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The Steward Mr. John Naddy
Division Labor Manager
| UNITED PARCEL SERVICE |
Dear Mr. Naddy:
Following is a list of information I request that you send to Local 78. This request is necessitated due to the actions that you instructed automotive management to take against me on December 20, 1996 (see attached document). I was expelled from company property and my identification card was confiscated per your instructions. I am trying to determine why I was treated in a discriminatory manner and I am preparing for a grievance meeting.
In addition to the specific items mentioned below, please supply all factual bases for the company's decision to remove me from company property.
1. Bargaining notes and arbitration summaries that would clarify or
supersede the published contract.
2. The dates and contents of any union statements upon which you are
relying; and the dates and descriptions of any practices or events which
you contend support your position.
3. Company manuals and guidelines.
4. Company memos and correspondence. I am looking for memos and correspondence
directing supervision to expel employees from company property in specific
circumstances.
5. Disciplinary records that would justify these actions.
6. Investigative reports that would pertain to me specifically.
7. A copy of my personnel file.
8. Copies of any of my personnel files that are being kept at a location
other than the shop office. I request a copy of my personnel file that
is being kept in the district office or other corporate locations. I am
specifically requesting any files pertaining to me that have been flagged
to indicate special attention. I demand to be informed in writing as to
whether or not these files exist.
9. Copies of reports and studies that encourage discriminatory treatment
of employees under "special circumstances".
10. Supervisors' notes pertaining to my situation.
11. Printed work rules or policy pertaining to my situation.
12. The names and titles of all persons that were responsible for my
expulsion from company property listed in descending order of authority.
Please include a job description of relevant responsibilities and duties
of these individuals.
13. Names and locations of other employees that have been subjected
to the same policy that I was.
This request is made without prejudice to the union's right to file subsequent requests. If any part of this letter is denied or if any material is unavailable, please provide the remaining items as soon as possible, which the union will accept without prejudice to its position that it is entitled to all documents and information called for in the request.
This request is being filed pursuant to Article 7, Section 2, paragraph (b) of the Northern California Supplemental Agreement. Please be advised that refusals to provide information, or unreasonable delays, are unfair labor practices in violation of Section 8(a)(5) of the National Labor Relations Act.
Sincerely,
Charles R. Engel
Steward, Local 78
cc: Mr. Dan Varella
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