Nolan Perroni, PC 73 Princeton Street, Suite 306 North Chelmsford, MA 01863 MUPL-16-5439, New England Police Benevolent Association Dear Mr. Mason and Mr.

_Address (street and No., city/town, state, and ZIP code) 73 Princeton Street, Suite 306 North Chelmsford, MA 01863 11. This charge is filed against (check one) LJ 12. Employer LJ 413 592 0027 9. Telephone Number 978-454-3800 10.

Town of Chelmsford and Local 877, The Union presented factual evidence to support the 10(a)(1) charge at hearing orally and in writing. With respect to the 10(a)(3) charge, the Union also submitted written analysis that aligned to the facts to the elements of the 10(a)(3) allegation.

The CERB does not analyze the motivation behind the conduct, Town of Chelmsford, 8 MLC 1913, 1916, MUP-4620 (March 12, 1982), aff'd sub nom. Town of Chelmsford v. Labor Relations Commission, 15 Mass. App. Ct. 1107 6 Complaint and Partial Dismissal (cont'd) SUP-22-9223 (1983), or whether the coercion succeeded or failed. Groton-Dunstable Regional School Committee, 15 MLC 1551, 1556, MUP-6748 (March 20, 1989).

The Board does not analyze the motivation behind the conduct, Town of Chelmsford, 8 MLC 1916 (1982), affd sub nom., Town of Chelmsford v. Labor Relations Commission, 1913, 15 Mass. App. Ct. 1107 (1983), or whether the coercion succeeded or failed. Groton-Dunstable Regional School Committee, 15 MLC at 1551. The Board's inquiry focuses on the objective impact that the employer's conduct would have on a reasonable employee under the circumstances.

. - VIA E-MAIL Qua, Hall, Harvey & Walsh 25 Fletcher Street Chelmsford, MA 01824 Joseph Lettiere, Esq. VIA E-MAIL Associate Counsel AFT MA 38 Chauncy Street, Suite 402 Boston, MA 02111 2012-Jun-21 03:10 PM City of Lowell - Law Dept. 978-453-1510 3/5 COMMONWEALTH OF MASSACHUSETTS DIVISION OF LABOR RELATIONS V. SS Case No.

McClure, Esq. 8 Westford Street Chelmsford, MA 01824 Timothy M. Burke, Esq. 160 Gould Street, Suite 100 Needham, MA 02494 Re: MUPL-13-2666 and MUPL-13-2700, Lowell Police Association Dear Mr. McClure and Mr.

McClure, Esquire 8 Westford Street Chelmsford, MA 01824 508-572-2418 BBO# 564713 CERTIFICATE OF SERVICE |, Richard P. McClure do hereby certify that | caused a copy of the foregoing pleading to be served upon the respondent, Lowell Police Association, by mailing, via first-class and electronic mail a copy of same to its attorney of record, Timothy M. Burke on this 8" day of August, 2013. /s/ Richard P. McClure Richard P.

McClure Attorney at Law 8 Westford Street Chelmsford, MA 01824 Phone (508) 572-2418 March 6, 2013 Department of Labor Relations Unfair Practices Investigative Unit Charles F. Hurley Building 19 Staniford Street, Ist Floor Boston, MA 02114 RE: Withycombe and Reyes v. Lowell Police Association Dear Sir/Madam, Please find enclosed for filing, a Charge of Prohibited Practice on behalf of Mr. Robert Reyes and Mr.

FAX Number 230 North Road Chelmsford MA 01824 978-251-5110 EMPLOYER'S LABOR RELATIONS REPRESENTATIVE 8. Name Jay Lang, Ed. D. Superintendent 9. Telephone Number 978-251-5100 10,11,12,13. Address (street and No., city/town, state, and ZIP 14. FAX Number code) 230 North Road Chelmsford MA 01824 978-251-5110 15. E-mail address 16. Firm/Organization langj@chelmsford.k12.ma.us Name Chelmsford Public Schools EMPLOYEE ORGANIZATION (if any) 17.Name 18.

Fax Number 73 Princeton Street, North Chelmsford, MA 01863 978-454-2767 11. This charge is filed against (check one) 12.

Town of Chelmsford, 8 Such authority may be actual, implied, or apparent. Id. The test of an agents apparent authority is whether written or spoken word or any other conduct of the principal can be reasonably interpreted by a third party as consent by the principal to the Leominster acts School done his behalf on Committee, 4 MLC a person 1950, 1951 by to act for him. (citing Neilson purporting (1978) _v.

, Signature and Title of Principal of Petitioning Party Date Signature and Title of Principal Representative of Other Party if Joint Petition If Petition is brought individually, | hereby state That | have caused a copy of this Petition to be Date Served on the Principal Representative of the other Party Signature of Principal Representative of Petitioning Party yf rn a == te - :& HEADQUARTERS 7 Technology Drive, Suite 102 BOSTON REGIONAL OFFICE Chelmsford