Saturday, January 19, 2013

Free Speech Under Attack

(John's note: The District Council is attempting to shut this blog down, thereby silencing yours and mine protected free speech rights! Any attorneys who would like to help protect and defend union members free speech rights please contact me).

On January 13, 2013, I sent the Review Officer (RO) an "Application for Veto," requesting a veto of the charges filed against me on July 25, 2012 by former New York City District Council president Bill Lebo, on the grounds that the charges are a infringement of my “free speech rights” and retaliation in violation of Title I of the Labor- Management Reporting and Disclosure Act (LMRDA), 29 U.S.C. §§ 411-415.

On January 14, the RO sent a "Notice of Possible Action" to District Council attorney James Murphy, relating to my request, requesting among other things, a formal written response on the question of "whether the District Council Executive Committee should proceed with consideration of whether to refer Bill Lebo’s charges" against me to the Trial Committee or "whether 29 U.S.C. Section 411 and the ruling in the Price case, and any other argument asserted by me, preclude such consideration and referral."

The RO stated he would be obliged if the response included "a discussion of whether the District Council suffered any harm as a result of the publication of Mr. Musumeci’s article on the retention of the three attorneys in question and whether any expressly confidential or proprietary information was disclosed in the article (and how Mr. Musumeci was put on notice of such confidential or proprietary status)."

Below is the response from District Council attorneys James M. Murphy and Adrian Healy, received yesterday.

I. Introduction

This memo responds to your request of January 14, 2013 for a statement of position on whether the District Council Executive Committee’s January 10, 2013 referral to the District Council Trial Committee of charges filed by District Council member (and then President) William S. Lebo on July 25, 2012 was proper under the LMRDA and controlling caselaw. Mr. Lebo charged member and Delegate of Local Union 157 John Musumeci with violations of the Constitution of the United Brotherhood of Carpenters (“UBC”) and the District Council’s Bylaws.

For the reasons discussed below, the Executive Committee acted properly. Mr. Musumeci’s request that you veto the charges should be denied. As detailed below, (1) Mr. Musumeci’s LMRDA rights are not violated by the charges; (2) the legal authorities cited by Mr. Musumeci do not compel a different result, and (3) in any event, Mr. Musemci’s request for relief is premature and misplaced.

II. Factual Background

Mr. Lebo’s July 25, 2012 charges allege that Mr. Musumeci violated the UBC Constitution Section 51A, subsections (1), (8), and (12). Those subsections respectively prohibit, “[c]ausing dissension among the members of the United Brotherhood;” “[d]ivulging to any unauthorized person, the business of any subordinate body without its consent;” and “(12) “[v]iolating the obligation.” Mr. Musumeci is also charged with violating sections (2) and 12(G) of the District Council Bylaws. Bylaw Section (2), states that the object of the District Council shall be to “promote and protect the interest of our membership;” and Bylaw Section 12(G) provides that the District Council Executive Committee has the authority and responsibility to provide information about the District Council to the public and membership.1 (1 While a violation of Bylaw Section (2) is listed on Mr. Lebo’s charge form, it is in fact Bylaw Section (3) that states the purpose of protecting the membership.)

Mr. Lebo’s statement in support of the charge provides greater detail. It specifies that on July 18, 2012, Mr. Musumeci posted on his public internet blog ( information about District Council legal strategies in connection with a pending grievance arbitration (the “MWA matter”). The charge alleges that the “MWA arbitration issue is an extremely complicated one” and that the “legal strategies had to be kept confidential so that we could proceed on the best possible ground.” The charge asserts, in sum that by posting the information— including the District Council’s planned retention of co-counsel—Mr. Musumeci has divulged confidential information that may compromise the District Council’s position in the MWA matter.

We understand that at its first reading of the charges on January 10, 2013, the Executive Committee referred the charges to the District Council Trial Committee. Mr. Musumeci’s request for a veto then followed.

III. Processing Internal District Council Charge

Section 52 of the UBC Constitution explains the role of the Executive Committee in the charge and trial process. When charges are filed, they are first presented to the Executive Committee under Constitution Section 52(D). The Executive Committee will examine the charging document and determine whether it adequately specifies the rule or bylaw violated. Assuming it does, the Executive Committee may only dismiss the charges because they are untimely or because the accuser fails to appear in support of the charges. Alternatively, the Executive Committee refers the charge to the Trial Committee.

Thus, the Executive Committee is given little discretion by UBC Constitution Section 52(D). It does not examine the merits of a charge, determining only whether the charge states a decipherable claim. Under Section 52(D)(2)(a) the Executive Committee has the authority to dismiss charges only “for reasons stated in paragraph 1 above [i.e., because the charges allege conduct that took place too long ago] or because the accuser fails to appear before the Executive Committee . . . .” It does not have the express power to dismiss charges for any other reason, so long as the charge states a cognizable violation of the rules or Bylaws.

Nonetheless, Mr. Musumeci has asked you, acting pursuant to your authority under Paragraphs 5.b.i, and 5.b.iii, or 5.f.v of the June 3, 2010 Stipulation and Order in United States v. District Council, et al., 90 Civ. 5722, to halt this process because he claims that the charges violate his free speech rights LMRDA §101(a)(2), 29 U.S.C. § 411(a)(2).

IV. The Charges Do Not Violate LMRDA Section 101(a)(2)

LMRDA Section 101(a)(2), 29 U.S.C. § 411(a)(2) provides,

Every member of any labor organization shall have the right to . . . express any views, arguments, or opinions; and to express at meetings of the labor organization his views, upon candidates in an election of the labor organization or upon any business properly before the meeting, subject to the organization's established and reasonable rules pertaining to the conduct of meetings: Provided, That nothing herein shall be construed to impair the right of a labor organization to adopt and enforce reasonable rules as to the responsibility of every member toward the organization as an institution and to his refraining from conduct that would interfere with its performance of its legal or contractual obligations.

(emphasis added). LMRDA § 101(a)(2) protections covers a wide range of union member speech on union matters. Libelous, offensive, and even false speech is protected. So too are critical attacks on union leadership, profanity, and petty name-calling. E.g., Petramale v. Local 17 of Laborers Int’l Union, 736 F.2d 13 (2d Cir. 1984) (Union cannot discipline member for slanderous statements critical of union officers); Farrell v. Hellen, 367 F.Supp. 2d 491 (S.D.N.Y. 2005) (Continuously calling union officers “mother-fuckers” was part of protected speech).

On the other hand, “free speech” under 101(a)(2) is not limitless. The statute does not extend to all member speech. A union may proscribe conduct, even if it interferes with interests protected by § 101(a)(2), as long as the union’s prohibition is “reasonably related to the protection of the organization as intuition.” United Steelworkers of Am. v. Sadlowski, 457 U.S. 102, 111-12 (1982). Mr. Musumeci’s request for your veto of the current charges entirely disregards the proviso highlighted above.

The present charges do not attack Mr. Musumeci’s right to speak out against union leadership or policies. Indeed, no member has ever sought to silence Mr. Musumeci’s speech on account of his viewpoints. His blog is continuously updated, with much material that could be considered disparaging at best, and defamatory at worst. And he concedes that no charges have even been filed against him.

Here, the central focus of Mr. Lebo’s charges is Mr. Musumeci’s disclosure of information that could damage the union’s position in a pending legal proceeding. That allegation states a violation of UBC Constitution Section 51A(8). And union rules that seek to protect sensitive union information from outsiders are reasonable attempts to preserve confidentiality and fall within the LMRDA § 101(a)(2) proviso. Quigley v. Giblin, 569 F.3d 449 (D.C. Cir. 2009).

In Quigley, members alleged violations of § 101(a)(2) when their international union passed a resolution requiring that union campaign websites would be password protected and accessible only to members. Id. at 452-53. The plaintiffs alleged that the rule frustrated and interfered with the campaigning members’ right to communicate with other members. Id. at 454. The court held that while the rule affected member interests under § 101(a)(2), it was reasonable and permissible under the proviso because it related to the union’s legitimate interest in protecting sensitive union information. Id. at 456-57.

The same principles apply here. UBC Constitution Section 51A(8) prohibits unauthorized divulgence of union business. Mr. Musumeci is alleged to have publicly distributed sensitive information about the union’s legal strategy in connection with the MWA matter. Section 51A(8) appears to be reasonably applicable here. The District Council has a legitimate interest in shielding its litigation and grievance strategies from the public, lest an employer or party-opponent could receive portions of that information and use it to the Union’s detriment.

In this connection, the lower court in Quigley (with whom the D.C. Circuit Court of Appeals agreed) noted that the union has a valid interest in protecting information about “negotiating, organizing, and grievance handling strategy and tactics.” Quigley v. Giblin, 582 F.Supp.2d 1, 12 (D.D.C. 2008). Retention of counsel is unquestionably an aspect of strategy. Mr. Musumeci, along with only the other District Council delegates, received an email from the District Council on July 16, 2012 about the possible retention of special outside counsel. Moreover, Mr. Musumeci’s blog article reveals the following about how MWA matter will be handled: “[t]he attorneys will ‘dispute the arbitrators [sic] decision’ and present questions which will involve the calculation of the ‘damages’ . . . .”

You have asked whether Mr. Musumeci was put on notice that the information in the July 16, 2012 email was confidential or proprietary. The very fact that the email was sent to this select group for action (as opposed to distributed in a public forum) indicates that the information contained therein was private.

You have also asked whether the District Council suffered any harm as a result of the publication of Mr. Musumeci’s article. But the LMRDA does not require a showing of actual harm in order for a reasonable rule to be imposed upon member communications. In Quigley, the D.C. Circuit held that “'[s]ection 101(a)(2) does not impose an evidentiary burden but requires only that a union rule be ‘reasonable.’” 569 F.3d at 456. The union was therefore not required to offer evidence that actual harm fell on the union from members broadcast of sensitive information. Id.

V. The Authorities Relied Upon by Mr. Musumeci Are Not Applicable Here

Mr. Musumeci, who is not an attorney, does a commendable job of recognizing certain LMRDA statutory goals. Yet, the legal authorities he cites are inapplicable here and actually cut against the position that he attempts to articulate. He recites a portion the Supreme Court’s Sadlowski decision regarding the legislative purposes behind enactment of LMRDA Title I. See Sadlowski, 457 U.S. at 111 (1982). Yet, he leaves out equally critical portions of the Court’s holding. The Court held that LMRDA’s free speech rights are not coextensive with the rights guaranteed by the First Amendment of the U.S. Constitution. Id. 111. (“There is absolutely no indication that Congress intended the scope of § 101(a)(2) to be identical to the scope of the First Amendment.” And, “First Amendment principles may be helpful, although they are not controlling.”)

Mr. Musumeci cites Knox County Local, Nat’l Rural Letter Carriers’ Ass’n v. Nat’l Rural Letter Carriers’ Ass’n, 720 F.2d 936, 937 (6th Cir. 1984) for the simple principle that LMRDA’s Title I free speech provisions are “modeled after the First Amendment.” He then appears to argue that the LMRDA’s free speech provisions are equivalent to the right to free speech under the U.S. Constitution. As stated above, the law plainly provides otherwise. Christian Legal Society v. Walker, 453 F.3d 853 (2005), a case referenced by Mr. Musumeci, where First Amendment rights where asserted (pursuant to one of the post-Civil War civil rights statutes, 42 U.S.C. § 1983) also has no application here. It is not an LMRDA case.

Finally, Mr. Musumeci cites Price v. Carpenters' Dist. Council of Greater St. Louis & Vicinity, 10-CV-0741-MJR-PMF, 2010 WL 3958669 (S.D. Ill. Oct. 8, 2010). In that case, a Carpenters District Council representative tried to force member Price to get rid of a bumper sticker that criticized the union. Id. at *2. The representative told Price that the sticker would have to be removed from Price’s truck or else he would be brought up on charges. Id. Price did not remove the sticker and was charged, among other things, with “causing dissension amongst the Brotherhood” (under the UBC Constitution). The court granted Price’s application for a preliminary injunction to prevent the union from pursuing the charges.

Price is inapplicable here, however, because that case dealt with an unreasonable content based prohibition on speech. The union’s application of the UBC Constitution in Price was plainly unreasonable because the member’s public expression of his views about the union by way of the bumper sticker were plainly within LMRDA § 101(a)(2)’s protections. The union there appeared to rely on an unreasonable rule that would interfere with Price’s speech. Here, the opposite is true. Mr. Musumeci’s communications have exposed sensitive union information and the union is entitled to curb dissemination of its private business information under the LMRDA § 101(a)(2) proviso.

VI. The Request For Relief is Premature

Even setting aside the above discussion, Mr. Musumeci’s request for “veto” relief is premature. First, as discussed above, the Executive Committee’s discretion is strictly limited. It can only dismiss charges for specifically enumerated reasons. Mr. Musumeci asked the Executive Committee to dismiss his charges on the merits. A review and decision on the merits is not within the Executive Committee’s authority under UBC Constitution Section 52. Therefore, Mr. Musumeci’s request to the Executive Committee was misdirected, though it may still be raised before the Trial Committee.

Second, Mr. Musumeci appears to rely on Stevens v. NW. Indiana Dist. Council of Carpenters, 20 F.3d 720, 721 (7th Cir. 1994) to suggest that exhaustion of intra-union remedies is not required prior to initiating a LMRDA Title I case. However, it is within the discretion of the courts to determine whether exhaustion of remedies is required. And the courts do so on a case by case basis. The courts “must balance the right of union members to institute suit against the policy of judicial noninterference in union affairs.” Maddalone v. Local 17, United Broth. of Carpenters & Joiners of Am., 152 F.3d 178, 186 (2d Cir. 1998) (quoting Johnson v. General Motors, 641 F.2d 1075, 1079 (2d. Cir. 1981) (internal quotation marks omitted)). The courts examine three factors in determining whether the exhaustion doctrine applies:

[F]irst, whether union officials are so hostile to the employee that he could not hope to obtain a fair hearing on his claim; second, whether the internal union appeals procedures would be inadequate either to reactivate the employee's grievance or to award him the full relief he seeks . . . ; and third, whether exhaustion of internal procedures would unreasonably delay the employee’s opportunity to obtain a judicial hearing on the merits of his claim.

Maddalone, 152 F.3d at 186 (quoting Clayton v. Int’l Union, UAW, 451 U.S. 679, 689 (1981)).

Mr. Musumeci presently seeks relief from you that would otherwise be available only in court before a U.S. District Judge. Therefore, an application of the exhaustion analysis is appropriate here. This inquiry starts and stops with the first factor. Here, no union official has any hand in the Trial Committee’s deliberations, proceedings, or adjudications. In short, there is no question that Mr. Musumeci will be entitled to fair consideration of his charges.

VII. Conclusion

For the foregoing reasons, the District Council’s Executive Committee properly referred the charges against Mr. Musumeci to the Trial Committee. This memo expresses no other opinion aside from those specifically set forth herein.



  2. The Bilello administration is the most totalitarian and secretive administration in the history of the UBC. They have targeted me since day one of being sworn in and they will be coming after you next.

    Consider the following regarding Murphy's response:

    The District Council cannot show they suffered any harm as a result of the article posted.

    The District Council cannot show that I disclosed "its litigation and grievance strategies."

    The District Council cannot show that they provided the information that, “[t]he attorneys will ‘dispute the arbitrators [sic] decision’ and present questions which will involve the calculation of the ‘damages’ . . . .”

    The District Council's reasoning that "the email was sent to this select group for action (as opposed to distributed in a public forum) indicates that the information contained therein was private," is absolutely ridiculous and flawed.

    This was not private information, Between May 13, and July 18, I had several different sources contact me, and I made several calls to different sources seeking information on the MWA Arbitration. All my sources among other things, discussed the retention of the three attorneys in question, and all had and knew all the details of the July 16, email sent by Yariela Carvaljal.

    Also, What is remotely confidential about the simple selection of a law firm for an arbitration matter, given most likely that every other delegate informed members of exactly the same information and, given that Union Delegates, duly elected are required to keep the District Council's disenfranchised Local Union members (or rank & file) informed.

    Is that not the essential purpose of Delegates, to inform members of the goings on at the District Council, given they refuse to do so via letter, postcard, mailing, pony express or updating of their website (an admitted failure of Bilello as recently as the 1-16-13 RO Town Hall).

    Nothing and absolutely nothing about the article in question (which is predicated on media sources & intel) involves confidentiality.

    Nothing in the article is proprietary, a trade secret, a patent, a process etc. warranting the blanket confidentiality the District Council seeks.

    To date I have posted 28 articles involving the MWA (not including the numerous comments from members in the forum) and the District Council has not written one word or has informed the membership of the MWA Arbitration Crisis, which I have as a "Hot Topic" on this blog.

    The District Council is a total disgrace!

  3. Bilello, akin to what he did with Franco on the 16th at the R.O. forum now wants John to come & kiss the ring because he cannot adapt or accept a world where the pace of technology exceeds his mental capacity to embrace it; and, make good use of it. It is a tool no different than a hammer or skil-saw. In a world of technology, Bilello is an admitted dinosaur.

    John has embraced this tool called the internet and used it to educate & inform those that would otherwise be intentionally left in the dark.
    Left to EST Bilello, his preference would be the world of tree killing and letter writing so he & others could round file member concerns and label those that don't drink the proverbial Kool-Aid deranged commie's, loners & dissidents. (McCarrons favortie line).

    The internet, blackberry's, i-phones, twitter etc are instantaneous. John waited two days prior to publication of his story. In this day & age it was ancient news!

    Moreover, the D.C. did not pursue charges against any other delegate. Quite assuredly, their phone & internet records would show others who would be similarly charged were an adequate investigation performed. Instead, the D.C. and Lebo & Bilello had an axe to grind with John and in a retaliatory move on their part singled him out for destruction.

  4. Does anybody know whats going on with the mwa arbitration. Was it today nobody knows anything. Nobody has any answers who ever you ask.

  5. John; Didn't the electronic "emergency" Delegate vote controversy, outright refusal to include any considerstion of debate, play a factor in the subsequent need to inform the membership about anything re: MWA. Then there was that apparant authority question you posed to the dais, man they hated that. Wasn't it the "secrecy" @ 395 which begun that journey. Perhaps the Bilello admin further waved their imperial arms when they saw you @ the delegate meeting & said - OUT!

  6. Fuckin' John Musumeci-- one of the delegates who actually takes democracy seriously, and cares enough to get the word out to the membership-- no good deed goes unpunished. If anything, they're retaliating against you for doing the job they fail to do. Time to step up and support the source of info for rank-and-file Carpenter. We know the Council website isn't.

  7. In Bartnicki v. Vopper, aka Williams, the U.S. Sup. Ct. stated:

    In this case, privacy concerns give way when balanced against the interest in publishing matters of public importance. As Warren and Brandeis stated in their classic law review article: "The right of privacy does not prohibit any publication of matter which is of public or general interest." The Right to Privacy, 4 Harv. L. Rev. 193, 214 (1890). One of the costs associated with participation in public affairs is an attendant loss of privacy.

    "Exposure of the self to others in varying degrees is a concomitant of life in a civilized community. The risk of this exposure is an essential incident of life in a society which places a primary value on freedom of speech and of press. `Freedom of discussion, if it would fulfill its historic function in this nation, must embrace all issues about which information is needed or appropriate to enable the members of society to cope with the exigencies of their period.' " Time, Inc. v. Hill, 385 U. S., at 388 (quoting Thornhill v. Alabama, 310 U. S. 88, 102 (1940)).21

    Our opinion in New York Times Co. v. Sullivan, 376 U. S. 254 (1964), reviewed many of the decisions that settled the "general proposition that freedom of expression upon public questions is secured by the First Amendment." Id., at 269; see Roth v. United States, 354 U. S. 476, 484 (1957); Bridges v. California, 314 U. S. 252, 270 (1941); Stromberg v. California, 283 U. S. 359, 369 (1931). Those cases all relied on our "profound national commitment to the principle that debate on public issues should be uninhibited, robust and wide-open," New York Times, 376 U. S., at 270; see Terminiello v. Chicago, 337 U. S. 1, 4 (1949); De Jonge v. Oregon, 299 U. S. 353, 365 (1937); Whitney v. California, 274 U. S. 357, 375-376 (1927) (Brandeis, J., concurring); see also Roth, 354 U. S., at 484; Stromberg, 283 U. S., at 369; Bridges, 314 U. S., at 270. It was the overriding importance of that commitment that supported our holding that neither factual error nor defamatory content, nor a combination of the two, sufficed to remove the First Amendment shield from criticism of official conduct. Id., at 273; see also NAACP v. Button, 371 U. S. 415, 445 (1963); Wood v. Georgia, 370 U. S. 375 (1962); Craig v. Harney, 331 U. S. 367 (1947); Pennekamp v. Florida, 328 U. S. 331, 342, 343, n. 5, 345 (1946); Bridges, 314 U. S., at 270.

    We think it clear that parallel reasoning requires the conclusion that a stranger's illegal conduct does not suffice to remove the First Amendment shield from speech about a matter of public concern.22 The months of negotiations over the proper level of compensation for teachers at the Wyoming Valley West High School were unquestionably a matter of public concern, and respondents were clearly engaged in debate about that concern. That debate may be more mundane than the Communist rhetoric that inspired Justice Brandeis' classic opinion in Whitney v. California, 274 U. S., at 372, but it is no less worthy of constitutional protection.

    The judgment is affirmed.

  8. Per the above base precepts, given that the NYCDCC's pattern of racketeering have gone on, generally unabated in the overall scheme of the Consent Decree, but generally tamed somewhat under Walsh's tenure; and, that it continues to remain in the public eye or public arena, the NYCDCC cannot hide behind the UBC Constitution or it's phony obligation given its having been declared unconstitutional by the the NLRB.

    The pattern of racketeering continues to this day and the Fed's could easily convene a grand jury against Sheil, Thomassen, Spencer & McCarron for executing a contract in direct contravention to the Consent Decree, thereby continuing the pattern of racketeering, fraud & extortion and the de-frauding of the Benefit Trust Funds which saw Forde, Greaney, Oliveri & others early morning wake up call, perp walk, arrest, arraignment, trial, convictions & sentencing and that all of this information is continually in the public domain, w/o cessation for 23+ years, there is no privacy claim or any cause of action whatsoever.

    The only thing going on here is the DC's manifest incompetence in addressing an ongoing racketeering activity which crossed state lines via the wire, mail etc. and the Fed's failure to indict the appropriate actors, agents & principals who orchestrated this shakedown scheme.

    The fact that it happened under the UBC International Trusteeship, directly under the nose of the prior IRO, U.S.A.O. & the Court should cause great concern as to why McCarron & crew have yet to be indicted & charged in the extortion scam given their direct control over every aspect of D.C. affairs at that time, which by direct implication include review & approval of all contract langauge by it and its legal counsel. The only question here, relevant to the MWA deal is who is greasing who & for how much

  9. None a more fitting or telling a description as to the failure of Torrance & Walsh, NONE! Especailly this part>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>

    The only thing going on here is the DC's manifest incompetence in addressing an ongoing racketeering activity which crossed state lines via the wire, mail etc. and the Fed's failure to indict the appropriate actors, agents & principals who orchestrated this shakedown scheme.

    The fact that it happened under the UBC International Trusteeship, directly under the nose of the prior IRO, U.S.A.O. & the Court should cause great concern as to why McCarron & crew have yet to be indicted & charged in the extortion scam given their direct control over every aspect of D.C. affairs at that time, which by direct implication include review & approval of all contract langauge by it and its legal counsel. The only question here, relevant to the MWA deal is who is greasing who & for how much


    1. The last paragraph in the relief seccion is wrong. There are payed District Council employees on the trail committee, this creates a GREAT conflict of intrest in this readers eyes

  10. This is an email sent by Greg,cc to the Review Officer.

    John: If the DC spent as much effort preparing for your case as they did preparing for the MWA arbitration we wouldn't be in the position we are in and possibly on the hook for 56 million plus.

    They claim you divulged their strategy? Hiring attorneys to mitigate the damages is a strategy? Any organization not being led by total morons would do the same, that's not a strategy, that is common sense.

    The question is , why wasn't it done sooner? These morons almost let the clock run out before they took action. The strategy would be, how do these attorneys plan to represent the DC to pay the least possible award to the plaintiff? That is a strategy which we know nothing about.

    Now if you had divulged that information (which you did not ) then you may have divulged the DC's strategy, which you did not.

    They can't admit when they are wrong. They just don't get it. They would rather spend valuable resources fighting you than doing the job they are being paid to do. Who is paying for these lawyers? If the DC is, was it approved by the delegate body? Were there 5 RFP's sent out? Was there a 5bi sent to DW's office?

    This is the effort we need from them in negotiating these contracts not fighting our own delegates. You are right, Lebo was attacking you from the dais, right from the beginning of his tenure with his constant interruptions and attempts to discredit you every time you got up to speak.

    God help us all,
    Greg Kelty
    Delegate to District Council


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