08/26/2013 1371 ENDORSED LETTER addressed to Judge Richard M. Berman from Raymond G. McGuire dated 8/22/13 re: Counsel states that the Trustees were polled and each stated he would waive any actual or potential conflict involved with my firm representing both the Funds and CAGNY in connection with the Court's consideration of the recently ratified collective bargaining agreement between CAGNY and the District Council. ENDORSEMENT: Thank you for the 8/22/13. What the Court is seeking--firm KM&M as well as District Council, RO, + AUSA--is a reasoned legal analysis with Authorities, regarding conflicts of interest. See TR. dated 7/16/13. Please submit analyses TODAY!! (Signed by Judge Richard M. Berman on 8/26/2013) (mro) Modified on 8/26/2013 (mro). (Main Document 1371 replaced on 8/26/2013) (mro). (Entered: 08/26/2013)
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8-26-2013 Case 1-90-cv-05722-RMB-THK Document 1371 ENDORSED LETTER addressed to Judge Richard M. Berman from Raymond G. McGuire dated 8/22/13
08/26/2013 1371 ENDORSED LETTER addressed to Judge Richard M. Berman from Raymond G. McGuire dated 8/22/13 re: Counsel states that the Trustees were polled and each stated he would waive any actual or potential conflict involved with my firm representing both the Funds and CAGNY in connection with the Court's consideration of the recently ratified collective bargaining agreement between CAGNY and the District Council. ENDORSEMENT: Thank you for the 8/22/13. What the Court is seeking--firm KM&M as well as District Council, RO, + AUSA--is a reasoned legal analysis with Authorities, regarding conflicts of interest. See TR. dated 7/16/13. Please submit analyses TODAY!! (Signed by Judge Richard M. Berman on 8/26/2013) (mro) Modified on 8/26/2013 (mro). (Main Document 1371 replaced on 8/26/2013) (mro). (Entered: 08/26/2013)
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08/26/2013 1371 ENDORSED LETTER addressed to Judge Richard M. Berman from Raymond G. McGuire dated 8/22/13 re: Counsel states that the Trustees were polled and each stated he would waive any actual or potential conflict involved with my firm representing both the Funds and CAGNY in connection with the Court's consideration of the recently ratified collective bargaining agreement between CAGNY and the District Council. ENDORSEMENT: Thank you for the 8/22/13. What the Court is seeking--firm KM&M as well as District Council, RO, + AUSA--is a reasoned legal analysis with Authorities, regarding conflicts of interest. See TR. dated 7/16/13. Please submit analyses TODAY!! (Signed by Judge Richard M. Berman on 8/26/2013) (mro) Modified on 8/26/2013 (mro). (Main Document 1371 replaced on 8/26/2013) (mro). (Entered: 08/26/2013)
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950 THIRD AVENUE . FOURTEENTH NEW YORK, N.Y. 10022 II RAYMOND C. MCCUII\.E TELEPHONE (212) 644-1010 DlRECT DIAL: (212) 909-0711 ELECTRONICALLY FILED FACSIMLE (212) 644-1936 DlRECT FAx: (212) 909-3511 NEW Yo MCCUIIU@KMM.COM DOC #: lDs ANC DATE FILED: fl2j>!&'/Vl,vW,KMM OM August 22, 2013 BY HAND DELIVERY Honorable Richard M. Berman United States District Court Judge United States District Court for the Southern District of New York Daniel Patrick Moynihan United \,I ... ..,. ...bc> 500 Pearl Street ..................-......... New York, New York 10007-1312 Re: U.S. v. District ofthe United Dear Judge Berman: You directed at the hearing before Your Honor on August 12, 2013 that my firm poll the eleven sitting Trustees of the New York City District Council of Carpenters Welfare, Pension, Annuity, and Apprenticeship, Journeyman Retraining, Educational and Industry Funds (collectively, the "Funds") to determine whether each would waive any actual or potential conflict of interest involved with my firm representing both the Funds and the Contractors Association of Greater New York ("CAGNY") in matters involving CAGNY and the New York City and Vicinity District Council of the United Brotherhood of Carpenters and Joiners of America (the "District Council") that are pending before Your Honor in the above-referenced matter. We did poll the Trustees and each stated he would waive any actual or potential conflict involved with my firm representing both the Funds and CAGNY in connection with the Court's consideration of the recently ratified collective bargaining agreement between CAGNY and the District Council. In an abundance of caution, however, and to eliminate the risk of a recurrence of the appearance of a conflict, CAGNY has retained Dennis Lalli of Bond Schoeneck & King PLLC ("BSK") to represent it in all matters involving it and the District Council, not just in matters arising before Your Honor; Mr. Lalli entered a KM M K AUF F MCGUlI'>E&MARGOL1S LLP Honorable Richard M. Berman August 22, 2013 Page 2 notice of appearance on August 20, 2013. Since neither I nor my firm had entered our appearance on behalf of CAGNY, I have not withdrawn as CAGNY's counsel in the captioned matter. .:=== My firm believes that the substitution of BSK as CAGNY's counsel should eliminate any appearance of a conflict involved in Kauff McGuire & Margolis' ("KM&M") representation of the Funds. We should note that in the two and a half years since my firm started representing the Funds, no actual conflicts involving KM&M, the Funds and CAGNY have arisen. To the extent my firm were called on by the Trustees to give legal advice to the Funds about any matters involving CAGNY or CAGNY members, or by CAGNY or CAGNY members to give legal advice about any matters involving the Funds, we would decline the representation request. At no point during our representation of the Funds have we been called on by the Trustees to give such legal advice to the Funds or by CAGNY or CAGNY members to give advice regarding the Funds. Thank you for your attention to this matter. Ifyou desire additional information or clarification of information in this letter, Mr. Lalli and I will both be present at the hearing presently scheduled for August 26, 2013. Respectfully submitted,
Raymond G. McGuire cc: Board of Trustees (via e-mail) Ryk Tierney (via e-mail) Benjamin Torrance, Esq. (via e-mail) Dennis Walsh, Esq. (via e-mail) Bridget Rohde, Esq. (via e-mail) James Murphy, Esq. (via e-mail) Dennis Lalli, Esq. (via e-mail)
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