THE GRAND JURY CHARGES:
- That at all times material to this Indictment, (name of union) was a labor organization engaged in an industry affecting commerce within the meaning of Title 29, United States Code, Sections 402(i) and (j).
- That on or about (date) in the _________ District of __________ and elsewhere, the defendant ___________, did unlawfully and willfully through the use of force and violence and threats of the use of force and violence restrain, coerce, and intimidate and attempt to restrain, coerce and intimidate (name of victim) , a member of (name of union) , for the purpose of interfering with* and preventing the exercise of his/her rights to which he/she was entitled under the provisions of Section [411, 414, 415, 431, 461, 481, 501(b)] Title 29, United States Code, that is, the right to (list specific right of free speech, equal participation, etc. affected by defendant) in that defendant did (describe how defendant interfered with union member's right)**.
All in violation of Title 29, United States Code, Section 530.
* See United States v. Kelley, 545 F.2d 619 (8th Cir. 1976) concerning retribution for prior exercise of rights.
** See United States v. Lynch, 792 F.2d 269 (1st Cir. 1986) concerning interference with a union member's rights by violence directed at a third person.
[cited in USAM 9-137.000]