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On July 30, the Employer-Petitioner, by letter to the Regional Director, confirmed the
parties' joint telephonic request for a seven day extension of time to file briefs. On July 31,
the Union by letter confirmed its joining in the request was contingent on the Employer's filing
the required documents with the Hearing Officer by August 1, and immediately providing copies to
the Union. On August 2, the Regional Director extended the time to submit briefs to August 14.
On August 2, the Union received copies of the documents the Employer filed with the
Hearing office. Missing from documents were the purchase orders for the past two years
reflecting the payment received for unpaid staff for special projects. On August 8, 1996,
the Union requested that the Regional Director keep the record open until all of the requested
documents are received, by the Regional Office of the National Labor Relations Board ("NLRB"
or the "Board" herein), simultaneously informing the Employer's counsel of the missing
The Union renews its Motion to Dismiss Petitions and Motion Requesting Regional
Director to Rule on Blocking Nature of Pending Unfair labor Practice Charges. (U. Ex. 10) For
the reasons stated in the Motions, this case should be dismissed. This is not a unit
clarification petition as filed, but rather a petition to decertify the Union without any
showing of interest in support thereof. The Employer-Petitioner is attempting to exclude
approximately 200 "unpaid staff" from the existing Unit of approximately 228 employees. The
parties history of collective bargaining has included these employees in the unit, and their
title as "unpaid staff" is actually a misnomer as will be reflected in the record herein.
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