The Rittling Corp.

National Labor Relations Board - Board Decisions

Apr 30, 1973

203 N.L.R.B. 355 (N.L.R.B. 1973)

RITTLING CORPORATION 355
The Rittling Corporation and Local 335, International
Union of Electrical , Radio and Machine Workers,
AFL-CIO-CLC. Case 3-CA-5016
April 30, 1973
DECISION AND ORDER
BY CHAIRMAN MILLER AND MEMBERS FANNING
AND PENELLO
On December 29, 1972, Administrative Law Judge
Almira Stevenson issued the attached Decision in this
proceeding. Thereafter, the Respondent filed excep-
tions and a supporting brief, and the General Counsel
filed limited exceptions and a brief in support thereof.
Pursuant to the provisions of Section 3(b) of the
National Labor Relations Act, as amended, the Na-
tional Labor Relations Board has delegated its au-
thority in this proceeding to a three-member panel.
The Board has considered the record and the at-
tached Decision in light of the exceptions and briefs
and has decided to affirm the rulings, findings, and
conclusions of the Administrative Law Judge and to
adopt her recommended Order.'
ORDER
Pursuant to Section 10(c) of the National Labor
Relations Act, as amended, the National Labor Rela-
tions Board adopts as its Order the recommended
Order of the Administrative Law Judge and hereby
orders that the Respondent, The Rittling Corpora-
tion, Buffalo , New York, its officers , agents, succes-
sors, and assigns, shall take the action set forth in the
said recommended Order.
8(a)(5) and (1) of the National Labor Relations Act, as
amended , by refusing to abide by its collective -bargaining
agreement with the Charging Party at the Respondent's new
plant located at Gowanda, New York; by unilaterally
changing the terms and conditions of employment at that
plant ; and by refusing to recognize the Charging Party as
the representative of the employees at the Gowanda plant.
For the reasons set forth below , I find that the Respon-
dent violated Section 8(a)(5) and (1) of the Act.
Upon the entire record,' including my observation of the
demeanor of the witnesses , and after due consideration of
the briefs filed by the General Counsel and the Respondent,
I make the following:
FINDINGS OF FACT 2
AND
CONCLUSIONS OF LAW
1. JURISDICTION
The Respondent, a New York corporation, at all times
material herein has maintained its principal office , place of
business , and manufacturing facilities at 252 Amherst
Street, Buffalo, New York, and, since about the middle of
September 1972, has operated and maintained a manufac-
turing plant on Commercial Street in Gowanda , New York.
The Respondent is engaged at said plants in the manufac-
ture, sale, and distribution of baseboard heating, radiators,
and related products.
During the past year, the Respondent purchased pipes
and other metal products and other goods and materials
valued in excess of $50,000 , of which goods and materials
valued in excess of $50 ,000 were transported to the afore-
said plants directly from States other than New York. The
Respondent admits , and I conclude , that it is an employer
engaged in commerce within the meaning of Section 2(6)
and (7) of the Act.
It. LABOR ORGANIZATION
i The General Counsel excepted to the failure of the Administrative Law
Judge to specifically require in her recommended Order that the current
collective-bargaining agreement between the Respondent and the Charging
Party be retroactively applied to the employees in the Respondent's Gowan-
da plant . Since such a requirement is already included in the section of her
decision entitled "Remedy" and that section is incorporated by reference into
the recommended Order and notice , which we have adopted , we find no
ment in the General Counsel 's exception.
DECISION
STATEMENT OF THE CASE
ALMIRA ABBOT STEVENSON, Administrative Law Judge:
This case was heard at Buffalo , New York, on November
2, 1972. The charge was filed by the Union August 23, 1972,
and served on the Respondent August 24, 1972. The com-
plaint was issued September 26, 1972, and amended at the
hearing.
The issue is whether the Respondent violated Section
The Charging Party, herein referred to as the Union, is a
labor organization within the meaning of Section 2(5) of the
Act.
111. THE UNFAIR LABOR PRACTICES
The Respondent has been in business in and around Buf-
falo, New York, since at least 1947. As indicated, it manu-
factures heating and ventilating equipment such as
baseboard heaters and radiators . Charles P. Rittling is the
president; Robert M. Hodgson is a factory manager.
In 1950, the Respondent moved its manufacturing plant
to Hamburg, New York. In April 1962, the Union was
certified by the Board as the exclusive representative of the
Respondent 's production and maintenance employees. The
t The General Counsel's motion for correction of errors in the official
report of proceedings is granted , in the absence of objection . Although the
stenographic transcript contains additional errors not included in the motion,
I do not deem it necessary to correct them as the true meaning is obvious.
2 Except as indicated , the facts are undisputed
203 NLRB No. 59
356 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
parties executed their first collective-bargaining agreement
on June 20 , 1962, and have been parties to successive agree-
ments since that time . Their most recent contract was execu-
ted July 7, 1970, effective for a term of 3 years. All of the
contracts have contained union-shop and checkoff provi-
sions . All have also contained the following provisions:3
Art. XIV, Sec. 15.4 In the event the Company should
move its plant or establish plants in other geographical
areas , senior employees shall have preference over all
other job applicants for any vacant positions.
Art. XXX. Functions of Management . Sec. I .. .
The Company shall be the exclusive judge of all mat-
ters pertaining to . . . the location of plants ... .
At the request of the Union, the unit was described in the
first collective-bargaining agreement, covering 1962-64, as
follows:
Art. I, Sec. 2. The term "employee" as used in this
Agreement refers to and includes all production and
maintenance employees of the Company at its factory
at 357 Pleasant Avenue in the Village of Hamburg, Erie
County, New York, excluding office clerical employees
and all guards , professional employees and supervisors
as defined in the Act.
In March 1963, union officials learned that Rittling was
attempting to acquire land adjacent to its Hamburg plant
for purposes of expansion. Although the Union and the
employees attempted to aid the Company in this endeavor,
by the fall of 1963 it became apparent that adjacent land
could not be acquired. The then international representative
of the Union , Harry Shaw , therefore asked Charles Rittling
about the Company's future plans. Rittling assured Shaw
that he would not abandon this area , where his roots were.
He said he was looking at possible sites in Buffalo and that
the Company would locate somewhere in Erie County.
Shaw suggested that the contract be modified by changing
the recognition clause accordingly in order to give security
to the employees . Rittling agreed , and the parties executed
an October 21, 1963, "letter" modifying the 1962-64 con-
tract as follows:
Art. 1. Sec. 2. The term "employee" as used in this
Agreement refers to and includes all Production and
Maintenance employees of the company at its factory
in Erie County, New York, excluding office clerical
employees , and all guards , professional employees and
supervisors as defined in the Act.
Thereafter, the Respondent leased a plant at 252 Amherst
Street, Ene County, Buffalo, New York, and, in early 1964,
began operations there , manufacturing the same products
with the same machines and practically the same methods.
The plant was located 6 to 8 miles from the Niagara County
line.
Meanwhile , William Gaden succeeded Harry Shaw as
international representative of the Union, and negotiations
i All collective -bargaining agreements between the parties also contained,
in art. XI, sec. 1(d), a provision that the arbitrator had no authority to add
to, subtract from , or modify any provision of the agreement . Contrary to the
Respondent , I do not consider that provision relevant to the issue in this case
It is a common practice to restrict arbitrators ' authority in such a manner.
4 Sec 15 of art XIV was renumbered as sec 17 in the 1964 and subsequent
contracts
began for a new collective -bargaining agreement . The initial
sessions were held at the Hamburg location , and the final
sessions at the Amherst Street location. In response to the
Union's proposal that art. I be conformed with the October
21, 1963, letter of agreement , the recognition clause of the
1964-66 contract, executed June 19, 1964, provided as fol-
lows:
Art. 1. Sec . 2. The term "employee" as used in this
agreement refers to and includes all production and
maintenance employees of the Company in the County
of Erie, State of New York , excluding office clerical
employees and all guards , professional employees and
supervisors as defined in the Act.
A 3-year 1966-69 agreement contained the same recogni-
tion provision as the prior contract.
The next , and current , collective-bargaining agreement
was negotiated for the Union by International Representa-
tive Russell Freund . As indicated , it is effective for 3 years
from the date of execution , July 7, 1970. Art. I, sec . 2, is the
same as the similarly numbered clause in the 1964 and 1966
agreements.
On May 15, 1972 , a committee of Local 335 officials met
with Charles Rittling and discussed rumors that the plant
would be moved again . Rittling told them he had no definite
news for them , but when the time arrived he would inform
the employees of the move to be made. On May 29 , Rittling
met with International Representative Freund . Rittling told
Freund that he anticipated moving the plant , and was con-
sidering several possible locations in Buffalo and Cheekto-
waga, as well as Gowanda . He said that Gowanda had
strong economic advantages for the Company, but there
were insurance problems to be solved. Rittling said he
would let Freund know when a decision was made . Rittling
stated that he did not wish to hurt any of his old employees,
and would give them all an opportunity to move to the new
location . Freund said that the collective-bargaining agree-
ment would be applicable if the plant moved to Gowanda,
but Rittling disagreed ; both said they would consult counsel
on this point.
On June 1 , 1972, at a time when 14 or 15 production and
maintenance employees were employed at the Amherst
Street plant , Rittling decided definitely to relocate the plant,
for economic reasons , at 170 Commercial Street , Gowanda,
Cattaraugus County, New York, just across the Erie County
line. He personally asked each employee if he or she wanted
to work at Gowanda; all but one answered yes.5
On June 2, Rittling informed Freund of these develop-
ments. In response to Freund 's inquiry dated June 9, the
Respondent's counsel advised him, by letter dated June 19,
that the collective -bargaining agreement would not be ap-
plicable to the Gowanda location because the contract was
limited by its own terms to Erie County . Rittling discussed
the matter with Freund on August 23 and again, apparently,
S Based on the credited and undisputed testimony of Charles Riffling A
document dated June 1, 1972, which Local 335 President Richard Ball testi-
fied he circulated among the employees, appears to indicate that one employ-
ee was not given an opportunity to move However, Ball did not testify to
that effect, and International Representative Freund testified Ball told him
that Charles Riffling had personally asked each employee if he wished to go
to Gowanda and all but one answered yes
RITTLING CORPORATION
on September 22. Freund insisted that the contract would
be applicable to the new location, and Rittling insisted it
would not because Gowanda was outside Erie County. Rit-
tling told Freund that new employees would be hired at a
lower rate at Gowanda; he failed to respond to Freund's
offer to negotiate such rates. Rittling was also unresponsive
to Freund's protest that the pension plan, which had been
included, for the first time, in the current collective-bargain-
ing agreement, was contingent on the employees' being
members and being covered by the contract without which
there would be no plan.6 In a letter to Freund dated October
3, 1972, the Respondent's counsel reiterated its dis-
agreement with Freund's position that the "contract applied
outside of Ene County," and asserted:
We therefore suggest that you reconsider your position,
and if you then concede that said contract does not
apply to the Gowanda location, Rittling will, if legally
permitted, bargain with you with respect to rates of
pay, hours of employment and other terms and condi-
tions of employment at Gowanda. [Emphasis in origi-
nal.]
On July 27, 1972, truckdriver Charles Stroaner, the first
new employee hired for work at the Gowanda plant and a
member of the Union, filed a grievance alleging violation of
the union-security and checkoff provisions of the contract
and failure to pay him the contract wage. The Respondent
denied the grievance on the ground that Stroaner "domi-
ciles in Gowanda" and the contract was not applicable. The
Union's request for a third-step meeting has not been grant-
ed. Freund testified, without dispute, that the Respondent
is delinquent in its payments into the pension fund, as re-
quired by the contract.
The Respondent will manufacture the same products
with the same machines and by the same methods at the
Gowanda plant as it did at the Amherst Street plant. The
first employee was transferred from Amherst Street to Gow-
anda in late August or early September. At the time of the
hearing in this proceeding, the move was not yet complete
because there was no steam for the degreaser at Gowanda,
without which finishing cannot be done, and no heat for
baking and painting. Charles Rittling hoped, however, to
complete the move within 2 or 3 weeks. Hodgson, who had
been factory manager at Amherst Street, was in charge at
Gowanda. Nine production and maintenance employees
had been transferred from Amherst' Street to Gowanda,
where they were engaged in shearing, punching, forming,
and assembling fin radiators and electric baseboard panels. '
Five production and maintenance employees were still at
Amherst Street (apparently including the one who does not
wish to transfer) They were engaged in finishing , degreas-
ing, painting , spot welding, and packing and shipping all
products except fin tubes which were being packed and
6 1 do not credit Freund's testimony that Railing told him, in one or more
of these conversations, that there would be no union at Gowanda or that he
was moving the plant there so he could pay lower wages and hire new
employees at lower rates Nor do I credit Ball's testimony that Rittling told
him he would like to have a clean break with the Union This testimony did
not have the ring of truth, and struck me as an afterthought. The complaint
does not allege, and the credible evidence does not show, that the move was
unlawfully motivated
357
shipped at Gowanda. In addition to the nine transferees,
there were seven new hires at the Gowanda plant consisting
of two laborers, a truckdriver, and four maintenance men
engaged solely in getting the new plant ready. Charles Rit-
thng testified that the maintenance men might be employed
after the move was completed, if there was something for
them to do and if they wanted to work.
The current collective-bargaining agreement with the
Union is being applied to the employees still working at
Amherst Street, but is not being applied to the production
and maintenance employees at the Gowanda plant.? For
example, although the contract wage for truckdrivers is
$3.77 an hour, the hourly wage of the newly hired truckdri-
ver at Gowanda is $3 an hour.
The parties stipulated that the distance between the Am-
herst Street plant and the Gowanda plant is 43 miles. Pearl
Smith, a production employee who has been transferred,
testified that it is 25 miles from her home to the Amherst
Street plant, and 15 miles from her home to the Gowanda
plant.
Analysis and Conclusions
The General Counsel contends that the words "County of
Erie" in the recognition clause of the current agreement, as
well as the words "Erie County" in prior agreements, are
merely descriptive, not words of geographical limitation, of
the unit covered. The Respondent contends that the lan-
guage was intended to be, and is, a geographical limitation.
I find that the Respondent's operation at Gowanda is a
continuation of its Amherst Street operation based on the
following considerations:
1. The same products are manufactured with the same
equipment, the same methods, and under the same supervi-
sion . It will also employ substantially the same employees.
Nine of the Amherst Street employees have already been
transferred to Gowanda, and of the remaining five at least
four will follow, probably within 2 or 3 weeks of the date
of the hearing in this proceeding. Most, if not all, of the
seven new hires at Gowanda are engaged only in getting the
plant ready, and no decision to keep them on the payroll
after that has been made.
2. The relocated plant is in the same general vicinity as
the old plant. The Amherst Street plant was located some-
what north of the city of Buffalo, and Gowanda is south of
Buffalo by several more miles. There is no indication that
any of the relocated employees will find it necessary to
move their homes in order to work at Gowanda. Indeed, for
at least one employee, the Gowanda plant is nearer her
home than the Amherst Street plant is.
3. The Union has represented the Respondent's produc-
tion and maintenance employees under four successive col-
lective-bargaining agreements for over 9 years, and its
7 Although Chief Steward Polus testified that Factory Manager Hodgson
told him, probably sometime in June , that anybody going to Gowanda would
have to take a cut in pay, he conceded that his own pay was not cut when
he transferred Moreover, it appears that all transferred employees whose
classifications are listed in the current collective- bargaining agreement are
being paid as much or more than the contract rate In these circumstances,
I do not believe that Hodgson made the statement attributed to him
358 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
current contract does not expire until June 6, 1973. The
Respondent does not contend that the Union does not rep-
resent a majority of the employees at Gowanda. Indeed, it
offered, in its letter of October 3, 1972, to recognize and
bargain with the Union as the representative of the employ-
ees there. Moreover, in view of the union-shop clause in all
the contracts, it is clear that all the production and mainte-
nance employees who transferred to Gowanda, and who
constitute a majority there, are members of the Union.
In this context, I find without merit the Respondent's
contention that the language of the contract construed as a
whole and the parties' performance thereunder establish
that the contract is not applicable at Gowanda. Thus, I find
no substance to the Respondent's contention that the phras-
es "County of Erie" and "Erie County" would not be in the
contracts unless they were geographic limitations . Place de-
signations frequently are used in unit descriptions in Board
certifications and collective -bargaining agreements as an
additional factor clarifying the employees covered. No
cases have been cited, and none have been found, in which
the Board has indicated that such ordinary place designa-
tions operate per se as geographical limitations which enable
an employer to dissolve its contract obligations merely by
moving its plant to an address different from the one in the
certified or contract unit description.
Nor can I agree with the Respondent that art. XIV, sec.
17, of the current contract would be meaningless if the
contract follows the plant, and that the only sensible inter-
pretation of this provision and article XXX, read together,
is that the Union knew that the contract was geographically
limited, and knew that if the Company exercised its right to
move the plant outside of the county, the only right retained
by the Union was that conceded in art. XIV, sec. 17. With-
out indulging in speculation regarding the possible mean-
ings of sec. 17, I note that it appears to be applicable not
only to a plant relocation such as the one involved in this
case but also to a relocation under circumstances where the
contract would not follow. Moreover, in my opinion, con-
comitant contract provisions giving an employer the right to
determine plant location and giving employees preference
to job vacancies at new plants do not preclude mutual intent
to have the contract follow the operations in circumstances
such as those present here.
As for the conduct of the parties under these contracts,
I find that the evidence regarding the 1963 negotiations of
the change in the recognition clause justifies the inference
that the designation "Erie County" was proposed by the
Union, and agreed to by the Respondent, only because the
precise future address of the plant was not known at the
time . If it had been known , it seems highly probable that the
parties would have substituted the Amherst Street address,
instead of the Erie County designation, for the street ad-
dress in Hamburg previously in the unit description. The
evidence does not, in my opinion, justify the inference that
the parties by entering into the October 21, 1963, letter of
agreement thereby acknowledged that the contract as writ-
ten was applicable only as long as the plant remained at 357
Pleasant Avenue in the village of Hamburg.
Upon the entire record, therefore, I find that the current
collective-bargaining agreement is applicable to the
Respondent's operations in Gowanda, and that it covers the
production and maintenance employees at that location. I
conclude that the Respondent refused to bargain with the
Union as the exclusive representative of the employees in
the appropriate unit by unilaterally changing the wage and
pension plan provisions, and otherwise refusing to apply the
terms of the collective-bargaining agreement at Gowanda,
New York, in violation of Section 8(a)(5) and (1) of the
Act.8
REMEDY
Having found that the Respondent violated Section
8(a)(5) and (1) of the Act, I recommend that it cease and
desist therefrom and take certain affirmative action de-
signed to effectuate the policies of the Act.
I recommend that the Respondent continue to recognize
the Union as the bargaining representative of the employees
in the appropriate unit, including those at the Gowanda,
New York, plant ; and apply retroactively, and maintain in
effect, the collective-bargaining agreement with the Union
which was in force at the Amherst Street plant, unless the
parties mutually agree to do otherwise. Nothing in my rec-
ommendation is to be taken as permitting the Respondent
to deprive employees of any benefits they may have re-
ceived as a result of its refusal to apply the contract terms
to the employees at Gowanda.
Upon the foregoing findings of fact and conclusions of
law and the entire record, and pursuant to Section 10(c) of
the Act, I hereby issue the following recommended:
ORDERS
The Respondent, The Rittling Corporation, Buffalo, New
York, its officers, agents , successors , and assigns , shall:
1. Cease and desist from:
(a) Refusing to bargain collectively with respect to rates
of pay, wages, hours of employment, and other terms and
conditions of employment, with Local 335, International
Union of Electrical, Radio and Machine Workers, AFL-
8 See Goodyear Tire & Rubber Company, 195 N LRB 767; Frasier & Johnston
Company, 189 NLRB 142. Accord, N L R B v. Storack Corporation, 357 F 2d
893 (C.A. 7, 1966), N L R.B v. Royal Oak Tool & Machine Company, et a!,
320 F.2d 77 (C.A. 6, 1963), Oddie et a! v. Ross Gear and Tool Company, Inc,
305 F.2d 143 (C.A. 6, 1962), and Local 1251 International Union of United
Automobile, Aircraft and Agricultural Implement Workers of America, UA W
v. Robertshaw Controls Co., 405 F 2d 29 (C.A. 2, 1968), relied on by the
Respondent, are inapposite In those cases, breach of contract suits were
dismissed based on the courts' conclusion that the contracts which on their
face covered employees "within the city limits of Detroit ," and "in its
Waterbury [Connecticut] Plants," respectively, were not applicable at new
plant locations where , unlike here, operations were moved as far as from
Michigan and Connecticut to Tennessee , and the conduct of the parties
revealed that they had in the past recognized that their contracts applied only
at the original locations.
9 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 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.
RITTLING CORPORATION
CIO-CLC, as the exclusive representative of its employees
in the following appropriate unit:
All production and maintenance employees of the
Company in the County of Erie, including employees
at Gowanda, State of New York, excluding office clen-
cal employees and all guards, professional employees,
and supervisors as defined in the Act.
(b) In any like or related manner interfering with, re-
straining, or coercing employees in the exercise of the rights
guaranteed in Section 7 of the Act.
2. Take the following affirmative action designed to ef-
fectuate the policies of the Act:
(a) Continue to recognize and, upon request, bargain col-
lectively with Local 335, International Union of Electrical,
Radio and Machine Workers, AFL-CIO-CLC, as the ex-
clusive bargaining representative of the employees in the
appropriate unit, including those at the Gowanda, New
York, plant, pursuant to the collective-bargaining agree-
ment between the parties which was in force and effect at
its Amherst Street plant at the time of the relocation to
Gowanda, in the manner described in the section hereof
entitled "Remedy."
(b) Preserve and, upon request, make available to the
Board or its agents, for examination and copying, all payroll
records, social security payment records, timecards, person-
nel records and reports, and all records necessary to analyze
the amount of any backpay and pension payments which
may be due under the terms of this Order.
(c) Post at its plant in Gowanda, New York, and, if still
in operation, at its plant on Amherst Street, copies of the
attached notice marked "Appendix." 10 Copies of the notice
on forms provided by the Regional Director for Region 3,
after being duly signed by an authorized representative of
the Respondent, shall be posted by the Respondent immedi-
ately upon receipt thereof, and be maintained for 60 consec-
utive days thereafter, in conspicuous places, including all
places where notices to employees are customarily posted.
Reasonable steps shall be taken by the Respondent to insure
that the notices are not altered, defaced, or covered by any
other material.
(d) Notify the Regional Director for Region 3, in writing,
within 20 days from the date of this Order, what steps the
Respondent has taken to comply herewith.
10 In the event that the Board's 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 "
APPENDIX
NOTICE TO EMPLOYEES
POSTED BY ORDER OF THE
NATIONAL LABOR RELATIONS BOARD
An Agency of the United States Government
359
WE WILL NOT refuse to bargain collectively with re-
spect to rates of pay, wages, hours of employment, and
other terms and conditions of employment, with Local
335, International Union of Electrical, Radio and Ma-
chine Workers, AFL-CIO-CLC, as the exclusive rep-
resentative of our employees in the following
appropriate unit:
All production and maintenance employees of the
Company in the County of Erie, including Gowan-
da, New York, excluding office clerical employees
and guards, professional employees and supervisors
as defined in the Act.
WE WILL NOT in any like or related manner interfere
with, restrain, or coerce our employees in the exercise
of the rights guaranteed in the National Labor Rela-
tions Act, as amended.
WE WILL continue to recognize and, upon request,
bargain collectively with Local 335, International
Union of Electrical, Radio and Machine Workers,
AFL-CIO-CLC, as the exclusive bargaining represent-
ative of our employees in the appropriate unit, includ-
ing those at the Gowanda, New York, plant, pursuant
to our collective-bargaining agreement with the Union
which was in force and effect at our Amherst Street
plant at the time of the relocation to Gowanda.
THE Rn-FLING CORPORATION
(Employer)
Dated By
(Representative) (Title)
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 direct-
ed to the Board's Office, Ninth Floor, Federal Building, 111
West Huron Street, Buffalo, New York 14202, Telephone
716-842-3106.