Cross Claims Pleading Draft 6 Conformed

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THIRD PARTY CLAIMS AND COUNTER CLIAMS OF DEFENDANT MICHAEL MCCARRON

THE
BLOOM FIRM

Lisa Bloom, Esq. (SBN: 158458)
Alan M. Goldberg (SBN: 136988)
THE BLOOM FIRM
22130 Clarendon Street
Woodland Hills, CA 91367
Telephone: (818) 914-7314
Facsimile: (866) 852-5666
Email: Lisa@thebloomfirm.com
Alan@thebloomfirm.com

Attorneys for Defendant, third party claimant and counter claimant

MICHAEL McCARRON
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

SOUTHWEST REGIONAL COUNCIL OF CARPENTERS, a
unincorporated association,
Plaintiff,
v.
MICHAEL McCARRON, an individual,
Defendant.

CASE NO.:
2:14-CV-02762
THIRD PARTY
CLAIMS AND
COUNTER
CLAIMS OF
DEFENDANT
MICHAEL
MCCARRON
MICHAEL McCARRON, an individual,

Third party and counter claimant,

vs

DOUGLAS McCARRON, an individual and in his capacity as
General President of the UBC; UNITED BROTHERHOOD OF
CARPENTERS AND JOINERS OF AMERICA (UBC),
ULLICO, a privately held insurance company, form unknown;
SOUTHWEST REGIONAL COUNCIL OF CARPENTERS
(SWRCC) an unincorporated association; DAN MACCONALD,
an individual and as an agent of the UBC and the SWRCC;
DOUGLAS BANES, an individual and as general vice president
of the UBC; MICHAEL DRAPER, as an individual and as
Western District Vice President; ROBERT PHIL NEWKIRK as
an individual and as Western District Vice President (UBC) and
SWRCC Supervisor, JUSTIN WEIDNER, as an individual and as
assistant chief of staff at the UBC, and DOES 1-50, inclusive,

Third Party and Counter defendants.

Case 2:14-cv-02762-PA-JC Document 26 Filed 08/18/14 Page 1 of 41 Page ID #:135
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1. Pursuant to Rule 13(b) and 14(a) of the Federal Rules of Civil Procedure
Defendant Mike McCarron (Mike) hereby alleges as follows: 1. Plaintiff Southwest
Regional Council of Carpenters (SWRCC) has filed against Mike a complaint, a copy
of which is attached hereto as Ex. A. Counter and third party complainants complaint
makes various charges and allegations of wrong doing alleging breach of fiduciary
duty under the Labor Management Reporting Disclosure Act (LMRDA) sec. 501 (29
USC sec. 501), state law breach of fiduciary duty and state law claims of claim &
delivery and breach of contract. Mike denies all the allegations in their entirety.
2. Mike brings this counter claim against the SWRCC for the causes set forth
below.
3. Mike brings this third party claim against all other defendants as set forth below.
4. Counter and third party complainant seeks preliminary and permanent
injunctions restoring him to membership in good standing, restoring him to his elected
offices, and vacating any other impositions of penalties issued against him, and other
appropriate relief. Immediate relief is necessary not only so that Counter and third
party complainant can campaign for office effectively but also so that he and his fellow
union members may exercise their free speech rights without fear of retaliation.
JURISDICTION
5. This Court has jurisdiction over this action pursuant the Labor-Management
Reporting and Disclosure Act of 1959 (LMRDA), 29 U.S.C. 412, 482.
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6. This Court has jurisdiction over this action pursuant to ___ 1367, because the
state law claims asserted in this matter are within the Court's supplemental jurisdiction,
as the Third-Party claims arise out of a suit based on federal question jurisdiction.
7. Additionally, this Court has diversity jurisdiction over this action pursuant to 28
U.S.C. 1332. Douglas McCarron (Douglas) and the UBC are residents of Las Vegas,
NV and the UBC is a resident also of Washington, DC. Jurisdiction over Douglas is
reasonable because Douglas does business in California.
VENUE
8. Venue is proper in the United States District Court for the Central District of
California because defendant, Mike McCarron is a resident of this district and the
violations complained of herein occurred in this district. 28 U.S.C. 1391(b); 29
U.S.C. 412.
PARTIES
9. The United Brotherhood of Carpenters and Joiners of America (UBC), a labor
organization within the meaning of 29 U.S.C. 402(i);
10. Douglas McCarron is the General President of the UBC and its highest officer.
He resides in Las Vegas, NV.
11. Dan MacDonald is team lead with the SWRCC and a resident of the County of
Los Angeles.
12. Douglas Banes is the General Vice President of the UBC and is a resident of
Illinois;
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13. Michael Draper: was the western district vice president at the time of the
happenings of the events alleged herein. He is a resident of Las Vegas, NV.
14. The Southwest Regional Council of Carpenters (Council or Regional
Council or SWRCC) is an unincorporated voluntary association and a labor
organization, as defined by 29 U.S.C. 402(i). The SWRCC maintains an office at 533
South Fremont Avenue, Los Angeles, California 90071.
15. Robert Phil Newkirk, at the time he was the Chief of Staff for Douglas
McCarron and is currently Western District Vice President and is a resident of Portland
Oregon.
16. Justin Weidner, was assistant chief of staff to UBC General President Douglas
McCarron. He is a resident of Long Beach, CA.
17. Michael McCarron is an individual residing in the Chatsworth neighborhood of
Los Angeles, California. He was a member of Local 1506 of the UBC. He was in good
standing until charges were filed against him on 6/28/13. From 1999 until July 22,
2013, McCarron served as the Executive Secretary-Treasurer ("EST") of the SWRCC.
The EST position is the highest-ranking position within the SWRCC. As EST,
McCarron was the SWRCC's chief executive officer and responsible for conducting
the SWRCC's daily business subject to the direction, control, and/or supervision of the
SWRCC's Executive Committee and/or Trustees. Mike was also planning to run for
the position of General President of the UBC currently held by his older brother,
defendant, Douglas McCarron. Douglas McCarron was also in fear of the SWRCC
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delegates who were not inclined to vote for Douglas McCarron again for president of
the UBC.
18. Union Labor Life Insurance Company (ULLICO) is a privately held insurance and
financial services company in the US. It is headquartered in Washington, DC. Ullico is
the insurance company to which Mikes insurance premiums were paid to cover him in
the event that he was sued for claims related to his position in the SWRCC. Mikes
premiums were paid for over 10 years to Ullico.
19. DOES 1-50 are sued under fictitious names. The true names and identities of
these counter and third party defendants is currently unknown to counter claimant.
When the true names and identities of these counter and third party defendants are
ascertained, counter claimant will amend this pleading and insert their names and
identities. Counter claimant is informed and believes that these fictitiously named
counter and third party defendants are in some way responsible for the occurrences
alleged herein and is in some way responsible for the damages suffered by counter
claimant.
20. Counter and third party complainant is informed and believes and thereon alleges
that at all times relevant, each counter and third party Defendant, including the DOE
Counter and third party defendants, was the agent, servant, representative and/or
employee of each of the other Counter and third party defendants, and that in doing the
things hereinafter alleged, each Defendant was acting within the course and scope of his,
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her or its authority as such agent, servant, representative and/or employee, with the
permission, knowledge, consent and ratification of each of the other Counter and third
party defendants. Unless otherwise indicated, all Counter and third party defendants,
including DOE counter and third party defendants, are collectively referred to herein as
the "Counter and third party defendants.
STATEMENT OF FACTS
21. In 1978, Mike McCarron joined Local 1506 in Los Angeles, California. He
completed the drywall-lathing apprenticeship program and earned his journeyman
card. While working with his tools, he attended all union meetings, volunteered for all
needed activities, including the subcontractors strike of 1983, and was union steward
on several large projects in the Los Angeles area. Mike took numerous labor law and
organizing classes in the evening, so he could prepare himself to be a representative of
the Brotherhood.
22. Mike was very active in Local 1506 and was hired as a field investigator in
1986, for the Drywall Contract Administration Trust (CAT). Two years later Mike
became an organizer for Local 1506, working with some of the best in the industry. As
an organizer Mike came up with innovative tactics for organizing that were met with
lots of success. He also maintained good working relationships with the Locals
contractor base. In 1989, Mike was elected warden of Local 1506, and elected delegate
to the then Los Angeles District Council.
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23. In 1996, Mike was elected president of Local 1506. During this time, Mike
created the Contract 98 Program. The program consisted of a series of meetings
held at local unions throughout the Council, in the months leading up to the expiration
of the Master-Labor Agreement. Thousands of Carpenters attended these pre-
negotiation meetings. Mike knew that if contractors understood that their skilled,
talented, and productive crews stood with the Union, the Union would retain its
contractor base. It was the right program at the right time. Mike knew the Unions
greatest strength was its membership. If contractors knew that skilled, talented, and
productive Carpenters were ready to strike, and not break ranks, then a new Master-
Labor Agreement could be achieved. The Contract 98 Program was a success and a
first in the brotherhood. The Contract tactic spread to every state in the Council and
many other Councils have adopted similar programs. The Contract 98 Program
was so successful that the membership got its Vacation Pay back. The Contract
Program has been used at every expiration throughout the Council. The 2012 Southern
California Master-Labor Agreement was so successful that a four year contract was
achieved.
24. In August of 1999, Mike McCarron was elected Executive Secretary-
Treasure (EST) of the then Southern California Nevada Regional Council of
Carpenters. In 2001, the International Brotherhood gave (merged) the Gold Coast
District Council and the Arizona Regional Council to Mike McCarron, because of his
leadership and innovative approaches to organizing. Soon after this merger, the
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Council was renamed the Southwest Regional Council of Carpenters (SWRCC). In
2003, the International gave the State of Utah to the SWRCC, and in 2006, gave the
state of New Mexico to the SWRCC. Then in 2010, the International gave the State of
Colorado to the SWRCC. The State of Colorado had been neglected by the Kansas
City Regional Council, and required the SWRCC to use an exorbitant amount of
resources to get Colorado back on track for its membership.
25. During his tenure as EST, Mike McCarron and his team grew the
Southwest Regional Council from approximately $30 million dollars to a high point of
$155 million dollars and built several state of the art, multi-million dollar training
centers. Through cutting edge organizing efforts the Southwest Regional Councils
membership grew to over 65,000 Carpenters.
26. Mike McCarron has worked tirelessly to increase the contractor base and
membership hours. He feels a deep personal responsibility to the union members and
families that he represented.
27. Mike also served as a trustee of the Training Fund.
28. On or about 6/28/13 Michael Draper of the UBC filed charges against
Mike under section 14D of the UBC constitution section 51(A((4), (6) and (12). The
charges included an allegation that Mike was responsible for over charging the
Training Fund rents on their leaseholds in buildings owned by the UBC which, the
prosecutor argued, was self dealing.
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29. The trial in this matter took place at the UBCs International Training
Center in Las Vegas, NV on 9/9-12/13. The trial committee found Mike guilty of the
charges and the penalty was expulsion from the UBC. Mike appealed the decision to
the General Secretary Treasurer of the UBC, Adris Silins on or about 10/23/13. The
decision of the trial committee was affirmed.
30. It is a shame that a personal matter between brothers Mike McCarron and
Doug McCarron (UBC general president), which started in December of 2011, and
escalated after the death of their mother in May 2013, has lead to an abuse of power by
the General President and his Executive Board. This abuse resulted in false charges,
improper use of emergency supervision, and the ultimate wrongful termination of EST
Mike McCarron.
FIRST CAUSE OF ACTION
Slander Per Se Against SWRCC, Dan MacDonald, Justin Weidner and UBC
31. Counter and third party complainant repeats and re-pleads Paragraphs 1 through
___, inclusive, and incorporates the same herein by reference.
32. On or about August 16, 2013, Counter and third party defendants, and each of
them, made defamatory statements which caused damage to Mike. These statements were
made to about 125 members of the Local 1506 union meeting on this date.
33. At the union meeting mentioned above, Mike asked why there were 15 armed
guards stationed at this meeting. Dan MacDonald, the local representative to the SWRCC
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who was based at that local, slandered Mike when he replied the reason they are here is
because you are mentally unstable.
34. At that same meeting on 8/16/13, Mr. MacDonald accused Mike of wrongdoing, by
unilaterally and improperly entering into leases with the JATC which were above market
rates. Mr. MacDonald then accused Mike, at that meeting, of owing the Counter and third
party complainant in excess of $260,000 in interest only due to that wrongdoing.
35. The oral statement by Dan MacDonald is a false and unprivileged publication
which imputes to Mike a loathsome disease, to wit, mental illness.
36. The oral statement by Dan MacDonald is a false and unprivileged publication that
tends to directly injure Mike in respect to his office, profession, trade or business by
imputing to him general disqualification in those things which his office or occupation
requires. The statements injured Mike in his profession, etc., because they attack Mikes
veracity as an esteemed member and EST with the SWRCC and led to his wrongful
termination.
37. By natural consequence, this has caused Mike substantial damage.
Upon information and belief, the members of the Local 1506 union in attendance
that evening, about 125 people, understood the statements were about Mike as the
statements were directly in reference to a question about Mike from Mike.
38. Both statements are entirely false as they pertain to Mike and they are defamatory
on their face and exposed Mike to hatred, contempt, ridicule and obloquy because Mike
engaged in no wrongdoing regarding the allegations made against him.
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39. These statements were understood, by those who heard them, in a way that
defamed the reputation of Mike as a well respected hard working EST and member of the
community of carpenters in that the statements imply efforts by Mike to steal from the
union.
40. Complaining party avers that the counter defendants, and each of their agents,
failed to use reasonable care to determine the truth or falsity of the statements.
41. Complaining party avers that the wrongful conduct of the counter defendant, and
their agents, was a substantial factor in causing Mike the harm complained of herein,
including, but not limited to, the loss of his income, his position at the SWRCC for which
he worked for over 10 years to acquire, his business, trade, profession, occupation, harm
to Mikes reputation, expenses he has had to pay to try to clear his name, including
investments of his time, in addition to the harm assumed by law.
42. As a proximate result of the above-described statements, Mike has suffered loss to
his reputation, shame, mortification, and hurt feelings, all to his general damages.
43. As a further proximate result of the above-described statements, Mike has suffered
loss of business, in an amount to be proven at trial.
44. By engaging in the above conduct, Counter and third party defendants, and each of
them, acted with malice, oppression, and/or fraud, entitling Mike to exemplary and
punitive damages.
45. On or about September 10 or 11, 2013, the UBC and the SWRCCC through their
agent, Dan MacDonald, recording secretary, attempted to tamper with a trial witness, Ben
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Rodriguez, by calling him just prior to Mr. Rodriguez trial testimony at the 14D trial and
made many malicious and defamatory statements in an approximately 35 minute phone
call which was recorded in Nevada. During this conversation Dan MacDonald told Ben
Rodriguez the following statements which were defamatory:
46. = Mike made unauthorized and unilateral loans to contractors which were not
enforced and which went into default which cost the union hundreds of thousands of
dollars;
47. = Mike spent $114k on union issued credit cards from 2010-13 and never provided
receipts, or accountability
48. = Mike is total fucking ass backwards fucked up and corrupt.
49. = Before I would agree (to testify on behalf of Mike) I would wait until I read that
fucking (supervision) letter, man. There will be copies available at the hearing tomorrow,
read it. You are not privy to all the information of how bad it is.
50. = Mike is off on planet fucking X, corrupt a criminal as a motherfucker, you are
going to put your character on the line for him. I wouldnt want you to vouch for someone
before you had access to all the information. Ask for that letter tomorrow.
51. = Mike is making shit up to save his own ass. He is pathological (liar). He is a
fucking flat out criminal.
52. = Dan advised Ben not to get involved, that is, not to testify, or, to change his
testimony away from support for Mike. Dan said Dont fucking testify for Mike, man,
its fucked up. Mike is totally fucking misleading. All the statements (charges) are flat
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out verifiable. They are going public tomorrow. Dan told Ben to trust in Doug
McCarron and in the brotherhood. Mike got thrown out for corrupt criminal actions. Dan
told Ben that Dan has seen all the evidence, that it is all totally verifiable and cant be
made up.
53. Dan MacDonald continued: Mikes actions have devastated the council, he (Mike)
is out of control and is ruining the brotherhood. He (Mike) didnt run the shit (Mikes
alleged agenda) through the executive board, he made unilateral decisions and used
intimidation tactics to push through his agenda.
54. Dan MacDonald also told Ben that there is a high probability that Mike would go
to jail. Dan MacDonald told Ben: dont get involved. Mike is guilty as fuck, he will be
found guilty I have no fucking doubt, it is all verifiable. Mike is a flat out fucking
criminal.
55. Dans behavior is guilty behavior and the awareness of Dan MacDonalds guilt
may be presumed from this behavior. CALCRIM Jury Instruction 371.
56. These oral statements by Dan MacDonald to Ben Rodriguez, are false and
unprivileged publications which tend to directly injure Mike in respect to his office,
profession, trade or business by imputing to him general disqualification in those things
which his office or occupation requires. The statements injured Mike in his profession,
etc., because they attack Mikes veracity as an esteemed member and EST with the
SWRCC. These statements also accuse Mike of being a criminal and committing criminal
acts. Such statements are made expressly by Dan MacDonald.
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57. By natural consequence, this has caused Mike substantial damage.
58. It is clear from the recording that Ben Rodriguez understood the statements were
about Mike as the statements were directly in reference to Mike.
59. The statements are entirely false as they pertain to Mike and they are defamatory on
their face and exposed Mike to hatred, contempt, ridicule and obloquy because Mike
engaged in no wrongdoing regarding the allegations made against him.
60. These statements were understood, by those who heard them, and continue to hear
them, in a way that defamed the reputation of Mike as a well respected hard working EST
and member of the community of carpenters in that the statements imply efforts by Mike
to steal from the union.
61. Complaining party avers that the counter defendants, and their agent, Dan
MacDonald, failed to use reasonable care to determine the truth or falsity of the
statements.
62. Complaining party avers that the wrongful conduct of the counter defendants, and
their agents, was a substantial factor in causing Mike the harm complained of herein,
including, but not limited to, the loss of his income, his position at the SWRCC for which
he worked for over 10 years to acquire, his business, trade, profession, occupation, harm
to Mikes reputation, expenses he has had to pay to try to clear his name, including
investments of his time, in addition to the harm assumed by law.
63. As a proximate result of the above-described statements, Mike has suffered loss to
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64. As a further proximate result of the above-described statements, Mike has suffered
loss of business, in an amount to be proven at trial.
65. By engaging in the above conduct, Counter and third party defendants, and each of
them, acted with malice, oppression, and/or fraud, entitling Mike to exemplary and
punitive damages.
66. On or about 9/9/13, at the supervision hearing, Mr. Weidner, on behalf of himself
and the UBC defamed Mike by stating an association between Mike and gangland
murderers and calling his behavior irrational and erratic.
SECOND CAUSE OF ACTION
[Defamation: Against Third Party defendants]
68. Counter Claimant makes the following claims against the following third party
defendants:
69. The United Brotherhood of Carpenters and Joiners of America: On September 11,
2013 Douglas Banes, General Vice President of the UBC, on behalf of the UBC, issued a
memo to all members of the Local Unions affiliated with the SWRCC giving notice of the
Supervision hearing which was to take place on 10/16-18/13. Ex. ___. This letter was
published to all local unions in the 6 states making up the SWRCC. This letter, and all the
defamatory statements therein, are incorporated herein by this reference, including all
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instances of defamation. Mike avers that they are all published, false and defamatory
causing him damage. Some of the examples in this letter are:
70. = Mikes management is described as the dis-functioning and autocratic
leadership of Southwest Councils Executive Secretary Treasurer, Mike McCarron, which
had taken it far from sound fiscal, democratic and orderly management. (p.2, 1
st
par.)
71. = Supervisor Draper uncovered hundreds of thousands of dollars in additional
hidden losses as well as wasteful and unapproved expenditures.
72. = EST Mike McCarron unilaterally pledged millions of dollars of Southwest
Councils assets . . . to provide collateral for lines of credit extended by the bank to the
following contractors (listed). Without these pledged CDs, the banks would not have
given these contractors lines of credit. The total amount currently pledged is almost $3
million dollars. The letter then claims that the money was lost. (p.2-3).
73. = In making these transactions Mike acted against the advice of the Southwest
Councils attorneys. (p.3, 2
nd
par.)
74. = The letter accuses Mike of failing to disclose such transactions to, or seek
approval from, the Southwest Councils Executive Committee . . . and violated the
Southwest Councils bylaws [and] section 501 of the Labor Management Reporting
Disclosure Act (LMRDA). (p.3, par. 3).
75. = The defamatory letter accuses Mike over substantial periods of time of failing
to provide any receipts to support his credit card expenses. (p.3, par.6). The letter then
claims that [w]ithout receipts, the Southwest Council has no way to verify whether any
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of the credit card purchases were improper. This, of course, is not true, as the purchases
can be verified from the statements.
76. = The defamatory letter, based on some contrived intent imputed to Mike, states
that Mike refused to employ any investment professional to monitor or advise the
Council on how to prudently manage these substantial holdings. (p.4, par. 2.)
77. = Regarding the leasing of properties to the Training Trust, the defamatory letter
states that Mike would unilaterally decide what rents the Southwest Council would
charge the Training Trust, and for the majority of the properties leased to the Training
Trust, overcharged rent. (p. 4, par. 3.)
78. = The letter accuses Mike of wrongdoing because, it says, that when Mike
McCarron received the Training Trusts bill for over $5 million dollars he did not submit
them to the Trustees for investigation. (p.4, par. 5.)
79. = Regarding vacations, the letter states that either EST Mike McCarron stole
vacation time or carried more than he should have been allowed under the policy. (p.5,
first full par.)
80. Other defamatory statements published and republished are:
81. = hired personnel when none was needed (p.5, par. 2, 4);
82. = improperly gave out a $20,000 raise (p.5, par. 3, 4);
83. = inadequate review of Southwest Council finances (p. 5, par. last);
84. = failed to document work preservation program (p. 6, par. 1);
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85. = Mike wrongfully and permanently stationed wrongfully purchased
vehicles at airports incurring thousands of dollars in vehicle purchase costs and parking
fees (p. 6, par. 2-5);
86. = Mike wrongfully instructed his chief-of-staff to carry a dozen or so pre-
signed blank checks and hid this practice from his Executive Committee (p.6-7);
87. = Mike unilaterally and autocratically circumvented the Board of Trustees
(p.7, par. last);
88. = The letter charges that EST Mike McCarron has also engaged in a pattern
of intimidation and threats of violence related to the 14D trial (p. 8, par. 6).
89. = The letter then accuses Mike of having ties to gangland murderers to
enforce the bogus threats made above (p. 8, par. 7).
90. = The letter accuses Mike of irrational, erratic and threatening behavior (p.
8, par. last).
91. = Mike failed to assure performance of collective bargaining agreements or
other duties of a bargaining representative (p. 9).
92. These are some of the defamatory published statements in the 9/11/13 letter. There
are many more which are not waived.
93. UBC and Douglas McCarron (General President of UBC): at the meeting of the
Local 1506 chapter, third party defendant, Douglas McCarron, on behalf of himself
and the UBC, called Mike a liar several times in front of the membership in
attendance, about 125 people. At the time, Mike was the EST of the SWRCC and was
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appearing before those members who voted him into the EST office. Mike was the
leader of the largest of the councils. At the time Douglas McCarron held the highest
position in the international union, the UBC.
94. Mike Draper (Western District Vice President of UBC): Mr. Draper presented
the evidence at Mikes supervision hearing beginning on 10/16/13 and Mr. Draper was
the prosecutor at Mikes UBC 14D trial which began on 9/9-13/13.
95. Mr. Draper made a power point presentation at the supervision hearing which
began on 10/16/13 and at the Local 1506 meeting in November, 2013. This power
point presentation made defamatory comments about Mike, such as:
96. = Mike was exhibiting erratic behavior;
97. = Mike failed to turn in his credit card receipts
98. = that Mike stole $5 million from SWRCC and the JATC;
99. = and that Mike wrongfully committed SWRCC funds for the building of a
garage in Denver, CO which was not needed; wasted SWRCC funds by building a
glulam roof at a new building in Buena Park, CA when it was not needed and wasted
SWRCC money by purchasing, without authority, new luxury Chevy Suburbans.
100. Mike avers that the members of the carpenters community heard and/or read the
defamatory statements and reasonably understood that the statements each defendant
made was about Mike as these statements referenced Mike expressly.
101. All the above statements are entirely false as they pertain to Mike and they are
defamatory on their face. These statements exposed, and continue to expose, Mike to
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hatred, contempt, ridicule, and obloquy because Mike did not do those things which were
said of him that he did. These statements were understood by all who heard or read them
in a way that defamed the reputation of Mike as a well respected hard working EST and
member of the community of carpenters in that the statements imply efforts by Mike to
steal from the union.
102. As a proximate result of the above-described publication, Mike has suffered loss to
103. Mike avers that in engaging in the above conduct, Counter and third party
defendants and DOES 1-___ inclusive, and each of them, acted with malice, oppression,
and/or fraud, entitling Mike to exemplary and punitive damages.
104. Robert Phil Newkirk and the SWRCC: On April 10, 2014 Mr. Newkirk penned a
letter on behalf of himself and the SWRCC in which he wrote defamatory statements
about Mike which were published to all the members of the SWRCC which covers 6
western states. In that letter, attached as Ex. ___, Mr. Newkirk wrote that Mike:
105. = spent over a hundred thousand dollars of undocumented charges on SWRCC
credit cards;
106. = pledged assets worth three million dollars as collateral for SWRCCs employers
lines of credit without providing legal protections of the assets;
107. = charged the Southwest Training Fund above market rents which constituted a
prohibited transaction under federal law in an amount which exceeded $5 million.
108. = characterized these allegations as serious financial violations.
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109. As a proximate result of the above-described publication, Mike has suffered loss to
THIRD CAUSE OF ACTION
(Conspiracy against counter defendants and all third party defendants)

112. In publishing each and every statement, either in writing or orally, counter and third
party defendants, and each of them, engaged in a conspiracy to defame Mike, to ruin his
reputation, to deprive him of his livelihood, to wrongfully terminate him, to oust him from
his occupation and strip him of his rank. The evidence of the collaboration by the counter
and third party defendants shows that they acted together in the formation and operation
of the conspiracy to issue those defamatory statements as set forth herein pursuant to the
conspiracy which resulted in the damages claimed herein.
113. The counter and third party defendants, and each of them, also conspired to affect
the outcome of the supervision hearing and the 14D trial:
114. Mike avers that the union had an open member admissions policy as long as the
applicant was a carpenter or other covered professional. Mike chose as his lawyer, for the
14D trial and the supervision hearing, his daughter Michelle McCarron who is a carpenter
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and a lawyer. Michelle applied for admission as a member to the union in order to
represent Mike at the hearing and she was wrongfully denied membership. Mike avers
that this denial was issued to deprive him of his chosen representation in order to affect
the outcome of the trial.
115. By reason of the foregoing, Mike has suffered and continues to suffer damages
in a sum which is, as yet unascertained. Mike will ask leave of court to amend these
counter and third party complaints when the true nature and extent of Mikes damages
have been ascertained.
FOURTH CAUSE OF ACTION
Unfair Competition (B&P 17200 et. Seq.
(Against all counter and third party defendants)

117. By reason of counter and third party defendants and each of their fraudulent,
deceptive, unfair and other wrongful conduct as herein alleged, said counter and third
party defendants, and each of them, have/has violated California Business Code section
17000, et. seq. including B&P section 17200, et. seq. by conspiring together, and planning
individually, and consummating an unlawful, unfair and fraudulent business practice,
designed to defame Mike, to ruin his reputation, to deprive him of his livelihood, to
wrongfully terminate him, to oust him from his occupation and strip him of his rank.
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FIFTH CAUSE OF ACTION
Violations of the Labor-Management Reporting and Disclosure Act (LMRDA)

120. Ratification: The UBC ratified the unlawful actions by the SWRCC and its agents,
and the SWRCC and its agents ratified the unlawful actions by the UBC and its agents, in
charging Mike with malfeasance and removing him from office. The UBC incurred
liability for ratification because it affirmed the Locals actions with full knowledge that it
was part of an overall scheme to suppress dissent in violation of the LMRDA. In fact, the
UBCs and Douglas McCarrons ratification went even further than passive ratification.
The UBC and Douglas McCarron, in ratifying the wrongful actions and statements against
Mike, wrongfully terminated and removed Mike from office and placed Michael Draper
in his stead at the head of the SWRCC as its supervisor. Mr. Draper took over all activities
of the SWRCC.
121. The SWRCC and its agents ratified the unlawful actions by the UBC and its agents,
in charging Mike with malfeasance and wrongfully terminating him and removing him
from office. The SWRCC incurred liability for ratification because it affirmed the UBCs
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and its agents actions with full knowledge that it was part of an overall scheme to
suppress dissent in violation of the LMRDA.
122. Retaliation: On information and belief, the UBC is in violation of section 101(a)(2),
and liable to Mike, for retaliation for Mikes opposition to union polices. Mike was a
union member at the time of the occurrence of the acts alleged herein. Mike exercised his
rights to oppose Douglas McCarron and the UBC policies for which he was subject to
retaliatory disciplinary action which was a direct result of Mikes decision to express
disagreement with the unions leadership (Casumpang) as follows:
123. = Mike voiced objection to the DeCarlo & Shanley firm crafting and causing the
implementation of Special Amendment #2 which carved out a special exemption for
Douglas McCarron to collect his pension while he was still employed.
124. = Mike voiced objection to the UBC and Douglas McCarron for their decision to
re-hire one Sandy Maloney, who, on information and belief, was the girlfriend of Douglas
McCarron, transferred her back from Las Vegas to the Fremont Building in violation of
an agreement between Mike and Douglas McCarron, and, to give her a $66,000 raise, a
company car and an approximately $2,500/mo. apartment in Marina Del Rey at the
expense of the Trust Fund.
125. = Douglas McCarron and the UBC had a policy of lending money to union shops
in hard times to keep the members employed. Douglas McCarron and the UBC made a $1
million per year pledge to a drywall contractor, E&K of Denver, CO, which was for
buying down bids for competitiveness. Douglas McCarron wrongfully transferred the
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liability of that debt to the SWRCC. Mike complained about imposing this liability on
SWRCC when this was a UBC program.
126. = Douglas McCarron, and UBC, had a policy of lending money to union shops in
hard times to keep the members employed. Douglas McCarron and the UBC made a loan
to a shop called John Jory. Douglas McCarron wrongfully transferred the liability of that
debt to the SWRCC. Mike complained about imposing this liability on SWRCC when this
was a UBC program.
127. Mike also avers that Douglas McCarrons retaliation against Mike was due, in fact,
to a rift the brothers had regarding the death of their mother on or about 5/21/13. The
following day Douglas McCarron accused Mike of removing Doug as a trustee on the
moms trust. Mike responded that Doug was never a trustee. Douglas McCarron then
called Mikes wife, Kathy McCarron, a cunt and made fun of her Mexican ethnicity
when Douglas McCarron said that fucking Mexican to Mike.
128. The following day, at their moms funeral, the brothers engaged each other again
and Douglas McCarron threatened Mike when he said is that what you want? Then
youre done.
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SIXTH CAUSE OF ACTION
Violations of the Racketeer Influenced Corrupt Organizations Act (RICO)

131. Counter and third party complainant incorporates by reference paragraphs 1
through ___ as though fully set forth here.
132. Counter and third party defendants, and each of them, are persons within the
meaning of 18 USC sec. 1961(3). All of Counter and third party defendants predicate
acts have a similar purpose: to wrongfully terminate and remove Mike from his post as
EST thereby depriving him of his livelihood, profession, position, etc., and to create an
example of what happens to members who cross Douglas McCarron and his co-
conspirators.
133. Counter and third party defendants, and each of them, committed acts of
racketeering within the meaning of 18 U.S.C. 1961, as follows:
134. = They conspired to maliciously charge Mike with false charges affecting his
reputation, livelihood and profession;
135. = They committed defamation against him as set forth above;
136. = They engaged in unfair business practices against Mike as set forth above.
137. = Violations of 18 U.S.C 1341 involving mail fraud including placing the
fraudulently created email (Ex. 45 of the 14D trial documents) in the mail to Mike to
further this unlawful scheme.
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138. Violations of 18 U.S.C 1341 involving mail fraud, including, for placing the
Supervision Hearing letter dated 9/11/13 which contained the fraudulent allegations
against Mike to every member of the SWRCC Regional Council which was also read
to the members at the locals meeting.
139. Counter and third party defendants, either directly or through their agents or as
part of the overall conspiracy as described herein, misrepresented Mikes activities vis-
-vis the SWRCC. The allegations against Mike are bogus trumped up charges and are
part of the way the union does business, or, have a valid explanation.
140. These misrepresentations were made either willfully, or alternatively,
negligently, without regard for their truth. The misrepresentations were intended by
Counter and third party defendants to be relied on by the members of the union to
cause hatred of Mike in the union.
141. Counter and third party defendants either willfully, or alternatively, negligently,
prevented the members of the union from fully understanding the true nature of the
feud between Douglas and Mike McCarron or the true facts of Mikes service to the
SWRCC.
142. Counter and third party defendants also fraudulently and intentionally concealed
evidence from the members and the judges at the supervision hearing and the 14D trial
for the purpose of obtaining a conviction improperly.
143. One of the charges against Mike, which was published to all the members, was
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that he used his union credit card for personal expenses and never turned in receipts
and never paid back the union. This is a false accusation. Yet, at no time did Counter
and third party defendants ever produce the credit card statements which would show
the nature of each charge or the purchasees identity to contact them.
144. Another example of concealing evidence occurred when the Washington, DC
firm of Williams & Connelly threatened Pat Conner, a former lawyer with the DeCarlo
& Shanley firm, plaintiffs current counsel, with fines and sanctions if he testified at
the 14D trial on behalf of Mike. He did not testify. He would have testified that the
leases at issue were not negotiated by Mike.
145. The racketeering acts committed by the Counter and third party defendants, and
each of them, constitute a pattern of racketeering activity within the meaning of 18
U.S.C. 1961(5) in that they are related to one another and are continuous. These
racketeering acts are continuous in that they have occurred over a period of time, will
continue into the future, and pose the threat of continuing for years. The racketeering
activities also pose a risk of continuation because Counter and third party defendants,
including Doug McCarron, Mike Draper, and their co-conspirators have used Mikes
case as an example that other members should fear for their security in their careers if
they dont comply with the arbitrary policies of the UBC and Doug McCarron.
146. The UBC, Douglas McCarron, Dan MacDonald, Douglas Banes and the
SWRCC are RICO enterprises within the meaning of 18 U.S.C. 1961(4), the activities
of which affect interstate or foreign commerce, and is continuous and has an ongoing
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structure and organization sufficient to permit its associates to commit a pattern of
racketeering activity.
147. Counter and third party defendants also violated 18 USC 1962(d) by conspiring
as alleged herein to violate 18 USC 1962(c).
148. As a direct and proximate result of Defendant's violation of 18 U.S.C. 1962(c),
Counter and third party complainant have suffered injury to their business or property,
including legal fees, investigative fees, damages (which should be trebled) court costs,
wrongful termination and deprivation of Mikes career and deprivation of his income
associated with that profession. Mike has also suffered extreme defamation to his
reputation both professionally and personally.
SEVENTH CAUSE OF ACTION
Violation of Mikes due process rights

151. The actions of the counter and third party defendants, and each of them,
unlawfully deprived Mike of his right to a full and fair hearing in violation of
Section 101(a)(5)(C) of the LMRDA, 29 U.S.C. 411(a)(5). Section 101(a)(5)
provides, No member of any labor organization may be fined, suspended, expelled, or
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otherwise disciplined . . . unless such member has been . . . (C) afforded a full and fair
hearing. Section 101(a)(5) (C) of the LMRDA guarantees union members a full and
fair disciplinary hearing, and this guarantee requires the charging party to provide
some evidence at the disciplinary hearing to support the charges made. Intl Bhd. of
Boilermakers v. Hardeman (1971) 401 U.S. 233, 246-47 (citations omitted).
152. Mike avers that neither the supervision hearing nor the 14D trial was fair. In this
case, counter and third party defendants failed to consider evidence which would have
exonerated Mike, such as the credit card statements. They set the supervision hearing in
Las Vegas when all of Mikes witnesses live in the Los Angeles area. The UBC paid for
40 employees, including wages and their room fees, to act as witnesses and give
testimony adverse to Mike in Los Vegas, while Mikes witnesses had to pay their own
way, which, of course, deterred Mikes witnesses from attending the supervision hearing.
They passed a special hearing rule for Mikes supervision hearing that the defendant was
now subject to cross examination when in prior supervision hearings the defendant was
not subject to cross examination. DeCarlo & Shanley wrote Mike a letter dated ___ which
admonished Mike about taking copies of any documents which might support his
defenses, thereby making it impossible for Mike to prove his case.
153. Mike avers that the union had an open admissions policy. Mike chose as his
lawyer, for the 14D trial and the supervision hearing, his daughter Michelle McCarron,
who is a lawyer. Michelle applied for admission as a member to the union in order to
represent Mike at the hearings and she was wrongfully denied membership. Mike avers
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that this denial was given to deprive him of his chosen representation in order to affect the
outcome of the trial.
EIGHTH CAUSE OF ACTION
Violation of Mikes free speech rights (LMRDA)

157. By considering a run for office against Douglas McCarron, voicing opposition to
Douglas McCarron and voicing other opinions concerning union affairs, Counter and
third party complainant engaged in activities protected under Sections 101(a)(1) and
(2) of the LMRDA, 29 U.S.C. 411(a)(1) and (2).
158. Counter and third party defendants retaliated against Counter and third party
complainant for exercising these rights by means of the above disciplinary process.
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159. Counter and third party defendants interfered with Counter and third party
complainants exercise of these rights through the disciplinary process described
above.
NINTH CAUSE OF ACTION
Abuse of Process: Against all counter and third party defendants

163. By using the processes of the Supervision Hearing, the 14D trial and the instant
litigation to wrongfully terminate and remove Mike from his post, deprive him of his
livelihood and maliciously defame him, the counter and third party defendants, and
each of them, entertained an ulterior motive in using these processes. Their collective
and individual acts of conspiring to use these processes to wrongfully terminate and
damage Mike was a willful act done in a wrongful manner.
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TENTH CAUSE OF ACTION
Bad Faith
(Against third party defendant Ullico)

167. California law implies a covenant of good faith and fair dealing in all contracts
between parties entered into in the State of California.
168. Within the contractual claims period, after Mike had been charged as set forth
herein, Mike made a claim for coverage and representation to Ullico which provided a
policy of insurance which covered this claim. Ullico was notified of the loss and
unreasonably failed to investigate the claim and bestow policy benefits on Mike. This
denial of benefits was wrongful and was a substantial factor in causing harm to Mike.
169. As a result of the actions of counter and third party defendants, and each of
them, set forth hereinabove, said counter and third party defendants have violated the
implied covenant of good faith and fair dealing contained in the contract of insurance
as against said Counter and third party complainant herein, and as a result thereof,
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Counter and third party complainant is entitled to damages as prayed.
170. The actions of said defendant as hereinbefore described in violation of said
implied covenant of good faith and fair dealing have caused the Counter and third
party complainant to suffer damages in amount to be proved at trial.
PRAYER
172. WHEREFORE, counter and third party complainant, Mike McCarron, prays for
judgment against all counter and third party defendants and each of them as follows:
173. Preliminarily and permanently enjoining counter and third party defendants to
vacate the penalties imposed against counter and third party complainant;
reinstate Counter and third party complainant to all elected offices from which has
been removed;
reinstate Counter and third party complainant to good standing, retroactive to the date
the charges were first imposed;
176. Permanently enjoining counter and third party defendants from imposing or
threatening discipline against Counter and third party complainant for exercising his
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LMRDA rights to campaign and run for union office and engage in other free speech
activity;
177. Granting Counter and third party complainant their reasonable attorneys fees
and expenses incurred in bringing this action; and
178. Granting such other relief as the Court may deem appropriate and just.
179. Mike also prays for damages as set forth below specific to each cause of action.
The prayer for damages above is incorporated into each cause of action as though fully
set forth.
180. FIRST CAUSE OF ACTION (Slander per Se)
1. for general damages in sum to be proven at trial, but, in an amount no less than
$50,000,000.00.
2. for all special damages in a sum to be proven at trial;
3. for exemplary and punitive damages as allowed by law in a sum to be proven at
trial;
4. for attorneys fees; and,
5. for such other and further relief as the Court may deem just and proper.
181. SECOND CAUSE OF ACTION (Defamation)
$50,000,000.00.
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trial;
182. THIRD CAUSE OF ACTION (Conspiracy)
$50,000,000.00.
trial;
183. FOURTH CAUSE OF ACTION (Unfair Competition)
$50,000,000.00.
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trial;
184. FIFTH CAUSE OF ACTION (LMRDA)
$50,000,000.00.
trial;
185. SIXTH CAUSE OF ACTION (RICO)
$50,000,000.00.
3. Counter and third party complainant is entitled to recover mandatory treble
damages, costs and attorneys fees under 18 USC 1964(c). This Court should also
order appropriate relief under 18 USC 1964(a);
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trial;
186. SEVENTH CAUSE OF ACTION (Due Process)
$50,000,000.00.
trial;

187. EIGHTH CAUSE OF ACTION (LMRDA free speech)
$50,000,000.00.
3. Counter and third party complainant are entitled to recover mandatory treble
damages, costs and attorneys fees under 18 USC 1964(c). This Court should also
order appropriate relief under 18 USC 1964(a);
trial;
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188. NINTH CAUSE OF ACTION (Abuse of Process)
$50,000,000.00.
3. Counter and third party complainant are entitled to recover mandatory
treble damages, costs and attorneys fees under 18 USC 1964(c). This Court should
also order appropriate relief under 18 USC 1964(a);
trial;
189. TENTH CAUSE OF ACTION (Bad Faith)
$50,000,000.00.
3. Counter and third party complainant are entitled to recover mandatory
treble damages, costs and attorneys fees under 18 USC 1964(c). This Court should
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also order appropriate relief under 18 USC 1964(a);
trial;
190. DEMAND FOR JURY TRIAL
Counter and third party complainant hereby demands trial by jury.

Dated: August 16, 2014
THE BLOOM FIRM

By: Alan M. Goldberg
Attorneys for third party and counter complainant
Michael McCarron

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THE
BLOOM FIRM

PROOF OF SERVICE

STATE OF CALIFORNIA ss. COUNTY OF LOS ANGELES )

I am employed in the County of Los Angeles, State of California. I am over the
age of 18 and not a party to the within action. My business address is 22130
Clarendon Street, Woodland Hills, CA 91367.

On the date below I served the following DOCUMENT(s) described as THIRD
PARTY CLAIMS AND COUNTER CLIAMS OF DEFENDANT MICHAEL
MCCARRON electronically or on the interested parties in this action by placing a true
and correct copy in an enclosed sealed envelope as follows:

Daniel M. Shanley, Esq.
DeCARLO & SHANLEY
533 S. Fremont Ave., 9
th
Flr.
Los Angeles, CA 90071-1706
dshanley@deconsel.com

ULLICO
1625 I St.
Washington, DC 20006
800-431-5425

[ ] BY EMAIL: I caused this document to be transmitted by email on the date below.

[X] U.S. MAIL I am readily familiar with the firms practice of collection and
processing correspondence by mailing. Under that same practice it would be
deposited with U.S. Postal Service on that same day with postage fully prepaid at Los
Angeles, California in the ordinary course of business. Following that practice, I
placed the foregoing DOCUMENT(s) for deposit and mailing in the United States
Postal Service that same day with postage prepaid, sealed and addressed as set forth
above, in the ordinary course of business.

[ ] BY U.S.P.S. EXPRESS MAIL SERVICE I am readily familiar with the firms
practice of collection and processing correspondence by overnight mail. Said Mail is
deposited with Overnight Express on that same day with charges made to our account
with that firm at Los Angeles, California in the ordinary course of business.

[ ] BY FAX TRANSMISSION I caused the said DOCUMENT(s) to be transmitted
to the office or residence of the addressee at the above referenced facsimile number.

[ ] BY PERSONAL SERVICE I delivered such envelope by hand to the addressee.

[ ] STATE I declare under penalty of perjury under the laws of the State of
California that the above is true and correct.

[ X ] FEDERAL I declare that I am employed in the offices of a member of this
Court at whose direction the service was made.

Executed on August 18, 2014 at Los Angeles, California.

By: Alan M. Goldberg

Cross Claims Pleading Draft 6 Conformed

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Cross Claims Pleading Draft 6 Conformed

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