NATIONAL FOOTBALL LEAGUE PLAYERS ASSOCIATION v. SAGAPOLUTELE et al

Filing 42

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NATIONAL FOOTBALL LEAGUE PLAYERS ASSOCIATION v. SAGAPOLUTELE et al Doc. 42 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) CASE NO. 1:09-CV-00620 (RMC) LABORERS' INTERNATIONAL UNION OF ) NORTH AMERICA, ) ) Petitioner, ) ) v. ) ) BRAND ENERGY SERVICES, LLC, et al., ) ) Respondents. ) ) AFFIDAVIT OF DANIEL SHANLEY IN SUPPORT OF PACIFIC NORTHWEST REGIONAL COUNCIL OF CARPENTERS' REPLY IN OPPOSITION TO LABORERS' INTERNATIONAL UNION OF NORTH AMERICA'S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO RESPONDENTS' MOTION TO STAY PROCEEDINGS I, DANIEL M. SHANLEY, pursuant to 28 U.S.C. 1746, declare the following facts to be true and correct: 1. I have personal knowledge of the facts herein. If called to testify, I could and would testify as follows. 2. I am an attorney admitted pro hac vice in this action and am a member of DeCarlo, Connor & Shanley, the attorneys of record for Respondents United Brotherhood of Carpenters and Joiners of America ("UBC"), Pacific Northwest Regional Council of Carpenters ("PNRCC"), and Carpenters Local 1849 (collectively "Defendants"). 3. I am filing this Affidavit in support of the Defendants' Reply in Opposition to Dockets.Justia.com Laborers' International Union of North America's Memorandum of Points and Authorities in Opposition to Respondents' Motion to Stay Proceedings. 4. Attached hereto as Exhibit A are true and correct copies of pages 445-459 of the Section 10(k) hearing that was held before the National Labor Relations Board on May 5, 2009. 5. Attached hereto as Exhibit B are true and correct copies of pages 413, 415-416 of the Section 10(k) hearing that was held before the National Labor Relations Board on May 5, 2009. I declare under penalty of perjury that the foregoing is true and correct. Executed this 2nd day of July, 2009, in Los Angeles, California. /s/ Daniel M. Shanley Daniel M. Shanley, Pro Hac Vice dshanley@deconsel.com DeCARLO, CONNOR & SHANLEY A Professional Corporation 533 South Fremont Ave., 9th Floor Los Angeles, CA 90071-1706 Phone: 213.488.4100 Fax: 213.488.4180 Brian F. Quinn, DC Bar #447619 DeCARLO, CONNOR & SHANLEY, A Professional Corporation 101 Constitution Ave., N.W., 10th Floor Washington, DC 20001 Phone: 202.589.1151 Fax: 202.589.0105 Attorneys for UNITED BROTHERHOOD OF CARPENTERS AND JOINERS OF AMERICA, PACIFIC NORTHWEST REGIONAL COUNCIL OF CARPENTERS, CARPENTERS LOCAL 1849, and MILLWRIGHTS LOCAL 1699 2 INDEX OF EXHIBITS A. Copies of pages 445-459 of the Section 10(k) hearing before the National Labor Relations Board Copies of pages 413, 415-416 of the Section 10(k) hearing before the National Labor Relations Board B. 3 CERTIFICATE OF SERVICE I hereby certify that on July 2, 2009, I electronically filed the AFFIDAVIT OF DANIEL SHANLEY IN SUPPORT OF PACIFIC NORTHWEST REGIONAL COUNCIL OF CARPENTERS' REPLY IN OPPOSITION TO LABORERS' INTERNATIONAL UNION OF NORTH AMERICA'S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO RESPONDENTS' MOTION TO STAY PROCEEDINGS and this certificate of service using the CM/ECF System which will send notification of such filing to the following: Elizabeth A. Roma, Esq.: eroma@geclaw.com Joseph Guerrieri, Jr., Esq.: jguerrieri@geclaw.com GUERRIERI, EDMOND, CLAYMAN & BARTOS, P.C. Michael Barrett, Esq.: MBARRETT@liuna.org Attorneys for LABORERS' INTERNATIONAL UNION OF NORTH AMERICA And by first-class mail to upon the following: Attorneys for BRAND ENERGY SERV ICES LLC Steve Atkinson, Esq. ATKINSON, ANDELSON, LOYA, RUUD & ROMO 12800 Center Court Drive, Suite 300 Cerritos, CA 90703 DATED: July 2, 2009 /s/ Nelly Caywood Nelly Caywood Legal Assistant DeCARLO, CONNOR & SHANLEY A Professional Corporation 533 South Fremont Ave., 9th Floor Los Angeles, CA 90071-1706 Phone: 213.488.4100 Fax: 213.488.4180 E-Mail: ncaywood@deconsel.com

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