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1 JOSEPH L PALLER JR. (SBN jlpaller@gslaw.org ROBERT A. CANTORE (SBN rac@gslaw.org MICHAEL D. WEINER (SBN mweiner@gslaw.org GILBERT & SACKMAN, A LAW CORPORATION 3699 Wilshire Boulevard, Suite 1200 Los Angeles, California Tel: ( Fax: ( Attorneys for Plaintiffs UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA MICHAEL McCARRON, an individual, MICHAEL OLDS, an individual, and LINDSEY MALDOON, an individual, v. Plaintiffs, U N I T E D B R O T H E R H O O D O F CARPENTERS AND JOINERS OF AMERICA, an unincorporated association, DOUGLAS J. McCARRON, an individual, DOUGLAS BANES, an individual, and MICHAEL V. DRAPER, an individual, Defendants. Case No. 8:13CV1559 JVS ANx DECLARATION OF MICHAEL OLDS IN SUPPORT OF EX PARTE APPLICATION FOR TEMPORARY RESTRAINING ORDER AND FOR ORDER TO SHOW CAUSE WHY P R E L IMINARY I N J U NCTION SHOULD NOT ISSUE DECLARATION OF MICHAEL OLDS Case No. 8:13CV1559 JVS ANx

leclaration 2 1, Michael Olds, say and declare as follows: OF MICIIALL OLDS 3 1. I am over 1 8 and am a party to this action. I have personal knowledge 4 facts stated herein and, 5 facts. 6 2.

2 leclaration 2 1, Michael Olds, say and declare as follows: OF MICIIALL OLDS 3 1. I am over 1 8 and am a party to this action. I have personal knowledge 4 facts stated herein and, 5 facts I began working as a 7 Carpenters and Joiners 8 my 9 tools delegate if called as a witness I could and would testify competently to those America carpenter in 1970, joined ( Carpenters in 1973, and (i.e., as a carpenter until I have been an elected for Local Union 61, United Brorhood Carpenters and 10 ( Local 61 since In 1990, I was elected as Financial Secretary United Brorhood continued working with ficer and council Joiners America In 1984, I was employed by Contract Administration Trust, a 13 sponsored by Carpenters and its councils to police collective bargaining 14 At time, Local 61 was in Orange County District Council In 1990, I was 16 District Council by its n hired Executive as a Business Representative Local Union Carpenters. program agreements. for Orange County Secretary, Bill Perry. In November 1991, 17 Orange County District Council merged with Los Angeles and 18 Council to eventually 19 Brorhood become Carpenters Southwest Regional Council and Joiners 20 McCarron ( Doug was elected as merged 21 Treasurer and chief executive ficer and I was Vicinities District Carpenters, United America ( Regional Council. Douglas organization s transferred first Executive Secretary- to its payroll In 2010, Doug s bror, Michael McCarron ( Mike, position 24 been elected as promoted me to an Administrative Assistant to Regional Council. At time, Mike had Regional Council s Executive Secretary-Treasurer, Doug s old 25 position. Administrative Assistants are essentially team leaders for [Business?/Special?] 26 Representatives employed by Regional Council. I also am an elected member Executive Committee Regional Council, a position I have had since beginning DECLARATION OF MICHAEL OLDS

6. Like any political entity, Carpenters arc full 2 and factions do not always get along or fight fairly (think 3 do not always agree with policies set by Carpenters 4 Doug s leadership, and union

3 6. Like any political entity, Carpenters arc full 2 and factions do not always get along or fight fairly (think 3 do not always agree with policies set by Carpenters 4 Doug s leadership, and union meetings with se factions 5 spirited. various political factions, Congress. These factions in Washington, D.C. present 6 7. I met with Doug on July 13, 2013, and spoke to him again on 7 on morning under ten become highly telephone July 15, 2013, concerning internal charges Regional Vice President 8 Michael Draper ( Draper had filed against Mike, seemingly at Doug s request. During 9 July l31 meeting, I told Doug that I could not 10 against Mike. Doug initial response was, How do you 11 makes me sick, but I m staying out 12 believe it now. During this conversation with Doug, I 14 step in and put a stop to charges against Mike. I 15 Carpenters do when we have problems - 16 public scorn. I cautioned Doug that charges 17 throughout believe think that charges had been filed I feel - he s my bror? It it. I didn t believe statement n and I don t we repeatedly told him that he needed to reminded Doug that this is what fix m; we don t hold one anor up to against Mike would have an adverse effect Carpenters, as factions who already did not trust him and rest 18 Carpenters leadership most Doug 20 read 14D responded charges? I certainly will run with to my replied concerns that, I 21 charges. Doug n asked me about a memo issue. by saying, This is very serious, have you have had discussions, but regarding have Trust Funds not read purportedly 22 written by Curtis Conyers, a management trustee. I again told Doug that I have had some discussions concerning it, 24 memo, which I did not but had not read memo. Doug handed me a copy believe Conyers wrote I asked Doug how Mike personally benefitted from higher lease rates to 26 Training Fund, to which Doug responded that, Maybe he didn t, but Council did. 27 I pointed out that we were talking about less than a million dollars a year over a 5-year 28 period, which Doug and I both knew was a very small portion Regional Council s DECLARATION OF MICHAEL OLDS 2

1 receipts for same period. Doug s response was something to effect that having 2 more money makes Council stronger and that Mike came up with lease rates on his 3 own (which I knew not to be true.

4 1 receipts for same period. Doug s response was something to effect that having 2 more money makes Council stronger and that Mike came up with lease rates on his 3 own (which I knew not to be true Doug n said that Mike is out control - he needs to resign. Doug 5 claimed that, due to over-payments, Training Fund had to make program cuts, 6 eliminate classes and lay f instructors because Training Fund did not have enough 7 money in its budget. This hurt our members. This is very serious, Doug said, and I am 8 going to do my best to keep Mike out jail. 1 couldn t believe what Doug was saying 9 and thought it was ridiculous pointed out that procedure for establishing rates for Training Fund s 11 leases had been carried over by Mike s administration from past administrations, including 12 his own. I pointed out that Regional Council is much larger geographically than when 13 he was Executive Secretary-Treasurer and now covers six states and ir training centers. 14 I also reminded him that his own Director or Real Estate, Randy Sowell, advises 15 Regional Council on all real estate issues, including Training Fund leases. I n told / 16 Doug that, once property appraisals were completed, Mike presented results to 17 Executive Committee which I am a member with a recommendation that Regional 18 Council repay excess rent to Training Fund with a higher than market interest rate 19 and that Executive Committee adopted Mike s recommendation I explained to Doug that, when Executive Committee, including Mike, 21 found out that our procedure for establishing lease rates was inappropriate, we made 22 correction and changed policy going forward. I n pointed out that Regional Council had between 120 and 150 million dollars in bank and didn t really benefit from an extra 24 million a year. Doug s response was, It makes council more powerful. This 25 response did not make any sense to me I pressed Doug, telling him that Mike is arguably best executive secretary 27 in our organization, and that our council is probably most successful. I argued that 28 success our council was due to Mike s leadership, so why should he resign? And I DECLARATION OF MICHAEL OLDS 3

I asked how would Mike s 2 keep him out jail. 3 15. Doug (who had 4 conversation and asked 5 suite throughout resigning change anything?

if told me earlier that he was staying out it shifted I knew that Mike had installed security cameras in every fice building, without permission from tenants.

5 I asked how would Mike s 2 keep him out jail Doug (who had 4 conversation and asked 5 suite throughout resigning change anything? Doug s response was that, It could Which made absolutely no sense to me. if told me earlier that he was staying out it shifted I knew that Mike had installed security cameras in every fice building, without permission from tenants. He claimed that 6 employees working in building are very uncomfortable working under surveillance and 7 that y are scared. He stated that Justin (Weidner - Mike s 8 chief former staff can sit at his desk and watch employees working within 9 his computer. He also told me that Regional Council can track and Doug s current building from everyone with a key fob 10 while y are in building. Thus, at any given moment, Regional Council knows 11 where an individual is located in building I told Doug that I was not (and still am not aware 13 being installed. Indeed, I did not know what Doug was 14 panic alarm system has been installed. 15 button If talking about re was a problem, and blue lights would begin to flicker and alert security and 16 building. There were no cameras or tracking Once again, Doug shifted 18 was that Mike is taking contractors devises. conversation and owing Trust Funds any security cameras staff until later on. A could hit a panic or tenants in told me a bigger problem millions dollars 19 delinquency list. He said this hurts our members, depriving our Trust Funds 20 needed money. I told Doug that I know we try to work with our 21 behind in submitting ir monthly contributions by setting 22 to help m through tough times. But, I had a hard time anyone f delinquency list for any reason - 24 over contractors who have not paid. I said that 25 m f much contractors when y get up with payment plans believing Mike would take because we use it as a hammer we hold re is no logical contractor who owes Trust Funds money from delinquency Doug s reason list. response was, Well, he (Mike did. Doug n to remove any claimed that Mike 27 would go to Trust Funds Delinquency Committee and tell m to remove contractors 28 from list, and that no one else knew about it. We continued discussing delinquency DECLARATION OF MICHAEL OLDS 4

1 list, and Doug told me that no or trustees knew. [his 2 especially 3 that, if any didn t make sense to me eir, because trustees sit on Delinquency Committee.

6 1 list, and Doug told me that no or trustees knew. [his 2 especially 3 that, if any didn t make sense to me eir, because trustees sit on Delinquency Committee. Accordingly, I told Doug 4 asked him if 1 was 5 trustees? [oug said, this were true, it sounded like a policy or procedure change is in order. I correct Yes, 6 overall trust board meets once a quarter After we had 8 more without Doug and that Delinquency Committee a subcommittee and Lclinquency Committee meets once a month and discussed whole issue Delinquency Committee a bit convincing me that Mike was doing anything wrong, Doug brought 9 up Regional Council s delegates meeting that was 10 told me that he had heard Mike intended to preside 11 charges Draper had filed against him at meeting. I 12 That s a bad idea. scheduled for July 25, Doug over meeting and to discuss didn t respond. Doug told me, Delegates to Regional Council are also delegates to General 14 Convention 15 Doug, are elected. I believe opportunity re-election Carpenters, which is when General ficers to hear Mike s side that if bid in I believe that Doug 18 nowhere, and ended shortly after that On Monday, July 20 a.m. (Pacific Time. Doug started delegates Regional story; Doug would have lost believed 15,2013,1 received Carpenters, like Council had had ir support this as well. The meeting was for his going a call from Doug at approximately 8:50 conversation by saying; you probably had heard that Justin Weidner went to work for Carpenters. I told Doug that I heard. I asked Doug if Justin for it? Doug claimed had been persuaded to go to work for Carpenters, or did he ask to go to work that Justin asked to go At this point, Doug accused me 25 claimed that I had lied to him on Saturday when I 26 against Mike. Doug said that Justin Weidner 27 out to everyone at a meeting at Mike s house that 28 I told Doug that I had discussed lying to him during our meeting. told him I had not read had told him that charges were Justin Doug charges handed and I had attended and reviewed. charges, as I had told him at our meeting, but had not DECLARATION OF MICHAEL OLDS 5

20 I actually read m, as I had said. 2. Ioug n told me that I needed to get fiur or live or members 3 Regional Council s Executive Committee toger and ask Mike (McCarron to resign.

7 20 I actually read m, as I had said. 2. Ioug n told me that I needed to get fiur or live or members 3 Regional Council s Executive Committee toger and ask Mike (McCarron to resign. 4 When I told Ioug that Mike had not done anything wrong, Doug s response to me was, 5 You will need to make a career decision. I did not ask Mike to resign and I did not ask 6 any Executive Committee members to ask for Mike s resignation On July 22, 2013, Carpenter s General Vice President imposed an 8 emergency supervision (trusteeship on Regional Council On August 6, 2013, I was terminated from my appointed position as an 10 Administrative Assistant and from my elected position on Executive Committee by 11 Draper, who had been appointed as Regional Council s supervisor/trustee. I asked 12 Draper why I was being terminated, and he told me, Your loyalty is in question. 13 Obviously, I had made wrong career decision, as only loyalty in question was my 14 loyalty to Doug, and that was based on logical thinking and facts I declare under penalty perjury under laws United States that 17 foregoing is true and correct and that this declaration was executed by me in 18 4RJ California on September 2S Michael Olds MO-2 DECLARATION.wpd DECLARATION OF MICHAEL OLDS 6

Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 1 of 32 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA

Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 1 of 32 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA Case 2:15-cv-05971-CJB-JCW Document 17-1 Filed 03/01/16 Page 1 of 32 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA RODNEY HENRY, Civil Action No. 15-cv-5971 Plaintiff, Section