Holding that a court has discretion to order a default judgment without a hearing if "the allegations in the complaint state a specific, cognizable claim for relief, and the defaulted party had fair notice of its opportunity to object"
Reading Board precedent to require that "when a union claims it has attained majority status and the parties, based on that claim, agree to a Section 9 relationship, the employer must challenge that status within a reasonable period of time (six months), or be bound by its agreement"