A & K Signal and Utility Company, LLC

National Labor Relations Board - Administrative Judge Opinions

Oct 21, 2015

28-CA-151930 (N.L.R.B. Oct. 21, 2015)

JD(SF)-43-15
Phoenix, AZ
UNITED STATES OF AMERICA
BEFORE THE NATIONAL LABOR RELATIONS BOARD
DIVISION OF JUDGES
A&K SIGNAL AND UTILITY COMPANY, LLC
and Case 28–CA–151930
INTERNATIONAL UNION OF OPERATING
ENGINEERS, LOCAL NO. 428, AFL–CIO
Christopher Doyle,
Alexander J. Gancayco
for the General Counsel.
Muhammad Kayani, pro se
for the Respondent.
DECISION
STATEMENT OF THE CASE
ELEANOR LAWS, Administrative Law Judge. I heard this case in Phoenix, Arizona on
September 29, 2015, at which time counsel for the General Counsel moved for default judgment
based upon A&K Signal and Utility Company, LLC’s (the Respondent’s) failure to file an
answer.
The International Union of Operating Engineers, Local No. 428, AFL–CIO (the Union or
Charging Party) filed the original charge in the above-captioned case on May 11, 2015, and an
amended charge on July 29. The General Counsel issued the complaint on July 31, 2015, and it
was served on the Respondent. The complaint notified the Respondent of its obligation, under
Sections 102.20 and 102.21 of the Board’s Rules and Regulations, to file an answer on or before
August 14. The complaint also put the Respondent on notice that if it did not file an answer, the
Board may find, pursuant to a motion for default judgment, that the complaint allegations are
true.
Having received no answer, on August 17, the General Counsel sent the Respondent a
letter permitting the Respondent to file an answer by August 24. The General Counsel stated
that if an answer was not received by that date, a motion for default judgment would be filed.
JD(SF)-43-15
2
On August 20, the General Counsel issued an order severing cases and withdrawing the
July 31 complaint. That same day, the General Counsel reissued the complaint and served it on
the Respondent. The reissued complaint notified the Respondent of its obligation to file an 5
answer on or before September 3, and affirmatively informed the Respondent that failure to file a
timely answer would result in a motion for default judgment.
Having not received a timely answer, on September 4, the General Counsel sent the
Respondent a letter advising that it must file and serve its answer by September 11, and its 10
failure to do so would result in a motion for default judgment.
On September 14, the General Counsel filed a motion for default judgment with the
administrative law judge.
15
I conducted a prehearing conference via telephone on September 23, 2015, which the
Respondent failed to attend.
The complaint alleges the Respondent violated Section 8(a)(3) and (1) of the National
Labor Relations Act (the Act) by laying off three employees, and that the Respondent violated 20
Section 8(a)(5) and (1) by failing to provide notice and an opportunity to bargain over the
layoffs, and by ceasing to make various trust fund contributions to the Union.
A. Default Judgment Legal Standards and Ruling25
Under Section 102.20 of the Board’s Rules and Regulations, allegations in a complaint
shall be deemed admitted if an answer is not filed within 14 days from service of the complaint,
unless good cause is shown.
30
The Respondent did not file an answer at any time. The Respondent’s owner,
Muhammad Kayani, appeared at the scheduled hearing on September 29. As the record reflects,
he was given the opportunity to establish good cause for failing to file an answer to the
complaint, but he failed to do so. When asked why he failed to answer the complaint allegations,
he stated he did not have the resources to pay the Union. When asked if he had gathered and 35
brought in documents the General Counsel had requested pursuant to a subpoena, Kayani replied
that he had not.
After giving the General Counsel an opportunity to be heard on its motion for default
judgment, Kayani was given another chance to offer a reason for failing to file an answer, but no 40
valid reason was forthcoming.
The parties were provided an opportunity to file briefs concerning whether default
judgment is warranted no later than October 14. Both parties filed briefs. The Respondent did
not provide a reason for failing to file an answer. Kayani explained the circumstances leading to 45
the Respondent ceasing to make contributions to the Union’s trust fund and the reason the
JD(SF)-43-15
3
employee named in the complaint ceased working for the Respondent. Kayani also indicated
that A&K has since gone out of business and is working on meeting its debts.1
Based on the foregoing, I find the Respondent has not established good cause for failing
to file an answer, and I deem the complaint allegations admitted. 5
On the entire record, I make the following
FINDINGS OF FACT
10
I. JURISDICTION
At all material times, Respondent has been a limited liability company with an office and
place of business in Phoenix, Arizona (Respondent’s facility), and has been engaged in the
business as a heavy equipment operating subcontractor. In conducting its operations during the 15
12-month period ending May 11, 2015, Respondent purchased and received at Respondent’s
facility goods valued in excess of $50,000 directly from points outside the State of Arizona. At
all material times, Respondent has been an employer engaged in commerce within the meaning
of Section 2(2), (6), and (7) of the Act. At all material times, the Union has been a labor
organization within the meaning of Section 2(5) of the Act. (Complaint paragraphs 2 and 3.) 20
II. COMPLAINT ALLEGATIONS DEEMED ADMITTED
At all material times, Muhammad Kayani has held the position of Owner and has been a
supervisor of Respondent within the meaning of Section 2(11) of the Act and an agent of 25
Respondent within the meaning of Section 2(13) of the Act. (Complaint paragraph 4.)
The following employees of Respondent (the Unit) constitute a unit appropriate for the
purposes of collective bargaining within the meaning of Section 9(b) of the Act:
30
All A-Frame Boom Truck; Air Compressor Operator; Beltcrete Operator; Boring Bridge
and Texture; Brakeman; Concrete Mixer Operator (skip type); Conductor; Conveyor
Operator; Cross Tineing and Pipe Float; Curing Machine Operator; Dinky Operator
(under 20 tons); Elevator Hoist Operator (Husky & similar); Fireman (all); Forklift &
Ross Carrier Operator; Generator Operator (all); Handler; Highline Cableway Signalman; 35
Hydrographic Mulcher; Hydrographic Seeder; Joint Inserter; Jumbo Finishing Machine;
Kolman Belt Loader Operator; Machine Conveyor Operator; Multiple Power Concrete
Saw Operator; Oiler; Pavement Breaker; Power Grizzly Operator; Power Sweeper;
Pressure Grout Machine Operator (as used in heavy engineering construction); Pump
Operator; Roller Operator (except as otherwise classified); Self-Propelled Chip Spreading 40
Machine; Skiploader (3 c.y. & less); Slurry Seal Machine Operator (moto-paver driver);
Small Self-Propelled Compactor (with blade)-backfill, ditch-operation; Straw Blower;
Tripper Operator; Tugger Operator; Welding Machine Operator; Wheel-Type Tractor
Operator (Ford-Ferguson type with attachments, etc.); Winch Truck; Aggregate Plant

1 I do not have reason to doubt Kayani in this regard. If, in fact, the Respondent has gone out of
business, the best course of action would seem to be for the parties to work toward settling the case.
JD(SF)-43-15
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Operator (including crushing, screening and sand plants, etc.); Asphalt Laydown
Machine Operator; Asphalt Plant Mixer Operator; Backhoe Operator (Rubber Tire or
Track less than 1 c.y.); Bee Gee Operator; Boring Machine Operator; Concrete Pump
Operator; Concrete Mechanical Tamping Spreading or Finishing Machine Operator
(including Clary, Johnson or similar types); Concrete Batch Plant operator (all types and 5
sizes); Concrete Mixer Operator (paving type and mobile mixers); Crane Operator
(crawler and pneumatic less than 15 tons capacity MRC); Drilling Machine Operator
(including water wells); Elevating Grader Operator (all types and sizes, except as
otherwise classified); Electrician Ground Man (assisting lineman electrician); Field
Equipment Serviceman; Locomotive Engineer (including Dinky 20 tons weight and 10
over); Moto-Paver (and similar type equipment) Operator; Motor Grader Operator (any
type power blade-rough); Oiler Driver; Operating Engineer Rigger; Pneumatic Tired
Scraper Operator (all sizes and types); Power Jumbo Form Setter Operator; Road Oil
Mixing Machine Operator; Roller Operator (on all types asphalt pavement); Screed
Operator; Self-Propelled Compactor (with blade) (815, 825 or equivalent – grade 15
operation); Skip Loader Operator (all types with a rated capacity over 3 but less than 6
c.y.); Slip Form Operator (power driven lifting device for concrete forms); Soil Cement
Road Mixing Machine Operator (single pass type); Stationary Pipe-Wrapping & Cleaning
Machine Operator; Surface Heater and Planer Operator; Tractor Operator (dozer, pusher-
all); Traveling Pipe-Wrapping Machine Operator; Trenching Machine Operator; Tugger 20
Operator (two or more drums); Auto Grade Machine Operator (CMI and similar
equipment); Barge Operator; Boring Machine Operator (including Mole, Badger,
Horizontal Boring or Directional Boring Operators); Concrete Pump Operator (truck
mounted, with boom attached); Crane Operator (crawler or pneumatic over 15 tons & less
than 100 ton capacity MRC); Crawler-Type Tractor Operator (with boom attachment and 25
slope bar); Derrick Operator; Gradall Operator; Grade Checker (excluding Civil
Engineer); Heavy Duty Mechanic/Welder; Helicopter Hoist Operator or Pilot; Highline
Cableway Operator; Mass Excavator Operator (150 Bucyrus, Erie and similar type);
Mechanical Hoist Operator (two or more drums); Motor Grade Operator (any type power
blade-finish); Mucking Machine Operator; Overhead Crane Operator; Piledriver Engineer 30
(portable, stationary or skid); Power Driven Ditch Lining or Ditch Trimming Machine
Operator; Remote Control Earth Moving Machine Operator; Rotomill and Milling
Machine Operator (asphalt or concrete planning); Skip Loader Operator (all types with
rated capacity 6 c.y. but less than 10 c.y.); Slip Form Paving Machine Operator
(including Gunnert, Zimmerman and similar types); Tech Engineer (Survey Instrument 35
Man); Tower Crane (or similar type); Universal Equipment Operator (shovel, backhoe,
dragline, clamshell, etc. up to 10 c.y.); Crane Operator (pneumatic or crawler – 100 ton
hoisting capacity and over MRC rating); Operating Engineer Electrician (including
lineman, tower erector, cable splicer, etc.); Skip Loader Operator (all types with rated
capacity of 10 c.y. or more); Survey Party Chief; Universal Equipment Operator (shovel, 40
backhoe, dragline, clamshell, etc., 10 c.y. and over); Electrical Helper Field Equipment;
Service Helper Heavy Duty Repair; and Helper Heavy Duty Welder Helper employed by
members of the Arizona Chapter of The Associated General Contractors of America, Inc.
and of employers who have authorized the Arizona Chapter of The Associated General
Contractors of America, Inc. to bargain on their behalf, including Respondent, but 45
excluding executives, superintendents, assistant superintendents, civil engineers and their
JD(SF)-43-15
5
helpers, master mechanics, all supervisory employees such as timekeepers, messengers,
guards and office workers.
(Complaint paragraph 5(a).)
5
The Arizona Chapter of The Associated General Contractors of America, Inc. (Arizona
Chapter) is composed of employers engaged in the building and construction industry and exists
for the purpose, inter alia, of representing its employer members in negotiating and administering
collective-bargaining agreements. About September 26, 2013, the Union entered into a 10
collective-bargaining agreement (the CBA) with the Arizona Chapter, effective from July 29,
2013 through May 31, 2016, recognizing the Union as the exclusive collective-bargaining
representative of the unit without regard to whether the Union’s majority status had ever been
established under Section 9(a) of the Act. Since about November 3, 2014, and at all material
times, Respondent has been a member of the Arizona Chapter and thereby agreed to recognize 15
the Union and be bound by the agreement described above in paragraph 5(c). From July 29,
2013 to May 31, 2016, based on Section 9(a) of the Act, the Union has been the exclusive
collective-bargaining representative of the unit. (Complaint paragraph 5(b)–(e).)
On about April 30, 2015, Respondent laid off its employees Jarret Simpson, Tony Hood 20
and Juan Lopez because these employees joined and assisted the Union and to discourage
employees from engaging in these activities, in violation of Section 8(a)(3) and (1) of the Act.
The layoffs, which are mandatory subjects of collective bargaining, occurred without prior notice
to the Union and without affording the Union an opportunity to bargain with Respondent with
respect to its conduct and the effects of this conduct, in violation of Section 8(a)(5) and (1) of the 25
Act. (Complaint paragraphs 6, 7(b)–(c), 8, 9.)
Since about March 2015, Respondent failed to continue in effect all the terms and
condition of CBA by ceasing to make contributions to the Union’s Health and Welfare Trust
Fund, the Union’s Pension Trust Fund, Arizona Operating Engineers Joint Apprenticeship and 30
Working Assessment Fund, and the Vacation-Savings Trust Fund, without the Union’s consent.
The trust fund contributions are a mandatory subject of bargaining. By its actions, the
Respondent has been failing and refusing to bargain collectively and in good faith with the
exclusive collective-bargaining representative of its employees within the meaning of Section
8(d) of the Act in violation of Section 8(a)(1) and (5) of the Act. (Complaint paragraphs 7(a), 35
(b), (d), 9.)
CONCLUSIONS OF LAW
The Respondent is an employer engaged in commerce and in a business affecting 40
commerce within the meaning of Section 2(6) and (7) of the Act and the Union is a labor
organization within the meaning of Section 2(5) of the Act. The unfair labor practices of
Respondent described above affect commerce within the meaning of Section 2(6) and (7) of the
Act.
45
JD(SF)-43-15
6
REMEDY
Having found that the Respondent has engaged in certain unfair labor practices, I shall
order it to cease and desist therefrom and to take certain affirmative action designed to effectuate
the policies of the Act.5
Having found that the Respondent violated Section 8(a)(3) and (1) by laying off
employees Jarret Simpson, Tony Hood, and Juan Lopez, I shall order the Respondent to offer
them full reinstatement to their former jobs or, if those jobs no longer exist, to substantially
equivalent positions, without prejudice to their seniority or any other rights or privileges 10
previously enjoyed, and to make them whole for any loss of earnings and other benefits suffered
as a result of the discrimination against them.
Backpay shall be computed in accordance with F. W. Woolworth Co., 90 NLRB 289
(1950), with interest at the rate prescribed in New Horizons, 283 NLRB 1173 (1987), 15
compounded daily as prescribed in Kentucky River Medical Center, 356 NLRB No. 8 (2010). I
shall also order the Respondent to compensate Simpson, Hood, and Lopez for any adverse tax
consequences of receiving lump-sum backpay awards and to file a report with the Social Security
Administration allocating the backpay to the appropriate calendar quarters. Don Chavas, LLC
d/b/a Tortillas Don Chavas, 361 NLRB No. 10 (2014). The Respondent shall be required to 20
remove from its files any and all references to the unlawful layoffs of Simpson, Hood, and
Lopez, and to notify them in writing that this has been done and that the discharges will not be
used against them in any way.
The General Counsel seeks, as part of the remedy, that Simpson, Hood, and Lopez be 25
reimbursed for search-for-work and work-related expenses, regardless of whether interim
earnings are in excess of these expenses. The General Counsel is seeking a change in Board law,
and the Board has declined to grant this remedy absent a full briefing by the affected parties. See
East Market Restaurant, Inc., 362 NLRB No. 143, slip op. at 5 fn. 5 (2015). Accordingly, I
decline to include the requested remedy in my recommended order.30
Having failed to make all contributions the Respondent was required to make to benefit
funds, including the Union’s Health and Welfare Trust Fund, the Union’s Pension Trust Fund,
the Arizona Operating Engineers Joint Apprenticeship and Working Assessment Fund, and the
Vacation-Savings Trust Fund, pursuant to the Collective-Bargaining Agreement since about 35
March 2015, as required by the collective-bargaining agreement, the Respondent shall be ordered
to make whole its unit employees by making all such delinquent fund contributions on behalf of
unit employees that have not been made since that date, including any additional amounts due
the funds in accordance with Merryweather Optical Co., 240 NLRB 1213, 1216 fn. 7 (1979).
The Respondent will be ordered to reimburse unit employees for any expenses ensuing from its 40
failure to make the required fund contributions, as set forth in Kraft Plumbing & Heating, 252
NLRB 891, 891 fn. 2 (1980), enfd. mem. 661 F.2d 940 (9th Cir. 1981), computed in the manner
set forth in Ogle Protection Service, 183 NLRB 682 (1970), enfd. 444 F.2d 502 (6th
Cir. 1971), with interest at the rate prescribed in New Horizons, supra, compounded daily as
prescribed in Kentucky River Medical Center, supra.45
JD(SF)-43-15
7
If employees have made personal contributions to a fund that were accepted by the fund
in lieu of the employer’s delinquent contributions, the Respondent will reimburse the employee,
but the amount of such reimbursement will constitute a setoff to the amount that the Respondent
otherwise owes the fund. Distler Construction Co., 363 NLRB No. 18, slip op. at 4 (2015).
5
Having failed to bargain with the Union over the layoffs or the benefit fund contributions,
the Respondent will be ordered to, upon request, bargain in good faith with the Union as the
exclusive collective-bargaining representative of its employees in the unit.
10
On these findings of fact and conclusions of law and on the entire record, I issue the
following recommended2
ORDER15
The Respondent, A&K Signal and Utility Company, LLC, Phoenix, Arizona, its officers,
agents, successors, and assigns, shall
1. Cease and desist from20
(a) Laying off or otherwise discriminating against employees for supporting the Union or
any other labor organization.
(b) Failing to make contractual contributions to the Union’s Health and Welfare Trust 25
Fund, the Union’s Pension Trust Fund, the Arizona Operating Engineers Joint Apprenticeship
and Working Assessment Fund, and the Vacation-Savings Trust Fund, pursuant to the
Collective-Bargaining Agreement on behalf of unit employees.
(c) Failing and refusing to bargain in good faith with the Union as the exclusive, 30
collective-bargaining representative of the unit employees.
(d) In any like or related manner interfering with, restraining, or coercing employees in
the exercise of the rights guaranteed them by Section 7 of the Act.
35
2. Take the following affirmative action necessary to effectuate the policies of the Act.
(a) On request, bargain with the Union as the exclusive representative of the employees
in the unit concerning terms and conditions of employment and, if an understanding is reached,
embody the understanding in a signed agreement.40
(b) Within 14 days from the date of the Board’s Order, offer Jarret Simpson, Tony Hood,
and Juan Lopez full reinstatement to their former jobs or, if those job no longer exists, to

2 If no exceptions are filed as provided by Sec. 102.46 of the Board’s Rules and Regulations, the
findings, conclusions, and recommended Order shall, as provided in Sec. 102.48 of the Rules, be adopted
by the Board and all objections to them shall be deemed waived for all purposes.
JD(SF)-43-15
8
substantially equivalent positions, without prejudice to their seniority or any other rights or
privileges previously enjoyed.
(c) Make Jarret Simpson, Tony Hood, and Juan Lopez whole for any loss of earnings and
other benefits suffered as a result of the discrimination against them, in the manner set forth in 5
the remedy section of the decision.
(d) Within 14 days from the date of the Board’s Order, remove from its files any
reference to the unlawful discharges, and within 3 days thereafter notify the employees in writing 10
that this has been done and that the discharges will not be used against them in any way.
(e) Preserve and, within 14 days of a request, or such additional time as the Regional
Director may allow for good cause shown, provide at a reasonable place designated by the Board
or its agents, all payroll records, social security payment records, timecards, personnel records 15
and reports, and all other records, including an electronic copy of such records if stored in
electronic form, necessary to analyze the amount of backpay due under the terms of this Order.
(f) Make all delinquent payments to the International Union of Operating Engineers,
Local No. 428, AFL–CIO’s Pension Trust Fund, Arizona Operating Engineers Joint 20
Apprenticeship and Working Assessment Fund, and the Vacation-Savings Trust Fund that have
not been made since about March 2015, on behalf of unit employees, and make the unit
employees whole for any expenses ensuing from their failure to make such payments, including
any additional amounts due to the funds on behalf of unit employees, with interest, in the manner
set forth in the remedy section of this decision.25
(g) Within 14 days after service by the Region, post at its facility in Phoenix, Arizona,
copies of the attached notice marked “Appendix.”3 Copies of the notice, on forms provided by
the Regional Director for Region 28, after being signed by the Respondent’s authorized
representative, shall be posted by the Respondent and maintained for 60 consecutive days in 30
conspicuous places including all places where notices to employees are customarily posted. In
addition to physical posting of paper notices, the notices shall be distributed electronically, such
as by email, posting on an intranet or an internet site, and/or other electronic means, if the
Respondent customarily communicates with its employees by such means. Reasonable steps
shall be taken by the Respondent to ensure that the notices are not altered, defaced, or covered by 35
any other material. In the event that, during the pendency of these proceedings, the Respondent
has gone out of business or closed the facility involved in these proceedings, the Respondent
shall duplicate and mail, at its own expense, a copy of the notice to all current employees and
former employees employed by the Respondent at any time since March 2015.
40

3 If this Order is enforced by a judgment of a United States court of appeals, the words in the notice
reading “Posted by Order of the National Labor Relations Board” shall read “Posted Pursuant to a
Judgment of the United States Court of Appeals Enforcing an Order of the National Labor Relations
Board.”
(h) Within 21 days after service by the Region, file with the Regional Director a sworn
certification of a responsible official on a form provided by the Region attesting to the steps that
the Respondent has taken to comply.
5
Dated, Washington, D.C. October 21, 2015

10

JD(SF)
9
____________________
Eleanor Laws
Administrative Law Judge
-43-15
APPENDIX
NOTICE TO EMPLOYEES
Posted by Order of the
National Labor Relations Board
An Agency of the United States Government
The National Labor Relations Board has found that we violated Federal labor law and has
ordered us to post and obey this notice.
FEDERAL LAW GIVES YOU THE RIGHT TO
Form, join, or assist a union
Choose representatives to bargain with us on your behalf
Act together with other employees for your benefit and protection
Choose not to engage in any of these protected activities.
WE WILL NOT do anything to prevent you from exercising these rights.
WE WILL NOT upon request, fail and refuse to bargain in good faith with the International
Union of Operating Engineers, Local No. 428, AFL–CIO (the Union), as the exclusive,
collective-bargaining representative of our employees in the unit.
WE WILL NOT unilaterally modify the terms of the Collective-Bargaining Agreement without
the Union’s consent.
WE WILL NOT fail to make contributions that we are required to make to benefit funds,
including the Union’s Health and Welfare Trust Fund, the Union’s Pension Trust Fund, the
Arizona Operating Engineers Joint Apprenticeship and Working Assessment Fund, and the
Vacation-Savings Trust Fund, pursuant to the Collective-Bargaining Agreement.
WE WILL NOT lay you off because of your union and other concerted activities.
WE WILL NOT in any like or related manner interfere with your rights under Section 7 of the
Act.
WE WILL make all contributions we were required to make to benefit funds, including the
Union’s Health and Welfare Trust Fund, the Union’s Pension Trust Fund, the Arizona Operating
Engineers Joint Apprenticeship and Working Assessment Fund, and the Vacation-Savings Trust
Fund, pursuant to the Collective-Bargaining Agreement.
WE WILL upon request, bargain in good faith with the Union as the exclusive, collective-
bargaining representative of employees in the unit.
WE WILL immediately offer Jarret Simpson, Tony Hood, and Juan Lopez reinstatement to their
former positions, and if those jobs no longer exist, to substantially equivalent positions, without
any loss to their seniority rights or any other privileges.
WE WILL immediately make Jarret Simpson, Tony Hood, and Juan Lopez whole with interest,
compounded on a daily basis, for the bonuses, dividends, wages and benefits they lost because
we laid them off.
WE WILL within 14 days, remove from our files, any and all records of the layoffs of Jarret
Simpson, Tony Hood, and Juan Lopez and WE WILL within 3 days thereafter, notify them in
writing that we have taken these actions, and that the materials removed will not be used as a
basis for any future personnel action against them or referred to in response to any inquiry from
any employer, employment agency, unemployment insurance office, or reference seeker, or
otherwise used against them.
(Employer)
Dated By
(Representative) (Title)
The National Labor Relations Board is an independent Federal agency created in 1935 to enforce the National Labor
Relations Act. It conducts secret-ballot elections to determine whether employees want union representation and it
investigates and remedies unfair labor practices by employers and unions. To find out more about your rights under
the Act and how to file a charge or election petition, you may speak confidentially to any agent with the Board’s
Regional Office set forth below. You may also obtain information from the Board’s website: www.nlrb.gov.
2600 North Central Avenue, Suite 1800, Phoenix, AZ 85004-3099
(602) 640-2160, Hours: 8:15 a.m. to 4:45 p.m.
The Administrative Law Judge’s decision can be found at www.nlrb.gov/case/28-CA-151930 or by using the QR code
below. Alternatively, you can obtain a copy of the decision from the Executive Secretary, National Labor Relations Board,
1015 Half Street, S.E., Washington, D.C. 20570, or by calling (202) 273-1940.
THIS IS AN OFFICIAL NOTICE AND MUST NOT BE DEFACED BY ANYONE
THIS NOTICE MUST REMAIN POSTED FOR 60 CONSECUTIVE DAYS FROM THE DATE OF POSTING AND MUST NOT BE
ALTERED, DEFACED, OR COVERED BY ANY OTHER MATERIAL. ANY QUESTIONS CONCERNING THIS NOTICE OR
COMPLIANCE WITH ITS PROVISIONS MAY BE DIRECTED TO THE ABOVE REGIONAL OFFICE’S
COMPLIANCE OFFICER, (602) 640-2146.