1. The New York City Department of Environmental Protection (NYC DEP) is the municipal agency responsible for providing 1.3 billion gallons of drinking water to over 8 million city residents daily while ensuring compliance with federal (EPA) regulations proscribing threshold levels of pollutants, including lead (15 parts per billion [ppb]). The overwhelming majority of NYC DEP’s employees are also members of District Council 37 (DC-37), New York City’s largest public employee union, and individually affiliated through one of its 56 locals, e.g., Local 1322-NYC DEP Supervisory Employees; Local 1320-NYC Sewage Treatment & Senior Sewage Treatment Workers; Local 375-Civil Service Technical Guild, etc.

2. Labor racketeering refers to the unlawful use of a union or benefit plan (e.g., pension plan) for personal benefit and includes: (a) improper labor management relations, (b) employee benefit plan fraud, (c) internal union corruption, and (d) infiltration by organized crime. This action was originally commenced by 10 existing & recently terminated NYC DEP whistleblower-employees asserting RICO Act claims and alleging egregious acts of workplace retaliation that occurred immediately after attempting to report an ongoing labor racketeering scheme existing within DC-37, as well as observed violations of the Clean Water Act.