Telephone Number City of Lawrence Elizabeth Valerio, Esq. 617-951-2300 3. Address (street and No., city/town, state, and ZIP code) 5. Fax Number 1 Design Center Place, Suit 600, Boston, MA, 02210 617-951-2323 6. | Employee Organization (if any): SEIU, Local 888, Supervisors 8. 7, Representative to contact 9.

COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF LABOR RELATIONS CITY OF LAWRENCE, Charging Party ) ) ) ) Vv. ) SEIU LOCAL 888, SUPERVISORS AND ADMINISTRATORS, ) ) ) Respondent ) ANSWER TO COMPLAINT 1. Admitted 2. Admitted 3. Admitted 4. Admitted 5. Denied 6. Admitted 7. Admitted 8. Admitted 9. Admitted 10. Admitted 11. Admitted 12. Admitted 13. Denied and calls upon City to prove same. Case No. MUPL-16-5631 14. Denied.

The parties agree that the following three dates between July 1, 2017 and September 30, 2017 are acceptable for scheduling the expedited hearing The dates must be within the following window: Date: Date: Date: COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF LABOR RELATIONS KEKKEEEKREEEEREEEREKERREEREEREEEEREEREEERREEEEKREKEEEEREE In the Matter of * SEIU, LOCAL 888, SUPERVISORS AND ADMINISTRATORS and * * * * CITY OF LAWRENCE * Case No.: MUPL-16-5631 Date

City Attorney City of Lawrence 200 Common Street Room 306 Lawrence, MA 01840 RE: Open Meeting Law Complaint Dear Attorney Boddy: This office received a complaint from Kathleen Runge, dated April 9, alleging that the Lawrence City Council (the "Council") violated the Open Meeting Law, G.L. c. 30A, 18-25.1 Specifically, the complaint alleges that: 1) the Council entered into executive session during its January 13 meeting without first taking a roll

The City of Lawrence is a public employer within the meaning of Section 1 of the Law. 2. The Lawrence Patrolmens Association (the LPA or Union) is the exclusive collective bargaining agent for a unit consisting of police patrolmen employed by the City of Lawrence (the City), The City and LPA are parties to a collective bargaining agreement which is effective by its own terms for the period from July 1, 2012 to June 30, 2015.

LEV efile.dir@state.ma.us www.mass.gov/dlr BOARD MEMBER : JOAN ACKERSTEIN BOARD MEMBER April 19, 2018 Case No # MUP-17-6258 Charging Party: LAWRENCE Respondent: CITY OF LAWRENCE Date Filed: 10/11/2017 POLICE PATROLMENS ASSOC. NOTICE OF COMPLAINT PROCEDURE FOR SCHEDULING HEARING Pursuant to G.L. c. 150E, 11, the Department of Labor Relations (Department or DLR) issues the attached Complaint of Prohibited Practice in the above-referenced case.

COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF LABOR RELATIONS In the Matter of CITY OF LAWRENCE Case No.: MUP-17-6258 and LAWRENCE POLICE PATROLMENS ASSOCIATION CITY OF LAWRENCES ANSWER TO COMPLAINT OF PROHIBITED PRACTICE The City answers the Complaint noting that while many of the alleged facts are admitted the Union has acted in bad faith and the City and the Chief of Police have the managerial prerogative to assign its workforce in the manner best

City - City of Lawrence; 2.

Kelley, LPA and the City of Lawrence have entered into a settlement agreement pertaining to the subjects at issue in the charge filed in MUP-13-3191, and that charge may now be withdrawn. Please advise whether any further information is desired. Thank you for your assistance. Mark J.

Morgan, Brown & Joy 200 State Street Boston, MA 02109 RE: MUP-13-3191 CITY OF LAWRENCE AND LAWRENCE PATROLMENS ASSOCIATION Dear Mr. Esposito and Mr. Connelly: The Division of Labor Relations (Division) has received, docketed and reviewed the above-referenced charge.

The City of Lawrence (City) is a public employer within the meaning of Section 1 of the Law. 2. The School Committee is the Citys collective bargaining representative for the purpose of dealing with school employees. 3. The Union is an employee organization within the meaning of Section 1 of the Law. 4. The Union is the exclusive collective bargaining representative for paraprofessionals in the Towns public schools. 5.

The City of Lawrence (City) is a public employer within the meaning of Section 1 of the Law. Response: Respondents admit the allegations set forth in paragraph 1. 2. The School Committee is the City's collective bargaining representative for the purpose of dealing with school employees. Response: Respondents deny the allegations set forth in paragraph 2, the Lawrence Receiver under G.L. c. 69, 1K holds the power of the School Committee. 3.

Address (street and No., city/town, state, and ZIP code) 237 Essex St Lawrence MA 01840 7. FAX Number EMPLOYER'S LABOR RELATIONS REPRESENTATIVE 8. Name David Connelly, Esq. 9. Telephone Number 617-523-6666 10,11,12,13. Address (street and No., city/town, state, and ZIP code) 200 State St 111th Fir Boston MA 02109 14, FAX Number 15. E-mail address dconnelly@morganbrown.com 16. Firm/Organization Name Morgan Brown EMPLOYEE ORGANIZATION (if any) 17.

Development, serving in his capacity as Chairperson (Chairperson) of the Board (Board) of the Massachusetts Development Finance Agency (the Agency), a Massachusetts body politic and corporate created and established under Chapter 23G of the Massachusetts General Laws (the Enabling Act), with a principal office and place of business at 99 High Street, Boston, Massachusetts, 02110, and Daniel Rivera, an individual with a primary address at 1 Thomas Road, Lawrence

Development, serving in his capacity as Chairperson (Chairperson) of the Board (Board) of the Massachusetts Development Finance Agency (the Agency), a Massachusetts body politic and corporate created and established under Chapter 23G of the Massachusetts General Laws (the Enabling Act), with a principal office and place of business at 99 High Street, Boston, Massachusetts, 02110, and Daniel Rivera, an individual with a primary address at 1 Thomas Road, Lawrence

Development, serving in his capacity as Chairperson (Chairperson) of the Board (Board) of the Massachusetts Development Finance Agency (the Agency), a Massachusetts body politic and corporate created and established under Chapter 23G of the Massachusetts General Laws (the Enabling Act), with a principal office and place of business at 99 High Street, Boston, Massachusetts, 02110, and Daniel Rivera, an individual with a primary address at 1 Thomas Road, Lawrence

Performed and directed the recruiting, interviewing, testing, selection, and induction of new employees EXCUTIVE DIRECTOR MINORITY INFORMATION & REFERAL AGENCY (MIRA), LAWRENCE, MA 1983-1986 Responsible for employees and annual budget. Established adequate metrics and procedures necessary for the management and operation of the agency.

AGREEMENT between CITY OF LAWRENCE and THE LAWRENCE PATROLMENS ASSOCIATION Effective: July 1, 2012 _ Expiring: June 30, 2015 ARTICLE TITLE I.

Address (street and No., city/town, state, and ZIP code) | re 200 Common Street Lawrence MA 01840 _ EMPLOYER'S LABOR 8. Name Elizabeth Valerio | 2. Telephone Number i i a 1. Name | _ | FAX Number 978-722-9200 _ | RELATIONS REPRESENTATIVE 9. Telephone Number ; 617-862-2005 7 ; 10, Hi, 12, 13. Address (street and No. city/town, state, and ZIP ~ 14. FAX Number 1 University Ave, Suite 300B Westwood MA 02090 i | | | \617- 862-2025 code) _ 16.

CITY OF LAWRENCE Respondent. RESPONDENT CITY OF LAWRENCES ANSWER TO COMPLAINT The City of Lawrence, the respondent employer, hereby answers the Complaint of Prohibited Practice (Complaint) as follows: Count 1 1. The City is a public employer within the meaning of Section 1 of the Law. Admitted. 2. The Union is an employee organization within the meaning of Section 1 of the Law. Admitted. 3.

CITY OF LAWRENCE Respondent. RESPONDENT CITY OF LAWRENCES ANSWER TO COMPLAINT The City of Lawrence, the respondent employer, hereby answers the Complaint of Prohibited Practice (Complaint) as follows: Count 1 1. The City is a public employer within the meaning of Section 1 of the Law. Admitted. 2. The Union is an employee organization within the meaning of Section 1 of the Law. Admitted. 3.

FACTS Knightly was a 32-year City of Lawrence employee. He was first hired as a Housing and Sanitary Code Inspector within the Citys Inspectional Services Department. His entire career with the City was within that department. In 1988, he was promoted to the position of Prosecuting Officer, and held that job until his lay off and subsequent retirement. Knightlys position appears as Section 2.72.050 of the Lawrence Municipal Code.

MUP-11-6279 AND SERVICE EMPLOYEES INTERNATIONAL UNION, LOCAL 888 AND AFSCME, COUNCIL 93 Cee YY In the matter of CITY OF LAWRENCE CITY OF LAWRENCES OPPOSITION TO THE UNIONS REQUEST FOR REVIEW Now comes the City of Lawrence (City) and hereby opposes the Request for Review and the Supplementary Statement of Service Employees International Union, Local 888 (Union) of the decision issued in this matter by Hearing Officer Susan Atwater (Hearing Officer)

In the Matter of * CITY OF LAWRENCE * and * SERVICE EMPLOYEES UNION, LOCAL 888 INTERNATIONAL Case No. MUP-11-6279 * Date Issued: . * December 13, 2012 and * AFSCME, COUNCIL 93, AFL-CIO * Hearing Officer: Susan L. Atwater, Esq. Appearances: Charles D. Boddy, Jr. Esq. - Representing the City of Lawrence David B. Rome, Esq. - Representing SEIU, Local 888 Erin L.