Plastic Workers Local No. 929

PLASTIC WORKERS LOCAL NO. 929 Plastic Workers Local No. 929, International Brother- hood of Pulp, Sulphite, and Paper Mill Workers, AFL-CIO, CLC, and International Brotherhood of Pulp, Sulphite and Paper Mill Workers, AFL- CIO, CLC and Doughboy Recreational, Domain Industries, Inc. Case 26-CB-677 November 24, 1972 DECISION AND ORDER By CHAIRMAN MILLER AND MEMBERS FANNING AND PENELLO On July 24, 1972, Administrative Law Judge' William J. Brown issued the attached Decision in this proceeding. Thereafter, the General Counsel filed exceptions and a supporting brief. Pursuant to the provisions of Section 3(b) of the National Labor Relations Act, as amended, the National Labor Relations Board has delegated its authority in this proceeding to a three-member panel. The Board has considered the record and the attached Decision in light of the exceptions and brief and has decided to affirm the rulings, findings,2 and conclusions3 of the Administrative Law Judge and to adopt his recommended Order, as modified herein. In its exceptions the General Counsel contends, inter alia, that although the Administrative Law Judge correctly found that Respondents violated Section 8(b)(1)(A) of the Act by engaging in the conduct alleged in paragraph 8(r) of the complaint, i.e., by threatening to whip an employee unless he quit working during the strike, the Administrative Law Judge inadvertently confused the testimony of Alton Dunlap with that of James Kimes. According to the General Counsel, it was Kimes, not Alton Dunlap, who testified in support of that allegation. We agree. According to Kimes' testimony, on about December 22, 1971, he was threatened by James Dunlap to the effect that Dunlap would "just have to whip up on" Kimes because he had returned to work during the strike. Therefore, we find that by such conduct, Respondents violated Section 8(b)(1)(A) of the Act.4 ORDER Pursuant to Section 10(c) of the National Labor Relations Act, as amended, the National Labor Relations Board adopts as its Order the recommend- ed Order of the Administrative Law Judge as herein modified and hereby orders that the Respondents, Plastic Workers Local No. 929, International Broth- erhood of Pulp, Sulphite and Paper Mill Workers, AFL-CIO, CLC, and International Brotherhood of Pulp, Sulphite and Paper Mill Workers, AFL-CIO, 200 NLRB No. 64 419 CLC, their officers, agents, and representatives, shall take the action set forth in the said recommended Order, as so modified. 1. Substitute the following for paragraph 1(a) of the recommended Order: "(a) Restraining or coercing employees of Dough- boy Recreational , Domain Industries, Inc., in the exercise of rights guaranteed under Section 7 of the Act by threatening employees with bodily harm, exclusion from pay increases, prevention from working, loss of jobs , beating with clubs, burning of the plant, tailgating employees ' automobiles, threats to whip employees , impliedly threatening burning of homes of employees who worked during the strike, or in any other manner threatening employees of the Company for refusing to support the union strike." i The title of "Trial Examiner" was changed to "Administrative Law Judge" effective August 19, 1972 2 The General Counsel has excepted to certain credibility findings made by the Administrative Law Judge. It is the Board's established policy not to overrule an Administrative Law Judge's resolutions with respect to credibility unless the clear preponderance of all of the relevant evidence convinces us that the resolutions were incorrect. Standard Dry Wall Products, Inc, 91 NLRB 544, enfd. 188 F.2d 362 (C.A 3). We have carefully examined the record and find no basis for reversing his findings. 3 We affirm the Administrative Law Judge's dismissal of paragraph 8(c) of the complaint alleging that Respondents, by Nathan Ashwood, their agent, on or about October 1, 1971, threatened and coerced an employee to sign a union card by telling the employee that if the Union had to set up a picket line they would not allow anyone to cross the line, and if he did not belong to the Union, he would be fired for not reporting to work. Although the General Counsel correctly contends that the Administrative Law Judge inadvertently considered that allegation in light of the testimony of employee Eubanks, when in fact it was employee Blue who offered testimony in support of that allegation , we note that Blue testified to only one conversation with Ashwood. Ashwood's remarks during that conversa- tion were found by the Administrative Law Judge to support the allegations contained in two other paragraphs of the complaint In any event, a finding that Ashwood's remarks also supported the allegation in paragraph 8(c) would be cumulative ; accordingly, we find that the Administrative Law Judge's inadvertent error was not prejudicial 4 In the absence of exceptions thereto, we adopt pro forma the Administrative Law Judge's remaining conclusions that Respondents' conduct violated Section 8(b)(1)(A) of the Act, as set forth in the Administrative Law Judge's Decision TRIAL EXAMINER'S DECISION WILLIAM J. BROWN, Trial Examiner: This proceeding under Section 10(b) of the National Labor Relations Act, as amended, hereinafter referred to as the Act , came on to be heard before the duly designated Trial Examiner at Helena, Arkansas, on April 25, 26, and 27, 1972. The original charge of unfair labor practice was filed January 4, 1972, by the Charging Party, herein was issued February 3, 1972 by the General Counsel of the National Labor Relations Board, acting through the Board's Regional Director for Region 26. It alleged and the duly filed answers of the Respondents denied the commission of unfair labor practices defined within the provisions of Section 8(b)(1)(A) of the Act. At the hearing the parties appeared and participated as noted above with full opportunity to present evidence and argument on the issues. Subsequent to the close of the hearing, briefs were filed by the General Counsel and the 420 DECISIONS OF NATIONAL LABOR RELATIONS BOARD Respondent Unions and have been fully considered. On the entire record herein and on my observation of the witnesses I make the following: FINDINGS OF FACT 1. THE BUSINESS OF THE EMPLOYER INVOLVED The pleadings and evidence establish and I find that the Company maintains a plant and place of business at West Helena, Arkansas, where it is engaged in the manufacture of swimming pools, accessories, and toys. During the calendar year preceding issuance of the complaint herein, the Company sold and shipped products valued in excess of $50,000 from its West Helena plant directly to points located outside the State of Arkansas. I find, as the pleadings establish, that the Company is an employer engaged in commerce within the purview of Sections 2(6) and (7) of the Act II. THE LABOR ORGANIZATIONS INVOLVED The pleadings and evidence establish and I find that the Respondents are, and have been at all material times, labor organizations within the purview of Section 2(5) of the Act. III. THE UNFAIR LABOR PRACTICES For a period of some 3 years preceding the events herein concerned, labor relations between the Company and the local and International unions had been governed by the terms of a collective-bargaining agreement which expired according to its terms on October 1, 1971.1 Negotiations for a new agreement proved unavailing and on November 29 the International union, hereinafter sometimes referred to as the International, and the local union, hereinafter sometimes referred to as the local, struck and picketed the Company's West Helena plant. International Representa- tive C. L. Hughes and Local Union President Homer Rose had headed the Unions' bargaining team and also managed the strike and picketing. The pleadings and evidence establish their status as agents of the Internation- al and the local, respectively. Early in the course of the labor dispute herein involved the local and International promulgated written rules governing picket lines and for picket captains. The rules appear to be designed primarily to insure the manning of the picket line with an adequate complement of pickets but they also contain the provision that the picket line captain on each shift should summon the police to remove a picket who refused to leave the premises after a union request to do so. I credit Rose's testimony that Hughes instructed him to see to it that the picket line captains be selected on the basis of their responsibility in order to minimize trouble on the picket lines. The complaint alleges some 26 instances of union restraint and coercion of employees on and away from the picket lines 2 They are next hereinafter discussed in order, including the allegations of paragraph 8(z) added by amendment with leave of the Trial Examiner at the outset of the hearing. It is alleged in paragraph 8(a) of the complaint that Respondents, by agents including Annie Rowlett, and on or about December 13, threatened a company employee that she would be beaten up if she continued to work during the strike . Mrs. Betty Lou Blalock, hired December 8 as a cutting table worker, testified that on or about December 13 Annie Rowlett , a union member and a striker, drove her car near to where Blalock was standing in the vicinity of the plant and offered Blalock a ride. When Blalock was in Rowlett's car the latter, according to Blalock, said that she was going to have to beat Blalock up if she continued to work during the strike . Annie Rowlett's account of the episode is to the effect that she merely told Blalock that she would appreciate the latter 's refraining from crossing the picket line. I credit Blalock's account of this episode and find that the conversation took the course indicated by the testimony of Mrs. Blalock. In determining the question as to the accountability of the local and International unions for this threat, the statutory touchstone is the provision of Section 2(13) of the Act to the effect that in determining agency the question of whether specific acts were actually authorized or subse- quently ratified shall not be controlling. Rose conceded that although he told the local members to refrain from violence on the picket line, he could not recall cautioning them regarding violence away from the picket line. I credit Blalock's testimony and find that by the threat of Rowlett, the local union engaged in an act of restraint and coercion within the purview of Section 8(b)(1)(A) of the Act. Paragraph 8(b) of the complaint alleges , and the Respondents' answers deny that, through the agency of Nathan Ashwood the Respondents, on or about October 1, threatened an employee in the plant by stating that if the Company granted a raise in pay and an employee were not a member of the Union, he would not participate in the pay raise. Employee Ira Blue, who signed a union card and attended two union meetings but continued to work during the strike, testified that shortly before the strike, Nathan Ashwood told him in the plant that if the employees received a pay increase and Blue were not a member of the Union he would not rece've the increase . Ashwood, a union steward and member of the Union's negotiating committee , testified with respect to other items alleged in the complaint but did not directly deny the testimony of Blue. I credit Blue's testimony and find that the allegations of Section 8(b) of the complaint are sustained by the evidence. Union agents, including Nathan Ashwood, are alleged in paragraph 8(c) of the complaint to have threatened an employee in the plant on or about October 1 and to have coerced him into signing a union card by telling him that unless he signed, if the Union set up a picket line, he would be fired for not reporting. Mathew Eubanks, a utility employee with 7 years' service, testified that sometime in October, Ashwood talked to him in the plant and solicited him to join the Union while threatening him that if he I Dates hereinafter, unless otherwise specified, relate to the calendar year of a prima facie case the allegations of paragraphs 8(f), (n), (o), (q), (s), (w), 1971 Both the local and International unions were parties to the agreement and (x) 2 At the hearing the Trial Examiner dismissed for want of establishment PLASTIC WORKERS LOCAL NO. 929 421 didn't join and the Union picketed he would be kept from entering the plant by clubs and sticks. It is plain that Ashwood talked to Eubanks in October about the matter of joining the Union; Ashwood denied, however, uttering any threats of the type attributed to him by Eubanks. I believe that Ashwood was the more credible witness and recommend dismissal of paragraph 8(c) of the complaint. It is alleged in paragraph 8(d) of the complaint that the Unions, through Ashwood and others, on or about October 1, coerced a company employee in the plant to sign a union authorization card by telling him that he would be sorry if he did not join the Union. It appears that the General Counsel relies on testimony of Ira Blue to establish the allegations of paragraph 8(d). Blue testified that about October 1 Ashwood solicited him to join the Union and told him that if the Union struck and picketed, nobody would cross the line when the Company called him to work and he would lose his job. I credit Blue's testimony which is not specifically controverted by Ashwood and find that the allegations of paragraph 8(d) of the complaint are sustained by Blue's credited testimony The complaint's paragraph 8(e) alleges that Respon- dents, by unknown agents, and on or about November 29 broke an employee's car window in the employee's home driveway, thereby restraining and coercing employees within the scope of Section 8(b)(1)(A) of the Act. This allegation apparently relates to damage done to the car of nonstriker Ira Blue who testified that he signed a union card but worked during the strike. Blue's car was stoned and a window broken by a thrown brick during the night early during the strike. There is no evidence linking this act to the Union or its agents and I recommend dismissal of the allegations of paragraph 8(e) of the complaint.3 Paragraphs 8(g), (h), and (f) of the complaint allege that agents of the Respondents, on or about December 17, at an employee's home, pulled loose the gas line and motor wires of the employee's car, cut the battery cable, and slashed the tires. Nonstriker Lula Mae Carter testified credibly that she was a veteran employee with 12 years' company service and worked during the strike. Sometime during the strike, according to her credited testimony, the gas line and wiring of her car was pulled loose while the car was parked at her home; she also credibly testified that shortly before Christmas the car's battery cable was cut loose and on New Year's Eve two tires were cut. Following the last act of vandalism, according to Mrs. Carter, a striker, Mrs. Brown, called and asked if her car was flat. There appears no convincing evidence to tie these deplorable acts to the Union or its agents and I recommend dismissal of these paragraphs of the complaint. The complaint alleges in paragraph 8(j) that the Union, through agents including Homer Rose and James Dunlap and commencing about November 29, coerced employees of the Company by copying down their automobile plate numbers as they arrived at and departed from the plant. Rose and Dunlap admit that they noted automobile tag numbers and they further credibly testified that Company Personnel Manager Coolidge and other non-striking employees also noted license numbers of some of the strikers' automobiles. I cannot conclude that the mere noting of license numbers in the circumstances here involved amounted to an instance of restraint and coercion within the scope of Section 8(b)(1)(A) of the Act. The complaint alleges in paragraph 8(k) that the Respondent Unions, by their agent James Dunlap, threatened to whip a company employee unless the latter stopped working during the strike. The company employee allegedly threatened was Alton Dunlap, cousin of James Dunlap. Alton, an employee of the Company with 3 years' service, worked during the strike. He testified that James, a striker, approached him downtown on the first day of the strike, cursed him and threatened him, desisting only when Alton Dunlap drew a knife. James Dunlap's account is to the effect that he brought coffee to the picket line at the occasion in question and merely asked Alton why he had changed his mind respecting support of the Union. I credit Alton Dunlap's testimony and find that, through James Dunlap's threat at a time he was acting as picket line captain for the Unions, the Unions engaged in the unfair labor practices alleged in this portion of the complaint. It is alleged in paragraph 8(1) of the complaint that the Unions, through the action of Nathan Ashwood on October 29 in the plant told an employee that if the Union struck he would not be permitted to work and that the Union would use sticks and clubs to prevent his working. Employee Eubanks testified that he worked during the strike and that Ashwood told him in October that if he did not join the Union and was called to work the Union would set up a picket line with sticks and clubs and would prevent him from entering the plant. I credit Eubanks' testimony and find that the allegations of the complaint in this regard are sustained by his testimony. The complaint alleges in paragraph 8(m) that the Unions, by Johnny Smith and or about December 2, threatened an employee on a street in West Helena by stating that unless the Union prevailed the plant would be burned down. Nonstriker Mathew Eubanks testified that sometime in October striker Johnnie Smith told him that if the Union didn't get what it wanted it would burn the plant down. Smith denied the charge. Smith appears to have been the union chief steward. I credit Eubanks' account and find that the allegations of the complaint in this regard are sustained by his credited testimony. It is alleged in paragraph 8(p) of the complaint that Respondents in late December coerced an employee by following her car bumper-to-bumper for over a mile. Arlease James participated in the strike for only 2 weeks. After she had returned to work she was followed home bumper-to-bumper, according to her account, by striker James Williams, a distance of over a mile until she turned off into her driveway. Williams was not located by the Unions to testify respecting this allegation. I credit Arlease James' testimony and find that the following bumper-to- bumper coming soon after the return to work of Arlease James occurred as she testified. I conclude that Williams was acting in the interest of and as agent for the Unions in this episode and that the Unions by this conduct engaged 3 While Blue credibly testified that some 2 weeks after the window would be broken, this testimony is no indication that the initial break was episode striker Geneva Edwards yelled at him that another car window perpetrated by the Union or those acting on its behalf 422 DECISIONS OF NATIONAL LABOR RELATIONS BOARD in unfair labor practice within the scope of Section 8(b)(1)(A) of the Act. Paragraph 8(r) of the complaint alleges that Respondents through agents, including James Dunlap, in a store parking lot on or about December 22, threatened an employee with a whipping unless he refrained from work during the strike. Alton Dunlap, a nonstriker and a cousin of striker James Dunlap who was a picket line captain, testified that at 4:30 p.m on the first day of the strike he was down town when James Dunlap approached him, cursed him, and threat- ened to whip his ass, whereupon Alton drew a knife and James desisted. Although the cousins apparently subse- quently made up, I credit Alton Dunlap's testimony and find that the Union through James Dunlap engaged in the unfair labor practices alleged in paragraph 8(r) of the complaint. Paragraph 8(t) of the complaint alleges that the Unions, through Georgia Thornton, on or about December 8 warned an employee by telephone that she should not have returned to work and that something would have to be done and she would be sorry. Rosetta Peden testified that she struck but abandoned the strike and returned to work about December 8. After her return to work she received a telephone call from Georgia Thornton who said that if she kept on working something would be done. Thornton denied ever speaking on the telephone to Peden. I credit Peden's account and find the allegations of paragraph 8(t) are sustained. Paragraph 8(u) of the complaint alleges that Respondent Unions, through Etta Beard and other agents, on or about November 24 warned an employee at the plant against working dunng the strike by stating that the Union was talking about burning homes of nonstrikers as well as the home of the plant manager. Mrs. G. I. Roberts, a nonunion employee of some 14 years' service, testified that some 5 days before the inception of the strike Etta Beard asked her if she was going to work during the strike and suggested that she not work because the union supporters planned to burn homes of nonstrikers including that of the plant manager. Etta Beard testified that all she said in the talk in question was to ask Mrs. Roberts if she had thought what might happen to her small children if she crossed the line, and that she asked the question from friendship and concern, not malice. I credit Mrs. Beard's account and find that the allegations of the complaint in paragraph 8(u) are not sustained by the evidence and should be dismissed. The complaint's paragraph 8(v) alleges that Respon- dents, by agents including Elenora Williams, in late December threatened an employee by telephone threats that she would have to suffer the consequences if she worked during the strike. Gurlean Williams, apparently no relation to Elenora, testified that on her first day of work Elenora Williams was captain of the picket line and said to Gurlean that she would have to suffer the consequences. This generalized prediction does not amount to a threat of any special or even general misconduct and I recommend dismissal of this paragraph of the complaint. It is alleged in paragraph 8(y) of the complaint that Respondents, by agents including Maxie Key, L G. Bryant, Dorothy Jett, Georgia Thornton, and others, about December 15, gathered in an employee's yard and threatened to whip the employee for working during the strike. The employee involved in this allegation, Rachel Lewis, had worked some 10 years for the Company. She attended union meetings and joined m the strike at its beginning only to quit the strike and return to work 2 weeks later. Her testimony is that on the second day after her return to work, strikers Arlease James and Maxie Key were following her bus home from work. When she alit from the bus near her home her young son told her that some women had been in the Lewis yard and had said that they were going to beat her up. This report of an anonymous threat, not made to or in the presence of Mrs. Lewis cannot be the basis of a finding of restraint and coercion against her and I recommend dismissal of the allegations of the complaint in this regard. By amendment of the complaint at the hearing the allegation was added as paragraph 8(z), to the effect that Respondents by unknown agents on or about December 10 threw a fire bomb against the West Helena home of an employee of the Company. Lula Carter, the employee involved , testified that on the Saturday night before Christmas, a fire bomb was thrown at her house. She reported the incident to the police who investigated the matter apparently without finding the thrower of the bomb. There may be grounds for suspicion that union supporters might have been responsible for the episode but evidence thereof is lacking and I recommend dismissal of paragraph 8(z) of the complaint. In determining the responsibility of the International and local unions it is fundamental that, in accordance with Section 2(13) of the Act , actual authorization or subse- quent ratification of specific acts shall not be controling. In the instant case the evidence clearly establishes that, as appears from the credited testimony of employee James Kimes, early in the course of the strike President Rose informed a meeting of strikers that something would have to be done to keep people from crossing the picket line and tacitly concurred in the statement that they would have to bust some heads . Rose also made it plain that he was not concerned with violence away from the picket line, as appears from the credited testimony of Rachel Lewis. Hughes tacitly concurred in the statements of Rose concerning the permissibility of violent action away from the picket line. IV. THE EFFECT OF THE UNFAIR LABOR PRACTICES UPON COMMERCE The activities of the Respondent labor organization set forth above and there found to constitute unfair labor practices, occurring in connection with the operations of the Employer involved, have a close, intimate, and substantial relationship to trade, traffic, and commerce among the several States and tend to lead to labor disputes burdening and obstructing such commerce and the free flow thereof. V. THE REMEDY In view of the findings above set forth to the effect that the Respondent labor organizations have engaged in unfair labor practices affecting commerce it will be recommended PLASTIC WORKERS LOCAL NO 929 that they be required to cease and desist therefrom and take certain affirmative action which appears necessary and appropriate to effectuate the policies of the Act. On the basis of the foregoing findings of fact and upon the entire record in this case, I make the following: CONCLUSIONS OF LAW 1 Doughboy Recreational, Domain Industries, Inc., is an employer engaged in commerce within the purview of Section 2(6) and (7) of the Act. 2. The Respondents herein are labor organizations within the purview of Section 2 (5) of the Act 3. By restraining and coercing employees of the Company in the exercise of their rights guaranteed in Section 7 of the Act, Respondents have engaged in unfair labor practices defined in Section 8(b)(1)(A) of the Act. 4. The aforesaid unfair labor practices affect commerce within the meaning of Section 2(6) and (7) of the Act On the basis of the foregoing findings of fact and conclusions of law, and upon the entire record in this case, I hereby issue the following recommended 4 ORDER Respondents, their officers, agents, representatives, successors, and assigns, shall. 1. Cease and desist from- (a) Restraining or coercing employees of Doughboy Recreational, Domain Industries, Inc., or any other employer, in the exercise of rights guaranteed under Section 7 of the Act by threatening employees with bodily harm, exclusion from pay increases, prevention from working, loss of jobs, beatings with clubs, burning of the plant, tailgating employees automobiles, threats to whip employees, impliedly threatening burning of homes of employees who worked during a strike, or in any other manner threatening employees of the Company for refusing to support the union strike (b) In any like or related manner restraining or coercing employees of the Company in the exercise of their rights under the Act. 2. Take the following affirmative action which appears necessary and appropriate to effectuate the policies of the Act: (a) Post at their business offices and meeting halls copies of the attached notice marked "Appendix" 5 Copies of said notice, on forms provided by the Board's Regional Director for Region 26, shall, after being duly signed by authorized agents of the local and International unions, be posted immediately upon receipt thereof and be main- tained for a period of 60 consecutive days thereafter, in conspicuous places, including all places where notices to members are customarily posted. Reasonable steps shall be taken by Respondent to ensure that said notices are not altered, removed, defaced, or covered by any other material. (b) Mail signed copies of said notice to the Regional Director for Region 26 for posting by the Company, if it so desires, in places where notices to employees are regularly posted. (c) Notify the Regional Director for Region 26, in 423 writing, within 20 days from the receipt of this Decision, what steps have been taken to comply herewith.6 4 In the event no exceptions are filed as provided by Sec 102 46 of the Rules and Regulations of the National Labor Relations Board , the findings, conclusions , and recommended Order herein shall, as provided in Sec 102 48 of the Rules and Regulations , be adopted by the Board and become its findings, conclusions, and Order, and all objections thereto shall be deemed waived for all purposes 5 In the event that the Board's Order is enforced by a Judgment of a United States Court of Appeals, the words in the notice reading "Posted by Order of the National Labor Relations Board" shall be changed to read "Posted Pursuant to a Judgment of the United States Court of Appeals Enforcing an Order of the National Labor Relations Board " 6 in the event that this recommended Order is adopted by the Board after exceptions have been filed, this provision shall be modified to read "Notify the Regional Director for Region 26, in writing , within 20 days from the date of this Order, what steps the Respondent has taken to comply herewith " APPENDIX NOTICE TO EMPLOYEES AND MEMBERS POSTED BY ORDER OF THE NATIONAL LABOR RELATIONS BOARD An Agency of the United States Government We hereby notify our members, officers, representatives, and all employees of Doughboy Recreational , Domain Industries, Inc., that: WE WILL NOT restrain or coerce employees of the above-named Employer by threatening them with bodily harm, exclusion from pay increases , prevention from working, beatings, burning of the company plant, tailgating automobiles , whippings, loss of jobs, or burning of homes of nonstrikers in reprisal for their refusal to support a strike called by the above-named Unions WE WILL NOT by any of the foregoing or in any like or related manner restrain or coerce employees of the Company in the exercise of their rights under the National Labor Relations Act, as amended. PLASTIC WORKERS LOCAL No. 929 , INTERNATIONAL BROTHERHOOD OF PULP, SULPHITE AND PAPER MILL WORKERS, AFL-CIO, CLC, (Labor Organization) Dated By (Representative) (Title) INTERNATIONAL BROTHERHOOD OF PULP, SULPHITE AND PAPER MILL WORKERS, AFL-CIO, CLC, (Labor Organization) Dated By (Representative) (Title) This is an official notice and must not be defaced by anyone. This notice must remain posted for 60 consecutive days from the date of posting and must not be altered, defaced, 424 DECISIONS OF NATIONAL LABOR RELATIONS BOARD or covered by any other material. Any questions concern - Building, Room 746, 167 North Main Street, Memphis, ing this notice or compliance with its provisions may be Tennessee 38103, Telephone 901-534-3161. directed to the Board's Office, Clifford Davis Federal