Garden Grove Hospital

National Labor Relations Board - Administrative Judge Opinions

Aug 4, 2010

21-CA-039031 (N.L.R.B. Aug. 4, 2010)

JD(SF)–31–10
Los Angeles, CA
UNITED STATES OF AMERICA
BEFORE THE NATIONAL LABOR RELATIONS BOARD
DIVISION OF JUDGES
SAN FRANCISCO BRANCH OFFICE
PRIME HEALTHCARE SERVICES-GARDEN
GROVE, LLC d/b/a GARDEN GROVE
HOSPITAL & MEDICAL CENTER
and Case 21-CA-39031
SERVICE EMPLOYEES INTERNATIONAL
UNION, UNITED HEALTHCARE WORKERS-WEST
Daniel A. Adlong, Esq. Los Angeles, California,
for the General Counsel.
Jonathan A. Siegel, Esq. (Jackson Lewis LLP),
Newport Beach, California, for the Respondent.
Bruce A. Harland, Esq. and Jacob J. White, Esq.,
Alameda, California, for the Union.
DECISION
Statement of the Case
JAY R. POLLACK, Administrative Law Judge. This case was tried in Los Angeles,
California on May 24 and 25, 2010. On September 28, 2009, Service Employees International
Union, United Healthcare Workers-West (the Union) filed the original charge in this case against
Prime Healthcare Services-Garden Grove, LLC d/b/a Garden Grove Hospital & Medical Center
(Respondent or the Employer). The Union filed the first amended charge on November 2, 2009.
On February 24, 2010, the Regional Director for Region 21 of the National Labor Relations
Board (the Board) issued a complaint against Respondent. The complaint alleges that
Respondent violated Section 8(a)(5) and (1) of the National Labor Relations Act (the Act) by
eliminating the reserve sick leave benefit of bargaining unit employees without prior notice and
bargaining with the Union. The Respondent filed a timely answer in which it denied that it had
violated the Act.
The parties have been afforded full opportunity to appear, to introduce relevant evidence,
to examine and cross-examine witnesses, and to file briefs. Upon the entire record, from my
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observation of the demeanor of the witnesses,1 and having considered the briefs submitted by the
parties, I make the following:
Findings of Fact
I. Jurisdiction
At all times material, Respondent has been a California corporation, engaged in the
operation of a hospital in Garden Grove, California. Respondent, in conducting its business
operations described above, during the 12-month period ending September 30, 2009, derived
gross revenues in excess of $250,000 and purchased and received goods valued in excess of
$50,000 directly from points outside the State of California. Accordingly, Respondent admits and I
find, Respondent is an employer engaged in commerce within the meaning of Sections 2(2), (6)
and (7) of the Act.
The parties stipulated that the Union is a labor organization within the meaning of Section
2(5) of the Act.
II. Facts
Since at least January 1, 2007, the Union had a collective-bargaining agreement with
Tenet Healthcare Corporation covering two appropriate units of hospital employees at the
Garden Grove Hospital. During the term of the 2007 -2011 collective bargaining agreement,
Tenet Healthcare sold the Garden Grove Hospital to Respondent effective July 1, 2008.
Respondent agreed to recognize the Union and to honor significant portions of Tenet’s
bargaining agreement with the Union. However, before the transfer of ownership from Tenet to
Respondent, Respondent set the initial terms and conditions of employment under which it
would hire Tenet’s employees. These terms included a different health plan, 401(k) plan, long
term and short term disability and life insurance plans, paid time off plan, and sick leave plan.
Tenet Healthcare provided employees with a reserve sick leave benefit. This reserve
sick leave benefit provided that full-time employees accrued 1.85 hours of reserve sick pay
every pay period and part-time employees accrued .92 hours of reserve sick leave per pay
period. When Respondent took over the hospital it set initial terms of employment. It
negotiated with the Union over changes to the health insurance plan and 401(k) plan. There
was no mention of the reserve sick leave plan.
While Respondent informed the unit employees, in June 2008, of its intentions through
“Employee Forums,” Respondent did not formally notify the Union of this change.2 However,

1 The credibility resolutions herein have been derived from a review of the entire testimonial
record and exhibits, with due regard for the logic of probability, the demeanor of the witnesses,
and the teachings of NLRB v. Walton Manufacturing Company, 369 U.S. 404, 408 (1962). As to
those witnesses testifying in contradiction to the findings herein, their testimony has been
discredited, either as having been in conflict with credited documentary or testimonial evidence, or
because it was in and of itself incredible and unworthy of belief.
2 Employee forums were meetings where Prime told employees about its intended changes
in various benefit plans, and informed employees of new equipment, software, and other
systems which would be implemented after July 1, 2008. Prime alleges that there were at least
ten of these forums. Prime contends that Union representatives attended these Employee
forums and heard about Prime’s intended changes during these meetings.
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due to clerical errors, from July 1, 2008 to April 17, 2009 the employees continued to accrue the
reserve sick leave benefits for every pay period during this time. On April 17, 2009,
Respondent notified employees of the mistake in a memo. In the memo, Respondent informed
the employees that the reserve sick leave benefit would no longer accrue and that the benefit
which had accrued since July 2008 would be rescinded.3 Respondent, however, did not inform
the Union of this change either before or after the memo was sent. Instead, the unit employees
informed the Union of this change.
A successor employer is not bound to honor the substantive terms of the collective
bargaining agreement the union negotiated with a predecessor employer. NLRB v. Burns Sec.
Serv., 406 U.S. 272, 282 (1971). Moreover, a successor employer has a right to set the initial
terms and conditions of employment under which it will hire the employees of a predecessor
without first bargaining with the employees’ bargaining representative. Id. at 294-95. One
exception to this right is when it is perfectly clear that the successor employer will retain the
predecessor’s employees under their prior working conditions. Id. at 294. The exception only
applies, however, when the successor employer “has either actively or by tacit inference misled
employees into believing they would be obtained without change in their wages, hours or
conditions of employment” or when the successor employer failed to clearly announce its plan to
establish new terms and conditions prior to inviting the predecessor’s employees to accept
employment. Spruce Up Corp., 209 NLRB 194, 195 (1974).
In this case, neither party disputes that Respondent purchased and then assumed
operation and control of the Hospital on July 1, 2008 from Tenet. . Respondent also recognized
the Union as the collective bargaining representative of unit employees. Respondent alleges
that between May 13, 2008 and July 1, 2008 it set the initial terms and conditions of
employment before it assumed operation of the Hospital as the Respondent had a right to under
Burns4 and that it held Employee Forums during which Respondent alleges it conveyed
Respondent’s intended changes. It appears that Respondent made it clear to the employees
that it would not hire them under the same terms and conditions of employment utilized by
Tenet. Therefore, as Respondent did not mislead these employees regarding its intent to
change employment terms and conditions, Respondent had the right to set the initial terms and
conditions of employment under which it would hire Tenet’s employees.

3 The memo read in pertinent part:
A mistake was made while setting up the employees of Garden Grove
Hospital following the sale of the hospital to Prime Healthcare Services. The
error was allowing the reserve sick accrual to continue after July 1, 2008.
Garden Grove Hospital will honor the reserve policy with respect to any
accrued balance as of June 30, 2008. However, after July 1, 2008 the accrual
of 1.85 hours per pay period for full-time employees and .92 hours for part-time
employees was supposed to end. The payroll department has corrected this
error for all Garden Grove employees.
As a result, you may see a change in the Reserve Sick balance on your
paystubs. The balance will reflect any accrued sick as of June 30, 2008 less
hours taken since July 1, 2008 only. Any hours accrued since July 1 has been
removed.
4 Burns Sec. Serv., 406 U.S. 272.
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III. Conclusions
A. Respondent’s Duty to Bargain with Incumbent Union
Where the bargaining unit remains unchanged and the successor employer hires a
majority of the predecessor’s employees which are represented by a certain bargaining agent,
the new employer has a duty to bargain with the incumbent union. Burns Sec. Serv., 406 U.S.
at 281. When the “substantial and representative complement” rule is satisfied, the bargaining
obligation attaches and the successor employer must bargain with the union that represents
those employees. Fall River Dyeing & Finishing Corp. v. NLRB, 482 U.S. 27, 47 (1987).5
Here, Respondent continued to employ the employees of Tenet without a break in
service. Therefore, while the Respondent had the right to set the initial terms and conditions of
employment, once it retained a majority of Tenet’s unit employees Respondent had a duty to
bargain with the Union.
B. The Nature of the Reserve Sick Leave Benefit as a Subject of Bargaining
Sections 8(a)(5) and 8(b)(3) of the Act compel collective bargaining for mandatory
subjects of bargaining. 29 U.S.C. §158. Mandatory subjects of bargaining concerning “rates of
pay, wages, hours of employment, or other conditions of employment.” NLRB v. Borg-Warner
Corp., Wooster Div., 356 U.S. 342 (1958). An employer is barred from taking unilateral action in
regard to mandatory subjects of bargaining.6 NLRB v. Katz, 369 U.S. 736 (1962). An employer
that unilaterally changes a condition classified as a mandatory subject of bargaining, altered
without negotiation and accomplished by evading the union, may support an inference of a lack
of good faith. Id. Moreover, the duty to bargain does not extinguish when a collective
bargaining agreement is in effect. See Conley v. Gibson, 355 U.S. 41, 46 (1957). The
U.S. Supreme Court has held that the “[c]ollective bargaining is a continuing process. Among
other things, it involves day to day adjustments in the contract and other working rules,
resolution of new problems not covered by existing agreements, and the protection of employee
rights already secured by the contract.” Id.
1. Sick Leave as a Mandatory Subject of Bargaining
The U.S. Supreme Court has recognized sick leave to be a term and condition of
employment and, therefore, a mandatory subject of bargaining. Katz, 369 U.S. at 744. In Katz,
the sick leave plan at issue consisted of employees having a certain number of paid sick leave
days annually plus the accumulation of unused sick days which could be carried over into the
next year. Id. The employer in Katz reduced the number of paid annual sick days from 10 days
to five days, but doubled the amount of accumulated sick leave days that could be carried over
from five days to 10 days. Id. The Court found that the entire sick leave plan was a mandatory
subject of bargaining and that the employer made a unilateral change violating Section 8(a)(5)
when it failed to bargain over this change. Id.

5 The Board’s “substantial and representative complement” rule determines the date when a
successor’s obligation to bargain with the predecessor’s employees’ union arises. Fall River
Dyeing & Finishing Corp. v. NLRB, 482 U.S. 27, 28 (1987). The obligation is fixed when the
successor employer hires a majority of predecessor’s unit employees. Id.
6 Unilateral changes made by an employer to mandatory subjects of bargaining are
considered per se refusals to bargain. NLRB v. Katz, 369 U.S. 736 (1962).
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In this case, the employees’ sick leave benefit, which included a reserved sick leave
benefit, is similar to the sick leave plan in Katz. Id. Respondent’s present employees who were
employees under Tenet were given a certain amount of sick leave days plus the reserve sick
leave benefit which allowed full time employees to accrue a certain amount of reserve sick leave
hours per pay period. If Respondent’s reserve sick leave benefit can be classified as not being
a separate or an extra benefit, but as a part of a sick leave plan like the one in Katz, then the
reserve sick leave benefit in this case is a mandatory subject of bargaining. Therefore,
Respondent’s change of the reserve sick leave benefit without bargaining with the Union is a
unilateral change and a violation of Section 8(a)(5).
2. Past Practices Create Mandatory Subject of Bargaining
The Board has also defined other miscellaneous employee benefits as wages and,
therefore, mandatory subjects of bargaining. See, e.g., Seafarers Local 777 (Yellow Cab Co.) v.
NLRB, 603 F.2d 862, enfg. in part, 229 NLRB 1329 (1977) (drivers being allowed to take their
taxi cabs home at night); AT&T Corp., 325 NLRB 150 (1997) (paycheck-cashing services);
Florida Steel Corp., 230 NLRB 1054 (1977) (reimbursement rates for lodging and meal
expenses and use of credit cards by employees); Master Slack Corp., 230 NLRB 1054 (1977),
enfd., 618 F.2d 6 (6th Cir. 1980) (allowing employees to purchase goods on layaway); Gratiot
Comty. Hosp., 312 NLRB 1075 (1993), enfd. in relevant part, 51 F.3d 1255 (6th Cir. 1995)
(longstanding practice of employer issuing and laundering uniforms). Whether these
miscellaneous benefits become mandatory subjects of bargaining is impacted by the duration of
the past practice of providing the benefit. Gratiot Comty. Hosp., 312 NLRB 1075 (1993).
An employer’s regular and longstanding practices that are neither random nor
intermittent become terms and conditions of employment even if these practices are not
required by a collective bargaining agreement. Sunoco, Inc., 349 NLRB 240, 244 (2007). As
such, these past practices cannot be changed without offering the unit employees’ collective
bargaining representative notice and an opportunity to bargain. Id. See also Granite City Steele
Co., 167 NLRB 310, 315 (1967); Queen Mary Rest. Corp. v. NLRB, 560 F.2d 403, 408 (9th Cir.
1977); Exxon Shipping Co., 291 NLRB 489, 493 (1988); B & D Plastics, 302 NLRB 245 fn. 2
(1991); DMI Distrib. of Delaware, 334 NLRB 409, 411 (2001).
The Board has generally held that employer practices which occur over a long period of
time supply the longevity needed to establish a past practice. In Granite City Steel Co., 167
NLRB at 315, the Board found a past practice when the employer allowed six succeeding union
business representatives access to the blast furnace plant for fifteen years for the purpose of
resolving grievances. In Sunoco, Inc., the Board found a past practice when for three years the
employer offered unit employees at certain facilities the chance to deliver jet fuel. Sunoco, Inc.,
349 NLRB at 244.
Moreover, a past practice must occur regularly and with such frequency that employees
could reasonably expect the “practice to continue or reoccur on a regular and consistent basis.”
Id. The Board in DMI Distrib. of Delaware, 334 NLRB at 411, did not find a past practice when
the policy of the employer giving bonuses was in effect for eleven years, but bonuses were only
actually given to employees “a couple of times.” See B & D Plastics, Inc., 302 NLRB 245, fn. 2
(1991) (Board found it a random event rather than a past practice when, only three times in the
past five years, an employer held cookouts for employees and gave the employees paid time off
to attend these cookouts.) See also Exxon Shipping Co., 291 NLRB 489 (1988) (Board found
that when the union participated twice in government investigations regarding the possible
death of one of its members, three years apart, too remote in time and too intermittent in their
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occurrence to be a past practice especially when there was no union participation in three
similar investigations).
General Counsel relies on JPH Mgmt., Inc., 337 NLRB 72 (2001) to assert that the nine
months of mistaken accrual of the reserve sick benefit in this case is long enough to establish a
past practice and therefore a term and condition of employment which Respondent needed to
bargain over in order to change or rescind. In JPH Mgmt., Inc., the employer mistakenly gave
its employees a wage increase for five weeks and subsequently rescinded the increase after
discussing the mistake with the union. General Counsel argues that the Board in JPH Mgmt.,
Inc. found that a term and condition of employment was established by this five week mistake
because the Board classified it as past practice. General Counsel’s reliance on JPH Mgmt., Inc.,
however, is misguided. While both this case and JPH Mgmt., Inc. are similar as both involve a
mistake an employer made which resulted in employee gain, the Board in JPH Mgmt., Inc. did
not find that this wage increase established a term and condition of employment because it was
a past practice, but rather because wages are always considered mandatory subjects of
bargaining. JPH Mgmt., Inc., 337 NLRB at 73. Neither the term “past practice” nor the
conclusion that five weeks was a long enough time to establish a past practice were a part of
the Board’s or the ALJ’s analysis in JPH Mgmt., Inc. Id. Therefore, General Counsel’s reliance
on JPH Mgmt., Inc.’s five week mistake to establish that Respondent’s nine month sick leave
accrual error was enough time to establish a past practice is erroneous.
Regardless of the distinguishability of JPH Mgmt., Inc., the mistaken accrual of the
reserve sick leave benefit happened with such regularly and frequency that Respondent’s
employees could have reasonably expected the “practice to continue or reoccur on a regular
and consistent basis” as Respondent mistakenly allowed this reserve sick leave benefit to
continue accruing every pay period for nine months. Sunoco, 349 NLRB at 244. However, as
the above cited cases show, the Board has found a past practice when the practice has been in
place and repeatedly used for a period of years. Prime’s mistaken practice occurred for only
nine months. On the other hand, the Board has never specifically stated that to find past
practice it is required it to have been affect for a number of years. Therefore, while the accrual
in this case only continued for nine months, based on the regular and consistent accrual of this
benefit, without interruption, this benefit could reasonably be classified as a past practice.
C. Conclusion
While Respondent was free to set the initial terms and conditions of employment under
which to hire Tenet’s former employees, when Respondent retained a majority of the Tenet
employees which were represented by the Union, the duty to bargain with the Union attached.
This duty does not expire even during the term of Respondent’s existing collective bargaining
agreement with the Union. The reserve sick leave benefit in this case could reasonably be
classified as a mandatory subject of bargaining as either sick leave or a past practice. Thus,
Prime had to duty to bargain with the Union when it rescinded the mistakenly accrued sick leave
benefit from the employees.
Conclusions of Law
1. Respondent is an employer engaged in commerce and in a business affecting
commerce within the meaning of Section 2(6) and (7) of the Act.
2. The Union is a labor organization within the meaning of Section 2(5) of the Act.
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3. Respondent violated Section 8(a)(5) and (1) of the Act when it rescinded the reserve
sick leave benefit in April 2009.
Remedy
Having found that the Respondent has engaged in unfair labor practices in violation of
8(a)(1) and (5), I find that it must be ordered to cease and desist and to take certain affirmative
action designed to effectuate the policies of the Act.
Upon the foregoing findings of fact and conclusions of law, and upon the entire record, and
pursuant to Section 10(c) of the Act, I hereby issue the following recommended:7
ORDER
The Respondent, Prime Healthcare Services-Garden Grove, LLC, its officers, agents,
successors, and assigns, shall
1. Cease and desist from unilaterally discontinuing the reserve sick leave benefit and
rescinding the reserve sick leave benefit time which employees accrued from July 1, 2008 to
April 17, 2009 without affording the Union notice and an opportunity to bargain.
2. Take the following affirmative actions necessary to effectuate the policies of the Act.
(a) Reinstate its' established past practice of conferring a reserve sick leave benefit
to employees.
(b) Restore the rescinded reserve sick leave benefit time that employees accrued
from July 1, 2008 to April 17, 2009.
(c) Bargain with the Union, on request, regarding its decisions, and the effects of
those decisions, in ceasing to provide a reserve sick leave benefit to employees and rescinding
reserve sick leave benefit time which employees accrued from July 1, 2008 to April 17, 2009, in
the following appropriate units:
Combined Service, Maintenance, Technical, Skilled Maintenance and Business
Office Clerical Unit:
Included: All full-time, regular part-time, and per diem Service, Maintenance,
Technical, Skilled Maintenance, and Business Office employees.
Excluded: All other employees, managers, supervisors, confidential employees,
guards, physicians, residents, central business office employees (whether Facility
based or not) who are solely engaged in qualifying or collection activities or are
employed by another Tenet entity, such as Syndicated Office Systems or Patient
Financial Services, employees of outside registries and other agencies supplying
labor to the Respondent and already represented employees.

7 All motions inconsistent with this recommended order are hereby denied. If no exceptions
are filed as provided by Section 102.46 of the Board's Rules and Regulations, the findings,
conclusions, and recommended Order shall, as provided in Section 102.48 of the Rules, be
adopted by the Board and all objections to them shall be deemed waived for all purposes.
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Professional Unit
Included: All full-time, regular part-time, and per diem Professional employees.
Excluded: All other employees, managers, supervisors, confidential employees,
guards, physicians, residents, central business office employees (whether Facility
based or not) who are solely engaged in qualifying or collection activities or are
employed by another Tenet entity, such as Syndicated Office Systems or Patient
Financial Services, employees of outside registries and other agencies supplying
labor to the Respondent and already represented employees.
(d) Make whole those Service Unit and Professional Unit employees who were
directly and indirectly affected, for any loss of earnings and other benefits they may have
suffered as a result of its unlawful conduct in ceasing to provide a reserve sick leave benefit and
rescinding reserve sick leave benefit time which unit employees accrued from July 1, 2008 to
April 17, 2009.
(e) Preserve and, on 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, including electronic copy of such records if
stored in electronic form, necessary to analyze the amount of compensation due under the
terms of this order.
(f) Post at its place of business in Garden Grove, California, copies of the attached
notice marked “Appendix.”8 Copies of the notice provided by the Regional Director for
Region 21, after being signed by the Respondent’s authorized representative, shall be posted
by the Respondent immediately upon receipt and maintained for 60 consecutive days in
conspicuous places including all places where notices to employees are customarily posted.
Reasonable steps shall be taken by the Respondent to ensure that the notices are not altered,
defaced, or covered by any other material.
(g) Notify the Regional Director in writing within 20 days from the date of this Order what
steps the Respondent has taken to comply.
Dated: Washington D.C. August 4, 2010
_____________________
Jay R. Pollack
Administrative Law Judge

8 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.”
JD(SF)–31–10
Los Angeles, CA
APPENDIX
NOTICE TO EMPLOYEES
Posted by Order of the
National Labor Relations Board
An Agency of the United States Government
After a hearing at which all sides had a chance to give evidence, the National Labor Relations
Board has found that we violated Federal labor law, Section 8(a)(5) and (1) of the National
Labor Relations Act, as amended, and has ordered us to post and abide by 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 unilaterally discontinue the reserve sick leave benefit or rescind the reserve sick
leave benefit time which, employees accrued from July 1, 2008 to April 17, 2009 without
affording the Union notice and an opportunity to bargain.
WE WILL reinstate the established past practice of conferring a reserve sick leave benefit to
employees.
WE WILL restore the rescinded reserve sick leave benefit time that employees accrued from
July 1, 2008 to April 17, 2009.
WE WILL bargain with the Union, on request, regarding our decisions, and the effects of those
decisions, in ceasing to provide a reserve sick leave benefit to employees and rescinding
reserve sick leave benefit time which employees accrued from July 1, 2008 to April 17, 2009, in
the following appropriate units:
Combined Service, Maintenance, Technical, Skilled Maintenance and Business Office
Clerical Unit Service Unit:
Included: All full-time, regular part-time, and per diem Service, Maintenance,
Technical, Skilled Maintenance, and Business Office employees.
Excluded: All other employees, managers, supervisors, confidential employees,
guards, physicians, residents, central business office employees (whether Facility
based or not) who are solely engaged in qualifying or collection activities or are
employed by another Tenet entity, such as Syndicated Office Systems or Patient
Financial Services, employees of outside registries and other agencies supplying
labor to the Respondent and already represented employees.
Professional Unit
Included: All full-time, regular part-time, and per diem Professional employees.
JD(SF)–31–10
Los Angeles, CA
Excluded: All other employees, managers, supervisors, confidential employees,
guards, physicians, residents, central business office employees (whether Facility
based or not) who are solely engaged in qualifying or collection activities or are
employed by another Tenet entity, such as Syndicated Office Systems or Patient
Financial Services, employees of outside registries and other agencies supplying
labor to the Respondent and already represented employees.
WE WILL make whole those Service Unit and Professional Unit employees who were directly
and indirectly affected, for any loss of earnings and other benefits they may have suffered as a
result of its unlawful conduct in ceasing to provide a reserve sick leave benefit and rescinding
reserve sick leave benefit time which unit employees accrued from July 1, 2008 to
April 17, 2009.
PRIME HEALTHCARE SERVICES-GARDEN
GROVE LLC d/b/a GARDEN GROVE HOSPITAL
AND MEDICAL CENTER
(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.
888 South Figueroa Street, 9th Floor
Los Angeles, California, 90014-5449
Telephone: 213-894-5200 - Hours: 8:30 a.m. to 5 p.m.
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, 213-894 5229.