Teamsters Local 952 (Westside Material)

National Labor Relations Board - Board Decisions

Jul 8, 1985

275 N.L.R.B. 1001 (N.L.R.B. 1985)

TEAMSTERS LOCAL 952 (WESTSIDE MATERIAL)
General Truck Drivers , Office, Food & Warehouse,
Local 952, International Brotherhood of Team-
sters, Chauffeurs , Warehousemen and Helpers
of America and Westside Building Material
Corporation; Martin Brothers Plastering Co.
Case 21-CD-525 --
8 July 1985
DECISION AND DETERMINATION OF
DISPUTE
BY CHAIRMAN-DOTSON AND MEMBERS
HUNTER AND DENNIS
The charge in this Section 10(k) proceeding was
filed 31 October 1984 by Westside Building Materi-
al Corporation (Westside) and Martin Brother:,
Plastering Co. (Martin Brothers), jointly the Em-
ployers, alleging that General Truck Drivers,
Office, Food & Warehouse, Local 952, Internation-
al Brotherhood of Teamsters, Chauffeurs, Ware-
housemen and Helpers of America (Teamsters 952)
violated Section 8(b)(4)(D) of the National Labor
Relations Act by engaging in -proscribed activity
with an object of forcing the Employers to assign
certain work to employees it represents rather than
to employees represented by Laborers' Local 300,
Laborers'. International Union of North America,
AFL-CIO (the Laborers). The hearing was held 3,
14, and 18. January 1985 before Hearing Officer
Rebecca G. Torres.
The Board affirms the hearing officer' s rulings,
finding them free from prejudicial error. On -the
entire record, the Board makes the following find-
ings.
1. JURISDICTION
•Westside, a California corporation, is engaged in
the construction industry as a supplier of building
materials with a facility in Anaheim, California,
where it annually purchases and receives goods
valued in excess of $50,000 directly from suppliers
located outside the State of California. • Martin
Brothers, a California corporation, is engaged in
the plastering. business in the construction -industry
with a facility in Gardena, California; where it an-
nually purchases goods valued in excess of,$50,000
directly from suppliers located outside the State of
California. The parties stipulate , and we find, that
the Employers are engaged in commerce within
the meaning of Section 2(6) and (7) of the Act and
that Teamsters 952 and the Laborers are labor or-
ganizations within the meaning of Section 2(5) of
the Act.
II. THE DISPUTE
1001
A. Background
PCL is the general contractor of the Citicorp
jobsite -located at Seventh and Figueroa Streets,
Los' Angeles, California (herein called Citicorp job-
site or project). Martin Brothers is the drywall sub-
contractor for PCL at that site for the erection of
drywall and related materials in the elevator shafts
and corridors of the building. Since Martin Broth-
ers began work at the Citicorp project it has uti-
lized Westside as its supplier for the delivery and
stocking of drywall. "Stocking" drywall is the
process of removing the drywall and related mate-
rials from the delivery trucks at the jobsite and
placing it at the. location designated by the pur-
chaser. Each purchase order between Westside and
Martin Brothers states specifically the location, in-
cluding floor, where the materials are to be deliv-
ered. A "stocker" is the person who unloads the
truck at the jobsite and distributes the material into
the building. The delivery-is not considered com-
plete and title to the material does not pass from
Westside'to Martin Brothers until Westside places
the - material, in good condition, at, the specific
location(s) designated by Martin Brothers pursuant
to its- purchase order and the materials are checked
and accepted by a Martin Brothers representative.
The manner in which 'the stocking is effected by
Westside's employees involves the use of -various
equipment, including forklifts, carts, pallet jacks,
rollers, and slings to move the drywall from the
truck to the area specified by Martin Brothers.
Much of this equipment has been specifically devel-
oped and/or refined by Westside for use by its
stocker employees.
Martin Brothers began work at the Citicorp job-
site in about July 1984, utilizing the services of em-
ployees represented by the Laborers, with whom
they have a- collective-bargaining relationship, to
assist other tradesmen in the installation of the
drywall. Westside has historically utilized its own
employees, who are represented'by Teamsters 952,
to perform the functions involved in the delivery
and stocking of drywall. About 15 August 1984,
Westside began diywall delivery and stocking to
the Citicorp jobsite utilizing its own employees. At
this time, the Laborers approached a Westside em-
ployee working there and claimed the stocking
work above the third floor. Thereafter, a series of
meetings ensued with representatives of various
parties in attendance including,' inter alia, at one
time or another, representatives from Teamsters
952, the Laborers, Westside, Martin Brothers, the
Associated General Contractors, and PCL. These
meetings were held during the" period August
275 NLRB No. 141
1002 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
through October 1984. During these meetings, both
the Laborers and Teamsters continuously claimed
the stocking work, 'the Laborers limiting their
claim to that above the third floor. At one of the
meetings, the Laborers stated it did not have stock-
ers available to 'do the work from its hiring hall,
but assured'Westside that men could be supplied to
do the work from another. Laborers local. About
this time the Laborers also told a representative of
Westside that Westside should be using Laborers
and should sign a labor agreement with the Labor-
ers. Westside refused on the basis of its collective-
bargaining agreement with Teamsters 952. On 24
or 25 October 1984 -Westside and Teamsters-952
had a meeting. Teamster 952's representative stated
that stocking was-Teamsters work and, if Westside
assigned any of this work, to. employees represented
by the Laborers, Teamsters 952 would take. eco-
nomic action, including picketing. against Westside
-and Martin Brothers. This- threat was reaffirmed in
a letter- dated 29 October 1984 sent by Teamsters
952 to the Employers and their legal counsel. -
Both Unions have -continued to claim the stock-
ing -work: At ,the- hearing, Teamsters- 952 withdrew
its threat.to picket and no.economic action has, in
fact, taken place. On 1 October,, 1984 the Laborers
requested, arbitration, pursuant to its collective-bar-
gaining agreement- with Martin Brothers', over
Martin ,Brothers' , "mis-assignment of - work,' and
"breach of subcontracting clause" . specifying -the
site of the dispute as `,Los Angeles, California."
B. The Work in Dispute
As clarified., at the, hearing, and in the parties'
posthearing briefs, the work in dispute is,limited to
the assignment of stocking work, above the first
three floors , of- the ;Citicorp project. ;The parties:
concede that, stocking, work to and including the
third floor is "Teamsters" work.. The Employers,
however,. urged ; at the hearing and in their post-
hearing':brief that. the scope •of the dispute should
be broadened, to include stocking above the third
floor.-on, all. present,, and future,,projects involving
Westside and Martin ,Brothers.. In: support of their
regarding the assignment of this work - was fully
litigated at the hearing. -
With respect to the Employers' contention, the
notice of hearing2 refers solely to the Citicorp job-
site . It does not appear, nor do the Employers con-
tend, that they filed any motion with the Regional
Director prior to hearing which would have ex-
panded the scope of the work in dispute so as to
provide for the inclusion of other projects, present
or future, conducted among the Employers. While
the Employers did raise this issue at the com-
mencement of the hearing, both Teamsters 952 and
the Laborers objected to the Employers' attempt to
expand the scope of the `disputed work and the
hearing officer's rulings were consistent with the
notice of hearing limiting the dispute to the Citi-
corp project only. The Board has in the past grant-
ed a' broad award encompassing the geographic
area in which an employer does business where ju-
risdictions of-the competing unions coincide and in
circumstances where there is an indication that the
dispute is likely to recur. -Cf. Iron' Workers Local
426 .(Angelo lafrafe Co.), 267 NLRB- 627, 630
(1983). However, the record evidence herein af-
firmatively establishes that this dispute has not
arisen in the recent past nor does it establish that
there is substantial likelihood that it will recur. Ad-
ditionally, while the Laborers collective-bargaining
agreement purports to extend its jurisdiction to the
11 southern counties of California, including Los
Angeles, the Teamsters collective-bargaining agree-
ment with Westside does not define its jurisdiction
nor did the record evidence specifically reflect the
territorial jurisdiction it encompasses. Thus, to the
extent, as the Laborers contends, that a 1973 juris-
dictional agreement between the Laborers and
Teamsters Joint Council #42 his consistently been
adhered to by other locals of the Teamsters whose
territorial jurisdiction overlaps that- of the Labor-
ers, it does not appear likely that the dispute will
recur. Thus, it appears that the warrant to grant a
broad -order- herein has not been established. Ac-
position, the (Employers argue. that. the Laborers',. cordingly, we find that the work in dispute in-
and Teamsters;:952's • demands for ;stockings ,work volves drywall -stocking work to points above the
above the third, floor, by--virtue of their-contractual,; third floor, of the Citicorp project on Seventh and
claims, extend to,; all high-rise projects- involving Figueroa Streets, Los Angeles, California.- Team-
Westside and Martin Brothers,- both present and - -
future,,,and not,, merely, the. Citicorp, project: The 2 The-instant case was initially consolidated for hearing along with a
Employers point out that all. stocking work ,is Ares-
charge involving the International Union of-Operating Engineers, Local
No'12 (21-CD-526) The dispute, as defined in the notice of hearing,
ently assigned to Westside's Teamsters employees. was' described 'as "Drywall stocking work, including but not limited to
The Employers 1 further. contend ,,that the question forklift operating after the first drop of material on the jobsite, at the Ci-
ticorp project at 7th and Figueroa Streets, Los Angeles, California " The
charge against the Operating Engineers was, however, resolved prior to
Martin Brothers is signatory to the Short Form Agreement with the hearing and severed from the instant proceeding and those portions of
Southern California Distnct Council of Laborers and its affiliates, includ - the notice of hearing as they related to Case 21-CD-526 were with-
mg' Laborers 300 drawn
TEAMSTERS LOCAL 952 (WESTSIDE MATERIAL)
sters Local 988 (Sullivan Transfer), 240 NLRB 1291,
1293 (1979).
C. Contentions of the Parties
In 1973 the Laborers entered into an agreement
with Teamsters Joint Council #42, of which Team-
sters 952 is a member , whereby all stocking of
drywall above the third floor in high-rise buildings
would be performed by the Laborers . This 1973
agreement was reaffirmed by Teamsters Joint
Council #42 on 29 November 1984 in the course of
the instant dispute . The Laborers contends that this
agreement is dispositive of the instant dispute. The
Laborers also claims the disputed work based on
their collective -bargaining agreement with Martin
Brothers . Additionally , the Laborers argues that to
the extent that the Employers contend that the dis-
puted work has been performed for years by West-
side 's Teamsters employees, any absence of protest
by the Laborers does not constitute a waiver by
the Laborers of its agreement with Teamsters Joint
Council #42 since it had no knowledge of this
practice by the Employers prior to the instant situ-
ation . Thus, the Laborers contends that the 1973
agreement is controlling as to the work in dispute
and, therefore , that the stocking of drywall above
the third floor, at Citicorp belongs to employees
represented by the Laborers. Finally , the Laborers
contends that the charge is moot and the matter
should be dismissed since , at the hearing, Team-
sters 952's representative withdrew its threat to
picket, stated that it would utilize the grievance
procedure in its collective -bargaining agreement
with Westside if the dispute continued , and never
in fact engaged in any economic activity.
The Employers. assert that the award of the dis-
puted work to Westside employees represented by
Teamsters 952 is appropriate in view of the collec-
tive-bargaining agreement which exists between
Westside and Teamsters 952,3 the Employers' pref-
erence and Westside 's past practice of almost 40
years of assigning the work to its Teamsters -repre-
sented employees , area practice , efficiency and
economy of operation , and skills possessed by
Westside 's Teamsters employees . , The Employer
further contends that , since neither Westside nor
Martin Brothers were parties to the 1973 agree-
ment , they are not bound by it . Finally, Westside
contends that it is a material supplier and is not en-
gaged in the construction industry and thus the La-
borers collective -bargaining agreement with Martin
9 The collective-bargaining agreement provides for exclusive recogni-
tion of Teamsters 952 as the collective-bargaining representative of van-
ous classifications of employees employed by Westside including "stock-
ers (lobside) "
1003
Brothers, with respect to subcontracting, does not
apply to it.
Teamsters 952 contends4 that the disputed work
should be assigned to Westside employees repre-
sented by it based on its collective-bargaining
agreement with Westside, past practice, and its
contention that it is not bound by the 1973 agree-
ment. -
D. Applicability of the Statute
Before the Board may proceed with a determina-
tion of a dispute pursuant to Section 10(k). of the
Act, if must be satisfied that (1) there is reasonable
cause to believe that Section 8(b)(4)(D ) has been
violated and (2) there is no agreed-upon method
for the voluntary resolution of the dispute.
With respect to (1) above, the record discloses
that, since August 1984, both the Laborers and
Teamsters 952 have been claiming the work in dis-
pute. Several meetings were held among various-bf
the parties involved in an attempt to reach a reso-
lution to the disputed claims . When no such resolu-
tion was, forthcoming, Teamsters 952's business
agent informed Westside, on 24 or 25 October 1984
and subsequently the Employers and their legal
counsel by letter dated 29 October 1984, that any
assignment of the disputed work to another union
by the Employers involved would cause Teamsters
952 to take economic action including ' picketing
against the Employers in order-to retain the work.5
Accordingly, we are satisfied that reasonable cause
exists to believe that Section 8(b)(4)(D) has been
violated.
With respect to (2) above, it is clear, from the
record as a whole, that there is no agreed-upon
method for the voluntary resolution of this dispute.
While refusing to stipulate to the matter; the La-
borers admitted (and the other parties stipulated)
that there is no- agreed-upon method to which all
parties are bound for resolving jurisdictional dis-
putes. The Laborers argues, however, that there is
a jurisdictional-dispute-resolution mechanism in
effect between Teamsters 952 and the Laborers by
virtue of the 1973 jurisdictional agreement. While
the 1973 agreement presumes to award the disput-
ed work involved herein to the Laborers and to
extend its coverage to Westside, there is no evi-
dence that Westside has at any time agreed to be
4 This contention is based on its position as stated at the hearing and
testimony of its representative, -Scott Teamsters 952 did not submit a
posthearing brief
s Contrary to the Laboiers contention, the instant case is not made
moot by the subsequent retraction of these threats : In so finding , we note
that the Teamsters retraction was not made until the hearing and that it
continues to claim the work in dispute In these circumstances , we find
that there is reasonable cause to believe Sec 8(bX4)(D) has been violated
and that the dispute is not moot
1004 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
bound by this agreement, and neither Martin
Brothers nor Westside has ever followed its work
assignment provisions vis-a-vis the type of work in-
volved herein. Additionally, the Laborers argues
that there is an arbitration provision in the collec-
tive-bargaining agreement between Martin Brothers
and the Laborers- which the Laborers have at-
tempted to invoke which would, if successful, re-
solve the dispute between Martin Brothers and the
Laborers. However, the Teamsters and Westside
would not be bound by this resolution. To consti-
tute an agreed-upon method for settlement, a pro-
cedure must bind all parties to the_ dispute, includ-
ing the employer.6 Further, Teamsters 952 has con-
tinued to, claim the work in dispute in the face of
the 1973 agreement without sanctions - from its
parent organization for doing. so. Thus it is clear
that there-is no agreed -upon method for the resolu-
tion of this dispute inasmuch as not one of the so-
called dispute resolution mechanisms involved
herein- binds all parties involved. Accordingly, - we
find there exists no agreed-upon method of volun.
tary adjustment of the dispute within the meaning
of Section 10(k) of the Act. NLRB v. Plasterers
Local 79- (Texas State Tile); 404 U.S. 116' (1971);
Teamsters Local 170,'240 NLRB '649, 650',(1979).
Thus, we find that the dispute is properly before
the Board for.determination.
E. Merits of the Dispute
Section 10(k) requires the Board 'to make an af-
firmative award.,of disputed work after considering
various factors. NLRB v. Electrical Workers IBEW
Local 1212 ((7olumbia Broadcasting), 364 U.S. 573
(1961). The Board has-held that its determination in
a jurisdictional dispute is an act of judgment based
on common _ sense - and experience, reached by bal-
ancing the factors involved in a particular case.
Machinists Lodge 1743 ,(J. A. Jones Construction),
135 NLRB 1402,(1962).
The following factors are- relevant in making the
determination of this dispute.
1. C ertificatio'ns and collective-bargaining
agreements
The record does not reflect whether either of the
labor organizations involved herein have been cer-
tified by the Board to represent the employees of
Westside or Martin Brothers. However, Westside
has been signatory to a collective-bargaining agree-
ment with various Teamsters Locals since the late
1940s or early 1950s..Westside has employed stock-
ers'-since about 1959. However, it- was not until
-- O 'NLRB v Plasterers Local 79 (Texas State Tile), 404 U S 116 (1971),
Teamsters Local 170 (Henley-Lundgren Co), 240 NLRB 649, 650 (1979)
1974 that the, specific classification for "stocker
(jobsite)" was added to its collective-bargaining
agreement with Teamsters 952. All of the collec-
tive-bargaining agreements entered into by West-
side and Teamsters 952 since 1974 have included
that classification. This classification was initially
inserted into the collective-bargaining agreement at
the Teamsters' insistence in 'order to protect their
jurisdiction over stocking work on all jobsites and
all. floors-All stocking work performed on behalf
of Westside has historically been accomplished by
its Teamsters-represented employees. -
Martin • Brothers and the Laborers are also par-
ties to a collective-bargaining agreement. This
agreement provides that the Laborers shall perform
"stocking and distribution of drywall material after
it has been delivered to the jobsite." Martin Broth-
ers does not employ any specific employees known
as stockers and, despite numerous pages in its col-
lective-bargaining agreement listing various classifi-
cations of employees, there is no specific classifica-
tion of "stocker" listed in the agreement between
Martin Brothers and the Laborers. The Laborers
collective-bargaining agreement with Martin Broth-
ers provides Martin Brothers will not engage in
subcontracting of unit work. A subcontractor
therein is defined as "any person . . . firm or cor-
poration, holding. a valid state contractor's license
where required by law . ."8 However, it ap-
pears that Westside'is a supplier to and not a sub-
contractor of Martin Brothers since Westside is not
required to possess a state contractors license for
the work in dispute. We find that the collective-
bargaining agreements 'herein do not favor an
award of'the disputed work to either group.
2. Employer's preference and past practice
Westside has employed Teamsters-represented
employees, including stockers, to perform its deliv-
ery and stocking work since the late 1940s or early
1950s. These employees have always performed
Wes'tside's delivery and stocking work for various
employers, including Martin Brothers at' the Citi-
corp jobsite. Martin Brothers has used Westside for
supplying and stocking its' drywall on numerous
projects since the early 1970s. Both Martin Broth-
ers and Westside representatives testified that they
preferred to have Westside's Teamsters-represented
Negotiations at that time involved- a multiemployer situation with
several Teamsters locals including Teamsters 952 -
8 On 1 October 1984 the Laborers filed a request for arbitration with
the Federal Mediation and Conciliation Service with respect to its dis-
pute with Martin Brothers The dispute alleged a violation of the collec-
tive-bargaining agreement concerning "breach of subcontracting clause"
and "misassignment of work," listing the sites of the dispute as Los An-
geles, California There is no indication in ,the record as to -the status of
this request
TEAMSTERS LOCAL 952 (WESTSIDE MATERIAL)
employees perform the disputed work rather than
the Laborers. Westside stated that its preference
was based on the fact that its Teamsters-represent-
ed employees have specialized training and skills,
that Westside considers stocking part of the contin-
uous delivery process in that one set of employees
can deliver and stock the supplies at the jobsite,
and that Westside's Teamsters-represented employ-
ees are familiar with all of the specialized equip-
ment developed and used by Westside in perform-
ing stocking work.
Martin Brothers based its preference for West-
side's Teamsters-represented employees performing
the stocking work on, inter alia, the fact that it
does not have to worry about delivery problems or
damage to the product when Westside employees
perform the work. Martin Brothers has had prob-
lems using certain other suppliers whose employees
are represented by the Laborers for stocking work
and thus has limited the use, of these other compa-
nies to small jobs. Approximately 99 percent of the
stocking work done for Martin Brothers on high-
rise projects is performed by Teamsters-represented
employees, including those employed by Westside.
There was testimony from both Westside and
Martin Brothers' representatives that they did not
care what labor organization represented Westside
employees as long as it was Westside's employees
that performed the work. From this the Laborers
argues that Westside could employ employees it
represents instead of employees represented by the
Teamsters to perform the disputed work. However,
it is undisputed that Westside's employees are in
fact represented for the purposes of collective bar-
gaining by the Teamsters and not the Laborers.
Thus, it is clear that this factor favors the assign-
ment of the disputed work to Westside's Team-
sters-represented employees.
3. Area and industry practice
The evidence in this area is mixed. It appears
from the record that several employers have used
Teamsters-represented employees to perform work
of the type in dispute and that at least one employ-
er has used Laborers-represented employees to per-
form stocking work. In 1973 Teamsters and Labor-
ers attempted to resolve between themselves issues
of this nature by entering into an agreement where-
in stocking above the third floor was awarded to
the Laborers.
While it is clear that a dispute regarding this
work has not arisen since the 1973 agreement, the
Laborers argues that this was because it had no
knowledge, heretofore, that Teamsters, and specifi-
cally Teamsters 952, was acting contrary to the
1973 agreement. Laborers argues that because the
1005
Teamsters-represented employees apparently do a
great deal of their stocking work after regular la-
borer hours, they had no way of knowing that
Teamsters 952 had in fact been violating the 1973
agreement until'the Citicorp project. In any event,
the record is not sufficiently developed to ascertain
area- and industry practice. Accordingly, we find
that this factor .does not favor an award of the
work to either group of employees.
4. Employee skills
The evidence shows that Westside has a 1-year
training program for its stocker employees. The
program teaches the employees 'not only skills in-
volved in stocking work, but also teaches them to
run specialized equipment which Westside has de-
veloped over the years to assist its employees in
performing stocking work in high-rise buildings.
The Laborers, in its posthearing brief, concedes
that Westside's employees are the ones that possess
the necessary skill and training to do the disputed
work. Moreover, the Laborers representatives testi-
fied that they did not have any skilled stockers
available to do the work. According to Westside's
representative, it would take Westside approximate-
ly 1 year to train laborers to perform the skills nec-
essary for stocking work. Clearly this factor war-
rants awarding the disputed work to • Westside's
Teamsters-represented employees.
5. Economy and efficiency of operations
The evidence shows that initially it is Westside's
Teamsters-represented employees who are respon-
sible for loading the drywall onto the' Westside's
trucks and thereafter unloading the drywall at the
delivery site. Under the present assignment of the
disputed work, employees represented - by • the
Teamsters perform every function involved in! the
delivery and stocking of drywall for Westside's
warehouse or suppliers to the location specified in
Martin Brothers' purchase order. The Laborers
does not claim that it• should be entitled to the
work of unloading the trucks or that the Team-
sters-represented employees should not be allowed
to stock the drywall up to and including the third
floor. Rather, at the point that the material is to be
moved beyond the third floor of a high-rise, the
Laborers claims the Teamsters-represented employ-
ees should cease performing the work and the La-
borers-represented employees commence stocking
it to the appropriate location. The evidence shows
that Westside sometimes. stocks high-rise and low-
rise buildings during the day and, with respect to
high-rise buildings, performs stocking work above
and below the third floor during the same period.
Westside's president testified that it would be more
1006 - DECISIONS OF NATIONAL LABOR RELATIONS BOARD
expensive and wasteful to have to employ two
crews: Laborers-represented employees to stock
above the third floor and Teamsters-represented
employees to do the loading, unloading, and stock-
ing on the first three floors. Westside's representa-
tive stated that this would create scheduling prob-
lems and could result in extra unneeded and/or un-
productive employees. For example,-if the employ-
ees represented by the Teamsters were hired for
delivery and stocking to points on the third floor
and below, and employees represented by the La-
borers above the third floor, this could result in
long periods where certain groups of employees
would remain idle while waiting for more work.
Accordingly, cost and efficiency clearly favors an
award of the disputed work to the employees rep-
resented by the Teamsters.
Conclusions
After considering all the relevant factors, we
conclude that employees represented by Teamsters
952 are entitled to perform the work in dispute. We
reach this conclusion relying on employer prefer-
ence and past practice, employee skills, and econo-
my and efficiency of operation. In making this de-
termination, we are awarding the work to employ-
ees represented by Teamsters- 952, not to that
Union or its members. The determination is limited
to the controversy that gave rise to this proceed-
ing.
DETERMINATION OF DISPUTE
The National Labor Relations Board makes the
following Determination of -Dispute. -
Employees of Westside Building Material Corpo-
ration represented • by General Truck Drivers,
Office, Food and Warehouse, Local 952, Interna-
tional Brotherhood of Teamsters, Chauffeurs,
Warehousemen and Helpers of America are enti-
tled to perform drywall stocking work to points
above the third floor at the Citicorp project at Sev-
enth and Figueroa Streets, Los Angeles, California.