-called     13        bargaining duties, we're proud that we bargain the best
14   allegations against UHW.                               14        contracts in the country. We were in the midst of
15       Q. And are these allegations related to the        15        beginning the early stages of the largest coordinated
16   Patients Education Fund?                               16        bargaining campaign in American healthcare history; and
17       A. One of them is.                                 17        that nobody, including President Stern, had ever
18       Q. And which one is that?                          18        criticized our ability or effectiveness in representing
19       A. Number one.                                     19        our members.
20       Q. And, by this letter, how did you interpret this 20           And then Sal reminded President Stern that the last
21   letter to relate to possible trusteeship?              21        time he appeared before the UHW Executive Board, he
22       A. This was really the moment that I believe that  22        acknowledged before more than 100 of our rank-and-file
23   SEIU's intention was to put UHW into trusteeship.      23        leaders, that UHW is a great union; and, that, if he had
24       Q. And why do you make that interpretation?        24        to be in a Local union, it would be UHW.
25       A. Well, the beginning of the letter spells out    25            And, then, the third point with regard to democratic

                                                                                           32 (Pages 122 to 125)
                                                        Page 126                                                            Page 128
1   procedures, we said, our union is a model of democracy.        1    dissent if our movement is to survive and grow.
2   Members elect stewards and officers members. Members are       2       Putting UHW under trusteeship would send a very
3   directly involved in the bargaining process and our            3    troubling message and may be viewed by many as a sign
4   members ratify contracts.                                      4    that internal democracy is not valued or tolerated within
5       In fact, we criticize the Stern administration for         5    SEIU.
6   its undemocratic practices, including the seizure of           6       In our view, this would have negative consequences
7   power from SEIU members, investing it in a handful of          7    for the workers directly affected by the SEIU itself and
8   officers, and political appointees in Washington.              8    the labor movement as a whole. We strongly urge you to
9       And then we laid out a series of our allegations           9    avoid such a tragedy."
10 against SEIU to make that assertion that:                       10      Q. And who signed that letter?
11     SEIU misused members' dues for political reasons by         11      A. It's signed by 100 leading academics from Norm
12 assigning International staff and consultants to engage         12 Chansky to Nelson Lictchenstein(sic) to Michael Dench,
13 in a disinformation campaign against UHW and its                13 Leon Fink, Bill Fletcher; again, most of the leading
14 leadership.                                                     14 labor intellectuals in the country.
15     It used International resources for the purpose of          15      Q. Now, with regard to the threatened trusteeship
16 making telephone calls, membership phone surveys, the           16 over the Patients Education Fund, and this response from
17 establishment of a website in an attempt to undermine           17 SEIU, and a response from very-well respected academics
18 members' democracy and dissuade UHW members and officers        18 and national leaders, did SEIU respond in a letter?
19 from participating in Local activities protected by the         19   A. They did.
20 SEIU Constitution.                                              20      Q. Could you turn to Exhibit 104, please?
21    We asserted there was an abuse of power and breach           21      A. Okay. I have it.
22 of membership confidentiality by releasing UHW                  22      MR. DAYAN: 104? I have an objection. I don't
23 memberships lists and telephone numbers to other SEIU           23 think they get it --
24 Locals;                                                         24     MR. CHATTERJEE: I don't think you get it.
25    And a number of other things.                                25      MR. DAYAN: No, no, let me make my objection.

                                                        Page 127                                                            Page 129
1       Q. Now, Mr. Borsos, to put this in context, SEIU           1       This letter, by definition, the back-and-forth
2   threatened the trusteeship in March; you respond by            2    between the academics, can have nothing to do with the
3   April.                                                         3    question of whether there was an improper movement of
4       I want to turn your attention to Exhibit 102 with          4    funds by the PEF. They'll be able to talk about this in
5   regard to the threatened trusteeship over the Patients         5    their affirmative defense.
6   Education Fund.                                                6       SECRETARY MARSHALL: Relate it to the --
7       A. Did you say 102?                                        7       MR. CHATTERJEE: This is SEIU's statements about the
8       Q. Exhibit 102.                                            8    Patients Education Fund that they've put at issue and
 9   A. Okay.                                                      9    that's how -- that's why it's very relevant.
10   Q. Now, Exhibit 102 is labeled "An Open Letter of             10      MR. DAYAN: Yeah, and they can assert that as an
11 Concern to andy stern from United Healthcare Workers            11 affirmative defense is our position.
12 West"?                                                          12     MR. CHATTERJEE: It's relevant to the issues they
13   A. Correct.                                                   13 put at the table and we're responding.
14     Q. What is Exhibit 102?                                     14    SECRETARY MARSHALL: All right. I'm going to let
15     A. This is a letter signed by approximately 100 of          15 you keep that up, but, try to keep it the relevances to
16 the leading journalists, authors, political activists,          16 the issue.
17 and educators who are committed to organized labor,             17    MR. CHATTERJEE: Q. Mr. Borsos, what did SEIU say
18 expressing their concerns about the potential of                18 in this letter about the Patients Education Fund and a
19 trusteeship with UHW.                                           19 possible trusteeship?
20    The last two paragraphs, I think, are the most               20    Q. So, this is a letter from Andy Stern to the
21 important, in my opinion:                                       21 educators. The last paragraph on the first page:
22    "We are writing to express our key concern about             22      Rather than take formal punitive action against UHW
23 SEIU's threatened trusteeship over its third largest            23 over the unlawful diversion of $3 million, nearly 20
24 (unintelligible). We believe that there must be always          24 percent of UHW's net assets to an outside fund Controlled
25 room within organized labor for legitimate and principled       25 by top UHW officers, SEIU filed a narrow lawsuit with the

                                                                                              33 (Pages 126 to 129)
                                                             Page 130                                                           Page 132
1    objective of returning UHW members -- I think there's a             1   Patients Education Fund -- whether there's anything
2    word missing -- money to the union's treasury as quickly            2   improper about transferring the funds.
3    as possible.                                                        3        This document is directly relevant to that because
4       Q. So, knowing everything that SEIU knew as of May               4   it's their admission that there's nothing wrong with what
5    2, 2008, did SEIU concede that their allegations of a               5   they're charging; and, I'd like to put that into
6    trusteeship were baseless?                                          6   evidence.
7       A. That's how I took it.                                         7       SECRETARY MARSHALL: All right.
 8      Q. Turn to Exhibit 105, please.                                  8       MR. HARRIS: They put in a lot of evidence what we
 9      A. Okay. I have it.                                              9   said in response their claims that were made, exactly, at
10      Q. What's Exhibit 105?                                          10   this time.
11    A. It's a letter from --                                          11       Now, we're not allowed to put what that said at this
12    MR. DAYAN: Objection. Again, this letter cannot                   12   time that indicates their evaluation of their PEF fund
13 possibly have any relevance on whether there was an                  13   claim?
14 improper movement of funds. It can only, potentially,                14       SECRETARY MARSHALL: Go ahead and put it in.
15 have relevance to the affirmative defense.                           15       MR. CHATTERJEE: Mr. Borsos, let's continue. What.
16    SECRETARY MARSHALL: What is the relation of this to               16      Q. Is Exhibit 105?
17 the Fund?                                                            17      A. It's a letter from about by SEIU appointed and
18     MR. CHATTERJEE: It relates directly to the Patients              18   elected officers to educators dated May 5, 2008.
19 Education Fund and what their basis is for them bringing             19      Q. And, in this letter, May 5, 2008, what do they
20 the charges that they've brought.                                    20   say?
21     MR. DAYAN: Let me give an example, maybe, to                     21      What does SEIU say about a possible trusteeship
22 illustrate our point, so they understood.                            22   regarding the Patients Education Fund?
23      Suppose we had a case where a Local union officer,              23      MR. ROTHNER: Secretary Marshall, I'm sorry. I'm
24 simply, who is an outstanding bargainer and an                       24   sorry. I'm sorry. I'd like to speak to an objection I'm
25 outstanding organizer;                                               25   making --

                                                             Page 131                                                           Page 133
1       Let's say we had a case where they stole union money             1      MR. CHATTERJEE: I believe there's been a ruling,
2    or embezzled it or sent it to their friends -- right?               2   your Honor --
3       Let's say we had that case and let's say that the                3      SECRETARY MARSHALL: All right.
4    Local union denied the charge, but also said there was a            4      MR. CHATTERJEE: -- and the ruling is that we can
5    longstanding political dispute and they wouldn't have               5   proceed with this exhibit after argument and I think --
6    cared about the embezzlement except for the political               6       MR. ROTHNER: I have an objection to the question.
7    dispute.                                                            7   I have an objection to the question.
8       It's very easy for lawyers -- this is very                       8       SECRETARY MARSHALL: All right, what's your
 9 disingenuous from the other side. It's very easy for                  9 objection?
10 lawyers to separate out the question:                                10     MR. ROTHNER: The question was, what did SEIU say to
11     Did he steal it?                                                 11 the educators?
12     If he did, were there other reasons for going after              12     SEIU didn't say anything to the educators.
13 the person than that he stole the money?                             13 Particular individual leaders of Local unions got
14     This cannot have anything to do with our charge --               14 together to write a letter; that's what was transmitted
15 which, admittedly, isn't stealing the money -- it's                  15 to the educators.
16 shifting it out of the members' control -- but, it's an              16     SECRETARY MARSHALL: Fair comment.
17 easy separation. And there's a continuing effort to                  17     MR. ROTHNER: And I would just like to say, UHW has,
18 circumvent that distinction and we just have to keep                 18 legitimately, asked for a fair process here. We've
19 objecting.                                                           19 cooperated. I know, Secretary Marshall, you have.
20    SECRETARY MARSHALL: Let me urge you to try and make               20     SECRETARY MARSHALL: Let us hear.
21 that distinction, if you can, and, keep it to the issue;             21     MR. ROTHNER: And we established an order of
22 and then you'll have to chance to put all this in at the             22 procedure and, every time we point out that they're
23 next hearing.                                                        23 veering off into their affirmative defense, and you make
24    MR. CHATTERJEE: Well, they've made it a issue                     24 a ruling, they come back with the very next question, or
25 whether or not there's anything improper about the                   25 the very next document, and get into their affirmative

                                                                                                 34 (Pages 130 to 133)
                                                         Page 134                                                               Page 136
 1   defense again. That's not a fair procedure.                    1        A. Yes, it did.
 2       SECRETARY MARSHALL: All right. Let me ask you all          2        Q. And then what happened?
 3   to try to observe that division of labor that we've made.      3        A. I don't understand your question.
 4      MR. CHATTERJEE: We're --                                    4        Q. Were jurisdictional hearings being held on that
 5      MR. HARRIS: We're trying to do that, Secretary              5    issue?
 6   Marshall. I think this witness would probably be               6        A. Jurisdictional hearings were then scheduled for
 7   finished if we haven't heard so much in the way of             7    May of 2008 and then July of 2008. And there was also a
 8   objections.                                                    8    resolution that was passed at the International union
 9        SECRETARY MARSHALL: Yes; and, of course, the              9    convention that -- the convention took the position that
10   letters are here and they say what they say, so, ask           10 healthcare workers in the state should be united into a
11   questions about the letter.                                    11 single long-term care Local union, which would have
12       MR. CHATTERJEE: Q. What's the point of this                12 mandated the transfer of 65,000 UHW members into 6434.
13   letter, Mr. Borsos?                                            13     Q. Could you turn to Exhibit 116?
14       A. The letter makes it clear that, at least from           14     A. 16 or 116?
15   48 appointed and elected leaders of SEIU, including            15     Q. 116.
16   Dennis Rivera, the head of SEIU healthcare, and George         16       A. 116? Yes.
17   Gresham, the head of the biggest Local in SEIU, and 46 of      17       Q. So, as of -- what is Exhibit 116?
18   their colleagues, that trusteeship, according to the           18       A. This is the resolution that was passed at the
19   letter, is only coming from UHW; in fact, the only talk        19 International convention in June of 2004 -- early June of
20   about trusteeship has come from UHW.                           20 2004 -- quite a contentious discussion, at least from our
21       I interpreted the letter that trusteeship was off          21 perspective, in which it says long-term care workers will
22   the table. It's off the table; and was surprised to            22 be -- in each state should be -- united into the same
23   learn from Mr. Hauptman's testimony, yesterday, that all       23 Local.
24   the evidence that they gathered on the PEF Fund had            24    Q. And what would be the effect on UHW if those
25   already been gathered by SEIU when they came into our          25 long-term care workers are removed from UHW?

                                                         Page 135                                                               Page 137
1    Local in August.                                               1       A. Our Local would be split in half.
2       There was no new evidence that came out of the PEF          2       And 65,000 of our long-term care members would go
3    Fund from this point forward; and they're saying to the        3    into a different Local and the remaining -- what is it --
4    world, trusteeship is off the table. I don't understand        4    85,000 members, their power would be severely weakend.
5    how it got back on the table -- at least related to the        5       Q. So, when did SEIU pass this resolution to go
6    PEF -- and we'd like to be able to talk about it.              6    forward with trying to dismantle UHW by removing 65,000
7       SECRETARY MARSHALL: Okay, talk about the PEF.               7    workers?
8       MR. CHATTERJEE: We also have to respond to their            8       A. It was early June -- June 1st or 2nd -- of
 9 witness yesterday. I believe it was their witness that           9    2008; one of the first days of the convention.
10 they voluntarily put on the stand, Mr. Mr. Amado David,          10      Q. And, at that time, the letters regarding the
11 talked about jurisdictional hearings regarding 65,000            11 trusteeship that you testified about earlier had already
12 members of UHW. That was their witness; and I would like         12 been written by SEIU saying the trusteeship is not
13 to respond to --                                                 13 warranted; is that correct?
14     SECRETARY MARSHALL: Go ahead.                                14      A. Correct.
15     MR. CHATTERJEE: What is that about?                          15      Q. Could you turn to Exhibit 115, please?
16     SECRETARY MARSHALL: Go ahead.                                16      SECRETARY MARSHALL: 150?
17     MR. BORSOS: What is which about?                             17      MR. CHATTERJEE: 115. Exhibit 11.
18     MR. CHATTERJEE: Q. What is this jurisdictional               18      MR. BORSOS: Yes, I have it.
19 hearing that Mr. Amado David talked about in his                 19      MR. CHATTERJEE: Q. What's Exhibit 115?
20 testimony yesterday?                                             20      MR. DAYAN: Objection.
21     A. There has been a move within SEIU to decimate             21      MR. BORSOS: It's an E-mail from Bill Reagan to to
22 UHW by removing 65,000 long-term care members and putting        22 Thomas Bruin (sic) dated June 5, 2008.
23 them under the leadership of Tyrone Freeman of 6434.             23    MR. DAYAN: Objection, objection, relevance; part of
24    Q. Did that move resurface in late 2007, early                24 the affirmative defense, at best.
25 2008?                                                            25      SECRETARY MARSHALL: What is the relevance of this

                                                                                                35 (Pages 134 to 137)
                                                        Page 138                                                        Page 140
 1   to the PEF?                                                    1   evidence to contribute. The letter can speak for itself
 2       MR. CHATTERJEE: It goes to the same issue that they        2   in the record. He can't add anything to it because he
 3   knew -- this is relevant, your Honor, because this is --       3   doesn't know what any of the participants said or did.
 4   we're going to use this to show this is a mission by           4       SECRETARY MARSHALL: You establish the foundation,
 5   SEIU, that their allegations of a trusteeship over the         5   if you can; otherwise, the letter speaks for itself.
 6   PEF fund are baseless. It's their initiative.                  6        MR. CHATTERJEE: Sure. Well, I think the letter has
 7         MR. DAYAN: Mr. Hearing officer, can we --                7   to be explained. I think it's very interesting that SEIU
 8         MR. CHATTERJEE: That's the relevance, your Honor.        8   is trying to stop this testimony going forward, your
 9         MR. DAYAN: There may be a way that -- I'll take up       9   Honor.
10   Mr. Harris' statement it was to be short and there wasn't     10    SECRETARY MARSHALL: If he wasn't involved in it,
11   much they were trying to do here.                             11 has no personal knowledge of it, how can he explain it?
12      If we can take a five-minute break and have the            12    MR. CHATTERJEE: Well, he can explain it because he
13   counsel, if you can show us the next four or five             13 understands the context of it.
14   documents --                                                  14    MR. DAYAN: You can read it in your closing
15      SECRETARY MARSHALL: In order to make this more             15 argument. It's not evidence unless someone --
16   orderly, why don't you all get together and see what you      16    MR. CHATTERJEE: Your Honor, I need my witness to
17   can do?                                                       17 explain to you the context --
18       MR. CHATTERJEE: Your Honor, I think it would be           18    SECRETARY MARSHALL: All right, establish the
19   faster just to proceed another five minutes.                  19 foundation; then, ask the question.
20       MR. HARRIS: Secretary Marshall, if Mr. Chatterjee         20    MR. CHATTERJEE: For the the record, the rules
21   were allowed to proceed, he could finish in five or 10        21 provided by SEIU stated that the formal rules of evidence
22   minutes. He would have finished long ago.                     22 do not apply to this hearing.
23      MR. DAYAN: Will you make a commitment that, in five        23     SEIU has not observed the formal rules of evidence.
24   minutes, he's off the stand, no matter what questions?        24 They've introduced hearsay. They've introduced documents
25      Well, then, don't be disingenuous.                         25 without foundation. We have not objected in our lines on

                                                        Page 139                                                        Page 141
 1       Okay, we need to break to have a discussion about          1   the rules provided by SEIU. They cannot change the rules
 2   the order of evidence.                                         2   here.
 3         SECRETARY MARSHALL: Do you need five minutes to do       3       MR. DAYAN: Let me briefly respond to that.
 4   it?                                                            4       SECRETARY MARSHALL: Wait, wait, wait, wait.
 5         All right, go on and make your case, but, try to         5       MR. DAYAN: There's a difference between saying the
 6   keep it relevant.                                              6   formal rules of evidence don't apply and that no
 7      MR. CHATTERJEE: I would just like to ask my                 7   standards of reliability apply. That's the opposite of
 8   questions, sir.                                                8   due process, if there's not minimal standards of
 9         SECRETARY MARSHALL: Yes.                                 9   reliability.
10         MR. CHATTERJEE: Mr. Borsos, what is Exhibit 115?        10       Unless this witness can testify that any of the
11         THE WITNESS: I'm sorry. I couldn't hear you.            11   people involved in deciding to issue this trusteeship
12    MR. DAYAN: I object.                                         12   notice saw the E-mail, understood the intent of the
13    MR. BORSOS: I couldn't hear. I'm sorry. I                    13   author of the E-mail, he can't contribute anything to it
14 couldn't hear counsel.                                          14   other than you could, as counsel, reading it or that
15         MR. CHATTERJEE: Mr. Borsos, what's Exhibit 115?         15   they've already done with the UHW by publishing it on
16         MR. BORSOS: I understand why SEIU doesn't want to       16   their website, which we know they have every right to do.
17 discuss this here, your Honor.                                  17       We're not trying to stop the public from hearing
18     So, what the E-mail is --                                   18   this letter. It's attached now to every -- it's linked
19     MR. DAYAN: Can I have a separate objection beyond           19   to everything they do.
20 it being proper for the affirmative defense, at most?           20       This is about a hearing. This is about a hearing
21     The other objection is basic foundation. Unless he          21   where we're trying to get evidence from people who have
22 can establish Mr. Borsos -- that he spoke with Mr.              22   some basis of knowledge and it's just beyond -- way
23 Reagan, spoke with any of the recipients of this letter,        23   beyond -- what's permissible.
24 has any knowledge about the intent of this letter, the          24      MR. CHATTERJEE: Your Honor, my five minutes have
25 author of the letter, he has no material, relevant              25   been used up by counsel talking.

                                                                                            36 (Pages 138 to 141)
                                                    Page 142                                                           Page 144
 1      I just want to proceed. Can I proceed and have my        1    take.."
 2   witness explain to you how this document came to be and     2       Q. My question to you, Mr. Borsos, based on your
 3   what this document means?                                   3    knowledge, was there a process that SEIU put in place to
 4       SECRETARY MARSHALL: All right, go ahead.                4    cause an implosion of UHW?
 5      The document is in, so, you can argue about that in      5       Q. Yeah, it was the movement of 65,000 --
 6   your brief. If you want to challenge, you can do that.      6       MR. DAYAN: Objection --
 7      MR. CHATTERJEE: Q. Mr. Borsos, this document, it         7       MR. BORSOS: -- long-term care members out of UHW
 8   says -- who is Bill Reagan?                                  8 and into 6434.
 9      A. Bill Reagan is a senior SEIU staff person.             9    MR. DAYAN: Objection to relevance to this whole
10    Q. And who is Thomas DeBruen(sic)?                         10 inquiry.
11    A. Thomas DeBruen(sic) is the International Vice           11      MR. HARRIS: Well, you used my five minutes.
12 President of SEIU. He was the president of 1199-P.            12      SECRETARY MARSHALL: All right, go ahead, and try --
13 He's, actually, the guy who hired me into the labor           13      MR. CHATTERJEE: Q. Is Mr. DeBruen a monitor right
14 movement back in 1993.                                        14 now?
15    Q. And who is Steven Lerner?                               15    A. He is.
16     A. Steven Lerner is on the International Executive        16   Q. Is Mr. Steven Lerner a monitor right now?
17 Board. He's a special assistant to Andy Stern.                17    A. He is.
18     Q. And in this E-mail Mr. Bill Reagan writes:             18   Q. A monitor of what?
19     A few thoughts: "Trusteeship would be difficult --        19    A. When the notice of trusteeship was announced,
20 it's like Iraq. Easy -- " and then -- "to get in" and         20 Stern -- President Stern -- notified us that he was
21 then a slog --                                                21 appointing monitors to come in and observe conditions in
22    Q. What did you take that to mean?                         22 the Local.
23    MR. ROTHNER: Objection, your Honor. We've been             23     He named Thomas DeBruen and Steven Lerner as two of
24 through this a number of times already.                       24 the monitors, to which we objected.
25     SECRETARY MARSHALL: Yeah, the real question is,           25      MR. CHATTERJEE: Now, the impression referred to

                                                    Page 143                                                           Page 145
 1   other than having it in, what is his understanding?          1   here, as described, to your knowledge, what happened
 2      How does that contribute to --                            2   after June 5, 2008 to affect this implosion plan by SEIU?
 3      MR. CHATTERJEE: Yes, that's what I'm trying to            3       MR. DAYAN: Objection.
 4   provide, your Honor.                                         4       MR. CHATTERJEE: I'm asking about his knowledge as
 5      SECRETARY MARSHALL: Yeah.                                 5   to what happened afterwards.
 6      MR. CHATTERJEE: What is your understanding of this        6       SECRETARY MARSHALL: What does this have to do with
 7   document?                                                    7   the PEF?
 8      MR. ROTHNER: Objection. His understanding from            8       MR. CHATTERJEE: It's the timing of these
 9   reading the document is no better than anyone else's         9 allegations and their concession as to their charges are
10   understanding.                                              10 baseless.
11      SECRETARY MARSHALL: All right, let's move on from        11    SECRETARY MARSHALL: You're saying there's a
12   there. Move on to the next question. The document           12 concession that the charges regarding PEF were not valid?
13   speaks for itself. Anybody can read it; therefore,          13    MR. CHATTERJEE: That's correct.
14   unless he has special -- was involved with it, other than   14    SECRETARY MARSHALL: All right, you can make that
15   having the letter in, it doesn't contribute much.           15 argument.
16      MR. CHATTERJEE: The document refers to implosion --      16    MR. ROTHNER: Secretary Marshall, that's an argument
17      MR. DAYAN: Objection --                                  17 that it's bad faith to pursue the charges; that's their
18      MR. CHATTERJEE: What was there --                        18 affirmative defense.
19      MR. DAYAN: Objection.                                    19      It still doesn't speak to whether they were -- what
20      MR. HARRIS: He hasn't asked the question yet. You        20 they're accused of with regard to the PEF.
21   can't object to the question. He hasn't finished the        21      SECRETARY MARSHALL: They're saying the charges
22   question.                                                   22 about the PEF were not valid -- about the PEF -- is that
23      SECRETARY MARSHALL: All right, go ahead.                 23 your argument?
24      MR. CHATTERJEE: The document reference to, "...an        24    MR. CHATTERJEE: That's right.
25   implosion would be a better outcome, but, what will it      25       And I'm going to have the witness explain what

                                                                                         37 (Pages 142 to 145)
                                                    Page 146                                                                    Page 148
 1   happened after this letter to bring us here to explain      1       And, in the same period that Annelle Grejada, who
 2   why these charges are baseless; and I just want to ask a    2    was an executive vice president, one of the six highest
 3   few more questions.                                         3    officers of SEIU, and appointed president by Andy Stern
 4      Q. So, my question is, Mr. Borsos -- I'm going to        4    of Local 721, was also put on paid administrative leave
 5   have to ask this question again.                            5    because of alleged financial improprieties in between
 6     After June 5, 2008, did anything happen to affect         6    then.
 7   the "implosion" of UHW?                                     7       And, then, on August the 25th, UHW received notice
 8      A. Yeah, the implosion.                                  8    of trusteeship hearings that led to this hearing today.
 9      Q. What happened?                                        9       Q. How many days after the exposure of Tyrone
10      A. Yes.                                                  10 Freeman did SEIU issue its notice of trusteeship that's
11      Q. What happened?                                        11 at issue here?
12      A. The implosion strategy was to move 65,000 of          12      A. 16 days.
13   our members into a new -- a 6434 run by Tyrone Freeman.     13      MR. CHATTERJEE: Your Honor, no further questions at
14   Their plans went up in smoke.                               14 this time.
15      Q. How did it go up in smoke?                            15      SECRETARY MARSHALL: All right.
16      A. Tyrone Freeman, on August the 9th, in an L.A.         16
17   Times article --                                            17                 CROSS-EXAMINATION
18      MR. DAYAN: Objection.                                    18      BY MR. DAYAN:
19      MR. BORSOS: -- that has been substantiated by            19      Q. Mr. Borsos, you testified in your
20   SEIU's charges against Tyrone Freeman that are published    20 direct-examination earlier this morning that UHW has a
21   or up on SEIU's website for gross misconduct in 6434,       21 bottom-up and not a top-down philosophy about governance
22   financial improprieties, the use of $10,000 of union        22 of the union; is that correct?
23   members' money for cigar bars, more than a $1 million       23      A. Yes.
24   that went into his family member's back pocket, and they    24      Q. And that UHW believes in transparency an
25   couldn't go forward in putting our members into that        25 informing the members about important decisions by the

                                                    Page 147                                                                    Page 149
 1   Local.                                                      1    officers; is that correct?
 2      MR. CHATTERJEE: Now, when did that article come          2       A. Yes.
 3   out?                                                        3       Q. And that UHW has a philosophy of bringing in as
 4        SECRETARY MARSHALL: Let me get this so we can move     4    many people in the senior staff and Executive Board into
 5   it along. It seems to me that you're getting into the       5    important decisions before they're made; is that correct?
 6   argument about the motives for establishing rather than     6       A. Yes.
 7   whether or not the PEF is -- something improper about the   7       Q. And that UHW isn't a Local union that's run by
 8   PEF itself.                                                 8    a small group of inside top officers in Oakland who make
 9    MR. CHATTERJEE: Your Honor, I have two more                9    the decisions, but, that those officers bring in outside
10 questions.                                                    10 people, all the EVP's, the Southern California ones, the
11    SECRETARY MARSHALL: Okay, go ahead. If you all             11 Northern California ones; isn't that correct?
12 want to object, I'll note it, but, let's get it done.         12    A. I don't believe that's what I testified.
13    MR. CHATTERJEE: Thank you, your Honor.                     13      Q. Well, also, it -- I'm not asking if you
14      Q. If you could turn to Exhibit 129?                     14 testified about it now --
15      A. Okay.                                                 15    A. I misunderstood your question then.
16      Q. 129 is an L.A. Times article entitled:                16      Q. Okay, isn't it a fact that would you agree with
17    "Union, charity paid thousands to firms owned by           17 me that UHW does not believe in making decisions through
18 official's relatives."                                        18 just a handful of top officers in Oakland deciding what
19    Is that the article you're referring to?                   19 to do on union matters; but, instead, tries to include
20    And, what's the date of that article?                      20 the whole group of administrative vice presidents?
21     A. It's August 9, 2008. 16 days later, after              21      A. It depends on what the issue is. We don't
22 Rickman Jackson, who is Tyrone Freeman's chief of staff,      22 incorporate every administrative vice president on every
23 was also alleged to have conducted financial                  23 single decision that gets made; it's not practical.
24 improprieties in the Michigan Local, to which he was          24      Q. Okay, so, would you try to do that on every
25 appointed ass the president by Andy Stern.                    25 important decision?

                                                                                             38 (Pages 146 to 149)
                                                          Page 150                                                             Page 152
1       A. Depends.                                                  1        A. A written budget?
2       MR. CHATTERJEE: Vague and ambiguous.                         2       Q. Yeah.
3       MR. DAYAN: Q. How do you define important?                   3       In advance of the May 18th to 19th meeting, was
4       A. I'm sorry?                                                4    there a written budget -- document -- that identified
5       Q. How do you define important?                              5    what the budget of this proposed PEF would be?
6       Would you agree with me that the entrustment of $6           6        A. No, not that I'm aware of.
7    million in union assets is an important matter?                 7       Q. Was there a business plan prepared in advance
 8     A. Yes.                                                        8 of the May 18th to 19th meeting that outlined what this
 9     Q. Okay, so, given that you believe that you                   9 PEF would do?
10 should include as many administrative vice presidents as          10     A. Not that I'm aware of.
11 possible on an important matter such as the transfer of           11    Q. Was there a memorandum from Sal Rosselli to
12 $6 million, can you tell me whether there were -- can you         12 anyone senior staff -- very top officers -- about the UHW
13 tell me whether, in advance of the May 18th to 19th               13 proposal to move $6 million of members' money to an
14 meeting, regarding the authorization to move $6 million           14 outside entity?
15 of union members' money to PEF, there were discussions            15    A. Not that I'm aware of.
16 among the administrative vice presidents, senior staff,           16   Q. So, it's a fact, then, that the UHW's leaders
17 and top officers of UHW?                                          17 left no paper trail of what they did before they proposed
18    A. I don't recall specific discussions about it.               18 this transfer of $6 million of union members' money out
19    Q. Did Sal Rosselli have an epiphany at the                    19 of the union into a new non-profit entity?
20 meeting, in the middle of the meeting, and say, I have a          20     A. That's actually not what the resolution is.
21 great idea, and just announced, right there, to move $6           21 The resolution says up to $6 million.
22 million out, or, was there some discussion of it before           22    Q. Isn't it a fact that the UHW's leaders left no
23 the meeting?                                                      23 paper trail about the decision to move up to $6 million
24    MR. CHATTERJEE: Objection, argumentative.                      24 of union members' money?
25    MR. DAYAN: You can answer.                                     25       A. It's in the minutes of the meeting where we

                                                          Page 151                                                             Page 153
1       MR. BORSOS: There's an objection.                            1    made a decision to move up to $6 million into the P.E. --
2       SECRETARY MARSHALL: Overruled. The objection is              2    whatever it's now called -- the PEF.
3    overruled. Go ahead.                                            3       Q. Yeah, and, my question is:
4       MR. BORSOS: Sorry. What was the question again?              4       In advance of that meeting, there was no paper trail
5       MR. DAYAN: Q. In advance of the May 18th to 19th             5    that would show how that proposal came to be formulated;
6    Executive Board meeting, did Sal Rosselli discuss the           6    isn't that a fact?
7    topic of moving up to $6 million of union members' funds        7       A. I don't know what you mean by a paper trail.
8    to an outside entity with the entire senior staff of the        8       Q. There are no documents that you are aware of
9    union?                                                          9    that describe anything like the proposal to move up to $6
10      A. I don't remember that.                                    10 million out of the UHW's treasury into a non-profit
11      Q. Did he discuss it with you?                               11 entity?
12     A. I actually don't remember whether we did. I                12    A. That's correct.
13 would imagine that I was involved in a discussion like            13      Q. So, the May 18th to 19th meeting then happened?
14 that. I can't remember a discussion like that.                    14      A. Pardon me?
15    Q. Isn't it a fact that, in advance of that                    15      Q. The May 18th to 19th meeting happened and, now,
16 meeting, there was no written record or discussion of the         16 I'm asking about what happened after the meeting.
17 merits or demerits of moving $6 million out of the                17      A. Okay.
18 union's treasury to a separate fund?                              18      Q. Well, on your direct testimony -- first of all,
19    A. I'm not following your question.                            19 you testified that the intent behind creating the PEF as
20    Could you repeat it?                                           20 expressed at the meeting -- at the meeting -- was to do a
21    Q. It's a simple question.                                     21 number of good things like work on healthcare reform; is
22    Was there -- I'll do it one by one.                            22 that correct?
23    A. Okay.                                                       23    A. Yes.
24   Q. Was there a written budget for the proposed                  24      Q. That one use of the fund that was discussed
25 PEF?                                                              25 would be of very good use in your mind was assisting the

                                                                                                39 (Pages 150 to 153)
                                                        Page 154                                                              Page 156
1    union in conducting its 2008 contract campaign?               1    healthcare reform campaign; isn't that correct?
2       A. Yeah. Excuse me. Do you remember the exhibit            2       A. It is.
3    number of the motion?                                         3       Q. So, these are all, you know, really good things
4       Q. Yes, it's Exhibit 1 of our exhibits.                    4    for the union to do; isn't that correct?
5       And, if you look at our exhibits, it's the white           5       A. For the union to do?
6    notebook, Volume I, Exhibit 1.                                6       Q. Yeah.
7       A. Okay. Go ahead.                                         7       In your opinion, it was a good thing for the union
 8    Q. Is it your recollection that, at the May 18th              8 to do?
 9 to 19th meeting, one of the purposes that the PEF would          9    A. Yes, it is.
10 be used for would be healthcare reform?                         10    Q. UHW publishes a magazine called "Unity"; is
11    A. The motion was very self-explanatory.                     11 that correct?
12    Q. I'm asking -- go ahead.                                   12    A. I'm sorry? Didn't hear the name.
13    A. This is my understanding of what the fund was             13    Q. UHW publishes a magazine called "Unity"?
14 created for, exactly as it's written:                           14    A. Yes, we do.
15     Educate healthcare workers and patients concerning          15    Q. And that's a quarterly magazine that's sent out
16 issues related to the healthcare crisis as well as other        16 to all members?
17 issues of importance to healthcare workers and their            17    A. I don't think it's even that frequently. It's
18 patients.                                                       18 two or three times a year.
19    Obviously, healthcare reform is part of the                  19    Q. Yeah.
20 healthcare crisis.                                              20    And, it's a means of keeping your members informed
21    Q. Okay, and, your counsel asked you what you had            21 about important developments in the union; isn't that
22 in mind as the potential purposes of this new fund; isn't       22 correct?
23 that correct?                                                   23    A. Yes.
24    A. Yes, he did.                                              24    Q. Isn't it a fact that not a single issue of
25    Q. And one of them was to educate around                     25 "Unity" magazine that was published to your members,

                                                        Page 155                                                              Page 157
1    healthcare reform and that's a good thing in your view;       1    after the PEF was authorized in May 18th to 19th of 2007,
2    isn't that correct?                                           2    said a word about the Patients Education Fund?
3       A. You added a couple of the things at the end of          3       MR. CHATTERJEE: Your Honor, he ought to be able to
4    that question.                                                4    provide all the Unity issues if he wants to refresh the
5       Q. No, I'm asking about your --                            5    witness' recollection.
6       A. I'm trying to answer the question that you              6       MR. DAYAN: Q. Do you recall --
7    asked.                                                        7       MR. CHATTERJEE: I think he should show the
8       So, educating around healthcare reform, I agree, is        8    magazines to the witness so he can refresh
9    a good thing.                                                 9    the witness' --
10    Q. And another purpose you identified that you had           10      MR. BORSOS: I can't remember every word of what was
11 in mind in May 18th to 19th, 2007, when this resolution         11 published in Unity magazine.
12 was adopted, was long-term thinking about your 2008 --          12    SECRETARY MARSHALL: Ask him what he knows about it.
13 carefully-planned contract campaign for the year 2008;          13      MR. DAYAN: Q. Right now, sitting here, do you
14 isn't that correct?                                             14 recall Unity ever discussing the issue of the PEF?
15    A. Yes.                                                      15      A. I couldn't tell you whether it did or whether
16    Q. And that would be a good use of money, in your            16 it didn't.
17 mind, to help you in any way with this very important           17     Q. Okay, well, we will introduce as an exhibit --
18 2008 contract campaign; isn't that correct?                     18 and you can put it at the end of our exhibits we already
19    A. Would using education dollars around a contract           19 have in the record -- one Unity magazine from Spring of
20 campaign? Yes.                                                  20 2008. We will put in the record the Unity magazines for
21      Q. Yeah.                                                   21 the period between the May 18th to 19th, 2007 Board
22      And, another thing I believe you said was that             22 meeting and the one that's already in the record, which
23 another purpose this could be put to that, in your mind,        23 is the Spring of 2008. I can distribute them to the
24 was also a very good purpose was to connect union               24 witness, to the hearing officer, and, to opposing
25 democracy issues to the contract campaign and to the            25 counsel.

                                                                                                 40 (Pages 154 to 157)
                                                        Page 158                                                               Page 160
1       SECRETARY MARSHALL: How are you marking these?             1       So, in addition to Unity magazine as a vehicle for
2       MR. DAYAN: Whatever the consecutive number after           2    communicating to your membership, you also have, and had,
3    our last number. It will be in the -- you know, give us       3    a website from the period May 2007 through the present;
4    one second to figure out how to properly designate it.        4    isn't that correct?
5       MR. ROTHNER: So, 76 will be Summer 2007;                   5       A. I believe that's right.
6       77 will be Fall 2007;                                      6       Q. And UHW also sponsors a website called "SEIU
7       And 78 will be Winter 2007.                                7    Voice". Is that correct?
8                     (SEIU Exhibit No.'s 76, 77 & 78              8       A. During this time period?
9                      marked for identification)                  9       Q. At any time from May 2007 through the present,
10    MR. CHATTERJEE: Is there a question pending?                 10 was there a period of time -- I'm not asking for you to
11    MR. DAYAN: We're all just getting the magazines              11 say it was the whole time.
12 numbered right so we all know what we're talking about on       12      A. I believe "SEIU Voice" was created in February
13 the record.                                                     13 of 2008.
14    Q. Just -- you've had a chance to look at Exhibits           14    Q. Okay, let's start with just the SEIU-UHW
15 76, 77, and 78, the three Unity magazines that Mr.              15 website.
16 Rothner just described?                                         16      Sitting here now, are you aware of any mention on
17   A. I just looked at the covers.                               17 that website of the Patients Education Fund?
18   Q. That's okay.                                               18      MR. CHATTERJEE: I can't hear the question.
19      Do you recognize these as Unity magazines?                 19      MR. DAYAN: Q. I'm asking Mr. Borsos if he knows
20      A. Yeah, they look like Unity magazines.                   20 whether he can dispute the fact that between May 2007 and
21    Q. Sitting right here, would you expect to find in           21 March 24, 2008, which was the date of the letter from
22 any of these three Unity magazines anything about the           22 President Stern, that you talked about in your direct
23 Patients Education Fund?                                        23 testimony, was there any mention of the UHW Patients
24    A. I don't know. I'd have to look through them to            24 Education Fund on the UHW official website?
25 see if it's actually in or not. I assume that you've            25    A. I don't know.

                                                        Page 159                                                               Page 161
1    done that.                                                    1       Q. Isn't it a fact that there wasn't a reference
2       Q. You assume what?                                        2    to the UHW-PEF on the SEIU voice website for the period
3       A. I assume that you've done that.                         3    from when it was created to March 24, 2008?
4       Q. Yeah.                                                   4       A. I don't know that either.
5       And, if I represented to you that you could look           5       Q. Isn't it a fact that, also, in the interest of
6    through all of these magazines 76, 77, and 78, and read       6    being an open union that communicates with your members
7    them cover-to-cover, you'll not find a mention of the         7    about important issues, you communicate with them through
8    Patients Education Fund?                                      8    means other than Unity and the two websites I referenced;
9       Would you have any reason to be surprised if I told        9    isn't that correct?
10 you that as a fact?                                             10      A. Yes.
11    MR. CHATTERJEE: Your Honor, I'm going to object. I           11      Q. Are you aware of any communication from UHW to
12 mean, the magazines speak for themselves.                       12 its members from the period between May 2007 and March
13    And the witness could sit here and read them all,            13 24, 2008 in which there was any reference to the Patients
14 but, that's not really a productive use of our time.            14 Education Fund?
15      SECRETARY MARSHALL: Yeah, let's don't do that.             15   A. Yeah. We put -- the practice in the union is,
16      MR. DAYAN: Well, I'm not asking --                         16 and has been, that, when the Executive Board minutes are
17      Q. I'm asking, would it be surprising to you if            17 approved, they're distributed to the union staff;
18 there was no reference to PEF in any of these three             18    And, in most cases, the union staff then gives those
19 editions of the Unity magazines?                                19 to the union stewards;
20    A. I -- well, I wouldn't have a reaction of                  20      And they're reviewed at the union steward Council
21 surprised or not surprised.                                     21 meetings.
22    Q. Okay, we'll put them in the record. They'll               22      Our Executive Board members also review Executive
23 speak for themselves.                                           23 Board members minutes at there facilities and the unions
24    Did I say that also the Spring of 2008 is in the             24 that they represent --
25 record already?                                                 25      Q. My question was, after that meeting --

                                                                                               41 (Pages 158 to 161)
                                                         Page 162                                                                Page 164
1       A. -- after the minutes were approved --                    1       Are you aware of any communication from UHW to the
2       Q. Fair enough.                                             2    general membership between the May 18th to 19th 2007
3       A. -- which would be June or July.                          3    meeting authorizing up to $6 million to be transferred
4       They would then go and actually -- I'm not even sure        4    through March 24, 2008?
5    when the next meeting was.                                     5       A. To the general membership?
6       After the minutes are approved, they're then                6       Q. To the general membership.
7    distributed to the staff;                                      7       A. Not in the way that you're describing it.
8       And the staff, generally, takes them to the steward         8    Again, the expectation is that it goes to steward Council
9    Council meetings;                                              9    meetings and the stewards talk to their constituents
10      And the Executive Board members take them to their          10 about issues as they come up.
11 steward Council meetings in the facilities and review the        11      Q. Okay, so, with that limitation, you're aware of
12 Executive Board minutes.                                         12 no other communications to the general membership; is
13    Q. Okay, we'll come back to that in a moment.                 13 that correct?
14      Do you recall a communication from the UHW to the           14    A. Not that I'm aware of.
15 general membership the way that Unity is sent to the             15      Q. And I would take it that, if you're not aware
16 general membership that mentioned PEF?                           16 of any communication other than the distribution of the
17      A. Not that I recall.                                       17 minutes that even mentioned PEF, you're also unaware of
18      Q. Isn't it a fact that there's not even a record           18 any communication to the general membership that promoted
19 of PEF being the -- minutes from the PEF meeting being --        19 PEF as a good idea?
20 seconded -- I mean being read and approved at the                20   A. If there wasn't communication about PEF, there
21 following meeting in June 2007?                                  21 wasn't communication about PEF, as you allege.
22      A. I'm sorry? I didn't follow the question.                 22      Q. So, this was a wonderful, noble education fund
23      Q. The June 2007 seven minutes are in the record.           23 that the union was committing up to $6 million to fund,
24      A. Okay.                                                    24 and it didn't rank as sufficiently important to UHW and
25      Q. They're in the first white binder, Exhibit 70.           25 its top leaders to carry out their philosophy of openness

                                                         Page 163                                                                Page 165
1       A. Your Volume I?                                           1    and membership inclusion and tell the members about it;
2       Q. Yeah, Volume I.                                          2    isn't that correct?
3       A. I'm sorry? What number?                                  3        MR. CHATTERJEE: Your Honor, that's just argument.
4       Q. Volume I. There's actually a tab called UHW --           4    It's argumentative. That's not a question; that's
5       A. Minutes?                                                 5    arguments.
6       Q. -- minutes. It's after the numbered tabs.                6        SECRETARY MARSHALL: You can go ahead and answer.
7    You'll have to turn to page 273.                               7        MR. DAYAN: It's cross-examination.
8       I direct your attention to about the fifth                  8        SECRETARY MARSHALL: Go ahead. You can go ahead.
9    paragraph -- 6th paragraph:                                    9        MR. BORSOS: Yeah, I don't think it's anything
10      M/S/P -- that means motion, seconded, and passes --         10 different than when we created the Shirley Ware Education
11 to approve the March 23rd and March 24th Executive Board         11 501(c)(3) in the '90's. I don't remember us making this
12 minutes with the corrected spelling of Gabe Krital's last        12 big broadcast that we had done it. We just kind of did
13 name.                                                            13 it. We committed up to $6 million to do this. We didn't
14      A. Okay.                                                    14 do it immediately, so --
15      Q. That is not a motion to second and approve the           15    MR. DAYAN: Q. Isn't it a fact that the Shirley
16 May 18th to 19th meetings; is it?                                16 Ware website is prominently mentioned on your website,
17      A. No, it's not.                                            17 even today -- excuse me -- the Shirley Ware Fund is
18      Q. No?                                                      18 prominently mentioned on your website to this day?
19      All right, all of the minutes are in the record and         19    A. Yeah, it is, now, seven years later, after it's
20 we can make argument about that. I'll just say that.             20 been created.
21      A. Yeah, my guess is that it's a typo because,              21      Q. Isn't it a fact --
22 usually, what we do at Executive Board minutes is, we            22       A. I don't think there was a website. I believe
23 approve minutes from the previous meetings.                      23 it was created in 1998. I don't believe that there was
24      Q. So, we talked about Unity magazine, the two              24 an immediate website created in 1998 when it was first
25 websites, and, let me just close this out.                       25 established, just like this fund. There's start-up time

                                                                                                42 (Pages 162 to 165)
                                                         Page 166                                                              Page 168
1    that's necessary. It's a beginning. It says up to $6           1    501(c)(3) in the hopes that we could create a training
2    million.                                                       2    center that would, effectively, upgrade the
3        So, I wouldn't be surprised, if we went back to            3    Taft-Hartley -- that's the way I understand -- I'm not an
4    1998, there's not a website around Shirley Ware;               4    expert on this -- if they go into the 501 and there are
5        There's not a communication other than what happened       5    other dollars, if they're employer-contributed through
6    with the membership in the minutes;                            6    the Taft-Hartley, I know enough about it that we thought
7        There's nothing in the Unity.                              7    that the same thing might be possible around the Patients
8        I don't know. It's just -- I don't know. I                 8    Education Fund.
9    can't -- I can only speculate.                                 9       MR. DAYAN: Okay, I have a simple question:
10     Q. So, your speculating that, when you committed             10      Q. Do you know whether, when the Shirley Ware Fund
11 $6 million to the Shirley Ware Fund -- and, by the way,          11 was set up, the union, initially, authorized the
12 is that a joint union-employer funded?                           12 contribution of a $1 million or more of union funds into
13     A. It is now.                                                13 that Shirley Ware Fund?
14     Q. When you first set it up, was it solely                   14      MR. CHATTERJEE: Your Honor, it's been asked and
15 union-funded?                                                    15 answered.
16     A. When we set it up -- in fact, it's one of the             16    MR. BORSOS: I, actually, don't remember.
17 things that we hope to do in this round of bargaining.           17      MR. DAYAN: Q. So, if you don't remember that, you
18     When we establishd the Shirley Ware 501(c)(3), it            18 don't remember whether the union communicated to its
19 was to be able to draw down grants and other dollars from        19 membership about whatever amount was contributed; do you?
20 places that we couldn't collectively bargain and upgrade         20      A. I think I already said that I don't remember.
21 the fund to compliment the 501(c)(3) that was part of the        21      Q. Okay.
22 Shirley Ware Center.                                             22      A. I don't remember -- the same as we treated the
23     We anticipated, possibly, doing the same thing with          23 creation of the Patients Education Fund -- I don't
24 this 501(c)(3). There would be seed money from the union         24 remember or don't -- we did this blanket announcement
25 to get the thing started. We would then collectively             25 that we had created the Shirley Ware Education Center.

                                                         Page 167                                                              Page 169
1    bargain where we could Taft-Hartley funds -- patient           1       Q. So, what I'm hearing now is that, on more than
2    advocacy funds is what we call them -- across the              2    one occasion, the union's officers decided to move a $1
3    bargaining table, so there's grant and foundation monies       3    million or more of union monies, without telling the
4    in other venues.                                               4    general membership, that that decision had recently be
5       Q. We'll get to that in a minute. My question to            5    made; isn't that a fact?
6    you is:                                                        6       MR. CHATTERJEE: That's not a question.
7       When the Shirley Ware Fund was set up, initially,           7       MR. DAYAN: Sure, it is.
8    was there, initially, an authorization for the union to        8       MR. CHATTERJEE: What's the question?
9    contribute more than a $1 million of its own funds to the      9       SECRETARY MARSHALL: The question is, is that a
10 Shirley Ware --                                                  10 fact?
11    A. I actually don't remember.                                 11      MR. DAYAN: Yeah.
12    Q. So, you're speculating about the comparison?               12      Q. Isn't it a fact that you are aware of, now, two
13    A. No, no, actually, I'm not speculating about the            13 occasions on which the UHW Executive Board decided to
14 comparison.                                                      14 move a $1 million or more of union funds out of the union
15      We understood when we created --                            15 and did not advise the general membership of that
16      Q. I asked a yes-or-no question.                            16 decision?
17      MR. CHATTERJEE: Your Honor, he's badgering the              17   MR. CHATTERJEE: That misstates testimony.
18 witness.                                                         18      MR. BORSOS: No, that's not, actually, what I said.
19     MR. BORSOS: Can I answer the question?                       19      What I said is, I don't remember how much money we
20     MR. CHATTERJEE: I would just like my witness to be           20 distributed, initially, to the Shirley Ware Education
21 able --                                                          21 Center.
22     SECRETARY MARSHALL: Go ahead.                                22      And the motion in front that is passed by the
23     MR. CHATTERJEE: It's completely out of line.                 23 Executive Board authorized up to $6 million --
24     MR. BORSOS: When we created the Shirley Ware                 24      MR. DAYAN: Q. The motion on the Shirley Ware Fund?
25 Education Center, it was for labor -- to create a                25      A. The motion on the Patients Education Fund

                                                                                               43 (Pages 166 to 169)
                                                          Page 170                                                             Page 172
1    authorized up to $6 million.                                    1       Q. And, isn't it a fact that no training sessions
2       Q. Okay, we'll move on.                                      2    were conducted by PEF, between May 18th to 19th, 2007,
3       Isn't it a fact that, after PEF was created, no one          3    and March 24th, 2008?
4    at UHW or PEF reached out to potential contributors to          4       A. Yeah; similar as to what happened with the
5    see if they would make a contribution to the PEF?               5    forums. We had discussions about the potential of
6       A. We had a discussion across the bargaining                 6    convening conferences on labor democracy in March or
7    table --                                                        7    April and May around that.
8       Q. Let's start with the first three months after             8       But, again, we -- because of the controversy around
9    the PEF was created --                                          9    the Fund, we didn't spend money after -- I want to say
10      A. I'm sorry? It's hard to hear.                             10 it's April the 7th or so -- somewhere in that
11      Q. Okay, yeah, the sound isn't --                            11 neighborhood.
12      Isn't it a fact that, within the first three                 12      Q. And, isn't it a fact, also, that no conferences
13 months -- let's start with that.                                  13 were held or sponsored by PEF between May 18th 2007 and
14      After the PEF was created in May of 2007, no one at          14 March 24, 2008?
15 UHW or PEF reached out to potential contributors to make          15      A. Yes.
16 a contribution to the PEF?                                        16      Q. And, isn't it a fact that PEF never created a
17      A. I believe that's true.                                    17 website for itself between May 18, 2007 and March 2008?
18      Q. And, isn't it a fact that, in the next three              18      A. Yeah. As I've said, we really didn't get it
19 months after that, no one at UHW or PEF reached out to            19 off the ground.
20 potential contributors to make a contribution to the PEF?         20      Q. And I asked about whether UHW reached out and
21    A. I believe that's true.                                      21 communicated through its magazine, website, or other
22      Q. So, we're now in November of 2007?                        22 means of communication to the general membership about
23      A. That was in October; maybe we're counting                 23 PEF.
24 differently.                                                      24      Let me ask you the same thing about PEF, itself.
25      Q. Are you aware of anyone at UHW or PEF reaching            25      Did PEF, itself, ever do anything to advertise

                                                          Page 171                                                             Page 173
1    out to potential contributors to make a contribution to         1    itself either to the members of UHW or to the general
2    the PEF between October 2007 and March 24, 2008?                2    public?
3       A. No. The fund hadn't gotten off the ground in              3       MR. CHATTERJEE: Your Honor, I assume he's asking
4    the way that we had hoped it had by March of 2004.              4    about the witness' knowledge. The witness is not on the
5       Q. And, isn't it a fact that, no one wrote a grant           5    PEF Education Fund Board and never was.
6    application to try to obtain money from a foundation,           6       MR. BORSOS: Correct. I wasn't on the Board.
7    government agency, or anyone else, for PEF, in that same        7       MR. DAYAN: Q. Well, you can answer for yourself.
8    period of time, from May 2007 through March 24, 2008?           8    You're not aware of them doing that?
9       A. The question is about writing a grant?                    9       A. I'm not aware.
10      Q. Yes.                                                      10      Q. Okay, isn't it also a fact you're not aware
11      A. I'm sorry, I'm --                                         11 that PEF generated any research papers between May 2007
12      Q. Yes, writing a grant application?                         12 and March 24, 2008?
13      A. That's correct.                                           13      A. Again, I'm not on the PEF Board.
14      Q. And, isn't it a fact that no one at UHW or PEF            14      Q. Let me direct your attention to exhibits --
15 wrote to, or communicated with, any other union between           15 let's start with Exhibit 67 of your exhibits -- not
16 March -- between May 18th 2007 and March 24, 2008 to              16 ours -- of the UHW exhibits.
17 solicit another union to make a contribution to the PEF?          17      A. 67? Did you say 67?
18     A. Yes, that's true.                                          18      Q. Before I ask you about 67, ask you -- I believe
19      Q. And, isn't it a fact that no classes or                   19 you just testified that PEF really didn't get off the
20 seminars were held by the PEF between May 18th and 19th,          20 ground by March 24, 2008; isn't that correct?
21 2007, and March 24th, 2008?                                       21    A. Correct.
22      A. Yeah, the seminars that we had planned were the           22      Q. You were --
23 ones we described in April; and, by the time we -- the            23      A. There was some activity, but, certainly, not
24 correspondence started going back with Stern, we didn't           24 what we hoped it to be.
25 want to use PEF money to be able to do that.                      25      Q. You were a member of the Executive Board of UHW

                                                                                                44 (Pages 170 to 173)
                                                          Page 174                                                                 Page 176
1    in early 2008; isn't that correct?                              1    contract campaign, again, with a kickoff on February the
2       A. In early 2008, yes.                                       2    20th.
3       Q. Well, if PEF didn't get off the ground --                 3       There was everything else that was going on
4    hadn't gotten off the ground by February of 2008 -- why         4    legislatively that we talked about in California, etc.
5    did the Executive Board of UHW decide to move another $2        5       Q. And the contract campaign, you've already
6    million in union members' money to the PEF?                     6    testified, was very important to the UHW; isn't that
7       MR. CHATTERJEE: Misstates the money. Another $2              7    correct?
8    million? I don't know what he's talking about.                  8       A. Yes.
9       MR. DAYAN: Q. Well, you're aware that $1 million             9       Q. And, isn't it a fact that, shortly after you
10 was transferred to the PEF shortly after the PEF was              10 made a decision to move $2 million to PEF, to assist PEF,
11 created in May 2007; isn't that correct?                          11 somehow, in helping you with the contract campaign, you
12      A. You'd have to show me what you're referring to.           12 didn't notify the general membership of that $2 million
13 I don't remember.                                                 13 transfer either?
14      Q. You don't remember whether $1 million was moved           14      A. You're stringing a lot of questions -- or a lot
15 shortly after it was created?                                     15 of clauses. I'm not sure exactly what you're asking me.
16    A. I know there's money that moved at some points.             16 I'm sorry.
17 If you could show me, help me refresh my memory where it          17      Q. You don't remember the date, but, you do
18 moved, I'd be happy to look at it.                                18 remember the $2 million dollars was moved?
19   Q. Okay, I might come back to that later.                       19    A. I do.
20      A. Okay.                                                     20      Q. And I'm asking you if you are aware of any
21      Q. So, let me just get this straight:                        21 communication from UHW to its general membership after
22      You do remember what was said about PEF in the May           22 that $2 million was moved and before March 24, 2008?
23 18, 2007 meeting that occurred some 16 months ago; isn't          23      A. No, I don't recall that.
24 that correct?                                                     24      Q. Now, let's talk about Exhibit 67 -- your
25    A. I'm not sure. You're packing a lot of things                25 Exhibit 67 -- UHW's.

                                                          Page 175                                                                 Page 177
1    in these questions.                                             1       This is a document that you testified about on your
2        Are you asking do I remember what happened in the           2    direct testimony; isn't that correct?
3    May meeting?                                                    3        A. It is.
4       Q. Yes.                                                      4       Q. And you described this as a research paper by
5        A. Yes. I testified to that.                                5    UHW about the California healthcare crisis?
6       Q. You do remember that -- you have no                       6        A. Correct.
7    recollection of the follow-up decisions to move $1              7       Q. Isn't it a fact that, if PEF would be doing
8    million and then $2 million to the PEF?                         8    anything, it would be the vehicle for publishing a
9        A. I know that money moved. I don't know exactly            9    research study like this?
10 when the dollars went because, what you asked me, if I            10     A. Yeah, that's what we envisioned PEF evolving
11 heard you correctly, is, shortly thereafter.                      11 into is the kind of organization that could put out
12    I don't know whether the money moved in May;                   12 policy papers like this.
13    I don't know whether the money moved in June;                  13     Among the things that we looked at is the South Bay
14    I don't know whether the money moved in July.                  14 Labor Council here in the San Jose area has a 501(c)(3)
15    I don't have that recall. I'm sorry.                           15 research part that oftentimes publishes papers comparable
16    Q. Do you recall why -- whenever they were moved,              16 to this. This is what we hoped PEF to become.
17 do you recall why the $1 million was moved?                       17     Q. Okay, so, let me see if I understand your
18    A. I don't.                                                    18 testimony.
19    Q. Do you recall why the $2 million dollars was                19    You're here today to say that, in May 2007, the UHW
20 moved?                                                            20 Executive Board had a good idea to:
21     A. The $2 million dollars was to -- the $1 million            21      Set up a new fund;
22 and $2 million in combination, which, I guess, was there          22      Move up to $6 million to the fund for education
23 around February -- February -- was to put the seed money          23 around healthcare reform issues;
24 to really have the Fund get off the ground.                       24    That $3 million was then moved out of UHW into the
25     It was also in anticipation of us beginning our               25 fund by -- and I'll represent to you there's not going to

                                                                                                 45 (Pages 174 to 177)
                                                           Page 178                                                            Page 180
1    be a dispute -- by February, 2008.                               1       If someone -- if a rank-and-file member of Local 399
2         A. Okay.                                                    2    or Local 250, back in 2004, thought that the merger was a
3         Q. And, that, after having done all of that, a              3    great idea, but, wanted to nominate someone to run
4    project that would seem to be what someone reading those         4    against Sal Rosselli, or the other two people, would
5    minutes would think PEF is about, wasn't done by PEF.            5    there have been a vehicle for them to do that?
6         That's your testimony?                                      6       A. I don't believe that's the case.
7         A. Yes.                                                     7       Q. So, it wasn't a real union election in the
8         Q. Okay.                                                    8    sense of opposing slates having a chance to compete for
9         A. And the reason is that we have a -- we have              9    office; isn't that a fact?
10 been having some issues being able to fill positions in            10      A. The way that you're describing it, yes, that's
11 the UHW research departments. So, filling those                    11 true.
12 positions, in addition to hiring the kind of staff that            12      Q. Okay.
13 PEF would require to be able to do reports like that, to           13      A. But, I also think that, to make sure that there
14 get the Fund up and running, you'd have to be able to go           14 was an opportunity for members to express their point of
15 and hire staff to be able to do that. We weren't able to           15 view that, rather than have -- if you give me one second,
16 do that.                                                           16 I'd like to look, because, I think that we set -- the
17        Q. So, if I'm hearing you right, was there a                17 Constitution set -- it that the officer elections would
18 meeting between you and anyone else where you said, hey,           18 be one year post-merger rather than the three years that
19 we're going to publish this April 2008 -- exhibit -- you           19 a union's entitled to do before they hold elections to
20 know, Exhibit 67 -- and there was a discussion where you           20 give members, exactly, that opportunity to do that --
21 deliberated between PEF versus UHW?                                21    Q. Understood.
22    A. No.                                                          22      A. -- at a time that was responsive to members who
23        Q. Okay, thank you.                                         23 may run against the officers of the union.
24        Are you aware of PEF posting any listings or doing          24   Q. Understood. I just want the record to be clear
25 anything to recruit employees of PEF?                              25 that we agree that this this document had three initial

                                                           Page 179                                                            Page 181
 1      A. No. There hadn't been decisions made at that               1    interim officers, and that that was part of the whole
 2   point to start hiring staff yet.                                 2    package being voted on.
 3        Q. Let me direct your attention to UHW's Exhibit            3       This wasn't an officer election in the ordinary
 4   2.                                                               4    sense; isn't that correct?
 5         A. Okay.                                                   5       A. Oh, I would agree with that.
 6     Q. This is the Constitution Bylaws Unification                 6       Q. Okay.
 7   Agreement between SEIU 250 and SEIU Local 399?                   7       Part of what was being voted on was the bylaws that
 8      A. Yes, it is.                                                8    would govern the newly merged union; isn't that correct?
 9         MR. CHATTERJEE: I'm sorry.                                 9       A. Yes.
10         What exhibit are we on?                                    10      Q. Let me direct your attention -- the print on
11         SECRETARY MARSHALL: Your No. 2.                            11 the bylaws is awfully small -- at least as it's
12         MR. HARRIS: Our 2?                                         12 reproduced here.
13         MR. DAYAN: Q. I believe you testified that you --          13      Let me direct your attention, then, to Article 21
14   excuse me -- I believe that you testified that Sal               14 and let's get an easier-to-read version of it, but --
15   Rosselli was elected to the presidency of the newly              15 let's start with your Exhibit 2, just to make sure we're
16   merged UHW back in approximately 2004; is that correct?          16 talking about the same thing. It's on page 8, to speed
17        A. Yes.                                                     17 this up.
18        The way that I understand that this vote happened           18      A. Okay.
19   is, people voted on the entire package.                          19      Q. And there are three columns of print --
20      The Unification Agreement between Local 250 and 399,          20      A. You said Article 21?
21   under the leadership structure of unification it says,           21      Q. Yes.
22   SEIU Local Executive Officers, and, it lists Sal Rosselli        22      A. Yeah, I see it.
23   as the president; and that was part of -- this was the           23      Q. Okay.
24   booklet that people voted on to accept merger.                   24      SECRETARY MARSHALL: Article 22 -- isn't it -- did
25        Q. Yeah.                                                    25 you say 22?

                                                                                                46 (Pages 178 to 181)
                                                              Page 182                                                             Page 184
1       MR. DAYAN: I'm talking about Article 21, Property                1       Q. There was no discussion at the May 18th to 19th
2    Rights of Members.                                                  2    Executive Board meeting about whether the proposed
3       SECRETARY MARSHALL: Okay, got it.                                3    transfer of up to $6 million in UHW member monies to
4       MR. DAYAN: Okay.                                                 4    another entity would violate Article 21?
5       Q. The members had that before them and voted on                 5       A. Correct. We believed we were acting with
6    that as well; isn't that a fact?                                    6    entire proper purposes.
7       A. Yes.                                                          7       Q. But, did you discuss Article 21?
8       Q. The members voted to make a set of bylaws that                8       MR. CHATTERJEE: That's been asked and answered.
9    would include Article 21?                                           9       MR. BORSOS: No.
10      A. Correct.                                                      10      MR. DAYAN: No? Okay.
11      Q. Okay, now, there's an easier to read version.                 11                    (Recess taken)
12      A. I can see it, so --                                           12      SECRETARY MARSHALL: We're back on the record. The
13      Q. Oh, you can read it?                                          13 hearing will continue.
14      A. Yeah.                                                         14      MR. DAYAN: Q. Mr. Borsos, you testified that one
15      Q. Well, if you can read it -- I will try my best                15 of the values of UHW is of the bottom-up decision-making;
16 to read it. My glasses aren't good enough prescription.               16 isn't that correct?
17 Let me read it. I think I can.                                        17      A. Yes.
18      The title to all property funds and other assets of              18      Q. If $6 million of member money is being
19 this union shall, at all times be vested in the Executive             19 entrusted to 10 individuals, would you agree with me that
20 Board for the joint use of the membership of this union               20 it's important to have a transparent process for
21 except for real property which may be held by a                       21 determining who those individuals are?
22 corporation created pursuant to -- I believe -- Internal              22    A. You're asking me that as a hypothetical?
23 Revenue Code Section (501(c)(2), but no member shall have             23      Q. Yes.
24 any severable property right -- title -- propriety right,             24      A. Can you restate the question?
25 title, or, interest therein.                                          25      Q. You testified that, you know, you're a student

                                                              Page 183                                                             Page 185
1       At the May 18th to 19th, 2007, meeting, at which                 1    of labor history and that your union has a philosophy of
2    there was a decision to authorize the transfer of up to             2    transparency and democracy and bottom up decision-making;
3    $6 million outside of the UHW to PEF, was there any                 3    isn't that correct?
4    discussion or attention paid to Article 21 of your bylaws           4       A. Correct.
5    that the members voted on in 2004?                                  5       Q. And I'm asking you, if $6 million of union
6       A. Not that I recall.                                            6    members' money is going to be put under the -- is going
7       I don't think our Constitution and bylaws prohibits              7    to be entrusted to a group of 10 individuals, would you
8    a donation to a 501(c)(3).                                          8    agree with me that it's important that there be a
9       Q. Would your Constitution and bylaws prohibit                   9    transparency process for determining and notifying the
10 moving $3 million to an entity that carried out union                 10 membership of who those individuals are?
11 business, but, only with a smaller group of officers than             11      A. Well, the motion that was passed on May 19th
12 the Executive Board?                                                  12 authorized up to $6 million --
13    A. Yeah, that sounds like -- I can't make a                        13    Q. Yeah, you've said that.
14 conclusion of law. I'm not a -- I couldn't make that                  14      A. -- and $6 million was never transferred, so,
15 determination.                                                        15 I'm not sure what the point of your question is.
16      Q. And there was no effort at the May 18th                       16    Q. Well, I'll break it down into smaller parts.
17 meeting, that you recall, to try to make an effort to                 17      A. Okay.
18 analyze that?                                                         18      Q. You have testified, I think, repeatedly, now,
19      A. I know there wasn't a effort -- I'm sorry --                  19 that it's up to $6 million and not $6 million?
20 what was the question again?                                          20      A. Correct.
21   Q. And there was no effort at the May 18th-19th                     21      Q. Isn't it a fact that the authorization of up to
22 meeting to analyze whether what you were proposing would              22 $6 million means that the Executive Board wouldn't have
23 create an issue or violate Article 21?                                23 to come back after, say, $1 million was transferred to
24    A. Hate to do this. Can you repeat that one more                   24 re-authorize the next $5 million?
25 time?                                                                 25      A. Would or would not?


                                                                                                     47 (Pages 182 to 185)
                                                           Page 186                                                            Page 188
1       Q. Would not.                                                  1       A. That's the way I understood it.
2       A. They would not.                                             2       If you're asking, do dollars get transferred in an
3       Q. So, the Executive Board was authorizing                     3   organization run by 10 -- maybe I misunderstood -- 10
4    transfer of up $6 million, meaning, after that decision,          4   individuals?
5    Sal Rosselli, himself, could make the decision to move            5       All those individuals are supposed to be identified
6    the next $5 million after the first $1 million; isn't             6   as opposed to the transfer of dollars from one
7    that correct?                                                     7   organization to another organization.
 8    A. I'm not sure I agree with that.                               8      Q. Yeah, but, let's take any organization that's
 9    Q. Where would it be in your Constitution that                   9   going to have $1 million of money coming from other
10 would determine how a $6 million authorization could be            10 people; right?
11 spent by an officer without going back to the Board?               11    You would agree that, if there's a fund and there's
12    A. I'd have to look at the Constitution. I'm not                12 10 trustees of that fund, it's not those trustees'
13 sure it's covered by the Constitution.                             13 individual money.
14    But, I don't know that it's a decision that would be            14    You would agree that; wouldn't you?
15 made by any single individual in the union.                        15    A. If you're asking -- if I understand you --
16    Q. It certainly would have to be made by the                    16 clarify your question, again. I'm sorry, but, you pack a
17 Executive Board which has rank-and-file members; isn't             17 lot of subordinate clauses in your question. It's hard
18 that a fact?                                                       18 to follow exactly what the point of your question is.
19   A. Yeah, it's true, the Board has rank-and-file                  19     Q. Yeah. You understand the question perfectly.
20 members; correct.                                                  20     A. No, I don't.
21   Q. And it's true that that Board wouldn't have to                21     MR. CHATTERJEE: Why don't you ask the question?
22 authorize the first $5 million after the first $1                  22     MR. BORSOS: No, I don't. I wouldn't have asked you
23 million?                                                           23 to repeat it.
24    A. Would or would not?                                          24     MR. CHATTERJEE: I want to say, for the record,
25      Q. Would not.                                                 25 that's uncalled for. It is unprofessional.

                                                           Page 187                                                            Page 189
1       A. By the motion that was passed, the motion was              1        MR. DAYAN: We don't need any lectures from you.
2    to authorize up to $6 million.                                   2       Q. Mr. Borsos, you know, I appreciate trying to
3       Q. Would you agree with me that, if $1 million                3    answer, exactly, the question that you're asking, you
4    were to be entrusted -- $1 million of union members dues'        4    know, in a room full of 1,500 people --
5    money was to be entrusted to a group of 10 individuals --        5        A. I want to make sure I understand the question
6    that there be a transparency process for determining who         6    that you're asking --
7    those individuals are and advising members of who those          7       Q. Fair enough.
8    individuals are?                                                 8        A. -- and don't appreciate getting criticized for
9       A. Not necessarily.                                           9    trying to --
10      Q. Would you agree that there be a process of                 10      Q. Let's take it piece by piece.
11 informing the members who would be entrusted with $1               11      Do you understand what it would mean for a union to
12 million of their money?                                            12 have a plan, or an idea, to contribute $10 million to an
13      Would you agree that there, at least, be a process            13 entity where the monies will be entrusted to 10
14 in place to identify 10 individuals worthy of the trust            14 individuals?
15 of the $1 million?                                                 15       A. You're talking hypothetically again?
16      A. Not necessarily.                                           16      Q. Yes.
17      MR. CHATTERJEE: Your Honor, these are all                     17       A. I guess I understand the premise of your
18 hypotheticals that are --                                          18 hypothetical.
19      MR. DAYAN: Q. Let's say we contributed SEIU-5                 19    Q. You do understand that?
20 funds as part of the Wal-Mart campaign --                          20    And what I'm asking you --
21      A. Would we have to identify all of the officers              21    MR. CHATTERJEE: Your Honor, I think we need an
22 of the 501(c)?                                                     22 admonition here. He's badgering the witness.
23     Is that what you're asking?                                    23     MR. DAYAN: No. He testified about the UHW's
24      Q. That's not my question.                                    24 openess and transparency. There's only going to be two
25      My question --                                                25 to three questions along this line.

                                                                                                   48 (Pages 186 to 189)
                                                              Page 190                                                               Page 192
1        SECRETARY MARSHALL: Go ahead, make it simple.                   1    around the expenditures and other decisions being made by
2        MR. DAYAN: Okay.                                                2    the union. That's the purpose of the Executive Board
3       Q. Is your philosophy -- under your philosophy of                3    being there.
4    transparency, would it be important that there be a means           4       The role of having rank-and-file members on the
5    of allowing the members to know who those 10 individuals            5    Executive Board is to have their co-workers -- to be able
6    are if the union, itself, was responsible for picking the           6    to explain to other co-workers, exactly, what's happening
7    10 individuals?                                                     7    at the Executive Board.
8        A. You're still talking about this as a                         8       And they should do that with decisions about
9    hypothetical?                                                       9    bargaining or expenditures around -- that's one of the
10      Q. Yes, I am.                                                    10 responsibilities of our Executive Board members.
11       A. Okay, so, if I understand your -- well, I hate               11    Q. And my question to you was just a yes-no.
12 to do this to you, and, at the risk of being criticized,              12      At that meeting, was there a specific instruction to
13 could you please repeat your question?                                13 those 90 or so Executive Board members to go out and
14      Q. Is it -- in your view, is it consistent with                  14 spread the word that the union had just created this new
15 the principles of transparency that if a union is to move             15 Fund and that $6 million of monies were being moved to
16 $1 million of its members' monies to a fund where it is               16 this new Fund?
17 entrusted to 10 individuals, and the union is going to                17      A. I don't remember.
18 choose those 10 individuals, that the members know who                18      But, with regard to decisions of the Executive
19 those individuals are?                                                19 Board, it's the expectation that the Executive Board
20       MR. CHATTERJEE: That's an incomplete hypothetical.              20 members talk to their co-workers what happens at the
21       MR. BORSOS: Well, at the risk of being                          21 Executive Board meeting.
22 argumentative, the members are the union and so in this               22    This would be no different.
23 situation --                                                          23      Q. Okay, and, you testified, earlier, that a
24       SECRETARY MARSHALL: Let us hear what he's got to                24 principal means of members learning about what happens
25 say.                                                                  25 with the union is the distribution of the minutes of the

                                                              Page 191                                                               Page 193
1         MR. BORSOS: -- rank-and-file members of the                    1    Executive Board meeting; is that correct?
2    Executive Board did not -- were able to volunteer to be             2        A. No.
3    part of the Fund. They were not hand-selected by the                3       Q. It's an important means of informing the
4    union --                                                            4    members?
5         MR. DAYAN: But, that's not the answer to my                    5        A. It's a means.
6    question.                                                           6       Q. It's an unimportant means?
7         MR. CHATTERJEE: I don't think the witness was                  7        A. No, it's a means; it's one of many means.
8    finished answering the question.                                    8       Q. Okay, would you agree that it's important that
9         MR. BORSOS: Maybe we have to define who the union              9    the official minutes be accurate and inform the members,
10 is. The members are the union.                                        10 accurately, of what happened in an Executive Board
11     MR. DAYAN: Q. There are 90 members of your                        11 meeting?
12 Executive Board; right?                                               12    A. I would agree that the Board minutes of any
13     A. Correct.                                                       13 organization should be accurate and, accurately, reflect
14     Q. And there are another 150,000 or so                            14 what happens at that meeting.
15 rank-and-file people who are not officers; isn't that                 15    Q. If I understood your testimony, you said that
16 correct?                                                              16 the way the 10 members of PEF were chosen is that Sal
17    A. Correct; and, of that Executive Board, 75 are                   17 just opened it up to volunteers and whoever said yes
18 rank-and-file members.                                                18 would be put on this Board and entrusted with $1 million
19    Q. At the May 18th to 19th meeting, did the full                   19 of member money?
20 Board instruct the rank-and-file members to go out and                20    A. Yeah, that's my recollection.
21 tell the next level of rank-and-file -- meaning the                   21      Q. And isn't it a fact --
22 150,000 non-officers -- that up to $6 million had been                22       A. It's not the first time we've done stuff like
23 authorized to be moved?                                               23 that.
24     A. It's the expectation of Executive Board members                24     You create a committee -- when we created the
25 to report what goes on at Executive Board meetings, both              25 committees around the merger, we said, who wants to be on

                                                                                                     49 (Pages 190 to 193)
                                                          Page 194                                                                Page 196
1    this committee? And hands went up.                        1          hate to say it -- I probably should know, but, I don't,
2        We created another committee around the merger. Who   2          so -- I don't know.
3    wants to be on this committee?                            3              As the treasurer, I think the SEIU Strike Fund has
4        And that's what happened with this committee.         4          what $9 million in it, so, I don't know whether I'm
5        Q. Isn't it a fact this group of 10 people who was    5          bonded or not; that's why we have SEIU counsel to make
6    going to be entrusted with, initially, $1 million and     6          sure that's done appropriately.
7    then up to $6 million?                                    7              MR. DAYAN: Q. I won't pursue this but, in advance
 8       A. Yes.                                               8          of the meeting where 10 individuals, according to you,
 9       Q. And isn't it a fact that the Executive Board       9          raise their hand to be entrusted with up to $6 million of
10   minutes do not say who those 10 officers were going to   10          member money, in advance of that meeting, was there any
11   be?                                                      11          notice to the Executive Board or agenda provided to the
12       A. Do the Executive Board minutes say who the        12          Board members that this topic would come up?
13   officers are going to be?                                13            A. I, actually, don't know.
14       Q. Yes.                                              14            Typically, we send out an agenda before the
15       A. I don't believe that they do; but, I'd have to    15          meetings.
16   look at the minutes. I have them. I found them.          16              I don't know.
17       Q. Do the Executive Board minutes of the May 18th    17              Q. Are those agendas saved as sort of official
18   to 19th meeting say who the 10 officers of the Patients  18          union records?
19   Education Fund will be?                                  19             A. I, actually, don't know.
20       A. No, no, it does not.                              20             Q. Do you know who Herman Benson is?
21       Q. Are you aware that federal law requires union     21              A. Yes, I know who he is.
22   officers and employees who are entrusted with discretion 22              Q. And you testified earlier about "SEIU Voice"?
23   over union funds to be bonded, meaning, procure an       23              A. Yes.
24   insurance bond so that, in the event they're responsible 24             Q. Did you have any role in the content of "SEIU
25   for the misuse of money, there's a vehicle for getting   25          Voice"?

                                                          Page 195                                                                Page 197
1    the money back?                                                 1       A. I don't know what you mean by that.
2       MR. CHATTERJEE: Your Honor, this is a legal                  2       Q. Did you have any role, you know, in
3    question. It's not appropriate for a percipient witness.        3    determining -- let me ask it differently.
4    It calls for a legal conclusion --                              4       Who is -- who were the UHW officers, or staff
5       MR. BORSOS: I don't.                                         5    employees, who were responsible for setting up "SEIU
6       MR. CHATTERJEE: -- and Mr. Borsos is not up there            6    Voice" and determining what, you know, should be posted
7    as an expert witness. This question is in appropriate.          7    on it?
8       SECRETARY MARSHALL: If you know the answer to that,          8       A. That's a complicated question. There's several
9    answer it.                                                      9    people who would be involved. I would be one of those.
10      MR. BORSOS: I don't know.                                    10      Q. You would be one of those? Okay.
11      SECRETARY MARSHALL: He doesn't know.                         11      A. Sometimes, on some things.
12      MR. DAYAN: Q. You don't know whether officers and            12      Q. Let me turn your attention to Exhibit 25.
13 employees need to be bonded to be entrusted with union            13      A. Your exhibit?
14 funds?                                                            14      Q. Yes -- oh -- I'm sorry -- 26 -- 26.
15      A. I don't know.                                             15      A. 26?
16      Q. Do you know whether you're bonded?                        16      Q. Yes.
17      A. I, actually, don't know.                                  17      A. Okay, Exhibit 26 is a screen capture of
18      Q. Do you know whether the 10 people who                     18 SEIUVoice.org, and there's a heading about Benson's union
19 volunteered to serve on PEF obtained bonds after PEF was          19 Democracy: Blogsters Threat to Trustee West Coast SEIU
20 created and they were entrusted with the $1 million,              20 Local Poses Danger to Democracy and Labor Movement.
21 initially, of PEF funds?                                          21      Are you familiar with that blog post?
22      A. I don't know.                                             22      A. Generally, I mean, I see part of it in front of
23      I'm the treasurer of the UHW psychiatric fund -- I'm         23 me.
24 sorry -- couldn't tempt you? I don't know. I'm sorry.             24      Q. And, can you see, from looking at that exhibit,
25 I can't answer that question. I'm the treasurer and I             25 that there's a link to the Benson blog?

                                                                                                50 (Pages 194 to 197)
                                                  Page 198                                                                  Page 200
1       A. Yes.                                                1        Q. And, then, the next sentence says:
2      Q. Okay, if you turn to the next page of Exhibit        2        ...and so the Local Executive Board voted to put
3    26, page 930, this is a web page from Benson's Union      3    money into a separate tax-exempt fund protected from
4    Democracy blog.                                           4    seizure by Stern with the express aim of defending
5      Do you see that?                                        5    membership rights.
6       A. Yes.                                                6        Do you see that?
7      Q. Have you read Benson's blog post about the           7        A. I do.
 8 Stern's Threat to Trustee West Coast SEIU Local?            8        Q. Isn't it a fact that Mr. Benson was,
 9    A. Yes.                                                  9    accurately, reporting that the local Executive Board of
10    Q. Let me direct --                                      10 UHW voted to put money into a separate tax-exempt fund
11    A. It's been a while since I've looked at it; but,       11 protected from seizure by Stern with the express aim of
12 yes, I read it.                                             12 defending membership rights?
13    Q. Were you one of the people who were involved          13    A. No.
14 with "SEIU VOICE" in deciding this would be a suitable      14       Unfortunately, in this article, Mr. Benson got that
15 thing to post on "SEIU Voice"?                              15 fact wrong; and, in fact, he had not talked to anybody in
16    A. Yes.                                                  16 UHW before he published this piece; and he is not
17    Q. Okay, and, let me direct your attention to the        17 authorized to speak for UHW and never has been authorized
18 document with the page -- excuse me -- that has 932 in      18 to speak for UHW.
19 the lower right corner?                                     19     Q. You had a role in deciding whether this was an
20    A. Okay.                                                 20 appropriate piece to post on SEIUVoice.org; isn't that a
21    Q. Let me just read to you from this blog post.          21 fact?
22    A. Okay. Where are you? I'm on the page. What            22       A. Correct.
23 paragraph?                                                  23       There's articles that we've published on SIEUvoice,
24    Q. Yeah, let's do five paragraphs down, the first        24 as I assume, on the SEIU website, that there may be
25 of the seven charges?                                       25 factual inaccuracies in the articles that have been

                                                  Page 199                                                                  Page 201
1       A. Okay.                                               1    posted. Posting something on a website does not ascribe
2       Q. And the first of the seven charges is referring     2    those representations to the people who put it on a
3    to -- you testified that there was a letter from Stern    3    website.
4    that had seven allegations against UHW?                   4       Q. I'll agree with you on one thing.
5       A. Yes.                                                5       You testified, earlier, about bonding. You're not a
6       Q. Okay, it says -- Mr. Benson says:                   6    lawyer. We're going to have a legal dispute about
7       The first of the seven charges present Defendant       7    responsibility, but, what I'll ask you is this:
8    Rosselli with an intricate "Catch-22" dilemma. The        8       Sometimes you might link to an article that contains
 9 Local, in effect, is threatened with trusteeship for        9    a factual inaccuracy. That could happen to anyone; would
10 taking steps to defend itself against the imposition of a   10 you agree?
11 trusteeship.                                                11       A. Yes.
12      Do you see that?                                       12      Q. You were at the May 18th to 19th Executive
13      A. I do.                                               13 Board meeting; isn't that a fact?
14     Q. The next sentence says:                              14       A. It is.
15     When the Local realized that, in retaliation for its    15      Q. So, you decided to post something that you knew
16 criticisms, Stern was almost certain to try to trustee      16 contained a false statement about the first and most
17 the Local, it decided to take an advance defensive          17 important charge that had just been leveled against UHW;
18 measure.                                                    18 isn't that a fact?
19     Do you see that?                                        19       A. It's true that article includes an inaccuracy.
20      A. I do.                                               20 It is absolutely true that this article includes an
21      Q. The next sentence says:                             21 inaccuracy.
22      Its misgivings, obviously, have been proven to be      22      Q. And you were responsible for the decision to
23 well-founded...                                             23 publish it?
24   Do you see that?                                          24       A. Correct.
25   A. Yes.                                                   25      Q. Let me say this --

                                                                                           51 (Pages 198 to 201)
                                                    Page 202                                                           Page 204
 1       SECRETARY MARSHALL: Go ahead and finish up as far       1    on the record.
 2   as you can. You're impinging on member time, but --         2       SECRETARY MARSHALL: You all have any cross?
 3       MR. DAYAN: One way of proceeding is, if we're going     3       MR. ROTHNER: I don't have any cross-examination,
 4   to come back a third day, any way, and we've agreed that    4    but, perhaps, next time, we'll think about hearing from
 5   we don't have to have -- we'll just continue the cross on   5    the people who he did have contact with.
 6   that third day.                                             6       SECRETARY MARSHALL: All right.
 7      SECRETARY MARSHALL: Okay, the same thing goes for        7       MR. HARRIS: Well, I think it's completely fair, if
 8   you and your members.                                       8    you're going to bring somebody to the microphone to make
 9      MR. HARRIS: Yes; and, we'll even redirect this           9    an allegation, a serious allegation, the person against
10   witness and, obviously, we have a lot of witnesses we       10 whom it's made have the chance to respond; and I just
11   intended to put on.                                         11 wanted to take two minutes to do that and I want to
12       I would like to do the one thing we talked about,       12 proceed with the members' statements.
13   which is take two minutes, and that would be to ask Dan     13    SECRETARY MARSHALL: All right, we have done that.
14   Martin to come up and respond to the allegation that was    14 Thank you.
15   made from that microphone this morning.                     15             (Recess taken)
16      SECRETARY MARSHALL: I told him he had to be              16     MR. BAIRD: Okay, this is the way we're going to do
17   responsible for your rebellion.                             17 the member statements. As you've been told before,
18       MR. HARRIS. I take responsibility.                      18 you'll have two minutes, each, to make the statements.
19       Do you want to hear from Dan Martin?                    19 You can make them up here. Just to my right, there's a
20       SECRETARY MARSHALL: And we'll have you back later.      20 microphone. I will call out five names and those five
21       MR. BORSOS: Thank you.                                  21 people should approach the microphone and any of those --
22       SECRETARY MARSHALL: All right.                          22 and just those five people. There will be someone there
23       You got your witness?                                   23 who will show you the time, so you know how much time you
24   /                                                           24 have left.
25   /                                                           25    As Secretary Marshall said, please, don't make

                                                    Page 203                                                           Page 205
1                   DANIEL MARTIN,                                1   repetitive statements so that we'll have more opportunity
2            called as a witness on behalf of                     2   for people to make statements about subjects that haven't
3             United Healthcare Workers-West,                     3   been covered already.
4             having been placed under oath,                      4       And so, these five people, if they will come up,
5                testified as follows:                            5   please, to the microphone;
6                                                                 6       Pam Reese;
7                 DIRECT EXAMINATION                              7       Della -- I think it's May(sic) Reed;
8        BY MR. HARRIS:                                           8       Dishana(sic) Handeman;
 9       Q. Could you state your name, for the record?            9       Linda Lopez;
10       A. My name?                                             10       And "Alesander".
11       Q. Your full name, for the record, please.              11                      --oOo--
12       A. Daniel Martin.                                       12                    MEMBER STATEMENTS
13       Q. And what's your current occupational position?       13                      --oOo-
14       A. I'm a union organizer.                               14      MS. REESE: My name is Pam Reese.
15       Q. Okay.                                                15      I'm a radiology tech and medical worker for the last
16       Mr. Martin, were you here this morning when             16   30 years. I am a member of the UHW -- yeah, go. I have
17 allegations were made from that microphone about              17   had conversation with Andy Stern on the phone and he told
18 statements that you were said to have made?                   18   me he does not believe in the democracy. He does not
19     A. Yes, I was.                                            19   believe in elections. He thinks it's a waste of money
20       Q. Were those allegations true?                         20   and it doesn't work. Those were words from his mouth. I
21       A. Absolutely not.                                      21   think this is a very bad situation put on our union and
22       Q. Have you had any contact with the people who         22   our workers and it is effectively caused us difficulty
23 you were alleged to have made those statements to?            23   with our contracts. It is causing us difficulty with our
24    A. I have not.                                             24   personal lives. They put us through the kind of stress
25    MR. HARRIS: Thank you. That's all I wanted to put          25   and our leadership who has been solely democracy.

                                                                                          52 (Pages 202 to 205)
                                                      Page 206                                                       Page 208
 1       I have been an activist for legislation for the          1   us? You'd be able to do $25 million less than you are
 2   health program and I can tell you that our politician --     2   doing, okay? So, we want Andy Stern to get his act
 3   political department -- has always given us the attitude     3   together because he's a burger to go.
 4   that we would probably not win, but, we would come back      4      MR. BAIRD: Before we start the next people, will
 5   strong; and that's what this money is for.                   5   these five people approach the microphone?
 6       These people that have controlled this money are not     6      Herb Steinkraus;
 7   people on the damn street. These are people we have          7      Liz Burgon;
 8   elected. I fully support my president. I cannot support      8      Monique Ozier;
 9   Andy Stern who thinks he can move 65,000 people, not         9      Darlene Rufino;
10   giving them a vote. I asked him about that and I told       10      And Tyrone Dickens.
11   him, Andy, I'm going to move you to Birmingham, Alabama     11                   --oOo--
12   and you have nothing to say about that. How does that       12      "ALEKSANDER": Hello, my name is Aleksander
13   make you feel?                                              13   (unintelligible). I'm a retired nurse after almost 21
14      He said, I wouldn't want to go. And I told him that      14   years now. I had to come up here, take off out of my
15   we needed to have our people have a vote. And he said to    15   retirement to come here and deal with the lame turkey
16   me, if they vote to go, what would you say? And I would     16   with the mouth in the middle belittling my union and his
17   say, go and God be with you. This is a democracy.           17   cronies can take Andy Stern's ass and kiss it because I'm
18       Sal and Joe are the best motivators that I have ever    18   tired of his filthy mouth.
19   seen. They have brought us here and are actively            19                        --oOo--
20   involved in our union and we're member-driven. We make      20       MS. OZIER: Monique Ozier, proud member, shop
21   decisions. We've been actively involved in the nursing      21   steward -- or -- chief steward, co-chair, and political
22   home thing. We've been involved in every aspect of that.    22   action leader.
23   I have no doubt that that money was planned way before it   23       Yesterday, you guys spoke about $6 million in money
24   was ever taken out and I strongly support my union and I    24   being into a self-selected group. I just need to know
25   want you guys to leave us alone. Sir? I object.             25   how that compares with the money that was lost by these

                                                      Page 207                                                       Page 209
1       MR. BAIRD: Just a second. The timer, when the two         1   6434 members just -- you're just -- because this is now,
2    minutes expires, would you wave your hand so the Hearing     2   to me, for the last three or four years, you talked about
3    Officer can see, please?                                     3   a covert operation and how -- I just need to know how
4                      --oOo--                                    4   much of that Andy Stern, actually, got out of 6434?
5       MS. REED: My name is Della Marie Reed. I'm a nurse        5   These are self-appointed people that he placed in office.
6    at Caifornia Pacific Medical Center. I have been a proud     6      How about the misappropriation of funds that was
7    member of my UHW for more years than I want to admit to.     7   used to overflow our mailboxes and to harass our members
8    I wanted to let you know that our union is a democratic      8   during our family time with our families? I'm just
 9 union where members have always come first. Our members        9   curious. I'm pissed off. We want you to leave us alone.
10 are the ones who have build our union. And all this junk      10       You need to focus on the Locals that are not doing
11 about what we're being charged for, it's -- we have           11   what they're supposed to do. And we are members and I
12 decent, reliable, well-respected members, leaders. All        12   guarantee you, if y'all busting us, it's not going to be
13 of our leaders are respectable.                               13   pretty. We're not going to be cooperative.
14      And we don't want SEIU to keep messing with us           14                   --oOo--
15 because, if SEIU will remember, UHW sends them $25            15      MR. DICKENS: First of all, I'd like you people to
16 million a year of our dues, our money that we worked hard     16   understand, I was born and raised in New York. I come
17 for. So, where would they be without our $25 million?         17   from one family -- I mean -- unstable home. I never had
18 And we are the second highest COPE collectors --              18   nothing. I joined this union, right, and it gave me a
19 contributors.                                                 19   sense of pride. And, to see you people, who I am paying,
20    No, it's not right. It's not right at all. And we          20   is working for somebody who is trying to take away what I
21 want you also to know that you better get ready because,      21   have.
22 you know, like In-N-Out Burgers -- I'm really, really,        22       Now, Mr. Marshall, I give you all the respect in the
23 upset. I like to be a lady and act nice, but, I'm really      23   world, but, when I read this thing, and I found out that
24 upset. Just like In-N-Out Burgers, SEIU, we don't work        24   you are being paid by the same people who are paying
25 for you; you work for us. And where would you be without      25   them, you scare me. You really scare me; right?

                                                                                         53 (Pages 206 to 209)
                                                    Page 210                                                         Page 212
 1      I mean, if you're getting paid by them, how are you       1      Referring to the healthcare reform claims that were
 2   impartial?                                                   2   mentioned, last year, me and my co-workers and stewards,
 3      How do I know?                                            3   worked very hard lobbying in Sacramento, having
 4      How can I go -- excuse me -- stop, stop, stop.            4   healthcare reform parties, even hosting them in my home
 5      How can I go home tonight and sleep knowing that          5   for my members and community activists and neighbors, so,
 6   tomorrow, next month, next, year my job is going to be       6   I know. We worked hard for healthcare reform last year.
 7   secure?                                                      7       I would like to put SEIU on a alert. I come from a
 8      How do I know that what the decision you're going to      8   three generation family of union ties from Hawaii to
 9   make is going to be the right decision?                      9   California, from the police department union,
10     That's going to benefit me, that's going to benefit       10 construction trades, to healthcare workers. If SEIU
11 my brothers here, my sister?                                  11 thinks that putting UHW into trusteeship they will be a
12     That's going to help me do what I have to do to live      12 force to reckon with.
13 a better life?                                                13      I will give up on the labor movement;
14     I really -- I do ask you. I mean, I looked at your        14      I'll de-COPE;
15 record. I looked at what you've done, and I really do         15      I'll be a fee-payer;
16 ask you:                                                      16    And, believe me, in this times of financial crisis,
17     Do the right thing;                                       17 my members will follow in suit -- I'm almost done.
18     Be impartial -- be impartial;                             18    We will continue this fight with SEIU to defend UHW
19     Don't let the money that these people giving you be       19 which has the best contracts in the nation and the most
20 the reason that you put us in a hole.                         20 democratic Local in SEIU.
21    SECRETARY MARSHALL: Let me tell you, I'm not making        21                   --oOo--
22 anymore working for -- doing this work than I would doing     22    MS.COLLADO: Good afternoon, everyone. My name is
23 other things, so, the net gain to me is 0.                    23 Teresita Collado. I am a member and work for Kaiser
24     MR. BAIRD: Will the next five people, please, come        24 Sunset.
25 up?                                                           25    How dare you, attorney, question the integrity of

                                                    Page 211                                                         Page 213
1       Torianto Yeargin;                                         1   those people in that Executive Board. The way we receive
2       Teresita Collado;                                         2   it at the end, it looks like there are questions of their
3       Ju'Anna Baiah;                                            3   integrity and reputation.
4       Pam Smith;                                                4        Look at the other unions, especially 6434. How come
5       Michael Rivera.                                           5   it looks like the three of them can be found and nothing
6                     --oOo--                                     6   is being addressed, too, because they were appointed.
7       MS. RUFINO: Hi, Mr. Marshall. My name is Darlene          7       Our leaders are elected. If we sat at a meeting,
8    Rufino, and, I'm a proud member and steward of UHW Kaiser    8   we're representing our members. We are responsible to
 9 division. I am a COPE contributor for the political fund       9 tell our members. We don't hide anything about anything
10 and an active organizer.                                      10 that we do.
11     First of all, I'm very offended by this E-mail sent       11      The thing that is happening right now portions --
12 by an SEIU executive staff member, Bill Reagan referring      12 or -- some of the members that is sitting at the back
13 to trusteeship being like Iraq. "Easy to attack and hard      13 accusing the UHW are our members; and I don't know why.
14 to get out." This is very insulting to me and I take it       14     And how did they come to the point and question
15 very personal. My son is, currently, serving active duty      15 about the integrity of their leaders when, in fact, they
16 with the Army, specializing in long range missile             16 are the leaders before who organize everybody and work
17 defense, protecting our freedom. Last year, he spent 12       17 hard to make this union succeed?
18 months overseas in the Middle East and that was very hard     18     So, please, Secretary Marshall, this is the first
19 for me and my family. He was protecting our freedom; and      19 time I have seen you and this is my pleadings to you.
20 he may be going overseas real soon in the next year or        20 With all the things that's in your biography, do not ruin
21 two.                                                          21 that by siding with SEIU, because all of the employees
22     SEIU should not be planning an invasion on UHW or         22 the unions who are sitting over here will remember you
23 creating war between rank-and-file members. Referring --      23 forever and one thing is it you're fair. Thank you.
24 I'm going to touch bases on a little -- everything that       24                    --oOo--
25 came up in this hearing:                                      25      MR. YEARGIN: Good afternoon. My name is Torianto

                                                                                         54 (Pages 210 to 213)
                                                    Page 214                                                           Page 216
 1   Yeargin from the Sunset Kaiser Division Council. I am      1       We're not greedy people. None of these people are
 2   Chief Steward.                                             2    greedy people, but, we want what's fair.
 3       I just want to make something very clear. The whole    3       And Andy Stern, I think, is a bit too greedy. He
 4   point of this whole process, you're saying, is about       4    sees that what we have is really good and under Sal, Sal
 5   trusteeship. It should be about what's best for the        5    has gotten for us what no other union has gotten for us
 6   members. Time and time again, UHW has proven that. You     6    or anybody else. And I have a feeling that Andy Stern
 7   said it yourself, Mr. Marshall, standing up here that,     7    may be jealous, too greedy, and he wants it all. And he
 8   looking at the labor movement, now, it does not look        8 wants to take it away from Sal, which would be the worst
 9   good. It is not lookin' good right now.                     9 thing for all of us. Because, if Andy Stern took over,
10     And we are one of the strongest union, if not the        10 we lose.
11 strongest, I do believe, across the board. This labor        11     And I'm afraid because my husband committed suicide.
12 movement has proven time and time again -- once again, at    12 I'm the only one who is making the mortgage payments.
13 Tenet -- that we can do things that SEIU cannot do; and      13 And, if Andy Stern comes in and starts taking away from
14 they're supposed to be the International.                    14 me, I'm going to lose everything that my husband and I
15     This whole case that they're putting on right now is     15 worked for. Thank you.
16 not sufficient. It has no bounds for everything that         16                   --oOo--
17 they're saying. I'm sorry. I'm getting real emotional.       17      MS. BAIAH: My name is Ju'Anna Baiah and I'm a proud
18 Let me get straight to the point. The point is this:         18 UHW member. I'm also a proud member of the UHW Executive
19     What's best for the members? Once again, going back      19 Board. And I just want to say that cover-up slander,
20 to what's best for the members and, at Sunset, that's        20 corruption, railroading members, that's not justice for
21 truly what we believe in. And we cannot have that with       21 all; that's justice not at all. And that's what we've
22 SEIU doing what you're doing.                                22 been getting around here for a while now.
23     Quite frankly, when you go to bed at night, I don't      23    What happened to us at the International
24 know how you sleep. Let's just put the facts out there.      24 convention -- to UHW -- that wasn't justice. That was
25    With Kaiser, UHW has better contracts, better wages,      25 not being given our democratic chance to speak on the

                                                    Page 215                                                           Page 217
 1   better benefits.                                            1   issues that we wanted to share with everyone; but, no, we
 2      What has SEIU done for us? That's my question.           2   weren't allowed to put that out there because, once
 3   That's my question.                                         3   again, they wanted to hush us up.
 4      And, how do you go to sleep at night?                    4      We run a democratic union where, the same people we
 5      And, let the truth be told from Sunset. Let's speak      5   vote in, we have a right to vote out. We don't appoint
 6   on it in regards to member retaliation. I hold you to       6   them, and they get to stay and do whatever they can until
 7   that Council. I am there and we speak very openly and       7   they corrupt and steal all the money and then they're put
 8   freely in regards to union democracy, once again, for       8   away.
 9   their members. Because the only reason why we're here       9      No, we have the write to speak on this. And the
10   our members and in that Council there's no retaliation.    10   rank-and-file members are the one who pays these salaries
11   We speak the truth. It's addressed. If you're not doing    11   and who have the right to speak on it. And rank-and-file
12   what's best for the members at that point in time and      12   members say, we're guaranteed what the proposal was at
13   moving on you shall not be there because you're elected    13   the International.
14   by the members. Let the truth be told.                     14      Minimum standard contracts. You don't even have to
15                   --oOo--                                    15   come to the table to bargain for minimum standard.
16      MS. SMITH: Hi. My name is Pam Smith. I work at          16   That's the least you can get. We deserve a lot better.
17   Kaiser Sunset in the operating room. I'm a certified       17   We get a lot better. We're happy where we are. We're
18   surgical technologist. Sorry. I have a small voice.        18   not going anywhere and we're not going to comply with --
19   Big body, small voice.                                     19   just let this sham go on any longer.
20       Again, my name is Pam Smith. I work in the             20      MR. BAIRD: Would the following people, please, come
21   operating room at Kaiser Sunset as a certified surgical    21   up to the microphone?
22   technologist. I've been there for 25 years. I love my      22      Steve Haas;
23   job. I'm thankful that Kaiser has a fantastic union; and   23       Tamala Wilson;
24   it sounds like everybody else out there wants to be just   24       Donna Hafer;
25   like and have what Kaiser has, thanks to the union.        25       Sheila Pinkney;

                                                                                           55 (Pages 214 to 217)
                                                       Page 218                                                      Page 220
1       And Laurel Knight.                                         1   their steward. They say, hey, I need you, and the
2                      --oOo--                                     2   steward, if he don't know the answer, they go to the
3       MR. HAAS: First thing I want to know is why the            3   organizer; if they don't the know the answer, they keep
4    counselor here is turning his back on members while           4   going up until the issue gets large enough where they
5    they're speaking to you. You're the only one on the           5   know someone will hear them and they'll be stand up for.
6    stage that is not engaging the members when they're           6      This is a union who wants it to be the UHW because
7    bringing their concerns to you. That is despicable, it's      7   of the members. This trusteeship is about somebody being
8    disrespectful, and we're not going to stand for it.           8   singly appointed to take over an elected body which was
9       Secondly, I'm going to stand right here so you know        9   elected by the members. They will not let that happen.
10 the level of my commitment. You can look in my eyes.           10   The rank-and-file members will stand up and say, we want
11 Okay? Most of the people that know me in this union know       11   our leaders back. We want to hear from them. So, I urge
12 I'm just a country boy, so, I don't put things in -- in        12   you to consider that the reason trusteeship should not
13 the old west, there was a code of the west and one of the      13   happen is because the members believe in their leaders
14 codes said, don't make threats unless you expect dire          14   and believe that their Board is their's. Thank you.
15 consequences. Your threats will be met with equal force.       15                     --oOo--
16 We are committed to preserving democracy and SEIU, we got      16      MS. WILLNER: My name is Jeannett Willner. I'm a
17 UHW. We got a little code of our own. When you take on         17   phlebotomist at El Camino Hospital. I had something
18 one of us, you take on all of us.                              18   written down to say, but, I'm just going to be straight
19    MR. BAIRD: Will the following five people please            19   to the point.
20 come up?                                                       20       I've been a member of the union for four years. And
21      Kim Johnson;                                              21   I work very hard for my dues and I don't want to see them
22      Richard Paul Bell-Tull;                                   22   go into a trusteeship, which doesn't support us, my
23      Maria M. Leiva;                                           23   brothers and sisters, as members. It should be for
24      Jeannett Willner;                                         24   healthcare workers and healthcare providers; and also for
25      And Tammy Buckles.                                        25   the patients who I give my life for every day when I draw

                                                       Page 219                                                      Page 221
 1                  --oOo--                                        1   their blood to do my job the right way. And I don't need
 2       MS. WILSON: Yes. My name is Pamela Wilson. I work         2   someone putting my money into something that will not
 3   for in-home care in Yolo County.                              3   benefit them as well as myself and healthcare workers.
 4       And I appreciate what my union has done for us            4   Thank you.
 5   because without Sal we wouldn't have what we have now.        5                    --oOo--
 6   And you people need to keep your nose out of our business     6       MS. BUCKLES: Hi. My name is Tammy Buckles and I am
 7   unless you know what you're talking about.                    7   the chief steward of El Camino Hospital. We seem to pull
 8                   --oOo--                                       8   three El Camino's out of the hat all at once here.
 9      MS. JOHNSON: Hi. My name is Kim Johnson. I'm a             9      And I wanted to address you all today because I am
10   phlebotomist at El Camino Hospital, just down a little       10 from a hospital that knows the difference between being
11   way in Mt. View.                                             11 with UHW and being with just another SEIU. We had an
12       I just want to say, the best evidence against the        12 initial contract with an open shop for six years where
13   trusteeship is the fact that the membership, everybody       13 members were pitted against other and administration took
14   here, believes in their leaders. They believe in this        14 advantage of us and all they tried to do was destroy our
15   union and they support it, every day, in all of their        15 union on a daily basis. We had mediocre benefits. We
16   actions.                                                     16 had mediocre things in our contract. And we fought in
17       Not just here;                                           17 the last hearings to get away from that because we
18       But, when they're at their hospitals;                    18 requested, and we made it known at the last hearing, we
19       When they're at their homes taking care of elderly       19 became part of UHW.
20   people;                                                      20     And now that we're part of UHW, we know what it's
21      They communicate with all of their employees;             21 like to win for a change. We know what it's like to hold
22      And they express how they represent each of them as       22 our heads high in our hospital and look management in the
23   a union member;                                              23 face, because we don't have an open shop anymore. We
24      How to be bargained and bargaining contracts.             24 have an agency shop. We have fully-paid healthcare for
25       If they have a question or an issue, they go to          25 part-time workers, people that could not even afford to

                                                                                          56 (Pages 218 to 221)
                                                     Page 222                                                          Page 224
 1   have their families covered. Okay? We have so many           1       The response was from those people in the press.
 2   things.                                                      2   We're glad to do it. We don't see the point in it. They
 3       There were so many loopholes in our last contract, I     3   ought to have known they were doing what was wrong. And
 4   don't even want to tell you what they were like to try to    4   they included in their statements that, as far as they
 5   deal with that, we had the expertise and the guidance of     5   could see, there was no grounds for trusteeing UHW and it
 6   the leadership of UHW, we fixed the problems. And, now,      6   looked like retaliation. And I will send you that
 7   we're on the course to move and bring all the standards      7   article, Mr. Marshall.
 8   up at our hospital.                                          8       The last thing I want to say is that we have reason
 9      And you can't tell me that now, because of this           9   to distrust SEIU. If they were to trustee us, they have
10   trusteeship hearing, you're going to take that all away     10 excluded our members from the bargaining table and they
11   from everybody at El Camino, or anybody in our union,       11 have signed off on contracts that would -- or proposed
12   because it's not gonna happen. You will not vilify our      12 contracts that would -- have limited our right to
13   union and defame our character with all these allegations   13 advocate for patients' rights, which is just amazing they
14   that aren't true. You will not -- let me repeat -- you      14 will sign off on contracts that bargaining unit members
15   will not vilify UHW.                                        15 would never sign off on if they were allowed to vote on
16       MR. BAIRD: Susan Andrews;                               16 them.
17       Esther Van Derloute;                                    17    MR. BAIRD: Okay, will the following people please
18      Simon Brasil;                                            18 come up to the mic'?
19      Renee' Thomas;                                           19    Rose Radford;
20      Michelle Brown.                                          20    Mary Johnson;
21                      --oOo--                                  21       Hilda Vasquez;
22      MR. BELL-TULL: Thank you, Mr. Marshall and               22       Micheula Fletchall -- I believe;
23   everybody for letting me speak. My name is Paul             23       Leslie Bristo.
24   Bell-Tull. I work in psychiatry in Vallejo with Kaiser.     24                   --oOo--
25   I'm a social worker, like Andy Stern used to be. I          25       MR. BRASIL: My name is Simon Brasil. I am UHW

                                                     Page 223                                                          Page 225
 1   wanted to tell you that I took a day off, took vacation     1    member with Kaiser Hayward. In spite of being a UHW
 2   time, yesterday, and, here, I'm on my day off, and          2    member, I'm not blinded by just blind allegiance, okay,
 3   everybody in this room came either by taking vacation       3    and support my union and everything that they do. I call
 4   time or on their day off to express their commitment.       4    it as I see it. Okay? UHW leadership portrays its
 5   There's 8,000 of us here who came as far as from San        5    practices as being the models of democracy.
 6   Diego to express our commitment, to show our support for    6       Okay, let me give you a little example about UHW
 7   our leadership.                                             7    democracy, okay? I was removed as steward by UHW back in
 8      I want you to know and you can look at the salary        8    2005. Upon my removal, okay, which was groundless,
 9   ranges that nobody is getting rich who works for UHW. I      9 because I simply spoke up in opposition to the corruption
10   asked one of my colleagues to apply for the position of     10 and to the subversion that I was seeing by the steward,
11   being a field rep for our chapter and she would have had    11 Council, by the field rep and Ralph Beneo(sic). Because
12   to take a significant cut in salary as a social worker to   12 I spoke up about this, they removed me as the steward.
13   work for UHW. And, if you look at the spread, from Sal      13     Upon my removal, they said, you can appeal it. You
14   Rosselli down, it's done democratically, and making sure    14 can appeal it to Ralph Beneo(sic). I appealed to Ralph
15   that Sal is not making significantly more than anybody      15 Beneo(sic). Okay, to this day, three years later, I'm
16   else in the union. Nobody is getting rich; and they work    16 still waiting for a response. That's UHW democracy for
17   their butts off for us.                                     17 you.
18       The next thing I want to say is that outsiders are      18      Additionally, UHW likes to portray itself as
19   putting the question on these proceedings. Andy Stern       19 leadership -- not UHW, but the leadership likes to
20   told the press, told the New York Times, he was going to    20 portray itself as aggressively enforcing the contract and
21   invite two respected reform leaders, including -- I think   21 representing members.
22   his name is Ken Path(sic) -- from the Teamsters to help     22    Okay, I thank you for your point in time and example
23   them form an ethics committee to make sure that the         23 of UHW democracy. You can talk if you have an opposing
24   things that are going on in the other Locals referred       24 point of view. Okay, UHW -- yeah, this is UHW democracy
25   here don't happen again.                                    25 right here. Okay?

                                                                                           57 (Pages 222 to 225)
                                                      Page 226                                                         Page 228
1       Like I said at the Environmental Service Department      1    and I'm not active enough in my union to know if my
2    in Hayward UHW abandoned the department that even core      2    leaders are doing something wrong.
3    contractual values elements such as -- yeah -- but, you     3       I mean, we can definitely voice our opinions; and,
4    know, they interrupted me -- okay -- such as wages and      4    if we thought something was wrong, we would have been the
5    benefits have come under fire. And you have repeated        5    first one to say it.
6    attempts to get people to get UHW representation to         6       Instead, you guys up of come up here and tell us,
7    support the members in the department. Okay, I organized    7    well, they did this and they did that; and you guys have
8    a protest march at UHW headquarters on December 22, 2006.   8    no clue what you're talking about.
9    About 35 members from my department picketed UHW            9       Well, we do. We're smart, we're intelligent, and
10 headquarters for their gross negligence. Okay, my time        10 we're very active. So, if we wanted to get rid of our
11 is up; but, I could go on for two more hours.                 11 elective leaders, we would have done that. Also, they've
12     MR. BAIRD: All right, will the following people           12 done nothing wrong. We want to keep them; and, if we
13 please come up and speak?                                     13 don't, we'll make that decision, not you. Thank you.
14    Ilda Luna;                                                 14     MR. BAIRD: Will the following people come up if
15    Joseph Trujillo;                                           15 they want to speak?
16      Tanya Britton;                                           16      Rodolfo Gonzelez;
17      Marla Heath;                                             17      Jesus Hernandez;
18      And Cynthia Arriala.                                     18      Jessica Maccas;
19                     --oOo--                                   19      Delares Jones;
20      MS. JOHNSON: Good afternoon. My name is Mary             20      Lorie Wesson;
21 Johnson. I am a shop steward and a worker of Kaiser           21      Patrice Powers;
22 Permanente Sacramento offices. I've been with Kaiser for      22      And Tonia Smith Frysi.
23 20 years, so, I have been in the union for 20 years.          23                      --oOo--
24 I've been a union member for 20 years.                        24    MS. KEES: Hi. My name is Ruth Kwwa, and I'm the
25     First of all, I'm sort of like the gentleman who          25 steward at Children's Hospital in Oakland.

                                                      Page 227                                                         Page 229
 1   said he was simple country boy. I was born and raised in     1       And what I would like to say to SEIU is this:
 2   New Orleans, Louisiana, so, I come from the south where      2       There was no transparency when I was getting E-mails
 3   there was no union. So, when I came to California, I         3   and letters and phone calls this year. There was no
 4   didn't even know what a union was. Once I was in it, I       4   transparency that says where that money came from. Well,
 5   liked it. It helped me get what I needed and it works.       5   we know the $25 million that we give you every year,
 6      So, all I have to say is to you Mr. Chairman, as          6   there's no transparency at all when it comes to what is
 7   everybody else I'm sure has said -- and I apologize for      7   being done, now, to the contracts that are being handled
 8   repeating -- is be fair. And, like I say, I'm a simple       8   and manipulated throughout SEIU.
 9 country girl because, where I'm from, there's an old           9     So what I'm saying is this: We want Andy Stern to
10 fable. There's three sides to every story and, in this        10 leave us alone. It's time for us. If you wanted to
11 case, it's ours, theirs, and the truth. So, I submit to       11 talk, to mediate, that was one thing; but, just to come
12 you to please look for the truth. Thank you.                  12 in and blatantly tell us what we're going to do, that's
13    MR. BAIRD: Will the following people please come up        13 not going to happen in California. We're not going to
14 to the mic'?                                                  14 allow it to happen. Thank you.
15     Leslie Terra;                                             15     MR. BAIRD: Will the following people, please, come
16     Stephanie Flores;                                         16 up to the mic' if they want to speak?
17       Richard Marlowe;                                        17     Karen Sandidge;
18       Ruth Kees;                                              18     Maria Mansfield;
19       And I think it's Irene Pakmcas from Bellflower.         19     Mithilesh Verna -- I think it is -- from Sunset
20                  --oOo--                                      20 Kaiser;
21    MS. BRITTON: Hi. My name is TANYA BRITTON and I'm          21     Mary Torres;
22 from Park Central in Fremont. I've been a CNA for 11          22       Phillip Sandoval;
23 years and a proud union member for 11 years.                  23       And Maria Montenegro.
24    And I'm not very good at this, but, I just wanted to       24       All right.
25 say I'm really offended that you think I'm unintelligent      25       Faye -- I think it's Johnson -- from Oakland;

                                                                                             58 (Pages 226 to 229)
                                                       Page 230                                                           Page 232
 1       Rachel Heltne;                                           1    at Kaiser Bellflower for 35 years. I was in 399 for --
 2      Oh, boy, I can't read the writing. I think the last       2    up until 2005 when we became UHW. I became an active
 3   name is Froze -- from Kaiser Manteca;                        3    steward 25 years ago and then got further involved and we
 4      Larry Brown.                                              4    went into trusteeship. 399 ended up helping to rewrite
 5       MR. BAIRD: Go ahead.                                     5    the Constitution and bylaws, bring us back, and was
 6                   --oOo--                                      6    elected to the first two boards. So, I've been actively
 7       MR. WILLIAMS: Hello. My name is James Williams.          7    involved both at the facility and within the Local. And.
 8   I'm a CNA at El Camino Hospital. And, Mr. Marshall, you      8       There was a lot of questions about of John Borsos
 9   have a good reputation among -- you are fair, so, just do    9    shouldn't we be notifying our members about this money.
10 the right thing; but, my other speech is a poem called:        10 And I know when I sat on the Board, you know, we made the
11     Ode to Mr. Stern.                                          11 business decisions for UHW, and all that information was
12     Mr. Stern, regarding your decisions towards UHW, we        12 available to the members. And we send it out at that
13 the members have serious concerns. Mr. Stern, can't you        13 time, the Board minutes, to the stewards, and the
14 see we don't want SEIU dictatorship trusteeship. UHW           14 stewards were supposed to get it out.
15 subject to a hearing. You're my people hired by you even       15    We also live in a country that where we have
16 has SEIU lawyers speak for you. What can we do as              16 representatives at the White House, at the Congress, and
17 members of UHW? We'll fight charges through and through        17 those guys don't send me a letter every time they make a
18 to keep UHW united, not divided. Our president's charges       18 business decision. It's my responsibility to know how
19 have been proven false, while two of Mr. Stern's leaders       19 they voted; and I follow that and I make sure I know how
20 have been tossed, burned by greed, probably going to           20 they voted; and I write to them.
21 prison. Listen to Mr. Stern making bad decisions. UHW          21    And we have that same availability within our union.
22 divide, we fall. United, we stand. Mr. Stern, we don't         22 We can call the Local and say, I want minutes from this
23 want dictatorship trusteeship. Do you understand, my           23 meeting. I want to know what happened.
24 man?                                                           24    So, when this information came out, I went to the
25                     --oOo--                                    25 people that were on the Board of that PEF, or whatever

                                                       Page 231                                                           Page 233
1       MS. COOK: Thank you. Hello. My name is Anita Cook          1   it's called, and talked to them, some of my trusted
2    everyone calls me Cookie.                                     2   friends who I had been on the Board with. There isn't
3       First of all, I would like to thank your Honor for         3   anything shaky going on here except what's happened with
4    being here at this kangaroo court.                            4   SEIU towards UHW.
5       Second of all, you know, UHW is the only union that        5      What else did I want to say? Let's see, we have
6    I know that I can go to and go ask Sal, can I look and        6   been -- our Local is known for being politically active.
7    see what's going on? I can go in and look in any kind of      7   We move things politically in this state and in this
8    files. I can look in anything. There is no secrets.           8   country. And we have been handicapped by this B.S.
 9 But, if you call, if I have a problem with anything, they       9   that's going on with this with Andy Stern coming after us
10 are there from John, from hospital, from John to               10   trying to retaliate. That my two minutes? I have so
11 convalescent.                                                  11   much to say.
12      And you sittin' up here disrespecting my president        12                  --oOo--
13 like that. I really don't like it, first of all. First         13       MR. VERNA: Hello. As usual, people have difficulty
14 of all, you know, for you to come in his house and come        14   pronouncing my name. Secretary Marshall, my name is
15 in here and disrespect him like that, I mean, just             15   Mithilesh Verna. I was born in India. The last 30 years
16 because you don't want to be an ass-kisser, I really           16   I've been here, I'm a healthcare provider through my long
17 don't understand, you know, why you come up here trumping      17   credentials with Sunset Kaiser. I do surgical assisting.
18 up all these charges.                                          18   And the question as my background is the same question
19     Second of all, we're all a package deal. All of us,        19   which has been asked in civilization again and again.
20 this is a package deal. All this is a package deal. So,        20     How come two person from District of Columbia,
21 you know, come what may.                                       21   Washington can come here and re-order 150,000 people?
22     Thank you your Honor and you guys have a blessed           22     This the same question that was asked in 1939 by a
23 evening.                                                       23   simple Indian lawyer Mr. Ghandi to British Crown. How
24                --oOo--                                         24   can 90,000 British citizen rule 39 million Indians?
25    A. Hi my name is Carla Brock. I've been working             25       And same question today. They have no business here

                                                                                            59 (Pages 230 to 233)
                                                   Page 234                                                                  Page 236
 1   and this trusteeship proceeding is wrong. It should be      1          I thank you, Secretary Marshall. Please do the
 2   stopped.                                                    2    right thing. If you want to go to sleep and sleep well,
 3      As much as I know about Andrew Stern, he's a spoiled     3    do the right thing. God bless you.
 4   brat son of a lawyer from New Jersey. He was bumming        4          MR. BAIRD: Will the following people, please, come
 5   around in Europe. When he cannot do anything, he took       5    up;
 6   this job and now he has a dream to be another Adolph        6          Beyer David;
 7   Hitler. This is a civilized society. To put a stop          7          Lervada (Yvonne) Anderson;
 8   because it took a lot of years to understand Adolph         8          Bernadette Haggett;
 9   Hitler and to kill him, but, Andy, it's gonna stop.         9          Marty Dougherty;
10   Thank you very much.                                        10         Tamara Zaqaunou;
11       MR. BAIRD: Will the following people, please, come      11         Loida Ionikoua;
12   up?                                                         12         Hasnija Harris.
13      Catherine Cox;                                           13    UNIDENTIFED MEMBER: Okay I'm one of the lucky ones.
14      Kristen Mazza;                                           14 I work for Kaiser Modesto. Through the help of UHW, we
15      Kari Lyn;                                                15 have a program called LMP. I can bring my ideas to the
16      Phyllis Fry;                                             16 table and sit with management and discuss them, discuss
17      Lu MacDonald;                                            17 how to make it better for my patients and Kaiser listens.
18      James Williams;                                          18 I feel I am valued and respected as an employee. UHW has
19      Latanya Amerson;                                         19 bargained good wages, good benefits, and pension plans
20      And Renee Mack.                                          20 for us. I'm a single mom. Don't take my dreams away
21                 --oOo--                                       21 from me. Don't take the dreams away from my kids or the
22      A. My name Anita Jay(sic) from Oakland Kaiser.           22 thousands of co-workers because they all have the same
23   I'm a shop steward. Secretary Marshall, I thank you for     23 dreams as I do, and UHW is a way to make them possible.
24   being fair and we want to hold you accountable that you     24                        --oOo--
25   continue that fairness in your decision-making. You         25         (Unintelligible) -- I don't know and the other

                                                   Page 235                                                                  Page 237
 1   know, I don't think this hearing really is needed because    1   attorneys has to be fair hearing and I feel like you are
 2   you don't have to have a law degree to know the reason       2   not being fair, see what I see, is not just see here.
 3   why we're here.                                              3   You people are so corrupted it is not funny. See these
 4      Okay, the reason is not what UHW West had done            4   brothers and sisters? This is our union. This is not
 5   wrongly; the reason we're here today is because our          5   your union. John and Sal are answering to us. They work
 6   so-called leader, all right, has too much power and power    6   for us, just like you do. They don't hide nothing from
 7   corrupt good people. He has to have power in his head.       7   us. The money you people get in Washington, D.C. is from
 8   He can do whatever he wants to do. This is a                 8   my COPE pay and from the people that I represent. I
 9   dictatorship regime. This is not democracy. This is not      9   represent Daughters of Charity. I have the highest COPE
10   democratic. Some of us came to America because it has a     10   pay from the kitchen that any hospital had. And I
11   democratic policy, so, we came to enjoy it. What we're      11   promise you -- Mr. Stern, where are you, coward?
12   seeing today, okay, is not democracy. What we're seeing     12      Why aren't you here to answer us?
13   is one man given too much power and oppressing and          13      What you are doing, I promise you, you put the
14   oppressing the people.                                      14   leadership, I will destroy this union. I am a strong
15      Sal is a good leader. Sal care. He cares about the       15   leader and I told the people follow and you have your
16   people. He knows that we can talk to him. We can hold       16   union. I am going to make sure that none of my members
17   his hand. He cries with us. This man is a good man.         17   pay dues or COPE pay. So, I urge you to think about it.
18   He's a good leader. He cares for his people. And I'm        18   What you're doing, you are very corrupted and I am
19   telling you, you know, Andy, this is the wrong thing to     19   ashamed to be associated with SEIU.
20   do. This is something -- this is such a defining moment     20      I am proud to be UHW. This is a great union and
21   in the history of the labor union. We are in economic       21   great leader. And how dare you come here and talk to
22   crisis in America. With all these people here today,        22   John Barsos and Sal and accuse them of such a thing which
23   they didn't just come over here to have fun. They came      23   is not true.
24   here because they care about their job. They care about     24       I come from a country that is not free and this is
25   what is going to happen.                                    25   democratic country and I will exercise my freedom and you

                                                                                              60 (Pages 234 to 237)
                                                    Page 238                                                            Page 240
 1   people in Washington, D.C. -- from Washington D.C. --        1   reputation. You got a chance here to do the right thing.
 2   you're nothing but a bunch of crooks and I am embarrassed    2   All appointed officers almost never rule against the
 3   of that.                                                     3   people that get appointed. I didn't realize you actually
 4                    --oOo--                                     4   got paid by them, as well. We implore you do the right
 5      MR. ROSE: That's going to be a tough act to follow.       5   thing.
 6      Hi. My name is Brian Rose. I'm chief steward at           6       There was no corruption here. There was no cigar
 7   O'Connor Hospital down the road in San Jose. I've been       7   bars going on. There was no backroom deals. We are
 8   there 22 years. The first 15 years, we didn't have a         8   open. We are democratic. We are transparent. And we're
 9   union. The organizers came in around 2001 and I,             9   not going to take it. So, please, take your act, your
10 personally, always believed that what we needed was a         10   little dog-and-pony show, and move it on back to
11 union, but, I didn't want to just jump head, first, into      11   Washington where it belongs.
12 anybody's union because I know that there's some good         12        MR. BAIRD: Will the following people, please, come
13 ones out there and there's some not-so-good ones out          13   up?
14 there. We've got a few of the not-so-good ones at             14         Sharon Martinez;
15 O'Connor representing our other job classes.                  15         Richard Dean;
16     So, I looked into SEIU and I looked; what I saw, I        16         Theresa Peluso;
17 like it a lot, and I got involved and started organizing.     17         Martha Vazquez;
18 I was part of the internal organizing committee. We           18         Jamie O'Brian;
19 voted in SEIU. I then became part of the bargaining           19         Karen Limy;
20 committee and I've remained on all bargaining committees      20         Teresita Anchonto;
21 since then. I took a chief steward role. I filed a lot        21         Porfino Quintano -- I think it is -- from CPMC.
22 of grievances. We are an active union.                        22         Lisa Carroll;
23     SEIU has had our back. They, personally, had my           23         And Juana Castro.
24 back when the employer came after me for my activities        24                   --oOo--
25 and bogused up a bunch of bullshit charges and fired me.      25         MS. DOUGHERTY: My name is Marty Dougherty. I'm a

                                                    Page 239                                                            Page 241
 1   I got my job back because they had my back.                  1   member from Stockton and Modesto.
 2      Sal, Dan, John, we got your back. We are proud of         2     And you guys talk about our transparency?
 3   the historic contracts that we've been part of with the      3        Where is the records of how you guys spent our $25
 4   Daughters and that we've seen in the other health            4   million that we send you guys every year?
 5   systems.                                                     5        And also who told Andy Stern he could use that money
 6      That really started to change this year. The              6   to publish a book and take his staff on a book-signing
 7   Daughters came in and the atmosphere was a whole lot         7   tour?
 8   different. We've actually heard from them a whole lot        8       How is that accounted for?
 9   different and it's about you people from SEIU                9    Who made those decisions?
10   International and this crap you started. You're starting    10    When a decision is made in UHW, the members have
11   division within the union. You're opening a Pandora's       11 some say in it. And we can go to our leaders and say,
12   box here and, just like Pandora, you are not going to       12 who made these decisions? and get an answer. And we do
13   like what comes out. I promise you. I'll be done in a       13 not follow our leaders blindly. We ask questions. We
14   minute.                                                     14 talk about it in committees. We go to meetings and find
15      It's a very easy sell when we explain to the members     15 out what's going on. And then we say yes we go along
16   how they can stop paying union dues, how they can stop      16 with your decision or maybe we need to rework that and
17   paying COPE; and, yes, how they can treat a contract that 17 not just say, hey, okay, whatever you say. We're not
18   you're required to enforce. That's a last resort. We      18 going to be, you know, easy to just push around.
19   don't want to go there.                                   19                    --oOo--
20      But, if you bring in people to take over John and        20     MR. DEAN: Hi. My name is Richard Dean and I'm
21   Dan and Sal's job and the people that are bargaining our    21 going to address you guys as a leader, you know, because
22   contract or lead negotiators, you're gonna get it --        22 a leader is somebody who gets a group of people and don't
23   you're going to get it in spades. You're not going to       23 take them anywhere; just help them get to where they want
24   like it. That's a promise.                                  24 to go. And, if you don't hear nothing else, you need to
25      So, Mr. Marshall, I urge you, don't sully your           25 hear where these people want to go. You know, they want

                                                                                            61 (Pages 238 to 241)
                                                      Page 242                                                         Page 244
 1   to go that way -- UHW. We have respect for our               1   switch hands or something like that. So, we want to make
 2   leadership. They have gotten us the respect that we          2   clear that we will continue the fight even if we have to
 3   needed.                                                      3   do it in the street. Thank you.
 4       And I would just like to tell them I'm really sorry      4                      --oOo--
 5   that this is happening to you, really, because I go to       5      MS. GRIFFITH: My name is Beverly Griffith and I
 6   work every day and have to go through this same stuff.       6   work at Sutter Health. I want to say something else,
 7   You have to fight with the boss to do a job that they pay    7   but, I know you're typing, but, this is what I want to
 8   me to do. You know, Sal is only doing the job that he's      8   say.
 9   supposed to do and he's leading us where we want to go.      9      Out of everything that we have been accused here of
10 And I hope you guys will just let him do his job. Be a        10   today, I want to know who is accountable for your
11 leader.                                                       11   salaries, being flown out here, to divide UHW. I want to
12                 --oOo--                                       12   know whose responsible for all of the mailings and the
13    MS. VAZQUEZ: Good afternoon. My name is Martha             13   hundreds of dollars that go to Washington, D.C., my money
14 Vazquea. I'm a radiology tech at CHW Hospital in              14   that you guys are fighting us with. It's not right.
15 Stockton.                                                     15   Okay?
16     I'm one of the people that was on the PEF fund that       16      I want to know who makes those decisions. I want to
17 received over 100 E-mails a day from Andy Stern because       17   know now the person that needs to be here and the person
18 you have robo-calls coming to me making these accusations     18   that needs to be accountable, today, is Andy Stern.
19 to me without any proof. I would look at each one and,        19       Where is he?
20 believe it or not, I sent myself an E-mail. That's how        20       Where is Andy Stern?
21 dishonest this whole parade has been. I'm sick and tired      21       Andy Stern told us in Minnesota that you, the
22 of all of these accusations about our union.                  22   attorneys, is the ones that make the decision, that's
23     We have strong leaders; John Borsos, Sal, our             23   doing all the corruption on UHW, that's making the false
24 Secretary/Treasurer. We hold them to the highest              24   accusations.
25 respect.                                                      25      Where is Andy?

                                                      Page 243                                                         Page 245
 1      I understand you're doing a job, but, again, we pay       1      I want to know. Andy needs to be impeached right
 2   your wages. Listen to us and don't forget what we're         2   now -- impeached -- get his ass out of office.
 3   saying. You're going to start something you can't            3       I will tell you this: I am at the bargaining table
 4   finish. We're UHW. We're going to fight.                     4   right now fighting a contract of my life where management
 5        MR. BAIRD: Will the following people, please, come      5   has proposed taking away seniority. They are proposing
 6   up?                                                          6   subcontractors. They are waiting at the door to see what
 7      Beverly Griffith;                                         7   you guys are going to do here today.
 8       Pamela Bell;                                             8      Mr. Marshall, you was appointed by Andy Stern. I
 9       Joanne Wales;                                            9   want you to know, you need to be fair. You cannot sleep.
10       Linda Bailey;                                           10   You have a track record be fair to the peoples out here
11       Merrill Rodriguez;                                      11   who really care.
12       Michael Gallegos;                                       12       We are the healthcare workers that is in the
13       Lettie Marquez;                                         13   trenches. Okay? We provide for you and we're telling
14       And Christina Rodriguez.                                14   you now be fair. We know that the things that we see is
15                     --oOo--                                   15   corrupted and the peoples that need to be on trial are
16       MS. QUINTANO: Good afternoon. My name is Porfino        16   not here.
17   Quintano. I am shop steward at California Pacific           17        Where is Andy Stern?
18   Medical Center and I am here to express my opinion about    18        Impeach Andy Stern. Get his ass out of office now.
19   what Andy Stern is doing with his hierarchy agenda. He's    19   I still got some time.
20   trying to run the business union, trying to run as a CEO.   20      I want to say -- I want to say my life holds on to
21   He doesn't understand that the union, as a definition, is   21   you because Sutter is waiting to see what you're going to
22   a united front; that everybody has a voice. We want to      22   do. If I don't have seniority rights, if I'm not a
23   continue our democratic union and he's doing this because   23   union, because they decide to move people out of my
24   he want to divert the corruption of his top-appointed       24   union, they are sitting up here saying, union -- they're
25   leaders and that's only he try to put our union fast,       25   saying the reps, all we got five hours in the facility.

                                                                                          62 (Pages 242 to 245)
                                                    Page 246                                                              Page 248
 1       Come on, now. We are the leaders here. We pay your      1                      --oOo--
 2   salaries. Hear us. I'm a fightin' person. I will            2       MS. PATASKI: Good afternoon. My name is Debra
 3   fight. I will fight. I will hurt.                           3   Pataski. I'm a registered dietician. Back in 2002-2003,
 4       And this lady back here saying, she's saying, is        4   I assisted with the unionization of Kaiser dieticians in
 5   that a threat? No, it's a promise. We are not done. We      5   Northern California. We chose UHW to be our union. We
 6   will fight. I tell my people's every day, we are, look      6   chose them because we looked at a lot of other unions and
 7   to the left, look to the right, look to the front, look     7   saw what they had and what they didn't have, and one of
 8   to the back, because I'm not going to die here. We're       8   things that we wanted very badly was a voice. And, even
 9   going to survive.                                           9   as professionals, we were Not given a voice. We were
10       I've been in trusteeship and I know, since             10 hiding out in Kaiser. And now we have a voice. I'm a
11   trusteeship, we have gone up, up, up. We ain't going       11 union steward. My colleagues also want to be union
12   down. We will not go back 50 years. Go back home.          12 stewards, so, we rotate every year to two years so that
13                 --oOo--                                      13 everybody has their training, everybody knows how to use
14      MR. GALLEGOS: My name is Michael Gallegos. I'm a        14 their voice.
15   member organizer. I'm shop steward. I'm chief shop         15     I'm very disappointed with the events of these last
16   steward. I'm political organizer. I'm in politics.         16 two days. I want to let you know that, if anything was
17      And I want you no know how insulted I am that you       17 done wrong, we will take care of it. It's our family.
18   would come here, insult our house and our Local and our    18 It's our house. We will clean it.
19   president.                                                 19                    --oOo--
20      Who are you to tell us what to do? Because there's      20      MR. CHANDLER: My name is Jim Chandler and I work at
21   no saying that you still have to be our union. We pay      21 Regional Medical Center of San Jose; been there for 30
22   your salary. You need to respect us. This is our           22 years.
23   movement. We decide what we want to do. We shape           23      And, in 1998, ATA bought our hospital and, in 1999,
24   politics; not you. This is our voice and we will not be    24 wound up calling Local 250 at the time and we asked for
25   silenced.                                                  25 help, and they came and they helped us organize. And

                                                    Page 247                                                              Page 249
 1      MR. BAIRD: Will the following people please come        1    we've a lot of lives have been changed and we trust our
 2   up?                                                        2    leaders.
 3      James Bodner;                                           3       And I just wanted to say to you guys, because I know
 4      Debra Pataski;                                          4    it's been a really hostile environment for you, for these
 5      Troy Ortiz;                                             5    past couple of days, I had the opportunity to go to a
 6      Jim Chandler;                                           6    Puerto Rico this year to the convention and that was
 7      Mildred Brown;                                          7    pretty hostile for seven days and really disrespected by
 8      Nancy Evans;                                            8    the rest of SEIU; and that's sisters and brothers.
 9      Dacina Howe;                                             9    I work really hard and I feel like I'm handing you
10      And Nancy Stengle.                                      10 my wallet and you're taking money out and using it
11                    --oOo--                                   11 however you want to.
12       MS. ALEDEROS: Okay, I'm Debbie Alederos. I'm the       12    The reason I called for the union, it wasn't because
13   chief shop steward in Modesto and we have followers. We    13 I wanted to get paid more. When ATA came, they're a
14   are opening a hospital Wednesday and I've got 246 people   14 corporation. They don't care about employees. They
15   and the head of the union team which is a union-based      15 don't care about patients. I called because I'd been
16   team, is what our union put in our contract. It's where    16 there for 20 years at that point and never seen staffing
17   the employees' voice is heard.                             17 like that, ever. That affects how patients get treated.
18       I can call Sal and he'll answer me. If I have a        18 I care about patients. I wish that you guys would.
19   problem, Sal answers me; but, it's not Sal's union. It's   19                   --oOo--
20   not John's union. It's our union. This is how we vote.     20    MR. MILLER: Hi. My name is Baron Miller and I'm
21   This is our voice. It's our union. Pack up, go home,       21 not a member, but, my wife worked for Kaiser and she's a
22   because you cannot -- you need to leave us alone. Our      22 member. And she didn't know how much power she had until
23   union protects all of us; protected our jobs. Do you       23 she was faced with our management was beating her down.
24   want us to lose our houses and lose everything we've       24 She lost our first child. She work for Kaiser.
25   fought for for so long? Back off.                          25    But, all I wanted to say is she lost her baby, and

                                                                                          63 (Pages 246 to 249)
                                                         Page 250                                                       Page 252
 1   when she found out that she was a member of the union,          1   thieves, and cigar smokers. We hope that Tyrone and
 2   she found out the union came in and they made her               2   Pilar had a great time on their Hawaiian honeymoon that
 3   stress-free. And they went there and they kick                  3   we paid for with our dues money with Andy Stern's
 4   management butt. They kicked management butt when they          4   blessing. So, we don't want a top-down unionism. We
 5   backed up my wife. Okay, now, she's stress-free. We             5   want member unionism and that's what we're going to keep.
 6   have a child for two years. I love the union I wish I           6                  --oOo--
 7   was a part of it.                                               7      MR. COLE: I'm also not in order. My name is Butch
 8                    --oOo--                                        8   Cole. I'm a surgical technologist from Rockwell
 9         UNIDENTIFIED MEMBER: I apologize. You know, I've          9   Community hospital. And, Mr. Marshall, I thank you very
10 been on strike for, like, the last couple of days. Since         10 much for being here.
11 we went on strike Wednesday and Thursday, Mr. Andy Stern         11    I feel however as though we're filming a very, very
12 froze the strike fund. Okay? We had $6 million lockout.          12 expensive movie and for an audience of one and he's not
13     All right?                                                   13 gonna watch it.
14     What do you have to say about that?                          14     I sat through the questions about transparency and
15     Is it a vendetta or what?                                    15 I'm a former board member and I stupidly and regrettably
16         Is it retribution against Sal or what?                   16 resigned from the Board when it was still Local 250.
17         Because we know him. He's targeting us.                  17     One of the things I can tell you from the Executive
18         And also I would like to say, is this what he's          18 Board was that it went to the point of annoying on how we
19 going to do?                                                     19 had to listen to every single penny that went anywhere.
20     Is Detroit a union?                                          20 It drove me nuts. I kept wanting to raise the amount of
21     Because, in California, I guarantee you that our             21 how much we -- the minimum amount we had to look at --
22 bargaining are going to find a new union; and, if you            22 and it didn't happen.
23 think that we can't mess with you, we'll show you. And,          23     I just feel -- I live in Watsonville where -- three
24 once we start doing it, the other ones will follow us.           24 hours away from Oakland. I'm not on the Executive Board,
25 You will destroy SEIU. Okay?                                     25 but, I knew about the Patients Education Fund. I

                                                         Page 251                                                       Page 253
 1         MR. BAIRD: Will the nothing people, please, come          1   wouldn't be able to tell you if I were sitting in that
 2   up?                                                             2   witness chair how I knew about it, but, I knew about it.
 3         Sandra Martinez;                                          3   And I have the same question that you folks had. Up to
 4         Cindy Thomas;                                             4   $6 million? But, you know what? The reason I and my
 5         Orline Person;                                            5   fellow members didn't question it is because we elected
 6         Anita Wicks;                                              6   those Executive Board members and we knew that they and
 7         Panseco Gatto;                                            7   Sal Rosselli and everybody else up there were going to be
 8         Jonathan Welch;                                           8   responsible to us. If they screwed up, if that money
 9         Michael Forrest;                                          9 went someplace that we didn't feel was right, they were
10         And Roberto Alvarez.                                     10 in trouble. Thank you.
11                       --oOo--                                    11                    --oOo--
12     MS. WALKER: Well, my name is not any of those                12     MS. NUNEZ: Hi. My name is Bertha Ferris-Nunez.
13 names, but, since no one stepped up here, I am. My name          13 I'm the chief steward at Salinas Valley Memorial
14 is Suzette Walker and I'm a 30-year CHW employee; but, I         14 Hospital. And I'm sure all of you guys know where that's
15 more proud of being UHW steward. So, I want to thank             15 at because it's by Pebble Beach, Monterey, and all of
16 you, Mr. Marshall, for allowing us the privilege to              16 that.
17 attend your kangaroo court for the past two days.                17     I just want to let everyone know that I think SEIU
18     We have worked long and hard to become the respected         18 has lost the main focus of what a union is. I think the
19 Local that we are. We are committed to equality for all          19 union is their members, and I think the Washington has
20 of our members -- our elected -- not appointed -- but,           20 lost that whole idea somewhere along the way. And I also
21 our elected leaders with the assistance of our shop              21 believe that they're looking scared because here are UHW.
22 steward's and our field reps keep us informed about us,          22 We're doing that and you know we are very proud of our
23 the members, to make decisions that affect our everyday          23 leadership. And you guys should be looking at UHW to
24 life.                                                            24 make changes for all the working people; not destroying
25         We don't want to be associated with lawyers,             25 us. And so I want to make sure that all of you guys know

                                                                                            64 (Pages 250 to 253)
                                                      Page 254                                                         Page 256
1    that the power is on the members, and the members at UHW     1                     --oOo--
2    are the ones to make the decisions. Thank you.               2       MS. TAYLOR: Hi. My name is Carol Taylor. I've got
3                      --oOo--                                    3   a card up there with you. I'm a steward from Marin
4       MR. BARBERO: Hi my name is Doug Barbero. I'm a            4   County. I'm also a proud member of the Teamsters Local
5    steward at Kaiser Hayward. I've been a steward for 20        5   853.
6    years, since I got into Kaiser. I started as a steward       6      When I tell my Teamsters brothers and sisters what
7    in '68 in the beer and soft drink companies and then I       7   UHW is doing, they go, what? What union is that? I
8    became a Teamster. So, I came in with a lot of               8   mean, my business rep, Jess Destares, he loves it. It's
9    knowledge, but, not in healthcare.                           9   got a real party going on there.
10     Our contract is valuable to us. Everyone in the           10       I want to thank you, Mr. Hearing Chairman, for your
11 country right now is looking at the Kaiser contract. It       11   respect for the elections. I understand that you ask
12 benefits, I think, the entire country.                        12   that this be postponed. I asked all of you, as
13     Now as a steward and an advocate for every member in      13   Americans, to please understand we need to elect Obama.
14 that hospital chain, I've been fired three times and,         14   We've got local campaigns. We have to win. Thank you.
15 because I know the contract, every one was illegal, so, I     15                    --oOo--
16 got my job back. Last one was for three years, but, I         16       MS. THOMAS: Hi. My name is Lisa Thomas and I'm an
17 came back to work. And I'm a little stronger now.             17   X-ray tech at Santa Clara Kaiser. I first would like to
18     During this time, I've known another speaker here,        18   speak to the attorneys that are sitting on this side of
19 Simon Brasil. He came up to the microphone here and he's      19   the room. You once went into this business because you
20 taking a vendetta against the union for personal reasons.     20   wanted to represent labor and the labor movement. I'd
21 He was asked to leave our steward union because of the        21   ask you to call back upon that, what brought you into it.
22 way he was acting here, he did at our Steward Council         22   Red is perfect color for our members out here because
23 meetings. Nobody had a say without his interjection of        23   we're pissed. We are so pissed. You guys have trained
24 what he wanted. And I still feel good to this day that        24   other reps from other Locals telling them -- we know the
25 he no longer is a steward with us. He intelligent. I          25   Board members on other Locals -- and telling them you

                                                      Page 255                                                         Page 257
 1   won't say he's dumb at all; but, he's just taken the        1    need to be prepared because this union is violent.
 2   whole contract a whole different route without democracy    2       I was at Labor Notes. I saw how the buses came in
 3   and we, in Kaiser, believe in democracy as the union        3    from the International and they raided that conference.
 4   does.                                                       4    That's where the violence is coming from.
 5                     --oOoo-                                   5       I went on the Take Back Labor Day tour. We weren't
 6      MS. GUZMAN: Hi. My name is Ruby Guzman. You              6    invited to be on the buses. We met with the members at
 7   didn't call my name, but, I just came up. I'm here to       7    each stop as we went by, we made friends with them. We
 8   talk about joining UHW. I was a member of another union     8    have same goals. We want to make sure we have universal
 9   and we as co-workers decided to join UHW because of its      9 healthcare. We made friends. Those members got on the
10   reputation. We joined UHW and I became part of the          10 buses and, at the next stop, they had daggers for us.
11   bargaining action committee. And one thing I noticed        11 They were on the buses with Andy Stern and Anna Burger.
12   that UHW is not a sellout. During our bargaining the        12 Somebody changed their minds and told lies about us.
13   company was waiting to get that proposal from another       13 This whole thing is such a sham.
14   Local in the south, 6434, and they sold their companies     14     We know that -- we know that the fund that we set
15   out. They gave poor mediocre wages.                         15 money aside for that we wanted to have to pass for the
16      What UHW did for us, they gave us a wage scale that      16 state California to have universal healthcare was so
17   became equal to Kaiser wages. That is so significant in     17 important to us that we wanted to move it there.
18   contracts. Because of that, I don't have to work two        18    We also know that the International, you guys, have
19   jobs. I can remain in one job, have health insurance,       19 similar funds, but Andy is so convicted with tearing down
20   and still continue my education and you -- so, what all     20 power in UHW, that much, he's going to go to any
21   these stories, all the members, we're all united. We're     21 length -- any length -- to tear down our power.
22   here because we want to be with UHW. Look, every story      22    And I say, shame on you guys. Shame on you guys for
23   is relevant. The jurisdiction, well, that didn't work,      23 tearing down the labor movement because this union, this
24   right, because we gave a fight. We will not go down         24 union right here, they know what democracy is about.
25   without a fight                                             25 They know how to represent their members. They know how

                                                                                          65 (Pages 254 to 257)
                                                       Page 258                                                      Page 260
 1   to bargain contracts. They know how to vote politics.         1      SECRETARY MARSHALL: All right, thank you.
 2   They know what's right for the Californian's healthcare.      2      MR. SANCHEZ: Secretary Marshall, my name is
 3   They know what's good for the labor movement. How dare        3   (unintelligible) Sanchez. I'm Kaiser with Baldwin Park.
 4   you try to change that.                                       4   I've been a steward for about a year-and-a-half. I've
 5                     --oOo--                                     5   been a union members for nine years.
 6     MR. NELSON: My name Hans Nelson. I'm a                      6       You know, my parents came to this country having
 7   medical-legal clerk for Kaiser South San Francisco, 19        7   nothing. My -- two of my brothers served in Vietnam. I
 8   years. I'm going make the best of my two minutes.             8   served under your President Marshall as a United States
 9      I'm going to show you a humble man. Sal, could you         9   Navalman. And I know I was willing to put my life on the
10 stand, please? Would you stand, Sal Rosselli? And I            10   line to protect all of us here. My brothers are willing
11 just want to encourage and take my two minutes to              11   to put their life on the line, one in Europe and one in
12 encourage up at this time all those lies and allegations.      12   Southeast Asia. And what we're seeing here is we're
13    Sal, you remember. 19 years ago, I was there at             13   seeing a tyranny, a guy that has totally taken his
14 25,000 members when they called us a little peon union.        14   abusive power and he's abused it.
15 I was there at 50,000 members as we celebrated our             15       When I became steward, I looked at it, what does
16 growth. I was there at 100,000 members when we thought         16   this guy do? First, he wants to say we're rigging votes;
17 we was doing something.                                        17   now, he's -- I mean, come on. Let the light shine on the
18     And now that we're on the verge of 200,000 members,        18   truth. The truth is that he's got a lot of corruption in
19 I understand Andy Stern's position. My mother always           19   his own place; that's where we're going to take care of
20 told me -- I'm an old boy from Oklahoma. My mama always        20   that with our Congressman and Senators.
21 told me that don't nobody want nothing that don't nobody       21      So, take back to Andy Stern, please, Secretary, the
22 want. So, if you can follow, that means that you have          22   union, you tear us all up through the movement, so, look
23 grown us to be something. And I understand that Andy           23   at this in the light. Take care of what you appointed
24 Stern is trying to go over and take over because there is      24   and own up to what you've done. So, that's all I have to
25 powers in numbers.                                             25   say. I believe in this union. It's done great things

                                                       Page 259                                                      Page 261
1       But, I do want you to understand my brothers and,          1   for my family. And I really believe that this is the
2    most importantly, Mr. Arbitrator, I want you to go home       2   wrong thing to do, put us in trusteeship. But, we don't
3    and sleep well; but, yesterday was very reflective on         3   go down because there'll be other things coming up in the
4    what we're dealing with here, brothers, sister.               4   International that you guys might be hired for those
5    Yesterday, the dinner they're offered to us, the dinner       5   things.
6    that we paid for, we went over, once again, we were told      6                      --oOo--
7    that some seafood was being done, but, it's only for the      7      (Unintelligible). I have a short time to be here.
8    SEIU folks. And you know what I told the guy? That's          8   I have to catch a bus and go back to Oakland. I'm a
 9 very reflective of what it is we're dealing with. Now,          9   nursing assistant at (unintelligible) Care in Pittsburg,
10 the folks on the higher level get the better things and        10   California. I'm also the chief steward and shop steward
11 the trickle down theories affected not only Republican         11   in. I was going to get up here -- I said, if I miss the
12 nature but within the union.                                   12   bus, I was going to miss it.
13    We shouldn't have to battle with that. So, I ask            13       But, you know what? This is a farce. I thought for
14 you today, brother, that's that a reflection of the            14   one time that I might have been in Australia. This is a
15 character of the person we are trying to turn our union        15   kangaroo court, Mr. Marshall. I have read your
16 over with.                                                     16   impressive resume, but, you know what? This is like
17    And I ask you, once again, to go home tonight and           17   Jesus standing before Pontius Pilate. We are innocent of
18 exercise some common sense, which is what these people         18   all charges, sir.
19 have. We may not be on the floor of jurisprudence as the       19       What you need to do is E-mail Emperor Stern and
20 rest of you, but, we have common sense; and common sense       20   Empress Burger and tell him and her know that I find no
21 in this forum, today, is telling us to turn over our           21   fault in Sal Rosselli. I find no fault in UHW. These
22 finances to a certified crook; one, who's, if I were you,      22   people are innocent. Sir, as of this day I resign. I
23 don't take their word. Public opinion, take the advice         23   resign. I resign the post that you have assigned me to.
24 of the songwriter and simply call Tyrone and he'll tell        24       And, lawyers, you need to get real. This is our
25 you all about it.                                              25   union. This is our house and we're not going down. I

                                                                                         66 (Pages 258 to 261)
                                                     Page 262                                                         Page 264
 1   didn't come from Pittsburg, California to be on the good     1   technology.
 2   ship Titanic. I'm going to fight with every inch of my       2                    --oOo--
 3   body. I will die before you let the union go into            3      MR. SILVERIA: Good afternoon. Thank you for your
 4   trusteeship. You cannot stop it. It is member-driven.        4   time and being here. My name, as of 11:15 a.m.,
 5   It is productive. Sal Rosselli and we are going on.          5   yesterday, and the grace of the California Supreme Court,
 6                      --oOo--                                   6   is Paul Silveria. I got married yesterday morning.
 7        MS. BECKHAM: Hello. My name is Linda Beckham. I'm       7       And I came here today to be here to fight for this
 8   a Northern California Kaiser employee. I went to work        8   union. There's a lot of discussion on transparency and
 9   for Kaiser Permanente in 1969 -- and, I'll do the math       9   several of the attorneys have asked about the PEF and
10 for you. I've worked for almost 39 years. And I made          10 several other funds that I, as a member, am very well
11 the mistake of becoming a manager; and that was the worst     11 aware of; and where the money went and how it was spent.
12 four years of my life; and I've been back in the union        12     I sat with Dave Keefer in Oakland, last week, and
13 movement ever since.                                          13 I've also E-mailed Anna Burger and several other key
14     I was part of the 1974 bargaining -- not as a             14 members of the financial committees of SEIU, and I wanted
15 member -- but, in 1973, we were on strike. We were            15 to know where my money had been spent against my union
16 members. We found out what it was to get a nickel and a       16 and. To date, no one from SEIU has responded to me.
17 defined benefit. I think we actually went over the two        17      I asked the same question of our Executive Board as
18 dollar mark in wages. We got dental. We had the               18 to how our money got spent in defense of our union; and I
19 opportunity to have maternity care, where we only had to      19 will tell you that I have been told by UHW, exactly,
20 pay for the television set in the room.                       20 where my money went. And I know how it was spent and I
21     There were things that happened for us that were so       21 approved of every dollar and penny of it being spent that
22 important and so big that, in 1974, when Tim Toomey asked     22 way. Please do not trustee UHW. We are the union. We
23 us, at our union meeting to sign up to pledge allegiance      23 are our members and we support UHW. Thank you.
24 to SEIU, we did; and we did it proudly.                       24                  --oOo--
25     And, since then through the trusteeship that we went      25      MS. GARCIA: Good afternoon, ladies and gentlemen.

                                                     Page 263                                                         Page 265
 1   through in 1986, I learned that there was a different way    1   My name is Mel Garcia. I am a medical assistant at
 2   of doing business.                                           2   Kaiser Permanente in Hayward, California. I'm also a
 3      I've moved forward. I was an Executive Board              3   steward -- a lead steward -- a representative chair
 4   member. I've been a steward. I knew when I was an            4   second term for my work site Steward Council. And I am
 5   Executive Board member my job was to go out and share        5   most proud to say I am also a Executive Board Vice
 6   with the convalescent homes in my county and share with      6   President for United Healthcare Workers-West.
 7   them what was happening. I also know that I was supposed     7        I've worked for Kaiser for 31 years and I'm going to
 8   to carry with me the financial records. This is a            8   tell you all today, like I told Mr. Keefer, yes, I was
 9 longstanding practice. I also know that as a dues-paying       9 the one that let all those members in to the Oakland
10 member of UHW, I have the right at any time to go to an       10 Tribune building into Room 725. You don't know me. You
11 Executive Board meeting. I have the right to listen to        11 don't know what kind of person I am. You don't know what
12 what is discussed; and I do whenever it's in my schedule      12 kind of work I do. You don't know how I am about my
13 and it is scheduled in Northern California. I'm one of        13 members.
14 the people that you will see there. There are not a lot       14    But, today, you ask any member that knows me and
15 of them because of the amount of trust that we have in        15 they will tell you that I am about the members, for the
16 our elected officials.                                        16 members, because of the members.
17     I have one other thing I want to say. Healthcare,         17     I also recently started a contract specialist
18 today, is in a crisis with technology and I'm one of the      18 position with United Healthcare Workers-West. It's
19 people that's helping work with workers and their ideas       19 probably the best job I've ever had. Why? Because I get
20 on how to cope with job loss because of technology.           20 to talk to the members day-in-and-day-out.
21    And the one thing I have not seen is anybody from          21     So, don't sit up there and assume anything. You
22 SEIU come down and help us deal with how we make people       22 don't come to work sites. You don't see rank-and-file
23 move forward. It's an education fund and if we could          23 members on a daily basis, sometimes, 24 hours day. You
24 have the patient defense fund back, I believe we could        24 don't come out to our work sites to meetings to help us,
25 make real differences in how people are treated based on      25 as my sister before said, improve, since we're going into

                                                                                          67 (Pages 262 to 265)
                                                     Page 266                                                       Page 268
 1   this technology world. Don't assume that you know what I     1      You want real reform and real justice?
 2   want.                                                        2       So, who better yet to do it than a member who pays
 3       But, I'm going to tell you what I want. I want to        3   their dues, Who shows up and who will speak for
 4   stay in UHW. I would have been and still continue to be      4   themselves because, when it comes to representation, it's
 5   a 31 year rank-and-file proud member of UHW because no       5   nothing like somebody who knows from in-house, not
 6   matter how many elected -- and let me underscore             6   outhouse. If you want to network, if you want somebody
 7   elected -- titles and positions that I have, the bottom      7   that stands with you, then you come to union territory.
 8   line is -- my foundation is -- I am a rank-and-file          8   You're not by yourself. You're not trying to stand on
 9   member, just like every single person in this room. So       9   your own, because we have brothers and sisters who are
10 until, you know me, don't assume that you know what I         10   willing to stand and fight. If you want real members to
11 want. Thank you                                               11   show up then come to our house and tell us what you think
12                  --oOo--                                      12   we should do, what you think we should have, and who we
13     MS. SWAGGERT: Good evening. My name is Irma               13   should have.
14 Swaggert, and I am a retired UHW worker; however, one of      14      Now, if you've looked at the commercials and you've
15 the reasons I did retire is because they went into this       15   seen Verizon and you see all the networks, when one
16 10-2-1. That is the biggest mess Alameda County Medical       16   person -- stand up, you guys, because I want them to see
17 Center has ever been through.                                 17   who is going to stand behind Sal, because we are the
18     Years ago, H.I.V. services, the service that I            18   network. We are going to stand with him. And you say
19 worked for as an LVN, was closing. UHW came out, fought.      19   that you came because we have lost the leadership. We
20 We had some political activists that were affected by the     20   all have faith in our leadership. Didn't anybody votes
21 disease. They kept H.I.V. open. Two weeks ago, on             21   like that, didn't anybody think like that.
22 Friday, H.I.V. is closing. 10-2-1 has not done a thing.       22       So, who told you that we lost faith in our
23 These people are all looking for jobs today. H.I.V. is        23   leadership? Andy Stern. And you're going to accuse
24 something very necessary.                                     24   somebody in the -- since all of you are attorneys, the
25    And, actually, today, I would rather be doing              25   accuser usually has to show up, if you're going to accuse

                                                     Page 267                                                       Page 269
 1   something else, but, this is something I feel very           1   somebody. But, I have looked high and low, out and in,
 2   necessary. I would like to be phone-banking to make this     2   all around, and I have yet to see Andy Stern anywhere in
 3   country is better, but, unfortunately, I'm here to make      3   the house. Where is he? He's hiding in Washington, D.C.
 4   sure that the union that I have been with for the last 20    4   If you're going hide in Washington, stay in Washington
 5   years is able to stay viable, because we definitely need     5   and don't send your cronies to do your job. If you want
 6   UHW.                                                         6   to accuse our president, then you should show up as your
 7      I'll volunteer doing down there and do whatever they      7   president.
 8   needed to because I'm retired from Alameda County 10-2-1.    8                     --oOo--
 9 If you need a union rep, you have a 1-866 number to call       9       MS. THIGPEN: Hi. I'm Haley Thigpen and I'm a
10 to Southern California to get some representation.            10   social worker from Kaiser in Fremont.
11 That's not how a union works, not at all. And I don't         11       And, Mr. Marshall, I'm going to address you because
12 appreciate it. I want UHW to stay viable like it's been       12   I know you're the decision-maker here -- well, you and
13 since I've known it, since 1979.                              13   the SEIU Executive Board. I'm concerned. I'm confused,
14     And that I hope that you can consider H.I.V. is           14   first of all, why you're hearing this case. There's a
15 closing now under this 10-2-1. No more help. All              15   lawsuit that you're addressing that's at issue at this
16 they're saying is, well, it's time. You knew it was           16   hearing which has already been thrown out of California
17 coming. That's not what UHW said. UHW said, we're going       17   court. So, I'm confused about why you think you can do a
18 make it happen. We're going to keep these people              18   better job here than the California court did.
19 working; and it happened just the way they said. Thank        19      And, secondly, I'm confused because I understand
20 you.                                                          20   that the Department of Labor requested the right to have
21                     --oOo--                                   21   an observer here and that you, after conferring with the
22     MS. PEACOCK: Hello. My name is Cheryl Peacock.            22   SEIU International Board, declined that request.
23 I'm from North Bay. I work at Kaiser Vallejo. And I'm         23       And I'm concerned because I mean I feel like, if you
24 just here to give my voice.                                   24   think you can do a better job than a California court,
25     You say you want a real voice?                            25   then you might want to have a Department of Labor

                                                                                         68 (Pages 266 to 269)
                                                      Page 270                                                        Page 272
 1   representative here to observe it and to add legitimacy    1        We should also be working together to get universal
 2   to this hearing.                                           2     healthcare. Why is SEIU creating fake battles when we
 3       SECRETARY MARSHALL: Let me tell you that the U.S.      3     have real battles to fight in this country?
 4   Department of Labor observers were here.                   4        And I urge you and I urge the SEIU Executive Board
 5       MS. THIGPEN: Were they?                                5     to get back to the real battles at hand; and, you know,
 6       SECRETARY MARSHALL: Yes, they were.                    6     if they're not sure how to work towards these things, UHW
 7       MS. THIGPEN: Great. Are they still here?               7     would be happy to show them the way.
 8       SECRETARY MARSHALL: I don't know. Is the D.O.L.        8        SECRETARY MARSHALL: All right. Thank you.
 9   people still here? They were; but, they did come and       9        MS. JANKOWSKI: Hi. My name is Sharon Jankowski. I
10   were here throughout most of the hearings.                10     work at Good Samaritan Hospital in San Joe. This is my
11       MS. THIGPEN: Great, great. I'm glad.                  11     son, Jared, and he's a future leader of UHW.
12       So, also, I mean, I feel like that's not much         12        And I just want to tell you, for the gentleman back
13   justice going on within our union right now. I mean, the  13     there, about Ralph. If it wasn't for Ralph, I wouldn't
14   SEIU International is filing lawsuits against its own     14     have a job or my home today.
15   members. But, we still have free speech, thank God, and 15          But, anyways, I met Sal probably seven years, eight
16   I understand that there were reporters here from our      16     years ago, and, if it wasn't for him, we all wouldn't be
17   major publications, our most reputable publications in    17     here right now, because we all have everything in the
18   the country during these two days.                        18     world that we need in our contracts and then some. And
19       So, I hope if you're not really concerned about       19     every year that we do a new contract, we get even more
20   justice, that you will be concerned about your reputation 20     and more that's better for us; not for the corporate and
21   and your credibility. I think that the nation is          21     the CEO's of the hospitals.
22   watching you now. The nation is watching. The whole       22         And nobody here which is on your side even looks at
23   labor movement is watching what's going on in these       23     the patients. If trusteeship comes, what's going to
24   proceedings.                                              24     happen to our patients? They don't look at that. You
25       Thirdly, SEIU International has accused UHW of many, 25      know, all they look is, come in and saying we're not

                                                      Page 271                                                        Page 273
1    many things that are untrue; but, one of them that is        1   doing the right job.
2    most egregious to me, right now, is that -- but, this was    2      Well, you know, we've come a long way from when I
3    a response. Can I ask for a little more time because         3   came seven years ago to now, and we have a lot of people
4    there was a response?                                        4   now, and all of us will stand together against all of
5       SECRETARY MARSHALL: Finish your thought.                  5   you -- which isn't very much -- I don't think so. You
6       MS. THIGPEN: Thank you. I'm pretty excited to have        6   know, we all stand together. One is one, so, thank you.
7    this mic' in my hand.                                        7      (Unintelligible) I'm in Fresno in home care. My mom
8       So, SEIU has accused us of many things, including         8   took care of my grandma and now I'm taking care of her.
 9 just-us unionism, just being concerned about our own           9   And I don't believe this shit. It's bullshit. We stand
10 members. This is clearly false, shown by the fact that        10   together as one. We stick together. Like my shirt here:
11 we've organized more member than all SEIU Locals in the       11   All together, union one, go.
12 last year. Unfortunately, organization with Stanford,         12                      --oOo-
13 Anna Burger, our own union leader, sent letters to these      13        MR. GROSS: Hi, Mr. Secretary. My name is Spencer
14 members, those potential members, these employees that we     14   Gross. I'm a clinical psychologist. Can you hear me
15 were trying to organize, alleging corruption in UHW.          15   now? Okay, thank you.
16     Now, this is union busting at the highest level and       16      Mr. Secretary Marshall my name is Spencer Gross.
17 we're being accused of just-us unionism. Also, we've got      17   I'm a clinical psychologist. My doctorate is in
18 important things to be doing in this country right now.       18   psychology. I've been practicing in Kaiser Permanente
19 I'm supposed to be in New Mexico, right now, with my          19   for 20 years. I'm in Pleasanton. I'm a member of the
20 brothers and sisters in SEIU Locals fighting to get a         20   UHW's Behavioral Health Professional Chapter, which has
21 democratic president elected. I'm not there because I         21   about 1100 mental health practitioners.
22 had to be here to defend my own union; and I'd much           22       First, I understand the concerns of UHW members that
23 rather be here. But, if I didn't have to defend my own        23   you are asked to chair this hearing without consultation
24 union, I could be working to get Obama elected. That's        24   of UHW. I think that UHW should have been consulted;
25 what we should be doing right now.                            25   however, I want to say that I was actually relieved when

                                                                                         69 (Pages 270 to 273)
                                                     Page 274                                                             Page 276
 1   I saw that you werea member of the Carter Administration,   1    only about money.
 2   were involved, because I think the Carter administration    2       We didn't hear anything about patients' care. We
 3   was, perhaps, the most ethical administration we've had.    3    didn't hear anything about what quality care we are
 4      I hope it's clear to you that what you've been           4    giving for our patients or what quality benefit we have
 5   pulled into that this issue of the PEF might be boiled      5    in the workplace or how proud we are to work in the
 6   down to a semantic argument about what constitutes          6    workplace. We are -- we stand our head straight to do
 7   non-profit education -- by any other definition -- a        7    whatever job is request for us because the union is
 8   broad definition -- and that it boils down to this,         8    behind us. We don't scared from anything. So, whatever
 9   because:                                                    9    you're talking, it is about money; and, if it is about
10      There is no allegation of misuse of funds for any        10 money, it will be tomorrow. We won't send for the money,
11   personal gain or profit;                                    11 if you're sitting in that seat.
12      No trips;                                                12                     --oOo--
13      No cars;                                                 13     MS. CHRIST: Hello my name is Carol Christ. I'm a
14      No swimming pools;                                       14 medical transcriptionist and chair of the medical
15      No nepotistic jobs;                                      15 transcription bargaining committee at Kaiser Permanente
16      And, as far as I know, no cigars.                        16    First of all, I want to give accolades to our court
17      So, this attempt at trusteeship, okay, only makes        17 reporter because I admire her work so much. She doesn't
18   sense within the political contest which has been           18 have the advantage of rewind, but -- so her work is even
19   described, this struggle for democratic local control of    19 more demanding than ours.
20   unions.                                                     20    I was born in Detroit, Michigan and lived most of my
21      I have just one more sentence. The main thing I          21 life in Michigan until I came to California ten years
22   want to communicate is that I have never seen any           22 ago. My father Richard Christ was a UAW organizer in the
23   behavior by Sal Rosselli as anything but principled and     23 1930's and 1940's when the battle for union rights
24   in support of the labor movement in general and in          24 involved murder and mayhem. He was chased down alleys by
25   support of the importance of the voices of local union      25 goons. He was accused of crimes he didn't commit. I

                                                     Page 275                                                             Page 277
 1   members.                                                     1   remember, as a child, the indictment of Dave Beghead of
 2     Trusteeship, certainly, will not serve our members.        2   the Teamster's Union who was convicted for racketeering.
 3   Thank you.                                                   3   I also remember the murder of Ken Yablonsky who
 4       SECRETARY MARSHALL: Excuse me. Just a minute. I          4   challenged the leadership of the Teamster's Union. My
 5   think we can stay. I'm not sure about it, but, we            5   memories of the trade unionism are long and they can be
 6   planned to cut this off at 5:30, but, I'm going let the      6   very unhappy memories.
 7   people who are standing already in the line speak; but,      7      But, I want to say, in April, in Detroit, of this
 8   that will be when we need to finish here. Go ahead. I'm      8   year, Labor Notes, a progressive labor newspaper which
 9   sorry to cut you off.                                        9 trains and advocates and teaches people in union
10       MS. POTI: My name is Nasbat Poti(sic). I work in        10 organizing and in advocates for democracy in unions, held
11   Kaiser Oakland as a CNA for 17 years. Our union is          11 a conference and, at that conference, I'm ashamed to say
12   strong. Our union is taking care of us, taking care of      12 SEIU members invaded the conference and injured people
13   our patients. There is nothing we can complain about        13 and caused a death from a heart attack of one of their
14   our union.                                                  14 own members.
15      Who are you guys coming here and saying the union is     15      Now, what I want to say is the latest news from
16   doing things wrong for us? We trust our union. We have      16 the -- okay -- the latest news from our Los Angeles Times
17   good benefit for our family. We are raising our kids,       17 is, according to the U.S. Department of Labor, over $27
18   sending them school to be good citizen for next             18 million of our union dues have gone to pay family members
19   generation, and we are working hard to do these things.     19 of SEIU members and outside counsel. This is called
20      So, I didn't hear anything that you guys say this        20 cronysm.
21   union didn't do this for you guys. They didn't do this      21     So, I want all of you, my brothers an sisters in
22   for the patients. All I heard is about the money, money,    22 this union, to E-mail, call, or write your Congressman
23   money. If it is about the money, next time, when you        23 and Senators Boxer and Feinstein and request a
24   guys are in the seat, you're going to sell us for           24 Congressional hearing on malfeasance of Service Employees
25   something, too. That's what we can expect in you. It is     25 International Union and then we will see who is

                                                                                           70 (Pages 274 to 277)
                                                     Page 278                                                         Page 280
 1   exonerated and who is indicted.                              1   Local 535. I appreciate this union. I'm so grateful to
 2                   --oOo--                                      2   be a member of this union. And I ask you to please keep
 3      MR. SCHWARTZ: Hi. My name is John Schwartz. I             3   us out of trusteeship.
 4   work for Dominican Hospital of Santa Cruz. It's part of      4       I'm appalled that we're here dealing with this right
 5   Catholic Healthcare West. I'm also on the bargaining         5   now we have other issues that we need to be dealing with
 6   team. And I speak for me and all the other members of my     6   at the national level and at our hospitals, in our homes,
 7   bargaining team.                                             7   dealing with our employers. My members have several open
 8      We respect Sal. We respect John. And we know that         8   grievances right now. I haven't even been able to talk
 9   CHW is waiting to see what happens at these hearings         9   to them about them for the last couple days because I've
10   because they, continuously, do not bargain. They go out     10 been here helping with this. Our fight should be for
11   shopping. They're not in bargaining. We know that.          11 labor. It should not be against each other. And this is
12   We've seen them at the malls. We do not want you guys at    12 in-fighting at the worst level. We should all be unified
13   our bargaining. We didn't ask you to show up, but, you      13 in one cause and that's labor. Thank you.
14   showed up. We kicked you out and we don't want you          14                    --oOo--
15   there. And how dare you sit here and accuse Sal and our     15      MS. WILLARD: My name is Anne Willard and I am a
16   E-Board members of doing wrongdoings? We elected them       16 California Laboratory Scientist at Sequoia Hospital, a
17   and we can kick them out.                                   17 part of CHW, where I have worked for 41 years. And
18      They're here. Where's Andy Stern? He's not here.         18 almost that whole time we have been unionized; but, for
19   He's accusing us, he's calling us, and mailing us, all      19 many years, we belonged to SEIU 535.
20   these accusations, using our union dues; and, if you        20    Several years ago, we began to realize that our
21   think he's not going to sell you guys down the river,       21 union wasn't really doing us much good and we began to
22   you're sadly mistaken, because he will he stab us in the    22 look around. And after we talked to our field rep, she
23   back, he'll stab you in the back as well.                   23 said to us, well, you know what? You're right. You're
24       And I speak for all of my brothers and sisters that     24 an anomaly to us and we don't know what to do with you.
25   are in bargaining, too; that's why their facilities are     25 So, she suggested that we join UHW. And, in 2006, we did

                                                     Page 279                                                         Page 281
 1   dragging their feets because they think they're going to     1   and finally we know what the union is all about. We know
 2   make a backdoor deal with you. We've told CHW that, if       2   the advantage that we have for belonging to a union.
 3   you think that you're going to make a backdoor deal with     3      And, as I have been here over these last two days,
 4   Andy Stern, you're sadly mistaken. We kicked you guys        4   and have listened to hearing procedures that have been
 5   out of our bargaining and we'll fight them tooth and nail    5   going on, I have to tell you that I have been very proud
 6   and we'll defend our leaders. Thank you.                     6   and very impressed with UHW, Sal, and all he said, with
 7                     --oOo--                                    7   John, with our Counsels. I think they have made their
 8      MS. RYAN: My name is Emily Ryan and I'm a social          8   case. I think it is clear that in the big picture
 9   worker at Kaiser in Folsom. I'd like to say, first, that     9   nothing -- there has been no indiscretion with any
10   I love UHW. I don't often spend two days in the sun         10   feduciary funds. And I think that this kind of a hearing
11   getting up at 6:00 in the morning for something that's      11   is so detrimental to the whole labor movement as a whole.
12   corrupt and that's what I've been doing for the last two    12       And the story I would like for you to take back to
13   days. I've been here defending this union that I love.      13   Andy Stern is that he's just creating negativity out in
14      So, I'd also like to say that I've been a member of      14   the world there towards unions by doing this kind of a
15   another SEIU Local. As a member of that Local, I didn't     15   process, covering up his own corruption, by going after
16   know who my rep was. I didn't have a steward. I didn't      16   us when, clearly, nothing has really been wrong. So,
17   have access to any information.                             17   please, take that message back for me. Thank you.
18      As a member of UHW, I have my rep's home phone           18                     --oOo--
19   number. We have stewards. I can catch my rep at 9           19      (Unintelligible). Good afternoon. My name is
20   o'clock at night; and I have a copy of the financial        20   (unintelligible). I work at St. Luke's Hospital as a
21   report at my house right now. I have access to              21   stop steward. Our hospital -- we're in a fight to stay
22   information about this organization at every level. I       22   open. We are in the middle of bargaining with our
23   can show up at the office. I can ask for anything that I    23   employer, CPMC, and they are waiting for the outcome of
24   want and it's handed to me.                                 24   this trusteeship.
25     That was not my experience being a member of SEIU         25       Andy Stern, we're not going allow an appointed

                                                                                         71 (Pages 278 to 281)
                                                    Page 282                                                       Page 284
 1   leader to ruin or UHW. It's our union. We make the           1   which Andy Stern claims to have.
 2   decision in a democratic way. We don't deal behind the       2      This is also about Andy Stern's personal vendetta
 3   closed door. Andy Stern, we have news for you. Hands         3   against Sal Rosselli for speaking out. Have you looked
 4   off our union. Our UHW, we're committed to defend our        4   into how Mr. Stern is "elected" president? He's elected
 5   union. We elected Sal Rosselli and we want to keep it        5   president by his Executive Board. And guess how his
 6   that way. Thank you.                                         6   Executive Board is gathered? He appoints his Executive
 7                     --oOo--                                    7   Board; so, therefore, somebody speaks out against him on
 8      MS. ELLIS: Good afternoon. My name is Irma Ellis          8   his Executive Board, that he doesn't like, he let's them
 9   and I am a Unit Clerk at California Pacific Medical          9   go, puts somebody else in there, puts another puppet in
10   Center St. Luke's Campus San Francisco. I've worked         10   there.
11   there for 18 years as a clerk and I've been a part of the   11      You all on this stage are members of a really big
12   union for, probably, 16 to 18 years.                        12   movie and you, Mr. Secretary, you have the leading role.
13      And I find that our union is one that is very            13   You all have supporting roles. This is all directed by
14   respectful, and it's hard for me to believe some of the     14   Andy Stern. He is directing this because no matter what
15   things that I've heard said here tonight because I feel     15   happens here, whether or not you write a report to put us
16   that Sal, as well as John, are very respectful people.      16   into trusteeship or not, Mr. Stern's, personally,
17   And I feel that if anyone should be checked out, it         17   appointed Executive Board has the final say. They vote.
18   should be Andy Stern. Very rarely do we see Andy Stern's    18   It doesn't matter what you write. They will vote how
19   face other than when he's creating problems for our         19   Andy Stern wants them to vote. So, your names will all
20   union.                                                      20   be linked to Andy Stern and his illegal placement of UHW
21      We have been members of this union for a long time       21   in trusteeship.
22   and if we have any problems with this union, we, the        22       But, mark my words. We will fight. For every one
23   members, will stand up and fight. We do not want to be      23   member you saw here over the last two days, there are
24   trusteeshipped. We do not want someone to come in and       24   3,000 and 4,000 more of us to come behind and we are a
25   dictate to us as to what we should do. We pay our union     25   force to be reckoned with.

                                                    Page 283                                                       Page 285
 1   dues, so we should have a voice in what is done with our     1      One of my rank-and-file co-members I understand said
 2   monies and what decisions are made for us this afternoon.    2   and I will hopefully get this quote correctly: "
 3       And I work at a hospital where Sutter Health is the      3       There will be a revolution in California in the
 4   owner and it is very difficult working in that workplace,    4   labor movement. If you put UHW into trusteeship, we will
 5   so, you know what? I do not want to be here today            5   not stand for it, and, we will make sure that everybody
 6   because of your wanting to take over our union. We do        6   knows about it."
 7   not want to be dictated to and we will not lie down and      7      So, remember, there are lots of people falling
 8   let you just do whatever you want to us this afternoon.      8   around Andy Stern right now. Your names will go linked
 9   When you take one of us on, you take all of us on --         9   to him.
10   remember that -- and please take it back to Andy Stern.     10                    --oOo--
11                  --oOo--                                      11      MR. NUNES: Hello. My name is Jesus Nunes. I'm
12      "KATHLEEN": Hi. My name is Kathleen. I work at           12   been working at O'Connor Hospital for 19 years. It's
13   CPMC. I remember in 2005 John Borsos and Sal were           13   very hard to work, so, I do any way because I like
14   together in the strike and I look at you guys, the SEIU,    14   helping people. But, this what I came for to tell you is
15   and you look like a suit to me, especially Andy Stern,      15   because I don't want SEIU to take over and tell me what I
16   like Dr. Batman. So, you guys have offended Sal and John    16   should get and what I'm getting. I want the freedom to
17   Borsos, you offended me, so I'm like Batman. You mess       17   say what I want and my job my workplace because I'm the
18   with me, you're going to Batman.                            18   one that has to get up and go to work. And I don't want
19                    --oOo--                                    19   what happened to Stern, whatever he did, he should be
20      MR. ARROYO: Good evening. My name is Dan Arroyo.         20   done with because taking somebody else's money is to do
21   I work at Methodist Hospital Sacramento. It's a CHW         21   whatever you want with it is wrong and against the law.
22   facility. I'm a co-rep, chair, shop steward, and I'm        22   Go there and rob a bank and see what happens if you want
23   currently on the CHW bargaining team.                       23   money.
24       Mr. Secretary, this is not about PEF. This is about     24                    --oOo--
25   the right to free speech within a so-called democracy,      25      MR. NELSON: Good afternoon. I want to thank you

                                                                                        72 (Pages 282 to 285)
                                                   Page 286                                                          Page 288
 1   for being here and waiting an extra while. My name is       1    John Borsos. Thank you, thank you. And my 900 members I
 2   Michael Nelson. I'm 32 year Kaiser employee. I work at      2    am from Columbia. I think Mafia is just in South
 3   Kaiser's Optical Richmond Lab; started SEIU 535; now        3    America? I was wrong.
 4   we've joined SEIU. And I want to commend John. I've         4       And I'm very, very disappointed with Andy Stern. My
 5   seen him in Puerto Rico and after seeing you in action as   5    900 members told me this is the message. You are not
 6   a witness I commend you. You did very well. The             6    going to get workplace. You are not going to control
 7   lawyers, you guys, were great. And every time you look      7    your workplace. Okay? We are ready to fight. We are
 8   at who's ever in the front row, you have to know someone    8    going to fight and we are going to win.
 9   behind them is doing their job. They're getting passed      9       We have a wonderful contract. The first contract
10   notes from their staff. I know this because my daughter     10 was free health medical; the second contract no
11   is a lawyer. I've been blessed through Kaiser for 32        11 subcontractors.
12   years, and I put her through law school.                    12    And we are very happy with Sal and we believe in him
13       To our chairman, I want to say that, even if you        13 and the way that he used the money. We agree with him.
14   turned out to be our biggest cheerleader and even in all    14 He consult to us. We are part of his decision and nobody
15   of our members show the courage of John and their staff.    15 is going to change that. Thank you.
16      Who are your lawyers? You have to do a job. If you     16                    --oOo--
17   guys suddenly went mute for the last two days and you     17     MS. OMNES: It's almost 6 o'clock. It's hot in
18   recommended that we don't go into trusteeship, Andy Stern 18 here. Everybody is exhausted. I didn't think I'd be
19   still has the power to say no and hell-no. And at any     19 coming up here and saying anything at all.
20   time one person has that much power it corrupts           20     My name is Tere Omnes. I'm the Director of
21   absolutely.                                               21 Membership at United Healthcare Workers-West. I became
22        I was in Puerto Rico. I saw how the other unions     22 involved in the labor movement in 1969 when I was 14
23   viewed us. There are 172 unions within SEIU. We are the   23 years old in high school. I became involved with United
24   second largest. We were the pariah at the convention.       24 Farm Workers. My father was a laborer. My grandfather
25   After trying to have talks with other members from other    25 was a Mariner. He was a member of the Mariner's union.

                                                   Page 287                                                          Page 289
 1   unions, we found out that they were orchestrated when to     1   My grandmother was a registered nurse.
 2   stand, when to get up. They were given speeches on what      2      In 1988, I went to work for SEIU Local 790, the
 3   to say. This is not democracy.                               3   president of which was Paul Veracelli. While I was the
 4       I want to let you know that as a union member for a      4   office manager of the membership department, my
 5   long time in SEIU I started my first contract                5   supervisor, the deputy director, and others on staff,
 6   negotiations in 1989. We always got a small contract,        6   were whistle-blowers. Paul was stealing and embezzling
 7   but we always got what 250 got. We always got the me-too     7   our members' money. Now, unfortunately, the
 8   cause. This is your legacy in the labor movement. In         8   whistle-blowers didn't -- they didn't get exonified(sic)
 9 the labor movement, when I first started, everyone talked      9   in the hearing, but, they came out ahead. Paul was
10 about -- everyone talked about what happened in the 30's      10   ostracized so-to-speak to Switzerland. That was his
11 and the 40's; then, the labor went mute. When the labor       11   punishment.
12 population was 30 and 40 percent of the work force, we're     12       I became a member organizer. I worked with members
13 down to nine, eight percent and why? Because we are           13   out in San Joaquin County, and it was one of the most
14 killing ourselves. We are killing ourselves. This is          14   powerful things that I've ever felt in my life to see
15 not going to do the labor movement any good. This is our      15   these workers who were petrified. They were afraid to be
16 legacy. This is what we are passing on to the next            16   seen with anybody having to do with the union. That fear
17 generation who don't know about unions, because we are        17   developed over time and it took about six months for them
18 eight and nine percent. My daughter will not join a           18   to become strong leaders. And we had a wonderful, very
19 union because, where she lives, the State sees how much       19   successful, campaign. We had 98 percent membership.
20 union lawyers get. They give them a little bit more just      20       What is going on here and what's been going on here
21 to keep them out of the union. This is our legacy.            21   for some time now is so dishonest. These members, I've
22                     --oOo-                                    22   never worked for an organization with the passion of
23     "CARMEN": Good afternoon. My name is Carmen               23   members and staff. They are so smart, they are strong,
24 (Unintelligible). I came from Providence Health System.       24   and they're right.
25 For me, it's an honor to be part of UHW. I love Sal,          25      Andy Stern, Anna Burger, and the current SEIU

                                                                                         73 (Pages 286 to 289)
                                                    Page 290                                                         Page 292
 1   Executive Board, are corrupt; and, for this hearing to       1   recourse is to the courts.
 2   find anything else other than, it just shows there's more    2       Now, the fact that all of that can happen keeps this
 3   corruption going on here. Thank you for your time.           3   from being a sham because it cannot be a kangaroo court,
 4                    --oOo--                                     4   as somebody said, if you have a final appeal to the real
 5      "JENNY": My name is Jenny and I work for Seton            5   courts.
 6   Medical Center almost for 22 years. I'm a single mom and     6      Now, on a personal note, I am not, particularly,
 7   I had kids and I'm proud to have a job. I had the two        7   fond of the way that the SEIU Constitution provides for
 8   jobs one to another because I didn't have benefits. Now      8   this selection of the Hearings Officers. I much prefer
 9   I can have the one.                                          9   the way I was chosen, say, to be an arbitrator; but, I
10       We are the one union. I want to tell you guys,          10   was chosen according to the SEIU Constitution. And the
11   please, leave Sal alone, leave John alone. We have to       11   fact is that I couldn't afford to do it if the SEIU
12   fight for our rights and the rights to have the job and     12   didn't pay my expenses. But, I can assure you that I'm
13   benefits because we have kids to support we have. And I     13   not making money by being here. I'm losing money and
14   see how I have to fight for people to have the job. I       14   losing time that I was devoted to other activities. And
15   have to become involved just to fight the job for them.     15   I did it because I have a strong belief, as I mentioned
16   And who is the one to say the job for them? We are the      16   at the outset, in strong unions and union democracy and
17   union.                                                      17   thought that, in spite of the fact that I was chosen by
18      And another thing it was long ago that the hospital      18   the International union, that I had the understanding to
19   decide to fire her. She no have insurance and she have      19   make an independent judgment and that's the way I intend
20   cancer but another top steward and I we talked to our       20   to do it.
21   vice president that she could have a job that she can       21        I thank you all again. I'm glad that the
22   have a job that she can have the insurance and she get      22   bitter-enders stayed as long as they did in order to hear
23   insurance. Why? Because we are the union. We are the        23   all this. This will end this phase of the hearing. As I
24   union.                                                      24   mentioned, we'll have some additional time later on.
25      That's the reason I want Obama to be the president       25     MR. HARRIS: Secretray Marshall, could I just raise

                                                    Page 291                                                         Page 293
 1   because I know with him we're going to have job for kids     1   two things, very quickly, for the record?
 2   that cannot be in the street, that they can be in the        2      One is a request -- and it really goes to what you
 3   school, because, how are the kids, they do it, you know,     3   said about the Labor Department having observers and
 4   so, that is the reason. Please, please, leave our union      4   watching this proceeding -- we know that they were not
 5   alone because we are the union and we want Sal and John      5   here because you asked for this -- at least this last
 6   to stay with us.                                             6   part --
 7       SECRETARY MARSHALL: All right.                           7       SECRETARY MARSHALL: They did come.
 8       Let me thank all of you who -- particularly, those       8       MR. HARRIS: No, the last part of the proceedings.
 9   of you who are bitter-enders here, to stay in this hall      9     So, my request, first, is that the tape of the
10   and give us your ideas and views.                           10 entire proceeding be made available to the Labor
11       Let me make one final comment. I'll reiterate what      11 Department, and, we would also request, again, as we have
12   I said to start with. And that is that what I intend to     12 before, that we also have a copy of the tape of the
13   do is to be guided, entirely, by the evidence, not by       13 proceedings.
14   the -- any kind of loyalty to anybody else except the       14     SECRETARY MARSHALL: Well, you can arrange that with
15   truth and the evidence, as I see it.                        15 the --
16       But, you don't have to rely entirely on that, as I      16     MR. HARRIS: I didn't understand. If that's true,
17   mentioned at the outset, because there are other people     17 we will certainly do that. Thank you. I understand now
18   watching this exercise who will -- if we can't keep         18 that we're able to do that.
19   ourselves honest, they will keep us honest.                 19     SECRETARY MARSHALL: Yeah, that was part of the rule
20      The Department of Labor is concerned about what we       20 to start with.
21   do. Andy Stern and the SEIU Executive Board are not,        21     Whoever wants -- anybody who wants a copy of the
22   necessarily, the final deciders of this matter because it   22 proceeding can make an arrangement with the court
23   will, ultimately -- probably -- I don't know that -- if     23 reporter.
24   we don't do it right, the Department of Labor will come     24     MR. HARRIS: Okay, and will a tape be made available
25   in and make a determination; and, if they don't, your       25 to the Department of Labor?

                                                                                         74 (Pages 290 to 293)
                                                     Page 294
 1      SECRETARY MARSHALL: That's right. It can be made          1        REPORTER'S CERTIFICATION OF CERTIFIED COPY
 2   available to them.                                           2
 3      MR. HARRIS: Okay.                                         3                I, MARYANN P. COSTA, RPR, RMR, CSR No.
 4       The second thing -- I'm talking about the video of       4   5820, a Certified Shorthand Reporter in the State of
 5   the proceedings --                                           5   California, certify that the foregoing pages 1 through ,
 6       SECRETARY MARSHALL: Yes.                                 6   constitute a true and correct copy of the original
 7      MR. HARRIS: Okay, secondly, we'd like to confirm          7   proceedings taken on Saturday, September 27, 2008.
 8   that the continuation of this hearing will be after the      8                I declare under penalty of perjury under
 9   presidential election, because this union needs to know      9   the laws of the State of California that the foregoing is
10   whether they can be out there working to elect a
                                                                 10   true and correct.
                                                                 11
11   president, whether they can go out there working to elect
                                                                 12              Dated this    day of         , 2008.
12   President Obama, or whether they need to be fighting this
                                                                 13
13   trusteeship.
                                                                 14
14       SECRETARY MARSHALL: It would be very difficult for
                                                                 15
15   me to do it any other way because I don't have any time     16           ________________________________________
16   before --
                                                                              MARYANN P. COSTA RPR, RMR, C.S.R. No. 5820
17      MR. ROTHNER: Just to be clear, we don't have a           17
18   problem with that.                                          18
19       MR. DAYAN: The International president is not going     19
20   to ask that the next phase take place before the            20
21   election, so, the precise date, after the election, we      21
22   can, maybe, work out.                                       22
23       SECRETARY MARSHALL: Okay, thank you all.                23
24           (Hearing adjourned at 6:07 p.m.)                    24
25                                                               25


 1               REPORTER'S CERTIFICATE
 2
 3                I, MARYANN P. COSTA RPR, RMR, C.S.R. NO.
 4   5820, Certified Shorthand Reporter, certify:
 5                That the foregoing proceedings were taken
 6   before me at the time and place therein set forth, at
 7   which time the witnesses were put under oath by me;
 8                That the testimony of the witnesses, the
 9   questions propounded, and all objections and statements
10   made at the time of the examination were recorded
11   stenographically by me and were thereafter transcribed;
12                That the foregoing is a true and correct
13   transcript of my shorthand notes so taken.
14                I further certify that I am not a
15   relative or employee of any attorney of the parties, nor
16   financially interested in the action.
17                I declare under penalty of perjury under
18   the laws of California that the foregoing is true and
19   correct.
20                Dated this day of          , 2008.
21
22
23          ________________________________________
            MARYANN P. COSTA RPR, RMR, C.S.R. NO. 5820
24
25

                                                                                         75 (Pages 294 to 296)
                                                                                           Page 297

         A              122:15 179:24        77:9 126:19          155:12             aggressively
AB 15:8,24 16:12      acceptable 122:20      238:24 292:14      advance 90:21          225:20
  16:17,18,21 19:1    access 82:2          activity 73:3 81:3     150:13 151:5,15    ago 67:10 70:21
  35:14,16 47:12        279:17,21            173:23               152:3,7 153:4        75:4 138:22
abandoned 226:2       accolades 276:16     actual 23:10           196:7,10 199:17      174:23 232:3
abandoning            account 8:2          acute 67:8 73:19     advances 75:10         258:13 266:18,21
  100:10              accountable 68:3       73:24 74:1         advantage 57:1         272:16 273:3
ability 68:10 69:17     234:24 244:10,18   add 38:13 140:2        72:14 221:14         276:22 280:20
  71:1 78:9 119:8     accountant 65:18       270:1                276:18 281:2         290:18
  125:18              accounted 241:8      added 14:13 155:3    advertise 172:25     agree 36:2,5,10,15
ABI-XI 20:18          accurate 9:13        addition 7:5         advice 58:20           39:15 50:25 73:1
able 23:22 32:15        44:23 193:9,13       118:12 160:1         259:23               114:4 149:16
  56:13 69:4,13       accurately 120:23      178:12             advise 169:15          150:6 155:8
  71:11,19 73:4         193:10,13 200:9    additional 17:2      advising 187:7         180:25 181:5
  75:22 76:23         accusations            118:10 292:24      advocacy 12:1          184:19 185:8
  77:13,20 79:3         242:18,22 244:24   Additionally           167:2                186:8 187:3,10
  94:5 97:11 98:14      278:20               225:18             advocate 224:13        187:13 188:11,14
  98:15 112:14,25     accuse 237:22        address 6:20           254:13               193:8,12 201:4
  113:23,24 116:7       268:23,25 269:6      14:11 79:10        advocated 22:5         201:10 288:13
  121:25 122:6          278:15               81:24 82:12,14     advocates 27:23      agreed 52:22
  129:4 135:6         accused 145:20         221:9 241:21         277:9,10             93:20 94:1,3
  157:3 166:19          244:9 270:25         269:11             Affairs 13:8           96:14,19 114:10
  167:21 171:25         271:8,17 276:25    addressed 15:22      affect 70:9 145:2      202:4
  178:10,13,14,15     accuser 268:25         18:1 25:17 213:6     146:6 251:23       agreement 63:12
  178:15 191:2        accusing 213:13        215:11             affiliation 18:21      71:4 89:21 92:4
  192:5 208:1           278:19             addressing           affirmative            92:13 93:5 96:7
  253:1 267:5         achieve 10:12          269:15               112:23 115:5         179:7,20
  280:8 293:18          11:16 44:17,19     adhere 79:24           117:7 118:24       agreements 65:23
absent 79:1,3           51:18 69:4 98:15   adjourned 294:24       119:9 121:11         66:1,9 68:12
ABSMC 89:10,14          98:16              administered           129:5,11 130:15      94:11 96:15
  89:19               acknowledged           84:17                133:23,25 137:24   ahead 7:7 9:20
absolutely 22:22        125:22             administration         139:20 145:18        42:23 43:5 54:17
  64:4 71:1 201:20    acoustics 36:14        11:13 14:8 19:11   afford 221:25          61:22 70:12,13
  203:21 286:21       act 207:23 208:2       126:5 221:13         292:11               104:25 106:1
abstained 24:24         238:5 240:9          274:1,2,3          afield 102:13          109:20 121:19
abstract 104:7        acting 184:5         administrative         104:12               123:2 132:14
abuse 126:21            254:22               54:18 57:13 58:3   afraid 216:11          135:14,16 142:4
abused 260:14         action 17:2 129:22     59:1 60:15,19        289:15               143:23 144:12
abusive 260:14          208:22 255:11        82:11 107:19       AFSCME 57:23           147:11 151:3
ABX 15:11               286:5 295:16         122:24 148:4       afternoon 114:5        154:7,12 165:6,8
ABXI-I 15:4,22,24     actions 219:16         149:20,22 150:10     212:22 213:25        165:8 167:22
  16:13,14,16,22      active 11:6 12:10      150:16               226:20 242:13        190:1 202:1
  16:24 17:4,6,23       32:22 57:21,23     admire 113:8           243:16 248:2         230:5 275:8
  19:1 20:11 21:22      211:10,15 228:1      276:17               264:3,25 281:19      289:9
  23:15 28:6 32:1       228:10 232:2       admission 132:4        282:8 283:2,8      aim 200:4,11
  35:14,17 36:21        233:6 238:22       admit 207:7            285:25 287:23      aimed 33:3
  38:18 39:7,10       actively 19:3,9,20   admittedly 131:15    agencies 77:15       ain't 246:11
  44:12 47:5,12         60:6 206:19,21     admonished           agency 171:7         Akron 56:17
  51:4,7                232:6                118:18               221:24             Alabama 206:11
AB2967 46:13          activist 206:1       admonition           agenda 64:23         Alameda 266:16
academics 20:4        activists 127:16       189:22               82:24 196:11,14      267:8
  128:11,17 129:2       212:5 266:20       Adolph 234:6,8         243:19             Alederos 247:12
accept 116:3          activities 9:14,15   adopted 23:24        agendas 196:17         247:12
                                                                                         Page 298

Aleksander           Amerson 234:19       announced 22:8       appealed 225:14       50:13,25 51:12
  208:12,12          amount 28:22          24:8 53:7 144:19    appear 29:4           51:24 81:20
alert 212:7           168:19 252:20,21     150:21              appeared 24:10        82:25 86:3
Alesander 205:10      263:15              announcement          97:7 125:21          124:17 127:3
alive 27:11          ample 119:9           168:24              appearing 102:23      171:23 172:7,10
allegation 202:14    analysis 20:22,25    announcements        Applause 123:1        178:19 277:7
  204:9,9 274:10     analyze 183:18,22     54:18 112:2         application 171:6   Aramark 94:12
allegations          Anchonto 240:20      annoying 252:18       171:12             arbitrate 71:15
  116:22 123:14,15   Anderson 236:7       annual 65:4,5,14     apply 53:8 102:5    arbitration 68:13
  124:21 126:9       Andrew 1:2 2:2       annually 33:5         140:22 141:6,7     arbitrations 58:19
  130:5 138:5         3:15 234:3          anomaly 280:24        223:10             arbitrator 259:2
  145:9 199:4        Andrews 222:16       anonymity 41:25      appoint 217:5         292:9
  203:17,20 222:13   andy 98:8 99:1,4,6   answer 42:15,17      appointed 59:2      area 24:8 71:25
  258:12              101:19 103:22        49:23 51:10,25       107:18 132:17        88:21 177:14
allege 164:21         106:23 107:18        65:7 116:13,14       134:15 147:25      areas 124:1
alleged 124:1         110:14 115:25        121:18 122:1,3       148:3 213:6        argue 91:3 142:5
  147:23 148:5        123:12 127:11        150:25 155:6         220:8 240:2,3      argued 117:13
  203:23              129:20 142:17        165:6 167:19         245:8 251:20       arguing 117:13
allegiance 225:2      147:25 148:3         173:7 189:3          260:23 281:25      argument 118:25
  262:23              205:17 206:9,11      191:5 195:8,9,25     284:17               121:10 133:5
alleging 271:15       208:2,17 209:4       220:2,3 237:12      appointees 126:8      140:15 145:15,16
alleys 276:24         216:3,6,9,13         241:12 247:18       appointing 144:21     145:23 147:6
Alliance 83:13,14     222:25 223:19       answered 33:25       appoints 284:6        163:20 165:3
  95:23 96:2,8,17     229:9 233:9          168:15 184:8        appreciate 49:1       274:6
  97:2,10             234:9 235:19        answering 191:8       111:24 114:12      argumentative
allies 77:12          241:5 242:17         237:5                121:15 189:2,8       150:24 165:4
allow 22:12 29:9      243:19 244:18,20    answers 34:1          219:4 267:12         190:22
  109:7 110:16        244:21,25 245:1      247:19               280:1              arguments 22:5
  122:17 229:14       245:8,17,18         anticipated 85:16    approach 204:21       53:16 119:2
  281:25              250:11 252:3         166:23               208:5                165:5
allowed 110:7         257:11,19 258:19    anticipation 76:12   appropriate 52:13   Arms 6:6 7:5,8,18
  114:5 132:11        258:23 260:21        175:25               53:3 96:23 121:3     7:20 112:5
  138:21 217:2        268:23 269:2        anybody 32:5          195:3,7 200:20     Army 211:16
  224:15              278:18 279:4         80:11 143:13        appropriately       arrange 293:14
allowing 190:5        281:13,25 282:3      200:15 216:6         196:6              arrangement 97:5
  251:16              282:18,18 283:10     222:11 223:15       approval 28:18        293:22
allows 69:14          283:15 284:1,2       263:21 268:20,21     32:2,6 61:18       Arriala 226:18
  72:16 77:8,9        284:14,19,20         289:16 291:14        64:1               arrival 11:3
Alta 84:5,6 89:14     285:8 286:18         293:21              approve 13:20       Arroyo 283:20,20
Alvarez 251:10        288:4 289:25        anybody's 238:12      17:17 18:16        Arthur 54:23 55:1
Amado 97:18           291:21              anymore 39:18         29:14,16 35:23     article 25:21,23
  104:18 108:19      Angeles 9:25 11:4     86:7 210:22          62:20,21,22          49:8 92:1 101:10
  116:21 135:10,19    12:2,4,8 24:22       221:23               78:16 163:11,15      101:13,14 102:2
amazing 224:13        61:10 277:16        anyone's 31:6         163:23               102:7,17,19
ambiguous 150:2      Anita 231:1 234:22   anyways 272:15       approved 17:5         109:3 146:17
amendment 17:14       251:6               apart 97:11           21:23,25 28:6        147:2,16,19,20
  31:5               Anna 99:1 257:11      117:17               161:17 162:1,6       181:13,20,24
America 235:10        264:13 271:13       apologize 65:20       162:20 264:21        182:1,9 183:4,23
  235:22 288:3        289:25               227:7 250:9         approving 58:19       184:4,7 200:14
American 13:1        Anne 280:15          appalled 280:4       approximately         201:8,19,20
  56:6,8,10 125:16   Annelle 107:9,14     apparent 27:8         65:21 127:15         224:7
Americans 83:13       107:15 122:23       appeal 225:13,14      179:16             articles 13:4,12
  256:13              148:1                292:4               April 29:22 49:16     20:3,5 27:17
                                                                                       Page 299

  60:2,4 102:4,5       261:9 265:1         70:12 113:4        A2081E8 1:25        bag 112:8,8
  102:12,24 200:23   assisted 248:4        252:12                                 Baiah 211:3
  200:25             assisting 153:25    August 135:1                 B            216:17,17
Arts 56:6              233:17              146:16 147:21      baby 249:25         Bailey 243:10
ascribe 201:1        associated 16:7       148:7              Bachelor 56:6       BAIRD 3:20 112:3
ashamed 237:19         237:19 251:25     Austin 3:3,5         Bachelor's 12:21     204:16 207:1
  277:11             association 11:20   Australia 261:14     back 10:24 11:6      208:4 210:24
Asia 260:12            19:2 34:24 35:3   authenticity          11:19 18:6,18       217:20 218:19
aside 79:13 257:15     35:12,15,25         52:24               23:1,4 25:9 27:2    222:16 224:17
asked 22:6 25:10       54:25             author 10:20          29:17,20 31:16      226:12 227:13
  33:23 64:13 80:9   assume 29:25          22:25 25:7,10       39:10 43:23         228:14 229:15
  133:18 143:20        45:3 158:25         139:25 141:13       49:21 50:18 55:6    230:5 234:11
  154:21 155:7         159:2,3 173:3     authored 15:5         55:7 61:6 70:15     236:4 240:12
  167:16 168:14        200:24 265:21       16:3                73:9 77:21 94:5     243:5 247:1
  172:20 175:10        266:1,10          authority 106:10      104:14 105:2        251:1
  184:8 188:22       assumed 23:18       authorization         110:14 111:5,23    balanced 46:5,6,7
  206:10 223:10        40:20               150:14 167:8        112:10 116:8       balancing 45:25
  233:19,22 248:24   assuming 30:19        185:21 186:10       122:10,19 133:24   Baldwin 260:3
  254:21 256:12      assure 292:12       authorize 183:2       135:5 142:14       ballot 17:8,19,21
  262:22 264:9,17    ass-kisser 231:16     186:22 187:2        146:24 162:13       17:22 29:8,10
  273:23 293:5       ATA 248:23 249:13   authorized 157:1      166:3 171:24        31:2,5,14 32:3
asking 41:23 50:3    ATKINSON-BA...        168:11 169:23       174:19 179:16       32:19 47:14,15
  86:25 145:4          1:21                170:1 185:12        180:2 184:12        47:16 48:2,4,8
  149:13 153:16      atmosphere 239:7      191:23 200:17,17    185:23 186:11       48:20 85:17
  154:12 155:5       attached 141:18     authorizing 164:3     195:1 202:4,20     ban 71:16 92:8
  159:16,17 160:10   attack 211:13         186:3               206:4 213:12        93:6 95:2
  160:19 173:3         277:13            authors 127:16        214:19 218:4       bank 285:22
  175:2 176:15,20    attacks 100:3       auto 72:20            220:11 225:7       Bans 68:17
  184:22 185:5       attempt 126:17      availability          232:5 238:23,24    Barbero 254:4,4
  187:23 188:2,15      274:17              232:21              239:1,1,2 240:10   bargain 69:17
  189:3,6,20         attempts 226:6      available 14:22       246:4,8,12,12       72:17 79:23
aspect 206:22        attend 32:20          57:1 125:11         247:25 248:3        87:20 125:13
aspects 13:5 22:4      77:24 79:6          232:12 293:10,24    254:16,17 256:21    166:20 167:1
ass 147:25 208:17      251:17              294:2               257:5 260:21        217:15 258:1
  245:2,18           attended 18:25      avenue 3:13,22        261:8 262:12        278:10
Assembly 10:20       attendees 78:24       76:23               263:24 272:5,12    bargained 219:24
  15:8,9 21:23       attention 25:25     avoid 119:22          278:23,23 281:12    236:19
  26:10 39:4           84:8 85:20 87:4     128:9               281:17 283:10      bargainer 130:24
Assemblyman            91:21 116:25      aware 48:3,6,17      backdoor 279:2,3    bargaining 58:5
  24:7,15              127:4 163:8         49:16 50:12,19     backed 250:5         58:15 64:17,20
assert 120:3,10        173:14 179:3        50:20 51:6,12      background 11:1      65:22 66:1 67:7
  129:10               181:10,13 183:4     79:16 112:8         11:2 12:20 56:4     67:13 70:2 72:11
asserted 126:21        197:12 198:17       152:6,10,15         233:18              72:16,19 73:8,11
assertion 126:10     attitude 206:3        153:8 160:16       backroom 240:7       73:22 74:18,25
asserts 123:13       attorney 30:15,23     161:11 164:1,11    backwards 29:3,8     75:10 80:25
assets 125:7           48:15,19 118:17     164:14,15 169:12   back-and-forth       82:12 84:16,19
  129:24 150:7         118:18 212:25       170:25 173:8,9      74:17 117:24        84:20 86:9,14,17
  182:18               295:15              173:10 174:9        129:1               86:19,23,24 87:1
assigned 261:23      attorneys 7:1         176:20 178:24      bad 145:17 205:21    87:2,3,9,21 89:6
assigning 126:12       237:1 244:22        194:21 264:11       230:21              90:1,4,5,7,11,12
assist 176:10          256:18 264:9      awful 42:20          badgering 167:17     91:1,2 92:16
assistance 251:21      268:24            awfully 181:11        189:22              93:4,23 96:11,17
assistant 142:17     audience 60:24      a.m 2:21 6:1 264:4   badly 248:8          96:22,25 119:23
                                                                                          Page 300

 124:4 125:13,16      175:25              benefits 67:16          76:20 128:13        162:10,12 163:11
 126:3 166:17        begins 26:1 68:4       90:22 95:13           137:21 142:8,9      163:22 169:13,23
 167:3 170:6         begun 86:25            215:1 221:15          142:18 211:12       173:5,6,13,25
 192:9 219:24        behalf 8:12 55:16      226:5 236:19        billing 46:5,6,8      174:5 177:20
 224:10,14 238:19     91:17 203:2           254:12 290:8,13     billion 96:21         182:20 183:12
 238:20 239:21       behavior 274:23      Beneo(sic) 225:11       101:16              184:2 185:22
 245:3 250:22        Behavioral 273:20      225:14,15           bills 16:8 45:8,15    186:3,11,17,19
 255:11,12 262:14    belief 292:15        Benson 196:20           45:17,19,21         186:21 191:2,12
 276:15 278:5,7      believe 20:2 31:6      197:25 199:6          46:18,21 47:1       191:17,20,24,25
 278:11,13,25         32:14 35:25           200:8,14            binder 9:2,5,6        192:2,5,7,10,13
 279:5 281:22         37:13 44:16         Benson's 197:18         20:15,16 48:23      192:19,19,21
 283:23               46:17,25 66:3         198:3,7               63:8,9 64:10        193:1,10,12,18
Baron 249:20          67:11 79:25         Bernadette 236:8        162:25              194:9,12,17
bars 146:23 240:7     90:23 98:18         Bertha 253:12         binders 53:11,12      196:11,12 200:2
Barsos 237:22         105:19,22 120:12    best 32:16 41:11      biography 213:20      200:9 201:13
based 41:17 97:6      123:22 127:24         67:11 72:22 91:3    Birmingham            213:1 214:11
 110:18 144:2         133:1 135:9           94:13 114:13          206:11              216:19 220:14
 263:25               149:12,17 150:9       125:13 137:24       bit 11:1 13:18        232:10,13,25
baseless 130:6        155:22 160:5,12       182:15 206:18         14:24 70:1 216:3    233:2 252:15,16
 138:6 145:10         165:22,23 170:17      212:19 214:5,19       287:20              252:18,24 253:6
 146:2                170:21 173:18         214:20 215:12       bitter-enders         256:25 263:3,5
bases 211:24          179:13,14 180:6       219:12 258:8          291:9 292:22        263:11 264:17
basic 139:21          182:22 194:15         265:19              bi-monthly 125:9      265:5 269:13,22
basically 39:1        205:18,19 212:16    Beth 42:14,15 43:7    blanket 168:24        272:4 284:5,6,7
 41:2                 214:11,21 219:14    better 10:15 90:15    blatantly 229:12      284:8,17 290:1
basis 53:8 96:14      220:13,14 224:22      90:24 143:9,25      bless 236:3           291:21
 130:19 141:22        242:20 253:21         207:21 210:13       blessed 231:22       boards 62:6,17,18
 221:15 265:23        255:3 260:25          214:25,25 215:1       286:11              232:6
Bates 84:5,6 89:14    261:1 263:24          217:16,17 236:17    blessing 252:4       BOB 3:21
Batman 283:16,17      273:9 282:14          259:10 267:3        blind 225:2          Bodner 247:3
 283:18               288:12                268:2 269:18,24     blinded 225:2        body 60:9 101:2
battle 259:13        believed 103:12        272:20              blindly 241:13        215:19 220:8
 276:23               103:13 184:5        Beverly 243:7         blog 197:21,25        262:3
battles 272:2,3,5     238:10                244:5                 198:4,7,21         bogused 238:25
Bay 71:5,5,7,25,25   believes 148:24      Beyer 236:6           Blogsters 197:19     boiled 274:5
 83:14 88:21          219:14              beyond 30:13 69:7     blood 221:1          boils 274:8
 177:13 267:23       belittling 208:16      84:11 108:5         Bloomington          bond 194:24
Beach 253:15         Bell 243:8             139:19 141:22,23      56:11              bonded 194:23
beating 249:23       Bellflower 227:19    big 61:13 165:12      blue 35:20,23         195:13,16 196:5
Beckham 262:7,7       232:1                 215:19 262:22         112:7,8            bonding 201:5
becoming 42:21       Bell-Tull 218:22       281:8 284:11        board 11:24 12:2     bonds 195:19
 262:11               222:22,24           biggest 52:2            55:1,2 59:6,9      book 60:4 241:6
bed 214:23           belonged 280:19        121:21 134:17         60:8,9,11,12       booklet 81:10
Bee 101:12           belonging 281:2        266:16 286:14         61:1 63:18,24       179:24
beer 254:7           belongs 112:9        bill 15:5,8,9,13,25     76:11 77:24 78:2   books 11:17
began 10:8 15:7       240:11                16:3,5,5,10,11,19     78:22 79:5 80:3    book-signing
 57:1 69:16 99:8     beneficial 99:18       21:1,6,22,25          80:6,9,10,11,13     241:6
 280:20,21           benefit 20:20 68:7     22:4,16,22,24         80:13,15,16,18     born 209:16 227:1
Beghead 277:1         69:9 70:24 71:14      23:6,23 24:1,12       80:20,21 85:1,5     233:15 276:20
beginning 14:3        93:12 94:24           24:22,25 25:5,7       107:2 125:10,21    Borsos 4:11 54:10
 53:7 81:6 86:14      210:10,10 221:3       25:9,10 33:9          142:17 149:4        55:8,10,11,15,25
 104:5 123:25         262:17 275:17         39:18 45:25           151:6 157:21        56:3 65:13 70:17
 125:15 166:1         276:4                 46:14,16 47:24        161:16,22,23        83:19 102:9,12
                                                                                           Page 301

  110:2 115:16         232:5 236:15       business 19:14,18      282:9 285:3         capita's 110:17
  116:2,12 121:18      239:20               51:16 152:7          295:18 296:5,9      capture 197:17
  121:20 122:12      bringing 130:19        183:11 219:6       Californians 26:7     card 6:13 256:3
  123:3 127:1          149:3 218:7          232:11,18 233:25     78:19               cards 113:11
  129:17 132:15      Bristo 224:23          243:20 256:8,19    Californian's         care 12:3 67:8,18
  134:13 135:17      British 233:23,24      263:2                258:2                 73:19,24,25 74:1
  137:18,21 139:10   Britton 226:16       busting 209:12       California's 81:19      75:8,16,23 76:1
  139:13,15,16,22      227:21,21            271:16               82:8                  82:3 91:15
  142:7 144:2,7      broad 274:8          busy 114:14          call 20:3 25:8 54:1     135:22 136:11,21
  146:4,19 148:19    broadcast 165:12     Butch 252:7            54:9 69:13 84:7       136:25 137:2
  151:1,4 157:10     broaden 77:18        butt 250:4,4           104:9 107:8           144:7 219:3,19
  160:19 165:9       broader 20:7         butts 223:17           167:2 204:20          235:15,24,24
  167:19,24 168:16     74:20 77:2 81:24   bylaws 62:10           225:3 231:9           245:11 248:17
  169:18 173:6       broadly 84:22          63:11 64:9           232:22 247:18         249:14,15,18
  184:9,14 188:22    Brock 231:25           106:11 179:6         255:7 256:21          260:19,23 261:9
  189:2 190:21       broke 115:22           181:7,11 182:8       259:24 267:9          262:19 273:7,8,8
  191:1,9 195:5,6    brother 259:14         183:4,7,9 232:5      277:22                275:12,12 276:2
  195:10 202:21      brothers 210:11      bypass 30:10         called 8:12 11:24       276:3
  232:8 242:23         220:23 237:4       B.S 233:8              15:7,20 30:16       cared 131:6
  283:13,17 288:1      249:8 256:6                               55:16 81:18         career 12:10
boss 242:7             259:1,4 260:7,10            C             87:25 88:1 95:7     carefully-plann...
bottom 185:2           268:9 271:20       c 3:1,21 77:7          95:9 96:1,8,15        155:13
  266:7                277:21 278:24      Caifornia 207:6        153:2 156:10,13     caregivers 82:5
bottom-up 148:21     brought 93:18        Cal 11:3               160:6 163:4         cares 235:15,18
  184:15               116:25 130:20      California 1:8         203:2 230:10        Carla 231:25
bought 248:23          206:19 256:21        2:21 3:9,13 9:24     233:1 236:15        Carlson 92:7
bounds 214:16        Brown 222:20           10:8,11,19 11:10     249:12,15 258:14    Carmen 287:23,23
box 3:4 239:12         230:4 247:7          11:11,14,19 12:1     277:19              Carol 256:2 276:13
Boxer 277:23         Bruin 137:22           12:7,14,16 13:18   calling 248:24        Carolina 56:9
boy 218:12 227:1     Buckles 218:25         13:23 14:1,14,17     278:19              carried 183:10
  230:2 258:20         221:6,6              14:21 17:9 18:4    calls 126:16 195:4    Carroll 240:22
branch 21:14         budget 65:4,14,15      18:4,12 19:23        229:3 231:2         carry 164:25 263:8
Brasil 222:18          65:16 151:24         26:22 29:13 31:8   Camino 219:10         cars 274:13
  224:25,25 254:19     152:1,4,5            31:13,16,20          220:17 221:7        Carter 274:1,2
brat 234:4           build 81:6 100:6       32:23 34:24 35:3     222:11 230:8        case 14:23 17:20
breach 126:21          207:10               35:12,15 41:3      Camino's 221:8          23:2 25:3,6
Breaches 124:3       building 265:10        45:19 52:3 57:9    campaign 12:17          29:18 41:21 42:5
break 53:25 54:5     bulb 6:5               59:24 61:15          31:19,23 71:22        70:3,6,7,13
  111:20 138:12      bullshit 238:25        81:25 82:19          75:20,25 76:22        79:14 104:15,25
  139:1 185:16         273:9                83:13,18 94:14       80:24 81:24           105:5,22 106:1
BREDHOFF 3:16        bumming 234:4          96:1,4 97:4          82:13 84:4            112:25 114:16
brevity 113:7        bump 39:1              100:15,20,21,22      119:23 125:16         117:17 118:9,22
brevity-challen...   bunch 238:2,25         100:23 103:23,24     126:13 154:1          120:11 130:23
  113:7              burger 99:1 208:3      149:10,11 176:4      155:13,18,20,25       131:1,3 139:5
Brian 238:6            257:11 261:20        177:5 212:9          156:1 176:1,5,11      180:6 214:15
brief 28:24 29:2       264:13 271:13        227:3 229:13         187:20 289:19         227:11 269:14
  142:6                289:25               243:17 248:5       campaigns 64:22         281:8
briefly 12:19 56:3   Burgers 207:22,24      250:21 257:16        74:16,19 256:14     cases 45:23,24
  141:3              Burgon 208:7           261:10 262:1,8     Campus 282:10           58:16,17 87:1
bring 23:1 25:9      burned 230:20          263:13 264:5       cancer 290:20           89:1 96:25
  39:3,10 77:20      bus 261:8,12           265:2 267:10       Canton 56:7             113:24 161:18
  146:1 149:9        buses 257:2,6,10       269:16,18,24       capacity 44:7         Castro 240:23
  204:8 222:7          257:11               276:21 280:16      capita 110:6,13,18    catch 261:8
                                                                                           Page 302

  279:19               276:14 283:22        4:13 34:19,22      childcare 101:17        284:1
Catch-22 199:8       chairman 227:6         43:6 45:13 49:2      101:22 102:22       Clara 256:17
Catherine 234:13       256:10 286:13        49:5,7,9,11,15     children 27:24        clarify 188:16
Catholic 3:6 64:16   chairperson 24:4       50:3,7,10 52:5       32:13               classes 59:20
  67:8 71:10 94:16   challenge 53:10        52:17 54:10 55:8   children's 27:24        171:19 238:15
  278:5                142:6                55:22 56:14          28:1 228:25         classic 102:5
caucus 90:13         challenged 277:4       61:23 65:12 70:4   choose 190:18         clause 95:15
caught 11:12         Challenges 81:19       70:14 71:18        chose 248:5,6         clauses 176:15
cause 12:14 31:13      82:20                100:19 102:14      chosen 193:16           188:17
  31:18,22 94:8      challenging 72:15      104:16 105:6,8       292:9,10,17         CLC 3:19
  144:4 280:13       chance 6:17 26:5       106:3 108:7,14     Christ 276:13,13      clean 48:17
  287:8                27:12 118:9          109:11,24 111:10     276:22                248:18
caused 205:22          120:1 131:22         111:16,18,21,24    Christina 243:14      clear 21:23 22:11
  277:13               158:14 180:8         115:16 116:10,17   Christmastime           27:23 35:24 42:9
causing 205:23         204:10 216:25        117:5 118:1,4,16     16:15                 43:20 51:5 64:4
celebrated 258:15      240:1                121:17 123:3       Chronicle 25:21         65:12 86:5 91:5
center 2:20 84:6     Chandler 247:6         128:24 129:7,12      102:17                99:8 112:14
  87:12 89:14          248:20,20            129:17 130:18      chronological           134:14 180:24
  94:16,19 95:8      change 141:1           131:24 132:15        105:23                214:3 244:2
  166:22 167:25        221:21 239:6         133:1,4 134:4,12   CHW 70:20,22            274:4 281:8
  168:2,25 169:21      258:4 288:15         135:8,15,18          71:9,9 86:23          294:17
  207:6 243:18       changed 16:14          137:17,19 138:2      108:15 242:14       clearly 24:5
  248:21 266:17        31:15 56:1 85:15     138:8,18,20          251:14 278:9          271:10 281:16
  282:10 290:6         249:1 257:12         139:7,10,15          279:2 280:17        clerical 57:21
Center-Seton         changes 253:24         140:6,12,16,20       283:21,23           clerk 258:7 282:9
  87:12              Chansky 128:12         141:24 142:7       cigar 146:23 240:6      282:11
Central 59:13        chapter 223:11         143:3,6,16,18,24     252:1               Cleveland 56:17
  227:22               273:20               144:13,25 145:4    cigarette 28:2        clinical 273:14,17
centralized 98:9     character 222:13       145:8,13,24        cigars 274:16         Clinton 11:13,15
CEO 34:24 243:20       259:15               147:2,9,13         Cindy 251:4             13:6
CEO's 272:21         charge 104:10          148:13 150:2,24    circulate 31:1        clock 28:20,25
certain 17:15 24:2     131:4,14 201:17      157:3,7 158:10     circulated 17:5         29:3 30:14
  28:21 29:15,16     charged 207:11         159:11 160:18      circulation 17:6      close 8:21 9:20
  89:1 90:8 103:13   charges 105:1,2        165:3 167:17,20    circumstance            59:8 72:12 96:20
  199:16               105:18 109:21        167:23 168:14        22:19 25:3            121:14 163:25
certainly 12:14        112:23 114:18,22     169:6,8,17 173:3   circumstances         closed 92:9 282:3
  16:12 64:18          116:16 118:24        174:7 179:9          105:24              closing 140:14
  97:13 102:16         119:5,7 130:20       184:8 187:17       circumvent              266:19,22 267:15
  114:3 117:1          145:9,12,17,21       188:21,24 189:21     131:18              clue 228:8
  173:23 186:16        146:2,20 198:25      190:20 191:7       circumvention         CNA 227:22 230:8
  275:2 293:17         199:2,7 230:17       195:2,6              124:7                 275:11
CERTIFICATE            230:18 231:18      check 125:10         cite 121:13           coalition 38:14
  295:1                238:25 261:18      checked 282:17       citizen 233:24          39:4 77:20 81:7
CERTIFICATION        charging 132:5       cheerleader            275:18                83:15
  296:1              charity 64:15          286:14             city 56:16 59:20      Coast 197:19
certified 215:17       75:16 87:3,16,22   Cheryl 267:22          95:17                 198:8
  215:21 259:22        88:9 90:10         chief 147:22         civilization 233:19   Coastside 87:12
  295:4 296:1,4        147:17 237:9         208:21 214:2       civilized 234:7       code 182:23
certify 295:4,14     charter 103:24         221:7 238:6,21     claim 120:18            218:13,17
  296:5                104:3 106:8,12       246:15 247:13        132:13              codes 218:14
chain 254:14           107:5                253:13 261:10      claimed 121:4         coincide 74:7
chair 9:23 253:2     chased 276:24        child 249:24 250:6   claims 120:5          coincides 75:20
  265:3 273:23       Chatterjee 3:8 4:9     277:1                132:9 212:1         Cole 252:7,8
                                                                                          Page 303

Collado 211:2          272:25 273:2         164:23             compliment 84:17     conferences
  212:23               282:24 284:24      common 12:14           166:21               172:6,12
collapsed 109:15       291:24 293:7         31:13,17,22        comply 217:18        conferring 269:21
colleagues 134:18    comes 216:13           64:15 259:18,20    components 20:6      confidence 42:4
  223:10 248:11        229:6 239:13         259:20             comprehensive          42:18 43:22
collect 30:2 31:4      268:4 272:23       communicate            20:9 32:19 44:17   confident 49:22
collected 17:16      comfortable            161:7 219:21         44:19                50:18
  113:11               53:18                274:22             compromise           confidentiality
collective 58:5,15   coming 17:23 29:5    communicated           32:22 103:15,17      126:22
  65:22 66:1 74:18     43:14 134:19         168:18 171:15      compromises          confirm 294:7
  82:12 84:18          188:9 233:9          172:21               101:21 102:21      conflict 85:19
  96:11 124:4          242:18 257:4       communicates           103:9                119:22
  125:12               261:3 267:17         161:6              con 22:5             confluence 75:24
collectively 79:23     275:15 288:19      communicating        concede 130:5        confused 15:10
  166:20,25          commencing 2:21        160:2              conceivable 27:2       269:13,17,19
collectors 207:18    commend 286:4,6      communication          48:10 109:5        Congress 232:16
College 56:7 59:21   comment 133:16         161:11 162:14      conceivably 27:1     Congressional
color 256:22           291:11               164:1,16,18,20     concern 47:1,2         277:24
Columbia 233:20      commented 22:17        164:21 166:5         78:20 91:6 94:8    Congressman
  288:2              comments 40:6          172:22 176:21        127:11,22            260:20 277:22
columnist 101:11       44:2 50:22,23      communications       concerned 269:13     connect 155:24
columns 181:19         113:18               164:12               269:23 270:19,20   connected 90:2
combination          commercials          community 19:15        271:9 291:20       connection 27:14
  175:22               268:14               58:24 74:20 77:2   concerning             34:3 50:10
come 23:4 26:8,17    commissioned           81:7 83:1,9,10       154:15             consecutive 158:2
  27:2 47:7 59:23      20:22                212:5 252:9        concerns 95:20       consensus 27:17
  61:22 62:10 65:1   Commissioner         companies 254:7        127:18 218:7       consequences
  73:6 78:8 86:18      11:9                 255:14               230:13 273:22        128:6 218:15
  86:21 87:3 90:7    commit 276:25        company 255:13       concession 145:9     consider 115:10
  104:14 105:1       commitment           comparable             145:12               220:12 267:14
  111:23 122:9         138:23 218:10        177:15             conclude 100:1       considered 28:2
  133:24 134:20        223:4,6            compared 61:24       concludes 52:11        52:15 99:22
  144:21 147:2       committed 100:6      compares 208:25      conclusion 43:15     considering 81:22
  162:13 164:10        127:17 165:13      comparison             183:14 195:4       consistent 51:22
  174:19 185:23        166:10 216:11        167:12,14          conclusions 40:24      84:8 106:25
  196:12 202:4,14      218:16 251:19      compete 67:17          41:17                110:7 190:14
  205:4 206:4          282:4                180:8              concurrently         consists 20:21
  207:9 208:14,15    committee 20:12      competent 125:1        15:19                54:23
  209:16 210:24        21:11,12,16,18     competing 98:1       conditions 90:22     constantly 108:21
  212:7 213:4,14       21:20,24 22:2,6    competition 67:17      98:6 144:21        constituency
  217:15,20 218:20     22:8,13,20,23      complain 275:13      conduct 74:16          18:22 32:10
  224:18 226:5,13      23:2,7,8,12,23     complained 111:3       115:22 124:6       constituents
  227:2,13 228:6       24:4,21 25:2,5       111:4              conducted 14:1         164:9
  228:14 229:11,15     26:11 27:15        complete 17:1          18:19 147:23       constitute 296:6
  231:14,14,17,21      193:24 194:1,2,3     21:1 49:12 93:6      172:2              constitutes 274:6
  233:20,21 234:11     194:4 223:23       completed 13:11      conducting 154:1     Constitution
  235:23 236:4         238:18,20 255:11     13:14              conference 32:20       62:10 63:11
  237:21,24 240:12     276:15             completely 30:10       32:25 33:1,4,8       106:11 126:20
  243:5 246:1,18     committees 91:1        70:22 116:23         33:10,16 34:11       179:6 180:17
  247:1 251:1          193:25 238:20        167:23 204:7         36:25 37:7,22        183:7,9 186:9,12
  260:17 262:1         241:14 264:14      completing 10:4        38:3 39:24 85:24     186:13 232:5
  263:22 265:22,24   Committee's 26:3     complicated            257:3 277:11,11      292:7,10
  268:7,11 270:9     committing             197:8                277:12             constitutional
                                                                                         Page 304

  17:14 31:5        continuously         contribution         correct 21:8 34:25     100:21,22 101:2
construction          278:10               168:12 170:5,16      35:1,11 36:3,11      101:3,6 103:18
  212:10            contract 66:3,4,7      170:20 171:1,17      36:22 37:1 38:19     103:23,24 104:3
constructive          67:2,4,6,7,8,14    contributor 211:9      39:7,21 40:11,25     105:3 106:12,18
  99:23               67:24 68:16,20     contributors           41:3,4,6 45:2        106:25 107:1,5
constructively        68:20,21,22 69:6     170:4,15,20          48:16 80:22          107:10,11,13
  99:15 100:8         71:5,11,21 72:4      171:1 207:19         82:22 83:8 85:25     109:13 110:4,5,8
consult 288:14        72:22,23 74:3,14   control 93:3           86:1 97:19 103:1     110:9,15,18,20
consultants           74:16,19 75:20       131:16 274:19        117:5 124:12         114:15 115:21,22
  126:12              75:25 76:21          288:6                127:13 137:13,14     116:4 122:13,15
consultation          80:24 81:4,23      controlled 98:4        145:13 148:22        122:25 161:20
  115:13 273:23       84:3,4,8 86:12       129:24 206:6         149:1,5,11           162:9,11 164:8
consulted 273:24      87:19,20 88:4,14   controversial          153:12,22 154:23     177:14 214:1
consumer 19:19        89:4,24 91:7,11      99:23                155:2,14,18          215:7,10 225:11
  19:20               91:18,20 92:9      controversy 109:9      156:1,4,11,22        254:22 265:4
contact 203:22        93:5,6 94:6 95:2     172:8                160:4,7 161:9      counsel 8:5
  204:5               95:4,10,19 96:16   convalescent           164:13 165:2         116:10 118:6
contained 106:11      154:1 155:13,18      73:24 231:11         171:13 173:6,20      119:5 138:13
  201:16              155:19,25 176:1      263:6                173:21 174:1,11      139:14 141:14,25
contains 201:8        176:5,11 221:12    convening 172:6        174:24 176:7         154:21 157:25
contemplated          221:16 222:3       convention 136:9       177:2,6 179:16       196:5 277:19
  27:25               225:20 239:17,22     136:9,19 137:9       181:4,8 182:10     counseled 90:13
contemplates          245:4 247:16         216:24 249:6         184:5,16 185:3,4     90:13
  32:5                254:10,11,15         286:24               185:20 186:7,20    counselor 218:4
contemplating         255:2 265:17       conversation           191:13,16,17       Counsels 281:7
  32:18               272:19 287:5,6       205:17               193:1 200:22       counter 92:1
content 20:23         288:9,9,10         convicted 257:19       201:24 295:12,19     121:3
  196:24            contractors 93:18      277:2                296:6,10           Counterproposal
contentious         contracts 58:12      Cook 231:1,1         corrected 163:12       87:13
  136:20              65:21 66:2,5,8     Cookie 231:2         correctly 175:11     counting 170:23
contest 274:18        66:11 67:5,11      cooperated             285:2              country 61:7 62:1
context 109:9         69:17 70:2 71:19     133:19             correspondence         66:4 67:5,12
  120:22 127:1        71:24 72:2,3,6,7   cooperative            171:24               69:8,10,13 75:23
  140:13,17           72:13 73:12,21       209:13             corrupt 217:7          125:14 128:14
contiguously          74:4,7 76:1,16     coordinated 71:21      235:7 279:12         218:12 227:1,9
  115:12              81:2 87:17 88:21     101:2 125:15         290:1                232:15 233:8
continuation          88:22 95:11        coordinating         corrupted 237:3        237:24,25 254:11
  294:8               125:14 126:4         100:24               237:18 245:15        254:12 260:6
continue 8:4 12:5     205:23 212:19      cope 125:8 207:18    corruption 216:20      267:3 270:18
  38:5,12 39:19       214:25 217:14        211:9 237:8,9,17     225:9 240:6          271:18 272:3
  49:19 50:15         219:24 224:11,12     239:17 263:20        243:24 244:23      Counts 114:7
  59:17 60:6          224:14 229:7       copy 37:9 49:1,2       260:18 271:15      county 219:3
  119:19 132:15       239:3 255:18         49:24 50:1,5         281:15 290:3         256:4 263:6
  184:13 202:5        258:1 272:18         279:20 293:12,21   corrupts 286:20        266:16 267:8
  212:18 234:25     contractual 226:3      296:1,6            cost 46:14 67:19       289:13
  243:23 244:2      contrary 90:18       cordial 7:24           82:2               couple 52:25
  255:20 266:4      contrast 98:7        core 88:20 226:2     Costa 1:24 2:21        54:12,15,18
continued 5:1       contribute 77:16     corner 198:19          295:3,23 296:3       112:2 155:3
  118:13              140:1 141:13       corporate 272:20       296:16               249:5 250:10
continues 26:2        143:2,15 167:9     corporation          costs 67:21,22,22      280:9
continuing 51:16      189:12               182:22 249:14        67:25 98:18        courage 286:15
  53:12 84:10       contributed          corporations         council 40:10        course 115:4
  131:17              168:19 187:19        75:14                59:14 100:16,20      134:9 222:7
                                                                                         Page 305

  251:17 261:15        281:13 282:19      Dacina 247:9          117:9 118:15        241:20,20
  264:5 269:17,18    creation 168:23      daggers 257:10        128:22,25 129:10   death 32:1 51:4
  269:24 276:16      credentials          daily 221:15          130:12,21 137:20    277:13
  292:3 293:22         233:17              265:23               137:23 138:7,9     debate 13:25
courts 292:1,5       credibility 270:21   damn 206:7            138:23 139:12,19    99:14,16 100:3
cover 9:18           cries 235:17         Dan 7:8 202:13,19     140:14 141:3,5      102:25 104:19,22
coverage 10:8,13     crimes 276:25         239:2,21 283:20      143:17,19 144:6    debated 13:17
  10:13,21 11:11     crisis 74:13 75:8    Danger 197:20         144:9 145:3         47:8
  11:16 13:20,23       75:12,19 81:19     Daniel 4:17           146:18 148:18      Debbie 247:12
  14:18 15:3 27:7      82:20 154:16,20     101:11 203:1,12      150:3,25 151:5     Debra 247:4 248:2
  28:1,8 32:13,19      177:5 212:16       dare 212:25           157:6,13 158:2     DeBruen 144:13
  33:4,6,14 47:4,4     235:22 263:18       237:21 258:3         158:11 159:16       144:23
  47:11              critical 42:7 74:5    278:15               160:19 165:7,15    DeBruen(sic)
covered 92:13          94:10,11           Darlene 208:9         168:9,17 169:7      142:10,11
  95:19 186:13       criticism 100:5       211:7                169:11,24 173:7    December 115:25
  205:3 222:1        criticisms 99:24     date 25:6 29:4,15     174:9 179:13        122:13 226:8
covering 6:23          100:3 199:16        29:17,21 50:21       182:1,4 184:10     decent 207:12
  72:13 281:15       criticize 126:5       51:20 86:4           184:14 187:19      decide 174:5
covers 17:12 66:9    criticized 125:18     110:17 147:20        189:1,23 190:2      245:23 246:23
  158:17               189:8 190:12        160:21 176:17        191:5,11 195:12     290:19
covert 209:3         cronies 208:17        264:16 294:21        196:7 202:3        decided 30:9
cover-to-cover         269:5              dated 104:1 107:2     294:19              169:2,13 199:17
  159:7              cronysm 277:20        115:25 123:8        days 6:19 18:6       201:15 255:9
cover-up 216:19      crook 259:22          132:18 137:22        22:10 23:4 30:3    deciders 291:22
coward 237:11        crooks 238:2          295:20 296:12        30:18,24 75:4      deciding 141:11
Cox 234:13           cross 4:14 35:23     daughter 286:10       115:11 137:9        149:18 198:14
co-chair 208:21        202:5 204:2         287:18               147:21 148:9,12     200:19
co-members           cross-examinat...    Daughters 64:15       248:16 249:5,7     decimate 135:21
  285:1                4:8 34:18 148:17    87:2,15,22 88:8      250:10 251:17      decision 23:2 26:3
co-rep 283:22          165:7 204:3         90:10 237:9          270:18 279:10,13    79:4 85:4 108:11
co-workers 192:5     Crown 233:23          239:4,7              280:9 281:3         149:23,25 152:23
  192:6,20 212:2     Cruz 66:6 278:4      Dave 264:12 277:1     284:23 286:17       153:1 169:4,16
  236:22 255:9       CSR 1:24 2:22        David 97:18          day-in-and-day...    176:10 183:2
CPMC 240:21            296:3               104:18 108:19        265:20              186:4,5,14
  281:23 283:13      CTW 3:19              116:19,21 135:10    day-to-day 58:20     201:22 210:8,9
crap 239:10          curious 209:9         135:19 236:6         58:22 74:17         228:13 232:18
create 10:7 62:10    current 9:22 86:9    day 1:10 22:3,9,12   dead 16:18 25:12     241:10,16 244:22
  73:10 80:8 100:7     203:13 289:25       23:4,20 24:2,7       26:15,15 27:14      282:2 288:14
  167:25 168:1       currently 10:3        34:3 36:21 44:4      28:13              decisions 98:5,9
  183:23 193:24        91:1 94:18          44:12 58:23         deadline 25:4        148:25 149:5,9
created 76:11,12       211:15 283:23       113:21 117:14       deal 70:11 90:15     149:17 175:7
  77:5 78:17 80:3    cursory 14:14         165:18 202:4,6       90:24 101:20        179:1 192:1,8,18
  80:6,23 154:14     cut 90:24 102:20      219:15 220:25        102:20 208:15       206:21 230:12,21
  160:12 161:3         118:13 121:24       223:1,2,4 225:15     222:5 231:19,20     232:11 241:9,12
  165:10,20,23,24      223:12 275:6,9      242:6,17 246:6       231:20 263:22       244:16 251:23
  167:15,24 168:25   cutting 61:16,17      254:24 257:5         279:2,3 282:2       254:2 283:2
  170:3,9,14         Cynthia 226:18        261:22 265:23       dealing 58:23       decision-maker
  172:16 174:11,15   C.S.R 295:3,23        295:20 296:12        75:13 259:4,9       269:12
  182:22 192:14        296:16             DAYAN 3:16 4:15       280:4,5,7          decision-making
  193:24 194:2       C.V 9:11 34:23        49:4,6,8,10,12      deals 240:7          184:15 185:2
  195:20                                   54:2 104:4          dealt 28:9           234:25
creating 153:19               D            107:20 108:23       Dean 40:7,8,14,18   declaration 20:23
  211:23 272:2       D 4:1 5:1             110:21 116:1,9       44:1,5,6 240:15    declare 295:17
                                                                                        Page 306

 296:8              demanding            dependents 68:6     Detroit 250:20         233:13
declared 110:3       276:19               88:13,15,19          276:20 277:7       dig 14:24
declined 269:22     demerits 151:17       94:21              develop 68:2 73:5    dilemma 199:8
decreasing 82:2     democracy 55:1       depending 77:19       73:9 96:5          dinner 259:5,5
dedicated 12:16      77:4 122:21         depends 53:14       developed 11:11      dire 218:14
defame 222:13        126:1,18 128:4       149:21 150:1         71:21 289:17       direct 4:6,12 8:16
defeat 26:11         155:25 172:6        depth 14:16 19:25   developments           55:21 57:14
 27:15 40:3          185:2 197:19,20     deputy 289:5          156:21               153:18 160:22
defeated 20:12       198:4 205:18,25     deregulation        devoted 292:14         163:8 173:14
defend 199:10        206:17 215:8         47:21,23 48:1      de-COPE 212:14         177:2 179:3
 212:18 271:22,23    218:16 225:5,7      Derloute 222:17     de-industrializ...     181:10,13 198:10
 279:6 282:4         225:16,23,24        describe 12:19        56:19                198:17 203:7
Defendant 199:7      235:9,12 255:2,3     62:2 73:21 94:13   dialogue 99:21       directed 284:13
defending 200:4      257:24 277:10        97:25 101:13       Dickens 208:10       directing 284:14
 200:12 279:13       283:25 287:3         153:9                209:15             directly 35:5
defense 108:1        292:16              described 30:14     dictate 282:25         58:16 70:21
 112:24 115:5       democratic 24:3       73:18 76:13 78:6   dictated 283:7         91:14 105:9,20
 117:7 118:24        24:12 66:25          81:3 89:22 145:1   dictatorship           108:17 109:16
 119:9 121:11        79:24 90:25          158:16 171:23        230:14,23 235:9      116:20 120:4,17
 129:5,11 130:15     100:11 124:7         177:4 274:19       die 246:8 262:3        126:3 128:7
 133:23 134:1        125:25 207:8        describes 37:18     died 30:6 33:9,24      130:18 132:3
 137:24 139:20       212:20 216:25        101:14,16,20         34:4               director 12:13
 145:18 211:17       217:4 235:10,11     describing 42:25    Diego 223:6            31:22 58:4
 263:24 264:18       237:25 240:8         73:13 102:19       dies 39:13             288:20 289:5
defensive 199:17     243:23 271:21        164:7 180:10       dietary 93:16        Directors 107:2
deficit-ridden       274:19 282:2        descriptions 13:6     94:15              direct-examina...
 26:6               democratically        13:7               dietician 248:3        148:20
defied 122:19        223:14              deserve 217:16      dieticians 248:4     disagree 26:9
define 150:3,5      democratically-...   designate 158:4     difference 65:19       38:1 99:14,16
 191:9               98:3                designed 75:21        141:5 221:10         118:23
defined 68:7 69:9   Democrats 19:5        76:5               differences 99:15    disagreement
 70:24 71:14         23:11,13 24:24      despicable 218:7      100:1,9 263:25       97:8,8 103:7
 94:24 262:17        27:2                destabilizing       different 16:12,12   disappointed
defining 235:20     demonstrate           99:23                16:13 17:12          248:15 288:4
definitely 228:3     61:18               Destares 256:8        19:18 27:20        disappointing
 267:5              demonstrates         destroy 221:14        33:25 47:6 66:10     99:21
definition 129:1     81:23                237:14 250:25        72:12,13,16 77:9   discretion 194:22
 243:21 274:7,8     demonstration        destroying 253:24     96:5 97:5,9,14     discuss 16:23 83:2
definitive 26:13     87:8                detail 62:3           97:16 99:7           115:8,9 139:17
degree 12:21 56:8   Dench 128:12         determination         101:23,23 137:3      151:6,11 184:7
 235:2              denied 131:4          183:15 291:25        165:10 192:22        236:16,16
DEIRDRE 3:21        Dennis 134:16        determine 23:22       239:8,9 255:2      discussed 28:15
Delares 228:19      dental 262:18         68:11 69:15          263:1                85:25 153:24
Delaware 2:20       denying 117:18        186:10             differently 170:24     263:12
delegates 103:23    department 9:23      determined 18:13      197:3              discussing 32:11
 111:1               92:7 206:3 212:9     62:15              difficult 6:25         32:12,16 53:2
delete 89:23         226:1,2,7,9         determining           13:19 23:25          115:21 157:14
deliberated          269:20,25 270:4      184:21 185:9         24:17 32:8 36:14   discussion 22:24
 178:21              277:17 289:4         187:6 197:3,6        48:12 119:3          33:7 36:5,7,10
delivered 71:3       291:20,24 293:3     detriment 98:18       142:19 283:4         36:15,18 39:20
 75:17               293:11,25            98:19                294:14               43:7,9,13 45:1
delivering 75:23    departments          detrimental         difficulty 27:9        45:22,24 51:23
Della 205:7 207:5    93:16,17 178:11      281:11               36:12 205:22,23      52:12,22 62:16
                                                                                         Page 307

  71:2 76:3 78:3,5     169:20               275:16 278:16      207:16 220:21       educating 78:18
  78:11 79:8,12      distribution           279:12 280:21      237:17 239:16         155:8
  80:8 102:15          164:16 192:25        281:14 286:9       252:3 268:3         education 9:15
  109:21 112:11      District 233:20      dollar 75:14         277:18 278:20         45:1 52:3 76:3,7
  114:24 136:20      distrust 224:9         101:16 262:18      283:1                 76:22 78:3,18
  139:1 150:22       diversion 129:23       264:21            dues-paying            79:9 80:4,15,21
  151:13,14,16       divert 243:24        dollars 86:7         263:9                 83:6,22 85:7,13
  170:6 178:20       diverting 85:20        155:19 166:19     dumb 255:1             85:24 86:5
  183:4 184:1        divide 230:22          168:5 175:10,19   dune 68:10             105:10,18,20
  264:8                244:11               175:21 176:18     duration 69:6          108:8,18 116:19
discussions 34:3     divided 230:18         188:2,6 244:13    duties 58:3 60:7       116:25 123:16
  52:1 90:8 101:18   division 57:15       Dominican 278:4      125:13                124:10,22 127:6
  150:15,18 172:5      58:4,11,13 97:20   donation 183:8      duty 124:3 211:15      128:16 129:8,18
disease 266:21         104:20,20 134:3    Donna 217:24        D.C 3:17,22 237:7      130:19 132:1,22
Dishana(sic)           211:9 214:1        dooming 26:5         238:1,1 244:13        155:19 157:2
  205:8                239:11             door 96:13 245:6     269:3                 158:23 159:8
dishonest 242:21     divisions 97:23        282:3             D.O.L 270:8            160:17,24 161:14
  289:21             doctorate 273:17     doors 92:10                                164:22 165:10
disinformation       document 52:16       doubt 206:23                 E             167:25 168:8,23
  126:13               54:2 63:15,25      Doug 254:4          E 3:1,1 4:1 5:1        168:25 169:20,25
disingenuous           64:10 81:15,21     Dougherty 236:9     earlier 12:10          173:5 177:22
  131:9 138:25         82:18,23 85:3        240:25,25           13:11 64:13 74:9     194:19 252:25
disloyal 99:22         87:11 88:6 89:10   dove-tailing          78:6 85:25           255:20 263:23
dismantle 105:15       89:17,20 92:3        74:24               107:11 137:11        274:7
  137:6                99:3,6 109:12      downloaded            148:20 192:23      educational 12:20
displeasure 93:24      132:3 133:25         25:20               196:22 201:5         56:4 81:8 83:3
dispute 70:2 86:6      142:2,3,5,7        dozens 45:19        early 10:9,9,22,22   educators 127:17
  95:25 117:24         143:7,9,12,16,24   Dr 34:21 65:12        10:23 11:8 14:3      129:21 132:18
  131:5,7 160:20       152:4 177:1          283:16              14:5 16:21 30:1      133:11,12,15
  178:1 201:6          180:25 198:18      draft 32:2            30:25 81:2 86:3    effect 15:24,25
disputes 110:23      documentary          dragging 279:1        120:15 125:15        17:7 41:8 50:22
disrespect 231:15      52:14              dramatic 70:19        135:24 136:19        50:23 51:4,7
disrespected         documents 52:20        89:5                137:8 174:1,2        87:8 104:2
  249:7                53:10 89:12        dramatically        easier 182:11          106:17 136:24
disrespectful          138:14 140:24        86:22             easier-to-read         199:9
  218:8                153:8              draw 166:19           181:14             effective 70:2
disrespecting        dog-and-pony           220:25            East 71:24 83:14       106:12,25
  231:12               240:10             drawn 40:25           211:18             effectively 11:12
disruption 7:25      doing 6:7 37:6         41:17             easy 52:17 131:8,9     25:12 168:2
dissent 128:1          72:14 107:12       draws 33:5            131:17 142:20        205:22
disseration 56:15      166:23 173:8       dream 234:6           211:13 239:15      effectiveness
dissolution            177:7 178:24       dreams 236:20,21      241:18               125:18
  119:15               208:2 209:10         236:23            echoes 36:13         effort 10:7 11:16
dissolved 119:21       210:22,22 214:22   drew 57:17 83:9     economic 87:13         31:18 34:12
  120:24               214:22 215:11      drink 254:7           235:21               81:24 96:3
dissuade 126:18        224:3 228:2        drive 67:23,23      Economics 12:23        131:17 183:16,17
distinct 17:10         237:13,18 242:8      73:4,25 98:17     economy 45:19          183:19,21
distinction 65:19      243:1,19,23        dropped 28:3          52:3 83:14,18      efforts 10:12
  131:18,21            244:23 250:24      drove 74:1 252:20     101:23,24            13:23 14:18
distribute 54:16       253:22 256:7       due 43:16 109:4,6   editions 159:19        19:25 100:9
  157:23               258:17 263:2         141:8             educate 45:5,5       egregious 271:2
distributed            266:25 267:7       dues 116:8 122:19     74:20 77:1 78:9    eight 91:22 272:15
  161:17 162:7         271:18,25 273:1      126:11 187:4        154:15,25            287:13,18
                                                                                         Page 308

either 19:8 68:13    embezzlement          258:12             equality 251:19      evidence 52:14
  161:4 173:1         131:6              ended 16:1,4         especially 35:23       53:8 102:4
  176:13 223:3       embezzling 289:6      22:18 93:5 232:4     41:13 213:4          105:11 116:18
El 219:10 220:17     emerge 72:19        endorsement            283:15               117:15 119:14,18
  221:7,8 222:11      99:17                16:15              ESQ 3:8,8,12,16,20     119:19 120:6,8
  230:8              emerging 56:17      enforce 239:18         3:21                 120:18 121:5
elderly 219:19       Emily 279:8         enforcing 225:20     essence 13:24          132:6,8 134:24
elect 62:12 110:25   emotional 214:17    engage 73:2            47:4 104:21          135:2 139:2
  111:1 126:2        Emperor 261:19        126:12             essentially 33:10      140:1,15,21,23
  256:13 294:10,11   emphasis 12:6       engaged 19:3,9         109:13               141:6,21 219:12
elected 57:14        employed 60:25        20:9,10 75:9       establish 52:24        291:13,15
  58:23 59:2,3,4,7   employee 94:20      engaging 218:6         139:22 140:4,18    evolving 177:10
  61:2 63:4 64:5      236:18 251:14      engineered           establishd 166:18    Evon 106:24
  83:11 110:5         262:8 286:2          109:13             established          EVP's 149:10
  132:18 134:15       295:15             enjoy 235:11           118:23 133:21      exact 86:4
  179:15 206:8       employees 3:11      enormous 67:25         165:25             exactly 6:11
  213:7 215:13        3:19 68:4,5        entail 58:15         establishes            119:19 132:9
  220:8,9 232:6       88:10,12,14,16     entire 20:21 67:12     106:24 109:12        154:14 175:9
  251:20,21 253:5     92:12,15 93:8,10     78:22 89:15,16     establishing 67:1      176:15 180:20
  263:16 266:6,7      96:24 178:25         105:8 125:8          120:12 147:6         188:18 189:3
  271:21,24 278:16    194:22 195:13        151:8 179:19       establishment          192:6 264:19
  282:5 284:4,4       197:5 213:21         184:6 254:12         107:1 126:17       examination 4:6
election 29:4,6       219:21 247:17        293:10             Esther 222:17          4:12,14,16 8:16
  64:8 74:5,8,15      249:14 271:14      entirely 80:17       estimate 111:16        55:21 203:7
  74:22 75:25         277:24               291:13,16          eternal 30:8           295:10
  89:21 109:12       employer 64:18      entitled 21:1        ethical 274:3        examine 48:25
  112:16,19 114:11    68:3,5 69:11,19      82:18 89:10        ethics 12:17           54:10
  114:14 115:9        69:20 71:2,12        91:25 94:22          223:23             example 27:21
  122:18 180:7        86:25 87:14 88:3     102:2 147:16       Europe 234:5           42:5 70:20 77:11
  181:3 294:9,21      89:15,20 90:23       180:19               260:11               91:19 94:13
  294:21              92:11,14 95:6,14   entity 151:8         EV 5:3                 95:24 117:25
elections 27:3        238:24 281:23        152:14,19 153:11   evaluation 132:12      119:13 130:21
  31:21 48:18        employers 18:14       183:10 184:4       Evans 247:8            225:6,22
  180:17,19 205:19    58:22 64:15          189:13             evening 32:24,25     examples 94:7
  256:11              67:17,23 68:10     entrusted 184:19       231:23 266:13        99:25
elective 228:11       72:25 75:13          185:7 187:4,5,11     283:20             exchange 101:21
electricity 47:21     84:18 86:10,19       189:13 190:17      event 2:20 84:5      excited 271:6
  47:23 48:1          90:4 91:2 280:7      193:18 194:6,22      92:14 194:24       excluded 224:10
electronic 28:10     employer's 89:22      195:13,20 196:9    events 102:7         exclusively 61:5
elements 28:6        employer-contr...   entrustment            105:12 108:3         64:13
  30:12 226:3         168:5                150:6                116:24 248:15      excuse 38:6,6
eliminate 87:19      employer-paid       entry 21:5,9         everybody 22:16        154:2 165:17
  89:3                88:18 94:20        entwined 119:13        27:10 32:17          179:14 198:18
eliminated 93:17      95:13              environment            33:20 34:9 43:18     210:4 275:4
  107:8              employment            13:22 99:9,13,21     55:6 112:3         excused 79:2
eliminating 88:24     68:17                100:7 249:4          114:14 213:16      executive 12:13
  103:17             empowered 98:5      Environmental          215:24 219:13        59:6,9 60:8,9,11
Ellis 282:8,8        Empress 261:20        226:1                222:11,23 223:3      60:12,17 61:1
else's 143:9         Emslie 60:18        envision 83:6          227:7 243:22         62:6,17,18 63:16
  285:20              63:23              envisioned 177:10      248:13,13 253:7      63:18,23,24
embarrassed          enabled 110:11      epiphany 150:19        285:5 288:18         76:11 77:24 78:2
  238:2              enact 17:11 19:25   equal 218:15         everyday 251:23        78:22 79:5 80:14
embezzled 131:2      encourage 258:11      255:17             everyone's 33:19       80:19 85:1,5
                                                                                           Page 309

  107:2,17 125:10      158:8 162:25         146:1 192:6          75:20 76:19           120:7,19,22
  125:21 142:16        173:15 176:24,25     239:15               85:23 98:13           201:16 230:19
  148:2 149:4          178:19,20 179:3    explained 140:7        126:5 134:19          244:23 271:10
  151:6 161:16,22      179:10 181:15      explaining 116:22      149:16 151:15       familiar 18:3
  161:22 162:10,12     197:12,13,17,24    exposure 148:9         152:16,22 153:6       21:12 25:14 46:2
  163:11,22 169:13     198:2              express 127:22         156:24 159:10         47:13,24 51:19
  169:23 173:25      Exhibited 115:19       180:14 200:4,11      160:20 161:1,5        66:22 76:6 97:20
  174:5 177:20       exhibits 5:2 37:10     219:22 223:4,6       162:18 165:15,21      100:15,19 197:21
  179:22 182:19        37:11,12 53:1,11     243:18               166:16 169:5,10     families 209:8
  183:12 184:2         53:12 54:12,15     expressed 22:7         169:12 170:3,12       222:1
  185:22 186:3,17      63:7 81:11,12        27:13,20 51:21       170:18 171:5,14     family 146:24
  191:2,12,17,24       154:4,5 157:18       93:24 120:18         171:19 172:1,12       209:8,17 211:19
  191:25 192:2,5,7     158:14 173:14,15     153:20               172:16 173:10         212:8 248:17
  192:10,13,18,19      173:16             expressing 127:18      176:9 177:7           261:1 275:17
  192:21 193:1,10    exist 67:11          extent 112:20          180:9 182:6           277:18
  194:9,12,17        exonerated 278:1     extra 286:1            185:21 186:18       fantastic 215:23
  196:11 200:2,9     exonified(sic)       extraordinarily        193:21 194:5,9      far 100:4 102:13
  201:12 211:12        289:8                32:7                 200:8,15,15,21        104:12 202:1
  213:1 216:18       Exorbitant 82:10     extraordinary          201:13,18 213:15      223:5 224:4
  252:17,24 253:6    expand 13:23           15:6,11,12,14,16     219:13 271:10         274:16
  263:3,5,11           32:13                15:17,18,19,20       292:2,11,17         farce 261:13
  264:17 265:5       expanded 28:12         16:5 22:22 69:4    factors 28:3 75:24    Farm 288:24
  269:13 272:4       expansion 28:1         116:10             facts 79:17 108:9     fast 243:25
  284:5,6,6,8,17       47:4               extreme 93:24          109:5 117:2         faster 138:19
  290:1 291:21       expansions 28:8      eye 11:12,23           214:24              father 57:19
executives 82:10       47:11              eyes 218:10          factual 200:25          276:22 288:24
exercise 237:25      expect 158:21        E-Board 278:16         201:9               fault 261:21,21
  259:18 291:18        218:14 275:25      E-mail 110:14,14     fail 33:12            favored 97:13
exhausted 288:18     expectation 164:8      115:24 122:13      failed 36:22 38:18    Faye 229:25
exhibit 9:3,7          191:24 192:19        137:21 139:18        39:7 44:12 51:9     fear 80:1 289:16
  37:14,17 38:8,23   expected 13:12         141:12,13 142:18   failure 25:1 79:23    February 14:5
  40:5 43:23 48:22     21:22                211:11 242:20        79:24                 30:1,20 32:20,24
  48:24 49:1,3,13    expenditures           261:19 277:22      fair 6:25 34:11         32:24 33:1,1,4,8
  49:15 50:2,3,6,8     192:1,9            E-mailed 264:13        48:18 66:20           39:24 45:7,14
  50:11 54:23,24     expenses 292:12      E-mails 229:2          133:16,18 134:1       48:8,20 83:19,20
  54:25 55:2 63:6    expensive 30:5         242:17               162:2 189:7           84:5 92:1 101:10
  78:14 81:9 82:15     48:13 252:12       E-V-O-N 106:24         204:7 213:23          160:12 174:4
  82:17 84:24 87:4   experience 9:15                             216:2 227:8           175:23,23 176:1
  87:6 89:8 91:21      31:7,10 279:25               F            230:9 234:24          178:1
  91:23 98:22        experienced          fable 227:10           237:1,2 245:9,10    federal 77:15
  101:7,9,10,25        91:12,13,14        face 221:23            245:14                194:21
  102:18 103:19,21   expert 168:4           282:19             fairly 27:13 35:22    feduciary 281:10
  106:5,20,22          195:7              faced 249:23           73:2                feel 49:22 50:18
  109:24 110:2       expertise 9:14       facilities 68:15     fairness 122:20         206:13 236:18
  115:17,23,24         222:5                72:12 73:9 82:6      234:25                237:1 249:9
  123:4,8 124:15     expire 71:25 81:2      93:23 161:23       faith 83:10 145:17      252:11,23 253:9
  124:17 127:4,8     expires 207:2          162:11 278:25        268:20,22             254:24 267:1
  127:10,14 128:20   expiring 72:2        facility 87:20       fake 272:2              269:23 270:12
  130:8,10 132:16      76:16                94:17 95:6,7       fall 5:5 15:7 62:11     282:15,17
  133:5 136:13,17    explain 28:24          232:7 245:25         101:14 158:6        feeling 216:6
  137:15,17,19         116:24 121:1,3       283:22               230:22              feets 279:1
  139:10,15 147:14     140:11,12,17       fact 15:15 17:13     falling 285:7         fee-payer 212:15
  154:2,4,6 157:17     142:2 145:25         33:9 35:2 37:22    false 119:16 120:5    Feinstein 277:23
                                                                                             Page 310

fell 97:11              212:16 263:8           231:3,13,13          224:17 226:12        116:22 139:21
fellow 253:5            264:14 279:20          232:6 238:8,11       227:13 228:14        140:4,19,25
felt 7:13,15 289:14   financially 125:5        249:24 256:17        229:15 234:11        167:3 171:6
Ferris-Nunez            125:5,9 295:16         260:16 269:14        236:4 240:12         266:8
   253:12             financing 12:17          273:22 276:16        243:5 247:1        foundations 10:5
fiduciary 124:3         30:11 31:20            279:9 287:5,9      follows 8:14 55:19     77:11,14
field 13:2 42:11        75:18                  288:9 293:9          203:5              foundation-fun...
   223:11 225:11      find 32:22 158:21     FITZPATRICK           follow-up 175:7        33:3
   251:22 280:22        159:7 241:14           3:21               Folsom 279:9         four 14:23 23:13
Fiesta 2:20             250:22 261:20,21    five 11:21 14:23      fond 292:7             124:1 138:13
Fifteenth 3:17          282:13 290:2           23:11 24:11 54:3   foot 96:13             209:2 220:20
fifth 163:8           fine 49:20 50:16         54:4 89:13 108:8   force 81:20 82:4,8     262:12
fight 27:8 39:20        53:20,20 111:21        113:12 138:13,19     82:20 92:25        fourth 38:10,24
   73:11 83:25 84:8     117:12                 138:21,23 139:3      93:21 212:12         88:7 99:11
   96:23 212:18       finish 112:13,15         141:24 144:11        218:15 284:25      four-year 72:3
   230:17 242:7         112:21 114:7,16        198:24 204:20,20     287:12             Fox 54:23 55:1
   243:4 244:2          116:8 121:18,25        204:22 205:4       foregoing 295:5      frame 50:25 51:2
   246:3,3,6 255:24     122:2 138:21           208:5 210:24         295:12,18 296:5      81:23
   255:25 262:2         202:1 243:4            218:19 245:25        296:9              Francisco 3:9
   264:7 268:10         271:5 275:8         five-minute 54:5      forever 213:23         25:21 59:21 61:8
   272:3 279:5        finished 8:6 56:20       138:12             forget 243:2           102:17 258:7
   280:10 281:21        134:7 138:22        five-state 10:10      form 26:22 39:10       282:10
   282:23 284:22        143:21 191:8           15:2                 223:23             frankly 18:10 39:9
   288:7,8 290:12     Fink 128:13           fixed 222:6           formal 129:22          214:23
   290:14,15          fire 93:20 226:5      flash 6:5               140:21,23 141:6    free 237:24 270:15
fightin 246:2           290:19              flawed 116:5          formed 61:8 62:3       283:25 288:10
fighting 39:14,16     fired 93:9 238:25     Fletchall 224:22      former 252:15        freedom 211:17
   40:2,3 67:6,13       254:14              Fletcher 128:13       forming 57:21          211:19 237:25
   76:21 244:14       firms 147:17          Flint 57:24           formulated 153:5       285:16
   245:4 271:20       firm's 54:24          flip 88:6             Forrest 251:9        freely 215:8
   294:12             first 9:6 10:6 14:3   floor 22:1 259:19     forth 29:17 295:6    Freeman 109:14
figure 30:22            15:12,13,16,19      Flores 227:16         fortunately 97:11      110:10 135:23
   114:16 158:4         16:9 20:23 26:1     flown 244:11          forum 83:1,9           146:13,16,20
FILE 1:25               26:9,14 38:23       focus 12:9 13:21        259:21               148:10
filed 17:5 48:3,7       52:12 54:1,9           61:3 209:10        forums 84:9 172:5    Freeman's 110:16
   48:14,14,19          65:9 69:3,8,10         253:18             forward 33:13          147:22
   129:25 238:21        69:12 71:11         focused 20:6            45:2 46:1 98:8     Fremont 227:22
files 231:8             72:23 84:4 87:14    focusing 56:17          103:10 118:9         269:10
filing 270:14           87:15,18 88:8       FOERSTER 3:7            119:22 135:3       frequently 46:18
fill 178:10             99:12 104:18        folks 60:23 72:6        137:6 140:8          156:17
filling 178:11          105:1 106:7            74:2 75:5 87:16      146:25 263:3,23    fresh 33:18
filming 252:11          109:21 114:18          253:3 259:8,10     foster 76:2 83:7     Fresno 273:7
filthy 208:18           116:16 122:3        follow 38:7 162:22    fought 71:4 93:3     Friday 266:22
final 22:1 29:21        129:21 137:9           188:18 212:17        94:5 95:21         friends 131:2
   284:17 291:11,22     153:18 162:25          232:19 237:15        221:16 247:25        233:2 257:7,9
   292:4                165:24 166:14          238:5 241:13         266:19             front 78:25 169:22
finally 281:1           170:8,12 186:6         250:24 258:22      found 76:19            197:22 243:22
finance 31:20           186:22,22 193:22    followers 247:13        112:10 194:16        246:7 286:8
finances 125:4          198:24 199:2,7      following 26:11         209:23 213:5       froze 230:3 250:12
   259:22               201:16 207:9           27:21 31:25          250:1,2 262:16     frustrations
financial 79:22         209:15 211:11          118:21 122:16        287:1                121:21
   124:5 146:22         213:18 218:3           151:19 162:21      foundation 14:10     Fry 234:16
   147:23 148:5         226:25 228:5           217:20 218:19        19:7 84:21         Frysi 228:22
                                                                                       Page 311

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full 23:24 28:20     funded 10:5          gentlemen 264:25      70:12,13 73:9      39:16,17,19,20
  69:13 93:6,15        166:12             George 3:8 134:16     97:17,24 104:24    39:22,23,24 41:5
  106:10 110:12      funding 96:10        getting 18:18         106:1 108:6        48:22,23 54:17
  120:11 189:4       funds 84:18 86:8       28:22 104:8,12      109:20 118:9,11    56:13 61:20 70:9
  191:19 203:11        117:19 129:4         113:13 147:5        119:22 121:19      73:7 74:4,10,20
fully 68:5 69:10       130:14 132:2         158:11 189:8        123:2 132:14       74:24 78:7 80:1
  71:12 88:17          151:7 167:1,2,9      194:25 210:1        135:14,16 137:2    83:25 86:12
  94:20,24 95:13       168:12 169:14        214:17 216:22       137:5 139:5        108:16 109:11,24
  110:17 116:7         182:18 187:20        223:9,16 229:2      142:4 143:23       112:1,12,14
  206:8                194:23 195:14,21     279:11 285:16       144:12 146:15,25   117:13 118:12
fully-paid 221:24      209:6 257:19         286:9               147:11 151:3       119:8,19 120:11
full-blown 95:15       264:10 274:10      Ghandi 233:23         154:7,12 162:4     122:14 129:14
fun 235:23             281:10             girl 227:9            165:6,8,8 167:22   131:12 138:4
function 77:22       funny 237:3          give 6:7 30:23        168:4 178:14       140:8 145:25
functioning 125:2    further 34:15 52:6     41:10,11,12         190:1 191:20       146:4 159:11
fund 18:15 59:16       52:9 88:6 148:13     53:23 56:3 92:21    192:13 202:1       171:24 176:3
  76:7,22,25 77:1      232:3 295:14         92:23 93:20         205:16 206:14,16   177:25 178:19
  77:5 78:3,18       future 33:13 39:25     94:13 99:17         206:17 208:3       185:6,6 186:11
  79:9,13 80:4,16      272:11               113:4 117:25        210:4,5 214:23     188:9 189:24
  80:21,23 83:3,6                           119:12 130:21       215:4 217:19       190:17 194:6,10
  83:22 84:13 85:7           G              158:3 180:15,20     219:25 220:2,22    194:13 201:6
  85:13,24 86:5      Gabe 163:12            209:22 212:13       226:11 230:5       202:3 204:8,16
  105:10,18,20       gain 210:23            220:25 225:6        231:6,6,7 236:2    206:11 209:12,13
  108:8,18 116:19     274:11                229:5 267:24        239:19 241:11,14   210:6,8,9,10,10
  116:23,25 118:7    Gallegos 243:12        276:16 287:20       241:15,24,25       210:12 211:20,24
  118:22 119:15       246:14,14             291:10              242:1,5,6,9        214:19 216:14
  120:5,7,23,24      Garamendi 11:10      given 15:5 25:7       244:13 246:12,12   217:18,18 218:8
  121:5 123:16        11:10                 27:4 28:5 33:9      247:21 249:5       218:9 220:4,18
  124:11,22 125:6    Garcia 264:25          33:18 37:7 51:15    255:24 256:7       222:10 223:20,24
  127:6 128:16        265:1                 53:14,17 58:23      257:20 258:24      229:12,13,13
  129:8,18,24        Garcia's 110:11        91:18 106:8         259:2,17 261:3,8   230:20 231:7
  130:17,19 132:1    gather 48:7,18         119:15 150:9        262:3 263:5,10     233:3,9 235:25
  132:12,22 134:24   gathered 134:24        206:3 216:25        273:11 275:8       237:16 238:5
  135:3 138:6         134:25 284:6          235:13 248:9        278:10 284:9       239:12,23,23
  151:18 153:24      Gatto 251:7            287:2               285:8,18,22        240:7,9 241:15
  154:13,22 157:2    general 30:16,23     gives 161:18          286:18 294:11      241:18,21 243:3
  158:23 159:8        39:12 45:18         giving 41:16 42:12   goal 39:12 44:16    243:4 245:7,21
  160:17,24 161:14    48:15,19 61:8         88:25 92:19 94:2    51:18              246:8,9,11
  164:22,23 165:17    78:10 162:15,16       206:10 210:19      goals 45:4 257:8    250:19,22 252:5
  165:25 166:11,21    164:2,5,6,12,18       276:4              God 206:17 236:3    253:7 256:9
  167:7 168:8,10      169:4,15 172:22     glad 115:10 224:2     270:15             257:20 258:8,9
  168:13,23 169:24    173:1 176:12,21       270:11 292:21      goes 68:16 105:20   260:19 261:11,12
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  175:24 177:21,22    23:18 44:7 52:23    gleaned 14:7          120:17,25 138:2    267:17,18 268:17
  177:25 178:14       60:3,7 162:8        GLENN 3:12            164:8 191:25       268:18,23,25
  188:11,12 190:16    197:22              go 7:7 8:22 9:20      202:7 293:2        269:4,11 270:13
  191:3 192:15,16    generate 96:20         14:16 17:19 22:1   going 6:15 7:3,11   270:23 272:23
  194:19 195:23      generated 173:11       25:1 29:8,17        9:18,19 10:24      275:6,24 278:21
  196:3 200:3,10     generation 212:8       30:15,20 35:6       11:6 16:23 18:5    279:1,3 281:5,15
  211:9 242:16        275:19 287:17         40:3 42:23 43:4     21:25 24:9 29:2    281:25 283:18
  250:12 252:25      gentleman 226:25       48:23 54:17         34:22 38:5,12,13   287:15 288:6,6,8
                                                                                        Page 312

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  289:20 290:3       grandmother           93:13 217:12        98:13 103:9         203:8,25 204:7
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gold 67:4            grant 167:3 171:5     175:22 189:17       220:9,13 222:12     293:8,16,24
gonna 222:12           171:9,12            284:5               223:25 229:13,14    294:3,7
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Gonzelez 228:16      grateful 280:1       guilty 107:25        292:2              hate 183:24
good 6:4 34:21       Gray 83:12            109:2,2            happened 7:6         190:11 196:1
  55:8 71:19         great 107:12         guy 142:13 259:8     14:25 16:17        HAUPTMAN 3:21
  112:18 153:21,25     125:23 150:21       260:13,16           20:11 21:19 27:5   Hauptman's
  155:1,9,16,24        180:3 237:20,21    guys 68:12 206:25    33:11 62:19 64:8    134:23
  156:3,7 164:19       252:2 260:25        208:23 228:6,7      86:25 93:14,24     Hawaii 212:8
  177:20 182:16        270:7,11,11         231:22 232:17       93:25 107:22       Hawaiian 252:2
  212:22 213:25        286:7               241:2,3,4,21        108:2,3,17 111:5   Hayward 225:1
  214:9,9 216:4      greed 230:20          242:10 244:14       120:24 136:2        226:2 254:5
  226:20 227:24      greedy 216:1,2,3,7    245:7 249:3,18      145:1,5 146:1,9     265:2
  230:9 235:7,15     green 6:19 113:19     253:14,23,25        146:11 153:13,15   head 25:16 31:13
  235:17,18 236:19   GREENSTONE            256:23 257:18,22    153:16 166:5        134:16,17 235:7
  236:19 238:12        3:12                257:22 261:4        172:4 175:2         238:11 247:15
  242:13 243:16      Grejada 122:23        268:16 275:15,20    179:18 193:10       276:6
  248:2 254:24         148:1               275:21,24 278:12    194:4 216:23       heading 197:18
  258:3 262:1        Gresham 134:17        278:21 279:4        232:23 233:3       headquarters
  264:3,25 266:13    grew 57:18 58:1       283:14,16 286:7     262:21 267:19       226:8,10
  272:10 275:17,18   grievances 238:22     286:17 290:10       285:19 287:10      heads 44:8 221:22
  280:21 281:19        280:8              Guzman 255:6,6      happening 84:1      health 9:24 11:2,7
  282:8 283:20       Griffith 243:7                            109:16 192:6        11:18,20 12:5,8
  285:25 287:15,23     244:5,5                     H           213:11 242:5        13:5,8,9 20:12
goons 276:25         gross 146:21         Haas 217:22 218:3    263:7               21:17,20 22:2
gotten 86:4 171:3      226:10 273:13,14   Hafer 217:24        happens 90:6         26:3,17 34:24
  174:4 216:5,5        273:16             Haggett 236:8        112:19 192:20,24    35:3,13,15,20
  242:2              ground 171:3         Haley 269:9          193:14 278:9        45:18,20 68:5,8
govern 181:8           172:19 173:20      half 73:23 95:18     284:15 285:22       69:11 71:12 76:1
governance             174:3,4 175:24      101:4 137:1        happy 100:14         88:11,12,15,18
  148:21             groundless 225:8     hall 2:20 291:9      174:18 217:17       88:24 89:14
governing 60:9       grounds 124:2        hand 80:12,20        272:7 288:12        94:20 95:1,16
government             224:5               196:9 207:2        harass 209:7         206:2 239:4
  77:15 171:7        group 7:9 11:24       235:17 271:7       hard 35:22 56:24     244:6 255:19
governor 14:3          149:8,20 183:11     272:5               67:6 103:15         273:20,21 283:3
  16:7,16 36:24        185:7 187:5        handed 279:24        170:10 188:17       287:24 288:10
  37:18,23 38:3,11     194:5 208:24       Handeman 205:8       207:16 211:13,18   healthcare 1:4 2:4
  38:17,24 39:6        241:22             handful 126:7        212:3,6 213:17      3:6 4:10 11:15
  49:17 50:13 51:6   groups 12:1 19:19     149:18              220:21 249:9        12:11 13:2 15:22
  51:13,15,20          19:20 32:21        handicapped          251:18 275:19       19:7,25 23:21
  76:19 102:20         34:14 51:17         233:8               282:14 285:13       26:5,8,23 32:23
governor's 16:15     grow 128:1           handing 249:9       harder 30:4 59:22    35:13 36:2,6,11
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grace 264:5          growth 98:11,12       229:7               53:6,25 54:3,9      39:2,6,12,21
Grajeda 107:9,14       98:15,17,19        hands 80:11 194:1    54:21 114:1,2,12    44:14,18,19 45:1
  107:15 109:1,9       258:16              244:1 282:3         119:12 120:4,17     45:2,4,8,15,21
grandfather          guarantee 93:11      hand-selected        121:7,16 132:8      46:9,11 47:1,2,6
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grandma 273:8          250:21             Hans 258:6           143:20 144:11       51:15,17,24 52:1
                                                                                         Page 313

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 75:8,9,11,17,18      24:1,3,7,11           285:14            HMO's 35:10           58:4,10 67:9
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 81:25 82:2,6,10      111:2 112:2,16      Hernandez 228:17      221:21 234:24       222:8 228:25
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 134:16 136:10        178:17 184:13         227:21 228:24       209:17 210:5        283:3,21 285:12
 153:21 154:10,15     204:4 207:2           231:25 238:6        212:4 246:12        290:18
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healthy 125:5,6       140:24              higher 259:10         109:11 111:10       245:25 252:24
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                                                                                         Page 314

husband 216:11     implore 240:4        include 30:11          279:17,22           intention 123:23
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hush 217:3           143:25 144:4         182:9                251:22                90:17,21 161:5
hypothetical         145:2 146:7,8,12   included 224:4       informing 148:25        182:25
 184:22 189:18     implying 13:19       includes 201:19        187:11 193:3        interested 295:16
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hypothetically     importance 78:21     including 13:5         221:12              interests 35:10
 189:15              154:17 274:25        19:16 35:20 72:5   initially 167:7,8       85:21 90:19 94:9
hypotheticals      important 36:2,6       77:3 84:15           168:11 169:20       interference
 187:18              36:11,16,19,21       125:17 126:6         194:6 195:21          69:19,21 124:4
H.I.V 266:18,21,22   73:14 74:14 75:1     134:15 223:21      initiative 17:4,7,9   interim 181:1
 266:23 267:14       75:2 77:3 81:21      271:8                17:12,20 18:2       interjection
H.R 90:10            104:17 114:6       inclusion 165:1        27:24,25 28:15        254:23
                     127:21 148:25      income 68:17           28:21 29:4 30:16    internal 99:5
          I          149:5,25 150:3,5   incoming 11:12         30:21 31:8 32:3       110:24 124:7
ID 5:3               150:7,11 155:17    incomplete             32:6,14,19 39:18      128:4 182:22
idea 81:7 96:10      156:21 161:7         190:20               48:3 85:16 138:6      238:18
   116:6 122:17      164:24 176:6       incorporate          initiatives 17:13     internally 35:19
   150:21 164:19     184:20 185:8         149:22               51:16 78:19           93:22 99:7,8
   177:20 180:3      190:4 193:3,8      increasingly         injured 277:12        international 1:2
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idealistic 32:9      262:22 271:18      incredibly 72:15       261:22                8:6 12:24 20:15
ideas 99:17 236:15 importantly 85:18    independent          inquiry 110:22          85:20 86:6,24
   263:19 291:10     85:18 259:2          292:19               144:10                91:16 92:5 105:3
identification     impose 70:8 79:18    independently        inside 63:16 149:8      110:19 112:22
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identified 152:4     90:14 91:7 94:8    Indian 233:23        instruction 192:12      136:8,19 142:11
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   187:14,21       impressed 281:6      indicates 132:12     insulting 211:14        239:10 257:3,18
Ilda 226:14        impression           indicted 278:1       insurance 11:7          261:4 269:22
illegal 254:15       144:25             indictment 277:1       28:13 46:20,22        270:14,25 277:25
   284:20          impressive 261:16    indiscretion 281:9     68:5 69:11 71:12      292:18 294:19
Illinois 10:11     improper 104:23      individual 46:19       88:11,12,15,18      International's
   14:20             117:15,19,19,22      46:21 133:13         94:21 95:16           59:16
illustrate 130:22    129:3 130:14         186:15 188:13        194:24 255:19       interpret 123:20
ill-fated 13:6       131:25 132:2       individuals 184:19     290:19,22,23        interpretation
imagine 151:13       147:7                184:21 185:7,10    Insure 11:24 33:2       123:24
immediate 165:24 improperly 116:18        187:5,7,8,14       insurers 51:17        interpreted
immediately        improprieties          188:4,5 189:14     integrity 212:25        134:21
   28:19,20 165:14   146:22 147:24        190:5,7,17,18,19     213:3,15            interrupt 70:7
impartial 210:2,18   148:5                196:8              intellectuals 20:4      116:11
   210:18          improve 49:21        industrial 56:16       128:14              interrupted 106:4
Impeach 245:18       50:17 96:9           56:18              intelligent 19:8        108:22 226:4
impeached 245:1      265:25             industry 67:9,20       228:9 254:25        interrupting
   245:2           inability 28:3         72:17,17 81:19     intend 291:12           118:17
impeaching         inaccuracies           82:9,20 88:16        292:19              intersection 15:1
   116:21            200:25               94:6 96:6,8,20     intended 17:22          20:7
impinging 202:2    inaccuracy 201:9     inform 193:9           84:13 202:11        intervention
implemented          201:19,21          information 11:1     intent 120:19           122:4
   17:3            Inadequate 82:3        14:7 41:11,12        139:24 141:12       interview 33:16
implicitly 94:1    inch 262:2             76:3 232:11,24       153:19                40:14,18,22
                                                                                          Page 315

  43:14                19:13 20:6 27:11   Jared 272:11           286:4                236:14,17 248:4
interviewed 14:1       33:13,13 52:19     Jarvis 18:6          joining 255:8          248:10 249:21,24
  18:23 19:2,5,6,7     74:24 79:17        Jay(sic) 234:22      joint 25:15 166:12     254:5,6,11 255:3
  19:10,12,17          86:18 104:6,9      jealous 216:7          182:20               255:17 256:17
  27:16 32:10          105:14 117:17      Jeannett 218:24      jointly 68:10          258:7 260:3
  40:17,20,25 41:2     119:4 124:9          220:16               69:14 84:17          262:8,9 265:2,7
  41:6,7               129:8,16 131:21    Jenny 290:5,5        Jonathan 251:8         267:23 269:10
interviewing           131:24 136:5       Jersey 234:4         Jones 228:19           273:18 275:11
  18:20 41:8           138:2 141:11       Jess 256:8           Jorge 60:17 63:19      276:15 279:9
interviews 14:2,7      148:10,11 149:21   Jessica 228:18       Jose 177:14 238:7      286:2,11
  14:23 18:19          156:24 157:14      Jesus 228:17           248:21             Kaiser's 286:3
intimidated 7:15       183:23 219:25        261:17 285:11      Joseph 226:15        Kaiser-Catholic
intricate 199:8        220:4 269:15       Jim 247:6 248:20     journal 13:9           96:12
introduce 16:4         274:5              Joan 60:18 63:23     journalist 41:8      kangaroo 231:4
  157:17             issues 11:3 18:8     Joanne 243:9         journalists 127:16     251:17 261:15
introduced 14:4        28:14 36:2,6       Joaquin 289:13       Joyce 92:7             292:3
  45:8,15 140:24       38:4 45:2 47:1,2   job 60:24 69:6       Juana 240:23         Karbalos 63:22
  140:24               51:24 52:12          107:12 210:6       judgment 292:19      Karen 229:17
introduction 82:1      74:23,25,25 75:1     215:23 221:1       July 136:7 162:3       240:19
invaded 277:12         75:11 76:2,4,24      234:6 235:24         175:14             Kari 234:15
invasion 211:22        77:2 78:10,20,20     238:15 239:1,21    jump 238:11          Kathleen 283:12
investing 126:7        81:22,25 82:14       242:7,8,10 243:1   June 99:5 136:19       283:12
invite 223:21          83:2 84:10 99:6      254:16 255:19        136:19 137:8,8     Keefer 264:12
invited 78:23 79:5     99:8,10,14           263:5,20 265:19      137:22 145:2         265:8
  80:15 257:6          102:25 103:3,6       269:5,18,24          146:6 162:3,21     keep 7:24 27:11
involve 47:10          104:14 105:20        272:14 273:1         162:23 175:13        39:14,16,23,24
involved 10:3          115:4 119:11         276:7 285:17       junk 207:10            56:12 70:12
  14:17 19:20          120:15 121:15        286:9,16 290:7     jurisdiction           79:13 104:13
  34:12 47:11,25       122:9 129:12         290:12,14,15,16      255:23               114:24 115:4
  70:21 126:3          154:16,17 155:25     290:21,22 291:1    jurisdictional         117:6,13 119:4
  140:10 141:11        157:4 161:7        jobs 56:24 91:19       135:11,18 136:4      119:10 121:14
  143:14 151:13        164:10 177:23        247:23 255:19        136:6                129:15,15 131:18
  197:9 198:13         178:10 217:1         266:23 274:15      jurisprudence          131:21 139:6
  206:20,21,22         280:5                290:8                259:19               207:14 219:6
  232:3,7 238:17     item 52:24           Joe 206:18 272:10    justice 216:20,21      220:3 228:12
  274:2 276:24       items 9:18           John 4:11 11:10        216:24 268:1         230:18 251:22
  288:22,23 290:15                          55:10,15,25          270:13,20            252:5 267:18
involvement 11:4              J             231:10,10 232:8    just-us 271:9,17       280:2 282:5
in-depth 10:6        Jackson 147:22         237:5,22 239:2     Ju'Anna 211:3          287:21 291:18,19
in-fighting 280:12   James 230:7            239:20 242:23        216:17             keeping 11:23
in-home 219:3          234:18 247:3         278:3,8 281:7                             49:19 50:15
in-house 268:5       Jamie 240:18           282:16 283:13,16           K              156:20
In-N-Out 207:22      Jankowski 272:9        286:4,15 288:1     Kaiser 3:16 35:20    keeps 292:2
  207:24               272:9                290:11 291:5        64:16 66:2,9        Kees 227:18
Ionikoua 236:11      January 14:3,4       Johnson 218:21        67:3,7 68:19,20       228:24
Iraq 142:20            20:13 21:6,10,19     219:9,9 224:20      69:4,5,6 86:15      Ken 223:22 277:3
  211:13               22:15 23:20          226:20,21 229:25    86:16 211:8         kept 252:20
Irene 227:19           24:19,20,21        John's 247:20         212:23 214:1,25       266:21
Irma 266:13 282:8      25:22 27:14,21     join 56:20 57:5       215:17,21,23,25     key 16:8 33:16,22
irregularities         27:24 28:19          69:20 255:9         222:24 225:1          127:22 264:13
  124:5                29:23 36:24          280:25 287:18       226:21,22 229:20    kick 250:3 278:17
issue 5:4,5,6 11:7     37:19 45:25        joined 37:23          230:3 232:1         kicked 250:4
  11:7,23 12:8         46:13,19,23 57:7     209:18 255:10       233:17 234:22         278:14 279:4
                                                                                        Page 316

kickoff 84:4 176:1   156:3 158:3,12      291:23 293:4          287:11,15 288:22     235:18 237:15,21
kids 28:1 236:21     158:24 160:25       294:9                 291:20,24 293:3      241:21,22 242:11
  275:17 290:7,13    161:4 166:8,8      knowing 130:4          293:10,25            271:13 272:11
  291:1,3            168:6,10 174:8      210:5               Laboratory             282:1
kill 234:9           174:16 175:9,9     knowledge 32:17        280:16             leaders 19:3 57:8
killing 287:14,14    175:12,13,14        102:9,11 109:6      laborer 288:24         58:24 66:19 73:6
Kim 106:24 218:21    178:20 183:19       139:24 140:11       labor-intensive        125:23 128:18
  219:9              184:25 186:14       141:22 144:3          67:20                133:13 134:15
kind 12:15 14:12     189:2,4 190:5,18    145:1,4 173:4       ladies 264:25          152:16,22 164:25
  16:18 20:9 31:22   195:8,10,11,12      254:9               lady 207:23 246:4      207:12,13 213:7
  33:3 44:8,10       195:15,16,17,18    knowledgeable        laid 124:25 126:9      213:15,16 219:14
  64:24 73:4 81:3    195:22,24 196:1     19:12               lame 208:15            220:11,13 223:21
  83:2,2,15 96:5     196:2,4,13,16,19   known 221:18         landscape 85:15        228:2,11 230:19
  97:5,12 104:6      196:20,21 197:1     224:3 233:6           89:18                241:11,13 242:23
  110:23 165:12      197:2,6 204:23      254:18 267:13       language 68:15         243:25 246:1
  177:11 178:12      207:8,21,22        knows 10:15,17         69:3 89:23,23        249:2 251:21
  205:24 231:7       208:24 209:3        102:7 108:25          95:5                 279:6 289:18
  265:11,12 281:10   210:3,8 212:6       157:12 160:19       large 61:24 220:4    leadership 64:25
  281:14 291:14      213:13 214:24       221:10 235:16       larger 6:14 71:21      126:14 135:23
kinds 47:10 51:21    218:3,9,11,11       248:13 265:14         105:5                179:21 205:25
  66:8               219:7 220:2,3,5     268:5 285:6         largest 62:1 66:4      222:6 223:7
kiss 208:17          221:20,21 223:8    Koppell 42:14,15       100:11 125:7,15      225:4,19,19
kitchen 237:10       226:4 227:4         43:7                  127:23 286:24        237:14 242:2
knew 74:4,10,23      228:1 229:5        Kristen 234:14       Larry 230:4            253:23 268:19,20
  108:8 117:2        231:5,6,14,17,21   Krital's 163:12      Latanya 234:19         268:23 277:4
  130:4 138:3        232:10,10,18,19    Kuehl 24:5           late 101:10 103:6    leading 10:20
  201:15 252:25      232:23 234:3       Kwwa 228:24            135:24               11:25 12:15 13:9
  253:2,2,6 263:4    235:1,2,19                              latest 277:15,16       35:16 58:16
  267:16             236:25 238:12               L           Laurel 218:1           127:16 128:11,13
Knight 218:1         241:18,21,25       L 1:2 2:2 3:15       law 183:14 194:21      242:9 284:12
know 6:11 7:22,23    242:8 244:7,10     Lab 286:3              235:2 285:21       leads 90:23
  13:6 18:4 20:8     244:12,16,17       labeled 127:10         286:12             lead-up 81:5
  25:15 27:10 40:8   245:1,9,14         labor 19:15,17       lawful 125:2         learn 134:23
  40:12,13 42:15     246:10,17 248:16     56:10,21,25        laws 47:9 295:18     learned 93:19
  43:18 44:6 46:4    249:3,22 250:9       57:17,18 58:1        296:9                263:1
  50:5,21 51:3,25    250:17 253:4,14      59:10,13,17 60:2   lawsuit 129:25       learning 192:24
  52:2 53:1,9,15     253:17,22,25         66:13,19,23          269:15             leave 25:17
  56:24 60:3 61:18   254:15 256:24        67:22 77:22        lawsuits 270:14        107:19 122:24
  61:20 65:14 66:7   257:14,14,18,24      97:17,23 98:1,4    lawyer 201:6           148:4 206:25
  69:3,5,12 70:10    257:25,25 258:1      100:7,12 127:17      233:23 234:4         209:9 229:10
  70:10 73:2 75:5    258:2,3 259:8        127:25 128:8,14      286:11               247:22 254:21
  78:12 83:8,25      260:6,9 261:13       134:3 142:13       lawyers 131:8,10       290:11,11 291:4
  87:17 90:2,14      261:16,20 263:7      167:25 172:6         230:16 251:25      lectures 189:1
  91:2 92:10 100:2   263:9 264:15,20      177:14 185:1         261:24 286:7,16    led 31:18 148:8
  102:4 103:4        265:10,11,11,12      197:20 212:13        287:20             left 8:5 9:3 24:6
  104:5,9 108:4,25   266:1,10,10          214:8,11 235:21    lay 99:25              31:3 152:17,22
  109:7 111:2,12     269:12 270:8         256:20,20 257:2    laying 116:21          204:24 246:7
  112:9,21 114:3,6   272:5,25 273:2,6     257:5,23 258:3     lay-offs 68:20       legacy 287:8,16,21
  114:15,17 115:11   274:16 278:8,11      269:20,25 270:4    lead 80:7 239:22     legal 92:7 195:2,4
  117:11,12 119:17   279:16 280:23,24     270:23 274:24        265:3                201:6
  119:18 120:22      281:1,1 283:5        277:8,8,17         leader 23:3 40:13    legally 16:18
  133:19 140:3       286:8,10 287:4       280:11,13 281:11     44:11 101:19       LegHis 20:19
  141:16 153:7       287:17 291:1,3       285:4 287:8,9,11     208:22 235:6,15    legislation 10:25
                                                                                              Page 317

  11:4 17:11 18:9     letting 222:23           285:8                 149:7 179:7,20       214:8 218:10
  26:23 28:17         let's 7:24 29:25      Lisa 240:22 256:16       179:22 180:1,2       221:22 223:8,13
  35:13,18 46:7          30:8 49:25 65:12   list 78:24               197:20 198:8         227:12 231:6,7,8
  47:7,9 206:1           101:15 104:13      listen 230:21            199:9,15,17          242:19 246:6,7,7
legislative 16:1         119:4 121:8           243:2 252:19          200:2,9 212:20       246:7 252:21
  18:24 19:24            131:1,3,3 132:15      263:11                232:7,22 233:6       255:22 260:22
  20:19,21,24            143:11 147:12      listened 281:4           246:18 248:24        272:24,25 280:22
  22:20 24:25 25:4       159:15 160:14      listens 236:17           251:19 252:16        283:14,15 286:7
  25:15,18,19            170:8,13 173:15    listings 178:24          255:14 256:4,14    looked 13:25
  32:22 33:17            176:24 181:14,15   lists 126:23 179:22      274:19,25 279:15     24:13,17 158:17
  45:20 76:18,20         187:19 188:8       literally 28:16          279:15 280:1         177:13 198:11
legislatively 176:4      189:10 198:24         31:3 47:7             289:2                210:14,15 224:6
legislators 18:23        214:24 215:5       litigated 111:5        locals 61:11,24        238:16,16 248:6
Legislature 10:22        233:5 284:8        little 10:25 13:18       63:1 66:14           260:15 268:14
  14:9 16:20 17:11    level 191:21             14:24 28:2 32:15      100:23,25 103:12     269:1 284:3
  18:12,17 21:14         218:10 259:10         36:12 62:3 70:1       110:6,17 126:24    lookin 214:9
  27:7 28:5,7            271:16 279:22         211:24 218:17         209:10 223:24      looking 10:10
  30:11 35:6 45:9        280:6,12              219:10 225:6          256:24,25 271:11     14:17 20:7 41:13
  45:16 46:1,15,20    leveled 201:17           240:10 254:17         271:20               82:1 197:24
  46:24 76:2          levels 68:11 69:15       258:14 271:3        lock 75:3              214:8 253:21,23
legitimacy 270:1      Lictchenstein(s...       287:20              locked 75:5            254:11 266:23
legitimate 121:6         128:12             live 210:12 232:15     Lockhart 51:14       looks 26:14 63:14
  127:25              lie 7:23 283:7           252:23              lockout 250:12         78:25 213:2,5
legitimately          lies 257:12 258:12    lived 276:20           logical 107:23         272:22
  133:18              life 91:20 210:13     lives 69:23 70:9,18    Loida 236:11         loopholes 222:3
Leiva 218:23             220:25 245:4,20       205:24 249:1        London 12:23         Lopez 205:9
length 22:21             251:24 260:9,11       287:19              long 64:21 84:13     Lorie 228:20
  257:21,21              262:12 276:21      Liz 208:7                93:2 111:17        Los 9:24 11:3 12:2
Leon 3:16 128:13         289:14             LLP 3:7                  138:22 211:16        12:4,8 24:22
Lerner 142:15,16      light 117:21          LMP 236:15               233:16 247:25        61:10 277:16
  144:16,23              260:17,23          lobby 35:5,7 96:19       251:18 273:2       lose 216:10,14
Lervada 236:7         liked 227:5           lobbying 19:16           277:5 282:21         247:24,24
Leslie 224:23         likes 225:18,19          212:3                 287:5 290:18       losing 292:13,14
  227:15              limit 119:8           lobbyist 35:3,5,8        292:22             loss 46:24 263:20
letter 86:4 99:1,4    limitation 164:11        44:10               longer 73:17         lost 13:7 112:10
  100:1,5 106:23      limited 32:13         lobbyists 14:9           89:24 93:10          208:25 249:24,25
  107:2 123:8,12         118:4 224:12          19:2                  111:8,14 217:19      253:18,20 268:19
  123:20,21,25        Limy 240:19           local 57:5,6,7,8,20      254:25               268:22
  124:13,17,20        Linda 205:9              60:10 61:6,9        longstanding         lot 41:3 42:20 53:2
  127:10,15 128:10       243:10 262:7          62:4,6,6,12,14,19     67:12 131:5          58:8 65:24 78:6
  128:18 129:1,18     line 72:7 73:21          62:20,21,22,25        263:9                80:25 132:8
  129:20 130:11,12       74:14 105:9,19        63:16,20 64:11      long-term 73:25        174:25 176:14,14
  132:17,19 133:14       108:24 113:12         64:14,14 69:8,9       135:22 136:11,21     188:17 202:10
  134:11,13,14,19        167:23 189:25         96:4 105:13           136:25 137:2         217:16,17 232:8
  134:21 139:23,24       260:10,11 266:8       107:18 109:14         144:7 155:12         234:8 238:17,21
  139:25 140:1,5,6       275:7                 110:11,11 121:13    look 8:3 9:2 20:14     239:7,8 248:6
  141:18 143:15       lined 71:24 74:4,7       124:2 125:2,24        20:16 37:11 62:9     249:1 254:8
  146:1 160:21           76:14                 126:19 130:23         63:14 87:10 98:2     260:18 263:14
  199:3 232:17        lines 46:18 110:22       131:4 133:13          101:15 154:5         264:8 273:3
letters 134:10           140:25                134:17 135:1          158:14,20,24       lots 285:7
  137:10 229:3        link 197:25 201:8        136:11,23 137:1       159:5 174:18       louder 7:19
  271:13              linked 17:4,23           137:3 144:22          180:16 186:12      Louisiana 227:2
Lettie 243:13            141:18 284:20         147:1,24 148:4        194:16 213:4       love 215:22 250:6
                                                                                     Page 318

  279:10,13 287:25   mama 258:20         53:4,13,18,22       294:14,23           269:23 270:12,13
loves 256:8          man 230:24          54:4,7,11,14,17    Martha 240:17       meaning 186:4
low 269:1             235:13,17,17       54:21 55:4,12       242:13              191:21 194:23
lower 21:3 198:19     258:9              56:12 61:16 70:4   Martin 4:17 7:8     means 17:10
lowest 67:19         management          70:11 100:18        202:14,19 203:1     29:14 39:20
loyalty 291:14        90:9 221:22        104:13,24 105:6     203:12,16           60:23 79:9 85:22
Lu 234:17             236:16 245:4       105:7,25 108:10    Martinez 240:14      105:16 142:3
lucky 236:13          249:23 250:4,4     108:13 109:18       251:3               156:20 161:8
Luke's 88:7          management's        111:8,12,17,19     Marty 236:9          163:10 172:22
  281:20 282:10       95:15              111:22 112:1,12     240:25              185:22 190:4
Luna 226:14          manager 31:23       114:2,9,13,21      Mary 92:6 224:20     192:24 193:3,5,6
lunch 111:20          262:11 289:4       115:1,3,10,15       226:20 229:21       193:7,7 258:22
LVN 266:19           mandated 136:12     116:15 117:3,6     Maryann 1:24        meant 19:16 28:8
Lyn 234:15           manipulated         118:2,3,20          2:21 295:3,23       68:9
L.A 12:3 146:16       229:8              119:12 120:1,9      296:3,16           measure 18:15
  147:16             Mansfield 229:18    121:2,8,19 122:2   Masachusetts         28:15 29:7,8,15
                     Manteca 230:3       123:2 129:6,14      3:22                29:16 31:14,19
        M            march 30:18,25      130:16 131:20      Massachusetts        47:18 48:1
M 218:23              48:4 84:6 87:22    132:7,14,23         10:11 14:19,20      199:18
Maccas 228:18         123:8 124:9        133:3,8,16,19,20   Master 66:9         measures 31:8
MacDonald             127:2 160:21       134:2,6,9 135:7    Masters 12:24       mediate 229:11
 234:17               161:3,12 163:11    135:14,16 137:16   Master's 56:8       medical 12:3,4
Mack 234:20           163:11 164:4       137:25 138:15,20   Mateo 1:8 2:20,21    28:10 46:24 84:5
Mafia 288:2           171:2,4,8,16,16    139:3,9 140:4,10   material 139:25      87:12,12 89:14
magazine 5:4,5,6      171:21 172:3,6     140:18 141:4       materials 14:18      94:16,19 95:8
 156:10,13,15,25      172:14,17 173:12   142:4,25 143:5      14:22 29:10,11      96:9 205:15
 157:11,19 160:1      173:20 176:22      143:11,23 144:12   maternity 262:19     207:6 243:18
 163:24 172:21        226:8              145:6,11,14,16     math 92:20 262:9     248:21 265:1
magazines 157:8      Marengo 3:13        145:21 147:4,11    matter 1:1 2:1       266:16 276:14,14
 157:20 158:11,15    Maria 218:23        148:15 151:2        31:25 46:3,5        282:9 288:10
 158:19,20,22         229:18,23          157:12 158:1        117:21 119:2        290:6
 159:6,12,19         Marie 207:5         159:15 165:6,8      138:24 150:7,11    medical-legal
mailboxes 209:7      Marin 256:3         167:22 169:9        266:6 284:14,18     258:7
mailed 29:13         Mariner 67:10       179:11 181:24       291:22             mediocre 221:15
mailing 278:19        288:25             182:3 184:12       matters 6:22         221:16 255:15
mailings 244:12      Mariner's 288:25    190:1,24 195:8      122:8 149:19       meet 51:16
main 253:18          mark 24:22 48:22    195:11 202:1,7     Matthews 63:21      meeting 21:7,9,12
 274:21               262:18 284:22      202:16,20,22       mature 96:11         22:10 77:24 78:2
major 47:10 73:7     marked 37:12        204:2,6,13,25      mayhem 276:24        79:8 91:1 150:14
 270:17               49:7,13 55:5       209:22 210:21      May(sic) 205:7       150:20,20,23
majority 23:9         63:15 158:9        211:7 213:18       Mazza 234:14         151:6,16 152:3,8
making 8:6 29:2      Market 3:9          214:7 222:22       mean 15:16 27:6      152:25 153:4,13
 53:9,10 65:20       marking 158:1       224:7 230:8         34:4 48:14 60:21    153:15,16,20,20
 95:18 108:11        Marla 226:17        233:14 234:23       67:14 92:23 93:1    154:9 157:22
 126:16 132:25       Marlowe 227:17      236:1 239:25        93:9 108:5 111:5    161:25 162:5,19
 149:17 165:11       Marquez 243:13      245:8 251:16        112:19 119:14       162:21 164:3
 210:21 216:12       married 264:6       252:9 260:1,2,8     120:7,15,20         174:23 175:3
 223:14,15 230:21    Marshall 3:3 6:4    261:15 269:11       142:22 153:7        178:18 183:1,17
 242:18 244:23        7:17,19,22 8:1,4   270:3,6,8 271:5     159:12 162:20       183:22 184:2
 292:13               9:9 20:20 34:16    272:8 273:16        189:11 197:1,22     191:19 192:12,21
malfeasance           34:20 42:19,22     275:4 291:7         209:17 210:1,14     193:1,11,14
 79:22 277:24         43:4 45:12 49:25   292:25 293:7,14     228:3 231:15        194:18 196:8,10
malls 278:12          50:9 52:10,13,19   293:19 294:1,6      256:8 260:17        201:13 213:7
                                                                                    Page 319

 232:23 262:23      126:2,2,2,4,7,11    288:5 289:7,12      266:16 283:17       170:1 174:6,8,9
 263:11             126:18,18 130:1     289:21,23          message 128:3        174:14 175:8,8
meetings 57:9       131:16 135:12,22   membership           281:17 288:5        175:17,19,21,21
 62:8,9 73:5        136:12 137:2,4      85:22 110:12       messing 207:14       175:22 176:10,12
 161:21 162:9,11    144:7 146:13,23     126:16,22 160:2    met 57:8 218:15      176:18,22 177:22
 163:16,23 164:9    146:25 148:25       162:15,16 164:2     257:6 272:15        177:24 183:3,10
 191:25 196:15      150:15 151:7        164:5,6,12,18      Methodist 283:21     184:3,18 185:5
 241:14 254:23      152:13,18,24        165:1 166:6        Mexico 271:19        185:12,14,19,19
 265:24             156:16,20,25        168:19 169:4,15    me-too 287:7         185:22,23,24
Mel 265:1           161:6,12,22,23      172:22 176:12,21   mic 8:21 224:18      186:4,6,6,10,22
member 4:19         162:10 165:1        182:20 185:10       227:14 229:16       186:23 187:2,3,4
 24:21 40:10 60:7   173:1 174:6         200:5,12 219:13     271:7               187:12,15 188:9
 60:22 80:19        180:14,20,22        288:21 289:4,19    Michael 128:12       189:12 190:16
 173:25 180:1       182:2,5,8 183:5    memberships          211:5 243:12        191:22 192:15
 182:23 184:3,18    185:6 186:17,20     126:23              246:14 251:9        193:18 194:6,7
 193:19 196:10      187:4,7,11 190:5   member's 125:11      286:2               195:20 196:4,9
 202:2 204:17       190:16,18,22        146:24             Michelle 7:21        207:16,17 208:1
 205:12,16 207:7    191:1,10,11,18     member-driven        222:20              208:23 229:5
 208:20 211:8,12    191:20,24 192:4     206:20 262:4       Micheula 224:22      233:24 241:4
 212:23 215:6       192:10,13,20,24    memorandum          Michigan 12:22       250:12 253:4
 216:18,18 219:23   193:4,9,16          152:11              147:24 276:20,21    277:18
 220:20 225:1,2     196:12 202:8       Memorial 253:13     microphone          Millions 82:11
 226:24 227:23      204:12 207:9,9     memories 277:5,6     202:15 203:17      mind 153:25
 236:13 241:1       207:12 209:1,7     memory 9:21          204:8,20,21         154:22 155:11,17
 246:15 249:21,22   209:11 211:23       174:17              205:5 208:5         155:23
 250:1,9 252:5,15   212:5,17 213:8,9   mental 273:21        217:21 254:19      minds 33:19
 254:13 255:8       213:12,13 214:6    mention 159:7       mid 69:16 71:20      257:12
 256:4 262:15       214:19,20 215:9     160:16,23          midday 22:7         minimal 141:8
 263:4,5,10         215:10,12,14       mentioned 6:9       middle 92:6         minimum 217:14
 264:10 265:14      216:20 217:10,12    11:5 13:11 32:12    112:17 116:12       217:15 252:21
 266:5,9 268:2      218:4,6 220:7,9     44:6 47:3 54:12     150:20 208:16      Minnesota 244:21
 271:11 273:19      220:10,13,23        97:14 113:17        211:18 281:22      minute 55:12
 274:1 279:14,15    221:13 224:10,14    122:5 162:16       midsentence          167:5 239:14
 279:18,25 280:2    225:21 226:7,9      164:17 165:16,18    121:25              275:4
 284:23 287:4       230:13,17 232:9     212:2 291:17       midst 125:14        minutes 9:4 14:2
 288:25 289:12      232:12 237:16       292:15,24          Mike 110:11          54:3,4 111:16,18
members 7:9,15      239:15 241:10      Mercy 94:16,18      Mildred 247:7        113:6,9 138:19
 7:20 8:2 22:6,13   251:20,23 253:5    merge 62:12         miles 95:7,17        138:22,24 139:3
 22:13 45:5 55:2    253:6,19 254:1,1   merged 61:11        militant 66:25       141:24 144:11
 58:10 59:5 60:10   255:21 256:22,25    62:14 179:16       Miller 249:20,20     152:25 161:16,23
 60:12,14,24        257:6,9,25          181:8              million 65:6,8,16    162:1,6,12,19,23
 62:21,22 63:2,18   258:14,15,16,18    merger 62:4,7,9      65:16 78:16         163:5,6,12,19,22
 64:1,5 66:2,10     260:5 262:16        62:21,21,22,25      83:21 110:13        163:23 164:17
 66:16,17 67:2      264:14,23 265:9     63:1,3,13 64:2      116:8 122:19        166:6 178:5
 69:24 70:9,18      265:13,15,16,16     64:11 179:24        125:6 129:23        192:25 193:9,12
 73:22 79:5 80:11   265:20,23 268:10    180:2 193:25        146:23 150:7,12     194:10,12,16,17
 80:14 86:17        270:15 271:10,14    194:2               150:14,22 151:7     202:13 204:11,18
 90:12,17,19,22     271:14 273:22      merit 87:16,17,24    151:17 152:13,18    207:2 232:13,22
 91:4,7,11,19       275:1,2 277:12      88:5                152:21,23 153:1     233:10 258:8,11
 92:20 93:3,22      277:14,18,19       merits 104:10        153:10 164:3,23    misappropriation
 94:9 98:4 99:19    278:6,16 280:7      151:17              165:13 166:2,11     209:6
 109:15 113:4       282:21,23 284:11   Merrill 243:11       167:9 168:12       misconduct
 114:4 125:19       286:15,25 288:1    mess 250:23          169:3,14,23         146:21
                                                                                      Page 320

misgivings 199:22    217:7 221:2         208:16,18          M/S/P 79:2            100:12 212:19
misplaced 112:7      229:4 232:9        move 32:15 33:13     163:10               270:21,22
misrepresented       237:7 241:5         43:2 109:14                             national 13:9
 117:23              244:13 249:10       135:21,24 143:11            N            26:23 101:19
missile 211:16       252:3 253:8         143:12 146:12      N 3:1 4:1 5:1         128:18 280:6
missing 130:2        257:15 264:11,15    147:4 150:14,21    nail 279:5           nature 28:11
mission 85:21        264:18,20 275:22    152:13,23 153:1    name 8:18,20,23       259:12
 138:4               275:22,23,23        153:9 169:2,14       10:16,17 18:21     Navalman 260:9
misstates 169:17     276:1,9,10,10       170:2 174:5          34:21 55:9,23      near 14:16
 174:7               285:20,23 288:13    175:7 176:10         122:21 156:12      nearly 129:23
mistake 262:11       289:7 292:13,13     177:22 186:5         163:13 203:9,10    near-universal
mistaken 278:22     monies 85:23         190:15 206:9,11      203:11 205:14       10:8,13
 279:4               167:3 169:3         222:7 233:7          207:5 208:12       necessarily 15:16
misunderstood        184:3 189:13        240:10 245:23        211:7 212:22        187:9,16 291:22
 149:15 188:3        190:16 192:15       257:17 263:23        213:25 215:16,20   necessary 90:16
misuse 194:25        283:2              moved 174:14,16       216:17 219:2,9      166:1 266:24
 274:10             Monique 208:8,20     174:18 175:9,12      220:16 221:6        267:2
misused 126:11      monitor 144:13,16    175:13,14,16,17      222:23 223:22      need 6:14 17:14
Mithilesh 229:19     144:18              175:20 176:18,22     224:25 226:20       18:11 30:12
 233:15             monitored 13:25      177:24 191:23        227:21 228:24       39:20,23 52:23
mix 119:4           monitors 86:23       192:15 263:3         230:3,7 231:1,25    53:1 61:21 105:5
MJC 92:6             144:21,24          movement 56:21        233:14,14 234:22    111:10 112:15,25
model 79:25 126:1   Montenegro           56:25 57:17 58:1     238:6 240:25        113:22 114:11
models 225:5         229:23              59:11,18 60:2        241:20 242:13       117:10 120:14
Modesto 236:14      Monterey 253:15      66:13,20,23          243:16 244:5        122:8 139:1,3
 241:1 247:13       month 67:10          97:17,24 98:1,4      246:14 248:2,20     140:16 189:1,21
modify 89:23         107:11 210:6        100:7 128:1,8        249:20 251:12,13    195:13 208:24
mom 236:20 273:7    months 30:2 31:4     129:3 130:14         252:7 253:12        209:3,10 219:6
 290:6               32:7 71:8 90:5      142:14 144:5         254:4 255:6,7       220:1 221:1
moment 52:7          108:8 170:8,13      197:20 212:13        256:2,16 258:6      241:16,24 245:9
 123:22 162:13       170:19 174:23       214:8,12 246:23      260:2 262:7         245:15 246:22
 235:20              211:18 289:17       256:20 257:23        264:4 265:1         247:22 256:13
Monday 26:3         mood 112:18          258:3 260:22         266:13 267:22       257:1 261:19,24
money 18:3 27:9     morning 4:3 6:4      262:13 270:23        272:9 273:13,16     267:5,9 272:18
 28:4,7 48:18        34:21 55:8          274:24 281:11        275:10 276:13       275:8 280:5
 77:11,12,14         113:18 148:20       285:4 287:8,9,15     278:3 279:8         294:12
 79:13 85:6,7        202:15 203:16       288:22               280:15 281:19      needed 23:6,9
 130:2 131:1,13      264:6 279:11       movie 252:12          282:8 283:12,20     24:3,12 51:18
 131:15 146:23      MORRISON 3:7         284:12               285:11 286:1        103:14 206:15
 150:15 152:13,18   mortgage 216:12     moving 46:1,14,20     287:23 288:20       227:5 235:1
 152:24 155:16      mother 57:21         46:24 151:7,17       290:5               238:10 242:3
 166:24 169:19       258:19              183:10 215:13      named 33:2 40:7       267:8
 171:6,25 172:9     mother-fuckers      MS.COLLADO            144:23             needs 105:22
 174:6,7,16 175:9    7:11                212:22             names 34:10           244:17,18 245:1
 175:12,13,14,23    motion 154:3,11     Mt 219:11             107:1 204:20        294:9
 184:18 185:6        163:10,15 169:22   multiple 71:6         251:13 284:19      negative 128:6
 187:5,12 188:9      169:24,25 185:11   multi-billion         285:8              negativity 281:13
 188:13 193:19       187:1,1             75:14              Nancy 247:8,10       negligence 226:10
 194:25 195:1       motivation 120:25   mundane 58:19       narrow 129:25        negotiate 97:5
 196:10 200:3,10    motivators 206:18   murder 276:24       narrowing 42:11      negotiated 92:8
 205:19 206:5,6     motive 117:15        277:3              narrowly 20:6        negotiating 93:5
 206:23 207:16      motives 147:6       mute 286:17         Nasbat 275:10        negotiations 58:8
 208:23,25 210:19   mouth 205:20         287:11             nation 12:16 60:3     58:17,18 81:4
                                                                                        Page 321

  84:4 86:12 89:11    260:5 287:13,18     72:5,12 74:22        128:22,25 130:12     157:24 180:17
  89:19 91:14 94:1   noble 164:22         75:3 81:2 92:15      132:24 133:6,7,9     181:3 186:11
  287:6              nominate 180:3       97:9 98:23 99:25     137:20,23,23         207:3
negotiators          nomination 116:3     118:4 123:13,19      139:19,21 142:23   officers 60:15
  239:22              122:15              126:25 142:24        143:8,17,19          62:13 63:16
neighborhood         non-issue 105:15     153:21 154:3         144:6,9 145:3        103:22 107:16
  172:11             non-money 28:14      158:2,3 163:3        146:18 150:24        110:4,15,25
neighbors 212:5      non-officers         267:9 279:19         151:1,2              126:2,8,18
neither 17:24         191:22             numbered 158:12     objections 52:25       129:25 132:18
Nelson 128:12        non-profit 78:17     163:6                53:9,19,22           148:3 149:1,8,9
  258:6,6 285:25      152:19 153:10      numbers 47:19,19      108:22 118:18        149:18 150:17
  286:2               274:7               62:23 126:23         134:8 295:9          152:12 169:2
nepotistic 274:15    non-union 70:22      258:25             objective 130:1        179:22 180:23
net 129:24 210:23    Norm 128:11         Nunes 285:11,11     observe 134:3          181:1 183:11
network 268:6,18     normal 30:3         Nunez 10:17,18,19     144:21 270:1         187:21 191:15
networks 268:15      North 267:23         15:6 16:3 25:10    observed 140:23        194:10,13,18,22
never 16:10,10       Northern 149:11      37:1,8,23 103:11   observer 269:21        195:12 197:4
  39:13 79:25         248:5 262:8         253:12             observers 19:8         240:2 292:8
  87:16 88:14         263:13             Nunez's 25:22         270:4 293:3        offices 226:22
  172:16 173:5       nose 219:6          nurse 66:6 207:5    obtain 32:2 71:19    official 25:22
  185:14 200:17      note 53:23,23        208:13 289:1         171:6                26:10 35:17
  209:17 224:15       147:12 292:6       nursing 67:11       obtained 195:19        40:12 44:7
  240:2 249:16       notebook 154:6       69:19 73:20        obvious 40:18          160:24 193:9
  274:22 289:22      notes 257:2 277:8    74:21 75:4 84:7    obviously 35:16        196:17
new 10:11 14:20       286:10 295:13       95:23 96:1,6,8       95:20 154:19       officially 16:18
  16:5 18:5 26:23    notice 74:6 87:23    96:10,17,21 97:2     199:22 202:10      officials 14:8
  48:22 62:10         89:6 90:6 103:22    97:4,10 206:21     occasion 169:2         58:24 83:11
  87:20 96:21         141:12 144:19       261:9              Occasionally           263:16
  99:17 106:24        148:7,10 196:11    nuts 252:20           22:24              official's 147:18
  107:1,2,11 110:3   noticed 75:5        N.W 3:17,22         occasions 169:13     oftentimes 177:15
  110:4,8 113:1       255:11                                 occupation 9:22      oh 36:14 46:6 79:1
  135:2 146:13       notified 144:20             O           occupational           181:5 182:13
  152:19 154:22      notify 176:12       Oakland 82:25         203:13               197:14 230:2
  177:21 192:14,16   notifying 185:9      149:8,18 228:25    occurred 174:23      Ohio 56:7,17
  209:16 223:20       232:9               229:25 234:22      October 103:8        okay 7:8,20 10:24
  227:2 234:4        notion 109:5         252:24 261:8         104:1 106:13,14      16:25 21:19
  250:22 271:19      notions 122:20       264:12 265:9         106:25 170:23        23:11 25:17 49:9
  272:19             not-so-good          275:11               171:2                49:12 55:23
newly 78:17           238:13,14          oath 8:13 55:18     Ode 230:11             81:13,14 84:25
  179:15 181:8       November 17:8,22     203:4 295:7        offended 211:11        87:5 91:22 98:25
news 277:15,16        17:23 27:4 29:5    Obama 256:13          227:25 283:16,17     108:24 110:1,1
  282:3               29:7 31:2 32:3      271:24 290:25      offer 99:23            115:14 117:17
newspaper 41:22       48:4,8,20 103:8     294:12             offered 53:1 259:5     123:7 124:16
  75:6 102:5,24       107:3 112:17       object 102:10,16    office 34:8 37:17      127:9 128:21
  109:1,3,8 277:8     113:2 170:22        139:12 143:21        40:13 44:9,11        130:9 135:7
newspapers           no-layoff 69:3       147:12 159:11        57:14 106:19         139:1 147:11,15
  102:12 107:16      number 5:3 6:14      206:25               107:7 180:9          149:16,24 150:9
  108:5               13:4 15:5,9        objected 140:25       209:5 245:2,18       151:23 153:17
nice 207:23           16:11 17:15,15      144:24               279:23 289:4         154:7,21 157:17
nickel 262:16         18:8,8 19:19       objecting 131:19    officer 3:2 59:3,7     158:18 159:22
night 214:23 215:4    28:12 31:4 44:14   objection 42:25       63:19 69:25          160:14 162:13,24
  279:20              46:4 48:24 62:9     107:20 110:21        102:3 117:9          163:14 164:11
nine 45:7,14,17       64:15 70:6,8        116:1 118:6          130:23 138:7         168:9,21 170:2
                                                                                         Page 322

  170:11 173:10       226:19 227:20        35:13,23 188:6     ORIN 3:20             181:2 231:19,20
  174:19,20 177:17    228:23 230:6,25    opposing 157:24      Orleans 227:2         231:20
  178:2,8,23 179:5    231:24 233:12        180:8 225:23       Orline 251:5         packing 174:25
  180:12 181:6,18     234:21 236:24      opposite 101:1       Ortiz 247:5          page 4:2,6,8,12,14
  181:23 182:3,4      238:4 240:24         141:7              ostracized 289:10     20:17,23,25 21:1
  182:11 184:10       241:19 242:12      opposition 225:9     ought 157:3 224:3     21:2 25:19,20
  185:17 190:2,11     243:15 244:4       oppressing           outcome 143:25        37:12 38:8,9,23
  192:23 193:8        246:13 247:11        235:13,14            281:23              40:5 44:1 55:3
  197:10,17 198:2     248:1,19 249:19    Optical 286:3        outhouse 268:6        63:15 78:15,25
  198:17,20,22        250:8 251:11       orchestrated         outlined 152:8        87:10,14 88:7
  199:1,6 202:7       252:6 253:11         287:1              outlines 13:6         89:20 129:21
  203:15 204:16       254:3 256:1,15     order 7:4,24 17:3    outreach 83:3,5       163:7 181:16
  208:2 218:11        258:5 261:6          29:7,15,15 104:5   outset 291:17         198:2,3,3,18,22
  222:1 224:17        262:6 264:2,24       104:7,11 107:23      292:16             pages 63:14 89:13
  225:2,4,6,7,8,15    266:12 267:21        113:9,11,24        outside 23:16         296:5
  225:22,24,25        269:8 273:12         122:7 133:21         56:16 71:6 93:17   paid 68:5 69:11
  226:4,7,10 235:4    276:12 278:2         138:15 139:2         129:24 149:9        71:12 122:24
  235:12 236:13       279:7 280:14         252:7 292:22         151:8 152:14        147:17 148:4
  241:17 244:15       281:18 282:7       orderly 6:25           183:3 277:19        183:4 209:24
  245:13 247:12       283:11,19 285:10     113:12 117:11      outsiders 223:18      210:1 240:4
  250:5,12,25         285:24 287:22        122:8 138:16       outstanding           249:13 252:3
  273:15 274:17       288:16 290:4       ordinary 181:3         130:24,25           259:6
  277:16 288:7       oOoo 255:5          organization         overflow 209:7       painstakingly-p...
  293:24 294:3,7     open 100:5 114:24     12:15 32:18 33:2   overhead 82:11        26:4
  294:23              127:10 161:6         33:3 45:3 77:22    overruled 151:2,3    Pakmcas 227:19
Oklahoma 258:20       221:12,23 240:8      100:23 177:11      overseas 211:18      Pam 205:6,14
old 110:8 218:13      266:21 280:7         188:3,7,7,8          211:20              211:4 215:16,20
  227:9 258:20        281:22               193:13 271:12      oversee 58:5         Pamela 219:2
  288:23             opened 104:19         279:22 289:22      overwhelmingly        243:8
oldest 61:7           193:17             organizations          63:2               pamphlet 29:10
Omnes 288:17,20      openess 189:24        19:16,19 40:2,3    owing 116:7           29:12
once 105:17          opening 108:25        45:23 62:24 65:1     122:19             Pandora 239:12
  214:12,19 215:8     239:11 247:14        116:6 122:17       owned 147:17         Pandora's 239:11
  217:2 221:8        openly 215:7        organize 69:17       owner 283:4          Panseco 251:7
  227:4 250:24       openness 164:25       101:22 102:22      Ozier 208:8,20,20    Panthers 83:12
  256:19 259:6,17    opens 77:16           113:23 213:16      O'Brian 240:18       paper 6:19 40:19
ones 47:3 69:22      operating 125:2       248:25 271:15      o'clock 279:20        81:18 83:1 84:9
  149:10,11 171:23    215:17,21          organized 19:15        288:17              152:17,23 153:4
  207:10 236:13      operation 209:3       19:17 71:8         O'Connor 238:7        153:7 177:4
  238:13,13,14       opinion 27:13         127:17,25 226:7      238:15 285:12      papers 173:11
  244:22 250:24       89:16 97:10          271:11             O.K 92:6              177:12,15
  254:2               127:21 156:7       organizer 130:25                          paperwork 48:7
only-a-few 43:19      243:18 259:23        203:14 211:10               P            48:18
on-going 83:16,16    opinions 228:3        220:3 246:15,16    P 1:24 2:21 3:1,1    parade 242:21
  84:14 95:25        opportunity 25:7      276:22 289:12        295:3,23 296:3     paragraph 26:1,9
oOo 6:3 205:11,13     26:20,21 33:15     organizers 238:9       296:16              38:10,25 40:6
  207:4 208:11,19     33:20 56:23        organizing 58:7      Pacific 207:6         101:16 129:21
  209:14 211:6        75:11,15 80:20       64:22 71:4,6         243:17 282:9        163:9,9 198:23
  212:21 213:24       115:8 119:10         89:4,21 238:17     pack 188:16          paragraphs 99:11
  215:15 216:16       180:14,20 205:1      238:18 277:10        247:21              127:20 198:24
  218:2 219:1,8       249:5 262:19       original 21:21       package 17:1 18:1    parcel 98:13
  220:15 221:5       oppose 36:1           296:6                25:19 30:10        Pardon 49:6,10
  222:21 224:24      opposed 12:11       origins 61:6           103:10,14 179:19    82:16 85:10
                                                                                         Page 323

 153:14               137:5 257:15        payments 110:7        28:12 32:9 33:21    287:12,13,18
parents 260:6        passage 17:7 22:1     110:19 216:12        33:22 40:19,25      289:19
pariah 286:24        passed 29:23,25      pays 217:10 268:2     41:3,7 42:1,4,6    percipient 195:3
Park 227:22 260:3     30:1 84:23,23       Peacock 267:22        42:10 43:17,19     perfect 75:10
part 52:15 58:1       85:5 136:8,18        267:22               43:22 52:4 55:7     256:22
 64:7 65:9 66:2       169:22 185:11       Pebble 253:15         59:8 63:12 64:7    perfectly 121:2,6
 67:25 76:21          187:1 286:9         PEF 104:10,11         64:10 73:11 75:7    188:19
 77:21 81:24         passes 163:10         109:10 111:7         80:10 86:24        performance
 82:13 83:9 89:24    passing 27:12         116:22 117:4         87:17 95:18         87:18 125:12
 92:12 96:4 98:13     287:16               118:7,22 119:2       113:8,9,12         performed 20:25
 98:14 101:23        passion 289:22        129:4 132:12         141:11,21 149:4     92:12
 103:14 105:19       Pataski 247:4         134:24 135:2,6,7     149:10 179:19,24   performer 125:7
 137:23 154:19        248:2,3              138:1,6 145:7,12     180:4 188:10       period 17:16 27:5
 166:21 177:15       Path(sic) 223:22      145:20,22,22         189:4 191:15        48:11,11 106:13
 179:23 181:1,7      patient 75:7 167:1    147:7,8 150:15       194:5 195:18        148:1 157:21
 187:20 191:3         263:24               151:25 152:5,9       197:9 198:13        160:3,8,10 161:2
 197:22 221:19,20    patients 76:7,22      153:2,19 154:9       201:2 203:22        161:12 171:8
 238:18,19 239:3      77:2 78:3,18,21      157:1,14 159:18      204:5,21,22        periodically 59:20
 250:7 255:10         79:9 80:4,15,21      162:16,19,19         205:2,4 206:6,7     59:23
 262:14 278:4         83:6,21 85:6,13      164:17,19,20,21      206:7,9,15 208:4   perjury 295:17
 280:17 282:11        85:23 86:5 105:9     170:3,4,5,9,14,15    208:5 209:5,15      296:8
 287:25 288:14        105:18,20 108:8      170:16,19,20,25      209:19,24 210:19   Permanente
 293:6,8,19           108:18 116:19,24     171:2,7,14,17,20     210:24 213:1        226:22 262:9
partial 14:19         123:16 124:10,22     171:25 172:2,13      216:1,1,2 217:4     265:2 273:18
participants 27:16    127:5 128:16         172:16,23,24,25      217:20 218:11,19    276:15
 29:1 30:9 32:21      129:8,18 130:18      173:5,11,13,19       219:6,20 221:25    permissible
 33:16,23 34:7        132:1,22 154:15      174:3,6,10,10,22     224:1,17 226:6      141:23
 140:3                154:18 157:2         175:8 176:10,10      226:12 227:13      permit 7:4
participate 60:6      158:23 159:8         177:7,10,16          228:14 229:15      person 40:7,21
 116:7 122:18         160:17,23 161:13     178:5,5,13,21,24     230:15 232:25       42:12 62:15 66:3
participating         168:7,23 169:25      178:25 183:3         233:13,21 234:11    79:1 131:13
 34:14 126:19         194:18 220:25        193:16 195:19,19     235:7,14,16,18      142:9 204:9
particular 40:1,1     224:13 236:17        195:21 232:25        235:22 236:4        233:20 244:17,17
 50:20,21 51:19       249:15,17,18         242:16 264:9         237:3,7,8,15        246:2 251:5
 51:20 61:3 68:22     252:25 272:23,24     274:5 283:24         238:1 239:9,20      259:15 265:11
 133:13               275:13,22 276:2     Peluso 240:16         239:21 240:3,12     266:9 268:16
particularly 11:7     276:4               penalty 295:17        241:22,25 242:16    286:20
 67:3 73:14 291:8    Patrice 228:21        296:8                243:5 245:23       personal 31:7
 292:6               pattern 72:19,23     pending 158:10        247:1,14 251:1      102:9,11 140:11
parties 96:14         72:24,25 73:1       Pennsylvania          253:24 259:18       205:24 211:15
 212:4 295:15        Paul 218:22           10:12 14:20          261:22 263:14,19    254:20 274:11
partners 58:24        222:23 264:6         56:23 57:2           263:22,25 266:23    284:2 292:6
 77:12,20 81:7        289:3,6,9           penny 252:19          267:18 270:9       personally 26:17
 83:9,15             pay 25:25 82:10       264:21               273:3 275:7         68:25 238:10,23
parts 119:25          87:16,17,18,24      pension 68:7 69:9     277:9,12 282:16     284:16
 185:16               88:5,11,12,14        70:24 71:14          285:7,14 290:14    perspective 65:17
party 256:9           237:8,10,17,17       94:24 236:19         291:17              76:14 92:17 94:6
part-time 88:11       242:7 243:1         peon 258:14          peoples 245:10,15    98:12 136:21
 88:16 221:25         246:1,21 262:20     people 6:6,12,15     people's 246:6      pertain 50:8
Pasadena 3:13         277:18 282:25        14:8,9,9,10,23      Perata 37:2,5       petitions 31:1
pass 23:6,23 31:19    292:12               15:10 17:10 19:7    percent 67:21       petrified 289:15
 36:22 38:18 39:7    paying 209:19,24      20:3,4 23:10,17      92:15,19,24 93:8   phase 292:23
 39:10 44:12 51:9     239:16,17            23:25 24:14          93:21 129:24        294:20
                                                                                           Page 324

Phillip 229:22       planning 107:9        214:4,18,18            178:10,12 266:7    preceded 20:22
philosophy 64:25       211:22              215:12 220:19        positive 23:9        precise 294:21
  148:21 149:3       plans 11:20 34:24     224:2 225:22,24      possible 8:22        prefer 40:16,21
  164:25 185:1         35:3,13,15,20       249:16 252:18          10:16 32:2 85:22     97:7 292:8
  190:3,3              70:25 146:14       pointed 124:25          86:18 123:21       preliminary 52:21
phlebotomist           236:19             points 101:1            124:10,21 129:19   premise 189:17
  219:10 220:17      played 97:9           113:16 174:16          130:3 132:21       prepared 89:20
phone 126:16         playing 83:4         police 212:9            150:11 168:7         152:7 257:1
  205:17 229:3       pleadings 213:19     policies 10:6           236:23             prescription
  279:18             Pleasanton           policy 11:3,18        possibly 130:13        182:16
phone-banking          273:19              12:6,9 13:3,5,9        166:23             presence 86:23
  267:2              please 8:19 20:16     13:22 14:13 15:2     post 197:21 198:7    present 8:24
photographs            37:10,14 43:5,24    20:6,8 41:14           198:15,21 200:20     119:19 160:3,9
  112:4                49:23 55:9,23       101:1 177:12           201:15 261:23        199:7
Phyllis 234:16         61:19,22 70:15      235:11               posted 26:10         presentation 8:7
Ph.D 13:1 56:10        78:14 81:9 82:15   political 12:11,17      197:6 201:1          114:7
  56:14,20             82:17 84:24 89:8    12:21 19:24          posting 178:24       presented 75:15
picketed 226:9         91:21 98:22         23:21 25:14 44:9       201:1                119:14,18
picking 190:6          101:7,25 103:19     44:11 64:22 75:2     postponed 22:25      preserve 115:7
picture 281:8          106:20 112:9        85:15 100:24           256:12             preserving 218:16
picture-taking         115:17 123:4        126:8,11 127:16      postponement         presidency 179:15
  6:6                  128:20 130:8        131:5,6 206:3          22:25              president 1:2 2:2
piece 18:1 45:18       137:15 190:13       208:21 211:9         post-merger            3:15 8:6 26:24
  52:2 189:10,10       203:11 204:25       246:16 266:20          180:18               34:23 57:13 58:4
  200:16,20            205:5 207:3         274:18               potential 79:10,17     59:1,13 60:16
pieces 41:14 47:6      210:24 213:18      politically 233:6,7     127:18 154:22        62:15 63:4,17
Pilar 252:2            217:20 218:19      politician 206:2        170:4,15,20          64:6 98:8 101:3
Pilate 261:17          224:17 226:13      politics 13:1,10,22     171:1 172:5          101:5 103:18
Pinkney 217:25         227:12,13 229:15    14:13,25 15:2          271:14               104:2 106:18
pinned 51:2            234:11 236:1,4      18:4 20:8 41:13      potentially 77:18      107:5,10,13,17
pissed 209:9           240:9,12 243:5      76:15 246:16,24        84:21 130:14         107:18 116:4
  256:23,23            247:1 251:1         258:1                POTI 275:10            119:6 122:15,25
pitted 221:13          256:13 258:10      Pontius 261:17        Poti(sic) 275:10       125:1,17,20
Pittsburg 261:9        260:21 264:22      pools 274:14          power 126:7,21         142:12,12 144:20
  262:1                280:2 281:17       poor 108:11             137:4 235:6,6,7      147:25 148:2,3
place 73:17 95:22      283:10 290:11       255:15                 235:13 249:22        149:22 160:22
  144:3 187:14         291:4,4            population 287:12       254:1 257:20,21      179:23 206:8
  260:19 294:20      pledge 262:23        Porfino 240:21          260:14 286:19,20     231:12 246:19
  295:6              PLLC 3:16             243:16               powerful 70:19         260:8 265:6
placed 8:13 55:18    pocket 146:24        portion 96:7            289:14               269:6,7 271:21
  80:13 85:17        poem 230:10          portions 91:17        powers 228:21          284:4,5 289:3
  203:4 209:5        point 9:21 20:20      213:11                 258:25               290:21,25 294:11
placement 284:20       24:17 25:1,13      portray 225:18,20     practical 31:25        294:12,19
places 64:17           51:3 57:5 83:8     portrays 225:4          149:23             presidential 74:5
  166:20               97:9 99:11 104:4   Poses 197:20          practically 32:4       74:7,15 75:25
plan 12:3,4 13:7       104:6,25 109:18    position 35:18,25     practice 161:15        76:15 294:9
  26:8 32:11 68:7      109:23 111:6        36:1 44:18,19,25       263:9              presidents 66:14
  69:9 71:14 94:25     113:23,25 114:3     57:12 61:1 93:11     practices 75:16        149:20 150:10,16
  145:2 152:7          125:25 130:22       129:11 136:9           79:24 124:5        president's 20:15
  189:12               133:22 134:12       203:13 223:10          126:6 225:5          60:20 105:3
planned 119:23         135:3 179:2         258:19 265:18        practicing 273:18      112:22 114:15
  171:22 206:23        180:14 185:15      positions 40:19       practitioners          119:5 230:18
  275:6                188:18 213:14       59:10 101:1            273:21             press 36:25 37:7
                                                                                          Page 325

  223:20 224:1         142:1 204:12       project 11:25 33:2     295:9              public 12:4 13:25
pressing 109:4       proceeding 8:25        178:4              propriety 182:24      14:17,21 18:25
presumably             52:23 108:6        projects 10:2        protect 90:17         31:20 36:5,10,15
  119:16               112:5 113:22       prominent 61:9         260:10              36:18 39:20 45:1
pretty 70:19           117:11 202:3         74:23,24           protected 126:19      45:1,6,21,24
  209:13 249:7         234:1 293:4,10     prominently            200:3,11 247:23     75:1 76:3 78:10
  271:6                293:22               165:16,18          protecting 211:17     84:7,9 101:1
prevent 7:25         proceedings 1:7      promise 237:11,13      211:19              102:14,25 141:17
prevention 28:9        2:20 4:2 104:5,7     239:13,24 246:5    protects 95:5         173:2 259:23
previous 163:23        104:11 107:24      promised 42:12         247:23             publication 14:11
PRE-TRUSTEES...        110:24 223:19      promote 83:7         protest 226:8         14:12
  1:1 2:1              270:24 293:8,13    promoted 31:14       proud 68:24,25       publications 60:3
pre-work 80:25         294:5 295:5          164:18               125:13 207:6        270:17,17
pride 209:19           296:7              promoting 31:8         208:20 211:8       publicly 14:1
primarily 12:16      process 19:8,24        85:21                216:17,18 227:23   publish 59:25
  73:19 100:24         23:22 24:25        pronouncing            237:20 239:2        178:19 201:23
primary 67:21,22       25:15 28:21          233:14               251:15 253:22       241:6
principal 192:24       33:17 42:7 75:2    proof 242:19           256:4 265:5        published 13:2,4,8
principled 127:25      81:8 90:25 96:18   Prop 47:13,14          266:5 276:5         13:12,13 20:3
  274:23               99:20 109:4,6        48:17                281:5 290:7         25:21 29:12
principles 190:15      113:13 116:4       proper 139:20        proudest 69:22        54:24 146:20
print 181:10,19        126:3 133:18         184:6              proudly 66:24         156:25 157:11
printout 37:17         141:8 144:3        properly 109:4         262:24              200:16,23
prior 11:3 24:3        184:20 185:9         118:23 158:4       prove 120:11         publishes 156:10
priority 44:15         187:6,10,13        property 182:1,18    proven 199:22         156:13 177:15
  83:17                214:4 281:15         182:21,24            214:6,12 230:19    publishing 36:7
prison 230:21        procure 194:23       proponent 10:20      provide 18:10         141:15 177:8
private 66:4         productive 159:14      16:8 25:6            37:9 67:19 75:10   Puerto 249:6
privilege 251:16       262:5              proponents 28:17       96:23 143:4         286:5,22
prize 99:18          professional 9:14      39:15                157:4 245:13       pull 72:15 221:7
pro 22:5               9:14 273:20        proposal 10:21       provided 53:11,11    pulled 274:5
probably 13:8,13     professionals          11:11 14:4 16:10     92:13 93:12        punishment
  26:7,16,22,24        248:9                16:11 26:5 27:3      99:13 106:14        289:11
  33:22 37:6 45:17   professor 9:23         32:13 40:1 47:5      140:21 141:1       punitive 129:22
  61:20 66:10 87:7     12:5                 87:21,24 88:7,9      196:11             puppet 284:9
  89:15 134:6        professors 14:10       89:1,4,22 121:12   Providence           pure 104:9
  196:1 206:4          19:12                152:13 153:5,9       287:24             purple 37:12
  230:20 265:19      proffer 104:21         217:12 255:13      provider 233:16       48:23 63:8,9
  272:15 282:12      profit 274:11        proposals 27:6       providers 51:17      purportedly 91:17
  291:23             profits 82:9           73:5,7,10,10         220:24             purpose 15:21,21
problem 70:1         program 76:20          84:16 90:5         provides 67:18        27:11 76:25
  231:9 247:19         82:24 83:3,5,6     propose 88:10          292:7               78:18 112:24
  294:18               99:18 206:2          89:3               provision 94:2        117:20 119:16
problems 222:6         236:15             proposed 18:2          95:3                120:19 121:4,12
  282:19,22          programs 28:10         46:7 89:25         provisions 88:20      126:15 155:10,23
procedure 133:22     progress 81:6          151:24 152:5,17      88:21 103:13        155:24 192:2
  134:1              progressed 77:19       184:2 224:11       pro-con 29:11        purposeful 75:21
procedures 124:8     progressive 66:25      245:5              psychiatric 195:23   purposes 27:17
  126:1 281:4          277:8              proposing 183:22     psychiatry 222:24     100:24 102:16
proceed 108:12       prohibit 183:9         245:5              psychologist          120:5,7,23 154:9
  109:20 113:20      prohibited 94:2      proposition 31:24      273:14,17           154:22 184:6
  122:9 133:5        prohibits 68:20        31:24 48:6         psychology           pursuant 182:22
  138:19,21 142:1      183:7              propounded             273:18             pursue 62:7
                                                                                           Page 326

  145:17 196:7        276:3,4              70:12               RAY 3:3                 209:25 210:14,15
pursuing 45:4        quarterly 156:15     Quintano 240:21      reach 68:12 114:3       216:4 227:25
push 45:2 241:18     question 19:22        243:16,17           reached 67:10           231:13,16 235:1
pushed 103:17         33:23 42:18         quite 58:25 65:20      94:12 96:7 170:4      239:6 242:4,5
pushing 103:15        44:23 45:11,12       136:20 214:23         170:15,19 172:20      245:11 249:4,7,9
put 8:21 16:10        49:23 50:8,10,12    quorum 79:3          reaching 170:25         261:1 270:19
  17:8,21,22 24:18    52:1 60:5 65:10     quote 285:2          react 100:13            280:21 281:16
  27:7 30:9 31:14     70:15,17 86:8                            reaction 109:21         284:11 293:2
  62:18 70:6 79:20    100:18 102:8                 R             159:20              reason 38:1 46:17
  80:1 88:24 92:17    110:4,5 111:13      R 3:1                read 65:11 70:15        106:8 114:10
  97:11 98:7          111:14 116:13,14    Rachel 230:1           70:16 108:5           118:13,25 119:21
  102:17 103:10       122:3,6,11 129:3    racketeering           109:8 140:14          120:12 159:9
  104:6 109:5,7       131:10 133:6,7        277:2                143:13 159:6,13       178:9 210:20
  114:18,18 117:8     133:10,24 136:3     Radford 224:19         162:20 182:11,13      215:9 220:12
  117:16 118:9        140:19 142:25       radiology 205:15       182:15,16,17          224:8 235:2,4,5
  119:23 120:7,11     143:12,20,21,22       242:14               198:7,12,21           249:12 253:4
  123:23 127:1        144:2 146:4,5       raided 257:3           209:23 230:2          290:25 291:4
  129:8,13 131:22     149:15 151:4,19     railroading            261:15              reasons 79:20
  132:5,8,11,14       151:21 153:3          216:20             reading 38:7            83:23 106:14
  135:10 144:3        155:4,6 158:10      raise 18:5,6 28:4      141:14 143:9          113:3 119:14,17
  148:4 155:23        160:18 161:25         77:11,12,13          178:4                 121:13 122:16
  157:18,20 159:22    162:22 165:4          79:17 93:22 99:8   ready 17:6 30:19        126:11 131:12
  161:15 175:23       167:5,16,19           99:10,14 104:4       113:13 207:21         254:20 266:15
  177:11 185:6        168:9 169:6,8,9       108:7 196:9          288:7               rebellion 202:17
  193:18 200:2,10     171:9 183:20          252:20 292:25      Reagan 137:21         recall 24:23 30:17
  201:2 202:11        184:24 185:15       raised 80:10,12,20     139:23 142:8,9        31:24 35:17 37:2
  203:25 205:21,24    187:24,25 188:16      117:1 124:9          142:18 211:12         37:5,8 62:11
  210:20 212:7        188:17,18,19,21       209:16 227:1       real 68:9 104:6         78:12 80:7,19
  214:24 217:2,7      189:3,5 190:13      raising 99:6           119:17 122:6          122:3 150:18
  218:12 234:7        191:6,8 192:11        275:17               142:25 180:7          157:6,14 162:14
  237:13 243:25       195:3,7,25 197:8    Raj 3:8 34:21          182:21 211:20         162:17 175:15,16
  247:16 260:9,11     212:25 213:14       Ralph 225:11,14        214:17 256:9          175:17,19 176:23
  261:2 284:15        215:2,3 219:25        225:14 272:13,13     261:24 263:25         183:6,17
  285:4 286:12        223:19 233:18,18    ran 97:8               267:25 268:1,1      receive 53:13
  295:7               233:22,25 253:3     range 66:1 211:16      268:10 272:3,5        213:1
puts 87:14 284:9,9    253:5 264:17        ranges 66:8,11         292:4               received 89:7
putting 31:5 32:18   questioning 38:21      223:9              realistic 26:25         148:7 242:17
  102:12 116:3        105:9 108:24        rank 164:24          realistically 26:19   Recess 54:6
  124:2 128:2        questions 22:6       rank-and-file          26:21 27:12           111:25 184:11
  135:22 146:25       34:2,15,22 52:6       60:13,22 66:17     realize 240:3           204:15
  212:11 214:15       52:9 134:11           80:14 98:3           280:20              recipients 139:23
  221:2 223:19        138:24 139:8          125:22 180:1       realized 28:18        reckon 212:12
P-R-O-C-E-E-D...      146:3 147:10          186:17,19 191:1      199:15              reckoned 284:25
  6:2                 148:13 175:1          191:15,18,20,21    really 14:6 17:24     recognize 81:15
P.E 153:1             176:14 189:25         192:4 211:23         28:8 58:1 59:22       158:19
p.m 294:24            213:2 232:8           217:10,11 220:10     64:25 67:17 68:1    recognized 67:5
P.O 3:4               241:13 252:14         265:22 266:5,8       68:19 71:20         recollection
                      295:9                 285:1                75:22 99:9            102:11 154:8
         Q           quicker 115:8        rarely 282:18          119:24 121:6          157:5 175:7
qualified 31:18      quickly 31:6 32:15   rate 82:6 94:18        123:22 156:3          193:20
qualify 32:2          130:2 293:1         rates 95:11            159:14 172:18       recommendation
quality 46:14        quiet 7:1,3 42:22    ratify 126:4           173:19 175:24         62:17
 67:18 75:23 82:3     43:5 61:19,22       ratio 46:24            207:22,22,23        recommended
                                                                                           Page 327

  286:18             reform 11:15           78:20 105:9         removed 106:19         90:9,10 91:16
reconsideration        12:11,11,17,17       123:15 135:5          136:25 225:7,12      92:5 121:22
  25:8,11              15:23 19:25          154:16              removing 135:22        232:16
record 8:19 14:18      23:21 26:6,17      relates 130:18          137:6              represented 35:4
  49:12 50:7 52:15     30:12 31:20        relating 31:19        Renee 222:19           35:9 64:19,24
  52:18 54:20 55:9     33:24 34:12        relation 130:16         234:20               92:12 95:9 159:5
  55:24 60:21          35:13,22 36:11     relations 12:25       renewal 96:1         representing
  65:11,12 67:14       36:16 38:18 39:2     58:22               rep 223:11 225:11      125:18 213:8
  70:16 94:7           39:7,13,21 44:14   relationship 83:17      256:8 267:9          225:21 238:15
  112:11 118:19        44:18,20 45:2,4      96:5,11,12 97:6       279:16,19 280:22   represents 58:9
  140:2,20 151:16      45:20 46:20,22       97:12 117:4         repeat 45:12           94:15
  157:19,20,22         49:18 52:2 74:10   relationships           47:19 65:10        reproduced
  158:13 159:22,25     74:11 76:1,17        13:21 84:19           151:20 183:24        181:12
  162:18,23 163:19     78:19 84:2,22,23   relative 295:15         188:23 190:13      reps 245:25
  180:24 184:12        101:18,21 102:21   relatives 147:18        222:14               251:22 256:24
  188:24 203:9,11      103:10,14 153:21   release 52:7          repeated 226:5       Republican 18:11
  204:1 210:15         154:10,19 155:1    releasing 126:22      repeatedly 185:18      23:17 27:10
  245:10 293:1         155:8 156:1        relevance 108:13      repeating 227:8        259:11
recorded 295:10        177:23 212:1,4,6     108:14 116:15,17    repetitive 205:1     Republicans
records 13:25          223:21 268:1         130:13,15 137:23    replicate 72:18        18:10 19:6 23:12
  28:10 196:18       reforms 28:10          137:25 138:8        report 109:1           23:14,15,18
  241:3 263:8        refresh 102:10         144:9                 191:25 279:21        24:16
recourse 292:1         157:4,8 174:17     relevances 129:15       284:15             reputable 270:17
recruit 178:25       regard 103:5         relevant 9:19         reported 1:24        reputation 66:22
Red 3:4 256:22         114:7 122:20         119:11 129:9,12       7:16 102:20          66:24 67:1,6,12
Redding 94:14,16       125:12,25 127:5      132:3 138:3         reporter 41:21,24      213:3 230:9
  94:19                128:15 145:20        139:6,25 255:23       276:17 293:23        240:1 255:10
redirect 202:9         192:18             reliability 141:7,9     295:4 296:4          270:20
redistricting        regarding 19:24      reliable 207:12       reporters 1:22       rep's 279:18
  31:15                46:13,23 47:21     relieved 273:25         270:16             request 23:3
reduced 91:8,11        47:22 48:6,17      rely 291:16           REPORTER'S 1:7         110:16 269:22
Reed 205:7 207:5       49:17 51:24        remain 86:17            4:2 295:1 296:1      276:7 277:23
  207:5                124:20 132:22        100:6 255:19        reporting 200:9        293:2,9,11
Reese 205:6,14,14      135:11 137:10      remained 238:20       reports 75:6 125:9   requested 110:10
refer 63:6             145:12 150:14      remaining 137:3         178:13               221:18 269:20
reference 53:10        230:12             remarks 37:18         represent 35:10      requests 25:9
  143:24 159:18      regards 215:6,8      remember 47:25          61:14 92:17,18     require 17:2 28:7
  161:1,13           regime 235:9           86:3 122:11           161:24 177:25        28:8 35:6 45:21
referenced 161:8     Regional 95:8          151:10,12,14          219:22 237:8,9       178:13
references 40:19       248:21               154:2 157:10          256:20 257:25      required 18:9
referred 44:1 55:3   registered 35:5        165:11 167:11       representation         239:18
  62:2 144:25          44:10 248:3          168:16,17,18,20       226:6 267:10       requires 44:25
  223:24               289:1                168:22,24 169:19      268:4                194:21
referring 9:5 21:7   regrettably            174:13,14,22        representational     requisite 31:4
  39:16 147:19         252:15               175:2,6 176:17        58:6               reschedule 114:25
  174:12 199:2       regroup 39:3           176:18 192:17       representations      rescinded 93:4
  211:12,23 212:1    regular 15:25 16:1     207:15 213:22         201:2              research 10:2
refers 143:16          16:4,19,19           258:13 277:1,3      representative         14:6 20:9 33:19
reflect 193:13       reiterate 291:11       283:10,13 285:7       20:24 43:1 265:3     173:11 177:4,9
reflecting 120:23    rejected 47:9        remind 6:4,24           270:1                177:15 178:11
reflection 9:13      relate 105:2           112:3               representatives      reserve 6:9
  44:23 259:14         123:21 129:6       reminded 125:20         19:10,14,17,18     resign 261:22,23
reflective 259:3,9   related 46:9,11      removal 225:8,13        34:8,14 43:1         261:23
                                                                                          Page 328

resolution 85:1,5      112:1 261:16       re-order 233:21        214:9,15 217:5       266:9
  85:14 122:8        resurface 135:24     rich 99:20 223:9       217:11 218:9       Rose 224:19 238:5
  136:8,18 137:5     resurrected            223:16               221:1 224:12         238:6
  152:20,21 155:11     105:17             Richard 218:22         225:25 226:12      Rosselli 60:16
resolve 99:15        retaliate 103:16       227:17 240:15        229:24 230:10        63:17 64:5 99:2
  120:14               105:12 233:10        241:20 276:22        235:6 236:2,3        101:5 106:17
resort 239:18        retaliation 104:9    Richmond 286:3         240:1,4 244:14       108:15 115:24
resources 119:24       104:22 108:15      Rickman 147:22         245:1,4 246:7        123:13 150:19
  126:15               109:16 117:15,18   Rico 249:6 286:5       250:13 253:9         151:6 152:11
respect 43:16          199:15 215:6,10      286:22               254:11 255:24        179:15,22 180:4
  125:3 209:22         224:6              rid 228:10             257:24 258:2         186:5 199:8
  242:1,2,25         retire 266:15        Ridley 24:22           260:1 263:10,11      223:14 253:7
  246:22 256:11      retired 83:13        rigged 109:13          269:20 270:13        258:10 261:21
  278:8,8              208:13 266:14      rigging 260:16         271:2,18,19,25       262:5 274:23
respectable            267:8              right 8:4 10:1         272:8,17 273:1       282:5 284:3
  207:13             retiree 68:8 95:1      15:22 16:23          279:21 280:4,8     rotate 248:12
respected 128:17       95:16                18:18 20:14 21:3     280:23 283:25      Rothner 3:12,12
  223:21 236:18      retirement 208:15      24:18 31:25          285:8 289:24         4:7 8:1,8,17 9:6
  251:18             retribution 112:25     34:16 37:13 43:4     291:7,24 294:1       9:8,10 34:15
respectful 282:14      119:1 120:13         45:22 46:9 52:10   rights 71:4,6 89:4     42:19,24 45:10
  282:16               121:12 250:16        54:7,21 55:4,6       89:21 95:15          48:25 49:23 50:1
respond 70:5         return 115:8,16        61:13 63:25 64:8     182:2 200:5,12       50:5 52:7,11,21
  105:1 118:1,3      returned 85:7,8        68:13 69:20          224:13 245:22        53:20,24 54:11
  124:13,20 127:2    returning 130:1        71:15 76:2 86:9      276:23 290:12,12     54:15,22 65:7,9
  128:18 135:8,13    revenue 18:8           86:13 88:25 89:3   rising 82:2            69:25 102:3
  141:3 202:14         65:16 77:17          91:18 92:11,19     risk 190:12,21         114:20,23 115:2
  204:10               182:23               92:21,21,24        river 3:4 278:21       115:7,14 132:23
responded 104:20     revenues 18:6,14       93:20 94:3 95:14   Rivera 134:16          133:6,10,17,21
  264:16               65:5 96:21           101:22 102:22        211:5                142:23 143:8
responding 120:8     review 14:14           104:8 106:6        RMR 1:24 2:21          145:16 158:5,16
  129:13               161:22 162:11        109:18 111:8,19      295:3,23 296:3       204:3 294:17
response 34:2        reviewed 14:21         112:12 114:19        296:16             round 166:17
  120:20 124:24        161:20               115:15 116:12      road 39:2 238:7      route 255:2
  128:16,17 132:9    reviewing 42:8         117:6 118:14       rob 285:22           row 286:8
  224:1 225:16       reviews 60:4           119:11 120:2,10    Roberto 251:10       RPR 1:24 2:21
  271:3,4            revocation 106:15      120:14,16 121:16   robo-calls 242:18      295:3,23 296:3
responsibilities       106:18               123:2 129:14       Rockwell 252:8         296:16
  58:14 192:10       revoke 106:12          131:2 132:7        Rodolfo 228:16       Rubber 57:19,22
responsibility       revoked 104:3          133:3,8 134:2      Rodriguez 60:17      Ruby 255:6
  201:7 202:18         106:8 107:6          139:5 140:18         63:19 243:11,14    Rufino 208:9
  232:18             revoking 103:23        141:16 142:4       role 12:11 83:4        211:7,8
responsible 190:6    revolution 285:3       143:11,23 144:12     86:25 192:4        ruin 213:20 282:1
  194:24 197:5       rewind 276:18          144:13,16 145:14     196:24 197:2       rule 18:4 25:15
  201:22 202:17      rework 241:16          145:24 148:15        200:19 238:21        233:24 240:2
  213:8 244:12       rewrite 232:4          150:21 157:13        284:12               293:19
  253:8              re-authorize           158:12,21 160:5    roles 284:13         ruled 18:7
responsive 180:22      185:24               163:19 178:17      rollbacks 88:23      rules 53:8 102:4
rest 113:21 249:8    re-cross 52:6          182:24,24 188:10   rolled 72:10           110:8 140:20,21
  259:20             re-introduced          191:12 198:19      room 33:21,21          140:23 141:1,1,6
restate 184:24         45:9,16              202:22 204:6,13      72:6 74:2 127:25   ruling 133:1,4,24
result 122:21        re-negotiations        204:19 207:20,20     189:4 215:17,21    rumored 101:20
resume 8:7 54:8        97:3                 209:18,25 210:9      223:3 256:19       run 28:16,21 107:4
  54:23 111:23       re-opener 86:16        210:17 213:11        262:20 265:10        107:9 122:14
                                                                                       Page 329

  146:13 149:7     Sal's 239:21         scale 255:16          42:22 43:4 45:12     242:24
  180:3,23 188:3     247:19             scales 68:4 70:23     49:25 50:9 52:10   Secretray 292:25
  217:4 243:20,20  Samaritan 272:10       71:13 94:4          52:13,19 53:4,13   secrets 231:8
running 122:22     San 1:8 2:20,20      scare 209:25,25       53:18,22 54:4,7    section 89:4
  178:14             3:9 25:20 59:21    scared 253:21         54:11,14,17,21       101:23 182:23
Ruth 227:18          61:8 102:17          276:8               55:4,12 56:12      sector 66:4
  228:24             177:14 223:5       schedule 112:16       61:16 70:4,11      secure 210:7
Ryan 279:8,8         238:7 248:21         114:10 263:12       100:18 104:13,24   security 68:18
                     258:7 272:10       scheduled 22:20       105:6,7,25         see 25:23 26:7,16
         S           282:10 289:13        136:6 263:13        108:10,13 109:18     26:18 37:20,24
s 3:1 158:8        Sanchez 260:2,3      school 12:23          111:8,12,17,19       38:15,24 49:20
Sabrina 51:13      Sandidge 229:17        275:18 286:12       111:22 112:1,12      50:5 74:19 78:25
Sacramento 40:13 Sandoval 229:22          288:23 291:3        114:2,9,13,21        82:12 84:10 88:6
  44:8 59:13 96:19 Sandra 251:3         Schwartz 278:3,3      115:1,3,10,15        89:17 91:23 92:6
  100:25 101:12    Santa 66:6 256:17    Schwarzenegger        116:15 117:3,6       97:24 101:15
  212:3 226:22       278:4                10:16 16:7 19:10    118:3,20 119:12      113:14 124:18
  283:21           sat 71:9 213:7         36:25 37:23 38:3    120:1,9 121:2,8      138:16 158:25
sadly 278:22 279:4   232:10 252:14        38:11,24 47:5       121:19 122:2         170:5 177:17
safe 76:20 99:9,13   264:12               49:17 50:13         123:2 129:6,14       181:22 182:12
  99:22            Saturday 1:9 2:21      103:10              130:16 131:20        197:22,24 198:5
sake 117:10          6:1 296:7          Schwarzenegg...       132:7,14,23          199:12,19,24
Sal 57:8 60:16     saved 196:17           51:13               133:3,8,16,19,20     200:6 207:3
  63:17 64:5 80:7  saw 72:19 73:24      Schwarzenegg...       134:2,5,9 135:7      209:19 220:21
  80:7 99:4,6        75:24 76:22          10:7 35:22          135:14,16 137:16     224:2,5 225:4
  101:5 103:18       77:18 83:3 84:14   Science 9:24          137:25 138:15,20     230:14 231:7
  106:17 107:8,12    84:20 141:12         12:21               139:3,9 140:4,10     233:5 237:2,2,2
  115:24 122:13,21   238:16 248:7       Scientist 280:16      140:18 141:4         237:3 245:6,14
  123:12 125:20      257:2 274:1        screen 197:17         142:4,25 143:5       245:21 263:14
  150:19 151:6       284:23 286:22      screwed 253:8         143:11,23 144:12     265:22 268:15,16
  152:11 179:14,22 saying 39:17,19      seafood 259:7         145:6,11,14,16       269:2 277:25
  180:4 186:5        61:19 100:1        seat 6:19 113:19      145:21 147:4,11      278:9 282:18
  193:16 206:18      107:9 110:15         275:24 276:11       148:15 151:2         285:22 289:14
  216:4,4,8 219:5    120:4,17,21        second 10:10          157:12 158:1         290:14 291:15
  223:13,15 231:6    122:14 135:3         15:13,17,18 21:5    159:15 165:6,8     seed 166:24
  235:15,15 237:5    137:12 141:5         40:6 55:3 62:1      167:22 169:9         175:23
  237:22 239:2       145:11,21 214:4      63:19 66:4 87:10    179:11 181:24      seeing 25:11
  242:8,23 247:18    214:17 229:9         101:4 105:6         182:3 184:12         50:16 225:10
  247:19 250:16      243:3 245:24,25      125:7 158:4         190:1,24 195:8       235:12,12 260:12
  253:7 258:9,10     246:4,4,21           163:15 180:15       195:11 202:1,7       260:13 286:5
  258:13 261:21      267:16 272:25        207:1,18 231:5      202:16,20,22       seek 107:4
  262:5 268:17       275:15 288:19        231:19 265:4        204:2,6,13,25      seen 98:17 123:9
  272:15 274:23    says 9:3 18:5          286:24 288:10       210:21 213:18        206:19 213:19
  278:8,15 281:6     21:10 25:5 37:25     294:4               233:14 234:23        239:4 249:16
  282:5,16 283:13    39:8 87:11 89:19   seconded 162:20       236:1 260:1,2,21     263:21 268:15
  283:16 284:3       92:10 116:2          163:10              270:3,6,8 271:5      274:22 278:12
  287:25 288:12      136:21 142:8       secondly 218:9        272:8 273:13,16      286:5 289:16
  290:11 291:5       152:21 166:1         269:19 294:7        275:4 283:24       sees 216:4 287:19
salaries 217:10      179:21 199:6,6     secret 102:23         284:12 291:7       SEGALL 3:12
  244:11 246:2       199:14,21 200:1    Secretary 3:3 6:4     293:7,14,19        SEIU 1:2,4 2:2,4
salary 223:8,12      229:4                7:17,19,22 8:1,4    294:1,6,14,23        3:20 4:4 5:2 8:13
  246:22           SB14440 46:23          9:9 17:17 20:19    Secretary-Trea...     40:13,19 42:6,7
Salinas 253:13     SB1527 46:19           29:9,14,16,20       60:18                42:10 43:1,7,14
salvaged 28:6      SB981 45:25 46:2       34:16,20 42:19     Secretary/Trea...     43:17 44:7,9
                                                                                        Page 330

56:23 57:2,9         271:8,11,20          150:16 151:8         45:20 90:1           247:13 251:21
59:15 61:25 62:1     272:2,4 277:12       152:12             sessions 172:1         261:10 283:22
63:18 66:14          277:19 279:15,25   seniority 245:5,22   set 68:2 72:23,24    shopping 278:11
79:10,18 82:19       280:19 283:14      sense 41:20 64:11      73:2 121:6         short 28:22 48:11
85:20 86:22          285:15 286:3,4       64:19 65:1 180:8     166:14,16 167:7      53:25 93:2
89:19 90:15,19       286:23 287:5         181:4 209:19         168:11 177:21        138:10 261:7
91:10,15 92:1,7      289:2,25 291:21      259:18,20,20         180:16,17 182:8    Shortages 82:5
92:16,23 93:19       292:7,10,11          274:18               257:14 262:20      shorter 30:4
94:1,12 96:4       SEIUVoice.org        sent 86:22 131:2       295:6              shorthand 295:4
97:6,13,15,18        197:18 200:20        156:15 162:15      Seton 87:12 290:5      295:13 296:4
98:8,17 99:10,13   SEIU's 99:20           211:11 242:20      setting 197:5        shortly 10:25
99:13,19 100:13      115:21 118:16,18     271:13             settled 72:3 86:15     174:10,15 175:11
100:23,25 101:6      123:23 127:23      sentence 26:2,14     settlement 67:9        176:9
101:15,15,19         129:7 146:20,21      26:16 38:10        seven 23:13 24:3     shoulder 112:8,8
103:7,12,16        SEIU-UHW 89:11         199:14,21 200:1      24:23 70:21        show 105:11,13
104:22 105:12,15     96:9 160:14          274:21               162:23 165:19        109:11,24 121:5
106:7,11,12        SEIU-5 187:19        separate 45:8,15       198:25 199:2,4,7     138:4,13 153:5
107:16,17 109:15   seizure 126:6          117:22 131:10        249:7 272:15         157:7 174:12,17
116:6 117:1,1,24     200:4,11             139:19 151:18        273:3                204:23 223:6
118:6 122:17       selection 292:8        200:3,10           seventh 101:16         240:10 250:23
124:9 126:7,10     self-appointed       separately 80:3      severable 182:24       258:9 268:11,25
126:11,20,23         209:5              separation 131:17    severely 137:4         269:6 272:7
127:1 128:5,7,17   self-evident 99:12   September 1:9        shaky 233:3            278:13 279:23
128:18 129:17,25   self-explanatory       2:21 6:1 16:2,21   sham 217:19            286:15
130:4,5 132:17       154:11               87:10,13,23          257:13 292:3       showed 119:16
132:21 133:10,12   self-selected          88:10 89:1,5       shame 257:22,22        278:14
134:15,16,17,25      208:24               296:7              shape 246:23         shown 271:10
135:21 137:5,12    sell 95:6 239:15     sequence 122:7       share 96:23 217:1    shows 268:3 290:2
138:5 139:16         275:24 278:21      Sequoia 280:16         263:5,6            shut 121:23
140:7,21,23        sellout 255:12       Sergeant 6:6 7:5     shared 64:14         sic 63:22 137:22
141:1 142:9,12     semantic 274:6         7:8,18,20 112:5    Sharon 240:14        sick 242:21
144:3 145:2        seminars 171:20      series 89:12           272:9              side 19:3 27:9
148:3,10 158:8       171:22               105:12 116:24      Shasta 95:8            58:7 73:19,24
160:6,12 161:2     Senate 20:12           126:9              sheet 6:19 113:19      131:9 256:18
179:7,7,22 196:3     21:17,17,20,24     serious 204:9        Sheila 24:4 217:25     272:22
196:5,22,24          22:1,2,13 23:3       230:13             Shield 35:21         sides 22:4 52:4
197:5,19 198:8       23:24 25:1 26:3    serve 12:2 59:6      shift 89:6             53:12,15 227:10
198:14,15 200:24     26:11 27:15          80:15,20 94:9      shifting 131:16      siding 213:21
207:14,15,24         28:18,20 29:24       195:19 275:2       shine 260:17         SIEUvoice 200:23
211:12,22 212:7      30:1,6 32:1        served 260:7,8       ship 262:2           sign 6:14,15 128:3
212:10,18,20         38:18 39:4,7       serves 55:1          Shirley 165:10,15      224:14,15 262:23
213:21 214:13,22     44:12 51:9         service 3:11,19        165:17 166:4,11    signatures 17:15
215:2 218:16       Senator 37:2,5         20:24 95:10          166:18,22 167:7      17:16,18 29:19
221:11 224:9       Senators 260:20        226:1 266:18         167:10,24 168:10     29:19,22 30:3
229:1,8 230:14       277:23               277:24               168:13,25 169:20     31:4 32:6 48:7
230:16 233:4       send 6:17,20         services 67:19         169:24               48:19
237:19 238:16,19     128:2 196:14         266:18             shirt 273:10         signed 6:13 91:17
238:23 239:9         224:6 232:12,17    serving 211:15       shit 273:9             92:5 127:15
249:8 250:25         241:4 269:5        session 4:3 6:10     shoot 26:4             128:10,11 224:11
253:17 259:8         276:10               15:6,7,12,12,14    shop 208:20          significant 73:3
262:24 263:22      sending 275:18         15:16,17,18,19       221:12,23,24         223:12 255:17
264:14,16 269:13   sends 207:15           15:20,25 16:1,4      226:21 234:23      significantly
269:22 270:14,25   senior 142:9 149:4     16:6,19,20,20        243:17 246:15,15     28:12 223:15
                                                                                            Page 331

signifies 15:15         256:18 276:11       son 211:15 234:4       229:16 230:16        90:11 139:22,23
signifys 15:8         situation 70:20         272:11               256:18 268:3         208:23 225:9,12
silenced 246:25         190:23 205:21       songwriter 259:24      275:7 278:6,24     spokesman 51:13
Silveria 264:3,6      situations 93:14      soon 43:20 211:20    speaker 10:19        sponsored 172:13
similar 172:4         six 23:8,9,10,10,11   Sophia 7:21            15:6 16:3 25:10    sponsors 160:6
  257:19                23:23 24:2,4,6      sorry 10:23 20:17      25:21 26:10        spouse 88:18
Simon 222:18            24:12 70:21 90:5      32:25 45:10 49:2     36:25 37:23          94:21
  224:25 254:19         107:16 148:2          54:11 65:7 98:23     254:18             spouses 68:6
simple 74:17            221:12 289:17         117:9 123:5        Speaker's 26:11        88:13,15
  151:21 168:9        slander 216:19          132:23,24,24       speaking 52:23       spread 192:14
  190:1 227:1,8       slates 180:8            139:11,13 150:4      94:10 117:3          223:13
  233:23              sleep 210:5 214:24      151:4 156:12         218:5 284:3        spring 81:3 119:15
simplest 97:25          215:4 236:2,2         162:22 163:3       speaks 140:5           120:6,25 157:19
simply 120:3,10         245:9 259:3           170:10 171:11        143:13 284:7         157:23 159:24
  130:24 225:9        slog 142:21             175:15 176:16      special 10:2 12:6    springs 30:8
  259:24              small 56:16 66:5        179:9 183:19         12:9 15:7 142:17   St 88:7 281:20
simultaneously          149:8 181:11          188:16 195:24,24     143:14               282:10
  98:13                 215:18,19 287:6       197:14 214:17      specialist 265:17    stab 278:22,23
single 71:10          smaller 183:11          215:18 242:4       specializing         staff 14:9 18:24
  125:10 136:11         185:16                275:9                211:16               58:12,17,20,21
  149:23 156:24       smart 228:9           sort 196:17 226:25   specific 15:21         126:12 142:9
  186:15 236:20         289:23              sound 125:5,6          52:25 150:18         147:22 149:4
  252:19 266:9        Smith 211:4             170:11               192:12               150:16 151:8
  290:6                 215:16,16,20        sounds 183:13        specifically 13:16     152:12 161:17,18
singly 220:8            228:22                215:24               40:17,22 42:2        162:7,8 178:12
sir 21:2 37:13,14     smoke 146:14,15       source 77:17           43:17                178:15 179:2
  40:8 41:15 43:6     smokers 252:1           85:19 86:5         specified 17:15        197:4 211:12
  43:16,23 44:12      Soaring 82:9          sources 18:9         speculate 166:9        241:6 286:10,15
  45:7 46:9 47:13     social 222:25         south 2:20 3:13      speculating            289:5,23
  48:22 49:3,15         223:12 269:10         56:9 177:13          166:10 167:12,13   staffing 68:9,11
  50:4,12 52:5          279:8                 227:2 255:14       speech 230:10          69:14,15 71:3,15
  61:24 111:24        society 234:7           258:7 288:2          270:15 283:25        76:20 82:7 95:3
  139:8 206:25        soft 254:7            Southeast 260:12     speeches 287:2         249:16
  261:18,22           sold 68:15 255:14     Southern 96:4        speed 181:16         stage 218:6
sister 210:11         sole 112:24 116:18      149:10 267:10      spell 8:18             284:11
  259:4 265:25          118:25 120:12       so-and-so 41:23      spelled 96:8         stages 125:15
sisters 220:23          121:12                41:24,24           spelling 163:12      stakeholders
  237:4 249:8         solely 166:14         so-called 123:13     spells 63:25           49:20 50:16
  256:6 268:9           205:25                235:6 283:25         123:25             stand 104:19
  271:20 277:21       solicit 171:17        so-to-speak          Spencer 273:13,16      135:10 138:24
  278:24              Solutions 81:20         289:10             spend 43:2 65:16       218:8,9 220:5,10
sit 68:10,12 159:13     82:21               space 71:8             86:7 172:9           230:22 258:10,10
  236:16 265:21       somebody 90:24        spades 239:23          279:10               268:8,10,16,17
  278:15                95:18 113:15        speak 6:12,17        spending 42:20         268:18 273:4,6,9
Sitdown 57:24           204:8 209:20          7:19 55:7 56:13    spent 12:23 86:8       276:6 282:23
site 265:4              220:7 241:22          84:20 113:13,15      186:11 211:17        285:5 287:2
sites 66:11 73:6        257:12 268:5,6        114:5 132:24         241:3 264:11,15    standard 67:4
  265:22,24             268:24 269:1          140:1 145:19         264:18,20,21         88:16 92:8 94:6
sittin 231:12           284:7,9 285:20        159:12,23 200:17   spirit 100:5           98:11 217:14,15
sitting 60:23           292:4                 200:18 215:5,7     spite 225:1 292:17   standards 67:2,6
  157:13 158:21       someplace 253:9         215:11 216:25      split 35:18 137:1      67:13,15,24 68:2
  160:16 213:12,22    somewhat 16:11          217:9,11 222:23    spoiled 234:3          68:3,23 71:17
  245:24 253:1        SOMNATH 3:8             226:13 228:15      spoke 32:17 34:9       73:4,25 74:1
                                                                                          Page 332

  91:7,11 95:21        7:6 50:20 51:20      230:22 233:9         88:23 112:6        struggle 75:9
  98:12,15,18          119:6 138:10         234:3 237:11         113:22,24 118:6      99:16,17 274:19
  141:7,8 222:7        201:16               241:5 242:17         118:17 140:8       student 184:25
standing 214:7       statements 4:19        243:19 244:18,20     141:17 210:4,4,4   studied 19:23
  261:17 275:7         22:14 51:3,6,22      244:21 245:8,17      234:7,9 239:16     studies 10:4 13:14
stands 268:7           120:21 129:7         245:18 250:11        239:16 257:7,10      13:15
Stanford 271:12        203:18,23 204:12     257:11 258:24        262:4 281:21       study 10:6,10,24
starkest 87:7          204:17,18 205:1      260:21 261:19      stopped 234:2          13:18,21,24
stars 76:14            205:2,12 224:4       268:23 269:2       stopping 114:3         14:13 15:2 18:18
start 81:4 84:3        295:9                278:18 279:4       stories 255:21         177:9
  94:18 104:11       states 10:12 11:17     281:13,25 282:3    story 93:2 104:21    stuff 88:4 193:22
  160:14 170:8,13      14:14,15,24,25       282:18 283:10,15     105:23 108:10,16     242:6
  173:15 179:2         260:8                284:1,4,14,19,20     111:11 116:20      stupidly 252:15
  181:15 208:4       State's 29:21          285:8,19 286:18      118:7 119:25       subcontract 88:25
  243:3 250:24       Status 89:19           288:4 289:25         120:2 121:22,24      91:19 92:11,14
  291:12 293:20      stay 93:3 217:6        291:21               122:6 227:10         92:19,22,24
started 31:1 57:6      266:4 267:5,12     Stern's 110:14         255:22 281:12        95:14
  71:23 99:6           269:4 275:5          198:8 208:17       straight 174:21      subcontracted
  166:25 171:24        281:21 291:6,9       230:19 252:3         214:18 220:18        93:7 95:9
  238:17 239:6,10    stayed 11:17           258:19 282:18        276:6              subcontracting
  254:6 265:17         292:22               284:2,16           strategy 71:22         68:17 71:16 92:9
  286:3 287:5,9      steal 131:11 217:7   Steve 63:21            72:22 73:13,14       93:6,14 95:2
starting 61:10       stealing 131:15        217:22               99:18 146:12       subcontractor
  239:10               289:6              Steven 142:15,16     street 3:9,17 95:7     93:12,13
starts 81:1 216:13   steel 72:20            144:16,23            206:7 244:3        subcontractors
start-up 165:25      Steinkraus 208:6     steward 161:20         291:2                94:11 245:6
stash 79:13          Stengle 247:10         162:8,11 164:8     strength 110:12        288:11
state 8:18 9:24      stenographically       208:21,21 211:8    stress 205:24        subject 11:2 33:7
  10:20,22 11:3        295:11               214:2 220:1,2      stress-free 250:3      33:10 46:3,5
  12:8 13:20 17:2    Stephanie 227:16       221:7 225:7,10       250:5                52:6 110:23
  17:17 21:17,20     stepped 122:23         225:12 226:21      strike 52:18 59:16     230:15
  26:3 29:9,12,14      251:13               228:25 232:3         61:8 68:13 73:3    subjects 205:2
  29:16 39:4,4       steps 51:18            234:23 238:6,21      75:4,7 94:3 97:1   submit 227:11
  40:10 51:23 55:9     199:10               243:17 246:15,16     125:6 196:3        submitting 102:15
  55:23 61:15 62:8   stern 1:2 2:2 3:15     247:13 248:11        250:10,11,12       subordinate
  77:15 100:15,20      98:8 99:1 101:19     251:15 253:13        262:15 283:14        188:17
  100:21,22 101:2      101:21 102:20        254:5,5,6,13,21    Striker 57:25        subsequently
  101:3,6 103:18       103:15,17,22         254:22,25 256:3    stringing 176:14       94:5
  103:23,24 104:3      106:23 107:18        260:4,15 261:10    strings 100:11       substantiated
  106:8,12,18,25       110:3 115:25         261:10 263:4       stripped-down          146:19
  107:5,10,11,13       122:13 123:12        265:3,3,4 279:16     96:16              substantive 43:6
  109:12 110:3,5,8     125:1,17,20          281:21 283:22      strong 27:13         subversion 225:10
  110:8,15,18,20       126:5 127:11         290:20               57:18 206:5        succeed 213:17
  115:21,22 116:4      129:20 142:17      stewards 126:2         237:14 242:23      success 14:19
  122:12,15,25         144:20,20 147:25     161:19 164:9         275:12 289:18,23   successful 100:12
  136:10,22 203:9      148:3 160:22         212:2 232:13,14      292:15,16            289:19
  233:7 257:16         171:24 199:3,16      248:12 279:19      stronger 254:17      successfully
  287:19 296:4,9       200:4,11 205:17    steward's 251:22     strongest 214:10       31:18
stated 38:4,11,25      206:9 208:2        stick 273:10           214:11             successor 15:24
  40:14 44:13          209:4 216:3,6,9    Stockton 241:1       strongly 128:8         16:22 68:16
  50:14 51:14          216:13 222:25        242:15               206:24             Successorship
  140:21               223:19 229:9       stole 131:1,13       struck 71:5            68:15
statement 6:17         230:11,12,13,21    stop 6:7 44:17       structure 179:21     succinct 106:1
                                                                                           Page 333

sudden 90:6            52:14 53:3 107:7     90:7,11 91:2         62:8 75:11,15,18    Teamster's 277:2
suddenly 286:17        115:20 140:6         96:22,25 129:13      82:1 83:1 84:21       277:4
sufficient 214:16      162:4 169:7          134:22,22 135:4      129:4 134:19        tear 257:21 260:22
sufficiently           174:25 176:15        135:5 167:3          135:6,7 164:9       tearing 257:19,23
  164:24               180:13 181:15        170:7 217:15         176:24 192:20       tech 205:15
suggest 47:3 53:4      185:15 186:8,13      224:10 236:16        225:23 229:11         242:14 256:17
  53:6                 189:5 196:6          245:3                235:16 237:21       technical 41:14
suggested 48:10        223:14,23 227:7    tables 72:16           241:2,14 255:8      technically 35:4,8
  280:25               232:19 237:16      tabs 163:6             265:20 280:8        technologist
suggesting 39:9        253:14,25 257:8    Taft-Hartley         talked 34:13 41:10      215:18,22 252:8
suggestion 42:20       267:4 272:6          84:18 167:1          42:1,2,7,10,11,16   technology
suggestions            275:5 285:5          168:3,6              42:17 43:17,18        263:18,20 264:1
  112:13             surface 14:24        tag 9:3                43:21,22 66:14        266:1
suicide 216:11       surgical 215:18,21   take 8:3 9:2 17:7      66:16,19 71:17      telephone 126:16
suit 212:17 283:15     233:17 252:8         20:14,16 30:10       107:12 135:11,19      126:23
suitable 198:14      surprised 134:22       33:15 35:17          160:22 163:24       television 262:20
sully 239:25           159:9,21,21          37:11 53:2,25        176:4 200:15        tell 13:15 41:5
Summary 30:17          166:3                54:4 65:15 67:16     202:12 209:2          42:2 46:2 108:9
Summer 5:4 158:5     surprising 159:17      72:22 77:23 88:3     233:1 280:22          108:16 111:10
Summit 84:5,6        surveys 126:16         100:5 112:9          287:9,10 290:20       118:8 119:24
  89:14              survive 128:1          113:11 129:22      talking 21:15           120:2 121:22,24
sun 279:10             246:9                138:9,12 142:22      39:12 75:7            122:6 150:12,13
Sunset 212:24        Susan 222:16           144:1 162:10         122:12 141:25         157:15 165:1
  214:1,20 215:5     Sustainable 83:14      164:15 188:8         158:12 174:8          191:21 206:2
  215:17,21 229:19   sustained 84:15        189:10 199:17        181:16 182:1          210:21 213:9
  233:17             Sutter 87:2 88:24      202:13,18 204:11     189:15 190:8          222:4,9 223:1
supervise 58:13        89:14 244:6          208:14,17 209:20     219:7 228:8           228:6 229:12
  58:20                245:21 283:3         211:14 216:8         276:9 294:4           242:4 245:3
supervising 58:17    Suzette 251:14         218:17,18 220:8    talks 63:21 286:25      246:6,20 252:17
supervisor 289:5     Swaggert 266:13        222:10 223:12      Tamala 217:23           253:1 256:6
support 23:18          266:14               236:20,21 239:20   Tamara 236:10           259:24 261:20
  27:10 73:10 83:7   swear 55:12            240:9,9 241:6,23   Tammy 218:25            264:19 265:8,15
  85:24 206:8,8,24   swimming 13:19         248:17 257:5         221:6                 266:3 268:11
  219:15 220:22        274:14               258:11,24 259:23   tank-type 20:4          270:3 272:12
  223:6 225:3        switch 244:1           259:23 260:19,21   Tanya 226:16            281:5 285:14,15
  226:7 264:23       Switzerland            260:23 281:12,17     227:21                290:10
  274:24,25 290:13     289:10               283:6,9,9,10       tape 293:9,12,24      telling 118:7 169:3
supported 63:2       synchronizing          285:15 294:20      targeting 250:17        235:19 245:13
supporter 16:16        73:12              taken 2:20 21:22     taught 12:7 56:22       256:24,25 259:21
supporters 33:6      System 287:24          30:24 54:6           59:20               Temp 20:24
supporting 23:15     systemic 13:22         111:25 184:11      tax 28:2 29:2         Template 96:15
  284:13             systems 69:18          204:15 206:24      taxes 18:5,7          temporary 96:14
supportive 24:5,8      239:5                255:1 260:13       tax-exempt 200:3      tempt 195:24
  35:21                                     295:5,13 296:7       200:10              ten 94:3 276:21
Suppose 130:23                T           takes 30:17 162:8    Taylor 256:2,2        Tenet 91:18 92:9
supposed 188:5       tab 20:18,21 163:4   take-away 87:25      teach 12:5 59:17        92:18,19,22,24
  209:11 214:14      table 64:17,20         88:1,2             teaches 277:9           93:3,7,10,15,20
  232:14 242:9         67:7,13 71:10      take-aways 89:25     team 90:12 93:23        93:23,23 94:2
  263:7 271:19         72:11 73:8,11,22     90:2                 247:15,16 278:6       214:13
Supreme 264:5          74:25 75:10        take-way 88:3          278:7 283:23        Tenethealth
sure 36:14 37:4        84:16,16,20        talk 21:9 33:21      Teamster 254:8          91:15,15
  40:23 45:13          86:24 87:2,3,9       40:16 41:23 42:3   Teamsters 223:22      tentative 92:4
  46:16 51:25          87:14 88:24 90:6     42:8,9,14 51:17      256:4,6               93:4
                                                                                          Page 334

tentatively 13:18      229:14 231:1,3       87:19 111:2          279:1,3 281:7,8      24:10 27:5 28:16
  15:1                 231:22 234:10,23     119:13 126:25        281:10 288:2,18      28:22 29:8 30:3
Tere 288:20            236:1 244:3          153:21 155:3       thinking 29:5 52:4     30:4,14 35:16
Teresita 211:2         251:15 252:9         156:3 166:17         155:12               42:20 43:3 48:11
  212:23 240:20        253:10 254:2         174:25 177:13      thinks 205:19          49:21 50:17,25
term 68:21 265:4       256:10,14 260:1      197:11 210:23        206:9 212:11         51:2 52:6 53:2,3
terminate 73:12        264:3,23 266:11      213:20 214:13      third 78:15 99:11      56:24,25 59:22
terminating 76:1       267:19 270:15        218:12 221:16        125:25 127:23        60:5 61:16,18
terminations           271:6 272:8          222:2 223:24         202:4,6              63:2 64:18 71:25
  74:15                273:6,15 275:3       233:7 245:14       Thirdly 270:25         72:1,2,5,10
terms 28:15,24         279:6 280:13         248:8 252:17       Thomas 24:22           73:13 76:2 77:25
  43:14 45:18          281:17 282:6         259:10 260:25        137:22 142:10,11     78:23 79:16 85:4
  97:17 98:11          285:25 288:1,1       261:3,5 262:21       144:23 222:19        87:15 88:8 103:4
Terra 227:15           288:15 290:3         271:1,8,18 272:6     251:4 256:16,16      105:4 106:9
territory 268:7        291:8 292:21         275:16,19 282:15   thorough 6:25          112:16,17 113:2
test 113:6             293:17 294:23        289:14 293:1       thought 23:25          113:12 114:11
testified 8:14       thankful 215:23      think 10:15 13:17      24:14 28:5 72:1      118:4 119:20,21
  40:24 43:15        thanks 215:25          20:4 23:25 27:1      97:3 102:9,10        120:22 121:22
  55:19 104:19       theirs 227:11          27:4 32:5 33:24      168:6 180:2          125:21 132:10,12
  137:11 148:19      their's 220:14         34:11 39:9,15,16     228:4 258:16         133:22 137:10
  149:12,14 153:19   then-Insurance         39:25 42:6,24        261:13 271:5         148:14 159:14
  173:19 175:5         11:9                 43:2,4 44:9,10       292:17               160:8,9,10,11
  176:6 177:1        then-Local 71:23       49:5,7 53:13       thoughts 101:17        165:25 171:8,23
  179:13,14 184:14   Theoretically 32:4     59:8 64:3 70:20      142:19               180:22 183:25
  184:25 185:18      theories 259:11        74:11 90:16,18     thousands 147:17       193:22 202:2
  189:23 192:23      theory 107:22          91:10 102:8          236:22               204:4,23,23
  196:22 199:3       Theresa 240:16         104:8,16 106:4     threat 87:8 197:19     209:8 213:19
  201:5 203:5        thieves 252:1          107:23 108:10        198:8 246:5          214:6,6,12,12
testify 9:20 108:3   Thigpen 269:9,9        111:6,9,10,14      threaten 97:1          215:12 223:2,4
  118:14 141:10        270:5,7,11 271:6     114:5,6,13 117:9   threatened 7:13        225:22 226:10
testimony 8:25       thing 65:17 72:8,9     119:13 120:9         8:2 90:3 117:1       229:10 232:13,17
  22:12 41:16 43:8     72:15 91:3 93:25     121:2,5 122:8        127:2,5,23           245:19 248:24
  43:10 52:11 64:3     95:20 108:23         127:20 128:23,24     128:15 199:9         252:2 254:18
  74:9 83:20 97:16     113:1 121:21         130:1 133:5        threats 218:14,15      258:12 261:7,14
  108:19 115:4         155:1,9,22 156:7     134:6 138:18       three 24:24 30:2       263:10 264:4
  118:10 134:23        166:23,25 168:7      140:6,7 156:17       60:15 66:6 79:25     267:16 271:3
  135:20 140:8         172:24 181:16        157:7 165:9,22       81:4 87:23           275:23 280:18
  153:18 160:23        198:15 201:4         168:20 178:5         115:11 156:18        282:21 286:7,20
  169:17 177:2,18      202:7,12 206:22      180:13,16 182:17     158:15,22 159:18     287:5 289:17,21
  178:6 193:15         209:23 210:17        183:7 185:18         170:8,12,18          290:3 292:14,24
  295:8                213:11,23 216:9      189:21 191:7         180:18,25 181:19     294:15 295:6,7
Texas 3:3,5            218:3 223:18         196:3 204:4,7        189:25 209:2         295:10
thank 9:17 34:20       224:8 229:11         205:7,21 216:3       212:8 213:5        timer 207:1
  52:5,10 53:24        230:10 235:19        223:21 227:19,25     221:8 225:15       times 71:6 142:24
  61:23 106:3          236:2,3 237:22       229:19,25 230:2      227:10 252:23        146:17 147:16
  114:2,12 121:16      240:1,5 255:11       235:1 237:17         254:14,16            156:18 182:19
  121:17 147:13        257:13 261:2         240:21 250:23      threshold 35:6         212:16 223:20
  178:23 202:21        263:17,21 266:22     253:17,18,19       thrown 269:16          254:14 277:16
  203:25 204:14        274:21 290:18        254:12 262:17      Thursday 250:11      timing 28:3 145:8
  213:23 216:15        294:4                268:11,12,21       ties 108:17 212:8    tiny 66:11
  220:14 221:4       things 6:20,21 7:6     269:17,24 270:21   Tim 262:22           Tipps 40:7,8,15,18
  222:22 225:22        28:9 47:7 77:19      273:5,24 274:2     time 6:9,11,15         44:2,5,6,13,25
  227:12 228:13        78:7 81:6 84:14      275:5 278:21         11:23 15:10        tired 208:18
                                                                                          Page 335

  242:21               196:12               184:20 240:8         90:23 91:3,6,10      140:8 141:17,21
Titanic 262:2        top-appointed        treasurer 57:19        94:8 104:23          143:3 155:6
title 13:16,17         243:24               59:15 63:23          105:10,14,18         189:2,9 209:20
  30:17 40:12        top-down 98:9          195:23,25 196:3      108:18 112:24        233:10 243:20,20
  182:18,24,25         148:21 252:4       treasury 130:2         117:2 119:1          258:24 259:15
titled 13:19 15:1    Torianto 211:1         151:18 153:10        120:13 121:12        268:8 271:15
titles 266:7           213:25             treat 239:17           123:21,23 124:2      286:25
today 6:10,17 7:14   Torres 229:21        treated 168:22         124:10,21 127:2    Tuesday 37:19
  36:19 40:24        tossed 230:20          249:17 263:25        127:5,19,23        tuning 49:20
  41:16 43:8,10,15   total 92:15          trenches 245:13        128:2,15 129:19      50:16
  76:19 105:21,24    totally 260:13       trial 245:15           130:6 132:21       turkey 208:15
  112:13,15,20       touch 211:24         tribunal 109:4         134:18,20,21       turn 20:18 24:14
  114:16 148:8       tough 238:5          Tribune 265:10         135:4 137:11,12      30:2 37:14 40:5
  165:17 177:19      tour 241:7 257:5     trickle 259:11         138:5 141:11         43:23 78:14 81:9
  221:9 233:25       track 94:7 245:10    tried 31:19 92:21      142:19 144:19        82:15,17 84:24
  235:5,12,22        trade 277:5            92:23 93:22          148:8,10 199:9       87:4 89:8 91:21
  244:10,18 245:7    trades 102:21          105:15 109:14        199:11 211:13        98:22 101:7,25
  259:14,21 263:18     212:10               221:14               212:11 214:5         103:19 106:20
  264:7 265:8,14     tragedy 128:9        tries 95:6 149:19      219:13 220:7,12      123:3 124:15
  266:23,25 272:14   trail 152:17,23      triple 102:6           220:22 222:10        127:4 128:20
  283:5                153:4,7            trips 274:12           230:14,23 232:4      130:8 136:13
togetherin 39:3      trained 256:23       Trister 49:8           234:1 246:10,11      137:15 147:14
told 7:20 34:10      training 168:1       trouble 7:17           261:2 262:4,25       163:7 197:12
  41:7,15 42:1,8       172:1 248:13         253:10               272:23 274:17        198:2 259:15,21
  42:16 43:1         trains 277:9         troubling 128:3        275:2 280:3        turned 107:8
  105:22 116:20      transactional        Troy 247:5             281:24 284:16,21     286:14
  121:4 159:9          97:6,12            true 35:2,12 41:18     285:4 286:18       turning 29:21
  202:16 204:17      transcribed            45:7,14 46:1,15      294:13               218:4
  205:17 206:10,14     295:11               46:25 93:15        trusteeshipped       turnover 82:4,6
  215:5,14 223:20    transcript 1:7         170:17,21 171:18     282:24             tweaked 47:9
  223:20 237:15        2:20 4:2 295:13      180:11 186:19,21   truth 215:5,11,14    two 1:10 10:4
  241:5 244:21       transcription          201:19,20 203:20     227:11,12 260:18     11:14,17 13:11
  257:12 258:20,21     276:15               222:14 237:23        260:18 291:15        13:14,15 26:18
  259:6,8 264:19     transcriptionist       293:16 295:12,18   try 14:24 49:19        31:3 32:7 52:12
  265:8 268:22         276:14               296:6,10             50:15 67:16,23       61:11 62:12 65:1
  279:2 288:5        transfer 117:19,23   Trujillo 226:15        68:2 104:25          66:5 70:8 74:3
tolerated 128:4        136:12 150:11      truly 214:21           109:3 113:10,20      75:4 95:7,17,21
tomorrow 69:5          152:18 176:13      trumping 231:17        114:22 119:4         97:23 105:1
  210:6 276:10         183:2 184:3        trust 44:22 187:14     120:14 121:22,23     109:21 113:5,6,9
Tonia 228:22           186:4 188:6          249:1 263:15         129:15 131:20        114:18 115:11
tonight 210:5        transferred 83:21      275:16               134:3 139:5          116:16 127:20
  259:17 282:15        164:3 174:10       trusted 233:1          144:12 149:24        144:23 147:9
tool 76:23             185:14,23 188:2    trustee 197:19         171:6 182:15         156:18 161:8
Toomey 262:22        transferring 132:2     198:8 199:16         183:17 199:16        163:24 169:12
tooth 279:5          transmitted            224:9 264:22         222:4 243:25         180:4 189:24
top 21:5 25:16         133:14             trusteeing 224:5       258:4                202:13 204:11,18
  37:12 83:17        transparency         trustees 188:12      trying 27:25 32:5      207:1 211:21
  89:25 90:8 92:6      46:14 148:24         188:12               32:22 39:23,25       223:21 226:11
  107:16 129:25        185:2,9 187:6      trusteeship 70:8       70:6,8,14 72:18      230:19 232:6
  149:8,18 150:17      189:24 190:4,15      79:10,14,17,21       72:20 108:9          233:10,20 248:12
  152:12 164:25        229:2,4,6 241:2      80:2 86:18 87:1      116:12 118:6         248:16 250:6
  290:20               252:14 264:8         87:8,24 89:6         121:7 134:5          251:17 255:18
topic 102:18 151:7   transparent            90:3,6,14,16,18      137:6 138:11         258:8,11 260:7
                                                                                     Page 336

  262:17 266:21      141:15 144:4,7       287:25             Unethical 124:6     161:6,15,17,18
  270:18 279:10,12   146:7 148:7,20     UHW's 37:9,12        unfair 19:22        161:19,20 164:23
  281:3 284:23       148:24 149:3,7       59:9 63:6 65:4     unfortunately       166:24 167:8
  286:17 290:7       149:17 150:17        65:14 66:22 67:1    200:14 267:3       168:11,12,18
  293:1              152:12 156:10,13     81:11 90:17 91:7    271:12 289:7       169:3,14,14
two-person 66:7      160:6,23,24          124:24 129:24      unfounded 116:23    171:15,17 174:6
two-thirds 18:7,9    161:11 162:14        152:16,22 153:10   unhappy 277:6       180:7,23 181:8
  18:12,16           163:4 164:1,24       176:25 179:3       Unhealthy 102:2     182:19,20 183:10
two-year 16:20       169:13 170:4,15      189:23 273:20      UNIDENTIFED         185:1,5 186:15
tying 39:25          170:19,25 171:14   UHW-PEF 161:2         236:13             187:4 189:11
type 83:5            172:20 173:1,16    UHW-W 9:4            unidentified        190:6,15,17,22
types 17:13          173:25 174:5       ultimately 31:23      42:25 250:9        191:4,9,10 192:2
Typically 196:14     176:6,21 177:5       45:5 98:19         unification 63:11   192:14,25 194:21
typing 244:7         177:19,24 178:11     291:23              179:6,20,21        194:23 195:13
typo 163:21          178:21 179:16      umbrella 100:22      unified 280:12      196:18 197:18
tyranny 260:13       183:3 184:3,15     unaware 164:17       unimportant         198:3 203:14
Tyrone 109:13        195:23 197:4       uncalled 188:25       193:6              205:21 206:20,24
  110:10,16 135:23   199:4 200:10,16    uncle 57:24          uninsured 11:8,25   207:8,9,10
  146:13,16,20       200:17,18 201:17   undemocratic          12:1,6,9 33:2      208:16 209:18
  147:22 148:9       205:16 207:7,15      126:6               75:19              212:8,9 213:17
  208:10 252:1       211:8,22 212:11    undermine 126:17     unintelligent       214:10 215:8,23
  259:24             212:18 213:13      undermines 90:25      227:25             215:25 216:5
                     214:6,25 216:18    underscore 266:6     unintelligible      217:4 218:11
        U            216:18,24 218:17   understand 23:3       127:24 208:13      219:4,15,23
UAW 276:22           220:6 221:11,19      40:23 65:20 77:8    236:25 260:3       220:6,20 221:15
UCLA 12:7,24 13:1    221:20 222:6,15      79:21 105:23,25     261:7,9 273:7      222:11,13 223:16
UHW 49:3,13          223:9,13 224:5       108:7,21 112:23     281:19,20 287:24   225:3 226:23,24
 57:10 58:4,8        224:25 225:1,4,6     114:9 118:5        union 3:11,19       227:3,4,23 228:1
 59:6 60:8,24        225:7,16,18,19       119:3 124:1         44:14 55:1 57:21   231:5 232:21
 61:3,12,13,24       225:23,24,24         135:4 136:3         58:24 60:10,14     235:21 237:4,5
 62:3,15 64:6,13     226:2,6,8,9          139:16 168:3        60:22,25 61:5,7    237:14,16,20
 65:21 66:2,24       230:12,14,17,18      177:17 179:18       61:10 62:20        238:9,11,12,22
 68:23 69:23 70:2    230:21 231:5         188:15,19 189:5     64:14,19 66:25     239:11,16 242:22
 70:17 71:18         232:2,11 233:4       189:11,17,19        69:8,20 73:19,23   243:20,21,23,25
 76:11 77:24         235:4 236:14,18      190:11 209:16       73:24 77:3,9,10    245:23,24,24
 79:12,18 83:21      236:23 237:20        230:23 231:17       79:20 85:8,20      246:21 247:15,16
 85:6,6,7,19,22      241:10 242:1         234:8 243:1,21      86:6 89:16 90:21   247:19,20,20,21
 86:17 90:19         243:4 244:11,23      256:11,13 258:19    91:16 92:5,13      247:23 248:5,11
 93:19 94:15         248:5 251:15         258:23 259:1        95:5 98:6 100:6    248:11 249:12
 95:19 96:5 97:14    253:21,23 254:1      269:19 270:16       100:12 102:2,3     250:1,2,6,20,22
 97:18 98:20         255:8,9,10,12,16     273:22 285:1        109:14 110:19      253:18,19 254:20
 103:2,2,5,12,12     255:22 256:7         293:16,17           119:24 121:13,23   254:21 255:3,8
 103:16 105:15       257:20 261:21      understanding         122:20 124:7,25    256:7 257:1,23
 117:16,18,24        263:10 264:19,22     51:23 117:10        125:2,4,8,10,23    257:24 258:14
 123:14,23 124:13    264:23 266:4,5       143:1,6,8,10        125:24 126:1       259:12,15 260:5
 124:20 125:1,21     266:14,19 267:6      154:13 292:18       130:23 131:1,4     260:22,25 261:25
 125:23,24 126:13    267:12,17,17       understands           136:8,11 146:22    262:3,12,23
 126:18,22 127:19    270:25 271:15        140:13              147:17 148:22      264:8,15,18,22
 128:2 129:22,25     272:6,11 273:22    understood            149:7,19 150:7     267:4,9,11 268:7
 130:1 133:17        273:24,24 279:10     130:22 141:12       150:15 151:7,9     270:13 271:13,16
 134:19,20 135:12    279:18 280:25        167:15 180:21,24    152:18,19,24       271:22,24 273:11
 135:22 136:12,24    281:6 282:1,4        188:1 193:15        154:1 155:24       274:25 275:11,12
 136:25 137:6        284:20 285:4       undertaking 72:1      156:4,5,7,21       275:14,15,16,21
                                                                                         Page 337

 276:7,23 277:2,4     162:15 163:24               V             60:17                267:7
 277:9,18,22,25       166:7              vacation 223:1,3     Vicki 63:21          volunteered
 278:20 279:13      universal 10:13,21   Vague 150:2          video 6:5 294:4        195:19
 280:1,2,21 281:1     11:11,16 13:20     valid 17:16,18       videorecording       volunteers 80:9
 281:2 282:1,4,5      14:18 15:2 26:5      145:12,22            112:4                193:17
 282:12,13,20,21      26:7,17,22 27:6    validate 29:18       Vietnam 260:7        vote 18:7,9,12,16
 282:22,25 283:6      32:23 33:4,6,14    Vallejo 222:24       view 27:20 28:25       21:22 22:11,18
 287:4,19,20,21       47:3 257:8,16        267:23               41:21 98:20          22:20,23 23:4,4
 288:25 289:16        272:1              Valley 253:13          103:2,5 113:16       23:10 24:9,20
 290:10,17,23,24    University 3:3       valuable 36:23         128:6 155:1          62:12,13,19,20
 291:4,5 292:16       9:24 12:8,22         254:10               180:15 190:14        80:8 110:7,11,18
 292:18 294:9         56:9,11            value 17:24            219:11 225:24        179:18 206:10,15
unionism 252:4,5    unlawful 129:23      valued 128:4         viewed 44:8 128:3      206:16 217:5,5
 271:9,17 277:5     unnecessary            236:18               286:23               224:15 247:20
unionization          85:19 119:22       values 184:15        views 22:7 42:10       258:1 284:17,18
 248:4              unorganized            226:3                51:21 97:14,16       284:19
unionized 280:18      69:18 87:20        Van 222:17             97:21 108:16       voted 24:22 62:7
unions 56:18          100:10             variety 58:25          291:10               62:21,22,25
 62:12,19 66:17     unprecedented        various 13:5 17:12   vilify 222:12,15       63:13 64:1,2,7
 69:10 133:13         69:7                 19:18              violate 183:23         64:10 78:12,16
 161:23 213:4,22    unprofessional       Vasquez 224:21         184:4                179:19,24 181:2
 248:6 274:20         188:25             Vazquea 242:14       violating 42:4,18      181:7 182:5,8
 277:10 281:14      Unsafe 82:7          Vazquez 240:17         43:21                183:5 200:2,10
 286:22,23 287:1    unspent 85:7           242:13             violation 110:25       232:19,20 238:19
 287:17 292:16      unspoken 102:23      veering 133:23       violence 257:4       voters 18:15 29:13
union's 57:14       unstable 209:17      vehicle 160:1        violent 257:1          30:10
 101:17 130:2       untrue 271:1           177:8 180:5        virtually 18:25      votes 18:11,11
 151:18 169:2       unusual 22:19,21       194:25             virtue 59:7 106:10     23:6,8,9,10,23
 180:19             unwound 85:13        vendetta 250:15      visible 35:24          24:2,4,6,12,23
union-based           105:17               254:20 284:2       vision 98:3,7          260:16 268:20
 247:15             upgrade 166:20       venues 167:4           99:18 100:10       voting 22:9 23:10
union-employer        168:2              Veracelli 289:3      visions 98:1 99:7      63:12
 166:12             uphill 24:13         verbatim 99:12       visiting 66:6
union-funded        upset 207:23,24                           voice 68:9 69:14             W
                                         verge 258:18
 166:15             Upstream 13:19       Verizon 268:15         75:22 98:20        wage 68:4 70:23
unit 92:16 224:14   urge 6:16 7:3        Verna 229:19           100:9 103:2,5       71:13 94:4 95:11
 282:9                118:20 128:8         233:13,15            160:7,12 161:2      255:16
united 1:4 2:4        131:20 220:11      version 25:20 93:2     196:22,25 197:6    wages 67:16
 4:10 11:16 55:17     237:17 239:25        181:14 182:11        198:14,15 215:18    90:22 93:12 94:4
 57:19,22 76:6,10     272:4,4            versions 96:16         215:19 228:3        214:25 226:4
 78:17 82:19 85:2   urgent 100:9         versus 178:21          243:22 246:24       236:19 243:2
 95:10 127:11       USC 11:22 12:7       very-well 128:17       247:17,21 248:8     255:15,17 262:18
 136:10,22 203:3    use 41:9 119:24      vested 182:19          248:9,10,14        wait 55:12 90:14
 230:18,22 243:22     138:4 146:22       vetoed 76:19           267:24,25 283:1     107:21,21,21,21
 255:21 260:8         153:24,25 155:16   viable 267:5,12      voices 274:25         141:4,4,4,4
 265:6,18 288:21      159:14 171:25      vice 57:13 58:3      voicing 108:15       waiting 225:16
 288:23               182:20 241:5         59:1 60:19         Volume 1:10           245:6,21 255:13
Unity 5:4,5,6         248:13               107:17 142:11        154:6 163:1,2,4     278:9 281:23
 156:10,13,25       usual 233:13           148:2 149:20,22    voluntarily 122:24    286:1
 157:4,11,14,19     usually 22:23 25:7     150:10,16 265:5      135:10             waive 110:16
 157:20 158:15,19     30:17 73:2           290:21             voluntary 61:1       waiver 110:10
 158:20,22 159:19     163:22 268:25      vice-chair 12:2        80:17              Wales 243:9
 160:1 161:8        U.S 270:3 277:17     Vice-President       volunteer 191:2      Walker 251:12,14
                                                                                     Page 338

wall 25:12           269:5,25 272:12     183:19 216:24       200:24 201:1,3      119:18 159:22
wallet 249:10        273:25 274:22       249:12 272:13,16   websites 161:8       162:13 167:5
Walsh 56:7           276:16 277:7,15     280:21              163:25              170:2 202:5,9,20
Walter 4:5 8:8,11    277:21 278:12,14   waste 205:19        Wednesday            204:4 205:1
 8:20,21,23          279:24 282:5,23    watch 252:13         247:14 250:11       228:13 230:17
Wal-Mart 187:20      282:24 283:5,7,8   watchers 23:21      week 33:9 88:17      250:23 279:5,6
want 10:25 20:14     285:15,16,17,18    watching 270:22      94:22 264:12        292:24
 25:11 29:4 45:23    285:21,22,25        270:22,23 291:18   weeks 81:4 87:23    we're 6:15,22
 49:12 51:2,5        286:4,13 287:4      293:4               266:21              16:23 38:13,13
 52:12,14 53:2       290:10,25 291:5    Watsonville         weight 53:14,16      39:2,10,14,15,17
 54:13 61:18 64:4   wanted 6:18          252:23              53:16               39:19,20,22,23
 67:17 70:10,10      20:20 22:17        wave 207:2          Weintraub 101:11     39:24 42:20
 77:23 80:9,12       41:10 78:9 79:12   way 18:5,13 19:9    Welch 251:8          48:22 61:5 62:1
 81:5 86:7 91:5      80:17 83:15 97:4    31:7,15,16 34:13   welcome 113:18       70:6,14 72:18,20
 104:4 105:25        112:3 113:14        42:12 73:5,25      welfare 85:21        75:13 76:21
 109:3,5 113:4,5     180:3 203:25        74:1,19,19 75:17   well-founded         79:25 90:4
 113:10 114:17,17    204:11 207:8        76:5 77:18 82:12    199:23              102:15 104:8,9
 114:22 115:3,5      217:1,3 221:9       84:7 93:25 94:13   well-respected       104:11 105:21,24
 118:7,8 121:9       223:1 227:24        97:25 98:10         207:12              108:9,16,21
 127:4 139:16        228:10 229:10       100:3 104:10       went 11:14 14:16     109:11 112:1,14
 142:1,6 146:2       248:8 249:3,13      108:5 109:9         22:16 23:20 75:4    117:12,13 118:5
 147:12 171:25       249:25 254:24       110:25,25 113:20    96:17,22 146:14     119:8 120:8,11
 172:9 180:24        256:20 257:15,17    113:24 114:13       146:24 166:3        121:7 125:7,13
 188:24 189:5        264:14              118:7,11 119:8      175:10 194:1        129:13 132:11
 202:19 204:11      wanting 252:20       121:14 125:3        232:4,24 250:3      134:4,5 138:4
 206:14,25 207:7     283:6               134:7 138:9         250:11 252:18,19    141:17,21 158:11
 207:14,21 208:2    wants 88:3 157:4     141:22 155:17       253:9 256:19        158:12 170:22,23
 209:9 214:3         193:25 194:3        162:15 164:7        257:5,7 259:6       178:19 181:15
 216:2,19 218:3      215:24 216:7,8      166:11 168:3        262:8,17,25         184:12 201:6
 219:12 220:10,11    220:6 235:8         171:4 179:18        264:11,20 266:15    202:3 204:16
 220:21 222:4        260:16 284:19       180:10 188:1        286:17 287:11       206:20 207:11
 223:8,18 224:8      293:21,21           193:16 202:3,4      289:2               209:13 213:8
 228:12,15 229:9    war 211:23           204:16 206:23      werea 274:1          215:9 216:1
 229:16 230:14,23   Ware 165:10,16,17    213:1 219:11       weren't 84:23        217:12,17,17,18
 231:16 232:22,23    166:4,11,18,22      221:1 236:23        100:14 107:7        218:8 221:20
 233:5 234:24        167:7,10,24         242:1 253:20        117:20 178:15       222:7 224:2
 236:2 238:11        168:10,13,25        254:22 263:1        217:2 257:5         228:9,9,10
 239:19 241:23,25    169:20,24           264:22 267:19      Wesson 228:20        229:12,13 231:19
 241:25 242:9       warranted 137:13     272:7 273:2        west 64:16 67:8      235:3,5,11,12
 243:22,24 244:1    Washington 3:17      282:2,6 285:13      71:5,5,7,10,25      240:8 241:17
 244:6,7,10,11,16    3:22 11:14,17       288:13 292:7,9      82:19 85:2 94:17    243:2,4,4 245:13
 244:16 245:1,9      126:8 233:21        292:19 294:15       127:12 197:19       246:8 252:5,11
 245:20,20 246:17    237:7 238:1,1      ways 77:13 97:9      198:8 218:13,13     253:22 255:21,21
 246:23 247:24       240:11 244:13      weakend 137:4        235:4 278:5         256:23 258:18
 248:11,16 249:11    253:19 269:3,4,4   web 198:3           West-type 96:12      259:4,9 260:12
 251:15,25 252:4    wasn't 24:5,8,9     website 25:22       we'll 6:11 8:7       260:12,16,19
 252:5 253:17,25     25:6 44:22 46:17    26:11 29:21         25:17 30:11 49:2    261:25 265:25
 255:22 256:10       47:25 93:25 99:9    54:24 126:17        49:19 50:15         267:17,18 271:17
 257:8 258:11,21     119:17 122:14       141:16 146:21       52:17,17 54:4       272:25 280:4
 258:22 259:1,2      138:10 140:10       160:3,6,15,17,24    111:22 112:18       281:21,25 282:4
 263:17 266:2,3,3    161:1 164:20,21     161:2 165:16,16     113:1,10,12,20      287:12 291:1
 266:11 267:12,25    173:6 178:5         165:18,22,24        114:23 115:1,5      293:18
 268:1,6,6,10,16     180:7 181:3         166:4 172:17,21     115:12 118:11      we've 68:1 69:3
                                                                                      Page 339

 72:24 75:21         145:25 157:5,8,9    251:18 262:10      worst 89:15 216:8     65:25 67:3 69:2
 87:16,21 88:14      157:24 159:13       265:7 266:19        262:11 280:12        73:15 76:5 78:15
 91:12 94:10,11      167:18,20 173:4     280:17 282:10      worthy 187:14         78:24 81:11,16
 96:20 98:17         173:4 189:22        289:12,22          wouldn't 26:14        83:24 88:1 89:13
 119:18 121:21       191:7 195:3,7      worker 60:25         42:1 131:5           92:4 93:10 94:10
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 193:22 200:23      witnesses 4:4,10     266:14 269:10       188:14,22 206:14     114:21 115:2,3,7
 202:4 206:21,22     7:2 22:4 97:18      279:9               219:5 253:1          118:3 122:2,12
 216:21 238:14       109:6 202:10       workers 57:20,22     272:13,16            129:10 142:25
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 249:1 256:14       won 68:23            64:24 68:23        write 30:21 32:5      146:8 152:2
 271:11,17 273:2    wonderful 164:22     69:18,20 71:2,5     113:19 133:14        153:3 154:2
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whistle-blowers      157:10 192:14       77:1,3 78:17,21    writes 125:11         161:15 163:2,21
 289:6,8             259:23              82:19 85:2 92:18    142:18               165:9,19 169:11
white 81:18 83:1    words 17:21 25:8     93:1 94:15 95:8    writing 25:11         170:11 171:22
 84:9 154:5          26:1 38:21          95:10 97:4          127:22 171:9,12      172:4,18 177:10
 162:25 232:16       205:20 284:22       100:10 101:17,22    230:2                179:25 181:22
wholly 117:17       work 6:7 58:6,7      102:22 127:11      written 6:17 20:5     182:14 183:13
Wicks 251:6          64:22 66:11 73:6    128:7 136:10,21     26:12 30:19 60:2     185:13 186:19
wife 249:21 250:5    81:20 82:4,8,20     136:25 137:7        113:18 137:12        188:8,19 193:20
Willard 280:15,15    84:8 88:17,25       154:15,17 205:22    151:16,24 152:1      198:24 205:16
Williams 230:7,7     90:24 92:12,25      212:10 220:24       152:4 154:14         225:24 226:3
 234:18              93:18,21 96:9       221:3,25 245:12     220:18               293:19
willing 18:10        97:3 100:8,25       263:19 288:24      wrong 15:10         year 10:14 12:22
 70:11 73:1          101:2 112:13        289:15              132:4 200:15         13:13 26:6,15,18
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 268:10              153:21 205:20       1:4 2:4 3:6 4:10    234:1 235:19         39:17 40:1 44:15
willingness 27:8     207:24,25 210:22    55:17 203:3         248:17 261:2         44:15 47:8,8
 27:10               212:23 213:16       265:6,18 288:21     275:16 281:16        73:14 74:5,5,10
Willner 218:24       215:16,20 219:2    working 11:13        285:21 288:3         74:15,22 76:16
 220:16,16           220:21 222:24       29:20 33:19 38:5   wrongdoings           101:18 155:13
Wilson 217:23        223:13,16 236:14    38:12 56:23 57:1    278:16               156:18 180:18
 219:2,2             237:5 242:6         57:10 64:21        wrongly 235:5         207:16 210:6
win 69:8,10 71:6     244:6 248:20        73:16 90:22        wrote 8:2 11:17       211:17,20 212:2
 71:11 75:9 94:5     249:9,24 254:17     91:17 94:22 98:5    56:15 171:5,15       212:6 229:3,5
 98:14,15 206:4      255:18,23 262:8     100:6 209:20       www.depo.com          239:6 241:4
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 288:8               265:22,24 267:23    253:24 267:19                            266:5 271:12
Winter 5:6 158:7     272:6,10 275:10     271:24 272:1                X            272:19 277:8
wish 249:18 250:6    276:5,17,18         275:19 283:4       X 4:1 5:1 15:11       286:2
witness 7:24 8:8     278:4 281:20        285:12 294:10,11   X-ray 256:17        Yeargin 211:1
 8:12,25 9:5,7       283:3,12,21        workplace 276:5     X-1 15:15             213:25 214:1
 37:9 42:24 48:25    285:13,18 286:2     276:6 283:4                            years 11:14,21,22
 52:8 54:1,9         287:12 289:2        285:17 288:6,7             Y             12:13 13:5 26:8
 55:13,16 65:8,10    290:5 294:22       works 29:3 223:9    Y 3:4                 26:17 66:13 68:1
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 116:11 118:13,17    11:22 35:22 72:6   world 135:4         yeah 43:25 53:18      74:6,8 94:3
 134:6 135:9,9,12    74:2 96:20          209:23 266:1         56:5,22 57:6        95:21 165:19
 139:11 140:16       207:16 212:3,6      272:18 281:14        59:7,12,19 60:1     180:18 205:16
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                                                              63:10 64:7,12
                                                                                         Page 340

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  225:15 226:23,23   $1.5 110:13 116:8     267:8,15             282:11,12                   2
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  232:1,3 233:15     $10 189:12            125:22 127:15        150:13 151:5         114:8 115:25
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  262:10,12 265:7    $25 207:15,17        105 130:8,10          172:13 183:1,16      129:23 226:23,23
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  276:21 280:17,19   $3 129:23 177:24      137:17 227:22,23    1800 3:22           20th 84:5 176:2
  280:20 282:11,12    183:10              11-hour 22:3,15      1877 116:6 122:18   200 65:22 72:12
  285:12 286:12      $5 125:6 185:24      11-member 23:8       19 10:22 77:23      200,000 258:18
  288:23 290:6        186:6,22            11:15 264:4           258:7,13 285:12    2000 69:12 72:4,7
year's 47:14         $6 78:16 150:6,12    1100 273:21          19th 150:13 151:5     74:6
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  260:4               151:17 152:13,18     139:10,15            153:15 154:9       2001-2002 93:15
yesterday 6:13        152:21,23 153:1     116 136:13,14,15      155:11 157:1,21    2002 34:25 73:18
  7:6,8 8:5 49:5,7    153:9 164:3,23       136:16,17            163:16 164:2       2002-2003 248:3
  64:4 97:16          165:13 166:1,11     1199-P 57:2           171:20 172:2       2003 96:3
  108:20 116:20       169:23 170:1         142:12               183:1 184:1        20036 3:22
  134:23 135:9,20     177:22 183:3        12 12:13 60:19        185:11 191:19      2004 62:6,11 72:8
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  259:3,5 264:5,6     185:12,14,19,19      92:19,24 93:8,20    1930's 56:18 61:6     136:19,20 171:4
yes-no 192:11         185:22 186:4,10      211:17               72:19 276:23         179:16 180:2
yes-or-no 167:16      187:2 191:22        121R.N 92:18         1939 233:22           183:5
Yolo 219:3            192:15 194:7        122 89:8             1940's 57:22        2004-2005 61:11
York 10:11 14:20      196:9 208:23        129 147:14,16         61:10 72:20        2005 3:17 47:15
  209:16 223:20       250:12 253:4        14 78:14 288:22       276:23               47:16 48:4,8,8
Yvette 7:21          $80 65:5,8           148 4:15             1960's 88:22,23       48:14 225:8
Yvonne 236:7         $81 65:5,8,16,16     15 73:17 104:1       1969 262:9 288:22     232:2 283:13
y'all 209:12         $9 95:11 196:4        106:25 238:8        1973 262:15         2006 48:20,20
                                          15th 57:7            1974 262:14,22        226:8 280:25
         Z                    0           150 30:3 137:16      1977 10:22          2006-2007 97:2
Zaqaunou 236:10      0 210:23             150,000 61:14        1979 267:13         2007 5:4,5,6 10:9
Zelman 4:5 8:9,11    08 17:22              191:14,22 233:21    1980's 56:19          10:23 14:3 15:7
  8:20,23,24 9:10                         150-day 17:16        1982 31:16            16:2,14,16,21
  34:21 36:24                 1           158 5:4,5,6          1986 31:17 263:1      21:24 74:10
  37:11              1 20:16 30:20 99:5   16 98:22,24 99:1     1988 289:2            76:11 77:23
Z-E-L-M-A-N 8:20       114:7 154:4,6       136:14 147:21       1989 287:6            79:16 80:1,23
  8:23                 296:5               148:12 174:23       1990's 11:8 71:20     87:13 92:2 99:5
                     1st 137:8             282:12              1993 11:15 57:4       101:4,5 103:6
        $            1,500 189:4          16th 82:25            142:14               104:1 106:13,25
$1 96:21 146:23      1-866 267:9          17 106:13 275:11     1994 11:15            107:3 115:25
 167:9 168:12        10 138:21 184:19     17,2005 48:4         1996 57:7,9 71:23     135:24 155:11
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 174:14 175:7,17       188:3,3,12         173 49:4,5,7,11,13   1998 34:25 165:23     158:7 160:3,9,20
 175:21 185:23         189:13 190:5,7      49:16 50:8,11        165:24 166:4         161:12 162:21,23
 186:6,22 187:3,4      190:17,18 193:16   174 49:3,4,9          248:23               164:2 170:14,22
 187:11,15 188:9       194:5,10,18
                                                                                          Page 341

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                                          510 3:13             76 5:4 48:6 158:5

				
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