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Page 1 UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
________________________________________________
)
)
)
Plaintiff,
)
)
v.
)
)
PHILADELPHIA METAL TRADES COUNCIL, et al.,
)
)
Defendants.
)
________________________________________________)
KVAERNER PHILADELPHIA SHIPYARD, INC.,
No. 02-CV-3710
DECLARATION OF RON AULT
I, Ron Ault, pursuant to 28 U.S.C. § 1746, depose and state as follows:
1.
I am the East Coast Representative of the Metal Trades Department of the
American Federation of Labor and Congress of Industrial Organizations (“MTD” or
“Department”). I have held that position since July 5, 1999.
2.
In my capacity as East Coast Representative, I assist local Metal Trades Councils
in negotiating and administering collective bargaining agreements with employers. I also carry
out assignments from the Department’s President.
3.
The MTD is a labor organization that was chartered by the American Federation
of Labor-Congress of Industrial Organizations (“AFL-CIO”).
The MTD maintains its
headquarters at 888 16th Street, N.W., Washington, D.C. 20006. The day-to-day operations of
the MTD are handled by the Department’s President and its representatives, under the overall
supervision of its Executive Council.
4.
The AFL-CIO chartered the MTD to coordinate negotiations, organizing and
political action among approximately twenty affiliated international unions who have membersPage 2 employed in the various metal trades. These affiliated international unions include, by way of
example, the United Association of Journeymen and Apprentices of the Plumbing and Pipefitting
Industry of the United States and Canada, AFL-CIO (“UA”); the International Brotherhood of
Electrical Workers, AFL-CIO (“IBEW”); the Sheet Metal Workers International Association,
AFL-CIO (“SMWIA”); International Brotherhood of Boilermakers, Iron Ship Builders,
Blacksmiths, Forgers and Helpers, AFL-CIO (“IBB”); and the International Association of Heat,
Frost, Insulation and Asbestos Workers, AFL-CIO (“IAHFIAW”).
5.
Most of these international unions are also affiliated with the Building and
Construction Trades Department (“BCTD”), which is a separate department charted by the AFLCIO to coordinate negotiations, organizing and political action among the members of those
international unions who are employed in the building and construction trades. The BCTD and
the MTD are separate and independent entities.
6.
The MTD has a Constitution and Bylaws, which governs the operations of the
Department and the Department’s own affiliates.
A true and accurate copy of the MTD
Constitution is attached hereto as Exhibit 1.
7.
Article VIII, Section 1 of the MTD Constitution provides for the chartering of
district Metal Trades Councils, state Metal Trades Councils and local Metal Trades Councils.
That section states that the MTD may issue a charter for a local Metal Trades Council upon the
request of three or more local unions of the affiliated international unions.
8.
Each local Metal Trades Council adopts its own constitution and bylaws in
accordance with Article X of the MTD Constitution.
2Page 3 Article VIII, Section 6 provides that each local Metal Trades Council shall
establish an executive board composed of the President and Secretary and one delegate from
each affiliated local union.
10.
Article VIII, Section 7 provides that the duties of local executive boards are to
attend to any business assigned to them by the local council in accordance with the laws of the
MTD.
11.
Article XI, Section 6 of the MTD Constitution provides that no local Metal Trades
Council can order a strike of the members affiliated without the consent of the MTD and the
sanction of the international metal trades unions involved.
12.
For the city of Philadelphia, the MTD has given a charter to the Philadelphia
Metal Trades Council, AFL-CIO (“PMTC” or “Council”).
13.
The PMTC is a labor organization composed of approximately eleven (11)
affiliated local unions whose international unions are affiliates of the MTD.
The eleven
affiliated local unions include, but are not limited to, local unions of the UA, IBEW, SMWIA,
IBB and IAHFIAW.
These local unions may be affiliated with the local building and
construction trades council in Philadelphia, just as their international unions may be affiliated
with the BCTD.
14.
One of the eleven local unions that are affiliated with the PMTC is the Insulation
and Asbestos Workers Local 14. (“Asbestos Workers Local 14” or “Local 14”). Local 14
represents no employees, and has no members, at the Kvaerner Philadelphia Shipyard.
15.
Asbestos Workers Local 14 is an affiliate of the Philadelphia Building and
Construction Trades Council.
3Page 4 The PMTC is an autonomous and independent entity that controls its own day-to-
day operations with the guidance of the MTD Constitution and Bylaws. In turn, the eleven
affiliated local unions are autonomous and independent from the PMTC, controlling their own
day-to-day operations in accordance with the bylaws and constitutions of their parent
international unions.
17.
The PMTC has adopted its own bylaws. A true and accurate copy of the PMTC
bylaws is attached hereto as Exhibit 2.
18.
Article III of the PMTC bylaws provides that the purpose of the Council is to
protect and promote the interests of the membership of the affiliated local unions. The PMTC
accomplishes these purposes by, among other things, negotiating and administering collective
bargaining agreements with employers with whom the Council is the recognized collective
bargaining representative.
19.
Until July 1999, the Executive Board governed the PMTC. However, effective
July 1, 1999, the MTD placed the PMTC into trusteeship for reasons unrelated to the issues
involved in the above-captioned matter. I am currently Trustee over the affairs of the PMTC.
20.
As the Trustee of the PMTC, my duties and responsibilities include the overall
management of the affairs of the Council. Pursuant to the Department’s Constitution, as Trustee,
I stand in the place of the Council’s officers with overall authority to handle the affairs of the
Council. Upon the imposition of the trusteeship, the council’s officers were removed, and none
of the Council’s former officers, including Phillip Rowan, identified in the Complaint as Vice
President of the Council has any authority to act for the Council during the trusteeship.
4Page 5 Historically, the PMTC was the exclusive bargaining representative of employees
who were employed at the Philadelphia Naval Shipyard while that shipyard was still owned and
operated by the United States government.
22.
The Philadelphia Naval Shipyard closed in 1995.
23.
In 1998, Kvaerner Philadelphia Shipyard, Inc. (“Kvaerner”) began constructing
and operating a shipyard on the premises of the Philadelphia Shipyard.
24.
In September 1998, Kvaerner and the PMTC, with the assistance of the MTD,
negotiated a collective bargaining agreement covering production and maintenance employees at
the Philadelphia Shipyard. I am familiar with the collective bargaining agreement because of my
role as East Coast Representative of the Department.
25.
The collective bargaining agreement provides that Kvaerner recognizes the
exclusive bargaining representative as the “Union,” which includes the PMTC, as well as the
United Association of Journeymen and Apprentices of the Plumbing and Pipe Fitting Industry;
the International Association of Bridge, Structural and Ornamental Iron Workers, International
Brotherhood of Boilermakers, United Brotherhood of Carpenters and Joiners; International
Association of Heat, Frost, Insulation and Asbestos Workers; Sheet Metal Workers International
Association; International Association of Machinists and Aerospace Workers; Laborers
International Union of North America; International Union of Operating Engineers; International
Union of Painters and Allied Trades. These eleven international unions are the international
metal trades unions of the local unions that are affiliated with the PMTC.
26.
The collective bargaining agreement contains a grievance and arbitration
procedure in Article 16.
5Page 6 The collective bargaining agreement contains a provision concerning the
subcontracting of work in Article 28.
28.
The PMTC has previously filed a grievance concerning Kvaerner’s alleged breach
of the subcontracting provision in the collective bargaining agreement. That grievance was filed
prior to the dispute in the above-captioned matter. The grievance is still pending and will be set
for arbitration in the near future.
29.
The collective bargaining agreement contains a no-strike/no-lockout provision in
Article 17. Section 1 of the no-strike clause sets forth the general prohibition that there shall be,
among other things, no strikes, picketing, slowdowns, sit-downs, cessation of work, boycotts,
and refusals to cross picket lines.
30.
Section 2 of the no-strike clause provides that the Union, its officers, agents,
representatives and members shall not in any way authorize, ratify, assist, encourage, participate
in, sanction, condone, or lend support to any strikes, picketing, slowdowns, et cetera.
31.
Section 2 also provides that if employees engage in unauthorized strikes,
picketing, slowdowns, et cetera, then the Union shall be obligated to support the Company and
endeavor, within twenty four hours after receiving written notice from Kvaerner, to undertake
four actions. First, the Union is supposed to publicly disavow the employees’ action. Second,
the Union would be required to advise Kvaerner’s Vice President of Human Resources in writing
that the Union has not authorized or sanctioned the employees’ actions. Third, the Union would
be required to notify the employees of its disapproval of their action and instruct the employees
to cease such action. Finally, the Union would be required to post a notice on all bulletin boards
advising employees that it disapproves of their action and instructing the employees to return to
6Page 7 work. The agreement provides that if these conditions are met, the Union has no responsibility
for an unauthorized work stoppage.
32.
The no-strike cla use does not require the Union to take those four steps if
Kvaerner fails to provide the written notice in the first instance.
33.
The PMTC and its authorized representatives did not engage in any picketing,
striking or boycotting at Kvaerner’s Philadelphia Shipyard. To my knowledge, none of the
employees at the Shipyard who are covered by the collective bargaining agreement have engaged
in picketing, striking, boycotts, work slowdowns and/or sympathy strikes.
34.
As previously noted, while the collective bargaining agreement contains a no-
strike clause, section 2 of that clause contains a specific procedure that must be followed when
seeking the PMTC’s assistance in stopping any alleged violation of the no-strike clause.
Kvaerner failed to follow that procedure in that, to my knowledge, it has not provided any
written notice to the PMTC that could trigger the PMTC’s obligations under the contract. It has
provided no such written notice to me.
35.
While Asbestos Workers Local 14 and/or its authorized representatives may have
engaged in picketing at the Philadelphia Shipyard, to my knowledge, such picketing was
undertaken by Local 14 in representation of Local 14’s building and construction trades
members. These individuals are not employed by Kvaerner and do not work at the Philadelphia
Shipyard.
As I further understand, Local 14 members were engaged in “area standards
picketing” to protest an out-of-town subcontractor’s payment of wages that were below the wage
rates in the area for insulation workers in the building and construction trades and that were,
therefore, undermining area standards. Further, to my knowledge, Local 14 did not engage in the
picketing because of any dispute arising under the Kvaerner agreement, including any dispute
7Page 8 concerning a breach of the subcontracting clause contained within the collective bargaining
agreement between PMTC and Kvaerner.
36.
I am attaching a recent article from the Philadelphia Inquirer that underscores my
understanding that the picketing is in furtherance of goals of entities other than the PMTC and
that does not relate to a dispute arbitrable under the collective bargaining agreement. A true and
accurate copy of that article, which is entitled “Kvaerner Owner’s 2 Challenges” from the June
10, 2002 edition of the Philadelphia Inquirer is attached hereto as Exhibit 3. As this article
demonstrates, building trades unions, such as Asbestos Workers Local 14, have disputes with
Kvaerner over issues other than alleged breaches of the subcontracting provision in the collective
bargaining agreement.
37.
As Asbestos Workers Local 14 has no employees working at the Philadelphia
shipyard and as it was Local 14’s building and construction trades members who were engaging
in the area standards picketing, the PMTC has no power or control over Local 14. The PMTC
bylaws do not contain any provisions that could be used to discipline or otherwise prevent Local
from engaging in areas standards picketing using building and construction trades members
over a dispute not arising under the Kvaerner agreement.
38.
While Article XVII of the PMTC’s bylaws provides for charges and penalties,
such charges are limited to those filed against any person representing the PMTC in any official
capacity for willful failure to perform duties under the bylaws or a collective bargaining
agreement; for malfeasance in office or misappropriation of PMTC funds or assets; and/or false
or slanderous statements by or against Council officers, delegates or an affiliated local union.
Given Asbestos Workers Local 14 members were not representing the PMTC in any capacity
when they engaged in their picketing, and given malfeasance and slander are not at issue, there is
8Page 9 no basis upon which the PMTC could take action against Local 14 for its area standards
picketing.
39.
On or around June 12, 2002, a letter was sent by the MTD to the Council and all
of the defendants informing them of the Court’s issuance of a temporary restraining order in the
above captioned matter. A true and accurate copy of that letter is attached hereto as Exhibit 4.
In that letter, the MTD and PMTC expressly disavowed and disapproved of any picketing or
refusal to report to work and notified all employees that they should return to work. Also, in that
letter, the MTD and PMTC stated they were notifying all concerned that they disavow and
disapprove of the actions undertaken by Asbestos Workers Local 14. Both the MTD and PMTC
stated that employees should continue to work.
I declare under the penalty of perjury that the foregoing is true and correct.
_____________________________
Ron Ault
DATED:_________________
93642_3
9
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UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
________________________________________________
)
)
)
Plaintiff,
)
)
v.
)
)
PHILADELPHIA METAL TRADES COUNCIL, et al.,
)
)
Defendants.
)
________________________________________________)
KVAERNER PHILADELPHIA SHIPYARD, INC.,
No. 02-CV-3710
DECLARATION OF RON AULT
I, Ron Ault, pursuant to 28 U.S.C. § 1746, depose and state as follows:
1.
I am the East Coast Representative of the Metal Trades Department of the
American Federation of Labor and Congress of Industrial Organizations (“MTD” or
“Department”). I have held that position since July 5, 1999.
2.
In my capacity as East Coast Representative, I assist local Metal Trades Councils
in negotiating and administering collective bargaining agreements with employers. I also carry
out assignments from the Department’s President.
3.
The MTD is a labor organization that was chartered by the American Federation
of Labor-Congress of Industrial Organizations (“AFL-CIO”).
The MTD maintains its
headquarters at 888 16th Street, N.W., Washington, D.C. 20006. The day-to-day operations of
the MTD are handled by the Department’s President and its representatives, under the overall
supervision of its Executive Council.
4.
The AFL-CIO chartered the MTD to coordinate negotiations, organizing and
political action among approximately twenty affiliated international unions who have members
PDF Page 3
Case 2:02-cv-03710-WY
Document 8
Filed 06/20/2002
Page 2 of 9
employed in the various metal trades. These affiliated international unions include, by way of
example, the United Association of Journeymen and Apprentices of the Plumbing and Pipefitting
Industry of the United States and Canada, AFL-CIO (“UA”); the International Brotherhood of
Electrical Workers, AFL-CIO (“IBEW”); the Sheet Metal Workers International Association,
AFL-CIO (“SMWIA”); International Brotherhood of Boilermakers, Iron Ship Builders,
Blacksmiths, Forgers and Helpers, AFL-CIO (“IBB”); and the International Association of Heat,
Frost, Insulation and Asbestos Workers, AFL-CIO (“IAHFIAW”).
5.
Most of these international unions are also affiliated with the Building and
Construction Trades Department (“BCTD”), which is a separate department charted by the AFLCIO to coordinate negotiations, organizing and political action among the members of those
international unions who are employed in the building and construction trades. The BCTD and
the MTD are separate and independent entities.
6.
The MTD has a Constitution and Bylaws, which governs the operations of the
Department and the Department’s own affiliates.
A true and accurate copy of the MTD
Constitution is attached hereto as Exhibit 1.
7.
Article VIII, Section 1 of the MTD Constitution provides for the chartering of
district Metal Trades Councils, state Metal Trades Councils and local Metal Trades Councils.
That section states that the MTD may issue a charter for a local Metal Trades Council upon the
request of three or more local unions of the affiliated international unions.
8.
Each local Metal Trades Council adopts its own constitution and bylaws in
accordance with Article X of the MTD Constitution.
2
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Case 2:02-cv-03710-WY
9.
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Article VIII, Section 6 provides that each local Metal Trades Council shall
establish an executive board composed of the President and Secretary and one delegate from
each affiliated local union.
10.
Article VIII, Section 7 provides that the duties of local executive boards are to
attend to any business assigned to them by the local council in accordance with the laws of the
MTD.
11.
Article XI, Section 6 of the MTD Constitution provides that no local Metal Trades
Council can order a strike of the members affiliated without the consent of the MTD and the
sanction of the international metal trades unions involved.
12.
For the city of Philadelphia, the MTD has given a charter to the Philadelphia
Metal Trades Council, AFL-CIO (“PMTC” or “Council”).
13.
The PMTC is a labor organization composed of approximately eleven (11)
affiliated local unions whose international unions are affiliates of the MTD.
The eleven
affiliated local unions include, but are not limited to, local unions of the UA, IBEW, SMWIA,
IBB and IAHFIAW.
These local unions may be affiliated with the local building and
construction trades council in Philadelphia, just as their international unions may be affiliated
with the BCTD.
14.
One of the eleven local unions that are affiliated with the PMTC is the Insulation
and Asbestos Workers Local 14. (“Asbestos Workers Local 14” or “Local 14”). Local 14
represents no employees, and has no members, at the Kvaerner Philadelphia Shipyard.
15.
Asbestos Workers Local 14 is an affiliate of the Philadelphia Building and
Construction Trades Council.
3
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16.
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The PMTC is an autonomous and independent entity that controls its own day-to-
day operations with the guidance of the MTD Constitution and Bylaws. In turn, the eleven
affiliated local unions are autonomous and independent from the PMTC, controlling their own
day-to-day operations in accordance with the bylaws and constitutions of their parent
international unions.
17.
The PMTC has adopted its own bylaws. A true and accurate copy of the PMTC
bylaws is attached hereto as Exhibit 2.
18.
Article III of the PMTC bylaws provides that the purpose of the Council is to
protect and promote the interests of the membership of the affiliated local unions. The PMTC
accomplishes these purposes by, among other things, negotiating and administering collective
bargaining agreements with employers with whom the Council is the recognized collective
bargaining representative.
19.
Until July 1999, the Executive Board governed the PMTC. However, effective
July 1, 1999, the MTD placed the PMTC into trusteeship for reasons unrelated to the issues
involved in the above-captioned matter. I am currently Trustee over the affairs of the PMTC.
20.
As the Trustee of the PMTC, my duties and responsibilities include the overall
management of the affairs of the Council. Pursuant to the Department’s Constitution, as Trustee,
I stand in the place of the Council’s officers with overall authority to handle the affairs of the
Council. Upon the imposition of the trusteeship, the council’s officers were removed, and none
of the Council’s former officers, including Phillip Rowan, identified in the Complaint as Vice
President of the Council has any authority to act for the Council during the trusteeship.
4
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Case 2:02-cv-03710-WY
21.
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Historically, the PMTC was the exclusive bargaining representative of employees
who were employed at the Philadelphia Naval Shipyard while that shipyard was still owned and
operated by the United States government.
22.
The Philadelphia Naval Shipyard closed in 1995.
23.
In 1998, Kvaerner Philadelphia Shipyard, Inc. (“Kvaerner”) began constructing
and operating a shipyard on the premises of the Philadelphia Shipyard.
24.
In September 1998, Kvaerner and the PMTC, with the assistance of the MTD,
negotiated a collective bargaining agreement covering production and maintenance employees at
the Philadelphia Shipyard. I am familiar with the collective bargaining agreement because of my
role as East Coast Representative of the Department.
25.
The collective bargaining agreement provides that Kvaerner recognizes the
exclusive bargaining representative as the “Union,” which includes the PMTC, as well as the
United Association of Journeymen and Apprentices of the Plumbing and Pipe Fitting Industry;
the International Association of Bridge, Structural and Ornamental Iron Workers, International
Brotherhood of Boilermakers, United Brotherhood of Carpenters and Joiners; International
Association of Heat, Frost, Insulation and Asbestos Workers; Sheet Metal Workers International
Association; International Association of Machinists and Aerospace Workers; Laborers
International Union of North America; International Union of Operating Engineers; International
Union of Painters and Allied Trades. These eleven international unions are the international
metal trades unions of the local unions that are affiliated with the PMTC.
26.
The collective bargaining agreement contains a grievance and arbitration
procedure in Article 16.
5
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Case 2:02-cv-03710-WY
27.
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Page 6 of 9
The collective bargaining agreement contains a provision concerning the
subcontracting of work in Article 28.
28.
The PMTC has previously filed a grievance concerning Kvaerner’s alleged breach
of the subcontracting provision in the collective bargaining agreement. That grievance was filed
prior to the dispute in the above-captioned matter. The grievance is still pending and will be set
for arbitration in the near future.
29.
The collective bargaining agreement contains a no-strike/no-lockout provision in
Article 17. Section 1 of the no-strike clause sets forth the general prohibition that there shall be,
among other things, no strikes, picketing, slowdowns, sit-downs, cessation of work, boycotts,
and refusals to cross picket lines.
30.
Section 2 of the no-strike clause provides that the Union, its officers, agents,
representatives and members shall not in any way authorize, ratify, assist, encourage, participate
in, sanction, condone, or lend support to any strikes, picketing, slowdowns, et cetera.
31.
Section 2 also provides that if employees engage in unauthorized strikes,
picketing, slowdowns, et cetera, then the Union shall be obligated to support the Company and
endeavor, within twenty four hours after receiving written notice from Kvaerner, to undertake
four actions. First, the Union is supposed to publicly disavow the employees’ action. Second,
the Union would be required to advise Kvaerner’s Vice President of Human Resources in writing
that the Union has not authorized or sanctioned the employees’ actions. Third, the Union would
be required to notify the employees of its disapproval of their action and instruct the employees
to cease such action. Finally, the Union would be required to post a notice on all bulletin boards
advising employees that it disapproves of their action and instructing the employees to return to
6
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work. The agreement provides that if these conditions are met, the Union has no responsibility
for an unauthorized work stoppage.
32.
The no-strike cla use does not require the Union to take those four steps if
Kvaerner fails to provide the written notice in the first instance.
33.
The PMTC and its authorized representatives did not engage in any picketing,
striking or boycotting at Kvaerner’s Philadelphia Shipyard. To my knowledge, none of the
employees at the Shipyard who are covered by the collective bargaining agreement have engaged
in picketing, striking, boycotts, work slowdowns and/or sympathy strikes.
34.
As previously noted, while the collective bargaining agreement contains a no-
strike clause, section 2 of that clause contains a specific procedure that must be followed when
seeking the PMTC’s assistance in stopping any alleged violation of the no-strike clause.
Kvaerner failed to follow that procedure in that, to my knowledge, it has not provided any
written notice to the PMTC that could trigger the PMTC’s obligations under the contract. It has
provided no such written notice to me.
35.
While Asbestos Workers Local 14 and/or its authorized representatives may have
engaged in picketing at the Philadelphia Shipyard, to my knowledge, such picketing was
undertaken by Local 14 in representation of Local 14’s building and construction trades
members. These individuals are not employed by Kvaerner and do not work at the Philadelphia
Shipyard.
As I further understand, Local 14 members were engaged in “area standards
picketing” to protest an out-of-town subcontractor’s payment of wages that were below the wage
rates in the area for insulation workers in the building and construction trades and that were,
therefore, undermining area standards. Further, to my knowledge, Local 14 did not engage in the
picketing because of any dispute arising under the Kvaerner agreement, including any dispute
7
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concerning a breach of the subcontracting clause contained within the collective bargaining
agreement between PMTC and Kvaerner.
36.
I am attaching a recent article from the Philadelphia Inquirer that underscores my
understanding that the picketing is in furtherance of goals of entities other than the PMTC and
that does not relate to a dispute arbitrable under the collective bargaining agreement. A true and
accurate copy of that article, which is entitled “Kvaerner Owner’s 2 Challenges” from the June
10, 2002 edition of the Philadelphia Inquirer is attached hereto as Exhibit 3. As this article
demonstrates, building trades unions, such as Asbestos Workers Local 14, have disputes with
Kvaerner over issues other than alleged breaches of the subcontracting provision in the collective
bargaining agreement.
37.
As Asbestos Workers Local 14 has no employees working at the Philadelphia
shipyard and as it was Local 14’s building and construction trades members who were engaging
in the area standards picketing, the PMTC has no power or control over Local 14. The PMTC
bylaws do not contain any provisions that could be used to discipline or otherwise prevent Local
14 from engaging in areas standards picketing using building and construction trades members
over a dispute not arising under the Kvaerner agreement.
38.
While Article XVII of the PMTC’s bylaws provides for charges and penalties,
such charges are limited to those filed against any person representing the PMTC in any official
capacity for willful failure to perform duties under the bylaws or a collective bargaining
agreement; for malfeasance in office or misappropriation of PMTC funds or assets; and/or false
or slanderous statements by or against Council officers, delegates or an affiliated local union.
Given Asbestos Workers Local 14 members were not representing the PMTC in any capacity
when they engaged in their picketing, and given malfeasance and slander are not at issue, there is
8
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no basis upon which the PMTC could take action against Local 14 for its area standards
picketing.
39.
On or around June 12, 2002, a letter was sent by the MTD to the Council and all
of the defendants informing them of the Court’s issuance of a temporary restraining order in the
above captioned matter. A true and accurate copy of that letter is attached hereto as Exhibit 4.
In that letter, the MTD and PMTC expressly disavowed and disapproved of any picketing or
refusal to report to work and notified all employees that they should return to work. Also, in that
letter, the MTD and PMTC stated they were notifying all concerned that they disavow and
disapprove of the actions undertaken by Asbestos Workers Local 14. Both the MTD and PMTC
stated that employees should continue to work.
I declare under the penalty of perjury that the foregoing is true and correct.
_____________________________
Ron Ault
DATED:_________________
93642_3
9
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