UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MISSOURI
UNITED STATES OF AMERICA
CRIMINAL COMPLAINT
v.
CASE NUMBER: 4:04MJ1286TIA
DONALD L. RUDD
I, Ralph Amelung, the undersigned complainant being duly sworn state the following is true and correct
to the best of my knowledge and belief. On or about October 22, 2003, in St. Louis County, in the Eastern
District of Missouri, defendant did,
embezzling and converting union funds to his own benefit while and officer of the union
in violation of Title 29, United States Code, Section 501(c). I further state that I am an Agent and
that this complaint is based on the following facts:
Continued on the attached sheet and made a part hereof. _X_ Yes
Sworn to before me, and subscribed in my presence
/SIGNED/_____
Signature of Complainant
Ralph Amelung
Agent
Department of Labor, OLMS
December 10, 2004
Date
at St. Louis. Missouri
City and State
/SIGNED/_____
Signature of Judicial Officer
Terry I. Adelman
United States Magistrate Judge
Name and Title of Judicial Officer
AFFIDAVIT
I, Ralph Amelung, being first duly sworn, depose and state that I am an Agent with the Department
of Labor, Office of Labor Management Standards. I have been a Federal Agent with the DOL/OLMS for
over 15 years. My duties as an Agent with the DOL/OLMS include the investigation of embezzlement of
union funds in violation of Title 29, United States Code, Section 501(c), and the creation of false
statements in union records in violation of Title 29, United States Code, Section 439.
I was assigned an audit of the Service Employees International Union, Local 50, in St. Louis,
Missouri.
The information contained within this affidavit is based on my investigation and on the
information either personally known to me or provided to me by other law enforcement officers in my
official capacity. Since this affidavit is being submitted for the limited purpose of securing a
warrant for the arrest of DONALD L. RUDD, a white male, date of birth ,
SSN , I have set forth
only the facts that I believe are necessary to establish probable cause that the suspect has violated
Title 29, United States Code, Sections 501(c) and 439.
Beginning in February of 2004, I started a routine audit of the Service Employees International
Union, Local 50, in St. Louis, Missouri. This audit was begun because the annual financial report of
the Local (LM-2) showed that the President's expenses had doubled in one year while the Local had
fallen $500,000.00 behind in their per capita payments. My investigation covered the period from
January of 1999 through January of 2004. In all of that time, Local records show that DONALD L. RUDD
was the President of the Local. In that capacity, he was issued a credit card by the Local to use
exclusively to pay expenses of the Local. Further, my investigation showed that DONALD L. RUDD was
the only officer of the Local actively involved in the financial matters of the Local.
By reviewing the records of the Local, I learned that in 2003 DONALD L. RUDD was paid a salary of
$77,830.25 and received the use of an automobile and health and pension benefits paid by the Local.
The Local's LM-2 for the fiscal year ending on June 30, 1999, showed DONALD L. RUDD's expenses to be
$9,733.00. The LM-2 for the fiscal year ending on June 30, 2003 showed those expenses had increased
to $35,076.00. I began to examine the records of the Local to determine what expenses made up this
increase. I found expenses I considered questionable. These expenses related to uses of the Union
Travel MasterCard the Local had provided to DONALD L. RUDD.
In the records which related to the use of the MasterCard, I found 530 examples of DONALD L. RUDD
using the MasterCard at lounges and a hotel near his residence. In 1999, I found 1 such charge for
$25.00. In 2000, I found 48 such charges for $1,215.01. In 2001, I found 113 such charges for
$3,268.77. In 2002, I found 206 such charges for $7,284.83. In 2003, I found 158 such charges for
$6,139.74, and in January of 2004, I found 4 such charges for $150.55. Included in these charges was
a February 6, 2002, $45.00 charge and a October 22, 2003, $120.00 charge for a room at the Stratford
Inn, a hotel connected to the Stratford Bar and Grill at which DONALD L. RUDD made frequent charges
on the Local's MasterCard. The records available to me showed that these charges generally occurred
at night, well after the Local's business hours. As DONALD L. RUDD was forbidden to use the Local's
MasterCard for personal expenses, I tried to determine the nature of these charges which totaled
$18,083.90.
I spoke with the manager of the Stratford Inn who told me that each of these charges was for the
rental of a sleeping room at the Inn. The Vice-President of the Local told me of meeting DONALD L.
RUDD at a number of bars, after union hours, for social occasions. He told me that DONALD L. RUDD had
told him that he (RUDD) had, "got pretty toasted and had to get a room." I spoke with Business
Agents, other officers of the Local, all of whom had also met DONALD L. RUDD in the bars to which he
had made charges on the MasterCard. All said the meetings were not for Local business and could not
have been charged to the Local by RUDD. The Secretary-Treasurer of the local said he knew of no union
activities that could have necessitated the charges. I could find no Local officer or employee to
back up that any of these expenses were related to the business of the Local. All said their meetings
with RUDD after hours in bars were social.
I then spoke with the Trustees of the Local, all of whom were unaware of the charges. All said
this use of the Local's MasterCard was improper.
I also interviewed bar personnel at two of the bars for which DONALD L. RUDD submitted charges
related to the MasterCard. At one of the establishments I was told that RUDD liked to play darts
while he was visiting. At another establishment an employee confirmed that RUDD visited with
co-workers and his girlfriend. The employee could not recall what types of activities RUDD engaged in
during his visits.
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