Security Services, Inc.

National Labor Relations Board - Board Decisions

Feb 26, 1973

201 N.L.R.B. 1010 (N.L.R.B. 1973)

1010 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
Security Services, Incorporated and Melvin E. Jones.
Case 7-CA-8852
February 26, 1973
SUPPLEMENTAL DECISION AND
ORDER
By CHAIRMAN MILLER AND MEMBERS
FANNING AND PENELLO
On October 26, 1972, Administrative Law Judge
Thomas E . Maher issued the attached Supplemental
Decision I in this proceeding . Thereafter , Respondent
filed exceptions and a supporting 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
authority in this proceeding to a three -member panel.
The Board has considered the record and the
attached Decision in light of the exceptions and brief
and has decided to affirm the rulings , findings,2 and
conclusions of the Administrative Law Judge and to
adopt his recommended Order as modified.
ORDER
Pursuant to Section 10(c) of the National Labor
Relations Act, as amended, the National Labor
Relations Board adopts as its Order the recommend-
ed Order of the Administrative Law Judge and
hereby orders that Respondent, Security Services,
Incorporation, Farmington, Michigan, its officers,
agents, successors, and assigns, shall take the action
set forth in the Administrative Law Judge's recom-
mended Order as herein modified:
1. Add the following subparagraph 1(d) and
reletter the present subparagraphs 1(d) and 1(e) to
1(e) and 1(f).
"(d) Instructing or requesting employees to engage
in surveillance of the union activities of other
employees."
2. Substitute the attached notice for the notice of
the Administrative Law Judge.
1 On March 10, 1972, the Administrative Law Judge ( then known as
Trial Examiner) issued his Decision in which he found that Respondent
violated Sec 8(a)(l) and (3) as alleged in the complaint Thereafter, the
Board in 198 NLRB No. 174, remanded the case for further hearing to
permit Respondent to examine the Charging Party, Melvin E Jones, not
previously called as a witness , pursuant to Rule 43(b) of the Federal Rules
of Civil Procedure At the reopened hearing the Respondent was afforded
full opportunity to cross-examine Jones Thereafter the Administrative Law
Judge issued his Supplemental Decision in which he reaffirmed his findings
and conclusions made in his original Decision concerning the ments of this
case . In doing so, he found it unnecessary to consider the testimony of
Melvin Jones taken at the remand hearing because it did not contradict any
of those findings We agree
2 The Respondent has excepted to certain credibility findings made by
the Administrative Law Judge. It is the Board 's established policy not to
overrule an Administrative Law Judge's resolutions with respect to
credibility unless the clear preponderance of all of the relevant evidence
convinces us that the resolutions were incorrect . Standard Dry Wall
Products, Inc, 91 NLRB 544, enfd 188 F 2d 362 (C A 3). We have carefully
examined the record and find no basis for reversing his findings
APPENDIX
NOTICE TO EMPLOYEES
POSTED BY ORDER OF THE
NATIONAL LABOR RELATIONS BOARD
An Agency of the United States Government
WE WILL NOT unlawfully interrogate our
employees concerning their union membership or
activities.
WE WILL NOT poll our employees to determine
their union preferences.
WE WILL NOT publish, maintain or enforce any
rule prohibiting solicitation by employees without
our prior approval.
WE WILL NOT instruct or request our employees
to engage in surveillance of the union activities of
our other employees.
WE WILL NOT discourage membership in
International Union, United Plant Guard Work-
ers of America, or any other labor organization,
by terminating the employment of our employees
or by thereafter failing and refusing to reinstate
them because they engaged in concerted activities
or union activities.
WE WILL NOT in any other manner interfere
with, restrain, or coerce our employees or unlaw-
fully discriminate against them in the exercise of
the rights guaranteed them by the National Labor
Relations Act.
WE WILL offer reinstatement to Melvin Jones
to his former position or, if that position no
longer exists, to a substantially equivalent posi-
tion, without prejudice to his seniority or other
rights and privileges, dismissing if necessary
anyone hired since his discharge on June 27, 1971,
and we will make him whole for the losses
occurred by him.
All of you, our employees, are free to remain or to
withdraw from, to become or to refrain from
becoming members of International Union, United
Plant Guard Workers of America, or any other labor
organization.
SECURITY SERVICES,
INCORPORATED
(Employer)
Dated By
(Representative) (Title)
We will notify immediately the above-named indi-
vidual, if presently serving in the Armed Forces of
the United States, of the right to full reinstatement,
upon application after discharge from the Armed
201 NLRB No. 148
SECURITY SERVICES , INC. 1011
Forces, in accordance with the Selective Service Act
and the Universal Military Training and Service Act.
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 compli-
ance with its provisions may be directed to the
Board's Office, 500 Book Building, 1249 Washington
Boulevard, Detroit, Michigan 48226, Telephone
313-226-3200.
SUPPLEMENTAL DECISION
STATEMENT OF THE CASE
THOMAS F. MAHER, Administrative Law Judge: Upon a
charge filed on July 27, 1971, by Melvin E. Jones, an
individual, against Security Services, Incorporated, Res-
pondent herein, the Regional Director for Region 7 of the
National Labor Relations Board , herein called the Board,
issued a complaint on behalf of the General Counsel of the
Board on August 27, 1971, alleging violations of Section
8(a)(1) and (3) of the National Labor Relations Act, as
amended (29 U.S.C., Sec. 151, et seq. ), herein called the
Act. In its duly filed answer Respondent , while admitting
certain allegations of the complaint, denied the commis-
sion of any unfair labor practice.
Pursuant to notice a trial was held before me in Detroit,
Michigan, on November 11, 1971, where all parties
appeared, were represented by counsel and afforded full
opportunity to be heard, present evidence and oral
argument , cross-examine witnesses , and file briefs. A brief
was filed by Respondent on December 10, 1971.
Thereafter, on March 10, 1972, I issued my Decision in
which I found Respondent to have violated Section 8(a)(1)
and (3), as alleged. On August 31, 1972 the Board issued a
Decision (198 NLRB No. 174) remanding the case for
further hearing to permit Respondent to cross-examine the
Charging Party, not previously called as a witness.
Pursuant to the order of remand a further hearing was held
before me on October 10, 1972, at which time Respondent
was afforded full opportunity to cross-examine Melvin
Jones . No further witnesses were called as a consequence
of this cross-examination. The filing of further briefs in the
matter was waived.
Upon consideration of the entire record herein, including
the brief filed with me , and specifically upon my
observation of each witness appearing before me ,' I make
the following:
FINDINGS OF FACT AND CONCLUSIONS OF LAW
I. THE BUSINESS OF THE RESPONDENT
Security Services , Incorporated , Respondent herein, is a
Michigan corporation with its principal office and place of
business at Farmington , Michigan , where it is engaged in
providing protective guard services for hire . During the
year ending September 30, 1971, Respondent , in the course
and conduct of its business operations , performed security
services valued in excess of $100 ,000 of which services
valued in excess of $50,000 were performed in Michigan
for designated companies , each of which annually pur-
chased goods valued in excess of $50,000 which are
shipped to the facilities of their respective corporations in
Michigan directly from outside the State of Michigan.
Upon the foregoing admitted facts I conclude and find
that the Respondent is an employer engaged in commerce
within the meaning of Section 2(6) and (7) of the Act.
II. THE LABOR ORGANIZATION INVOLVED
It is stipulated by the parties and I accordingly conclude
and find that International Union, United Plant Guard
Workers of America, herein called the Union, is a labor
organization within the meaning of Section 2(5) of the Act.
III. THE UNFAIR LABOR PRACTICES
A. The Facts
In late June 1971 Melvin Jones, a guard employed by
Respondent , communicated with Dempsey Dillion , region-
al director of the Union , and inquired of the possibility of
organizing Respondent 's employees . At a meeting between
the two thereafter Dillion gave Jones a supply of
application and authorization cards which Jones proceed-
ed to distribute among his fellow employees , enlisting their
membership in the Union .2 What transpired thereafter can
best be detailed by substantial reliance upon the testimony
of Respondent 's executive vice president, Allen Silvarman,
called as a witness by General Counsel.3
On or about July 16 , 1971, Silvarman summoned Melvin
Jones to the office and questioned him at length in the
presence of Alfred Lamb , designated as "Inspector" in the
organization and stipulated to be a supervisor , and Jerome
Silvarman the office manager and brother of Allen
Silvarman . Silvarman stated that Jones was called to the
i I have considered the testimony of all witnesses , including those whose
testimony I neither accept nor refer to. In evaluating the testimony of each
witness I have relied specifically on his demeanor and have made my
findings accordingly . And while, apart from considerations of demeanor, I
have taken into account inconsistencies and conflicting evidence , my failure
to detail each of these is not to be deemed a failure on my part to have fully
considered it. Bishop and Malco, Inc, 159 NLRB 1159,116 1.
Y The credited testimony of Dillion
3 Although considerable of my findings herein are based on Silvarman's
testimony I find it incumbent to qualify the credence I place upon him as a
witness Throughout his testimony Allen Silvarman gave the definite
impression of studied evasion and obfuscation , which on one occasion
required a warning by me, on the record, that a continuation of this pattern
of answer to the questions propounded would not be tolerated . Neverthe-
less, his direct examination , as an adverse witness called by counsel for the
General Counsel under Rule 43(b) of the Rules of Federal Procedure,
developed an abundance of evidence in support of the allegations in the
complaint To the extent, therefore, that portions of Allen Silverman's
testimony constitute admissions against his or Respondent 's interest herein,
and to the further extent that portions of his testimony are corroborated by
the testimony of credible witnesses I shall rely on such portions. The
remainder of his testimony I do not accept as credible.
In view of this reliance upon Silvarman 's testimony I find it unnecessary
to consider the belated testimony of Melvin Jones, taken at the resumed
hearing, none of which I find to contradict any finding herein.
1012 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
office to ascertain, among other things, "If he was or was
not soliciting for people to Join the Union." This activity, it
appears, came to Silvarman's attention through a "discipli-
nary action slip" dated the previous day, July 15, and
signed by Sgt. Gary Furtner. This slip, indicating on its
face the penalty of discharge which was not then carried
out, stated:
Officer was off duty on the Account. Soliciting personel
[sic] for a union for his own gain and profit without
sufficient o.k. from the company.
In conjunction with this disciplinary slip a written report
for the incident was filed with the Company, thus stating,
in part:
Officer was trying to get F & G drivers and Stationaries
at some of the Accts. to sign up for a union without
getting authorization from company ... .
Silvarman, in describing the interview with Jones, stated
that:
We asked him if he knew of anybody who was
soliciting, if he was organizing, and he denied any of
this.
When Jones denied the accusations he was reminded of
past infractions that had been noted in his personnel file
and was told that they expected him to do a good job
henceforth. This ended the interview and Jones continued
in his job, despite the fact that the disciplinary slip had
indicated he was to be discharged. Several days thereafter,
on payday, the employees' paychecks were distributed with
a form attached, stating:
SECRET BALLOT
Check one box only and place in
ballot box
0
0
I want a union at Security
Services
I don't want a union at
Security Services
This was done by Sgt. McNear, pursuant to Silvarman's
instructions. The mechanics of this operation were credibly
described by employee Pauszkiewicz, conveniently identi-
fied throughout the record and in Respondent 's organiza-
tion as Mr. Alphabet. Thus the dispatcher gave him a
ballot to fill out, and when he filled it out he was given his
paycheck. The dispatcher took the ballot and without
looking at it or marking it placed it in a box provided for
the purpose. Upon tallying these ballots Silvarman noted
that Melvin Jones had not complied with the balloting
procedure, having signed his name and failed to indicate a
choice.
About the same time , on July 18, employee Pauszkiewicz
received a call from headquarters while on car patrol. He
I McNear was not called as a witness Silvarman confirmed the incident.
S Silvarman 's version of the overall incident conforms with Pausczkiew-
icz' except the manner in which the liaison with Jones was established. Thus
was instructed to report at 5 p.m. to a new assignment,
North Detroit General Hospital. After he had reported
there he was met by Sgt. McNear. Pauszkiewicz' credited
account of this meeting following: 4
Sgt. McNear told me at this time the men in the
Company were trying to organize the Union, and I
would be approached by a gentleman from our
corporation in regard to joining the Union, and I was
to get all or any information on the man. All cards or
anything that was said. And deliver this to either Sgt.
McNear or Col. Silvarman.
Sgt. McNear then told Pausczkiewicz that it was his job
to do and that he would be fired if he did not do it as
instructed. Accordingly, when Jones approached him later
that evening and asked him to sign a union card
Pausczkiewicz agreed to do so. Jones told him that he did
not keep cards on his person but would bring him a card
the following day. As promised, Jones brought the card to
Pausczkiewicz on July 19, and he signed and returned it.
He also asked and received from Jones three additional
cards, as he had been instructed to do. Then, in accordance
with this instruction he called headquarters and was
directed to return with the information and the blank
cards. Upon his arrival he met with Silvarman, Sgt. Furtner
who had disciplined him earlier, and Inspector Lamb. He
turned the blank cards over to Silvarman who inspected
them and then, returning them instructed him to fill the
cards in with names and addresses he could glean from a
telephone book , using random social security numbers.
Silvarman , by his own admission , filled out one of these
cards in this fashion, saying "See how easy it is?"5 When
asked at the trial why he did this Silvarman replied that
they were interested in finding out where the signed card
would go. Pausczkiewicz credibly testified that Silvarman
instructed him to return the cards to Jones.
At this point in his conversation with Pausczkiewicz
Silvarman told him that the Union had to be stopped from
coming in because if it came in the men would lose
advantages presently enjoyed, and would be required to
pay for their gun training. He then instructed Pausczkiew-
icz to get all the information that he could on Jones, and
expressed the hope that the spurious cards would have the
effect of embarassing Jones with the Union and would
cause it to drop the campaign. Pausczkiewicz actually
turned over 10 cards to the Union and gave Silvarman a
written report of his total activities with respect to the
cards.
On July 26 another employee, John Jones, telephoned to
headquarters from his post at North Detroit General
Hospital and reported that Melvin Jones, the Charging
Party herein, had solicited him to join the Union.
Whereupon the full force of Respondent's investigatory
resources went into action, the final result of which was
Melvin Jones' discharge. A fuller chronology and analysis
of this event brings it into clearer focus.
Employee John Jones, testifying for the Respondent,
stated that on January 25 he was called at home and told
not to report to his regular assignment at 1300 Lafayette
he described Pauszkiewicz, without identifying him, as a volunteer who was
anxious to inform on Jones and help the Company keep the Union out. I do
not credit this version.
SECURITY SERVICES , INC. 1013
Street, but to take a new assignment at the North Detroit
General Hospital where Melvin Jones was regularly
assigned to duty at the main desk on the shift beginning 5
p.m. John Jones' assignment was to begin on the follow-
ing morning. On January 26 Melvin Jones checked in
sometime before 5 p.m., according to John Jones, and he
immediately engaged him in the conversation concerning
the Union , asking him to sign an authorization card.
Shortly thereafter, after 5 p.m., John Jones had occasion to
go to the main desk where Melvin Jones was stationed and
Melvin Jones again brought up the subject of the Union.
Whereupon John Jones returned to his duty station
headquarters .6 Shortly thereafter Sgt. Donald Golden and
Lt. James Butler appeared on the scene , at the direction of
Lamb of headquarters.? Jones repeated his story to the two
supervisors and was told to submit a written report to
headquarters. The supervisors then proceeded to talk with
Melvin Jones and, after verifying the fact that he had
solicited John Jones for the Union, relieved him from duty,
picked up his badge and other equipment and discharged
him. The discharge slip given to Melvin Jones described
the circumstances justifying the discharge as follows:
Interfering with another officer 's dutyes [sic].
In defense of the action taken against Melvin Jones it is
Respondent's contention that he was not discharged for
soliciting for the Union but for interfering with another
officer while on duty. In this respect it distinguishes the
July 26 action of discharge from the July 15 warning to
Jones which did not result in a discharge, but in a warning.
On that previous occasion Respondent claims that Melvin
Jones was reprimanded for violating a company rule
respecting solicitation . The rule read as follows and
appears in the Company's employee manual:
Solicitations and collections for any purpose without
specific approval by commanding officer.8
It seeks thus to distinguish the reasons for the discharge
and the earlier warning. Furthermore Respondent put into
the record documentary evidence of warnings given to
Melvin Jones for other transgressions during his term of
employment.
B. Conclusions
A reading of Silvarman's testimony underscores Respon-
dent's antipathy towards the unionization of its employees
and its determination to thwart it. Thus , as summarized
above , Silvarman has virtually admitted to a variety of the
strategems traditionally used to unlawfully interfere with
employees in the exercise of their rights to self-organization
and to restrain and coerce them.
He called Jones to his office to question him about his
union activity among his fellow guards; specifically asking
him if he was organizing for the Union and who else was
soliciting for the Union. Several days later Silvarman
directed that a ballot be issued canvassing the employees'
6 There is a dispute among Respondent 's witnesses, Jones and Sgt
Donald Golden , and the testimony of Vice President Silvarman on this
subject . Jones testified that he called headquarters in line of duty and
Silvarman testified they received the call , whereas Golden , who appeared on
the scene within a short period of time , emphatically denied headquarters
received a call and insisted that Silvarman was wrong in his testimony I do
not credit Golden and find the call was made.
7 The testimony of Silvarman . John Jones also states that two supervisors
choice for or against the Union; and in Pausczkiewicz'
testimony it is clear that the receipt of paychecks was
conditioned upon the return of such ballot. It is well
established that such interrogation and canvassing of
employees, occurring as it did here in the context of the
Employer's expressed opposition to the Union constitutes
interference, restraint, and coercion to employees which I
conclude and find to violate Section 8(a)(I) of the Act.
In addition Respondent , by Silvarman 's directions to
Pausczkiewicz, conveyed to him by his supervisors (supra),
constituted instructions to spy on Melvin Jones and to
entrap him , and then , by returning to him spurious
authorization cards, to embarrass Jones with the Union
and hopefully discourage it in its campaign to organize the
men. Citation of authority is certainly not necessary to
conclude and find, as I do, that such conduct on
Respondent 's part as I have described constitutes the
grossest form of employee interference , restraint, and
coercion and I, accordingly, further conclude and find that
Respondent has thereby violated Section 8(axl).
In such a context of unlawful activity to destroy the
organizing efforts of Melvin Jones and the Union it can
hardly be suggested that Respondent's rule prohibiting
solicitation was intended for or enforced for the legitimate
purpose of maintaining good order and efficient security
service . The rule, as previously stated , required advanced
company approval of any solicitation. However innocuous
this may appear in isolation , its breadth and the Respon-
dent's expressed motives in enforcing it destroy any
immunity it might otherwise have enjoyed. For this reason
and in the context of its implementation I conclude that
the rule and the Respondent 's enforcement of it by
warning Melvin Jones was a further interference , restraint,
and coercion in violation of Section 8(a)(1).
Melvin Jones was discharged within the week following
his interrogation and reprimand for soliciting in behalf of
the Union. I find the testimony of Vice President
Silvarman to be totally fatuous as it explains and seeks to
justify this action . Not only did he substantially admit to
the bulk of facts upon which I have based the foregoing
findings of violations, but in an effort to justify the
discharge of Melvin Jones he engaged in a pattern of
obfuscation and contradiction that could serve only to
further implicate Respondent in the unlawful conduct
alleged . Jones was believed to be the instigator of the
Union, and he was called in and questioned about it; then
he was warned against a repetition of this activity. A trap
was devised to procure evidence of his activity by
instructing Pausczkiewicz , under threat of discharge, to
obtain from Jones the incriminating union cards, and then
to compromise him with the Union by returning falsely
signed cards.
Finally Respondent set a second trap to implicate Jones
by directing John Jones to be available for solicitation and
together interviewed him and thereafter met with Melvin Jones . I reject
Golden 's testimony to the contrary.
8 Although the rule as it thus appears in the Respondent 's "Official
Officers ' Manual" is grammatically an incomplete sentence , it is to be noted
that in the overall context of the publication the statement appears as an
item of conduct for which a penalty is imposed; in this instance a warning
on the first offense, I week's suspension on the second , and discharge on the
third.
1014 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
then to inform. My finding in this respect I base on
inferences which flow from the general context in which
the event occurred. John Jones denied he was told to seek
out Melvin Jones for this purpose and report into
headquarters, but there is more suspicion than coincidence
to the sequence of Jones' work history at that time: He was
suddenly detailed to work with Melvin Jones, he immedi-
ately had occasion to report him to headquarters, and he
was thereafter reassigned to work in the Company's office,
certainly a more desirable situation. Furthermore, two
supervisors, Golden and Butler, almost immediately
appeared on the scene in answer to John Jones' report and
forthwith discharged Melvin Jones.
Viewed in the light of what had transpired since
Respondent's first suspicion of Melvin Jones' union
activity before June 15, what occurred to him on June 26
when he was discharged, and the manner in which it was
accomplished, permits no other reasonable inference than
that he was discharged because of his union and concerted
activities. This I conclude and find to constitute discrimi-
nation in violation of Section 8(a)(3) of the Act and further
interference, restraint, and coercion of employees in
violation of Section 8(a)(1).
IV. THE EFFECT OF THE UNFAIR LABOR PRACTICES
UPON COMMERCE
The activities of Respondent set forth in section III,
above, occurring in connection with the Respondent's
operations described in section I, above, have a close,
intimate, and substantial relation to trade, traffic, and
commerce among the several States and tend to lead to
labor disputes threatening and obstructing commerce and
the free flow of commerce.
V. THE REMEDY
I have found that Respondent has interfered with,
restrained, and coerced its employees in certain respects,
and that it has discriminately discharged Melvin Jones. I
shall recommend that Respondent cease and desist from
this conduct, and because the nature of the unfair labor
practices committed here are of such gravity as to present a
threat of future violation of the Act I shall recommend that
Respondent cease and desist from in any other manner
interfering with, restraining, or coercing its employees in
the exercise of their statutory rights.
Affirmatively I shall recommend that Respondent
reinstate Melvin Jones to his former position with backpay
to be computed in the customary manner,9 with interest at
the rate of 6 percent per annum,10 and that it post
9 F W Woolworth Company, 90 NLRB 716
10 Isis Plumbing & Heating Co, 138 NLRB 716
11 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
12 In the event that the Board 's Order is enforced by a Judgment of a
appropriate notice of compliance with such Order as the
Board issues.
Upon the foregoing findings of fact, conclusions of law
and the entire record , and pursuant to Section 10(c) of the
Act, I hereby issue the following recommended:
iORDER"
Respondent Security Services, Incorporated, its officers,
agents , successors , and assigns, shall:
1. Cease and desist from:
(a) Unlawfully interrogating its employees concerning
their concerted or union activities or union membership.
(b) Polling their employees to determine their union
preferences.
(c) Publishing , maintaining , and/or enforcing a rule
prohibiting the solicitation by employees for any purpose
without specific approval of Respondent's supervisors or
officials.
(d) Discouraging membership in International Union,
United Plant Guard Workers of America, or any other
labor organization, by terminating the employment of their
employees and thereafter failing and refusing to reinstate
them because they engaged in concerted and union
activities.
(e) In any other manner interfering with, restraining, or
coercing its employees, or unlawfully discriminating
against them in the exercise of rights guaranteed them by
Section 7 of the Act.
2. Take the following affirmative action which it is
deemed will effectuate the policies of the Act:
(a) Offer reinstatement to Melvin E. Jones whom it
terminated and thereafter failed and refused to reinstate,
dismissing, if necessary, any individual hired since June 27,
1971.
(b) Make whole Melvin E. Jones in the manner set forth
in "The Remedy."
(c) Post at its Farmington, Michigan, headquarters, and
wherever else it maintained notices for employees, the
attached notice marked "Appendix." 12 Copies of the
notice on forms provided by the Regional Director for
Region 7, shall, after being duly signed by the Respondent,
be posted immediately upon receipt thereof, in conspicu-
ous places, and be maintained for 60 consecutive days.
Reasonable steps shall be taken to insure that said notices
are not altered, defaced, or covered by any other material.
(d) Notify the said Regional Director, in writing, within
20 days from the receipt of the Administrative Law Judge's
Supplemental Decision, what steps it has taken to comply
therewith.13
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 "
13 In the event that this recommended Order is adopted by the Board
after exceptions have been filed, this provision shall be modified to read
"Notify the Regional Director for Region 7, in writing, within 10 days from
the days of this Order, what steps the Respondent has taken to comply
herewith "