Brief for the Respondent in Opposition — United Aircraft Corp. v. National Labor Relations Board

we?

, INDEX '

Opinions below____- .

Jurisdiction.._.. --__.

Questions presented. _

Statute involved. oe ;

ee eee

. The Board’ s ny of fact-.

: The Board’s conclusions and order.

C. The court of cued Geeinton .

EGG A OR ne oe

CITATIONS

Cases: ;

' National Labor Relations Board v. Ap

Mills, 242 1°. 2d 669

Nationa! Labor Relations Board v. Babcock &

Wilcox. Co., 351. U.S, 108. __.

National Labor Relations Board v. (

Furniture Co., 199 F..2d 267, certiorari

denied, 345 U.S *. 907, enforcing 97 N.L.R.B.

* 1501. - EEE hes

National fae ai Relations Board v. Great ‘Allen-

tic & Pacific Tea Co., 277 ¥. 2d 759

National Labor Relations Board vy. Illinois

Tool Works, 153 V. 2d S11, enforcing 61

N.L.R.B. 1129.0 es

Nationa! Labor Relations Board v. ‘La Salle

Stl Co., ¥7S ¥. 2d 829, certiorari denied,

| B39 US. 963, enforcing 72 N_L.R.B. 41}

il

723 221 —-64 I

11

12

ee ee

*

"National Labor Reletions Beard v Monarch ©

Tool Co:, 210 F.:2d 183, certiorari denied,

347 US. '967, enforcing 102 N.L.R.B. 1242. -

National Labor Relations Board v. Rockwell

Mfg. Co., 271 F. 2d 109_- :

National Labor Rdiations “Board yi ‘tam

Aluminum Co., 300 F. 2d 315, oe

denied, 303 F. 2d 435... a

‘National ‘Labor Relations Board v. “United

_ Steelworkers of America, 357 U.S. 357. .

National Labor Relations Board vy. Walton » Mio.

Co., 289 F. 2d 177.. et

Nutone, Inc., 112 NLRB 1153__ per Se

Olin “Industries, Inc. v. National Labor Rela-

ions Board, 19} F. 2d 613, certiorari denied,

343 USL 19, enforcing 86 N:L.R.B. 203_.

Peyton P ing Co., 49 N.L.R.B. 828... _..

Republic — n Corp. v. National Labor -

Relations , 324 U.S. 793... ___- 9, 10,

Stoddar rk Manufacturing ‘Co., 138

” N.L.R.B. 615-.

Time-O-Matic, Ine. v. National Labor Rela-

tions Board, 264 F. 2d 96, enforemg 121 .

Ts cap ngtiuesawaswtcewaowea

11, 12

12

12, 13

United Steelworkers \ v. National Labor Rela- .

tions Board, 243 ¥ . 2d 593... sce cca

Universal Camera Corp. v. Naiional Labor.

Seees eee, 340 US. 474. 1-5 iii

Statute: es

National see Relations Act, a8 amended (61

Stat. 136, 29 U.S.C., Sec. 151, et seq.):

Section 7.. /.. Ricnte aos wan

Section 8(a)(1) Lie

11

14

9x the Supreme Court of the Winited States

October ‘TERM, 1963

No. 807

Untrep Arcrarr Corporation, Prarr & WHiITwEx

AIRCRAFT JJIVISION, PETITIONER =~

Vv.

| Nationa Lasor Re.ations Boarp .

ON ‘PETITION FOR A WRIT OF CERTIORARI TO THB UNITED

STATES COURT OF APPBALS FOR THE SECOND O1ROUIT

BRIEF YOR THE NATIONAL LABOR RELATIONS BOARD I”

The opinion of the court of appeals (Pet. 2a-8a) ) is

; reported at 324 F. 2d 128. -The Board's decision and

_ order (J.A. 1-23)’ are reported at 139 N.L.R.B. 39.

30 RISDICTION

The decree ot the court of appeals was entered on

December 2, 1963 (Pet. 9a). The petition for a writ

of certiorari was filed on February 3, 1963. The ju-

‘ References designated “J.A.” are to the decision and urder

» of the Nafional Labor Relations Bourd and to portions of the

testimony and exhibits printed *® # joint appenii< in the court

of appeals.e =

, «i>

" +.

- .

risdiction of this Court is en under 28 U.S.C.

ae QUESTIONS PRESENTED

1. Whether it is an unfair labor practice, regardless

of the availability of other means of distribution, for | )

an employer to ban the distribution of union literature

on company property (such as the area between the

parking lot and the work buildings) during the em-

ployees’ own free time. _

2. Whether substantial evidence sii the

Board’s finding that the literature banned by the ‘em-

ployer did not disrupt discipline or production. -

| STATUTE INVOLVED |

The relevant portioris of the National Labor =

tions Act (61 Stat. 136, 29 U.S.C. 151, et seq.) are set

forth at page la of the petition.

STATEMENT

A. THE BOARD’S FINDINGS OF FACT

Petitioner is a manufacturer of aircraft engines

' and parts. Since 1953, it has had a contract with

UAW ®* Loeal 1234, the certified bargaining repre- °

~ sentative of production and maintenance employees -

_at.its North- Haven plant (J.A. 7; 80-81). -In Sep-

tember 1959, about half of the approximately 3500 -

. employees in the unit were members of the Union,

but between then and May 1960 the unit increased

to 4100 or 4200 employees (J.A.-7, 9; 80-82). The

collective agreement had no union -seeurity provision

(J.A. 96; 102).

2 International Union, United Automobile, Aire raft, and Agri-

cultural Liplement Worker-, APL-C1O.

hs

*’

od »

. -

Prior to 1956, the Union distributed literature to

petitiondr’s employees off Company premises, gen-

erally at the base of a ramp connecting the Company

parking lots with the publie highway” (J.A, 7; 156).

In 1956, the ‘Company gave the Union permission to

distribute jiterature at two tunnel entrances to the.

plant through which employees customarily. walked

to work after parking their cars on the adjacent.Com-

pany parking lots (J.A. 7; 156). Thereafter, and -

until petitioner promulgated its no-distribution rule

- on September 16, 1959, employees distributed union

literature to fellow employees be fore they reported to

- work,’ by standing | in the parking lots about 10 feet

“from the entrances to the tunnels leading to the plant —

(JA. 7-8 ; 82-85).

In May 1959, while the Loeal was heine adminis-

tered by Greenberg on behalf of the International .

Union, the Union distributed two leaflets which, inter

alia, characterized petitioner’s officials as “ Fascists,’’

“Communists’”’ and ‘Storm Troopers’’ (J.A. 8; 66,

67-69, 88). Greenberg -was replaced in June 1959,

when employee Warren Chamberlain was elected pres-

ident of the Local. (J.A. 8; 80, 88). Thereafter, Wil-

fred Hall; petitioner’s North Haven plant personnel

manager, called Chamberlain to his office to discuss

any problems Chamberlain or the Union “felt they

might have”? (J.A. 8; 149, 152). Hall ’ protested

aguinst leaflets, like those Greenberg had distributed,

"The Union did not attempt ‘to distribute literature to em-

ployees as: they left work because “they are rushing. for their

cars pell mell”’¢ employees came to work much more leisurely

(J.A. 109).

ed

ges on

%

4

complaining that they had vilified Company officials

with unfounded accusations (J.A. 8; 153), and urgéed

_ the Union to discuss complaints with: management -

before airing them in its leaflets (J.A. 8; 90, 164).

_ Chamberlain told Hall that the Union Was dis-

satisfied with certain cafeteria conditions,‘ and com-

plained about the delay which employees encountered

upon leaving the parking lots at the close of their

shift, and about poor ventilation in the plant (J,A.

8-9; 90-% 116). As a result of this conversation,

‘Chamberlain “‘understood’’ that Hall was going to look | |

into these conditions, but never. heard anything more:

about them (J.A. 91).

From June 23 to September 16, 1959, Chamberlain

prepared a series of ‘six Jeaflets which employees dis-

tributed at the tunnel entrances to petitioner's plant

(J.A. 9; 91, 92). These leaflets (J.A. 28-42) criti-

cized food quality, high prices, and unclean trays in

the cafeteria; voiced unremedied complaints about

plant ventilation, slow-snoving traffic at the end of the

shifts, and other werking conditions ; announced termi-

nation of the International’s control over the Local’s

affairs; urged members to vote in coming union elec-

tions; objected to a Company official’s personal attack

upon the Union president during a grievance proceed-

ing; and appealed to. nonmembers to join the Union

so that-they might “pay their way’’ and help the _

' Union secure an increase in membership, essential to

Victory in its fight for a better contract (J.A. 9; 91-92,

* Chamberjain testified that he complained about the “greasy

French fried / potatoes” and “trays not being cleaned” (J.A.

90, 91). Pa ; ey

rg : ~

“s

- §

3-114). The Union also isssed three other leaflets,

a prepared by Chamberlain, juring this period.

“These (J.A. 48-55) announced | tle pendmg end of

the International's administration of the Local; urged

the selection of competent stewards and committee-

‘men ; announced a forthcoming grievance meeting with *

petitioner; criticized petitioner’ s vice president for

not meeting to discuss employee vacation schedules ;

and complained that an employee’s improvgment sug-

gestion had gone unrewarded. None of the. leaflets: ©

distributed after June 1959, characterized Company

officials i in terms like those used in the earlier leaflets,

to-which petitioner had objected (J.A.-9; 163).

At a meeting with the Union on July 10, 1959,

Personnel Manager Morse criticized the leaflets,

singling out the objectionable matter in the earlier

(Greenberg leaflets (J.A. 10; 160; 161, 166). Morse

reminded the Union that ‘distributing literature on

Company property was a privilege, not.a right, and

that this privilege could be lost (J.A. 10; 160). At

another grievance meeting held about the beginning:

of September 1959, Assistant Personnel .Manager

Corper criticized Chamberlain ‘for telling petitioner

. how to run its cafeterias and warned him that the

cafeterias were operated for the convenience of the

employees and might. be discontinued (J.A. 10; 89).

- Around the first of September 1959, many of the’ —-

employees on the ll.and 11:15 a.m. eating shift boy:

cotted one of the cafeterias by bringing a) own

- Junehes (J.A. 10; 150-151). Some booed those who

approached the food line (J.A. 10; 151), but ‘petitioner

did not complain to Chamtbe ‘rlain ‘about the situation

6

(J.A..10; 134, 160) although the booing incidents con-

tinued for about two weeks. The incidents prompcy

stopped when pétitioner warned the employees that, if

‘gu¢h conduet continued, they might be disciplined or

-. forbiddén to use the carceria (JA: 10; 151-152,. 158-

" 159). The. protest was not organized by the Union

GIA. 119). . cats

On September. 16, 1959, Hall callee# Chamberlain

into his office and told him, that, since the Union had

abused the pr ivilege of distr ibuting literature on Com-

pany property, petitioner was withdrawing it (JA.

11; 86, 96, 155). “Hall referred to “the litter problem

whieh hi _ been disei usseq With Chambe ‘rlain’s predés__

cessors, ’ and to an 25) cident in December 1958, when

Golentana, 1 former Ghion president; allegedly spoke

Improperly to an employee while handing out leatlets

and was ‘permanently barred from distributing them

as a result ( J.A. 11; 87). “Hall objected to leaflets

“designed to incite employees and to. tell them what

_a lousy place Pratt Whitney was to work,” and to the

Union's use af the Company's “front porch, so to

speak tor such a purpose’? (J.A. 11; 86-87, 155).

Hall. insisted that “Chamberlain’s predecessor * * *

had written these things and no matter how subtly

Chamber lain might have attempted to — iis thy Crs,

I eould see no‘appreciable difference’ | (J.A. 11; 155).

Finally,-Uall warned that “ ‘anyone who atterpted to

> Hall testified at the hearing that leaflets littered the tunnei

rei .on days when Hyers were distributed (J.A. 157), but the

Company had never previously complained about this. problem:

o

to Ciguiberlain (JA. 11:86). -

£

‘

hand out flyers on company property would be escorted

_off the property”? (J.A. 87, 156). :

Sinee the promulgation of the rule against distribu-

tion on Company property, employees haye been dis-

tributing union literature on a pablic highway. at the

foot of a ramp leading to the parking lots, handing —

“flyers tc employees as they drove to work (J.A. 11;

89, 97).° 7 a. ye

om, 3 See

B. THE BOARD’S CONCLUSIONS AND ORDER

‘The Board. found that petitioner’s bai was

prompted by the content of the leaflets distributed

after Chamberlain took office and not by the littering

problem or the 1958.Celentano incident (J.A. 11, 15).

It further found that the post-Chamberlain leaflets.

were designed to improve working conditions ‘and

union organization, matters of vital interest to the em-

ployees; that the relevant, sharp criticism contained

in those léaflets was neither malicious nor ** deliberately

untrue’’:! and that the leaflets neither advocated nor

contributed to the spontaneous cafeteria demonstra-

toms CJA. 11, 15-16, 17). Moreover, the Board *

Fed,

“In lighwof its view of the law Ahe Board made no tindings

“concerning the adequacy fof tii method of distributions (J.A%. +

owevér, that distributors must stand

footing whieh is slippery when

f near accideats, and that

‘ibuting leaflets (uA.

18). The record shows,

between lines of cars on slop:

wet, that there have been i mimnbe

a car mitror struck one employee dis

97-99). .

* The epithets “Communist.” “Fascist.” and “storm Trooper”

were not repeated in the leaflets distributed by Chamberlain

(JA. 16), and the earlier leaflets were not considered by- the

Board in reaching its decision (J.A. 200. 1). |

723. 221---f4—--2

*

a

ee ey ee ee

ee ne 0s

8

found that, even if the leaflets had contributed to the

demonstrations, petitioner’s no-distribution rule was

. not needed to maintain production or discipline, for

threats of disciplinary action had proved sufficient to

curb the booing incidents (J.A. 17).

On these facts, the Board concluded that petitione.:

violated Section 8(a)(1) of the Act by prohibiting =~

employees from distributing union literature on non-

—— time in nonworking areas of the plant (J.A.

2,15). The Board declined to consider the availabil-

ity of other means of distribution, holding that other

means would not excuse the prohibition where, as here, -.

‘the rights of employees, as distinguished from non-

employees, were. involved (J.A.'17-18).- The Board’s

order requires petitioner to rescind its*ban on dis-

tribution during. nonworking time, and to cease and ~

desist trom in “any like or related manner’ inter-

fering with its employees’ right to self-organization

(J.A. 2-3). The order also requires petitioner to

notify the Local and the International that the non-

distribution order is rescinded and to post appropriate

notices << A. -3-4).

. THE COURT OF APPEALS’ DECISION _ a ew

The court of appeals held that the record sealant

the Board's findings of fact that the ieaflets were not

improper and did not disrupt production or discipline

(Pet. 3a’ It also held that the Board did not err -

in failing to consider the availability of alternative

‘means oi communication (Pet. 4a-8a). Accordingiy,

the court enforced the Board’s order in full (Pet. 8).

9

ee The court of appeals correctly rejected petition-

er’s argument that the Board should weigh the alter-

native means of communication available to employees

in this particular. case in -testing the validity: of

the employer’s no-distribution ruling: The inquiry

was irrelevant because a rule barring employees from

distributing union literature on company property

such-as a parking lot during their own free. time is an

interference with rights guaranteed by Section 7 re-

cardless of the availability of other means of distribu-

tion. The point was settled almost 20 years ago in Re-

public, Aviatioh: Corp. v. National Labor Relations

Board (the Le Tourneau case), 324 U.S. 793, where the

Court considered. ane expressly rejected petitioner's

contention. In Le Tourneau, as here, the employer

banned the distribution by employees of union litera-

ture in a company parking lot during non-working

time.’ -The company argued that the Be.rd could not

find that the ban was an unfair labor practice unless

there was evidence showing that the rule “interfered

with and discouraged union erganization in the cireum-

stanees and situation of ‘each company” (324 U.S. at

798). The Court noted that there was no “evidence or

a fiiding that the plant’s physical location made solici-

tation away from company property ineffective to reach

prospective union members’’ (pp. 798-799), but never-

* The Court's opinion covered two .cases, Republic Aviation

and National Labor Reletions Board vy. Le TYourneauw lo.

Republic Aviatio. involved a rule,against solicitation of union

membership, whereas Le Zourneau involved a rule against dis-

tribution of union literature.

theless held that the’ ban on the distribution of union

literature by empleyees on their own time violated the

Act. Thé cireumstances were indistinguishable from

those of the present case.

In the Republic and Le Tourneau cases the Court

expressly approved the #oard’s handling of these

problems under*the principles established by Peyton

Packing Co., 49 N.L.R.B. 828, where the Board, calling

ypon its expert knowledge of industrial, conditions,

determined that rules barring union solicitation by

employees on company property outside of working

hours would be presumed undue impediments to self- —

- organization in the absence of evidence that extraordi-

nary circumstances prevailing in the particular plant

made the rule necessary to maintain production or dis-

cipline.”. While this approach allows the employer

to prove some special need that justifies the rule, the

Peyton Packing presumption, as applied and approved

by this Court in Le Tourneau, allows no exceptions

based upon the claim that the union could engage FT)

solicitation or distribute unien literature elsewhere.

The other avenues of distribution Were considered

then, and the balance Was struck i in favor of freedom of

communication regardless of how favorable the alter-

natives might be. The-court below restated the reason

effectively in the present case (Pet. 5a): “In a plant

the entire work iorce may be contacted by a relatively

It was to addure ev idenice relating to a possible disrupt ion of

production or dise ipline, and not evidence relating to alternative

mean= of communication (see Pet. 15), thar the Court thought

« motion for leave to adduce additional evidence in the court

of appeals or before the Board might have been’ granted. 324

[oat ee Ot

1]

small number of employees with little expense., The

solicitors have the Ppportunity for personal coufronta-

tion, so that they can present their message with maxi- |

mum persuasiveness. In contrast, the predictable

alternatives bear without exception the flaws of greater

expense and effort, and a lower degree of effectiveness.”

No subsequent decision qualifies or casts doubt upon

the clear holding-of Republic and Le Tourneau. Na-

—— Labor Relations Board v. Babcock & Wilcox

Co., 351 U.S. 105, dealt with distribution by non-

employees int reaffirmed the ruling in Republic that—.

No restriction may be placed on the émployees’

right to discuss self-or ganization among them-

selves unless the employer can demonstrate that

a restriction is necessary to maintain production

or discipline. * * * [351 U.S. at 113.]°

National Labor Relations Board \. United Steel-

workers of America, 357 U.S. 357, deait only with the

narrow question whether an employer who has adopted

a no-solicitation rule, under circumstances in which it

is conceded to be valid,” commits an unfair labor prae-

tice by enforcing the rule against employees while he

In Vutone, the first of’ the cases covered by the Court's

opinion in Steelrorkers, the employer's broad no- distribution

rule was invalid on its face. but the. General -Counsel neither

alleged its invalidity inthe complaint nor excepted to the

Trial Exanfiner’s =o that it was valid. Vutone, Jnc., 112

NLRB 1153, 1154, n. 2. See also United Sterlirorkers v. Na-

tions! Labor Relitions PRoard, 2455 F. 2d 593, 596 (C.A. D.C.).

In the companion case, Avondale Mills. the emplover prehibited

union solicitation only during working hours. See ational

Labor Relations Roard v. Avondale Mills, 242-F. 2d 669, 670-

671 (CLA. 552s - - ,

ee

- himself enrages in anti-union solicitation. It was

only in this limited context, where the question was

whether the employer had created a condition in which

he and the union had unequal opportunities for com-

munieation, that the Court indicated that: the Board

should consider the alternative avenues available to

the-tinion."

The rule established by Republic and Le Tourneau —

has been followed by the Board and in the courts of

appeals with virtually unbroken uniformity.”

. National Labor Relations Bourd vy. Rockwell Manu-

facturing Co., 271 F. 24 109 \may indicate a departure

in the Third Cireuit~put we doubt that it represents

"The dictum in Steelworkers upon hich petitioner relies

(Pet..17) cannot fairly be read as a #ub silentio overruling of

_ Republic Aviation. ‘The viability of that decision was not chal-

lenged by any party in Steelworkers. See Brief for: the Re-

_spondent in No. 2869, October Term, 1957, pp. 21, 37; Brief for *

Respondent in No. 81, October Term, 1957, pp. 20-24; Brief for

the National Labor Relations Board in No. 81, October Term,

1957, pp. 4, n. 3, 19-20, n. 5, 22.

* See, for example, Olin Industries, /ne. v. National Labor

Relations Board, 191 F. 2d 612, 616-617 (C.A. 5), certiorari de-

nied, 343 U.S. 919. enforcing 86 N.L.R.B. 203; National Labor

Relations Board .. Illinois Tool Works. 153 F. 2d 811, 814-814.

_ (CA. 7), enforemg 61 N.L.R.B.-1129: National Lobor Rela-

tions Board v. La Salie Steel Us., 178 F. 2d 829, 833-834 (C.A.

' 7). certiorari denied, 339 U.S. 963, enforcing 72 N.L.R.B. 411: .

Time-O-Maiic, Inc: vy. National Labor Relations Board, 264

F. 2d 96, 100-101 (CLA. 7), enforcing 121 N.L.R.B. 179; Na-

tional..Labor Relations Board +. Caldwell Furniture Co., 19%

F. 2d 267 (CLA. 4), certioran: denied, 345 U.S. 907, enforcing’

97 N.L.R.B. 1501; National Labor Relations Board vy. Monarch

Tool Co., 210 F. 2d 188, 186-187 (C.A. 6), certiorari derfted, 347

U.S. 967, enforcing 102 N.L.R.B. 1242. See, also, Stoddard. Quirk

Manufacturing Co., 138 NALRB. 615.

13

_ any real difference of opinion or uncertainty concern-

ing the continued vitality of the long-standing princi-

ple. Since the Rockwell decision over, four years

ago, the Fifth Circuit has twice appiied the Le Tour-

neau principle in accordance with the decision below.

National Labor Relations Board v. Walton Mfg. Co.,

289 -F 2d 177, 180-181; National “abor Relations

Board v. Texas Aluminum Co., 300 F. 2d 315. rehear-

ing denied, 303 F. 2d 435." see also Time-O0-Matic,

Inc. v. National Labor Relations Board, 264 '. 2d 96,

100-101 (C.A. 7). Despite’ some of the language

Rockwell is probably to be explaine -d upon special

grounds nov in true conflict with the decision below :

that the employer’s no-distribution rule was promul-

gated six years before the dispute, ‘was premised on its

desire to ‘serve production, order and discipline”” and

the company “enforced its no-distribution rule to

maintain order’’ (271 R. 2d at 116). In the present

case, onthe other hand, petitioner did not succeed in

justifying its rule upon that ground (Pei. 3a; J.A.17).

Accordingly, the Third Circuit may reasonabi; be

expected to adhere to the otherwise uniform current of

authority when the issue is squarely presented. :

2: Petitioner’s other contentions (Pet. 18-20) re

late to “special circumstances”? allegedly justifying its

_no-distribution rule. Each of these contentions, , in

effect, asks this Co 3 to reverse Board findings ef fact

based based upon substantial evidence and ‘affirmed by the -

4 See "18 See also National Labor Relations Beard v. Great Afigntio

& Pacific Tea Co., 277 F. Wd 759. 762-763 (CLA. 5).

14

court of apneals. “There is no basis for further review

of these factual issues. Universal Camera Corp. Vv.

Nativnal Labor Relations Board, .3A0 U.S. 474, 491.

Thus, petitioner says the ban was lunited to literature

telling employees the Company was “a lousy place to

work” and disrupting discipline. The. Board found

‘upon the basis of undisputed testimony—including

that of petitioner’s own witness—that the prohibition .

was general (J.A. 11; 86, 96, 155, 342-343).. More-°

over, petitioner’s contention ‘that the Board’s order,

requires it to permit the distribution of union litera- -

ture which is disruptive of production and discipline

rests on the premise that-the leaflets in fact caused a

_ litter problem’ and the cafeteria disturbances. But,

‘ as to the litter prablem, petitioner admitted in its brief

to the Trial Examiner that its ban was ‘*brought about

solely because of the contents of the literature’? (Br.

p. 10), and the Board found upon substantial evidence

that the littering claim was an afterthought (J.A. 11,

“n. 7;-86). And, as to whether the leaflets caused the

cafeteria d¢monstrations, the Board found upon sub-

stantia. evidence that they did not, and that “it was

Just ag reasonable to infer that the employees engaged

in’such conduct on their own” (J.A. 17; 40).”*

"+ Although Union leaflets criticized pe wer conditions be-

fore and during the two-week demonstration period (J.A. 36, 38,

40-41), per tioner never asked Union Representative Chamberlain

to ciscontinue the criticisins (J.-A. 19; 134-155, 160).

15

CONCLUSION

; For the above stated reasons, the petition for a writ -

of certiorari should be denied. :

‘Respectfully submitted. —

’ ARCHIBALD Cox,

Solicitor General. -

ARNOLD ORDMAN,

General Counsel,

Dominick L. MaNout,

Associate General Counsel,

Norton. J. Come,

, Assistunt General Counsel,

Grorce B. Driessen, .

Attorney,

‘Nattonal Labor Relations Reaid.

Marcu 1964.

*

Q.

1S GOV CORMERT PRIN TINS OFFICE 1964 >