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The Ron Carey Campaign 
    400 North Capitol St., N.W. 
    Suite 855 
    Washington, D.C. 20001 
    (202) 624-3500 
    (800) 565-VOTE 
    (202) 624-3525 Facsimile 

    Milwaukee Office 
    Perry, Lerner & Quindel, S.C. 
    823 North Cass St. 
    (414) 272-7400 
    (414) 272-2450 Facsimile 

    Barbara Zack Quindel 
    Election Officer 


    Honorable David N. Edelstein 
    United States District Judge 
    Foley Square, Room 2104 
    40 Centre Street 
    New York, NY 1004-1408 

    RE:  United States vs. IBT 
            88 Civ. 4486 (DNE) 

    Dear Judge Edelstein: 

    I am writing in regard to two matters that have arisen involving my role as Election Officer in certain post-election protests.  The first involved questions regarding a contribuiton made by the IBT in April 1997 to the New Party, a political party of which  my husband and are members.  The second matter involves contacts my husband, my attorney, and I have with the state affiliates of Citizen Action, a national organization which plays a role in the pending campaign contribution protest investigation.  In the interests of keeping the Court fully advised, I am reporting the facts regarding these matters to Your Honor, the Consent Order parties, and the attorneys to the campaigns involved in pending post-election protests. 

    IBT Contribution to the New Party 

    I recently received a copy of an anonymous leaflet (signed "Teamster Rank and File") that alleged that my husband, Roger Quindel, was the "head" of the New Party which had received a $5,000 contribution from the IBT in February 1997, in response to a request for $25,000 from that organization.  The leaflet questions my ability to be impartial in rendering a decision on the pending campaign contribution protests.  A copy of that leaflet is enclosed.  On June 2, 1997, I received a copy of a letter addressed to Mary Jo White, United States Attorney for the Southern District of New York, from Patrick Szymanski, attorney for the Hoffa campaign.  Mr. Szymanski also raised the issue of the IBT contribution to the New Party and requested the U.S. Attorney investigate the matter.  A copy of the letter is also enclosed. 

    The New Party is an independent political party comprised of chapters in nine states and the District of Columbia.  It is headquartered in New York City.  The chapters support candidates for local or state-wide office, frequently working on non-partisan electoral races.  The New Party has advocated the right of candidates to be listed on the state or local electoral ballot as the candidate of more than one political party.  See Timmo ns v. Twin Cities Area New Party, U.S. __, 117 S.Ct.1364 (Apr. 28, 1997).  The New Party and its chapters are funded by membership dues and contributions and by institutional support from a number of labor unions and foundations.  I am informed the New Party has between 10,000 and 11,000 members. 

    My husband, Roger Quindel, and I are members of Progressive Milwaukee, a local political party that has supported candidates for local elections since 1991.  Progressive Milwaukee affiliated with the New Party in 1992.  My husband and I then became members of the national organization.  The New Party is governed by a national steering committee comprised of approximately 20 members.  During 1993 and 1994, Mr. Quindel served as a Wisconsin representative on this national committee.  He has not participated in the national governance since then.  He has never been "head" or "chair" of the New Party. 

    Progressive Milwaukee endorsed Mr. Quindel as a candidate for county supervisor in 1992 and worked to support his election.  Mr. Quindel ran for re-election in 1996 and was unopposed.  Progressive Milwaukee endorsed him but did not raise or contribute any monies toward his 1996 re-election.  Minimal fundraising was done for this campaign because he had no opposition candidate. 

    Mr. Quindel has been a member of the steering committee of Progressive Milwaukee for several years.  My associate, Richard Saks, currently serves on the board of Progressive Milwaukee.  I have not held a leadership position in the organization, although I have attended meetings and participated in campaigns.  My husband I have made contributions to Progressive Milwaukee averaging about $500 per year for the last four years. 

    I first learned in mid-May of the possible contribution to the New Party by the IBT.  I showed the enclosed leaflet to my husband and inquired whether he was aware of any request by the New Party for contribution to it from the IBT.  He advised me that he was not and in no way solicited any such contribution. 

    As part of the investigation into the pending protests, I have acquired a computer listing, printed April 1 and 2, 1997, of contributions and donations greater than $1,000 made by the IBT from the Political Affairs Department, the General Fund and DRIVE (1) in 1996 and early 1997.  These records show hundreds of contributions and gifts to political parties, civic betterment organizations, national, state and local candidates totaling more than four million dollars during the period of 1996 through February, 1997 (2). 

    The submission of Attorney Szymanski indicates that the $5,000 contribution from the IBT was made in April, 1997, apparently at the request of IBT Local Union 705 of Chicago, Illinois.  Neither my husband nor I had any knowledge relating to the request or the contribution prior to mid-May 1997, when I saw reference to it as discussed above.  The New Party has not figured in my investigation of the pending protests in any way.  Any such contribution made by the IBT has not had and will not have any impact whatsoever on my investigation into and resolution of pending post-election protests. 

    Contacts involving the investigation 

    The second matter involved contacts my husband, my attorney, and I have had with state affiliates of Citizen Action, a national organization involved in the pending campaign contribution protests. 

    Citizen Action is a national organization with offices in Washington, D.C.  State affiliates operate in 32 states and claim a membership of more than 2 million people.  The state groups are generally coalitions of labor and community organizations that work on initiatives in areas such as consumer and environmental protection, pesticide reform, health care, transportation, voter registration and campaign finance reform. 

    Mr. Quindel has served as a member of the Board of the Wisconsin Citizen Action organization since 1992.  The Board is comprised of approximately 45 individuals form around the state, generally officers in the the labor unions and community groups which are part of the organization.  Mr. Quindel has no responsibility for oversight of the day-to-day operations of the organization.  He receives no compensation for serving on this Board.  Our financial records show a total contribution to Wisconsin Citizen Action of $400 from 1993 to the present. 

    Mr. Quindel has not held any position with the national Citizen Action and is not involved in any way with the national organization. 

    I have never served on the Board or in any leadership role in Wisconsin Citizen Action.  I am, however, familiar with its work and have worked with Wisconsin Citizen Action as part of a City of Milwaukee, Department of Health Task Force on Lead Poisoning Prevention.  I have also worked on electoral campaigns in the past in which Wisconsin Citizen Action was involved. 

    In the Fall of 1996 the Director of Wisconsin Citizen Action asked to consult with an associate of my law  firm on a legal matter.  My associate gave general advice but declined to represent the organization in the matter. 

    Counsel for the Election Officer, Theodore M. Lieverman, also informs me that New Jersey Citizen Action and Pennsylvania Citizen Action have each been joint plaintiffs with labor unions represented by him in litigation on two matters in those respective states.  After the two Citizen Action affiliates became joint plaintiffs, Mr. Lieverman represented those organizations as well.  The Pennsylvania litigation was between 1984-1987; the New Jersey litigation arose in 1993 and is inactive.  Neither he nor his firm have had any relationship or provided representation to Citizen Action. 

    Citizen Action's Executive Director is Ira Arlook.  I met Mr. Arlook once, when he was visiting mutual friends in Milwaukee in 1995. 

    Finally, in the course of this investigation it came to my attention that someone suggested I had once "dated" Michael Ansara, the husband of a contributor to the Carey campaign and a principal figure in the pending investigation.  I knew of Michael Ansara when I lived in Boston in the 1970's, but he was not a friend or acquaintance.  My husband informs me that he met Michael Ansara once in the 1980's in connection with his work at the time. 

    Based on the circumstances described above, I do not believe that my previous contact with either the New Party or Citizen Action would in any way impair my ability to properly investigate and impartially render a decision in this matter.  See United States v. IBT, 931 F, Supp. 1074, 1101-1106 (S.D.N.Y. 1996), appeal pending.  However, I wanted to make this information available to the Court, the Consent Order parties, and the attorneys to the campaigns involved in pending post-election protests. 

    I would be happy to answer any questions the Court may have. 


    Barbara Zack Quindel 
    Election Officer 

    Cc. Karen Konigsberg, Esq. 
    Earl V. Brown, Esq. 
    Pat Szymanski, Esq. 
    Susan Davis, Esq. 
    Kenneth Conboy, Esq. 

    (1)  DRIVE is the political acronym for the political action committee of the IBT. 

    (2)  The IBT list of donations and contributions includes the National Lawyers' Guild Labor Law Center, the NAACP and the Lawyers Committee for Civil Rights.  I am a member of the National Lawyers Guild.  My law firm represents the local chapter of the NAACP in a pending voting rights case we co-counsel with attorneys from the Lawyers Committee for Civil Rights.