Franklin Parish Broadcasting, Inc.

National Labor Relations Board - Board Decisions

May 11, 1977

229 N.L.R.B. 556 (N.L.R.B. 1977)

DECISIONS OF NATIONAL LABOR RELATIONS BOARD
Franklin Parish Broadcasting, Inc. and Local Union
446, International Brotherhood of Electrical Work-
ers, AFL-CIO-CLC. Cases 15-CA-5951 and 15-
CA-5965
May 11, 1977
DECISION AND ORDER
BY MEMBERS JENKINS, PENELLO, AND MURPHY
On November 29, 1976, Administrative Law Judge
Karl H. Buschmann issued the attached Decision in
this proceeding. Thereafter, both the Respondent
and General Counsel filed exceptions and supporting
briefs.
Pursuant to the provisions of Section 3(b) of the
National Labor Relations Act, as amended, the
National Labor Relations Board has delegated its
authority in this proceeding to a three-member panel.
The Board has considered the record and the
attached Decision in light of the exceptions and
briefs and has decided to affirm the rulings, find-
ings,' and conclusions2 of the Administrative Law
Judge and to adopt his recommended Order, as
modified herein.
ORDER
Pursuant to Section 10(c) of the National Labor
Relations Act, as amended, the National Labor
Relations Board adopts as its Order the recommend-
ed Order of the Administrative Law Judge, as
modified below, and hereby orders that the Respon-
dent, Franklin Parish Broadcasting, Inc., Winnsboro,
Louisiana, its officers, agents, successors, and as-
signs, shall take the action set forth in the said
recommended Order, as so modified:
1. Substitute the following for paragraph 2(a):
"(a) Offer Davis L. Roberts immediate and full
reinstatement to his former position or, if such
position no longer exists, to a substantially equiva-
lent position, and make him whole for any loss of pay
or other benefits that he may have suffered by reason
of the Respondent's discrimination against him with
interest at 6 percent per annum."
2. Substitute the attached notice for that of the
Administrative Law Judge.
I The Order of the Administrative Law Judge is modified to accord more
fully with his various findings.
2 The Administrative Law Judge found, and we agree, that Respondent
not only violated Sec. 8(a)(3) but also violated Sec. 8(aX4) of the Act in its
discharge of Davis Roberts. We find it significant that Respondent's attitude
toward Roberts became markedly negative after Roberts testified in the
previous unfair labor practice proceeding against Respondent before this
Board.
229 NLRB No. 72
APPENDIX
NOTICE To EMPLOYEES
POSTED BY ORDER OF THE
NATIONAL LABOR RELATIONS BOARD
An Agency of the United States Government
We hereby notify our employees that the National
Labor Relations Board has found that we violated
the law and has ordered us to post this notice.
The Act gives all our employees these rights:
To organize themselves
To form, join, or help unions
To bargain as a group through represen-
tatives they choose
To act together for collective bargaining
or other mutual aid or protection
To refuse to do any or all of these things.
WE WILL NOT do anything which interferes with
these rights.
WE WILL offer Davis L. Roberts his job or, if
his job no longer exists, a substantially equivalent
job.
WE WILL restore his seniority and pay him the
backpay and all other benefits he lost because we
discharged him.
WE WILL NOT unlawfully discharge any of our
employees because of their union affection or
because they engage in union activities, or
because they gave testimony in a Board proceed-
ing.
WE WILL NOT unlawfully and unilaterally
change conditions of employment including pay
raises or working hours of our employees without
notifying and bargaining with the Union and WE
WILL reimburse James Burns who lost wages by
reason of the schedule change.
WE WILL NOT unlawfully and unilaterally
withhold planned bonuses because of our em-
ployees' union activities and WE WILL reimburse
full-time employees $100 each and part-time
employees $50 each for the 1975 Christmas bonus
we withheld from them.
WE WILL, upon request, recognize and bargain
with Local Union 446, International Brotherhood
of Electrical Workers, AFL-CIO-CLC, as the
exclusive collective-bargaining representative in a
unit of all employees employed by Franklin
Parish Broadcasting, Inc., at its Winnsboro,
Louisiana, radio station KMAR, AM and FM,
excluding the maid, guards, and supervisors as
defined in the Act.
556
FRANKLIN PARISH BROADCASTING, INC.
All our employees are free to remain, or refrain
from becoming or remaining, members of a labor
organization.
FRANKLIN PARISH
BROADCASTING, INC.
DECISION
KARL H. BUsCHMANN, Administrative Law Judge: This
case arises upon a complaint, issued February 13, 1976, by
the National Labor Relations Board alleging that Franklin
Parish Broadcasting, Inc., had violated Section 8(a)(1), (3),
(4), and (5) of the National Labor Relations Act. In its
answer, filed February 26, 1976, Respondent admitted
several allegations, but it denied all of the substantive
allegations that it had committed any unfair labor
practices.
The hearing on these charges was held in Monroe,
Louisiana, on April 27 and 28, 1976. The General Counsel
and Respondent were represented by counsel and afforded
full opportunity to adduce evidence, to call, examine, and
cross-examine witnesses, and to file briefs. Upon the entire
record in this case, including briefs of counsel, and from
my observation of the witnesses, I make the following
findings of fact and conclusions of law.
Background
Franklin Parish Broadcasting, Inc., was a respondent in
a prior Board proceeding. On February 27, 1976, the Board
affirmed the decision ' of Administrative Law Judge Lowell
Goerlich, finding that Franklin Parish Broadcasting, Inc.,
had violated Section 8(a)(1) and (3) of the Act in
connection with the original union campaign.
The findings and conclusions in that decision are,
according to the General Counsel, res judicata and
absolutely binding on the trier of facts in the instant case.
Respondent, on the other hand, argues that since the
decision by the Board has not been tested in any U.S. court
of appeals, and since Respondent has advised the Board
that it does not regard the order as valid and that it has
refused to comply with its provisions, the finding of a
violation in the prior proceeding "does not change or shift
that burden of proof, nor does it create any presumptions
or inferences."
I have little difficulty in recognizing that the prior
decision does not dispense with the General Counsel's
usual burden of proof of establishing a primafacie case, but
it is axiomatic that the findings in the prior decision, if
relevant to the present case, are binding on the Administra-
tive Law Judge as the agent of the Board, irrespective of
judicial review by a court of appeals. Insurance Agents'
International Union, AFL-CIO (The Prudential Insurance
Company of America), 119 NLRB 768 (1957); Iowa Beef
Packers, Inc., 144 NLRB 615 (1963).
Jurisdictional findings, including the status of Respon-
dent as an employer within the meaning of the Act, have
already been established. Respondent, Franklin Parish
Broadcasting, Inc., was and presently is an employer
engaged in commerce within the meaning of Section 2(6)
and (7) of the Act over which the Board has jurisdiction.
Respondent is a Louisiana corporation engaged in the
operation of a radio station KMAR, AM and FM, in
Winnsboro, Louisiana. President and owner of the radio
station, Edward O. Fritts, acquired the station in early
1973. He also owns and operates one or two other radio
stations.
The Union, Local Union 446, International Brotherhood
of Electrical Workers, AFL-CIO-CLC, is and at all times
has been a labor organization within the meaning of
Section 2(5) of the Act.
According to the prior decision, the Union's campaign at
KMAR began in December 1974. Respondent's employees
Alpe and Roberts had contacted the Union and had
solicited signatures on union cards. Primarily as a result of
the efforts of these two employees, the Union was able to
file a petition for an election on December 9, 1974. A
representation hearing was held on December 30, 1974,
and January 3, 1975, following which the Regional
Director issued a Decision and Direction of Election in
Case 15-RC-5606. He found that employees Roberts and
Alpe, who had testified at the hearing, were unit employees
within the meaning of the Act. After the Board granted
Respondent's request for review of the Regional Director's
decision, the election was postponed indefinitely, and on
March 25, 1975, the petition was withdrawn.
The Board's prior decision further shows that following
the Union's attempt to gain a foothold in Respondent's
radio station, Respondent engaged in several acts and
practices which violated the National Labor Relations Act.
In addition to the usual remedies, the Board also issued a
bargaining order requiring Respondent to bargain collec-
tively as of December 10, 1974.
With respect to Roberts, the Charging Party in the
present proceeding, the Board found:
Conversations with Roberts: Fritts engaged in conver-
sations with Roberts on about four or five occasions
between February 4 and 14, 1975. Among other things,
Fritts told Roberts that the Company was against the
Union and that "he didn't believe in unions. They were
troublemakers, and he was not going to sign a
contract." Fritts further said that he had recently
purchased a new station and was looking for a station
manager; that when he replaced a manager "he always
looked to key personnel, and [Roberts] was certainly a
key employee." Fritts added that if Roberts voted for
the Union he would not have a future at KMAR. He
asked Roberts to vote the Union "down" and give him
"another chance." Fritts also inquired whether Roberts
was "against the Union" and said he would appreciate
it if Roberts "talked to the other boys and tried to
convince them to vote 'no.' " Fritts also commented
that "he wasn't under law to sign a contract," and that
he "liked to work with his employees on a warm
friendly basis instead of cold hard facts," as it would be
if the Union came into the station.
I Reported at 222 NLRB 1133.
557
DECISIONS OF NATIONAL LABOR RELATIONS BOARD
Further finding that Roberts was a credible witness, the
decision concluded that Respondent had violated the Act
with regard to employee Roberts as follows:
(h) Fritts' representation to Roberts that he was not
going to sign a contract; Fritts' implied promise to
Roberts, that, if the Union were voted "down," he
would be considered for a position as a station
manager; Fritts' threat to Roberts that if he voted for
the Union he would not have a future at KMAR;
Fritts' interrogations as to whether Roberts was against
the Union; Fritts' solicitation of Roberts to "[talk] to
the other boys and [try to convince them to vote
'no' "; and his suggestion that Roberts get on the
"bandwagon and help vote the Union out."
Issues
The issues in the present proceeding are directly related
to the prior Board decision (222 NLRB 1133), because it is
now alleged that (1) Roberts was discharged in violation of
Section 8(a)(1), (3), and (4) of the Act, and (2) Respondent
unilaterally implemented the following: a wage increase of
several unit employees, a reduction in hours of a unit
employee, and a policy denying employees annually
scheduled Christmas bonuses in violation of the require-
ment to bargain with the Union.
Findings
The discharge of employee Roberts: The record shows that
Roberts was hired by station KMAR as an announcer-
salesman in October 1973. In this capacity he ordinarily
worked from 6 a.m. to 10 a.m. as an announcer on the air,
and from 10 a.m. to about 3 or 4 p.m. as a salesman
soliciting advertising for the station. On December 31,
1975, Roberts was fired. The reason for the discharge,
given orally and by letter, was Roberts' failure as a sales
representative for the radio station. The record evidence,
however, shows that it was not lack of sales, but Roberts'
union activity, which prompted his discharge.
The first time that Roberts heard any criticism about his
sales' performance was by letter of August 4, 1974, 4 weeks
after the prior unfair labor practice case had closed. In this
letter, Fritts, president and owner of KMAR, complained
about Roberts' failure to increase his sales in the first 7-
month period in 1975, as compared to the sales perfor-
mance in the same 7-month period in 1974. The letter
explained that the sales effort by Don Murray, the station
manager and only other salesman, was responsible for
increased sales by the station as a whole, and it emphasized
that Roberts' prime function at the station was that of a
salesman.
In September 1975, Fritts had a meeting with Roberts
during which the former suggested a new working schedule
in order to assist Roberts in improving his sales picture.
Under the suggested schedule Roberts would have spent 2
hours less time in performing his usual announcing
functions and thereby add this time to his sales efforts.
However, Roberts was not receptive to the idea, and the
suggestion was abandoned. During this time, however,
Roberts became aware that three other unit employees
received raises from 25 to 30 cents an hour while he
received no raise at all.
Shortly thereafter, Roberts received another letter, dated
October 2, 1975, in which Fritts reprimanded Roberts,
accusing him of selling advertising to an uncollectible
account. In this regard, the record shows that Roberts had
solicited advertising from Winnsboro Meat Company in
the amount of $717. This amount was a relatively large sale
for which Roberts accepted the firm's credit. Unfortunate-
ly, the company turned out to be a "fly-by-night" operation
which could not be located after the advertisement had
been "aired" by the station. Roberts was blamed because
he had not adequately checked the firm's credit. Roberts
had merely called a number that was given to him by the
meat company which identified itself as the Better Business
Bureau and which vouched for the credit of the meat
company.
Fritts' reaction to this episode was strong, suggesting in
his letter:
In my twelve years of radio station ownership and
management, I have never had a salesman so flagrantly
ignore such an important business practice [proper
evaluation of the accounts]. I am not sure as to whether
you can be held personally liable for this loss, but I am
checking into this possibility.
The same letter also criticized Roberts' continued "sagging
sales effort." By letter of October 6, 1976, Roberts replied
to some of the criticism leveled against him, and in a
somewhat hostile fashion suggested that his union activi-
ties-not his sales efforts-were the real cause for Respon-
dent's motives.
Again, by letter of December 24, 1975, Fritts criticized
Roberts' lack of sales and expressed hope that sales for
November and December would improve. On December
27, 1975, Station Manager Murray met with Roberts and
discussed management's concern over Roberts' failure to
improve his sales efforts.
Finally, on December 31, 1975, Roberts was summoned
to meet with Fritts in Murray's office. During the meeting
Fritts informed Roberts that his employment was terminat-
ed because Roberts had been unable to generate the
expected amount of sales. With Respondent's efforts
providing Roberts with assistance and training, Fritts was
of the opinion that the expected sales should have
amounted to $30,000 rather than the $18,559.95 which
Roberts produced and which Fritts considered an insignifi-
cant improvement over the sales figure of $18,087.80 in
1974.
My review of the record as a whole and considering the
relevant portions dealing directly with Respondent's
conduct vis-a-vis Roberts in the Board's prior decision, 222
NLRB 1133, I conclude that Davis Roberts was discharged
because of his union activities.
During most of his tenure from October 1973 to July
1975, Roberts had not received any criticism. Not until
after the prior proceeding had closed in which Roberts
testified against his employer did the attitude of Respon-
dent change, particularly after Roberts failed to comply
with the request of his employer to talk "to the other boys"
to try "to convince them to vote" against the Union.
558
FRANKLIN PARISH BROADCASTING, INC.
Furthermore, Respondent's criticism over the $717 as an
uncollectible account was exaggerated. This was not the
first bad debt which the station had incurred. Yet no letter
of reprimands were ever written to the culpable employees.
Indeed, Roberts was not solely to blame for the station's
loss on this account, since Roberts had fully informed
Station Manager Murray of the new account and his
efforts in checking its credit. As a result Murray himself
became involved. For example, at one point he met with
the people of the meat company and another time Murray
attempted to contact a credit reference for this account.
Clearly, Murray, as manager and with his own participa-
tion in the matter, was as much to blame as Roberts. Yet
Fritts used this episode as a convenient tool to downgrade
Roberts.
Also Respondent's insistence that Roberts was a failure
as a salesman appears incongruent with Fritts' own
expectations for the station. To be sure, Roberts' sales in
1975 did not increase significantly from his sales in 1974.
However, the record shows that Fritts testified in the prior
proceeding to the effect that he did not expect overall sales
in 1975 to be as high as in 1974. Accordingly, even the
modest increase in sales which Roberts was able to show
were beyond Fritts' own expectations which he expressed
in June 1975.
Particularly unconvincing in Respondent's line of argu-
ment is Fritts' offer to Roberts of a more responsible
position in his organization. On April 21, 1975, Fritts
offered Roberts the position as the station manager of a
newly acquired radio station in Helena, Arkansas. It is
highly unlikely that Fritts' could have been sincere about
his proposal offering Roberts a more demanding position
in April 1975 when in August of the same year Roberts, in
the opinion of his superiors, could not even perform his job
as a salesman. In any case, Roberts declined to accept the
position for two realistic reasons. First, he feared that such
a promotion would have taken him out of the bargaining
unit so that he would lose the protection afforded by the
Act. Roberts' apprehension in this regard was justified,
since a similar promotion scheme was used by Respondent
in connection with the discharge of another employee, as
fully detailed in the prior case. Roberts' other reason was
that he did not feel sufficiently confident to accept the new
challenge.
Finally, in an effort to buttress its justification for
terminating Roberts' employment, Respondent relied upon
a test by Marketing Survey and Research Corp. the results
of which show that Roberts' aptitude as a salesman was
marginal. In addition, Respondent has attempted to
compare the sales performance of Station Manager Murray
with that of Roberts. With respect to the test results, I have
serious doubt that they were a significant factor in
Respondent's determination to discharge Roberts because
a similar test shows that Murray had serious handicaps as a
manager. Murray's position as station manager involved
essentially two functions, management and salesmanship.
While the test results are favorable to Murray as salesman,
they are very critical of his managerial abilities. Similarly
with regard to Roberts, the test results-although not
specifically directed towards his announcing ability-are
only critical of certain personal traits involved in salesman-
ship. An evenhanded policy by management based on
these test results would certainly not single out Roberts as
the only target. Indeed, the test results show that, under
skillful management, his sales performance could become
"quite good" which suggests that Murray, the manager, is
partially responsible for the alleged sales deficiencies.
Fritts' adverse action directed solely against Roberts
therefore suggests that these tests were used for pretextual
purposes. Similarly, Respondent's efforts to compare
Murray and Roberts as salesmen are inconclusive and
unpersuasive. Even if it is assumed, as Respondent argues,
that Murray's record in sales far surpasses that of Roberts,
the evidence does not suggest that Roberts was a failure in
his job. As already stated, 50 percent of Roberts' working
time was devoted to announcing. No criticism of that
function was ever proffered. And with regard to Roberts'
sales function, there is nothing out of the ordinary for a
"boss" to be a better performer than his subordinate. In
addition, Murray's efforts at selling were performed on a
full-time basis rather than, as in the case with Roberts, on a
divided schedule. Also the accounts which Murray as-
signed to himself were the larger and more stable
customers. The record shows that several of Roberts'
customers had gone out of business. Accordingly, for these
and additional reasons detailed in General Counsel's brief
a fair comparison between Murray's and Roberts' sales
performances was difficult at best and certainly inconclu-
sive to establish Roberts as a failure in salesmanship.
On balance, I conclude that Roberts was discharged
primarily because of his union activity and not, as argued
by Respondent, because of any failure or inability to
perform as a salesman for KMAR.
Unilateral changes in working conditions: The record
shows, and Respondent does not dispute, that three of
Respondent's employees, Dean, Clark, and Burns, were
granted a 25-cent-per-hour wage increase in September
1975. Furthermore, the working hours of employee Burns
were reduced from 32 hours to 11 hours per week in order
to accommodate the employment of another employee.
Finally, Respondent failed to pay the customary Christmas
bonus in 1975. AU these changes are alleged to be in
violation of Respondent's bargaining obligation estab-
lished by the Board in the prior case, 222 NLRB
1133(1976), which unequivocally established that Respon-
dent's bargaining obligation commenced as of December
10, 1974.
Respondent argues that no bargaining obligation existed,
since the order has not been enforced by a court and since
no request to bargain was made by the Union. Dispositive
of this contention is the Board's decision in J. P. Stevens &
Co., Gulistan Division, 186 NLRB 180(1970). There a Gissel
bargaining order was pending in the court of appeals, yet
the Board held that Respondent's unilaterial changes in the
wage structure constituted a further violation of Section
8(aX)(5). Once an obligation to bargain has been established
by contract or by Board order, it is incumbent upon the
employer to notify the union of any planned changes in
working conditions so that the union is able to make a
request to bargain. The record is clear that the obligation to
bargain existed as of December 10, 1974. Respondent's
subsequent unilateral changes were effectuated without
559
DECISIONS OF NATIONAL LABOR RELATIONS BOARD
notifying the Union. The three employees, Clark, Burns,
and Dean who received raises in September 1975, when the
obligation to bargain was in effect, had signed union cards
and had designated the Union as their bargaining agent.
And Respondent's failure to notify and bargain with the
Union is violative of Section 8(a)5).
Furthermore, Respondent's failure to pay the Christmas
bonus in 1975 continues to be a violation of Section 8(a)(5).
The prior Board decision held that Respondent's failure to
pay the bonus in 1974 because of the union activity was a
violation of the Act. The bonus had become a regularly
expected benefit prior to 1974.
Finally, the reduction in employee Burns' working hours
amounted to a substantial reduction which should have
been the subject matter of negotiations between the Union
and management no matter what reason Respondent had
assigned to the change. Burns had signed a union card and
selected the Union as the bargaining agent. Respondent's
failure to notify and bargain with the Union was violative
of Section 8(a)(5).
CONCLUSIONS OF LAW
1. Respondent, Franklin Parish Broadcasting, Inc., is
an employer within the meaning of Section 2(2) of the Act
and engaged in commerce within the meaning of Section
2(6) of the Act.
2. The Union, Local 1146, International Brotherhood
of Electrical Workers, AFL-CIO-CLC, is a labor organiza-
tion within the meaning of Section 2(5) of the Act.
3. By unlawfully discharging Davis L. Roberts, a
witness in the prior case, on December 31, 1975, Respon-
dent engaged in unfair labor practices in violation of
Section 8(a)(l), (3), and (4) of the Act.
4. By unilaterally changing working conditions, includ-
ing wage increases to employees Dean, Clark, and Burns,
the reduction in working hours of employee Burns, and the
failure to grant the 1975 Christmas bonus, Respondent
violated Section 8(a)(1) and (5) of the Act.
THE REMEDY
Having found that Respondent engaged in unfair labor
practices in violation of Section 8(a)(l), (3), (4), and (5) of
the Act, I recommend that Respondent be ordered to cease
and desist from its unlawful practices. I further recommend
that Respondent be ordered to post an appropriate notice
and take affirmative action in order to effectuate the
policies of the Act.
In addition, I recommend that Davis L. Roberts be
offered full and immediate reinstatement with backpay,
computed as provided in F. W. Woolworth Company, 90
NLRB 289 (1950), and Isis Plumbing & Heating Co., 138
NLRB 716 (1962). 1 also recommend that the Respondent
reimburse any of its employees who lost pay by reason of
Respondent's work schedule change or by reason of its
withholding of the Christmas bonus, including interest at 6
percent per annum in accordance with the Board's usual
formula.
2 In the event no exceptions are filed as provided by Sec. 102.46 of the
Rules and Regulations of the National Labor Relations Board, the findings,
conclusions, and recommended Order herein shall, as provided in Sec.
Upon the basis of the foregoing findings of fact,
conclusions of law, and the entire record and pursuant to
Section 10(c) of the Act, I issue the following recommend-
ed:
ORDER 2
Respondent Franklin Parish Broadcasting, Inc., Winns-
boro, Louisiana, its officers, agents, successors, and
assigns, shall:
I. Cease and desist from:
(a) Discouraging membership in Local Union 446,
International Brotherhood of Electrical Workers, AFL-
CIO-CLC, or any other labor organization, by unlawfully
discharging any of its employees or discriminating in any
other manner with respect to their hire or tenure of
employment or any term or condition of employment in
violation of Section 8(a)(3) of the Act.
(b) Unlawfully and unilaterally changing conditions of
employment of its employees who are members of the
Union.
(c) Unlawfully discharging or otherwise discriminating
against any of its employees because he has given
testimony under the Act.
(d) Refusing to bargain collectively with the Union
subject to Section 9(a) of the Act.
(e) In any other manner interfering with, restraining, or
coercing any employees in the exercise of the rights granted
them by Section 7 of the Act.
2. Take the following affirmative action which will
effectuate the policies of the Act:
(a) Offer Davis L. Roberts immediate and full reinstate-
ment to his former position or, if such position no longer
exists, to a substantially equivalent position, and make him
whole for any loss of pay that he may have suffered by
reason of the Respondent's discrimination against him in
accordance with the recommendations set forth herein
under "The Remedy."
(b) Pay to each employee who was on the payroll of
Respondent the 1975 Christmas bonus in amounts of $100
to full-time employees and $50 to part-time employees.
(c) Pay to employee Burns the salary or wages which he
lost as a result of the reduction of his working hours.
(d) Upon request, recognize and bargain with the Union
as the exclusive bargaining representative of the employees
in a unit of all employees employed by Respondent at its
Winnsboro, Louisiana, radio station KMAR, AM and FM,
excluding the maids, guards, and supervisors, as defined in
the Act, as amended.
(e) Preserve and, upon request, make available to the
Board or its agents, for examination and copying, all
payroll records, social security payment records, timecards,
personnel records and reports, and all other records
necessary to analyze the amount of backpay due under the
terms of this recommended Order.
102.48 of the Rules and Regulations, be adopted by the Board and become
its findings, conclusions, and Order, and all objections thereto shall be
deemed waived for all purposes.
560
FRANKLIN PARISH BROADCASTING, INC.
(f) Post at its Winnsboro, Louisiana, station copies of the
attached noticed marked "Appendix." 3 Copies of said
notice, on forms provided by the Regional Director for
Region 15, after being duly signed by Respondent's
representative, shall be posted by it immediately upon
receipt thereof, and be maintained by it for 60 consecutive
days thereafter, in conspicuous places, including all places
3 In the event the Board's Order is enforced by a Judgment of the 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
where notices to employees are customarily posted.
Reasonable steps shall be taken by Respondent to insure
that said notices are not altered, defaced, or covered by any
other material.
(g) Notify the Regional Director for Region 15, in
writing, within 20 days from the date of this Order, what
steps the Respondent has taken to comply herewith.
Judgment of the United States Court of Appeals Enforcing an Order of the
National Labor Relations Board."
561