Carol N. Lambos

James R. Campbell

THE LAMBOS FIRM, LLP

599 Avenue C

Bayonne, NJ 07002

Tel: (201) 823-1000

Attorneys for Plaintiffs

Donato Caruso

William M. Spelman

THE LAMBOS FIRM, LLP

303 South Broadway, Suite 410

Tarrytown, New York 10591

Tel. (212) 943-2470

Attorneys for Plaintiffs

UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

-------------------------------------------------------------------------------------------- x

NEW YORK SHIPPING ASSOCIATION, INC.; AMERICAN

PRESIDENT

:

LINES, LTD.; A.P. MOELLER - MAERSK A/S; ATLANTIC :

CONTAINER LINE A.B.; CARGOTEC USA INC.; CERES ATLANTIC :

TERMINALS INC.; CMA CGM S.A.; COSCO CONTAINER LINES :

CO. LTD.; EVERGREEN LINE JOINT SERVICE AGREEMENT; :

GLOBAL TERMINAL & CONTAINER SERVICES, LLC; HAMBURG : Document Filed 

SÜDAMERI KANISCHE DAMPFSCHIFFFAHRTS GESELLSCHAFT : Electronically

KG; HANJIN SHIPPING CO., LTD.; HAPAG-LLOYD AG; HORIZON :

LINES, LLC; KAWASAKI KISEN KAISHA, LTD.; MAHER : COMPLAINT

TERMINALS LLC; MEDITERRANEAN SHIPPING COMPANY S.A.; :

MITSUI O.S.K. LINES, LTD.; NEW YORK CONTAINER TERMINAL, :

INC.; NYK LINE (NORTH AMERICA) INC. as agent for NIPPON

YUSEN

:

KABUSHIKI KAISHA; ORIENT OVERSEAS CONTAINER LINE :

LIMITED; PORTS AMERICA, INC.; TURKON LINE; UNITED ARAB : Civil Action No.:

SHIPPING COMPANY (S.A.G.); UNIVERSAL MARITIME SERVICE :

CORP.; YANG MING MARINE TRANSPORT CORP.; and :

ZIM INTEGRATED SHIPPING SERVICES CO., LTD.; :

Plaintiffs, :

:

- v. - :

:

INTERNATIONAL LONGSHOREMEN’S ASSOCIATION, AFL-CIO; :

LOCAL 1, INTERNATIONAL LONGSHOREMEN’S ASSOCIATION, :

AFL-CIO; LOCAL 920, INTERNATIONAL LONGSHOREMEN’S :

ASSOCIATION, AFL-CIO; LOCAL 1233, INTERNATIONAL :

LONGSHOREMEN’S ASSOCIATION, AFL-CIO; LOCAL 1235, :

INTERNATIONAL LONGSHOREMEN’S ASSOCIATION, AFL-CIO; :

LOCAL 1242, INTERNATIONAL LONGSHOREMEN’S ASSOCIATION, :

AFL-CIO; LOCAL 1291, INTERNATIONAL LONGSHOREMEN’S :

ASSOCIATION, AFL-CIO; LOCAL 1566, INTERNATIONAL :

LONGSHOREMEN’S ASSOCIATION, AFL-CIO; LOCAL 1588, :

INTERNATIONAL LONGSHOREMEN’S ASSOCIATION, AFL-CIO; :

LOCAL 1804-1, INTERNATIONAL LONGSHOREMEN’S :

ASSOCIATION, AFL-CIO; and LOCAL 1814, INTERNATIONAL :

LONGSHOREMEN’S ASSOCIATION, AFL-CIO; :

Defendants. :

-------------------------------------------------------------------------------------------- x

A0008057

Case 2:10-cv-06261-DRD -MAS Document 1 Filed 12/03/10 Page 1 of 28 PageID: 1
Plaintiffs, by and through their undersigned attorneys, The Lambos Firm, LLP, as and for

their complaint, respectfully allege as follows:

JURISDICTION AND VENUE

1. This is an action pursuant to section 303 of the Labor Management Relations Act

(LMRA), 29 U.S.C.A. § 187 (West 1998), seeking damages for injuries suffered as the result of an

unfair labor practice in violation of 29 U.S.C.A. § 158(b)(4) (West 1998). 

2. This court has subject-matter jurisdiction to entertain this proceeding pursuant to

LMRA § 303(b), 29 U.S.C.A. § 187(b) (West 1998), and 28 U.S.C.A. §§ 1331, 1337 (West 2006).

3. Venue in the District of New Jersey is proper under 28 U.S.C.A. § 1391 (West 2006)

and 29 U.S.C.A §§ 185, 187 (West 1998) because (a) defendants are found, do, or transact business

in the District of New Jersey, (b) the respective duly authorized officers and agents of defendants

are engaged in representing and acting for their members in the District of New Jersey; and (c) a

substantial part of the events or omissions giving rise to the claims occurred in the District of New

Jersey. 

NON-PARTY

4. United States Maritime Alliance, Ltd. (USMX) is a non-profit membership

corporation organized and existing under and by virtue of the laws of the State of Delaware with its

principal office located at 485C U.S. Highway 1 South, Iselin, New Jersey 08830. USMX is a

multiemployer collective-bargaining representative for its members, which consist of shipping

companies or lines (also known as carriers), marine terminal operators and stevedoring companies,

and port associations that represent employers of longshore labor engaged in container and roll

on/roll off (ro/ro) operations in ports on the East and Gulf Coasts of the United States, including the

A0008057 -2-

Case 2:10-cv-06261-DRD -MAS Document 1 Filed 12/03/10 Page 2 of 28 PageID: 2
Port of New York and New Jersey (NY-NJ Port). USMX on behalf of its members negotiates and

administers with Defendant International Longshoremen’s Association, AFL-CIO (ILA) on behalf

of its constituent locals, including each of the locals that is a defendant in this action, a collective

bargaining agreement, known as the Master Contract, which prescribes the key terms and conditions

of employment for longshore workers employed in container and ro/ro operations in ports on the

East and Gulf Coasts of the United States, including the NY-NJ Port. 

PARTIES

5. Plaintiff New York Shipping Association, Inc. (NYSA) is a not-for-profit

membership corporation organized and existing under and by virtue of the laws of the State of New

York with its principal office located at 333 Thornall Street, Suite 3A, Edison, New Jersey 08837. 

NYSA is authorized to carry on its corporate activities in the State of New Jersey. NYSA is a

multiemployer collective-bargaining representative for its members, which consist of carriers,

marine terminal operators, stevedoring companies, and other employers of longshore labor engaged

in maritime operations in the NY-NJ Port. NYSA on behalf of its members negotiates, enters into,

and administers with the ILA on behalf of its constituent locals in the NY-NJ Port a collective

bargaining agreement that prescribes the terms and conditions of employment for longshore workers

in the NY-NJ Port (hereinafter referred to as “NYSA-ILA CBA”). NYSA is a port-association

member of USMX, and NYSA and its members are bound to the Master Contract.

Carrier Plaintiffs

6. Plaintiff American President Lines, Ltd. (APL) is a company organized and existing

under and by virtue of the laws of the State of Delaware with its principal place of business at 16220

N. Scottsdale Road, Suite 300, Scottsdale, Arizona 85254. APL is engaged in the business of

A0008057 -3-

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transporting cargo by sea in international trade and commerce. Its ships call at ports in the United

States, including the NY-NJ Port. APL is a member of both NYSA and USMX and is bound by the

collective bargaining agreements negotiated by NYSA and USMX with the ILA. 

7. Plaintiff A.P. Moeller - Maersk A/S (Maersk) is a company organized and existing

under and by virtue of the laws of Denmark. Maersk is represented in the United States by Maersk

Agency USA, Inc., which is a corporation organized and existing under and by virtue of the laws

of the State of Delaware and has its principal place of business at 2 Giralda Farms, Madison, New

Jersey 07940. Maersk is engaged in the business of transporting cargo by sea in international trade

and commerce. Its ships call at ports in the United States, including the NY-NJ Port. Maersk is a

member of both NYSA and USMX and is bound by the collective bargaining agreements negotiated

by NYSA and USMX with the ILA.

8. Plaintiff Atlantic Container Line A.B. (ACL) is a company organized and existing

under and by virtue of the laws of Italy with a principal place of business in the United States at 50

Cardinal Drive, Westfield, New Jersey 07090. ACL is engaged in the business of transporting cargo

by sea in international trade and commerce. Its ships call at ports in the United States, including the

NY-NJ Port. ACL is a member of both NYSA and USMX and is bound by the collective bargaining

agreements negotiated by NYSA and USMX with the ILA.

9. Plaintiff CMA CGM S.A. (CMA CGM) is a company organized and existing under

and by virtue of the laws of France. CMA CGM is represented in the United States by CMA CGM

(America) LLC, which is a corporation organized and existing under and by virtue of the laws of

the State of New Jersey and has its principal place of business at 5701 Lake Wright Drive, Norfolk,

Virginia 23502. CMA CGM is engaged in the business of transporting cargo by sea in international

A0008057 -4-

Case 2:10-cv-06261-DRD -MAS Document 1 Filed 12/03/10 Page 4 of 28 PageID: 4
trade and commerce. Its ships call at ports in the United States, including the NY-NJ Port. CMA

CGM is a member of both NYSA and USMX and is bound by the collective bargaining agreements

negotiated by NYSA and USMX with the ILA.

10. Plaintiff Cosco Container Lines Co. Ltd. (Cosco) is a company organized and

existing under and by virtue of the laws of China. Cosco is represented in the United States by

Cosco Container Lines Americas, Inc., which is a corporation organized and existing under and by

virtue of the laws of the State of Delaware and has its principal place of business at 100 Lighting

Way, Secaucus, New Jersey 07094. Cosco is engaged in the business of transporting cargo by sea

in international trade and commerce. Its ships call at ports in the United States, including the NY-NJ

Port. Cosco is a member of both NYSA and USMX and is bound by the collective bargaining

agreements negotiated by NYSA and USMX with the ILA.

11. Plaintiff Evergreen Line Joint Service Agreement (Evergreen) is a joint venture of

Evergreen Marine Corp. (Taiwan) Ltd., Evergreen Marine (UK) Limited, Italia Marittima SpA,

Evergreen Marine (Hong Kong) Ltd., and Evergreen Marine (Singapore) Pte. Ltd., carriers engaged

in the business of transporting cargo by sea in international trade and commerce. Evergreen is

represented in the United States by Evergreen Shipping Agency (America) Corp., which is a

corporation organized and existing under and by virtue of the laws of the State of New Jersey and

has its principal place of business at 1 Evertrust Plaza, Jersey City, New Jersey 07302. Evergreen’s

ships call at ports in the United States, including the NY-NJ Port. Evergreen is a member of both

NYSA and USMX and is bound by the collective bargaining agreements negotiated by NYSA and

USMX with the ILA. 

A0008057 -5-

Case 2:10-cv-06261-DRD -MAS Document 1 Filed 12/03/10 Page 5 of 28 PageID: 5
12. Plaintiff Hamburg Südamerikanische Dampfschifffahrtsgesellschaft KG (Hamburg

Süd) is a company organized and existing under and by virtue of the laws of Germany. Hamburg 

Süd is represented in the United States by Hamburg Süd North America, Inc.,which is a corporation

organized and existing under and by virtue of the laws of the State of Delaware and has its principal

place of business at 465 South Street, Morristown, New Jersey 07960. Hamburg Süd is engaged in

the business of transporting cargo by sea in international trade and commerce. Its ships call at ports

in the United States, including the NY-NJ Port. Hamburg Süd is a member of both NYSA and

USMX and is bound by the collective bargaining agreements negotiated by NYSA and USMX with

the ILA. 

13. Plaintiff Hanjin Shipping Co., Ltd. (Hanjin) is a company organized and existing

under and by virtue of the laws of the Republic of Korea. Hanjin has an office in the United States

at 80 East Route 4, Suite 490, Paramus, New Jersey 07652. Hanjin is engaged in the business of

transporting cargo by sea in international trade and commerce. Its ships call at ports in the United

States, including the NY-NJ Port. Hanjin is a member of both NYSA and USMX and is bound by

the collective bargaining agreements negotiated by NYSA and USMX with the ILA.

14. Plaintiff Hapag-Lloyd AG (Hapag-LLoyd) is a company organized and existing under

and by virtue of the laws of Germany. Hapag-LLoyd is represented in the United States by HapagLloyd (America) Inc., which is a corporation organized and existing under and by virtue of the laws

of the State of Delaware and has its principal place of business at 399 Hoes Lane, Piscataway, New

Jersey 08854. Hapag-Lloyd is engaged in the business of transporting cargo by sea in international

trade and commerce. Its ships call at ports in the United States, including the NY-NJ Port. HapagA0008057 -6-

Case 2:10-cv-06261-DRD -MAS Document 1 Filed 12/03/10 Page 6 of 28 PageID: 6
Lloyd is a member of both NYSA and USMX and is bound by the collective bargaining agreements

negotiated by NYSA and USMX with the ILA. 

15. Plaintiff Horizon Lines, LLC (Horizon) is a limited liability company organized and

existing under and by virtue of the laws of the State of Delaware with its principal place of business

at 4064 Colony Road, Suite 200, Charlotte, North Carolina 20211. Horizon is engaged in the

business of transporting cargo by sea in interstate and foreign commerce. Its ships call at ports in

the United States, including the NY-NJ Port. Horizon is a member of both NYSA and USMX and

is bound by the collective bargaining agreements negotiated by NYSA and USMX with the ILA.

16. Plaintiff Kawasaki Kisen Kaisha, Ltd. (“K” Line) is a company organized and

existing under and by virtue of the laws of Japan. “K” Line is represented in the United States by

“K” Line America, Inc., which is a corporation organized and existing under and by virtue of the

laws of the State of Michigan and which has its principal place of business at 890 Mountain Avenue,

Murray Hill, New Jersey 07974. “K” Line is engaged in the business of transporting cargo by sea

in international trade and commerce. Its ships call at ports in the United States, including the NY-NJ

Port. “K” Line is a member of both NYSA and USMX and is bound by the collective bargaining

agreements negotiated by NYSA and USMX with the ILA.

17. Plaintiff Mediterranean Shipping Company S.A. (MSC) is a company organized and

existing under and by virtue of the laws of Switzerland. MSC is represented in the United States

by MSC USA Inc., which is a corporation organized and existing under and by virtue of the laws

of the State of New York and has its principal place of business at 420 Fifth Avenue, 8th Floor, New

York, New York 10018. MSC is engaged in the business of transporting cargo by sea in

international trade and commerce. Its ships call at ports in the United States, including the NY-NJ

A0008057 -7-

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Port. MSC is a member of both NYSA and USMX and is bound by the collective bargaining

agreements negotiated by NYSA and USMX with the ILA.

18. Plaintiff Mitsui O.S.K. Lines, Ltd. (MOL) is a company organized and existing under

and by virtue of the laws of Japan. MOL is represented in the United States by MOL (America)

Inc., which is a corporation organized and existing under and by virtue of the laws of the State of

Delaware and has its principal place of business at 700 E. Butterfield Rd, Suite 250, Lombard,

Illinois 60148. MOL is engaged in the business of transporting cargo by sea in international trade

and commerce. Its ships call at ports in the United States, including the NY-NJ Port. MOL is a

member of both NYSA and USMX and is bound by the collective bargaining agreements negotiated

by NYSA and USMX with the ILA.

19. Plaintiff Nippon Yusen Kabushiki Kaisha (NYK Line) is a company organized and

existing under and by virtue of the laws of Japan. NYK Line is represented in the United States by

NYK Line (North America) Inc., which is a corporation organized and existing under and by virtue

of the laws of the State of Delaware and which has its principal place of business at 300 Lighting

Way, 5th Floor, Secaucus, New Jersey 07094. NYK Line is engaged in the business of transporting

cargo by sea in international trade and commerce. Its ships call at ports in the United States,

including the NY-NJ Port. NYK Line is a member of both NYSA and USMX and is bound by the

collective bargaining agreements negotiated by NYSA and USMX with the ILA. 

20. Plaintiff Orient Overseas Container Line Limited (OOCL) is a company organized

and existing under and by virtue of the laws of Hong Kong. OOCL is represented in the United

States by OOCL (USA) Inc., which is a corporation organized and existing under and by virtue of

the laws of the State of New York and has its principal place of business at 2633 Camino Ramon,

A0008057 -8-

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San Ramon, California 94563. OOCL is engaged in the business of transporting cargo by sea in

international trade and commerce. Its ships call at ports in the United States, including the NY-NJ

Port. OOCL is a member of both NYSA and USMX and is bound by the collective bargaining

agreements negotiated by NYSA and USMX with the ILA.

21. Plaintiff Turkon Line (Turkon) is a company organized and existing under and by

virtue of the laws of Turkey. Turkon is represented in the United States by Turkon America Inc.,

which is a corporation organized and existing under and by virtue of the laws of the State of New

Jersey and has its principal place of business at 100 Plaza Drive, Secaucus, New Jersey 07094. 

Turkon is engaged in the business of transporting cargo by sea in international trade and commerce. 

Its ships call at ports in the United States, including the NY-NJ Port. Turkon is a member of both

NYSA and USMX and is bound by the collective bargaining agreements negotiated by NYSA and

USMX with the ILA.

22. Plaintiff United Arab Shipping Company (S.A.G.) (UASC) is a company organized

and existing under and by virtue of the laws of Kuwait. UASC has an office in the United States at

511 South Avenue, Cranford, New Jersey 07016. UASC is engaged in the business of transporting

cargo by sea in international trade and commerce. Its ships call at ports in the United States,

including the NY-NJ Port. UASC is a member of both NYSA and USMX and is bound by the

collective bargaining agreements negotiated by NYSA and USMX with the ILA. 

23. Plaintiff Yang Ming Marine Transport Corp. (Yang Ming) is a company organized

and existing under and by virtue of the laws of Taiwan. Yang Ming is represented in the United

States by Yang Ming (America) Corp., which is a corporation organized and existing under and by

virtue of the laws of the State of New York and has its principal place of business at 525 Washington

A0008057 -9-

Case 2:10-cv-06261-DRD -MAS Document 1 Filed 12/03/10 Page 9 of 28 PageID: 9
Blvd., 25th Floor, Jersey City, New Jersey 07310. Yang Ming is engaged in the business of

transporting cargo by sea in international trade and commerce. Its ships call at ports in the United

States, including the NY-NJ Port. Yang Ming is a member of both NYSA and USMX and is bound

by the collective bargaining agreements negotiated by NYSA and USMX with the ILA. 

24. Plaintiff ZIM Integrated Shipping Services Co., Ltd. (ZIM) is a company organized

and existing under and by virtue of the laws of Israel. ZIM is represented in the United States by

ZIM American Integrated Shipping Services Co., Inc., which is a corporation organized and existing

under and by virtue of the laws of the State of New York and has its principal place of business at

5801 Lake Wright Drive, Norfolk, Virginia 23502. ZIM is engaged in the business of transporting

cargo by sea in international trade and commerce. Its ships call at ports in the United States,

including the NY-NJ Port. ZIM is a member of both NYSA and USMX and is bound by the

collective bargaining agreements negotiated by NYSA and USMX with the ILA.

25. The plaintiffs identified in paragraphs 6 through 24 are collectively referred to in this

complaint as the “Carrier Plaintiffs.”

MTO/Stevedore Plaintiffs

26. Plaintiff Ceres Atlantic Terminals Inc. (Ceres), a business corporation organized and

existing under and by virtue of the laws of the State of Delaware, is a stevedore in the NY-NJ Port. 

Its principal place of business is at 51 Port Terminal Blvd., Bayonne, New Jersey 07002. Ceres is

engaged in the business of stevedoring cruise ships in the NY-NJ Port. Ceres is a member of both

NYSA and USMX and is bound by the collective bargaining agreements negotiated by NYSA and

USMX with the ILA. 

A0008057 -10-

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27. Plaintiff Global Terminal & Container Services, LLC (Global), a limited liability

company organized and existing under and by virtue of the laws of the State of Delaware, is a

marine terminal operator (MTO) in the NY-NJ Port. Its principal place of business is at 302 Port

Jersey Boulevard, Jersey City, New Jersey 07305. Global is engaged in the business of operating

a marine terminal and stevedoring cargo ships in the NY-NJ Port. Global is a member of both

NYSA and USMX and is bound by the collective bargaining agreements negotiated by NYSA and

USMX with the ILA. 

28. Plaintiff Maher Terminals LLC (Maher), a limited liability company organized and

existing under and by virtue of the laws of the State of Delaware, is an MTO in the NY-NJ Port. Its

principal place of business is at 1210 Corbin Street, Elizabeth, New Jersey 07201. Maher is engaged

in the business of operating a marine terminal and stevedoring cargo ships in the NY-NJ Port. Maher

is a member of both NYSA and USMX and is bound by the collective bargaining agreements

negotiated by NYSA and USMX with the ILA. 

29. Plaintiff New York Container Terminal, Inc. (NYCT), a business corporation

organized and existing under and by virtue of the laws of the State of New York, is an MTO in the

NY-NJ Port. Its principal place of business is at 300 Western Avenue, Staten Island, New York

10303. NYCT is engaged in the business of operating a marine terminal and stevedoring cargo ships

in the NY-NJ Port. NYCT is a member of both NYSA and USMX and is bound by the collective

bargaining agreements negotiated by NYSA and USMX with the ILA. 

30. Plaintiff Ports America, Inc. (Ports America), a business corporation organized and

existing under and by virtue of the laws of the State of Delaware, is an MTO in the NY-NJ Port. Its

principal office is at 99 Wood Avenue South, Iselin, New Jersey 08830. Ports America is engaged

A0008057 -11-

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in the business of operating a marine terminal and stevedoring cargo ships in the NY-NJ Port. Ports

America is a member of both NYSA and USMX and is bound by the collective bargaining

agreements negotiated by NYSA and USMX with the ILA. Ports America has three facilities in the

NY-NJ Port: Port Newark Container Terminal, Port Newark Auto Terminal, and Bayonne Auto

Terminal.

31. Plaintiff Universal Maritime Service Corp. (Universal), a business corporation

organized and existing under and by virtue of the laws of the State of New York, is an MTO in the

NY-NJ Port. Its principal office is at 5080 McLester Street, Elizabeth, New Jersey 07207. 

Universal is engaged in the business of operating a marine terminal and stevedoring cargo ships in

the NY-NJ Port. Universal is a member of both NYSA and USMX and is bound by the collective

bargaining agreements negotiated by NYSA and USMX with the ILA.

32. The plaintiffs identified in paragraphs 26 through 31 are collectively referred to in

this complaint as the “MTO/Stevedore Plaintiffs.”

33. Plaintiff Cargotec USA Inc. (Cargotec), a company organized and existing under and

by virtue of the laws of the State of Delaware, is a crane maintenance repair company operating in

the NY-NJ Port. Its principal place of business is at 415 E. Dundee Street, Ottawa, Kansas 66067. 

Cargotec is a member of NYSA and is bound by the collective bargaining agreements negotiated

by NYSA and USMX with the ILA. 

34. Defendant International Longshoremen’s Association, AFL-CIO (ILA) is an

unincorporated association, i.e., a labor organization, with its principal office located at 17 Battery

Place, New York, New York 10004. The ILA represents longshore workers in ports on the Atlantic

and Gulf Coasts, including longshore workers employed by NYSA’s members in the NY-NJ Port. 

A0008057 -12-

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The ILA on behalf of its constituent locals, including the ILA locals named as defendants in this

complaint, negotiates and administers the Master Contract with USMX and the NYSA-ILA CBA

with NYSA. The ILA is a labor organization within the meaning of Section 2(5) of the LMRA, 29

U.S.C.A. § 152(5) (West 1998).

NY-NJ ILA Locals

35. Defendant Local 1, International Longshoremen’s Association, AFL-CIO (ILA Local

1) is an unincorporated association, i.e., a labor organization, with its principal office located at 235

Clifford Street, Newark, New Jersey 07105. ILA Local 1 represents the craft of longshore workers

known as clerks and checkers who are employed by NYSA’s members throughout the NY-NJ Port

and are responsible for locating and tallying cargo. ILA Local 1is a party to collective bargaining

agreements with NYSA and USMX, and ILA Local 1 is a labor organization within the meaning of

Section 2(5) of the LMRA, 29 U.S.C.A. § 152(5) (West 1998).

36. Defendant Local 920, International Longshoremen’s Association, AFL-CIO (ILA

Local 920) is an unincorporated association, i.e., a labor organization, with its principal office

located at 2015 Forest Avenue, Staten Island, New York 10303. ILA Local 920 represents the craft

of longshore workers known as longshoremen who are employed in Staten Island, New York, which

is within the NY-NJ Port, and who are responsible for loading and unloading cargo on to and off of

cargo ships. ILA Local 920 is a party to collective bargaining agreements with NYSA and USMX,

and ILA Local 920 is a labor organization within the meaning of Section 2(5) of the LMRA, 29

U.S.C.A. § 152(5) (West 1998).

37. Defendant Local 1233, International Longshoremen’s Association, AFL-CIO (ILA

Local 1233) is an unincorporated association, i.e., a labor organization, with its principal office

A0008057 -13-

Case 2:10-cv-06261-DRD -MAS Document 1 Filed 12/03/10 Page 13 of 28 PageID: 13
located at 731 South 10th Street, Newark, New Jersey 07108. ILA Local 1233 represents the craft

of longshore workers known as longshoremen who are employed by NYSA’s members in Newark

and Elizabeth, New Jersey, which is within the NY-NJ Port, and who are responsible for loading and

unloading cargo on to and off of cargo ships. ILA Local 1233 is a party to collective bargaining

agreements with NYSA and USMX, and ILA Local 1233 is a labor organization within the meaning

of Section 2(5) of the LMRA, 29 U.S.C.A. § 152(5) (West 1998). 

38. Defendant Local 1235, International Longshoremen’s Association, AFL-CIO (ILA

Local 1235) is an unincorporated association, i.e., a labor organization, with its principal office

located at 30 Hennessey Street, Newark, New Jersey 07105. ILA Local 1235 represents the craft

of longshore workers known as longshoremen who are employed by NYSA’s members in Newark

and Elizabeth, New Jersey, which is within the NY-NJ Port, and who are responsible for loading and

unloading cargo on to and off of cargo ships. ILA Local 1235 is a party to collective bargaining

agreements with NYSA and USMX, and ILA Local 1235 is a labor organization within the meaning

of Section 2(5) of the LMRA, 29 U.S.C.A. § 152(5) (West 1998).

39. Defendant Local 1588, International Longshoremen’s Association, AFL-CIO (ILA

Local 1588) is an unincorporated association, i.e., a labor organization, with its principal office

located at 550 Kennedy Boulevard, Bayonne, New Jersey 07002. ILA Local 1588 represents the

craft of longshore workers known as longshoremen who are employed by NYSA’s members in

Bayonne, New Jersey, which is within the NY-NJ Port, and who are responsible for loading and

unloading cargo on to and off of cargo ships and loading and unloading baggage on to and off of

cruise ships. ILA Local 1588 is a party to collective bargaining agreements with NYSA and USMX,

A0008057 -14-

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and ILA Local 1588 is a labor organization within the meaning of Section 2(5) of the LMRA, 29

U.S.C.A. § 152(5) (West 1998).

40. Defendant Local 1804-1, International Longshoremen’s Association, AFL-CIO (ILA

Local 1804-1) is an unincorporated association, i.e., a labor organization, with its principal office

located at 5000 West Side Avenue, North Bergen, New Jersey 07047. ILA Local 1804-1 represents

the craft of longshore workers known as maintenance and repair (M&R) workers who are employed

by NYSA’s members on the New Jersey side of the NY-NJ Port and are responsible for the

maintenance and repair of cargo-handling equipment. ILA Local 1804-1 is a party to collective

bargaining agreements with NYSA and USMX, and ILA Local 1804-1 is a labor organization within

the meaning of Section 2(5) of the LMRA, 29 U.S.C.A. § 152(5) (West 1998). 

41. Defendant Local 1814, International Longshoremen’s Association, AFL-CIO (ILA

Local 1814) is an unincorporated association, i.e., a labor organization, with its principal office

located at 70 20th Street, Brooklyn, New York 11232. ILA Local 1814 represents two crafts of

longshore workers, longshoremen and M&R workers who are employed by NYSA’s members on

the New York side of the NY-NJ Port. Local 1814's members who are longshoremen are

responsible for the loading and unloading of cargo on to and off of cargo ships and baggage on to

and off of cruise ships. Local 1814's members who are M&R workers are responsible for the

maintenance and repair of cargo-handling equipment. ILA Local 1814 is a party to collective

bargaining agreements with NYSA and USMX, and ILA Local 1814 is a labor organization within

the meaning of Section 2(5) of the LMRA, 29 U.S.C.A. § 152(5) (West 1998). 

42. The defendants identified in paragraphs 35 through 41 are collectively referred to in

this complaint as the “NY-NJ ILA Locals.” 

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Philadelphia ILA Locals

43. Defendant Local 1242, International Longshoremen’s Association, AFL-CIO (ILA

Local 1242) is an unincorporated association, i.e., a labor organization, with its principal office

located at 236 East Richmond Street, Philadelphia, Pennsylvania 19125. ILA Local 1242 represents

the craft of longshore workers known as clerks and checkers who are employed in the Port of

Philadelphia, which includes ports along the Delaware River in New Jersey and in Pennsylvania,

and who are responsible for the locating and tallying of cargo. ILA Local 1242 is a party to

collective bargaining agreements with USMX, and ILA Local 1242 is a labor organization within

the meaning of Section 2(5) of the LMRA, 29 U.S.C.A. § 152(5) (West 1998). 

44. Defendant Local 1291, International Longshoremen’s Association, AFL-CIO (ILA

Local 1291) is an unincorporated association, i.e., a labor organization, with its principal office

located at 3460 North Delaware Avenue, Suite 101, Philadelphia, Pennsylvania 19134. ILA Local

1291 represents the craft of longshore workers known as longshoremen who are employed in the

Port of Philadelphia, which includes ports along the Delaware River in New Jersey and in

Pennsylvania, and who are responsible for loading and unloading cargo on to and off of cargo ships. 

ILA Local 1291 is a party to collective bargaining agreements with USMX, and ILA Local 1291 is

a labor organization within the meaning of Section 2(5) of the LMRA, 29 U.S.C.A. § 152(5) (West

1998). 

45. Defendant Local 1566, International Longshoremen’s Association, AFL-CIO (ILA

Local 1566) is an unincorporated association, i.e., a labor organization, with its principal office

located at 1341 North Delaware Avenue, Suite 302, Philadelphia, Pennsylvania 19125. ILA Local

1566 represents the craft of longshore workers known as M&R workers who are employed in the

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Port of Philadelphia, which includes ports along the Delaware River in New Jersey and in

Pennsylvania, and who are responsible for the maintenance and repair of cargo-handling equipment. 

ILA Local 1566 is a party to collective bargaining agreements with USMX, and ILA Local 1566 is

a labor organization within the meaning of Section 2(5) of the LMRA, 29 U.S.C.A. § 152(5) (West

1998).

46. The defendants identified in paragraphs 43 through 45 are collectively referred to in

this complaint as the “Philadelphia ILA Locals.” 

BACKGROUND FACTS

47. Upon information and belief, members of the Holt family operate marine terminal

facilities in the Port of Philadelphia, including the Packer Avenue Marine Terminal (PAMT) on the

Pennsylvania bank of the Delaware River and the Gloucester Marine Terminal (GMT) on the New

Jersey bank of the Delaware River. 

48. Upon information and belief, the Philadelphia ILA Locals represent workers

employed at PAMT but do not represent workers employed at GMT.

49. The Holt company that operates the terminal at PAMT is Greenwich Terminals LLC,

which is a member of the Philadelphia Marine Trade Association Inc. (PMTA), a port association

which, like NYSA, is also a member of USMX. By virtue of its membership in the PMTA,

Greenwich Terminals LLC is bound by the Master Contract negotiated by USMX with the ILA.

50. Upon information and belief, during the spring of this year three carriers calling at

the NY-NJ Port considered relocating to PAMT in the Port of Philadelphia. Upon information and

belief, certain Philadelphia ILA Locals objected because Greenwich Terminals LLC does not

employ union labor that is represented by the ILA exclusively, since maintenance workers at PAMT

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are represented not by the ILA but by the International Association of Machinists. In addition, upon

information and belief, the employees at the automobile processing plant adjacent to PAMT are

represented by the International Brotherhood of Teamsters. Those objections were joined by the

objections of NY-NJ ILA Locals that did not want Greenwich Terminals LLC to get that work from

the NY-NJ Port.

51. Upon information and belief, the Philadelphia ILA Locals in or about the spring of

2010 requested that carrier-members of USMX write letters to the Governor of the Commonwealth

of Pennsylvania, requesting the Governor to cease giving preferential treatment to the facilities

owned by members of the Holt family on the grounds that it was creating labor dissension within

the Port of Philadelphia and, if the Governor refuses to do so, threatening to discontinue their calls

to the Port of Philadelphia.

52. Upon information and belief, the Philadelphia ILA Locals in or about the spring of

2010 requested that carriers cease calling at PAMT because the Philadelphia ILA Locals assert that

the Holt family uses Greenwich Terminals LLC to subsidize operations at GMT to take business

away from facilities in the Port of Philadelphia at which ILA-represented longshore workers are

employed.

53. In May 2010, the ILA and the NY-NJ ILA Locals requested a special meeting of the

NYSA-ILA Contract Board, which is the joint labor-management body responsible for the

administration of the NYSA-ILA CBA, to permit James H. Paylor, Jr., an International Vice

President of Defendant ILA from the Port of Philadelphia and the president of Defendant ILA Local

1566, to make a PowerPoint presentation. During that presentation Mr. Paylor sought the assistance

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of NYSA and its carrier-members to dissuade carriers from calling at PAMT and other facilities in

the Port of Philadelphia where employees are not represented by the ILA exclusively.

54. Upon information and belief, for many years vessels operated by Del Monte Fresh

Produce Co. (Del Monte) had called at a marine terminal facility in the Port of Philadelphia located

in Camden, New Jersey, at which members of the Philadelphia ILA Locals were employed. Del

Monte is not a member of Plaintiff NYSA or USMX, and it is not a party to a collective bargaining

agreement with Defendant ILA or any of Defendant ILA’s affiliated locals. 

55. Upon information and belief, in or about August of 2010 Del Monte entered into a

new agreement with GMT, which resulted in a loss of employment for numerous members of the

Philadelphia ILA Locals.

56. Upon information and belief, in or about early to mid September 2010, officers,

agents, and employees of the ILA, the NY-NJ ILA Locals, and the Philadelphia ILA Locals met in

New Jersey and Maryland to address the Philadelphia ILA Locals’ dispute with the companies

owned by members of the Holt family. Upon information and belief, at these meetings officers,

agents, and employees of the ILA, the NY-NJ ILA Locals, and the Philadelphia ILA Locals agreed

and conspired to devise and carry out a plan to direct, assist, and finance picketing by members of

the Philadelphia ILA Locals at marine terminals in the NY-NJ Port and to instruct members of the

NY-NJ ILA Locals to engage in a work stoppage in the NY-NJ Port by honoring the Philadelphia

members’ picket lines. Upon information and belief, the purpose of this plan was to embroil in the

dispute between the Philadelphia ILA Locals and the companies owned by members of the Holt

family the members of NYSA, including carrier-members of NYSA whose ships call at the Holt

family’s PAMT facility operated by Greenwich Terminals LLC, and thus encourage those NYSA

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members to cease doing business with Greenwich Terminals LLC or otherwise to pressure and

compel Greenwich Terminals LLC and the Holt family to discontinue their purported practice of

subsidizing GMT to take business away from facilities in the Port of Philadelphia at which ILArepresented longshore workers are employed or to force or require Greenwich Terminals LLC and

Gloucester Terminals LLC to recognize or bargain with the Philadelphia ILA Locals exclusively as

the representative of all their employees.

57. Approximately 3,600 members of the ILA and its affiliated locals are employed by

members of NYSA in the NY-NJ Port in the loading and unloading of cargo ships and ancillary

work. The continuous service of these employees is essential to the ability of NYSA’s members to

provide adequate service to their customers, to maintain the NY-NJ Port as a viable transportation

gateway, and to service the needs of the general public.

58. The NYSA-ILA CBA currently in full force and effect prescribes wages, hours, and

other terms and conditions of employment for the various crafts of longshore employees. The

agreement contains a comprehensive provision for the submission and settlement of all disputes

under the labor contract through the contract’s grievance and dispute resolution process, culminating

in the arbitration of disputes not resolved through the grievance procedure, and states that all parties

to the agreement agree to abide by the outcome of this procedure.

59. Article XXIV of the NYSA-ILA CBA provides that during its term “there shall be

no strikes or work stoppages by the employees.” That article also provides that the right of ILA

members not to cross a bona fide picket line is recognized by the employers. 

60. On Friday, September 24, 2010, there were reliable reports that members of the NYNJ ILA Locals would refuse to cross picket lines established by ILA members of the Philadelphia

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ILA Locals to protest the use by certain carrier-members of NYSA of the PAMT facility operated

by Greenwich Terminals LLC. Those carrier-members of NYSA are Plaintiffs CMA CGM, 

Hamburg Süd, MSC, and Maersk.

61. On September 24, 2010, NYSA on behalf of its members invoked the grievance and

dispute-resolution process of the NYSA-ILA CBA. Joseph Curto, President of Plaintiff NYSA and

the Management Cochairman of the NYSA-ILA Contract Board, submitted to Harold J. Daggett,

Executive Vice President of Defendant ILA, President of Defendant Local 1804-1, and Union

Cochairman of the NYSA-ILA Contract Board, a grievance objecting to the threats of a work

stoppage.

62. Mr. Curto issued in accordance with the NYSA-ILA CBA a notice scheduling for

Monday, September 27, 2010, at 10:00 A.M., a meeting of the NYSA-ILA Contract Board, the joint

labor-management grievance panel.

63. On September 27, 2010, the NYSA-ILA Contract Board convened the meeting as

scheduled, but the ILA members of the Contract Board who are the presidents of the NY-NJ ILA

Locals did not attend. In accordance with Article V, Section 3(B) of the Contract Board’s Bylaws

any actions taken by the side in attendance shall be deemed to have been voted against by the absent

party, resulting in a deadlock.

64. At 11:00 A.M. on September 27, 2010, a notice pursuant to Article XXV, Section

6(b) of the NYSA-ILA CBA was e-mailed by the Executive Secretary of the NYSA-ILA Contract

Board to Harold J. Daggett, stating that an expedited arbitration hearing would be held at 12:00 noon

at NYSA’s office in Edison, New Jersey before Arbitrator Eric J. Schmertz to resolve NYSA’s

grievance. Notice of the arbitration was provided by telephone to Defendant ILA’s counsel. A

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hearing was held at which Arbitrator Schmertz heard testimony and received exhibits from NYSA. 

Again, the union members of the Contract Board, who are the presidents of the NY-NJ ILA Locals,

did not appear at the arbitration.

65. At the conclusion of the hearing, Arbitrator Schmertz issued a short-form award that

states in part:

There have been reliable reports of imminent picketing at the Port of New York and

New Jersey by members of ILA locals from outside the Port of New York and New

Jersey to protest carriers that call at terminals operated in the Port of Philadelphia by

Holt Terminals. This picketing would constitute secondary activity in violation of

the National Labor Relations Act. Accordingly, the threatened picket lines are not

bona fide and the members of the ILA have no right to refuse to cross any such

picket line. If such picketing commences, I order the officers of the International

Longshoremen’s Association, AFL-CIO and its constitutent locals in the Port of New

York and New Jersey to inform their members that such picket lines are not bona

fide and their refusal to cross those picket lines is a violation of the no-strike clause

of the NYSA-ILA Collective Bargaining Agreement. 

66. By facsimile dated September 27, 2010, a copy of Arbitrator Schmertz’s Arbitration

Award was served upon the ILA’s Executive Vice President and the ILA’s General Counsel, who

subsequently advised that that day he sent a copy of the Award to each of the NY-NJ ILA Locals. 

67. On September 28, 2010, pickets appeared early in the morning at the marine terminal

facilities operated by the MTO/Stevedore Plaintiffs.

68. Upon information and belief, the pickets were established by members of the

Philadelphia ILA Locals.

69. Members of the NY-NJ ILA Locals who had been working left their respective

terminals and stood behind the picket lines; other members of the NY-NJ ILA Locals refused to

cross the picket lines; and numerous members of the NY-NJ ILA Locals joined the pickets.

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70. Members of the NY-NJ ILA Locals ignored their employers’ instructions to return

to work, and some union shop stewards joined the picket lines.

71. Upon information and belief, officers, agents, and representatives of the NY-NJ ILA

Locals were present at marine terminal facilities in the NY-NJ Port during the picketing and either

encouraged members of the NY-NJ ILA Locals to refuse to cross the picket lines or failed to take

action to dissuade them from doing so. 

72. Upon information and belief, picket signs at the marine terminal facilities in the NYNJ Port contained statements, such as “Holt took our jobs. We are on strike”; “Holt Starves My

Family”; “Holt has taken our jobs from us. He moved Delmonte from our pier to Gloucester, NJ for

$8.00 per hour scabs”; and “Holt starves my family. He went after Delmonte. Our jobs are being

displaced. Labor agreed to concessions. Terminated our Delmonte contract.”

73. Upon information and belief, officers, agents, employees, and representatives of the

NY-NJ ILA Locals instructed members of those locals to leave the terminals. 

74. On September 28, 2010, NYSA on behalf of its members filed with this Court a

petition to confirm and enforce the arbitration award and to obtain preliminary and permanent

injunctive relief. See New York Shipping Association, Inc. v. International Longshoremen’s

Association, AFL-CIO, et al., 10-cv-4960 (DRD)(MAS). At 3:00 P.M. on that day, the Honorable

Dickinson R. Debevoise issued an Order to Show Cause and Temporary Restraining Order (Order),

which (1) enjoined the ILA, the ILA locals in the NY-NJ Port, and their respective officers, agents,

servants, members, employees, representatives, and attorneys who receive notice of the Order from

failing to comply with the terms of the Award and from threatening, calling, engaging in,

conducting, organizing, taking part in, sanctioning, inducing, ordering, encouraging, or aiding any

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work stoppage contrary to the Award and (2) directed the ILA, the ILA locals in the NY-NJ Port,

and their respective officers, agents, servants, members, employees, representatives, and attorneys

who receive notice of the Order to maintain the working conditions, work assignments, and manning

decisions prevailing between the parties on September 27, 2010, and to take all appropriate measures

to terminate and prevent any violation of the Award, including the issuance forthwith of notices to

the members, officers, servants, attorneys, employees, and agents of the ILA and the ILA locals in

the NY-NJ Port to terminate and refrain from honoring the picket lines or otherwise violating the

terms of the Award.

75. On September 28, 2010, copies of the Court’s Order were delivered by electronic

mail to the ILA, its counsel, counsel to certain of the NY-NJ ILA Locals, including Defendants ILA

Local 1, ILA Local 1233, ILA Local 1804-1, and ILA Local 1814; telephonic notification

concerning the Order was provided to ILA Local 1233; copies of the Order were sent via facsimile

to the ILA and to all the NY-NJ ILA Locals; and copies of the Order were distributed by hand to

dozens of individual longshore workers.

76. Members of the NY-NJ ILA Locals refused to return to work for the 7:00 P.M. shift

on September 28, 2010. 

77. The next morning members of the NY-NJ ILA Locals again refused to return to work. 

By 10:30 A.M. on September 29, 2010, the ILA and each of the NY-NJ ILA Locals had been served

with a hard copy of the Court’s Order. NYSA warned the ILA that contempt proceedings would be

commenced that day if the work stoppage was not called off.

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78. By the afternoon of September 29, 2010, the ILA informed NYSA that its members

would return to work for the 7:00 P.M. shift. ILA members without exception did in fact return to

work for that shift.

79. On October 7, 2010, at a meeting of the Industry Resource Committee (IRC), a joint

labor-management administrative body under the Master Contract, Management representatives

expressed concern about the reoccurrence of picketing in the NY-NJ Port concerning the

Philadelphia dispute but were assured by Harold J. Daggett, Defendant ILA’s Executive Vice

President and the president of Defendant ILA Local 1804-1, that there would be no further work

stoppage. James H. Paylor, Jr., who was also in attendance at this IRC meeting, reiterated the need

for the carriers to send a letter to the Governor of Pennsylvania threatening to withdraw from the

Port of Philadelphia and requested USMX to agree to an amendment to the Master Contract

prohibiting carriers from calling at terminals operated by companies with double-breasted

operations, which in the view of Mr. Paylor means the Holt family companies because one company

has ILA-represented employees and the other does not.

80. On November 1, 2010, this Court issued a Consent Order and Judgment in New York

Shipping Association, Inc. v. International Longshoremen’s Association, AFL-CIO, et al., 10-cv4960, that inter alia confirms and enforces Arbitrator Schmertz’s Award and permanently enjoins

the ILA and the NY-NJ ILA Locals from failing to comply with Arbitrator Schmertz’s Award and

from threatening or engaging in any work stoppage contrary to that Award. 

COUNT I

81. Plaintiffs repeat and reallege each of the allegations set forth in Paragraphs 1-80

above and incorporate same by reference as if fully set forth herein.

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82. Plaintiffs are engaged in commerce or in an industry affecting commerce.

83. Section 8(b)(4) of the Labor-Management Relations Act, 29 U.S.C.A. § 158(b)(4)

(West 1998), provides inter alia as follows:

It shall be an unfair labor practice for a labor organization or its agents – . . .

(4) (i) to engage in, or to induce or encourage any individual employed by

any person engaged in commerce or in an industry affecting

commerce to engage in, a strike or a refusal in the course of his

employment to use, manufacture, process, transport, or otherwise

handle or work on any goods, articles, materials, or commodities or

to perform any services; or (ii) to threaten, coerce, or restrain any

person engaged in commerce or in an industry affecting commerce,

where in either case an object thereof is – . . .

(B) forcing or requiring any person to cease using, selling,

handling, transporting, or otherwise dealing in the products of

any other producer, processor, or manufacturer, or to cease

doing business with any other person, or forcing or requiring

any other employer to recognize or bargain with a labor

organization as the representative of his employees . . . .

84. Section 303 of the Labor-Management Relations Act, 29 U.S.C.A. § 187 (West

1998), provides as follows:

(a) It shall be unlawful for the purpose of this section only, in an industry or

activity affecting commerce, for any labor organization to engage in any

activity or conduct defined as an unfair labor practice in section 158(b)(4) of

this title.

(b) Whoever shall be injured in his business or property by reason of any

violation of subsection (a) of this section may sue therefor in any district

court of the United States subject to the limitations and provisions of section

185 of this title without respect to the amount in controversy, or in any other

court having jurisdiction of the parties, and shall recover the damages by him

sustained and the cost of the suit.

85. Defendants engaged in or induced or encouraged their members who are employed

by Plaintiffs to engage in a strike or a refusal in the course of their employment to perform any

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services for Plaintiffs or threatened, coerced, or restrained Plaintiffs, where the object of such

conduct was to force or require Plaintiffs to cease doing business with Greenwich Terminals LLC

or to alter their relationships with Greenwich Terminals LLC or threatened, coerced, or restrained

Plaintiffs to force or require Gloucester Terminals LLC to recognize or bargain with the Philadelphia

ILA Locals as the representative of the employees at GMT or to force or require Greenwich

Terminals LLC to recognize or bargain with the Philadelphia ILA locals as the representative of all

its employees.

86. The acts and conduct of Defendants are unlawful and in violation of 29 U.S.C.A.

§ 158(b)(4) (West 1998) and, therefore, in violation of 29 U.S.C.A. § 187 (West 1998)

87. As a result of the acts and conduct of Defendants, Plaintiffs have suffered damages

in an aggregate amount exceeding Five Million ($5,000,000) Dollars.

COUNT II

88. Plaintiffs repeat and reallege each of the allegations set forth in Paragraphs 1-80

above and incorporate same by reference as if fully set forth herein.

89. Defendant ILA and Defendants NY-NJ ILA Locals in bad faith and in willful

disobedience of both an arbitration award and a court order induced, encouraged, or directed their

members to engage in an unlawful work stoppage in violation of 29 U.S.C.A. § 158(b)(4) (West

1998) and, therefore, in violation of 29 U.S.C.A. § 187 (West 1998).

90. As a result of that conduct, Plaintiff NYSA has suffered damages in that Plaintiff

NYSA incurred attorneys’ fees in connection with its efforts to terminate the work stoppage.

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PRAYER FOR RELIEF

WHEREFORE, Plaintiffs respectfully request judgment be entered as follows:

(1) ordering Defendants jointly and severally to pay a money judgment to each

Plaintiff to reimburse each Plaintiff for the damages that it suffered as a result

of Defendants’ unlawful activity;

(2) ordering Defendants jointly and severally to pay to Plaintiff NYSA the

attorneys’ fees it incurred in connection with its efforts to terminate the work

stoppage;

(3) ordering Defendants jointly and severally to pay the reasonable costs of this

action; and

(4) ordering such other and further relief as the Court may deem just and proper.

Dated: Bayonne, New Jersey 

 December 3, 2010

THE LAMBOS FIRM, LLP

By: s/ James R. Campbell 

Carol N. Lambos

James R. Campbell

599 Avenue C

Bayonne, New Jersey 07002

Tel. (201) 823-1000

Fax (201) 823-3097

and

Donato Caruso

William M. Spelman

THE LAMBOS FIRM, LLP

303 South Broadway, Suite 410

Tarrytown, New York 10591

Tel. (212) 943-2470

Fax (212) 797-9213

Attorneys for Plaintiffs

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