Hahner, Foreman & Harness, Inc.

National Labor Relations Board - Administrative Judge Opinions

Mar 17, 2004

17-CA-022383 (N.L.R.B. Mar. 17, 2004)

JD(ATL)—13—04
Wichita, KS
UNITED STATES OF AMERICA
BEFORE THE NATIONAL LABOR RELATIONS BOARD
DIVISION OF JUDGES
ATLANTA BRANCH OFFICE
HAHNER, FOREMAN & HARNESS, INC.
and CASES 17-CA-22382
17-RC-12206
UNITED BROTHERNOOD OF
CARPENTERS & JOINERS OF
AMERICA, CARPENTERS
DISTRICT COUNCIL OF KANSAS
CITY & VICINITY AND LOCAL 201
Stanley Williams, Esq.,
for the General Counsel.
J. Michael Kennalley, Esq., and
W. Stanley Churchill, Esq.,
for the Respondent.
Angela M. Ford, Esq. and
Michael J. Stapp, Esq., for the
Charging Party.
DECISION
Statement of the Case
LAWRENCE W. CULLEN, Administrative Law Judge: This case was heard
before me on February 3, 2004, in Wichita, Kansas. Following the filing of the Petition
in Case 17-RC-12206 on May 29, 2003, and pursuant to a Stipulated Election Agreement
approved by the Regional Director of the Seventeenth Region of the National Labor
Relations Board (“the Board”) on June 12, 2003, an election by secret ballot was
conducted on July 9, 2003, among the employees in the agreed upon appropriate unit.1
1 All journeymen and apprentice carpenters employed by the Employer within the
Kansas Counties of Barber, Barton, Butler, Chautauqua, Cheyenne, Clark,
Comanche, Cowley, Decatur, Edwards, Elk, Ellis, Ellsworth, Finney, Ford,
Gove, Graham, Grant, Gary, Greeley, Greenwood, Hamilton, Harper, Harvey
Haskell, Hodgeman, Kearner, Kingman, Kiowa, Lane, Logan, Marion,
McPherson, Meade, Morton, Ness, Norton, Osborne, Pawnee, Phillips, Pratt,
Rawlins, Reno, Rice, Rooks, Rush, Russell, Scott, Sedgewick, Seward,
Sheridan, Sherman, Smith, Stafford, Stanton, Stevens, Sumner, Thomas, Trego,
Wallace, and Wichita, but EXCLUDING all other employees, guards and
supervisors as defined by the National Labor Relations Act.
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The tally of ballots shows there were approximately ten eligible voters two (2) of who
cast their ballots for the Petitioner, United Brotherhood of Carpenters & Joiners of
America, Carpenters District Council of Kansas City & Vicinity and Local 201 (“the
Union”) and one (1) of who cast their ballot against the Petitioner. There were no void
ballots and five (5) ballots were challenged.
On November 24, 2003, the Board issued a Decision and Direction in Case 17-
RC-12206, directing that the challenge to the ballot of Fabian Morales be overruled, and
ordering that the procedure be remanded to the Acting Regional Director for a hearing to
resolve the issues raised by the challenges to the ballots of Daniel Caudell and Todd
Stewart.
Upon a charge filed by the Union on September 10, 2003, in Case 17-CA-22382,
on October 29, 2003, a Complaint and Notice of Hearing issued alleging that Respondent
Hahner, Foreman & Harness, Inc. (“the Respondent” or “the employer”) has engaged in
various actions and conduct violative of Section 8(a)(1) of the National Labor Relations
Act (“the Act”). The issues raised by the challenges to the ballots of Daniel Caudell and
Todd Stewart were consolidated by the Acting Regional Director for hearing and decision
with the issues in Case 17-CA-22382. The complaint alleges, Respondent admits and I
find that at all times material herein, Respondent has been a corporation, with an office
and place of business in Wichita, Kansas engaged in the building and construction
industry, that during the 12-month period ending October 31, 2003, Respondent, in
conducting its business operations, purchased and received at its facility, goods valued in
excess of $50,000 directly from points outside the State of Kansas and Respondent has
been an employer engaged in commerce within the meaning of Section 2(2), (6) and (7)
of the Act. The complaint also alleges and Respondent admits and I find that at all
material times the Union has been a labor organization within the meaning of Section
2(5) of the Act. It is further alleged and admitted and I find that David A. Foreman is
President and Bradley L. Oxford is General Superintendent and that at all material times
they have each been supervisors of Respondent within the meaning of Section 2(11) of
the Act and agents of Respondent within the meaning of Section 2(13) of the Act.
The complaint also alleges that on April 10, 2003, Respondent’s employees
Daniel Caudell and Todd Stewart concertedly complained to Respondent regarding the
wages, hours and working conditions of Respondent’s employees, about changes to their
health insurance, pension benefits and wages and on that date Respondent discharged its
employees Daniel Caudell and Todd Stewart because they engaged in the aforesaid
conduct and to discourage employees from engaging in these or other concerted
activities.
At the hearing the parties stipulated to the following facts: Respondent is
engaged in the construction industry as a general contractor for commercial and industrial
buildings. The Union and the Respondent had been parties to successive 8(f) collective
bargaining agreements for over 35 years. The last collective bargaining agreement
between the Union and the Respondent was effective from April 1, 2002 through March
31, 2003, and has been entered in the record as Joint Exhibit 1. Under Article 10 of this
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collective bargaining agreement Respondent paid pension and health and welfare benefits
on behalf of unit employees into funds administered by the Kansas Building Trades also
known as Kansas Construction Trade Funds. The amounts of these contributions are set
forth in Article 12 of the collective bargaining agreement. Thursday, April 10, 2003, was
the last day that Todd Stewart and Daniel Caudell worked for Respondent. The last
project that Stewart and Caudell worked on was the Southwestern Bell project in Derby,
Kansas. It was further stipulated that Robert Dick was both a foreman on this project and
a member of the Carpenters Union as is permitted. At the hearing the General Counsel,
with no objections, amended the complaint to correct the dates appearing in Paragraph
5A and 5B to April 10, 2003.
When the contract expired by its terms on March 31, 2003, the pension obligation
and the health and welfare insurance (health insurance) coverage of the unit employees
ceased. The employees learned of this curtailment of their benefits shortly thereafter.
Employee Daniel Caudell learned of this when he tried to have a prescription for
medicine filled and was told that his insurance was cancelled. He confirmed this by a
telephone call to the Administrator of the Kansas Building Trades Funds. About a week
prior to April 10, 2003, Caudell met with Respondent’s President Dave Foreman to find
out how his benefits would be affected by the expiration of the collective bargaining
agreement. Caudell had worked regularly for Respondent for 20 to 25 years. He had
been subject to periodic layoffs for lack of work when construction was slow but had
worked exclusively for Respondent, as he would be called back to work as work became
available. He was a valued employee and had on occasion served as superintendent on
Respondent’s projects. Foreman assured Caudell that he would not lose anything when
the contract expired. Respondent’s General Superintendent Bradley Oxford also assured
employees including Caudell that they would not suffer any economic harm if the labor
agreement expired and told them that the Respondent would pay the employees the
money it had been paying to the benefit funds.
Following the expiration of the labor agreement most of the unit employees
continued to work for Respondent with the Union’s approval. It was not until early April
that Caudell discovered he no longer had health insurance when he tried to have a
prescription for medicine filled. Employee Todd Stewart also learned of the expiration of
the labor agreement and his loss of health insurance, which was a matter of serious
concern to him as he is a single father with partial custody of his son and he needed
coverage to protect his son in the event of a need for medical care. On April 10, 2003,
employees picked up their paychecks and Caudell found the fringe benefit contributions
were not on his check and his check had not been increased by the amount of the benefit
contributions as he had been assured by Foreman that it would be. Todd Stewart also
found that his check no longer contained the fringe benefit contributions with no
commensurate increase in his pay to compensate for the loss of the fringe benefits.
Caudell asked job superintendent Bob Dick about this. Superintendent Dick told Caudell
he did not know but would check with the office and left the Southwestern Bell jobsite
where they were working to check with management. Later that morning General
Superintendent Brad Oxford arrived at the jobsite and was initially approached by Todd
Stewart who expressed his dissatisfaction with cancellation of his health insurance. The
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conversation between Oxford and Stewart became heated and Caudell joined the
conversation and then began to ask Oxford why his check had not been increased to make
up for the cost of the benefits, which he had previously received. Oxford told Stewart
and Caudell that this was the way it was going to be and if they did not like it, they could
quit. Steward told Oxford he was not going to quit and that Oxford would have to lay
him off if they wanted to get rid of him. Caudell told Oxford that there were three
choices, he could quit, Respondent could lay him off or they could fire him and that he
was not going to quit and if Respondent fired him, he would file a lawsuit. During the
course of this conversation, Caudell told Oxford that if this was the way it was going to
be, alluding to the loss of benefits and no commensurate increase in his paycheck, that he
might not be able to work as fast as he normally did. Steward made a joking comment
that he (Steward) was already going so slow that he did not see how he could slow down
any. Oxford told them that a slowdown would be unacceptable. Oxford testified he then
went to call Foreman on his cell phone and told him that Caudell and Stewart were
threatening to slow down as a result of the loss of benefits. Foreman told Oxford to fire
them. Oxford also told Foreman that Caudell had threatened to sue if he were fired.
Foreman then told Oxford to lay them off and Oxford did so immediately and
sarcastically said “Bye Bye” to them as they left the jobsite. Neither employee has since
been recalled to work. There was a good deal of work available to be performed at the
time as the work on the Southwestern Bell project had just begun.
Analysis
I find that employees Caudell and Stewart were engaged in protected concerted
activities when Caudell joined Steward and commenced to voice his complaints about the
loss of benefits and no commensurate increase in pay for the loss of benefits. Although I
note that Stewart was more upset with the loss of his health insurance which covered his
son, and Caudell appeared more upset about the lack of a commensurate increase in pay
to enable him to purchase health insurance, they essentially joined together to protest the
loss of benefits with the object of recovering the benefits or at least the amount of the
contributions by Respondent to enable them to obtain benefits to replace the coverage
they were losing. Thus they were engaged in protected concerted activities for their
mutual aid and protection. I find they were engaged in protected concerted activities
under Section 7 of the Act. I find that the General Counsel has established a prima facie
case of a violation of the Act by Respondent when it laid off its employees Stewart and
Caudell with no intention of recalling them after they complained to Respondent with a
goal of recovering their benefits. I find that Respondent has failed to rebut the prima
facie case by the preponderance of the evidence. I find the discussion of a slow down by
Caudell and the limited joking comments by Stewart concerning his inability to slow
down were not so egregious as to lose the protection of the Act.
The Board in Meyers Industries (Meyers I), 268 NLRB 493 (1984), remanded
sub. Nom. Prill v. NLRB, 755 F.2d 941 (D.C. Cir. 1985) noted that the concept of
concerted action has its basis in Section 7 of the Act. Section 7 of the Act in pertinent
part states:
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Employees shall have the right to self-organization to form, join, or
assist labor organizations, to bargain collectively through
representatives of their own choosing and to engage in other
concerted activities for the purpose of collective bargaining or
other mutual aid and protection.
The Board pointed out in Meyers I that although the legislative history of Section
7 of the Act does not specifically define concerted activity, it does reveal that Congress
considered the concept in terms of individuals united in pursuit of a common goal. The
Statute requires that the activities under consideration be “concerted” before they can be
“protected.” As the Board observed in Meyers I, “Indeed, Section 7 does not use the
term ‘protected concerted activities’ but only concerted activity.” It goes without saying
that the Act does not protect all concerted activity. With the above, as well as other
considerations in mind, the Board in Meyers I set forth the following definition of
concerted activity:
In general, to find an employee’s activity to be ‘concerted,’ we
shall require that it be engaged in with or on the authority of other
employees, and not solely by and on behalf of the employee
himself. Once the activity is found to be concerted an 8(a)(1)
violation will be found if, in addition, the employer knew of the
concerted nature of the employee’s activity, the concerted activity
was protected by the Act, and the adverse employment action at
issue (e.g., discharge) was motivated by the employee’s protected
concerted activity.
In Meyers Industries (Meyers II), 281 NLRB 882 (1986), enfd. Sub. Nom. Prill
v. NLRB, 835 F.2d 1481 (D.C. Cir. 1987), the Board made it clear that under the proper
circumstance a single employee could engage in concerted activity within the meaning of
Section 7 of the Act. The question of whether an employee has engaged in concerted
activity is a factual one based on the totality of record evidence. See e.g. Ewing v.
NLRB, 861 F.2d 353 (2nd Cir. 1988). The Board has found an individual employee’s
activities to be concerted when they grew out of prior group activity. Every Women’s
Place, 282 NLRB 413 (1986). An employee’s activity will be concerted when he or she
acts formally or informally on behalf of the group. Oakes Machine Corp., 288 NLRB
456 (1988). Concerted activity has been found where an individual solicits other
employees to engage in concerted or group action even where such solicitations are
rejected. El Gran Combo de Puerto Rico, 284 NLRB 1115 (1987), enfd. 853 F.2d 966
(1st Cir. 1988). The Board has long held, however, that for conversations between
employees to be found protected concerted activity, they must look toward group activity
and that mere “griping” is not protected. See Mushroom Transportation Co. v. NLRB,
330 F.2d 683 (3rd Cir. 1964).
In Wright Line, 251 NLRB 1083, enfd. 662 F.2d 899 (1st Cir. 1981), cert. denied
455 U.S. 989 (1982); approved in NLRB v. Transportation Management Corp., 462
U.S. 393 (1983), the Board set forth its causation test for cases alleging violations of the
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Act that turn, as does the case herein, on employer motivation. First the General Counsel
must persuade the Board that antiunion sentiment was a substantial or motivating factor
in the challenged employer conduct or decision. Once this is established the burden then
shifts to the employer to prove its affirmative defense that it would have taken the same
action even if its employee had not engaged in protected concerted activity. See Manno
Electric, Inc., 321 NLRB 278, fn. 12 (1996).
Counsel for the General Counsel must demonstrate by preponderant evidence (1)
that the employee was engaged in protected concerted activity; (2) that the employer was
aware of the activity; (3) that the activity or the workers’ union affiliation was a
substantial or motivating reason for the employer’s action; and (4) there was a causal
connection between the employer’s animus and its discharge decision.
Counsel for General Counsel may meet the Wright Line burden with evidence
short of direct evidence of motivation, i.e., inferential evidence arising from a variety of
circumstances such as union animus, timing or pretext may sustain the General Counsel’s
burden. Furthermore, it may be found that where an employer’s proffered non-
discriminatory motivational explanation is false, even in the absence of direct evidence of
motivation, the trier of fact may infer unlawful motivation. Shattuck Denn Mining
Corp.(Iron King Branch) v. NLRB, 362 F.2d 466, 470 (9th Cir. 1966); Fluor Daniel,
Inc., 304 NLRB 970 (1991). Motivation of union animus may be inferred from the
record as a whole, where an employer’s proffered explanation is implausible or a
combination of factors circumstantially support such inference. Union Tribune Pub. Co.
v. NLRB, 1 F.3d 486, 490-492 (7th Cir. 1993). Direct evidence of union animus is not
required to support such inference. NLRB v. S0-White Freight Lines, Inc., 969 F.2d 401
(7th Cir. 1992).
It is clear as discussed above that Caudell and Stewart were engaged in protected
concerted activity when they voiced their protests to Oxford concerning the loss of their
health insurance and the loss of their retirement and pension benefits and the lack of an
increase in Caudell’s paycheck in the amount the Respondent had been expending on the
health insurance and pension benefits. As the General Counsel notes in his brief, these
two employees were understandably upset by the loss of the benefits and had discussed
the situation with themselves and with other employees. Under these circumstances the
statement by Caudell, an employee of more than 20 years, that if he was to be paid $5
less an hour he might not be able to work as hard as he had been was part of his protest
and was not so egregious as to lose the protection of the Act. Stewart testified that he
(Stewart) stated he did not believe he could work any slower in a joking reference to his
normal rate of speed which was reputed to be slow. However there was no threat made
by Stewart that he would slow down. Only after prolonged testimony on cross-
examination did Oxford testify that Stewart had threatened to slow down. However this
testimony is in conflict with the testimony of Foreman as well as that of Stewart as
Foreman testified that Oxford reported to him that Stewart and Caudell were protesting
their loss of health insurance and benefits and that Caudell had threatened to file a lawsuit
if he were fired and had threatened to slow down. Foreman’s testimony clearly did not
support that of Oxford concerning Stewart’s alleged threat of a slowdown and yet
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Foreman testified he had initially decided to fire Stewart and Caudell but decided to lay
them off instead. Foreman did not testify that he had received any information
whatsoever from Oxford that Stewart had threatened to slow down and yet Foreman
made the decision to lay off Stewart as well as Caudell. This clearly demonstrates that
Caudell and Stewart were laid off because of their protest of the loss of their health and
pension benefits and at least in Caudell’s case the lack of a corresponding increase in his
paycheck to ensure that he not sustain any loss in pay as a result of the loss of health
insurance and pension benefits as both Foreman and Oxford had assured him.
Applying the above-discussed relevant case law to the facts of this case, I find
General Counsel has established prima facie cases of violations of Section 8(a)(1) by the
layoffs of Stewart and Caudell with no prospects of recall by Respondent. Essentially
Respondent discharged Stewart and Caudell as it had no intention of recalling them.
Respondent admittedly termed the action as a layoff rather than a discharge as it
perceived that this might fend off the possibility of a lawsuit which Caudell had
threatened to file if he were discharged. The evidence is uncontroverted that Respondent
discharged Caudell and Stewart because of their engagement in protected concerted
activities when they complained about the loss of benefits. I find that the reference to a
slowdown by Caudell and the limited comment by Steward concerning his inability to
slow down were not so egregious as to lose the protection of the Act. I find that the
Respondent had knowledge of Caudell’s and Stewart’s engagement in protected
concerted activities, and that their discharge was motivated by Respondent’s disdain for
their engagement in the protected concerted activities. I further find that the Respondent
has failed to rebut the prima facie cases by the preponderance of the evidence as it has
not shown that it would have discharged them in the absence of their engagement in
protected concerted activities. I find that the discussion of a possible slowdown by
Caudell and Stewart was not so egregious as to cause them the loss of the protection of
the Act. I also find that there was ample work available at the time of their discharge.
Wright Line, supra.
Conclusions of Law
1. Respondent is an employer within the meaning of Section 2(2), (6) and (7)
of the Act.
2. The Union is a labor organization within the meaning of Section 2(5) of
the Act.
3. Respondent violated Section 8(a)(1) of the Act by discharging Daniel
Caudell and Todd Stewart.
4. The above unfair labor practices in conjunction with Respondent’s status
as an employer affect commerce within the meaning of Section 2(2), (6) and (7) of the
Act.
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The Remedy
Having found that Respondent has violated Section 8(a)(1) of the Act, it shall be
ordered to cease and desist therefrom and to take certain affirmative actions designed to
effectuate the policies of the Act.
Respondent having discriminately discharged Daniel Caudell and Todd Stewart,
shall be ordered to offer them reinstatement to their former positions, or if those positions
no longer exist, to substantially equivalent positions and make them whole for any loss of
earnings and benefits they sustained as a result of the unlawful discrimination against
them less any net interim earnings, as prescribed in F. W. Woolworth Co., 90 NLRB 289
(1950), plus interest as computed in New Horizons for the Retarded, 283 NLRB 1173
(1987).
On these findings of fact and conclusions of law and on the entire record, I issue
the following recommended:2
ORDER
Respondent Hahner, Foreman & Harness, Inc., its officers, agents, successors, and
assigns shall:
1. Cease and desist from:
(a) Unlawfully discharging employees because of their engagement in
protected concerted activities.
(b) In any like or related manner interfering with, restraining, or
coercing employees in the exercise of the rights guaranteed them under Section 7 of the
Act.
2. Take the following affirmative actions:
(a) Rescind the discharges of employees Daniel Caudell and Todd
Stewart.
(b) Within 14 days from the date of this Order, offer Daniel Caudell
and Todd Stewart full reinstatement to their former jobs, or if those jobs no longer exist,
to substantially equivalent positions without prejudice to seniority or any other rights or
privileges previously enjoyed. Make Daniel Caudell and Todd Stewart whole for any
loss of earnings and other benefits suffered as a result of the discrimination against them
in the manner set forth in The Remedy section of this decision.
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.
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(c) Within 14 days from the date of this Order, remove from its files
any reference to the unlawful discharges and within 3 days thereafter notify the
employees in writing that this has been done and that the warnings and discharges will
not be used against them in any way.
(d) Preserve and, within 14 days of a 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 an electronic copy of the records if stored in electronic form, necessary to
analyze the amount of backpay due under the terms of this Order.
(e) Within 14 days after service by the Region, post at its facility in
Wichita, Kansas copies of the attached notice marked “Appendix.”3 Copies of the notice,
on forms provided by the Regional Director for Region 17, 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. 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 employers employed by the Respondent at any time since
March 2003.
(f) 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.
As I have found that employees Daniel Caudell and Todd Stewart were
unlawfully discharged and have ordered their reinstatement I find the challenges to their
ballots should be and they hereby are Dismissed. I order also that Case 17-RC-12206 be
severed from Case 17-CA-22382 and remanded to the Regional Director of Region 17 for
a tally of the Ballots and the certification of the results of the election.
Dated at Washington, D.C.
_______________________
Lawrence W. Cullen
Administrative Law Judge
3 If this 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 JUDGMENT OF THE UNITED STATES
COURT OF APPEALS ENFORCING AN ORDER OF THE NATIONAL LABOR
RELATIONS BOARD.”
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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 discharge or otherwise discriminate against employees who engage in
protected concerted activities.
WE WILL NOT in any like or related manner interfere with you in the exercise of your
rights under the National Labor Relations Act.
WE WILL rescind the unlawful discharges of Daniel Caudell and Todd Stewart.
WE WILL offer Daniel Caudell and Todd Stewart reinstatement to their former jobs, or,
if those jobs no longer exist, to substantially equivalent jobs with all the rights and
privileges previously enjoyed by them.
WE WILL make them whole in the manner set forth in The Remedy provisions of this
Decision from the dates of their discharges until the date of a valid offer of employment
or reinstatement.
WE WILL expunge from our files any reference to the unlawful warnings and
discharges and notify them in writing that this has been done and that these personnel
actions will not be used against them in any manner.
HAHNER, FOREMAN & HARNESS, INC.
(Employer)
Dated By
(Representative) (Title)
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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
8600 Farley St., Ste. 100, Overland Park, KS 66212-4677.
(913) 967-3000, Hours: 8:15 a.m. to 4:45 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, (817) 978-2925.