AMALGAMATED & the ALL WRITS ACT

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AMALGAMATED & the ALL WRITS ACT

Ted
A. The All Writs Act

The Government submitted that this Court has the power to issue extraordinary writs under the All Writs Act. That statute reads as follows:

The Supreme Court and all courts established by Act of Congress may issue all writs necessary or appropriate in aid of their respective jurisdictions and agreeable to the usages and principles of law.

28 U.S.C. § 1651(a).
The broad language of the All Writs Act has been supplemented by case law which outlines the appropriate situations for issuing injunctions that bar parties from litigating suits before other tribunals.

In this Circuit, Courts interpreting the scope of this power under the All Writs Act look to that act, and also by analogy to circumstances involving the Anti-Injunction Act, 28 U.S.C. § 2283, which prevents Federal Courts from issuing injunctions barring proceedings in state tribunals except "when necessary in aid of jurisdiction." In re Baldwin-United Corporation,770 F.2d 328, 335 (2d Cir.1985).

Circumstances where inter-court injunctions under the All Writs Act are appropriate include

(1) enjoining state actions when necessary to prevent relitigation of an existing federal judgment; Id., see United States v. New York Telephone,434 U.S. 159, 172, 98 S.Ct. 364, 372, 54 L.Ed.2d 376 (1977);

(2) preventing a state court from interfering with a federal court's consideration or disposition of a case so "as to seriously impair the federal court's flexibility and authority to decide that case" Baldwin-United, supra, 770 F.2d at 335, quoting Atlantic Coast Line R.R. Co. v. Brotherhood of Locomotive Engineers,398 U.S. 281, 295, 90 S.Ct. 1739, 1747, 26 L.Ed.2d 234 (1970);

(3) enjoining a state court seeking to entertain an action over the same res; and in an in rem action, when the parallel state action will defeat the already attached jurisdiction of the federal court. Baldwin-United, supra, 770 F.2d at 336; see Kline v. Burke Construction Co.,260 U.S. 226, 230, 43 S.Ct. 79, 81, 67 L.Ed. 226 (1922); Cf. Vendo Co. v. Lektro-Vend Corp.,433 U.S. 623, 642, 97 S.Ct. 2881, 2893, 53 L.Ed.2d 1009 (1977);

(4) enjoining repeated, baseless, vexatious litigation by the same plaintiff in a federal court, Safir v. United States Lines, Inc,792 F.2d 19, 23-24 (2d Cir.1986); and

(5) in certain actions involving parallel actions in foreign courts, see Laker Airways v. Sabena, Belgian World Airways,731 F.2d 909, 926-34 (D.C.Cir.1984).

In addition to those general circumstances, under the All Writs Act courts may issue injunctions to enjoin other proceedings when the unique character of the litigation requires that relief be determined "flexibly." New York Telephone, supra, 434 U.S. at 173, 98 S.Ct. at 372. A federal court has the power "to issue commands under the All Writs Act as may be necessary or appropriate to effectuate and prevent the frustration of orders it has previously issued in the exercise of jurisdiction otherwise obtained." Id. at 174, 98 S.Ct. at 373.

The All Writs Act also grants courts the authority to bind non-parties to an action "when needed to preserve the Court's ability to reach or enforce its decision in a case over which it has proper jurisdiction." Baldwin-United, supra, 770 F.2d at 338; see New York Telephone, supra, 434 U.S. at 172, 98 S.Ct. at 372, cf. Vuitton et Fils



[ 728 F.Supp. 1044 ]


S.A. v. Carousel Handbags,592 F.2d 126, 129 n. 6 (2d Cir.1979) (discussion in dicta).
The existing authority on injunctions under the All Writs Act indicates that a federal court, under special circumstances, has the power to enjoin a parallel proceeding. In addition, a federal court may invoke the All Writs Act to bring before it parties whom it otherwise does not have personal jurisdiction over. The special circumstances of this IBT litigation warrant this Court's exercising its powers under the All Writs Act and enjoining the subordinate entities from litigating matters pertinent to the Consent Decree in any other forum.
_________________________________

The All Writs Act can be utilized by the Federal Court upon proper application by the R.O. or the U.S.A.O. to prevent the NLRB, non parties, Bisceglie etc. from interfering with the mandates of the Consent Decree.

The NLRB is a quasi-legislative and quasi-judicial inferior department of the Executive Branch of Government under the United States Constitution. It is not a Court of Law; and it does not hold that the NLRB controls the subject matter jurisdiction relative to the issue concerning Amalgamated and the Dockbuilders.

It is up to the current Executive squad and the DC Attorneys, Trust Fund attorneys to admit into the record all pertinent issues, exhibits, empirical data and facts to preserve any & all appeal rights now at issue in this proceeding.

Ted
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Re: AMALGAMATED & the ALL WRITS ACT

Ted

U.S. Supreme Court

NATIONAL LABOR RELATIONS BOARD v. ELECTRICAL WORKERS, 308 U.S. 413 (1940)

308 U.S. 413

NATIONAL LABOR RELATIONS BOARD
v.
INTERNATIONAL BROTHERHOOD OF ELECTRICAL WORKERS et al.
No. 253.

Argued Dec. 8, 1939.
Decided Jan. 2, 1940.


Messrs. Frank Murphy, Atty. Gen., and Charles Fahy, of Washington, D. C., for petitioner.
 
Messrs. Taft, Slettinius & Hollister, and John B. Hollister, all of Cincinnati, Ohio, and Isaac Lobe Straus, and Sigmund Levin, both of Baltimore, Md., for respondents.
 
Mr. Justice STONE delivered the opinion of the Court.

This is a companion case to American Federation of Labor, et al. v. National Labor Relations Board, 308 U.S. 401 , 60 S.Ct. 300, decided this day. The decisive question raised by the petition is whether a direction for an election made by the National Labor Relations Board in a representation proceeding under 9(c) of the Wagner Act, 49 Stat. 449, 453, 29 U.S.C., Supp. IV, 151-166, 29 U.S.C.A. 151-166, is reviewable by a circuit court of appeals under 10(f) of the Act. [308 U.S. 413, 414]   In February, 1938, International Brotherhood of Electrical Workers, Local 876, one of the respondents, and an affiliate of respondent, American Federation of Labor, filed with the regional director of the Board a petition asking an investigation and the certification of a representative, for purposes of collective bargaining, of the employees of Consumers Power Company, pursuant to 9(c) of the Act. After a hearing, in which the petitioner, the employer, and the Utility Workers Organizing Committee, an affiliate of the Congress of Industrial Organization, participated, the Board issued a 'decision and direction of election.' 9 N. L.R.B. 742. At the election in January, 1939, 2,806 of the total 2,977 employees voted. Of these 1,072 voted for I.B.E.W. and 1,164 voted for U.W. O.C.
 
After further proceedings and a hearing the Board found 'that the question concerning representation which has arisen can best be resolved by the holding of a run-off election in which the employees in the appropriate unit will be given the opportunity to decide whether or not they desire to be represented by U.W.O.C.' and made its 'direction' accordingly. 11 N.L.R.B. 848.
 
Contending that the direction, contrary to law, excludes Union 876 from the ballot on the run-off election, respondents petitioned the Court of Appeals for the Sixth Circuit to review the direction under the provisions of 10(f) of the Act. That court set aside the direction as infringing the free choice by employees of their representatives for purposes of collective bargaining assured to them by 1, 7, 9(a) and (c) of the Wagner Act, 29 U.S.C.A. 151, 157, 159(a, c). We granted certiorari October 9, 1939, 308 U.S. 537 , 60 S.Ct. 105, 84 L.Ed. --, so that the case might be considered with American Federation of Labor et al. v. National Labor Relations Board, 308 U.S. 401 , 60 S.Ct. 300.
 
Decision here is controlled by our decision in that case. The direction for an election is but a part of the repre- [308 U.S. 413, 415]   sentation proceeding authorized by 9(c) and is no more subject to review under 10(f) than is a certification which is the final step in such a proceeding and which we have just held Congress has excluded from the review afforded by that subdivision.
 
Reversed.
Ted
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Re: AMALGAMATED & the ALL WRITS ACT

Ted
This post was updated on .
In reply to this post by Ted
excerpt: Kevin Price at  page 11 & 12

Next, the Court rejects Defendants’ contention that Price’s display of the sticker and expression of views constitutes “dual unionism,” precluding it from being symbolic speech protected by the LMRDA.

Simply put, dual unionism is “promoting a rival union” in a way that “impairs the ability of one’s own union to carry out its collective bargaining responsibilities by diminishing its authority as bargaining representative.” Aircraft Mechanics Fraternal Association v. Transport Workers Union of America, Local514 , 98 F.3d 597, 598-600 (10 Cir. 1996).thin Aircraft Mechanics ,the Tenth Circuit described dual unionism as “the active promotion of a rival labor organization contrary to the interests of one’s own union.” Id.at 601.Dual unionism is itself a punishable offense “leveled at a union member or  -11-  

officer who seeks or accepts membership or position in a rival union, or otherwise attempts to undermine a union by helping its rival.” Id.

Typically, this occurs where a member collects signatures for a rival union, files an election petition for a rival union, or distributes or encourages other individuals to sign cards authorizing a rival union to be their exclusive bargaining representative. Id.The record currently before this Court doesnotsupport the conclusion thatPrice engaged in dual unionism. Price is a proud and loyal member of his own Carpentersunion who wants to preserve that union. He vehemently disagrees with certain policiesadvocated by his current union leaders – policies he believes are antithetical to the best interests of his beloved union.

But he is not sponsored by (or sponsoring) a rival union. He has not joined a rival union and is not encouraging others to do so. Nor is Price championing a rival union against his own union. His expression of anti-Local 57 views occurred squarely within the context of his desire to reform his own union’s policies from within,not to undermine his union by helping a rival organization. He does not wish to belong to anyother union, he wants to protect and restore what he believes are the core values, history and traditions of his own union.
Ted
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Re: AMALGAMATED & the ALL WRITS ACT

Ted
In reply to this post by Ted
Simply put, dual unionism is “promoting a rival union” in a way that “impairs the ability of one’s own union to carry out its collective bargaining responsibilities by diminishing its authority as bargaining representative.” Aircraft Mechanics Fraternal Association v. Transport Workers Union of America, Local514 , 98 F.3d 597, 598-600 (10 Cir. 1996).thin Aircraft Mechanics ,the Tenth Circuit described dual unionism as “the active promotion of a rival labor organization contrary to the interests of one’s own union.” Id.at 601.Dual unionism is itself a punishable offense “leveled at a union member or  -11-  

officer who seeks or accepts membership or position in a rival union, or otherwise attempts to undermine a union by helping its rival.” Id.

__________________________________

Assuredly, we're not all rocket scientists as the cliche is used, but it seems to me that rather than target 157 blogspot and the sites owner for bogus charges - that the NYCDCC Officers ought to be looking into preferring charges and expulsions of those members who have not resigned their UBC cards/books per Section 47 of the Constitution; and, who are willfully & wantonly causing dissension and whom are advocating for Amalgamated via the "dual unionism" as a punishable offense described by the Court in the cases cited above.

Just one man's opinion - seems that the DC Attorneys should take notice and proceed accordingly, as the loss of critical man-hours and assets are what they are after. IUPAT will not provide the Dock-builders any form of security, whether in weekly pay or in the receipt of benefits in the near term or in the long term. IUPAT is in it for themselves, as are the Attorneys for Amalgamated...the rank & file being their last concern.
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Re: AMALGAMATED & the ALL WRITS ACT

Dockbuilder
You are just one man with an opinion, we are the rank and file. We are fighting for reform, the union needs it, and this reform is the only kind that has got anyone's attention. Why? Because they are scared, they know that by organizing under our rights as citizens they can lose us, it's all about the money with them, with us it's about our rights as union members to vote directly on our representatives, contracts, and assessments. You can't say that within the UBC we will ever have those rights again, but under our organization not only can you, but you will.
Ted
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Re: AMALGAMATED & the ALL WRITS ACT

Ted
A ton of case law says otherwise. I have read it, have you? Just as tradesman applied "lessons learned", so to do the attorneys, regarding what works and what does not work.

Subject matter jurisdiction brings this well within the purview of the R.O. and the Funds Attorneys. They have many legal angles at their ready disposal. It would appear that hostile take-overs by mobbed up parasites to get at the trust fund monies, which is ultimately what they are after would warrant such a review and subsequent application.

Prong 1 of the Consent Decree trumps Prong 2 of the Consent Decree. Accordingly, the democratic rights, the latter may just have to yield to the former. ERISA mandates a withdrawal liability, the cost of which far exceeds the 401(k) the mobsters seek to replace the defined benefit pension & annuity plans with sparking more issues relevant to the 10-year ERISA approved FIP's to ensure the Funds properly receive adequate revenue to fund at mandated levels above the 65% endangered fund status and the 80% critical status.

These few issues alone could generate years of litigation.

The reason this alleged attempt at reform "has got anyone's attention" is because it is akin to a Brink's Job or bank heist if your prefer, via electronic transfer of assets, from the now sterilized NYCDCC to unknown  & alleged mobbed up principles, players and crime syndicate associates, which by the chatter to date would more than likely include fiduciaries and accountants playing on their team, people who do not see faces or families or victims, but simply numbers.

Having a Carpenters Book does not necessarily make one a competent Journeyman Carpenter, same as phony certification or skills forms. The same holds for attorneys. Having a bar card to practice law, does not mean you are necessarily any good at the craft. So, in my analogy, you are comparing Journeyman to Scrappers & Helpers, yet schooled. Gotta go, the bells ringing
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Re: AMALGAMATED & the ALL WRITS ACT

HUNTER
yeah but when the UBC resorts to using known proven skells like ollie olsen to stand up for it, then you can see the point of the members Ted. They feel ripped off and are looking for recourse. I mean cmon, a guy who killed the dockbuilders talking about the virtues of the UBC? Hard to believe they think people wont notice. I guess Olsen knows where the bodies are buried.
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Re: AMALGAMATED & the ALL WRITS ACT

Dockbuilder
It would stand to reason that the chatter you speak of would need to be proven? So far the UBC knows the allegations can't be proven so they used to power of the pen and the office of the RO. No further attempts to stop this election, because they know there is nothing to the claim. All your doing is adding fuel to the fire
Ted
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Re: AMALGAMATED & the ALL WRITS ACT

Ted
In reply to this post by Dockbuilder
The newly elected team of Bilello, Lebo & Cavanaugh, Executive Delegates & Council Delegate Body addressed that - mooting your argument.

Read this case as to how that right functions under a multi-employer union such as the NYCDCC.
_______________________________

FORD MOTOR CO. v. HOFFMAN 345 US 330 (1953)...EXCERPT:

COLLECTIVE BARGAINING

The authority of every bargaining representative under the National Labor Relations Act, as amended, is stated in broad terms:


"SEC. 7. Employees shall have the right to self-organization, to form, join, or assist labor organizations, [345 U.S. 330, 337] to bargain collectively through representatives of their own choosing, and to engage in other concerted activities for the purpose of collective bargaining or other mutual aid or protection . . . .

. . . . .

"SEC. 9. (a) Representatives designated or selected for the purposes of collective bargaining by the majority of the employees in a unit appropriate for such purposes, shall be the exclusive representatives of all the employees in such unit for the purposes of collective bargaining in respect to rates of pay, wages, hours of employment, or other conditions of employment: . . . ." (Emphasis supplied.) 61 Stat. 140, 143, 29 U.S.C. (Supp. V) 157, 159 (a).

In the absence of limiting factors, the above purposes, including "mutual aid or protection" and "other conditions of employment," are broad enough to cover terms of seniority.

The National Labor Relations Act, as passed in 1935 and as amended in 1947, exemplifies the faith of Congress in free collective bargaining between employers and their employees when conducted by freely and fairly chosen representatives of appropriate units of employees.

That the authority of bargaining representatives, however, is not absolute is recognized in Steele v. Louisville & N. R. Co., 323 U.S. 192, 198 -199, in connection with comparable provisions of the Railway Labor Act.

Their statutory obligation to represent all members of an appropriate unit requires them to make an honest effort to serve the interests of all of those members, without hostility to any. Id., at 198, 202-204; Tunstall v. Brotherhood of Locomotive Firemen, 323 U.S. 210, 211 ; Brotherhood of Railroad Trainmen v. Howard, 343 U.S. 768 .

Any authority to negotiate derives its principal strength from a delegation to the negotiators of a discretion [345 U.S. 330, 338] to make such concessions and accept such advantages as, in the light of all relevant considerations, they believe will best serve the interests of the parties represented.

A major responsibility of negotiators is to weigh the relative advantages and disadvantages of differing proposals.

A bargaining representative, under the National Labor Relations Act, as amended, often is a labor organization but it is not essential that it be such. The employees represented often are members of the labor organization which represents them at the bargaining table, but it is not essential that they be such.

The bargaining representative, whoever it may be, is responsible to, and owes complete loyalty to, the interests of all whom it represents. In the instant controversy, International represented, with certain exceptions not material here, all employees at the Louisville works, including both the veterans with, and those without, prior employment by Ford, as well as the employees having no military service.

Inevitably differences arise in the manner and degree to which the terms of any negotiated agreement affect individual employees and classes of employees. The mere existence of such differences does not make them invalid.

The complete satisfaction of all who are represented is hardly to be expected. A wide range of reasonableness must be allowed a statutory bargaining representative in serving the unit it represents, subject always to complete good faith and honesty of purpose in the exercise of its discretion.
__________________________________

Current membership of the NYCDCC per 2011 LM's filed are: 21,798 members, with 14,504 active. Dockbuilders and Timberman represent 1,300 or 5.96% of the total membership base. In terms of wages, pension, annuity and welfare funds, both trades have benefitted immensely.

Fiduciaries, Trustees and DC management are bound to protect the majority interests, which in this situation are the rights of the clear majority totaling 20,498 members and their families.

It appears the majority of the issues present concern 10(k) Jurisdicitonal Disputes (Green Book) both within the UBC and via trade raiding by other Unions seeking to obtain and perform your work. Instead of running away like a petulant child, one would think that you would have allowed the new team to be properly seated and that you would utilize the dispute resolution, grievance and arbitration procedures or board processes against the rival unions who are attempting to claim your work.

The Second Interim Report of the Review Officer made it quite clear that your rep's failed miserably at performing their duties as alleged business managers, trustees or fiduciairies. All of them should have been summarily fired, for cause.

Instead of acknowledging the obvious, you seek to repeat it by aligning with the same characters who caused the merger to occur. This is not an issue centering on democracy, rather, it is one centering on the foundation of Fiduciary & Trustee accountability and lack thereof.

The DC team barely were sworn in and immediately addressed concerns and began screening and interviewing potential candidates with specific experience of each sub-trade
and you have to give that time to play out. Running away never solves a thing and it seems out of character for guys who claim they fight for their rights, yet who readily jump into the arms of Painters???
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Re: AMALGAMATED & the ALL WRITS ACT

Dockbuilder
You still havent addressed the question. Your post is titled amalgamated and the all writs act, you have painted a pretty broad brush that this should apply, because of racketeering, I asked what your proof is, not for another tangent that is incoherent and makes zero sense
Ted
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Re: AMALGAMATED & the ALL WRITS ACT

Ted
Courts have long held that the concept of property under the Hobbs Act is not limited to tangible property, but also includes "any valuable right considered as a source or element of wealth." United States v. Tropiano, 418 F.2d 1069, 1075 (2d Cir.1969), cert. denied, 397 U.S. 1021, 90 S.Ct. 1258, 25 L.Ed.2d 530 (1970). Intangible business rights, including the business rights of unions, are considered property.

The geographical jurisdiction of the Dockbuilders & Timberman is the very source of wealth that this hostile takeover attempt by the minority centers on. This country and the union do not center on minority rule, nor does Board, the Appellate Court or the United States Supreme Court.
________________________

Fight or flight, so for all the talk & bluster you got nothing there; as you'd rather run away to the Painters Union for 30-40% less, a 401k and a lousy HMO.

The Cat was let out of the bag on day one of this disloyal and selfish action. The Painters didn't get the Dockies or Timberman to where they are now...the UBC did!

Robert, you have not sold anyone on this, less a small group who attend the rah, rah captive audience seminars hosted by the painters. Is that where you picked up the "pretty broad brush" line? Hardly original now is it. You need better material. The constant denial, obfuscation and the never ending spin you have put on this defection are not turning new converts to your position because you cannot provide them with any concrete or specific information, and you have consistently refused to do so.


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Re: AMALGAMATED & the ALL WRITS ACT

The truth
I have yet to see a stand up union man or anyone other than those seeking personal gain endorse Amalgamated. There are no signed documents other than the letters of support from the building trades and they are just doing what they are told. The real reason they want Amalgamated is obvious. THEY WANT OUR MONEY!

Amalgamated is being run by the wrong people. We can do better and by voting NO we can also weed out the bad apples for good!
Ted
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Re: AMALGAMATED & the ALL WRITS ACT

Ted
Exactly; and, akin to a regulatory taking, wherein a federal agency creates a justification for a taking without just compensation.

The NYCDCC & UBCJA are both non-profit corporations, on paper and for IRS purposes. However, the inherent fiduciary duty and the law require the NLRB to support the will of the majority. The irony in in all this, is that the charge is led by expelled and vetoed members and a lawyer who defends mob interests.

Given the newly imposed NLRB "Quickie Elections Rules", Amalgamated is seeking to delay the Vote into late March or early April because they simply do not have the votes.

Three (3) of one-hundred fifty (150) Employers  (2%) does not a majority make. They represent 60 of 1,300 potential workers. The GCA & DC needs to terminate their contracts with these employers as their aims run contrary to the consent decree. You want to hang with the mob and push their agenda, then suffer the ramifications of that. Decisions have consequences. They made their bed, now lie in it.
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Re: AMALGAMATED & the ALL WRITS ACT

Dockbuilder
you again talk more shit without a clue. The petitioner must have a showing of interest in the appropriate unit as determined by the board. Stop pretending to be a lawyer.
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Re: AMALGAMATED & the ALL WRITS ACT

Curious
As you should stop,pretending to be a dockbulder
Ted
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Re: AMALGAMATED & the ALL WRITS ACT

Ted
In reply to this post by Dockbuilder
http://www.bermangrp.com/portfolio.html

The Union Construction Marketing Kit.

http://www.bermangrp.com/clients.html

Client List
____________________________________

Face it Robert, you are not up to the task.
Ted
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Re: AMALGAMATED & the ALL WRITS ACT

Ted
In reply to this post by Curious
US. v. IBT 732 F. Supp. 1032 (1990), excerpt:

....under the All Writs Act courts may issue injunctions to enjoin other proceedings when the unique character of the litigation requires that relief be determined "flexibly." New York Telephone, supra, 434 U.S. at 173, 98 S.Ct. at 372. A federal court has the power "to issue commands under the All Writs Act as may be necessary or appropriate to effectuate and prevent the frustration of orders it has previously issued in the exercise of jurisdiction otherwise obtained." Id. at 174, 98 S.Ct. at 373. The All Writs Act also grants courts the authority to bind non-parties to an action "when needed to preserve the Court's ability to reach or enforce its decision in a case over which it has proper jurisdiction." Baldwin-United, supra, 770 F.2d at 338; see New York Telephone, supra, 434 U.S. at 172, 98 S.Ct. at 372, cf. Vuitton et Fils
__________________________________________

Whether you like it or not, Local 1456 (now 1556) fails the subordinate entity test and you are bound by the terms & conditions of the Consent Decree. Running to the NLRB, who is itself biased and willing to overlook its own precedents in representation elections in order to further its political agenda relative to their multiple failed EFCA bids will also not save you.
Ted
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Re: AMALGAMATED & the ALL WRITS ACT

Ted
In reply to this post by Ted
ANOTHER REASON TO VOTE NO ON ALL MOU's & PROPOSED CONTRACTS.

Given this is tied squarely to the demise of Forde, Thomassen, Sheil & Greaney and others - and all the RICO predicates & causes of action, McCarron does not have clean hands in this mess and should be thus excluded from conducting a Unilateral Trusteeship wherein he alone appoints all. This arrogance was as much responsible for the defection as was the fraud and abuses in the 2nd Interim Report of the R.O. Time to admit it, address it fairly and move on.

This should be a "one for one" appointed and elected body put in place for 3-years under RO Walsh & Matt Walkers direct control as well as the USAO's office.

UBCJA Dock-Builders & Timberman (one each min., at same ratio as appointee side) should be allowed to sit in on their own Contract Negotiations and all members should vote to ratify same.
Ted
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Re: AMALGAMATED & the ALL WRITS ACT

Ted
In reply to this post by Ted
Have the Council Delegates appointed an Election Committee to review the Votes submitted for Amalgamated and to initiate challenges to ballots where appropriate?

Your right to have election observers are not foreclosed by the use of AAA and mail in ballots.
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Re: AMALGAMATED & the ALL WRITS ACT

Robert Kwiecinski
Ted, this is more proof that you are a total Lebo suck up. Stick the all writs act up your ***.
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