1.  Financial Wrongdoing

 

THE $3 MILLION "EDUCATION" FUND

Recently received information sheds new light on the improper diversion of $3 million in members' dues money to a bogus non-profit organization, which Rosselli and his followers claimed was a healthcare educational fund for members and the public.

 

One of the recently obtained e-mails shows that when John Borsos, one of NUHW's senior leaders, was a top official with SEIU-UHW, he was advised by their attorney, Arthur Fox, that using the ostensible 501(c)(3) "educational" fund referenced above to finance internal union battles was illegal but that if UHW's then-leaders were to "play dumb," they might well be able to evade IRS scrutiny and get away with the illegal conduct:

 

"Another possible scenario would be for you to "play dumb" ... put your money in the (c)(3) where it would be very difficult for SEIU to get its hands on it, and use it as you see fit and hope the IRS never catches up to you. And, even when IRS launches an investigation, it takes many months for it to conclude it. By then, who knows...... As long as no contributions to your Fund were claimed as deductions on tax returns, the IRS should not be terribly upset. You would just say, "Woops, Sorry, We Screwed Up. I guess we should have called ourselves a (c)(4) or (5) in the first instance" (Ellipses in original).[12]

 

The SEIU-UHW former officials appear to have followed this advice, authorizing in February 2008 expenditures from the $3 million that they had transferred to the sham 501(c)(3) entity on matters having nothing to do with healthcare reform "education." Ultimately, they spent about $121,000.[13] The only reason the balance of the $3 million was not spent was because SEIU's investigation had proceeded to the point where the then-leaders of SEIU-UHW had reason to fear personal liability for the money.

 

MORE THAN $11.5 MILLION SPENT TO MAINTAIN PERSONAL POWER

In total in 2008, according to a recently completed financial report, the ousted SEIU-UHW officials spent more than $11.5 million in members' money on their attempts to maintain their personal power,[14] and then tried to hide the spending from members. This money represents more than half of SEIU-UHW's net assets, and 10 percent of its 2008 operating budget, and is money that was not spent to support members, process grievances, negotiate contracts, or provide basic services members needed and expected.[15]

 

Details include:

 

1.     A major piece of the spending was hidden in a $9.33 million budget line item called "Nursing Home Organizing."[16] (For instance, the $670,000 catering bill in No. 2, below, was found in this line item when it was examined more closely.) In fact, SEIU-UHW did not organize a single nursing home worker in 2008. Spending in this account was three times more than was budgeted because this is where the former officers tried to camouflage much of the money they spent. Even if members had looked at the books, they would have no way of knowing that most of the $9.33 million was not spent on organizing nursing home workers because the true purpose of the spending can only be found when individual bills are pulled. These attempts to hide deceptive financial practices were inconsistent with Rosselli's public statements in support of "transparency" in union financial reporting. For example, in a January 17 Los Angeles Times story, Rosselli was quoted as saying, "Transparency on how unions spend their members' dollars, from our point of view, is wanted."[17]

2.     Among the spending in the "Nursing Home Organizing" line item was payment of a $670,000 catering bill to a company called Ovations to feed people at a hearing in San Mateo on whether the local should be put in trusteeship.[18] The bill was paid in advance and was based on feeding 6,000 people at the hearing. However, far fewer people showed up – some estimates are that it was only half or less – so the excess food, paid for by members' dues money, had to be donated to non-members to prevent it from going completely to waste.

3.     The former leaders rented space at the San Mateo County Fairgrounds where they financed a lavish stage set-up with complex lighting and paid musical entertainment.[19]

4.     Also in the "Nursing Home Organizing" line item is $2.5 million for "room/travel/ meetings" to, in large part, pay for the room, travel and stage set-ups at several hearings.[20] The hotel expenses included rooms blocked in advance that were paid for but never used and suites for officers and consultants. The spending in this line item is 12 times more than budgeted,[21] reflecting the former officers' attempt to create a circus atmosphere at the hearings by paying massive amounts for members to attend (such as renting 37 large passenger vans for a week at the San Mateo hearing and using only 10).[22] Later, in January 2009, Rosselli's Research Director, Fred Seavey, who lives in San Francisco, rented a room at the Homewood Suites in Oakland for three weeks, never used it, and charged the room to SEIU-UHW members.  Seavey booked the room solely so he would have an excuse to go on the hotel's premises and harass and attempt to intimidate SEIU staff members who were staying there.

 

5.     Among the other spending:

·      $1.7 million (from September 2008 through January 2009) to Morrison and Foerster, a management-side law firm with a history of union-busting.[23] Known as MOFO, this firm, according to its Web site, has "done extensive counseling work with clients on union avoidance, and have conducted numerous seminars with companies on responding to employee questions about unions and creating an environment to remain union-free" http://www.mofo.com/practice/practice/
employment/laborrelations/overview.html .  Morrison and Foerster has represented Kaiser Permanente management and advertises this on their Web site http://catsearch.mofo.com/search/?sp-q=kaiser&sp-a=sp10038afa&sp-p=all&sp-f=ISO-8859-1&sp-t=catsearch. Some 45,000 SEIU-UHW members work at Kaiser, making it the biggest employer of SEIU-UHW members.

 

The money spent on MOFO included paying the lead attorney $700 an hour, and a legal secretary $175/hour to, among other things, carry t-shirts back to the union office.

·      More than $2.5 million to public relations consultants.[24]

·      $75,000 on a full-page ad in The New York Times.[25]

·      $244,000 for online advertising of an anti-SEIU Web site.[26]

2.   Members put in jeopardy

 

One of the basic tenets of trade unionism is that union officials and staff are duty-bound to fairly represent members' best interests at all times. Rosselli and the other ousted officials, however, violated this bedrock responsibility when they put members' welfare directly in jeopardy in order to pursue their own interests.

 

NUHW WORKS BEHIND SCENES TO CUT HOME CARE WORKER WAGES

In May, when Gov. Arnold Schwarzenegger was locked in a fight with SEIU over his plan to cut the wages of California home care workers, he had some very surprising allies: the leadership of NUHW, run by Sal Rosselli and the other former officials of SEIU-UHW.

 

SEIU members across California were battling Schwarzenegger's plan to cut wages by $2 an hour, from $11.50 to $9.50. At the same time, Paul Kumar, a former SEIU-UHW administrative vice president, now a top leader of NUHW, was strategizing with a public relations consultant on how to get the Los Angeles Times to write a story that would undermine SEIU's efforts to preserve workers' wages by bolstering the governor's pay cut proposal.[27]

 

After the governor initially proposed the pay reductions, the Obama administration announced that the cuts violated the terms of the federal economic stimulus package, and that if California persisted in cutting the wages they would lose their $6.8 billion share of the stimulus money.[28] On May 11, the Los Angeles Times, in a front-page story, quoted Schwarzenegger administration officials saying it was "inappropriate" for SEIU staff to have been on a conference call with the Obama administration and state officials to discuss the cuts and the threatened withholding of stimulus money.[29]

 

The following day, in an e-mail to Jamie Horwitz, of Tricom/PRwork, Inc., a Washington, D.C.-area public relations agency that was paid more than half a million by SEIU-UHW under Rosselli, Kumar asked Horwitz about "the potential for and the wisdom of" generating another Los Angeles Times story "on SEIU's 'inappropriate' involvement in this matter." The goal, Kumar wrote, was to make the Obama administration back off their threat to hold the stimulus money by "making this potato too hot for them to handle."[30] Ultimately, the administration did back off, which left home care worker wages in jeopardy.

 

Why would the former union leaders plot ways to support Schwarzenegger's pay cuts for workers they were hoping to represent? At the time, they were locked in an election fight with SEIU-UHW over 10,000 home care workers in Fresno County. And if home care wages were cut, it gave them an opening to criticize SEIU and perhaps win a few extra votes.[31] They wanted to make SEIU look bad and win the election at all costs, even if home care workers – the people they were seeking to represent – lost $2 an hour in wages.

 

In an ironic footnote, Rosselli wrote an op-ed in the Sacramento Bee July 22, 2009 criticizing the governor for the very same cuts that his associate Kumar sought to support.[32]

 

ROSSELLI AND OTHER OFFICIALS CANCEL CONTRACT EXTENSIONS AND LEAVE CONTRACTS OPEN, PUTTING MEMBERS' WELFARE AT RISK

Just prior to the trusteeship, the former SEIU-UHW officials canceled contract extensions on as many as 25 or more labor agreements at nursing homes, leaving members with no union protection whatsoever.[33] In all, more than 100 contracts were left open. They did this because once contract agreements are reached and ratified, those units cannot be decertified by another union. For as many as 18 months before the trusteeship, they began planning to start up a shadow labor organization should they be removed from office, and that concept then evolved from a shadow organization to a rival union. To help accomplish this, Rosselli and the other former SEIU-UHW officials worked to leave as many contracts open as possible so they could come back later when they formed their new union and seek to represent these same groups. They were willing to play "chicken" with workers' well-being because it suited their personal aims, no matter the jeopardy it created for SEIU-UHW members. And while they were being paid by SEIU-UHW members to represent members' interests, and while utilizing the resources of SEIU-UHW, they were in fact using an ever-growing portion of their time, power, and the union's money preparing to start up a new union, which thus far represents no members.

 

SEIU-UHW members were not told of the contract manipulation, nor did they have a say in the matter. Since the trusteeship, many members have reported being puzzled and angered that contract negotiations had slowed to a crawl or stopped altogether, but were never told why it was happening. As a result, they have been forced to negotiate those agreements in an economy that has continued to worsen and with companies whose financial positions have deteriorated, making it much harder to achieve a contract with the standards they need.

 

The effort to leave contracts open is another example of how, in contradiction of their words about "bottom up democracy" and "democratic unionism," Rosselli and his followers were doing the opposite. They were working behind members' backs, often against members' interests, to achieve their own aims.

 

$3 MILLION RAID ON MEMBERS' STRIKE FUND

In December 2008, Rosselli and his associates raided the members' strike fund, borrowing $3 million to finance their activities and never paying the money back. This left members with a shrunken war chest to take on employers in the worst economy in 70 years. The transfer of these funds was mentioned in minutes of the meeting circulated to UHW board members the following month, but it was never reported to the membership, presumably because union members see the strike fund as sacred, and it would have created questions and major controversy.[34]

 

The money was moved from the strike fund to the general fund at the Rosselli-led SEIU-UHW Executive Board meeting December 12-13, 2008. The authorizing resolution said in part that the money was needed because of "unanticipated expenses for transportation, food, lodging, legal fees and costs and other items"[35] related to the battle he and others were waging inside the union to maintain their personal power. It included the $670,000 spent on catering, the $1.7 million spent on the management law firm of Morrison & Foerster, the more than $2.5 million on public relations agencies, and other expenses. An indication of the recklessness of the spending by the former officials is captured in a memo from John Vellardita, a close aide to Rosselli at SEIU-UHW (and now at NUHW), to an assistant in early January 2009 in which he writes, "We no longer have the luxury of simply making arrangements without taking costs into consideration." [36]

3.  Theft and destruction of SEIU-UHW records needed to defend members

 

In the time leading up to and in the days following the trusteeship, when SEIU representatives were kept from entering SEIU-UHW offices, at minimum hundreds of thousands of files, memos, e-mails, letters, electronic records, and other materials were illegally removed from the various SEIU-UHW offices, erased, taken electronically, shredded, or otherwise destroyed. These included the loss of grievance records that made it impossible to address management contract violations and defend members' rights on the job in a timely way.[37]

 

To cover these activities and to set themselves up in the new union they planned to form, Rosselli and his followers were willing to steal grievance files, bargaining notes, bargaining timelines and schedules, member lists, contract costing information, and other documents vital to representing the interests of members on the job and in contract negotiations.[38] In some instances after the trusteeship, union members and staff had to rely on notes taken by management to determine the status of contract bargaining. These actions directly impeded bargaining and undermined the welfare of members on the job. It was another part of the strategy to make the local "ungovernable" and make the trustees look bad in the eyes of members so it would be easier for Rosselli's start-up union to decertify SEIU-UHW members.

 

As Judge Alsup wrote in granting a preliminary injunction July 27, requiring the documents to be preserved, "Upon leaving UHW, the individual defendants [Rosselli and his followers] took and reproduced UHW property for use at NUHW and destroyed other UHW property in an effort to hamstring their soon-to-be competitor" (parenthesis added).[39]

 

Evidence of the deliberate destruction of records is found in another recently obtained e-mail from one of Rosselli's chief attorneys both before and after the trusteeship. In the e-mail, Arthur Fox advises both Borsos and Rosselli on how they could misappropriate SEIU-UHW documents and hide the wrongdoing to create plausible deniability were they required to testify under oath – advice the former SEIU-UHW leaders took.

 

Fox wrote in an e-mail to Rosselli and Borsos:

"In fact, you may want to download a significant volume of materials in your data base from your computer servers, including a membership list, etc., into a "foreign" computer or server where you will be able to collect the info at some future point in time. Ideally, this new electronic depository would be one over which you do not have immediate or absolute control. Or, preferably, knowledge. Sooner or later SEIU will probably put you and your close associates under oath and ask questions whose answers you can honestly say you do not possess. CAVEAT. Use your best judgment on this. Stern might at some future time accuse you of violating some SEIU privacy/confidentiality duty ... or even theft of union property, by virtue of your "stealing" info from UHW."[40]

The destruction and theft of records was carried out deliberately. Judge Alsup, in issuing his preliminary injunction on July 27, 2009, found that both Rosselli and Borsos failed to testify truthfully when being examined under oath in an April 2009 court hearing about the destruction of documents.

Judge Alsup wrote:

Defendant Rosselli deleted more than 12,000 files from his computer. Directly contradicting testimony he gave at the TRO hearing, an unrebutted analysis by plaintiffs' vendor indicates that Rosselli "double deleted" a significant portion of these files, i.e., he not only deleted the files from where they were stored on his computer but also took the extra step of deleting the files from the "deleted items" folder on his computer. According to the analysis, this was not his ordinary practice before January 2009 (underline added).[41]

 

He further wrote concerning Borsos:

After the trusteeship, UHW obtained Borsos' email files from Intermedia and thus discovered that all emails sent to Borsos were missing for 2008 and 2009. Again, the evidence tends to contradict Borsos' testimony at the TRO hearing. When asked if his emails were hosted by Intermedia, which did not back up his email, rather than UHW's servers, he stated that he "ha[d] no idea" and did not know who Intermedia was. The evidence suggests otherwise (underline added).[42]

 

One indication of the lengths to which Rosselli and the former officials went to hide their activities was the fact that they established a private e-mail system, bypassing their normal SEIU-UHW e-mail, to conduct communications they did not want to reside on the official SEIU-UHW system. Many of these e-mails are still being sought.[43]

 

In issuing a temporary restraining order April 8, 2009, that seeks the return of records that were taken, U.S. District Court Judge William Alsup confirmed what he called a "shadow" e-mail system and also the wholesale theft and destruction of documents that were important to members' representation and welfare.

 

In issuing the temporary restraining order, Judge Alsup wrote:

"When the trusteeship was approved and imposed on January 27, the trustees relieved the individual defendants of management responsibility. In response, the individual defendants went a step further and resigned completely from the union. Immediately, they formed the National Union of Healthcare Workers, a new and competing labor association. In several instances, they departed the offices, knowing that the offices were occupied by the stewards and some rank-and-file who had barricaded themselves inside to resist a trusteeship. Credible evidence has been provided that those remaining inside removed or destroyed records and information.

 

While all individual defendants may not have expressly ordered the havoc or participated personally in it, it seems plain that the individual defendants anticipated the likely course of events once a trusteeship came down afterward, [and] they simply walked away, letting the havoc unfold and, indeed, expecting it to happen. Beyond this, as the trusteeship lurked on the horizon, almost all of the individual defendants established a shadow e-mail system using personal PDAs. Through this system, they discussed how UHW should and would resist the international. And, as the eventful day approached, at least one individual defendant e-mailed UHW documents to his personal account for further use.

 

In short, even at this early stage, considerable and convincing evidence shows that,

when the SEIU threatened to impose a trusteeship under the union constitution, the then-leaders of UHW — now the individual defendants — embarked on a vigorous resistance strategy, including a plan to disrupt union operations so as to make the situation ungovernable. When SEIU finally imposed a trusteeship, defendants walked away immediately and, one day later, formed a rival union, namely the NUHA (sic). Forming a new union after the fact, of course, was lawful. What was not lawful, however, was filching or sabotaging of UHW property and information or aiding and abetting others in doing so (emphasis added).[44]

4.  Anti-democratic activities

 

THE FAÇADE OF DEMOCRACY

One of the cornerstones of Rosselli's campaign against SEIU is that he and the other officials are the champions of "democratic unionism" and a "member-driven" approach to running the union.[45] This claim has raised a lot of eyebrows in California among people who for years had watched Rosselli and a relatively small circle of (mostly male) senior staff (John Borsos, Paul Kumar, Dan Martin, John Vellardita, Glen Goldstein, and a few others) dominate the local union and run it with an iron fist. Virtually nothing happened in the union that was not directed from the top. Members describe themselves as being soldiers who were given orders (attend this picket, sign this postcard, lobby this legislator, wear this button, circulate this petition), and the Executive Board, rather than being a real decision-making body, was tightly controlled and rubber-stamped decisions hashed out in advance of the meetings by Rosselli's tight circle of senior staff.

 

To further the "bottom-up" illusion, Rosselli and other former SEIU-UHW officials created a massive public relations campaign, paid for by millions in members' dues money, to "frame" their actions as demonstrating their commitment to democratic unionism. And they were fully aware of the appearance they were trying to project. For example, in one e-mail, Paul Kumar worried about the fact that there were very few women or people of color in the local union's top positions, and expressed concern about how it would look to the outside world: "We also need to (sic) a plan to deal with the lack of both real and publicly marketable women and people of color among the top rungs of our leadership group."[46]

USING MEMBERS

In one of the more cynical episodes, Arthur Fox, an attorney for SEIU-UHW under Rosselli, advised Rosselli and Borsos how to use members to cover up their activities by engaging in covert, rather than "overt[]," activities; and by "laundering" transactions through front groups that would appear to be funded by rank-and-file members. Rosselli and Borsos took the advice.

 

Fox wrote in a January 31, 2008 memo to Rosselli and Borsos:

"As a consequence, it would be wise for UHW and its officers to proceed cautiously so as not to appear, overtly, to be attempting to subvert the SEIU IEB's jurisdictional mandates. Rather, to the extent the UHW may wish to resist implementation of any particular mandate it should probably "lay low" and simply provide information and advice, and perhaps well-concealed assistance, to members who are, themselves, anxious to resist those directives for their own reasons. Ideally, such assistance should be "laundered" through an intermediary."[47]

 

Under Rosselli, the modus operandi was for the top leaders to make all major (and even many minor) decisions and then order staff to find a relatively small number of members in the workplace to support and carry out those decisions. The idea was (and for NUHW continues to be) to "get" members to carry the message, pushing them forward; putting words in their mouths; writing statements, petitions, and letters for them to sign; and even creating "spontaneous" actions and demonstrations. The leaders would then act as if those ideas were initiated by rank-and-file members.

 

An example of this occurred in January 2009, when Rosselli and his senior advisers decided they wanted a member petition sent to SEIU President Andy Stern calling for a disaffiliation vote among SEIU-UHW members. Rosselli and the other former officers could not ask for such an election because of internal union rules, so they put their "bottom-up" machinery into action. Here's how it worked:[48]

 

1.     The top leaders drafted template language to be used in a petition to SEIU President Andy Stern designed to appear to be from members and calling for the disaffiliation vote.

2.     At a meeting on January 8, 2009, senior staff – with a wink and a nod – were told that officers of SEIU-UHW could not move disaffiliation petitions because it was improper for them to do so, but that if they happened to receive such petitions from members they would be obligated to report it to the SEIU International union.

3.     The lead staff were given the petition and instructed to get at least two signatures from members in each bargaining unit in time for the local union executive board meeting the following day.

4.     Senior staff ordered their subordinate staff to go out and get the signatures. They managed to get roughly 100-200 signatures (of 150,000 members).

5.     At an executive session on January 9, 2009, Rosselli and the senior staff told the SEIU-UHW executive board that rank-and-file members were submitting a petition for disaffiliation. The board was not shown the petition, told how many petitions there were, told that the template petition had been drafted by officers and senior staff, or informed that the petitions had been circulated by SEIU-UHW staff on instructions from the officers.

6.     Board members were told that it would be improper for them to support a disaffiliation, but it was their duty to inform SEIU International of member-initiated petitions calling for a disaffiliation vote and for SEIU to schedule an election. The board then approved a letter to the SEIU president along those lines.

7.      Finally, the process came full circle when SEIU-UHW issued a press release that began:

UHW Members Call on SEIU to Schedule Disaffiliation Vote

"Widespread and Profound Opposition" Cited

 

OAKLAND, CALIF.—In response to letters, petitions and other requests from members employed at healthcare facilities and worksites across California, the Executive Board of SEIU United Healthcare Workers-West (UHW), consistent with provisions contained in the Service Employees International Union International Constitution, has sent a letter to SEIU President Andy Stern requesting that he schedule a vote of the local union's 150,000 members to formally disaffiliate from the Washington, D.C.-based SEIU.

 

The petitions submitted to the Executive Board cite various concerns that have led members to request the disaffiliation vote (underline added).[49]

 

Even members who believed fervently in Rosselli's cause were often manipulated and lied to in order to do the bidding of the former officials. They were not aware that while these activities were ongoing, those same former officials were plotting the start-up of a new union that would leave members vulnerable, as described in earlier sections.

 

TOP-DOWN CONTROL

Rosselli and the other former leaders had virtually no opposition inside the union. For example, on January 14, 2009, prior to the trusteeship, Rosselli and the 17 statewide officers in SEIU-UHW were elected without opposition.[50] Another clear indication of their iron-clad control is found in Borsos's testimony on Nov. 12, 2008 at the pre-trusteeship hearing conducted by Secretary Marshall. In the course of being questioned about the bogus $3 million charitable "education" fund, Borsos expressed surprise over the possibility that someone on the SEIU-UHW executive board may have voted against it or even abstained:

 

Question: And I believe you testified that the UHW Executive Board voted, unanimously, to support the Education Fund; is that correct?

Borsos: Yes.

Question: And what is your basis for saying that?

Borsos: Because if somebody – in that case if somebody ends up voting against it, it's a pretty unusual thing; and I just don't remember anybody voting against it.

 

Another example of Rosselli and the other leaders' controlling approach to running the union was provided by a former board member, Sherri Macias, who in a declaration on February 4, 2009, said:

 

"Finally, with regard to my former position on the executive board of the local union, there were a few instances on which I was participating in a vote at a meeting and Sal Roselli (sic), former President of UHW, would say, "is everyone with me??" Two times, I could not in good conscience vote along with everyone else and was, on those occasions, the only dissenting vote at those meetings. Following one of the meetings, Pamela Martinez, who was an assistant to Mr. Roselli (sic), looked at me and said, "You go with the leadership." I told her that I was voting and that I should have the right to vote my mind. She just repeated herself, saying that I should follow the leadership."[51]

5.  Intimidation

 

After the trusteeship, Rosselli's staff and supporters unleashed a concerted and widespread campaign of intimidation against employees who chose to work for SEIU-UHW after the trusteeship, carried out through threats of physical violence against them, vandalizing of their automobiles, and placing harassing and threatening anonymous phone calls.

 

A deposition was given to attorneys for Rosselli and the other former officers by Jerry Bullock of Bullock & Associates of Washington, D.C., who was hired by the trustees to protect people and property in connection with the trusteeship. Bullock spent nearly 20 years in security and investigative roles with the U.S. Marshals Service and the Department of Justice, and has been in private practice since 1994. He described the campaign of intimidation:

 

"The second night I was there...a number of staff people had been physically confronted in a hotel where they were staying. They were so frightened they called me, because by that time we were trying to set up a way for them to call in with information because the people were just threatened...I think about four individuals had confronted them really in a menacing way. We had a security person at the hotel who observed what was going on and responded. The hotel security person responded...But just based on what the staff people told me, I knew that a police report needed to be done, that it was something that serious."[52]

 

He testified:

 

"And by the time the trusteeship came around, there were actually a number of incidents where people were chased off the road in their cars as they left Alameda (the SEIU-UHW Alameda office). Someone was clearly observing, especially late at night, when people were leaving the office. They were confronted. When you confront somebody with an automobile, that's a fairly serious thing."[53]

 

He continued:

 

"But as I talked with staff, they were clearly shaken. People had been confronted in their communities with fliers. One individual told me that I guess moments after he agreed...to assist that he got a threatening phone call from somebody who said they were with UHW telling him not to come (to UHW), there was going to be trouble if he came."[54]

 

He later testified:

 

"When they would bring new people in, I would have about a five-minute do's and don'ts on the security; don't go anywhere by yourself, watch where you're going, don't leave alone, be observant of things around you. And it was pretty relentless."[55]

 

And finally:

 

"...the other thing that had happened in both the Homewood Suites in Oakland and at several of the hotels in Los Angeles were basically threatening flyers were passed out in Los Angeles. They had staff people's photograph's on them and they were put under their room doors. So clearly somebody knew where they were staying, to the point that they got an individual flyer with their picture on it under their room door or taped to their room door in the case of Homewood Suites."[56]

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