Robert W. Earley submitted expenses of approximately $26, 269 pursuant to the Settlement Agreement and Release of 1:94CV0597. Admit, hell, Lance, you know that is true because we gave you the records and you have published them.
	Robert W. Earley received a check made out to him personally in excess of $48,000 for those expenses. Admit, but we're still trying to find out how you got that information and we will discipline anyone who gave it to you.
	The Washington firm of Guerrieri, Edmond & Claymon, P.C. has billed UTU over $150,000 in prosecuting Smoot on UTU=s counterclaims and attempting to execute the "judgment". Admit that it is between $100,000 and $200,000 but you will have to access those records through legal action.
	Did you put up a $100,000 bond just in case UTU had no right to their Writ of Attachment. Admit, now Lance, you know that's true, you put up a copy of the bond on your web site.
	Did UTU International pay members of Local 1918 one or two committee days to visit the bus when it was in El Paso late last year. Admit, now Lance you know that's true and you just want me to deny it so you can put up the records. I'm too smart to fall for that!
	The UTU International pays UTU members who support you to come to Region Meetings and applaud on cue. I have insufficient knowledge to admit or deny that allegation or in the alternative, I take the Fifth! Wait, you're not referring to Special Reps, are you? Hell, I'd have to admit that, they are swarming everywhere.
	Did the UTU International pay out approximately $1.6 million dollars to "Special Representatives" in 1998. Admit, now Lance, you know that's true because we sent you the LM2 and 990 and I know you probably have a list with every name, amount, and total.
	The Job Benefit Fund shows in the Monthly GS&T Report under "Funds held in Trust". Admit, but Lance you know we just fraudulently transferred the money over there to hide it from the Blankenbaker lawyers. We can use it however we want, unless we have to put it over there again to hide it from Smoot's lawyers!
	The Job Benefit Fund showed as "Funds held in Trust"in 1995 when you and the Board of Directors determined you could use the money as if it was member=s dues dollars. Admit, now Lance, asked and answered above!
	Approximately $2 million was transferred from JBI into the General Fund in March 1999. Admit, but I have insufficient knowledge to admit or deny where the money actually came from, I let the GS&T take care of all that stuff for me (haha)!
	You continue to "barrow" money from the JBI faster than you are paying it back. Deny, I think we may be a few hundred thousand ahead by now, but that's not to say we may have to fund the NMB election with the JBI fund since we don't have but about a million we can actually use.
	Your Washington law firm will argue before the Sixth Circuit that a Federal District Court Judge has no jurisdiction to hear a case filed under 45 U.S.C. ' 153 First (q). Admit, Clint tells me we got a 50/50 chance at overturning federal law!
	You paid a previous designated legal counsel over $3000 to aver what Bob Earley did at PLB 3882 was within the wide range of reasonableness allowed a union officer. Admit, now Lance you know we also gave you those records and you also have the brief. You can't trick me.
	You violated Article 24, lines 13 - 17 (Oct. 1, 1995 Blue Constitution) when you interfered (stopped) with the Executive Board trial of VP Robert W. Earley by using an alleged, illegal "Settlement Agreement and Release". Deny, now Lance, you know Article 16 supersedes all other articles in the UTU Constitution, hell, you even have a cartoon about it on your web site.
	The UTU Board of Directors upheld your interference in the trial by approving the "SAR". Admit, Of course they did, they know who is the Boss - ah, well, everyone EXCEPT ONE!

You affiliated with a labor union in England that costs UTU $25,000 per year in violation of Article 31, lines 16 - 20. Deny, now Lance you know that is a damn lie, the first year cost us $25,000 to affiliate in violation of the Constitution but you surely know, because we gave you those records, that it only cost us $15,984.38 last year. I might add that is approximately a $9000 asset!

You gave Yardmaster Department Officers raises far in excess of those allowed under the Constitution and/or the Employee Agreement. Admit, but Lance you know as well as I do the the Board of Directors denied your frivolous complaint on that matter.

You spent approximately $30,000 of UTU monies for a Designated Counsel Meeting in Arizona recently. Admit, but I had a real good time in Arizona and I didn't hear one complaint from any designated counsel!

You don=t know the difference between right and wrong, a lie and the truth. Now Lance, I have insufficient knowledge to admit or deny that allegation.

"Bulletproof if "u" tell the truth"