Address (street and No., city/town, state, and ZIP code) Dwyer and Duddy, 25 Burlington Mall Rd, S. 411, Burlington, MA 01803 10. Fax Number 781-272-8692 11. This charge is filed against (check one) 12.

Dwyer, BBO #139840 Dwyer and Duddy Attorneys at Law, P.C. 25 Burlington Mall Road, Suite 411 Burlington, MA 01803 781-359-9777 Date: October 19, 2018 F:\BASAS\Negotiations2016MUP18-6820Regression Bargaining\pldg\noticevoluntarylwithdrawal.docx

Fax Number Dwyer and Duddy, 25 Burlington Mall Road, S. 411, Burlington, MA 01803 781-272-8692 11. This charge is filed against (check one) 12.

Dwyer Dwyer and Duddy Attorneys at Law, P.C. 25 Burlington Mall Road, S. 411 Burlington, MA 01803 781-359-9777 Date: September [6 , 2016 CERTIFICATE OF SERVICE a I hereby certify that on September \e , 2016 the attached Notice of Withdrawal of Charge of Prohibited Practice Charge was sent via electronic and regular mail to: Stephen Sutliff, Esquire Office of Labor Relations Boston Police Department One Schroeder Plaza Boston, MA 02120 \ CVV [ Matthew

Dwyer & Duddy, 25 Burlington Mall Road, Suite 411 Burlington, MA 01803 Stephen Sutliff, Esq. Office of Labor Relations/Boston Police Department One Schroeder Place, Boston, MA 02120 Re: MUP-16-5436, City of Boston Dear Mr. Dwyer and Mr. Sutliff: The Department of Labor Relations (Department) has received, docketed and reviewed the above-referenced charge, which alleges that the City of Boston (City) violated G.

Dwyer 781-359-9777 Address (street and No., city/town, state, and ZIP code) Dwyer and Duddy, 25 Burlington Mall Road, S. 411, Burlington, MA 10. Fax Number 01803 781-272-8692 11 This charge is filed against (check one) 12.

Dwyer and Duddy 25 Burlington Mall Road, Suite 411 Burlington, MA 01803 Matthew Buckley, Esq. Valerio Dominello & Hillman, LLC One University Avenue, Suite 300B Westwood, MA 02090 RE: MUP-18-6836 Lawrence, City of and Lawrence Police Patrolmens Association Dear Mr. Dwyer and Mr. Buckley: The Department of Labor Relations (Department) has received, docketed and reviewed the above-referenced charge.

Dwyer, BBO # 139840 Dwyer and Duddy Attorneys At Law, P.C. 25 Burlington Mall Road, Suite 411 Burlington, MA 01803 (781) 359-9777 Date: September 14, 2018 F:\LPA\New15DaySickLeaveRuleMUP- 18-6836\pldg\positionstatementonpre-arbitrationdeferral.docx 7 BaghSoe So eae . ie Pcie, wat ae eis Uae h 2A rg - cac , Fait te Te anges ede. bt * * i EME ee ae a ate ; +h | co 1 ps ct ace, iS et oe iE i a eS, wk ee pk - "s : wy wringer: ive a: oe ee iat tadoo ike

Town of Burlington, 35 MLC 30, 2008), aff'd sub Relations Board, Massachusetts, nom., Town of Burlington 18, 25, MUP-04-4157 (June v. Commonwealth 85 Mass. App. Ct. 1120 (May 19, 2014); 27 SUP-4304 30, MLC 1, 5, (June Employment Commonwealth 2000).

Town of Burlington, 35 MLC 18, 25, MUP-04-4157 (June 30, 2008), aff'd sub nom., Town of Burlington v. 5 Dismissal (cont.) MUP-20-7960 Commonwealth Employment Relations Board, 85 Mass. App. Ct. 1120 (May 19, 2014); Commonwealth of Massachusetts, 27 MLC 1, 5, SUP-4304 (June 30, 2000).

Address (street and No., city/town, state, and ZIP code) Dwyer and Duddy, 25 Burlington Mall Rd, S. 411, Burlington, MA 01803 11. This charge is filed against (check one) 12. 10.

Dwyer, Esquire Dwyer and Duddy Attorneys at Law, P.C. 25 Burlington Mall Road, Suite 411 Burlington, MA 01830 781-359-9777 Dated: October 25, 2016 CERTIFICATE OF SERVICE I hereby certify that the attached Notice of Voluntary Withdrawal was e-mailed on October 25, 2016 to David Murphy, Labor Counsel, Boston Public Schools. /med/__________________________________ Matthew E.

Address (street and No., city/town, state, and ZIP code) 7 Bedford burlington ma 01803 28. FAX Number 781-750-8028 INCUMBENT EMPLOYEE ORGANIZATION'S LABOR RELATIONS REPRESENTATIVE 29. Name Sean Cronin 30. Telephone Number 31,32,33,34. Address (street and No., city/town, state, and ZIP code) 7 Bedford burlington ma 01803 35, FAX Number 781-750-8028 36. E-mail Address 37.

Mirick OConnell 1800 West Park Drive, Suite 400 Westborough, MA 01581-3926 Rodney Pelkey 102 Gorham Street Chelmsford, MA 01824 Sean Cronin AFSCME Council 93, Local 1703 7 Bedford Street Burlington, MA 01803 RE: MCR-19-7090, Town of Chelmsford Dear Mr. Terry, Mr. Pelkey, and Mr.

Town of Burlington v. Labor Relations Commission, 390 See Mass, 157, 163 (1983) (selectmens bargaining authority cannot override the decision of the district attorney to enter any or all criminal cases in the district court or the prosecution of criminal matters).

See Complaint citing Town of Burlington, supra. When an employer improperly implements a nondelegable decision without impact bargaining, the employer need not go back on the exercise of that right. Town of Dennis, supra. Accordingly, the CERB may not now order that the City restore Knightlys prosecutorial work. The most it could order is that he be returned to perform only his non-prosecutorial duties.

Town of Burlington v. Labor Relations Commission, 390 Mass. 157, 166 (1983). see also, Town of Dennis and Local 579, International Brotherhood of Police Officers, 26 MLC 203 (2000).

Fax Number 25 Burlington Mall Road, S. 411, Burlington, MA 01803 This charge is filed against (check one) 11. 781-272-8692 12.

Dwyer and Duddy, P.C. 25 Burlington Mall Road, Suite 411 Burlington, MA 01803 mdwyer@ddelaborlaw.com I ) Ye Thomas Costello, Esq. Labor Counsel Office of Labor Relations Boston City Hall, Room 624 Boston, MA 02201 (617) 635-2784

Town of Burlington, 35 MLC 18, 25, MUP-04-4157 (June 30, 2008), aff'd sub nom., Town of Burlington v. Commonwealth Employment Relations Board, 85 Mass. App. Ct. 1120 (May 19, 2014); Commonwealth of Massachusetts, 27 MLC 1, 5, SUP-4304 (June 30, 2000).