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1 To: Secretary Treasurer of Joint Council 53 From: Re: Members of the Independent Review Board Proposed Charges Concerning Thomas Ryan President of Local 107 Date: July 10, 1996 I. RECOMMENDATION The Independent Review Board recommends to the Secretary Treasurer of Joint Council 53 that Thomas Ryan ("Ryan"), President of Local 107, be charged with bringing reproach upon the IBT, breaching his fiduciary duties and embezzling approximately $1,100 from Local 107. This figure represents personal expenses, including a health club membership and airline tickets for his wife, he caused the Local to pay. (Ex. 35) II. SUMMARY Local 107, located in Philadelphia, consists of approximately 3,064 members. Ryan became a full-time Local 107 officer in (Ex. 8 at 5, 6) He is currently the President and principal officer and is paid a salary of $77,224 per annum. (Ex. 1)' Ryan was appointed president to fill the term of Joseph Cimino, who was permanently barred from the IBT for knowingly associating with organized crime members. It appears that between 1994 and the present, Ryan * According to the 1995 Form LM-2 Local 107 filed, Ryan's gross salary was $77,224 with an allowance of $15,950 and an additional $33,463 for "Disbursements for Official Business" which together totalled $126,637. (Ex. 1)

2 embezzled at least $1,100 of Local 107 funds by causing the Local to pay for personal items unrelated to any union purpose. (Ex. 35) After the Chief Investigator's books and records examination was conducted in March 1996, Ryan repaid the Local for some personal expenses the Local paid on his behalf. For two other items he had repaid the Local after IBT auditors questioned the expenses in Based upon this conduct, it appears that Ryan violated Article II, Section 2(a) and Article XIX, Section 7(b)(1), (2) and (3) of the IBT Constitution by embezzling approximately $1,100 in Local 107 funds. Ryan's embezzlement occurred at a time when the Local mortgaged its offices to pay off previous debts and to pay operating expenses. III. INVESTIGATIVE FINDINGS A. Rvan Breached his Fiduciary Duties and Embezzled from Local 107 Ryan had the Local pay for personal expenses at a time the Local was in financial trouble. In addition to the expenses detailed below there were other suspect expenses.^ Ryan's scheme was aided by the Local's failure to require adequate documentation for reimbursed expenses. Between 1994 and 1995, on at least three ^Among Ryan's suspect expenses with little or no documentation that the Local paid were $ spent on 11/10/94 at a kite store in South Carolina (Ex. 8 at 47; Ex. 28); $ spent 10/7/94 for cribs (Ex. 8 at 49, 50; Ex. 29); $ spent on 4/13/95 and $ on 3/30/95 for theater tickets (Ex. 8 at 41-44; Exs ); liquor expenses at The Saloon for $ on 9/8/95 (Ex. 32), $ on 1/19/95 (Ex. 33), and a food and liquor bill of $ which included a $145 bottle of Dom Perignon on 5/4/94. (Ex. 34) 2

3 occasions Ryan charged personal items using the American Express credit card Local 107 provided for use in connection with union business. (Exs. 2-4) Local 107 then paid for these items. (Exs. 5-7) Ryan did not repay the Local for these expenses until after the IRB examination of the Local's records in March (Exs. 36 and 37) The personal items for which Ryan had the Local pay and for which charges are recommended below totalled approximately $1,100. On October 16, 1994 Ryan charged $ in airplane tickets for his wife to his Local American Express card for which the Local paid. (Ex. 8 at 48; Exs. 3 and 6) On June 17, 1995, he charged to the Local and it paid $50.00 for another airline ticket for his wife. (Exs. 4 and 7) He admitted they were expenses unrelated to union business. (Ex. 8 at 52) Earlier, on July 11, 1994, Ryan had charged a membership fee of $ for Bally's Health Club to the Local. (Ex. 2) The Local paid it. (Ex. 5) Ryan admitted this was a personal expense. (Ex. 8 at 51-52) On May 5, 1994 Ryan charged to the local a $28.00 bottle of wine he gave as a present to a lawyer for providing free personal legal advice to him. (Ex. 9) The bar charge slip on the Local's house account at The Saloon, a bar and restaurant, had handwritten on it "Tom Ryan... Wine for Joe." (Ex. 9) In different handwriting below Joe was written "Cimino." (Ex. 9) Joseph Cimino, the former Local 107 president, was barred permanently from the IBT on October 16, 1991 for knowingly associating with organized crime members. (Ex. 38) Ryan testified 3

4 that it was not his handwriting and the wine was for Cimino's daughter, a lawyer who had done him favors. (Ex. 8 at 60-61) He admitted this was a personal expense and claimed he repaid it after an International auditor brought it to his attention in (Ex. 26) As a result of the International audit in April 1995, Ryan was reguired to reimburse the Local $81.81 for out of town personal expenses which included hotel movie charges. (Ex. 39) On May 12, 1995, Ryan repaid this amount to the Local. (Ex. 27) These personal expenditures were not oversights as Ryan claimed. (Ex. 8 at 35) the members' money. Ryan was reckless with his personal use of For example, at The Saloon he freguently tipped over 50% of the bill. (Exs. 10, 13, 16, 17) Indeed, on five other occasions, he tipped over 100% of the bill. (Ex. 41) For example, on May 18, 1994 Ryan spent $30.00 at the Saloon for liquor and tipped $ (Ex. 18) These five tips were paid as Local expenses through an account the Local had at The Saloon and totalled $ (Exs. 11, 12, 14, 15, 18; Ex. 41) Ryan's tipping on five occasions was 100% of the bill or more and constituted embezzlement. Ryan's personal expenses and grossly excessive tipping that the Local paid occurred during the period when the Local was experiencing difficulties meeting its financial obligations. From the beginning of 1991 to the end of 1994, the Form LM-2's Local 107 filed showed a decrease in the Local's general fund from $174,671 to $30,385. (Exs. 19 to 22, 43) In 1995, the Local took a $210,000 4

5 mortgage on its union office which included land, building and contents. (Ex. 40) This was used to pay off debts and to pay current operating expenses. (Ex. 8 at 37) Pursuant to Section 13 (A) (3) and (10) of the Local Bylaws, the membership should have approved this mortgage. (Ex. 23)3 indeed, Ryan's failure to have this mortgage approved by the members as required under the Bylaws is further evidence that his personal expenditures at Local expense were intentional. There was no review of Ryan's expenses at the Local. No Local officer ever challenged any expenses, including the health club membership. The current Secretary-Treasurer, who has held office since January, does not review Ryan's expenses even though Ryan had to reimburse the Local after the International audit. (Ex. 24 at 12) In addition, the Trustees merely sign the Trustee reports as fully prepared by the Local's accountants. The accountants never raised a question as to any Ryan expense. (Ex. 8 at 42) B. Standard for Embezzlement In order for an embezzlement charge to be proven, it must be shown that the charged party had the fraudulent intent to embezzle. See. United States v. Welch. 728 F.2d 1113, 1118 (9th Cir. 1989) ("under any test, union officials violate Section 501(c) only when they possess fraudulent intent to deprive the Union of 3 In fact, there were no general membership meetings from 1991 to September 17, (Ex. 42) 5

6 its funds.") Here, Ryan's intent to embezzle was demonstrated by his pattern of causing the Local to pay for personal expenses. Ryan joined a health club, bought airplane tickets for his wife, gave wine to a lawyer who performed free personal services for him and indulged himself in excessive tipping over 100% of the bill at the members' expense. In addition, Ryan's intent to embezzle was *also demonstrated by his pattern of violating Section 4.1 of the IBT Secretary Treasurer's Manual which provides that "[U]nder no circumstances should personal expenses be charged to and/or run through the Local Union books." (emphasis in original) (Ex. 25) Ryan ignored this provision. Given that Ryan caused the Local to take a mortgage to repay prior local debts and pay operating expenses, he was fully aware that Local expenses needed to be absolutely necessary to Local purposes, yet he indulged himself at the members' expense. It is apparent that he intended to embezzle Local 107 funds. In Investigations Officer v. Frank Baccaro. IA Decision dated June 23, 1992 at 6, the Independent Administrator found that Baccaro's reimbursement to the Local only after being informed of possible embezzlement charges was "evidence of Baccaro's intent to deprive his Local of its funds." The Independent Administrator found that "[t]o find otherwise would be to invite an intolerable situation where those committing financial wrongdoing would simply wait and see if they are discovered before deciding whether to make restitution." Id. Here the inference is even stronger because 6

7 after the International auditor raised questions in 1995, Ryan reimbursed the Local for Cimino's wine and hotel movies (Exs. 26 and 27), but he did not pay back other personal expenses until after the IRB began its investigation in (Exs ) IV. PROPOSED CHARGES Based upon the foregoing, it is recommended that Thomas Ryan be charged as follows: Between 1993 and the present, while an officer of Local 107 you brought reproach upon the IBT, breached your fiduciary duties and embezzled approximately $1,100 in Local 107 funds in violation of Article II, Section 2(a) and Article XIX, Section 7(b)(1), (2) and (3) of the IBT Constitution, to wit: While an officer of Local 107, between 1993 and the present, you embezzled Local 107 funds by engaging in a pattern of purchasing personal items and causing the Local to pay for these items which totalled approximately $1,100. These personal charges were of no benefit to the union and included airline tickets for your wife, a health club membership, wine for a personal friend, movies and tips at bars in excess of the bills. 7

8 EXHIBITS TO THOMAS RYAN REPORT Ex. 1 Local LM-2 Ex. 2 American Express - Bally's Health Club 7/11/94 Ex. 3 American Express - Rachelle Ryan Airline Ticket 10/16/94 Ex. 4 American Express - Rachelle Ryan Airline Ticket 6/17/95 Ex. 5 Local 107 Check for American Express bill dated 8/5/94 Ex. 6 Local 107 Check for American Express bill dated 11/4/94 Ex. 7 Local 107 Check for American Express bill dated 7/5/95 Ex. 8 Ex. 9 Sworn Examination of Thomas Ryan Ryan's Saloon receipt dated 5/5/94 - Cimino Ex. 10 Ryan's Saloon receipt dated 11/11/94 Ex. 11 Ryan's Saloon receipt dated 3/22/95 Ex. 12 Ryan's Saloon receipt dated 3/15/95 Ex. 13 Ryan's Saloon receipt dated 3/2/95 Ex. 14 Ryan's Saloon receipt dated 2/24/95 Ex. 15 Ryan's Saloon receipt dated 1/12/95 Ex. 16 Ryan's Saloon receipt dated 11/10/94 Ex. 17 Ryan's Saloon receipt dated 5/25/94 Ex. 18 Ryan's Saloon receipt dated 5/18/94 Ex. 19 Ex. 20 Ex. 21 Ex. 22 Ex. 23 Ex. 24 Local LM-2 Local LM-2 Local LM-2 Local LM-2 Local 107 Bylaws Sworn Examination of Joseph Ferla 8

9 Ex. 25 Secretary Treasurer's Manual - Section t 4.1 Ex. 26 Ryan's repayment of expenditure dated 5/11/95 Ex. 27 Ryan's repayment of expenditure dated 5/12/95 Ex. 28 American Express bill dated 11/10/94 Ex. 29 American Express bill dated 10/7/94 Ex. 30 American Express bill dated 4/13/95 Ex. 31 American Express bill dated 3/30/95 Ex. 32 Ryan's Saloon receipt dated 9/8/95 Ex. 33 Ryan's Saloon receipt dated 1/19/95 Ex. 34 Ryan's Saloon receipt dated 5/4/94 Ex. 35 Embezzlement Schedule Ex. 36 Ryan Reimbursement to Local 6/6/96 Ex. 37 Ryan Reimbursement to Local 6/19/96 Ex. 38 Ex. 39 Cimino Decision IBT Auditor Schedule Ex. 40 Promissory Note on Local 107 Ex. 41 Schedule on Ryan's Tips over 100% Ex. 42 Ex. 43 Inv. Schwally Memo Re: General Membership Meetings Schedule of Local 107 General Fund Ex. 44 Exhibits used during sworn examination Joseph Ferla of Thomas Ryan, 9

10 /?o 377 3/S" UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA v Plaintiff INTERNATIONAL BROTHERHOOD OF TEAMSTERS, et al. Defendant 88 Civ (DNE) APPLICATION XX OF THE INDEPENDENT REVIEW BOARD AGREEMENT BETWEEN THE INDEPENDENT REVIEW BOARD AND DENNIS RAYMOND, JAMES GILMORE, LOUIS PARISI, CLIFFORD SOCQUET, JOSEPH MCALLISTER AND ANDRE RIVARD Pursuant to Paragraph o. of the Rules and Procedures for Operation of the Independent Review Board ("IRB") for the International Brotherhood of Teamsters ("IRB Rules"), the IRB files this Application submitting the Compromise Agreement with the Officers of Local 677 in Waterbury, Connecticut. This Agreement was approved by the IRB and is submitted to Your Honor for review and, if appropriate, to be entered as an order. Although proposed charges against the officers of Local 677 for giving away a Local Union automobile to a retiring officer were never finalized by the Independent Review Board, this Agreement seeks to resolve the matter against them. This Application recognizes the importance of Your Honor's February 2, 1994, Order in which Your Honor stated that all IRB Compromise Agreements shall "contain a paragraph informing signatories that the agreement will be reviewed and may be rejected." The Agreements reached between the IRB and the Local 677 Officers satisfy this procedure for Your Honor's review.

11 The Respondents are all officers of IBT Local 677 and members of the IBT. Raymond, Local 677's President; Gilmore, secretary- Treasurer; Parisi, Vice President; Socquet, Recording Secretary; and Trustees McAllister and Rivard acknowledged and admitted the giving of an automobile to retiring officer Perley Rossignol despite the provision of the Local 677 Bylaws which mandates that the title to union-owned cars shall always remain in the name of the Local. This was in violation of Article II, Section 2(a) and Article XIX, Section 7(b)(1) and (2) of the IBT Constitution and Article IV, Section 5 of the Local 677 Bylaws. After the IRB raised the issue of a possible Bylaw violation, Perley Rossignol paid $17, to the Local 677 general fund and Officers Raymond, Gilmore, Parisi and Socquet paid a fine of $ each to the general fund. We have found the Agreement comports with Your Honor's February 2, 1994, Order and serves to resolve the charges in a fair and equitable manner. Therefore, we respectfully request that Your Honor execute the Agreement on the line provided. This will, in effect, serve to have this Agreement "so ordered" by the Court. Thereafter, it is respectfully requested that a member of Your Honor's staff file the fully executed original Agreement with the Clerk. Dated June 29, 1995 Frederick B. Laeey f Member of the Independent Review Board 2

12 In the Matter of X DENNIS RAYMOND, President, JAMES GILMORE, Secretary-Treasurer, LOUIS PARISI, Vice President, CLIFFORD SOCQUET, Recording Secretary, JOSEPH MCALLISTER, Trustee, and ANDRE RIVARD, Trustee, AFFIDAVIT AND AGREEMENT x DENNIS RAYMOND, JAMES GILMORE, LOUIS PARISI, CLIFFORD SOCQUET, JOSEPH MCALLISTER AND ANDRE RIVARD, depose and say and agree as follows: 1. The Independent Review Board, appointed pursuant to the Consent Order entered March 14, 1989 in United States v. International Brotherhood of Teamsters. 88 Civ (DNE) (SDNY) (the "Consent Order") has approved a report of proposed charges against Local 677 officers Dennis Raymond, James Gilmore, Louis Parisi, Clifford Socquet, Joseph McAllister and Andre Rivard. 2. This Agreement is made to resolve the proposed charges in the report regarding the gift of a car to a retiring officer allegedly in violation of a Local 677 Bylaw. This Agreement does not constitute either an admission or a denial of any impropriety, or violation of the Local Union Bylaws, International Constitution or Consent Order. 3. We understand and agree that this Agreement will be submitted to the Independent Review Board ("IRB") for its review and, if approved by the IRB, it will be submitted to the United States District Court for the Southern District of New York for review. We understand that if this Agreement is approved by the United States District Court for the Southern District of New York it will be entered as a court order. We understand that no representations have been made as to whether this Agreement will be approved by the IRB or the United States District Court for the Southern District of New York. We further understand that this

13 Agreement is subject to review by the United States District Court for the Southern District of New York and if, upon review, this Agreement is not approved by the United States District Court for the Southern District of New York, this Agreement will be void. 4. Each Respondent is a member of IBT Union Local 677 and was a member of the Local Union Executive Board and held the Local Union office set forth opposite their respective names: Dennis Raymond James Gilmore Louis Parisi Clifford Socquet Joseph McAllister Andre Rivard President Secretary-Treasurer Vice President Recording Secretary Trustee Trustee 5. Article IV, Section 5 of the Bylaws of Local Union 677 provides in pertinent part as follows: The Local Union may provide its officers or representatives with automobiles upon authorization of the membership or in lieu thereof, they may be paid an allowance for use of their automobiles in such amount or at such rate as shall be approved by the Local Union Executive Board. In such instances where the Local Union provides an automobile, title to the automobile shall remain at all times in the name of the Local Union... Upon authorization of the Local Union Executive Board, the Secretary is empowered to sell, exchange or lease automobiles or arrange financing therefor in behalf of Local Union. 6. It is acknowledged and admitted that we approved or ratified the giving of an automobile to Perley Rossignol, the retiring officer, on or about June 1, 1994 and that the value of the particular automobile was $21, We did that after receiving advice from the Local's then counsel that the gift was not in violation of the Local's Bylaws. 7. After the IRB raised the issue concerning a possible Bylaw violation, Perley Rossignol, on February 2, 1995, paid $17, to the Local 677 general fund. On February 2, 1995, the four salaried officers, Dennis Raymond Jr., James Gilmore, Louis Parisi and Clifford Socquet paid to the Local 677 general fund a fine of $1, each for a total of $4, These fines were paid out of our personal funds in order to resolve the charges in the IRB's report with no compensation, salary increase or repayment in any manner for such expenditure. Attached as Exhibit A are documents reflecting this payment to the Local 677 general fund. 8. On April 21, 1995 the Executive Board of Local 677

14 passed a resolution at the Local whereby they shall cease using the services of attorney Norman Zolot or his firm. As of April 21, 1995 Local 677 terminated all representation by Norman Zolot or his firm in the future. This resolution and a sworn certification as to his termination are attached as Exhibit B. 9. We have entered this Agreement on the understanding that the IRB agrees not to pursue the charges described in the attached report. We understand that this Agreement, which is subject to review by the United States District Court for the Southern District of New York, is limited to the charges detailed in the May 14, 1995 report and the IRB expressly reserves the right to pursue charges against any other officer, member, employee or entity of the IBT and Local 677 arising out of the allegations contained in the report of charges or any other investigations. 10. We make this agreement after consultation with our attorney and fully understand its terms. Dennis Raymqftd Clifford Socqu J%mes Gilmore foseph McAllister LCuls Parisi Andre Rivard Sworn to before me this <^4?day of ^ ^ 1995 Notary Public MyaMWMBmhpMEAp*34:sa ^ J Susan Martin Counsel for Respondents Recommended: Charles M. Carberry IRB Chief Investigator By:

15 Approved: Independent Review Board By: So Ordered: Hon. David N. Edelstein U.S. District Judge Dated: i /

16 INDEPENDENT REVIEW BOARD 444 North Capitol St., NW, Suite 528 Washington, DC (202) Facsimile (202) Corruption Hotline (800) CALL IRB Chief Investigator: Charles M. Carberry, Esq. 17 Battery Place, Suite 331 New York, NY Administrator: John J. Cronin, Jr. VIA PP5 NBXT DAY AI3 Hon. David N. Edelstein United States District Court 40 Centre Street Foley Square, Room 2104 New York, NY May 2, 1997 Board Members: Grant Crandall, Esq. Crandall, Pyles & Haviland 1021 Quarrier Street Charleston, WV Frederick B. Lacey, Esq. LeBoeuf, Lamb, Greene & MacRae One Riverfront Plaza Newark, NJ William H. Webster, Esq. Milbank, Tweed, Hadley & McCloy 1825 Eye Street, NW, Suite 1100 Washington, DC Re: REVISED APPLICATION XX OF THE INDEPENDENT REVIEW BOARD Dear Judge Edelstein: I transmit herewith one original and two copies of Revised Application XX of the Independent Review Board seeking entry of an order by Your Honor approving the resolution of Application XX regarding the charges and penalties imposed on the Officers of Local 677. Also enclosed are the "backed" original and two copies of a proposed Order and the "backed" original and two copies of the Acknowledgment of Receipt. I respectfully request that, if Your Honor finds it appropriate to do so, you execute the proposed form of order and have a member of your staff file the "backed" original Order, Revised Application, Acknowledgment of Receipt and Affidavit of Service with the Clerk's office. FBL:saw Enclosures Frederick B. Lacey cc: via UPS NEXT DAY AIR Grant Crandall, Esq. William H. Webster, Esq. John J. Cronin, Jr. Susan Martin, Esq. David Neigus, Esq. Karen Konigsberg, AUSA Charles M. Carberry, Esq. Jay Gilmore, Secretary-Treasurer of Local Union 677 Pursuant to the Consent Order of the United States District Court, S.D.N.Y. United States -v- International Brotherhood of Teamsters 88 CIV 4486 (DNE)

17 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA v. Plaintiff INTERNATIONAL BROTHERHOOD OF TEAMSTERS, at al., 88 Civ (DNE) REVISED APPLICATION XX OF THE INDEPENDENT REVIEW BOARD SEEKING ENTRY OF AN ORDER APPROVING THE RESOLUTION OF APPLICATION XX Defendant. Pursuant to Paragraph 0. of the Rules and Procedures for Operation of the Independent Review Board ("IRB") for the International Brotherhood of Teamsters ("IRB Rules"), this Application is made seeking entry of an order approving the resolution of the matter regarding the charges and penalties imposed on the Officers of Local 677 in Waterbury, Connecticut. The six officers, Dennis Raymond, J r. ("Raymond"), james Gilmore ("Gilmore"), Louis Parisi ("Parisi"), Clifford Socquet ("Socquet"), Joseph McAllister and Andre Rivard were charged with giving away a Local Union automobile to a retiring officer. Local 677 Officers Raymond, Parisi and Socquet agreed to pay the Local 677 general fund a fine of $1, each, Gilmore agreed to pay $3, to the Local 677 general fund, and Perley Rossignol, the retiring officer who received the automobile, paid $17, to the Local 677 general fund. This Agreement was approved by the IRB and submitted to Your Honor for review on June 29, 1995, by way of Application XX (Ex. A). Thereafter, Your Honor returned the Application to the IRB indicating that the proposed penalties were inadequate. Acting under the IRB Rules Paragraph I., sec. 4, the

18 IRB referred its Investigative Report on the matter to IBT Joint Council 64 on November 3, 1995 (Ex. B). Under cover of letter dated June 3, 1996, the IBT Hearing Panel transmitted its determination imposing a 30-day suspension from office, without pay (Ex. C). On June 10, 1996, the IRB informed IBT Joint Council 64 that the decision of the hearing panel was inadequate as to the penalty (Ex. D). The IBT responded on June 20, 1996, modifying the penalty to a 90-day suspension (Ex. E). On July 10, 1996, the IRB wrote to the IBT informing it that its modified decision was "not inadequate" and that the modified decision would be submitted to Your Honor for review (Ex. F). On December 13, 1996, the IRB received a letter from your Chambers requesting that the IRB submit an Application to this Court: (1) informing this Court that all penalties imposed by the IRB in conjunction with Application XX have been satisfied; and (2) seeking entry of an Order approving the resolution of Application XX. These suspensions have now been completed and fines have been paid. Enclosed as Exhibit G is the April 15, 1997, letter from Jay Gilmore, Secretary-Treasurer of Local Union 677, attaching copies of membership ledgers, payroll records and Local 677 state unemployment tax returns which document each of the officer's suspensions. Documentation regarding payment of the fines was included as part of the original Application XX. See Ex. A of the original Agreement.

19 Therefore, we respectfully request that Your Honor execute the enclosed form of order. This will, in effect, serve to have the Agreement, as modified by the IBT's decision, to be "so ordered" by the Court. Thereafter, it is respectfully requested that a member of Your Honor's staff file the fully executed order with the Clerk. Dated: May 2, 1997 By: Member of the Independent Review Board

20 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA,. Plaintiff, 88 Civ, 4486 (DNE) ORDER v. INTERNATIONAL BROTHERHOOD OF TEAMSTERS, at al-, Defendant. This matter being brought to the attention of the Court by the Independent Review Board by way of Revised Application XX and the Court having considered the Revised Application and accompanying exhibits and for good cause shown, It is on this ( Z- day of _, 199* ; ORDERED that the Affidavit and Agreement in the matter of Raymond, at al-, as modified by the ibt's revised penalty of 30- days suspension is hereby approved and so ordered.

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