Local 585 (Ernest W. Hann, Inc.)

National Labor Relations Board - Board Decisions

Dec 16, 1969

180 N.L.R.B. 364 (N.L.R.B. 1969)

364 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
Southern California District Council of Laborers and
Laborers International Union of North America
Local 585 (Ernest W. Hahn, Inc. and Masonry
Builders, Inc.) and Ernest W. Hahn , Inc. Case
3l-CD-35
December 16, 1969
DECISION AND ORDER
BY CHAIRMAN MCCULLOCH AND MEMBERS
JENKINS AND ZAGORIA
On August 27, 1969, Trial Examiner Maurice
Alexandre issued his Decision in this proceeding,
finding that Respondents had engaged in and were
engaging in certain unfair labor practices and
recommending that they cease and desist therefrom
and take certain affirmative action, as set forth in
the attached Trial Examiner's Decision. Thereafter,
Respondents filed exceptions to the Trial Examiner's
Decision, and a supporting brief, and the Charging
Party filed an answering brief.
Pursuant to the provisions of Section 3(b) of the
National Labor Relations Act, as amended, the
National Labor Relations Board has delegated its
powers in connection with this case to a
three-member panel.
The Board has reviewed the rulings of the Trial
Examiner at the hearing and finds that no
prejudicial error was committed. The rulings are
hereby affirmed. The Board has considered the Trial
Examiner's Decision, the exceptions and briefs, and
the entire record in this proceeding, and hereby
adopts the findings,' conclusions, and
recommendations of the Trial Examiner, except as
modified herein.
ORDER
Pursuant to Section 10(c) of the National Labor
Relations Act, as amended, the National Labor
Relations Board hereby adopts as its Order the
Recommended Order of the Trial Examiner, as
modified herein, and orders that Respondents,
Southern California District Council of Laborers
and Laborers International Union of North
America Local 585, their officers, agents,
successors , and assigns , shall take the action set
forth in the Trial Examiner's Recommended Order,
as so modified.
1. Delete from the fourth line of paragraph 1 of
the Trial Examiner's Recommended Order the
words "Masonry or any other employer," and
substitute therefor the words "or masonry" at the
'In adopting the Trial Examiner 's finding that all parties to the dispute
had agreed to be bound by the determination of the National Joint Board
for Settlement of Jurisdictional Disputes , the Board relies on its prior
decisions in Electrical Workers Local 26, etc. (McCloskey & Co ). 147
NLRB 1498, and Local No 825, International Union of Operating
Engineers . AFL-CIO ( Burns & Roe. Inc.). 162 NLRB 1617.
Esplanade Mall project.
2. Delete from the fifth line in the indented
paragraph of both Appendices A and B attached to
the Trial Examiner's Decision the words "Masonry
Builders, Inc., or any other employer," and
substitute therefor the words "or Masonry Builders,
Inc." at the Esplanade Mall project.
TRIAL EXAMINER'S DECISION
MAURICE ALEXANDRE, Trial Examiner: This case was
heard in Ventura, California on July 8, 1969, upon a
complaint issued on May 28, 1969,' alleging that
Respondents had violated Section 8(b)(4)(ii)(D) of the
National Labor Relations Act, as amended. In their joint
answer, the Respondents denied the commission of the
alleged unfair labor practices.
Upon the entire record, my observation of the
witnesses, the brief filed by the General Counsel, and the
joint brief filed by Respondents, I make the following:
FINDINGS AND CONCLUSIONS'
THE UNFAIR LABOR PRACTICES
A. The Evidence
Ernest W Hahn, Inc. (Hahn), a California corporation
with its principal office located in Hawthorne, California,
is a general contractor engaged in the building and
construction industry. For some time, Hahn has been
engaged as general contractor in certain construction work
at a project known as The Esplanade Mall in Oxnard,
California. Hahn employs both laborers and carpenters at
the project. A number of the laborers, possibly a majority,
are members of Respondent Local 585. By contracts dated
December 20, 1968, and January 10, 1969,' Hahn
subcontracted certain masonry work on the project to
Masonry Builders, Inc. (Masonry), a California
corporation with its principal office located in Los
Angeles, California. In performing its work under the
subcontracts, it has been necessary for Masonry to erect
and dismantle scaffolding exceeding 14 feet in height.
Prior to the execution of these subcontracts, i.e. in
September 1968, a prejob conference was held at which
those present included Clouse (Hahn 's general
superintendent), Arellano (business agent for Respondent
Local 585), and Southerland (a representative of the
Carpenters Union). During the conference, Southerland
stated that 14 foot scaffolding was the work of the
Carpenters Union, and asked whether Hahn, as general
contractor, would see to it that such work was given to
that union. Clouse replied that that matter should be
discussed with the subcontractor because "scaffolding was
not part of our contract." I interpret this to mean that
such work had been subcontracted to Masonry.
'Based upon a charge filed on March 18, 1969 , by Ernest W. Hahn, Inc
'The complaint alleged and the answer admitted facts which, I find,
establish that Masonry Builders, Inc. and Ernest W . Hahn, Inc. (the
employers involved herein), and Mason Contractors' Exchange of Southern
California, Inc. (an employer 's association to which Masonry belongs), are
engaged in interstate commerce or in operations affecting commerce within
the meaning of Sections 2(6) and (7) and 8(b)(4) of the Act I further find
that Respondents are labor organizations within the meaning of the Act
'All dates referred to hereafter relate to 1969 unless otherwise stated
1180 NLRB No. 73
LOCAL 585 (ERNEST W. HAHN, INC.)
Subsequent to the execution of the above-mentioned
contracts, i.e. on February 12, 1969, a general job
conference was held. After it ended, a number of
individuals held a meeting of their own. These included
Clouse, Masonry President Rembac, and three
representatives of the Carpenters Union, Southerland,
Olson and Howard. Howard stated that the Carpenters
Union had been unable to come to any agreement with
the Laborers, presumably Respondents, regarding the
scaffolding work, and intended to request a decision from
the Joint Board.' He then added that he had no doubt that
the work would be awarded to the Carpenters Union, and
that that union intended to do the work if it received the
award. As the meeting was ending, those present were
joined by Local 585 Business Agent Arellano, Espinoza
(Field Representative for Respondent District Council),
and Flores (another representative of the District
Council). Rembac asked Espinoza if there was any reason
why Masonry should not proceed with the job using
Laborers on the scaffolding.'
By letter dated February 19, 1969, and addressed to
Hahn and Masonry, the Joint Board stated that it had
been advised of a jurisdictional dispute between the
Carpenters Union and the Laborers International Union
of North America respecting the erection and dismantling
of scaffolding over 14 feet in height at the Esplanade
project, and requested a complete description of the work
in dispute. By letter dated March 7, 1969, and addressed
to the president of the Carpenters Union, to the president
of the Laborers International Union of North America, to
Hahn, and to Masonry, the Joint Board stated that it had
voted to assign the work in dispute to the Carpenters
Union.
On the morning of March 12, Clouse received a
telephone call from Southerland of the Carpenters Union
who asked what Hahn intended to do about the award.
Clouse replied that he would have to return Southerland's
call after he discussed the matter with his superiors.
Clouse then talked to one Mojay, a representative of
Masonry, and after being advised that the latter knew of
the award, asked whether Mojay intended to assign the
scaffolding work to the Carpenters Union. Mojay replied
that Masonry had a contract with "the Laborers, Hod
Carriers and with his Association", but not with the
Carpenters Union, and could not give the work to the
latter. Clouse then telephoned Espinoza. According to
Clouse, the conversation was as follows:
A. I asked for Felix Espinoza, and a girl called him.
I said, "Felix," and he said, "Yes", and I introduced
myself as being Dick Clouse with Ernest Hahn, and
asked if he was aware of the decision of the National
Joint Board as far as the scaffolding goes with the
Esplanade.
And he said that he was. He did not recognize it. He
said they were not bound by the decision, as they had
been suspended.
And I asked him that, if in the event that Ernest
Hahn removed the scaffolding portion of the work from
the contractors, Masonry Building , and we used our
carpenters, what would be the position of the Laborers.
And he told me that he would remove all the
Laborers from the job and file charges with the
'Officially known as National Joint Board for Settlement of
Jurisdictional Disputes, Building and Construction Industry.
'Espinoza ' s reply as shown by the transcript of testimony appears
somewhat garbled.
365
National Labor Relations Board to get the money that
was due to the Laborers that had entailed the
scaffolding.
Q. Was anything else further said in this
conversation?
A. I don't believe so.
According to Espinoza, the conversation was as follows:
A. Well, he asked me what was the decision of the
Council if he changed the assignment from the brick
tenders to the Carpenters.
I told him that he had no right to make changes in
assignment, as the brick tenders were not on his payroll
- we were on his payroll, Builders' payroll.
And if he made the change in assignment, the brick
tenders were liable to go to the National Labor
Relations Board and file for lost wages
Q. Is this all you recall of the conversation, or was
there anything more?
A. No, I don' t recall.
B. Concluding Findings
Section 8(b)(4) of the Act provides that it shall be an
unfair labor practice for a labor organization or its agents:
(ii) to threaten, coerce or restrain any person
engaged in commerce or in an industry affecting
commerce, where . . . an object thereof is.
* * * * *
(D) forcing or requiring any employer to assign
particular work to employees in a particular labor
organization or in a particular trade, craft, or class
rather than to employees in another labor
organization or in another trade, craft or class ... .
The General Counsel contends that Hahn, Masonry, the
Respondents and the Carpenters Union were contractually
bound to submit the jurisdictional dispute over the
scaffolding work to the Joint Board for adjustment;' that
since the Joint Board awarded the work to the Carpenters
Union, Respondents were not entitled to seek that work
by methods prohibited by Section 8(b)(4)(D); and that
Espinoza's warning to Clouse, that he would remove all
laborers from the jobsite if the scaffolding work were
assigned to the Carpenters Union in compliance with the
award, constituted a threat proscribed by Section
8(b)(4)(ii)(D).
Since it is not disputed that both the Carpenters Union
and the Respondents claimed the scaffolding work, I find
that a jurisdictional dispute over such work existed.
Respondents contend, however, that they did not violate
the above Section for several reasons: (1) neither they nor
Masonry were bound to submit the dispute to the Joint
Board; (2) they made no threats; (3) assuming a threat to
Hahn, it was not for a prohibited object; and (4) the
General Counsel has failed to prove the allegation in the
complaint that Hahn and/or Masonry refused to abide by
the Joint Board's award as a result of a threat by
Espinoza. I agree with the General Counsel.
1. At the hearing, the parties stipulated that at all times
material, Hahn was a member of Southern California
'Absent such an agreement , the complaint would be subject to dismissal
inasmuch as there is nothing to show that the National Labor Relations
Board has made a jurisdictional award in a proceeding under Section 10(k)
of the Act
366 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
Chapter of the Associated General Contractors of
America (AGC) and, as such, was bound by two
collective-bargaining agreements entered into by AGC.
One was with Respondent District Council acting on
behalf of itself and its affiliated locals;' the other was with
the United Brotherhood of Carpenters and Joiners of
America, acting for its affiliated District Councils and
local unions in Southern California.' Article IV, Section E
of the agreement with Respondent District Council
provides that all jurisdictional disputes between said
Respondent (or any of its locals bound by the agreement)
with any other union affiliated with the Building and
Construction Trades Department, AFL-CIO, "shall be
determined" in the manner and by the procedure
established by the Joint Board, and that determinations by
that Board "shall be binding upon and accepted" by the
parties to the agreement. Article I, Section 304 of the
agreement with the Carpenters Union contains a
substantially similar provision relating to jurisdictional
disputes between that union and any other union affiliated
with the Building and Construction Trades Department,
AFL-CIO. The agreement with Respondent District
Council further provides (Article I, Section C.2) that if an
employer bound thereby enters into a subcontract,
provision "shall be made in such subcontract ... for the
observance by said subcontractor and his subcontractors
of all the terms of this agreement." Article I, Sections
103.3 and 103.4 of the agreement with the Carpenters
Union contain substantially similar provisions. In Section
25 of their subcontracts, Hahn and Masonry agreed to:
Comply with all terms and conditions of the Labor
Agreement between the Associated General Contractors
and A.F. of L. Building & Construction Trades Unions
now in existence and any revision or extension thereof.
It is clear from the above contractual provisions that
Hahn, Masonry, Respondents and the Carpenters Union
had all agreed upon a method for the voluntary
adjustment of jurisdictional disputes, i e. a determination
by the Joint Board. International Association of Bridge.
Structural and Ornamental Iron Workers, Local Union
No. 25, AFL-CIO (Pittsburgh Plate Glass Co.), 125
NLRB 1035; United Brotherhood of Carpenters and
Joiners of America, AFL-CIO, Local No. 753 (Blount
Bros. Corporation). 177 NLRB No. 81. Although
Respondents make a contrary contention in their brief, it
consists of nothing more than a bald assertion without
supporting argument or citation of authority. I am aware
of no basis for their contention.
2. There is no evidence and no contention that
Respondents at any time threatened Masonry. I find,
however, that Espinoza did threaten Hahn. Based on the
nature of the testimony given by Clouse and Espinoza as
well as their demeanor, I reject Espinoza's version of their
telephone conversation of March 12 and credit Clouse's
version, i.e., that Espinoza stated that he would remove all
the laborers from the Esplanade project if Hahn
'The exact name of the contracting union was "Southern California
District Council of Laborers, affiliated with the international Hod
Carriers, Budding and Common Laborers ' Union of America, in behalf of
itself and in behalf of its affiliated Local Unions which have jurisdiction
over the work in the territory hereinafter described, all affiliated with the
Building and Construction Trades Department of the American Federation
of Labor and Congress of Industrial Organization."
11 take official notice that the Carpenters Union is affiliated with the
Building and Construction Trades Department , AFL-CIO. U.S. Dept. of
Labor, Bureau of Labor Statistics , "Directory of National and
International Labor Unions in the United States, 1967", Bulletin No
1596, p. 5.
reacquired the scaffolding work and assigned it to the
Carpenters Union. Espinoza did not expressly deny the
statement attributed to him by Clouse and testified that
apart from informing Clouse that he would go to the
National Labor Relations Board and file for lost wages,
he could not recall whether he said anything else.
I further find that Espinoza's warning was a threat
within the meaning of Section 8(b)(4)(ii). Respondents'
contention that the remark, even if made, was merely the
answer to a hypothetical question is unconvincing. The
warning clearly conveyed Espinoza's intention to call a
strike of all laborers at the project, including those
employed by Hahn, if the scaffolding work were assigned
to the Carpenters Union. Such a threat was no more
hypothetical than those found unlawful in the Blount case,
supra, and in the McCloskey case, infra
3. Respondents assert that assuming a threat to Hahn,
its object could not have been to force or require Hahn to
assign the scaffolding work to Laborers rather than
Carpenters, because it was the work of Masonry's
employees and Hahn had no employees performing that
work. They further assert that absent a threat to
Masonry, Respondents cannot be regarded as having
intended to force or require Masonry to make any
assignment of the disputed work. Finally, Respondents
argue that Masonry needed no coercion and voluntarily
intended to assign the work to Laborers.
It is clear that an object of Espinoza's threat to Clouse
was to prevent Hahn from seeking to reacquire the
scaffolding work from Masonry and then assigning it to
Carpenters, in accordance with the award of the Joint
Board , rather to Laborers. Forcing or requiring an
employer to assign disputed work to one union, and
preventing an employer from reacquiring and assigning
the work to another union, are merely different sides of
the same coin . It follows, and I find, that an object of the
threat to Hahn was to exert upon Hahn the type of force
prohibited by Section 8(b)(4)(ii)(D).
I further find that another object of the threat was to
prevent Hahn from exerting pressure upon Masonry to
comply with the Joint Board award. It cannot be assumed
that Masonry would necessarily have resisted pressure
from Hahn. Thus, it is reasonable to conclude that by
threatening Hahn, Respondents indirectly sought to
prevent Masonry from changing its mind and honoring
the Joint Board award. I therefore find that an object of
the threat to Hahn was to exert upon Masonry the type of
force prohibited by the above Section. Although the
threatened employer (Hahn) and the assigning employer
(Masonry) were different, the statute does not require that
they be one and the same . Local Union's 272, etc.
(Prestress Erectors, Inc. ). 172 NLRB No. 19
(Supplemental TXD, fn. 24); Electrical Workers Local
26, etc. (McCloskey & Co.). 147 NLRB 1498; cf. Local
450, International Union of Operating Engineers v.
Elliott, 256 F.2d 630 (C.A. 5); United Brotherhood of
Carpenters and Joiners, etc., Local No. 753 (Blount Bros.
Corporation), 175 NLRB No. 81.
In sum , I find that an object of Espinoza's threat was
to force or require Hahn and/or Masonry, whichever did
or would control the disputed work, to assign it to
employees represented by Respondents rather than to
employees represented by the Carpenters Union.
4. Respondents contend that Masonry's decision to
disregard the Joint Board' s decision was made
independently of any threat by Respondents, and that
there was no reason for Hahn to abide by that decision
because the scaffolding work was not part of its contract.
LOCAL 585 (ERNEST W. HAHN, INC.)
Accordingly, Respondents assert, the General Counsel has
failed to prove the allegation in the complaint that
Espinoza's threat caused Hahn and/or Masonry to refuse
to abide by the Joint Board's decision. The difficulty with
this contention, which I reject, is that Section
8(b)(4)(ii)(D) does not require proof that a threat is
successful. It only requires proof of a threat for a
proscribed object. The record here establishes such a
threat. It is thus unnecessary to resolve the question
whether the General Counsel has proved the allegation in
question, and I do not reach that question.
5. There is no doubt, and I find, that Respondent
District Council is chargeable with the unlawful threat by
Espinoza, since he is admittedly an agent of the Council'
In agreement with the General Counsel, I further find that
the threat is also attributable to Respondent Local 585.
It is true that Espinoza, a Field Representative for
Respondent District Council, was not a member of
Respondent Local 585. The record shows, however, that
Respondents had jointly executed a collective-bargaining
agreement with Mason Contractors' Exchange of
Southern California, Inc., an employer's association, and
that Masonry was admittedly bound thereby by virtue of
its membership in that association.10 That agreement
provided that scaffolding was the work of laborers
(Section A of Article X). It also contained a
union-security provision requiring employees covered by
the agreement to become members of Respondent Local
585 within a prescribed time (Section D of Article II.)
The record further shows that Arellano, a representative
of Local 585, attended the conferences in September 1968
and on February 12, 1969, when the issue of scaffolding
work was raised, and that Espinoza attended the latter
conference. Finally, Espinoza admitted that during his
telephone conversation with Clouse, he stated that Hahn
had no right to change the assignment of the scaffolding
work, since the brick tenders, i.e., those for whom he
claimed such work, were employees of Masonry.
These considerations lead me to conclude, and I find,
that when Espinoza made his threat to Hahn, he was
seeking to protect the interests of Local 585 as well as
those of the District Council. It is apparent from his
warning to Clouse that Espinoza was claiming the
scaffolding work for laborers pursuant to the agreement
entered into jointly by both Respondents with Masonry.
But more than that, in view of the union-security
provision in the agreement, Espinoza's threat constituted
an effort to protect Local 585's interest in obtaining the
disputed work for laborers who would subsequently
become members of, or at least pay dues to, Local 585.
And since many, if not a majority, of the laborers
employed by Hahn at the Esplanade project were
members of Local 585, Espinoza's threat to remove all the
laborers from the project constituted a threat of a strike
by Local 585. I accordingly find that Espinoza's conduct
is attributable, not only to Respondent District Council,
but also to Respondent Local 585; and that since it was
for an object proscribed by Section 8(b)(4)(ii)(D), both
Respondents were guilty of unfair labor practices within
the meaning of that Section.
'The parties so stipulated at the hearing.
'.Ibid.
CONCLUSIONS OF LAW
367
1. By threatening , coercing or restraining Hahn with an
object of forcing Hahn and/or Masonry to assign the
disputed work to employees represented by Respondents
rather than to employees represented by the Carpenters
Union , Respondents engaged in unfair labor practices
within the meaning of Section 8(b)(4)(ii )(D) of the Act.
2. The aforesaid unfair labor practices affect commerce
within the meaning of Sections 2(6) and (7) of the Act.
THE REMEDY
I recommend that Respondents be ordered to cease and
desist from their unfair labor practices and to take the
affirmative action set forth below which, I find, is
designed to effectuate the policies of the Act.
RECOMMENDED ORDER
Respondent District Council and Respondent Local
585, their respective officers, agents, successors and
assigns, shall:
1. Cease and desist from threatening, restraining, or
coercing Hahn or any other employer or person engaged
in commerce or in an industry affecting commerce where
an object thereof is to force or require Hahn, Masonry or
any other employer to assign the work of erecting or
dismantling scaffolding 14 feet or more in height to
employees represented by Respondents rather than to
employees represented by the Carpenters Union or any
other labor organization, except insofar as any such action
is permitted under Section 8(b)(4)(ii)(D) of the Act.
2. Take the following affirmative action:
(a) In the case of Respondent District Council, post
copies of the attached notice marked "Appendix A", and
in the case of Respondent Local 585, post copies of the
attached notice marked "Appendix B." Such notices shall
be posted by the respective Respondents in conspicuous
places, in their respective business offices and meeting
halls and other places where they customarily post notices
to its members." Copies of said notices, on forms
provided by the Regional Director for Region 31, after
being duly signed by the authorized representatives of
Respondents, shall be posted by the Respondents, as
aforesaid, immediately upon receipt thereof, and be
maintained for 60 consecutive days thereafter. Reasonable
steps shall be taken by the Respondents to insure that said
notices are not altered, defaced, or covered by any other
material.
(b) Notify the Regional Director for Region 31, in
writing, within 20 days from the receipt of this Decision,
what steps the Respondents have taken to comply
herewith.' r
"In the event that this Recommended Order is adopted by the Board,
the words "a Decision and Order" shall be substituted for the words "the
Recommended Order of a Trial Examinee' in the notice . In the further
event that the Board 's Order is enforced by a decree of the United States
Court of Appeals, the words , "a Decree of the United States Court of
Appeals, Enforcing an Order" shall be substituted for the words "A
Decision and Order."
"In the event that this Recommended Order is adopted by the Board,
this provision shall be modified to read : "Notify said Regional Director, in
writing, within 10 days from the date of this Order, what steps
Respondents have taken to comply herewith."
368 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
APPENDIX A
NOTICE TO ALL MEMBERS
Pursuant to the Recommended Order of a Trial
Examiner of the National Labor Relations Board and ►n
order to effectuate the policies of the National Labor
Relations Act, as amended, we hereby notify you that:
WE WILL NOT threaten, coerce or restrain Ernest W.
Hahn, Inc. or any other employer or person engaged ►n
commerce or ►n any industry affecting commerce where
an object thereof is to force or require Ernest W. Hahn,
Inc., Masonry Builders, Inc., or any other employer to
assign the work of erecting or dismantling scaffolding
14 feet or higher to employees represented by Southern
California District Council of Laborers or by Laborers
International Union of North America, Local 585,
rather than to employees represented by the Carpenters
Union or by any other labor organization , except
insofar as such action is permitted by Section
8(b)(4)(ii)(D) of the Act.
SOUTHERN CALIFORNIA
DISTRICT COUNCIL OF
LABORERS
(Labor Organization)
Dated By
(Representative ) (Title)
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.
If members have any question concerning this notice or
compliance with its provisions, they may communicate
directly with the Board's Regional Office, Federal
Building , Room 12100, 11000 Wilshire Boulevard, Los
Angeles, California 90024, Telephone 824-7357.
APPENDIX B
NOTICE TO ALL MEMBERS
Pursuant to the Recommended Order of a Trial
Examiner of the National Labor Relations Board and ►n
order to effectuate the policies of the National Labor
Relations Act, as amended, we hereby notify you that:
WE WILL NOT threaten, coerce or restrain Ernest W.
Hahn, Inc. or any other employer or person engaged ►n
commerce or in any industry affecting commerce where
an object thereof is to force or require Ernest W. Hahn,
Inc., Masonry Builders , Inc., or any other employer to
assign the work of erecting or dismantling scaffolding
14 feet or higher to employees represented by
Southern California District Council of Laborers or by
Laborers International Union of North America, Local
585, rather than to employees represented by the
Carpenters Union or any other labor organization,
except insofar as such action is permitted by
Section 8(b)(4)(ii)(D) of the Act.
Dated By
LABORERS
INTERNATIONAL UNION
OF NORTH AMERICA
LOCAL 585
(Labor Organization)
(Representative) (Title)
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.
If members have any question concerning this notice or
compliance with its provisions, they may communicate
directly with the Board ' s Regional Office, Federal
Building , Room 12100, 11000 Wilshire Boulevard, Los
Angeles, California 90024, Telephone 824-7357.