Marx-Haas Clothing Co.

350 DECISIONS OF NATIONAL LABOR RELATIONS BOARD Marx-Haas Clothing Company and Teamsters Local Union No. 688, affiliated with International Broth- erhood of Teamsters, Chauffeurs, Warehousemen and Helpers of America. Case 14-CA-7630 June 11, 1974 DECISION AND ORDER BY MEMBERS JENKINS, KENNEDY, AND PENELLO On March 22, 1974, Administrative Law Judge John P. von Rohr issued the attached Decision in this proceeding. Thereafter, the Respondent 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 briefs and has decided to affirm the rulings, findings,' and conclusions of the Administrative Law Judge and to adopt his recommended Order. 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 and hereby orders that Respondent, Marx-Haas Clothing Company, St. Louis, Missouri, its officers, agents, successors, and assigns, shall take the action set forth in the said recommended Order. I The Respondent 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 are 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. DECISION STATEMENT OF THE CASE JOHN P. VON ROHR, Administrative Law Judge: Upon a charge filed on October 23, 1973, the General Counsel of the National Labor Relations Board, by the Regional Director for the Region 14 (St. Louis, Missouri), issued a complaint on December 5, 1973, against Marx-Haas Clothing Company,' herein called the Respondent or the Company, alleging that it had engaged in certain unfair I Respondent's answer indicates that the Company is a division of Chromalloy American Corporation. However, there was no motion to correct the pleadings to this effect. 2 At the outset of the hearing the General Counsel moved to amend the complaint by withdrawing the Section 8(a)(3) allegation pertaining to Veronne H. Sheppard. The Charging Party objected to this motion and 211 NLRB No. 66 labor practices in violation of Section 8(a)(1) and (3) of the National Labor Relations Act, as amended, herein called the Act .2 The Respondent filed an answer denying the allegations of unlawful conduct alleged in the complaint. Pursuant to notice, a hearing was held before Adminis- trative Law Judge John P. von Rohr in St. Louis, Missouri, on February 6, 1974. Briefs were received from the General Counsel, the Charging Party, and the Respondent on March 4, 1974, and they have been carefully considered. Upon the entire record in this case and from my observation of the witness, I hereby make the following: FINDINGS OF FACT I. THE BUSINESS OF THE RESPONDENT The Respondent is a Missouri corporation with its principal office and place of business located in St. Louis, Missouri, where it is engaged in the manufacture, sale, and distribution of men's clothing and related products. During the calendar year ending December 31, 1972, Respondent purchased goods and materials valued in excess of $50,000, which were shipped to it from points and places located outside the State of Missouri. Respondent concedes, and I find, that it is engaged in commerce within the meaning of Section 2(6) and (7) of the Act. II. THE LABOR ORGANIZATION INVOLVED Teamsters Local Union No. 688, affiliated with Interna- tional Brotherhood of Teamsters, Chauffeurs, Warehouse- men and Helpers of America, herein called the Charging Party or the Union, is a labor organization within the meaning of Section 2(5) of the Act. III. THE UNFAIR LABOR PRACTICES A. The Issues The issues in this case are: (1) whether Respondent discharged employee Veronne H. Sheppard on October 17 1973, in violation of Section 8(a)(1) and (3) of the Act, and (2) whether Respondent engaged in certain other conduct alleged to be independently violative of Section 8(a)(1) of the Act. B. The Discharge of Veronne H. Sheppard The facts surrounding the discharge of Veronne H. Sheppard, as found herein, are set forth below in accordance with the credited and uncontroverted testimo- ny of this employee. Sheppard was referred to the Respondent for employ- ment by an employment agency a few days before September 17, 1973.3 At the plant office she was inter- viewed by Howard Bodker, the Company's merchandising co-ordinator, for a job either in the texograph department in the factory or for a clerical position in the main office. It asserted that it wished to adduce evidence on behalf of the Sheppard case. In view of well-established authority in support of the Charging Party's position, I overruled the General Counsel's motion and permitted the Charging Party to present evidence on Sheppard's behalf. 3 All dates hereinafter refer to the year 1973. MARX-HAAS CLOTHING CO. was finally agreed that she would be hired in the main office, Bodker specifically informing her that one Mrs. Samuels, who worked in the main office, would be retiring and that she was being hired to replace Samuels. With a starting salary of $500 per month, Sheppard commenced working for Respondent on Monday, September 17. She was placed under the supervision of Mrs. Samuels and apparently also received some instructions from Samuels' assistant, one Joan, whose last name is not reflected in the record. Sheppard's duties in the office were briefly described as involving the preparation of cutting tickets for suits and sports coats. From time to time she and Joan were sent to the eighth floor factory office, located approximately two blocks from the main office, to assist employee Pamela Kinzel with other clerical tasks. This occurred at least eight times during her employment for half or whole day work. Not long after being hired by the Company, Sheppard and Kinzel discussed the possibility of the clerical employees becoming organized and being represented by a union. These discussions soon included employees Roberta Decker and Tom Schultz and usually took place on breaks and during lunch periods in either the lunchroom or in the eighth floor factory office. At one point during these early discussions, Sheppard and Kinzel broached a steward of the Amalgamated Clothing Workers, the collective-bar- gaining agent for Respondent's production amd mainte- nance employees, to seek his advice concerning the organization of the office employees. The steward told them that he would take the matter up with the business agent of Amalgamated. However, the two declined and told the steward that they would contact the Teamsters Union. Shortly thereafter, in about the first or second week of October, Sheppard spoke to her husband about the matter. Her husband, a member of the Teamsters, suggested that she contact Mr. Schneider, a representative of the Charging Union. She did so and made an appointment for the employees to meet with Schneider. The first meeting had to be cancelled, but a second meeting was arranged for October 17 at 5 p.m. On October 15, a Monday, Sheppard went to the union office during her luncheon break and procurred four union authorization cards. These were for the four employees who discussed the Union, namely herself, Kinzel, Decker, and Schultz. She returned to the factory office and gave three of the cards to Kinzel.4 The three employees returned their signed cards while still in the plant to Sheppard just before quitting time and Sheppard took them, including her own signed card, to the Union immediately thereafter. On the same day, October 15, one Delores Crider was referred to Respondent for employment. She was hired that day by Bodker as an inventory clerk in the factory office as assistant to Kinzel. On Wednesday, October 17, Sheppard was assigned to perform some statistical typing in the factory office. After lunch, about 1 p.m., John Rossi, the vice president of Manufacturing, advised Sheppard that the Company was 4 Sheppard testified that she gave Kinzel the cards because Kinzel had easier access to the employees who worked in the factory office. She testified that she (Sheppard) was not working in the factory office at the time. 351 going to hire a Kelly girl as statistical typist because she could perform this work more rapidly. At the same time he told her that Harvey Gerstein, Respondent's executive vice president, wished to see her in the main office. Upon entering Gerstein's office, Gerstein first said that he had a problem and then proceeded to say that he did not know what to do with her [Sheppard] because he had no place to put her. Sheppard testified that when she asked what he was talking about, Gerstein stated "that they were deciding not to go into computerization because it was going to cost too much money, sales were down from last year and they couldn't afford computerization and Chromalloy . . . had advised them against it, so, Sue Douglas could not move into the computer department and I could not take her place." He thereupon added that Joan, the employee with whom Sheppard worked, had been given a clean bill of health after recovering from tuberculosis, that he did not think she would be leaving, that therefore he could not place Sheppard in Joan's spot, and that therefore he had a problem as to what to do with her [Sheppard]. When at this point Sheppard protested that she had not been hired to replace either of the employees mentioned by Gerstein, but rather that she had been hired to train for Mrs. Samuels' job and to replace Samuels when she left, Gerstein responded by "knocking on the table" and stating that he hoped that Samuels would be with the Company for several more years. Continuing, Gerstein finally told Sheppard that he would have to let her go, adding that if the Company had not hired a girl in the factory office on the day before (undoubtedly referring to the hire of Delores Crider on October 15) he would have offered her the job, but that he did not know about it. He then stated that he would call her back if something worked out. After some discussion concerning Sheppard's initial employment fee (which Gerstein said he would pay), Gerstein gave Sheppard a check for 2 days covering October 16 and 17 .5 Sheppard thereupon stated that since she had been paid for the full day, she would like to return to finish the work she was doing and would work until the end of the day. Gerstein stated "no," that he would rather that she left the plant immediately. Sheppard, however, reiterated that since she had been paid she would like to finish out the day. Gerstein again refused, stating that when employees were let go they became too upset to do their work. Sheppard stated that she was not upset, that she could do the work. At this point Gerstein stated that he was getting "very upset," that it was his policy that when he had to let someone go he wanted them to leave immediately. Sheppard thereupon stated that she would not be able to get her car out of the middle of the parking lot because it was blocked in by other cars. Gerstein said that he would have a man get her car out for her. Sheppard thereupon departed. C. Conclusions as to Sheppard I am, of course, cognizant of the well-established rule that the burden is upon the General Counsel, or here the 5 Sheppard had received a check the previous Friday for the regular workweek. The check which Gerstein gave Sheppard at this time had been previously prepared and was in Gerstein's possession when she came to his office. 352 DECISIONS OF NATIONAL LABOR RELATIONS BOARD Charging Party, to show company knowledge in order to establish a violation of Section 8(a)(3) of the Act and that this usually is accomplished by the adducing of some element of direct proof. As to the latter, however, the Board and courts have recognized an exception to the general rule, namely, that company knowledge may be inferred when the entire circumstances so permit. American Grinding & Machine Co., 150 NLRB 1357; Allied Distribut- ing Corporation, 130 NLRB 1348; N.L.R.B. v. Abingdon Nursing Center, 80 LRRM 3232 (C.A. 7, 1972).6 I am convinced that this is a case where the facts, under entire scrutiny, warrant the taking of an inference of company knowledge. The discharge of a leading union advocate is a classic and effective method of undermining a union organization effort. N.L.R.B. v. Longhorn Transfer Service, Inc., 346 F.2d 1003, 1006 (C.A. 5, 1956). In the instant case, the Company discharged Sheppard 2 days after she went to the union office and brought back cards to the plant which were signed by four employees that same day, and but only 3 or 4 hours prior to the first scheduled union meeting which she had arranged for the office employees to attend. As indicated below, however, there is a good deal more to this case than only the patently suspicious coincidental nature of these occurrences. First, the reason given to Sheppard for her discharge, which is the only reason reflected on this record, does not stand up under scrutiny. As previously related, Sheppard was told at the time of her hire that she was being hired for the specific purpose of replacing Mrs. Samuels in the main office. The record reflects, notwithstanding that at times she helped out in the factory office, that Sheppard in fact received training to this end. Conversely, there is no evidence in the record to indicate that Respondent's purpose in so hiring Sheppard was ever changed or modified. At the time of her discharge, however, Gerstein (in generalized terms) told Sheppard that the reason he was letting her go was because the Company could not afford computerization and that therefore Sue Douglas could not move into the computer department. One need hardly point out that this had nothing to do whatever with the position for which Sheppard actually was hired. Equally unrelated to the reason for Sheppard's hire was Gerstein's vague statement that he did not think that Joan, another employee in the main office, would be leaving because she had recovered from tuberculosis. Indeed, when Sheppard finally reminded Gerstein that she had been hired to replace Mrs. Samuels, Gerstein responded by pounding on the table and meeting the question with the evasive statement that he hoped Samuels would remain with the Company for a long time. If nothing else, surely the last statement in itself is entirely inconsistent with Respon- dent's reason for hiring Sheppard in the first instance. Moreover, it will be recalled that Gerstein referred to the hiring of another clerical just the day before with the assertion that did not offer her the job because he did not know about this clerical being hired. Yet, the evidence 6 See also N.L.R.B. v. Melrose Proccessing Co., 351 F.2d 693 (CA. 8); N.L.R.B. v. Ri-Dell Tool Mfg. Co., 486 F. 2d 1406 (CA. 7, 1973); N.L.R.B. v. Murray-Ohio Mfg. Co., 385 F.2d 948 950 (CA. 6, 1966). r After giving Crider a Wonderlick test, Bodker recommended her to Rossi. Crider thereupon went to see Rossi and was thereupon hired by him. reveals that Crider, who also was referred to Respondent by an employment agency, was first interviewed and tested by Howard Bodker . . . and it was Bodker who hired Sheppard.? It therefore appearing that Bodker was the company representative most familiar with Respondent's clerical needs, it is indeed strange that Gerstein would so suddenly interject himself into the picture, terminate Sheppard, and assert to her that he did not know about the filling of a clerical opening on the day before. In short, I would find Gerstein's explanation to Sheppard in this regard as incredible. Secondly, Respondent (who failed to call any witnesses) offered no explanation whatsoever for its precipitant action in so suddenly terminating Sheppard during the early afternoon work hours of Tuesday, a weekday. Absent any reason for taking this action, I think under all the circumstances, some ulterior motive is plainly apparent. Furthermore, it is clear that Gerstein wished Sheppard to be off the premises as quickly as possible. Why else did he refuse her request that she complete her work and finish out the workday. Indeed, clearly indicative of a purpose to seal off the employees from further contact with Sheppard is the fact that Gerstein had her check already prepared and even saw to it that her car would be removed from the crowded company parking lot during the middle of the day. See. N.L.R.B. v. Ra-Rich Mfg. Co., 276 F.2d 451, 454 (C.A. 2, 1960); N.L.R.B. v. Symons Mfg. Co., 328 F.2d 835 (C.A. 7, 1964). Finally, and as reflected in more detail in the succeeding section, the record establishes that Respondent was opposed to the unionization of its clerical employees by the Teamsters Union, the Charging Party herein. Thus, while engaging in coercive interrogation of employees concern- ing the organizational efforts by the Teamsters, Respon- dent's representative made such statements to employees as "why did you go to the Teamsters and not the Amalgamated"; "You know they [the Teamsters] are a rough union and have a bad reputation"; "[You] would be better off if [you] went to the Amalgamated"; and "I guess you know we have been having union difficulties" and ["he (Gerstein) asked if Pam had approached me about the Union" 1.8 In sum, upon the entire record, and particularly in view of the following, I conclude and find that a prime facie case has been presented which establishes that Respondent terminated Sheppard in order to thwart the organizational activity among the clerical employees: (1) the timing of the termination, within 2 days after the cards were signed and but approximately 4 hours prior to the first scheduled union meeting; (2) the sudden and precipitous nature of this employee's termination, including her prompt expul- sion from Respondent's premises by the company vice president; (3) the reason given to Sheppard for her discharge, which was entirely inconsistent with the reason for which she was hired; (4) the hiring of a new clerical employee at or about the same time of Sheppard's termination; (5) the relatively small size of the clerical unit 8 Although these conversations occurred subsequent to Sheppard's termination, Respondent's union hostility as displayed therein is neverthe- less relevant and admissible insofar as it may relate to Respondent's motives in terminating this employee. MARX-HAAS CLOTHING CO. 353 wherein Sheppard's organizational activities took place; (6) Respondent's hostility to the Teamsters Union which sought to organize these employees ; and (7) Respondent's failure to call any witnesses or to present any evidence in explanation of all the foregoing . Accordingly, by its conduct in so terminating Sheppard , I find that Respon- dent violated Section 8(a)(1) and (3) of the Act. D. Interference, Restraint, Coercion On August 25, 1973, the Charging Union filed a petition in Case 14-RC-7505 for a unit comprised of all office and plant clerical employees, exclusive of all other employees and other statutory exclusions. It is undisputed that upon receipt of the above petition on October 26, Respondent Vice President John Rossi engaged in the following conversations with various of the clerical employees: Rossi summoned employee Pamela Kinzel into the lunchroom, asked her to sit down, and began by stating, "I think you know what I want to talk to you about." When Kinzel responded that she did not, Rossi rejoined that a petition had been filed on behalf of the clericals and then stated, "Pam, you always seemed like a pretty smart girl to me, I can't understand why you would want to do something like this . It has really hurt me a lot." Upon Kinzel's reply that she needed more money, Rossi asked, "Do you think a union is really going to help?" Kinzel thereupon gave additional reasons for wanting a union, to which Rossi finally stated, "Well, why did you go to the Teamsters and not go to the Amalgamated?" When Kinzel gave her reasons , Rossi ended the conversation with the statement, "Well, I'm sorry things had to happen this way, we would have worked them out." Cuba Stechmesser, the payroll clerk, was summoned by Rossi to his desk where he first related that a petition had been filed and then asked why the employees choose the Teamsters Union. Stechmesser replied that she "figured" the employees wanted the "strongest union they could get." Rossi responded that the Teamsters Union was "a rough union and have a bad reputation." Stechmesser said that at this point "she had to agree" whereupon Rossi asked why the employees felt they could have better benefits with a union. Stechmesser did not respond, but at this point Janet Decker, an office employee , came up to the desk and was invited by Rossi to join the conversation. Telling her that "this concerns you, too," Rossi proceeded to ask Decker why the Teamster Union had been selected as the organizing agent rather than the Amalgamated. Decker replied that since the clericals were a small group they needed a powerful union. Rossi responded that there were "drawbacks" to unions and the discussion thereupon turned to the pros and cons of Respondent's present working conditions. According to the undenied testimony of Decker, the conversation concluded as follows: He [Rossi] seemed to think that we could be better off if we could have gone to the Amalgamated. He, more or less, tried to push the other Union on us, he said, it had drawbacks. I didn't care to hear anything else so I turned and went to my work. On or about November 13, Vice President Gerstein came up to clerical employee Delores Crider and asked her to accompany him down to the lunchroom to discuss her insurance. When they arrived at the lunchroom Gerstein told Crider that the reason for his mentioning insurance as the topic of discussion was because "he did not want everybody up there to make something out of nothing." He thereupon stated, "I guess you know we have been having union difficulties." When Crider nodded her head, Ger- stein proceeded to ask if she had been approached by Pamela Kinzel about the Union. Crider did not answer. Gerstein then asked if she had signed a union card. Crider replied that she did not have to answer. According to Crider's undenied testimony, Gerstein then ". . . kept trying to find out if Pam was the instigator of the Union ... this is what he was trying to get out of me ... for me to say Pam Kinzel approached me." Crider said that at this point she asked Gerstein if he wanted her to repeat all that he said to Kinzel, whereupon, she testified, "He didn't say anything. He just shut up then. He quit asking me any questions." I find that by all of the foregoing Respondent coercively interrogated employees about their union activities and sympathies and about the union activities and sympathies of other employees, all in violation of Section 8(a)(1) of the Act. IV. THE EFFECT OF THE UNFAIR LABOR PRACTICES UPON COMMERCE The activities of the Respondent set forth in section III, above, occurring in connection with the operations of Respondent described in section I, above, 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 commerce and the free flow of commerce. V. THE REMEDY Having found that Respondent has engaged in certain unfair labor practices I shall recommend that it cease and desist therefrom and take certain affirmative action designed to effectuate the policies of the Act. It having been found that Respondent discharged Veronne H. Sheppard in violation of Section 8(a)(1) and (3) of the Act, I shall recommend that Respondent be ordered to offer her full and immediate reinstatement to her former job or, if this job no longer exists, to a substantially equivalent position, without prejudice to her seniority and other rights and privileges and to make her whole for any loss of earnings she may have suffered from the date of her discharge to the date of Respondent 's offer of reinstatement. Backpay shall be computed in accord- ance with the formula set forth in F. W. Woolworth Company, 90 NLRB 289, with interest thereon computed in the manner and amount prescribed in Isis Plumbing & Heating Co., 138 NLRB 716. Since a discriminatory discharge of an employee goes to the very heart of the Act (N.L.RB. v. Entwistle Mfg. Co., 120 F.2d 532, 536 (C.A. 4)) it will be recommended that Respondent be ordered to cease and desist from in any 354 DECISIONS OF NATIONAL LABOR RELATIONS BOARD manner infringing upon the rights guaranteed employees in Section 7 of the Act. CONCLUSIONS OF LAW 1. Respondent is engaged in commerce and the Union is a labor organization, all within the meaning of the Act. 2. By discriminating in regard to the hire and tenure of employment of Veronne H. Sheppard, thereby discourag- ing membership in the Union, Respondent has engaged in and is engaging in unfair labor practices within the meaning of Section 8(a)(1) and (3) of the Act. 3. By interfering with, restraining, and coercing its em- ployees in the exercise of rights guaranteed by Section 7 of the Act, Respondent has engaged in and is engaging in unfair labor practices within the meaning of Section 8(a)(1) of the Act. 4. The aforesaid unfair labor practices affect commerce within the meaning of Section 2(6) and (7) of the Act. Upon the basis of the foregoing findings of fact and conclusions of law, and upon the entire record in this case and pursuant to Section 10(c) of the Act, I hereby make the following: customarily posted. Reasonable steps shall be taken by the Respondent to insure that such notices are not altered, defaced, or covered by any other material. (d) Notify the Regional Director for Region 14, in writing, within 20 days from the date of the receipt of this Decision what steps the Respondent has taken to comply herewith. 9 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. io In the event the Board's Order is enforced by a Judgment of the United States Court of Appeals, the words in the notice reading "Posted by Order of the National Labor Relations Board shall read "Posted Pursuant to a Judgment of the United States Court of Appeals Enforcing an Order of the National Labor Relations Board." APPENDIX NOTICE To EMPLOYEES POSTED BY ORDER OF THE NATIONAL LABOR RELATIONS BOARD An Agency of the United States Government ORDERS Respondent, Marx-Haas Clothing Company, its officers, agents, successors , and assigns, shall: 1. Cease and desist from: (a) Discharging or otherwise discriminating against any employee because of activity on behalf of Teamsters Local Union No. 688, affiliated with International Brotherhood of Teamsters, Chauffeurs, Warehousemen and Helpers of America, or in any other labor organization. (b) Interrogating employees concerning their union activities and sympathies and the activities and sympathies of other employees, in a manner constituting interference, restraint, and coercion. (c) In any other manner interfering with, restraining, or coercing employees in the exercise of rights guaranteed in Section 7 of the Act, as amended. 2. Take the following affirmative action which is necessary to effectuate the policies of the Act: (a) Offer to Veronne H. Sheppard immediate and full reinstatement to her former job or, if this job no longer exists, to a substantially equivalent position without prejudice to her seniority or other rights and privileges, and make her whole in the manner set forth in the section of this Decision entitled "The Remedy." WE WILL NOT discourage membership in Teamsters Local Union No. 688, affiliated with International Brotherhood of Teamsters, Chauffeurs, Warehousemen and Helpers of America, or any other labor organiza- tion, by discharging or otherwise discriminating against our employees because of their union activities. WE WILL NOT coercively interrogate our employees concerning their union activities or sympathies or the union activities or sympathies of other employees. WE WILL offer Veronne H. Sheppard immediate and full reinstatement to her former job or, if this job no longer exists, to a substantial position, without preju- dice to her seniority or other rights and privileges and make her whole for any loss of pay she may have suffered as a result of the discrimination against her. WE WILL NOT in any other manner interfere with, restrain, or coerce our employees in the exercise of their rights guaranteed them in Section 7 of the Act, as amended. MARX-HAAS CLOTHING COMPANY (Employer) (b) Preserve and make available to the Board or its Dated By agents, for examination and copying, all payroll records, social security payment records, timecards, personnel records and reports, and all other records necessary or appropriate to analyze the amount of backpay due. (c) Post at its plant in St. Louis, Missouri, copies of the attached notice marked "Appendix." 10 Copies of the notice, on forms provided by the Regional Director for Region 14, after being duly signed by Respondent's authorized representative, shall be posted by it for a period of 60 consecutive days thereafter, in conspicuous places, including all places where notices to employees are (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, or covered by any other material. Any questions concerning this notice or compliance with its provisions may be directed to the Board's Office, 210 North 12th Boulevard, Room 448 , St. Louis, Missouri, 63101, Telephone 314-622-4167.