COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS Natick Patrol Officers Association, Petitioner Case No. MUP-15-4244 ee ee and Town of Natick, ee Respondent TOWN OF NATICKS ANSWER TO COMPLAINT OF PROHIBITED PRACTICE Respondent, Town of Natick (Town), hereby answers the complaint in the abovecaptioned matter. The Town denies that it has violated the Law, and specifically answers the allegations of the complaint as follows: 1.
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS RREKKKREREKREREEEEKREREEREREKKEREEREEEERREKEERERREEREKEREKER In the Matter of and * * * * * NATICK PATROL OFFICERS ASSOCIATION * TOWN OF NATICK Case No.: Date Issued: MUP-15-4244 February 17, 2017 Hearing Officer: Kathleen Goodberlet, Esq.
COMMONWEALTH OF MASSACHUSETTTS DO NOT WRITE IN THIS SPACE DEPARTMENT OFLABORRELATIONS CHARGE OF PROHIBITED PRACTICE Case No. M.G.L. 6, 150E INSTRUCTIONS: Answer all applicable questions. Date Filed MU e-14-4yy4|O1-07-7S Failing to provide information may result in the dismissal of the charge. File an original and two (2) copies of this form with the Division.
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS ______________________________ Natick Patrol Officers Association, ) Petitioner ) ) and ) ) Town of Natick, ) Respondent ) ______________________________) Case No. MUP-15-4244 TOWN OF NATICKS RESPONSE TO NPOAS REQUEST FOR REVIEW Respondent, Town of Natick (Town), hereby responds to the Request for Review filed by the Petitioner, Natick Patrol Officers Association (NPOA).
On April 10, 2015, the Department ofLaborRelations (Department) issued a Complaint of Prohibited Practice against the Town regarding the failure to satisfy its duty to bargain about the impacts of the deployment, but partially dismissed the charge as it related to the Towns failure to bargain over the decision to deploy of Narcan.
COMMONWEALTH OF MASSACHUSETTS BEFORE THE DEPARTMENT OFLABORRELATIONS In the matter of Natick Patrol Officers Association Case No. MUP-15-4244 and Town of Natick POST HEARING MEMORANDUM ON BEHALF OF THE NATICK PATROL OFFICERS ASSOCIATION I. INTRODUCTION The Natick Patrol Officers Association (NPOA or Union) is the exclusive representative for a bargaining unit comprised of patrol officers employed by the Town of Natick (Town).
Srednicki Department ofLaborRelations 19 Staniford Street, 1 Floor Boston, MA 02114 RE: Lexington Education Association & the Lexington School Committee MUP: 14-3961 Dear Mr. Srednicki: Please enter my appearance as counsel for the Respondent in the above-noted matter. Please direct all notices to my attention. Thank you for your time and attention to this matter. CVE Sincerely. - Colby C. Brunt Counsel for Lexington School Committee cc: Dr.
Srednicki Department ofLaborRelations 19 Staniford Street, 1 Floor Boston, MA 02114 RE: Lexington Education Association & the Lexington School Committee MUP: 14-3961 Dear Mr. Srednicki: Enclosed please find Lexington School Committees Answer to the Complaint of Prohibited Practice. Thank you for your time and attention to this matter, ec iat . fF , . Colby C. Brunt Counsel for Lexington School Committee cc: Dr.
AFFIDAVITS JULIA FINLEY PHYLLIS NEUFELD COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABOR RELATIONS LEXINGTON EDUCATION ASSOCIATION and LEXINGTON SCHOOL COMMITTEE AFFIDAVIT OF JULIA FINLEY I depose and say under the penalties of perjury: 1. My name is Julia Finley and I reside at 15 Grandview Avenue, Lexington, MA 02421- 7513. I was employed for thirteen (13) years as a Special Classroom Teaching Assistant in the Lexington Public Schools.
MURPHY MIRIAM K, FREEDMAN OF COUNSEL August 7, 2015 VIA ELECTRONIC MAIL ONLY kerry.bonner@state.ma.us) ( efile.dlr@massmail.state.ma.us: Kerry Bonner, Hearing Officer Department ofLaborRelations 19 Staniford Street, 1 Floor Boston, MA 02114 RE: Lexington Education Association & the Lexington School Committee MUP: 14-3961 Dear Hearing Officer Bonner: Enclosed please find Lexington School Committees Closing Brief. time and attention to this matter
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS BEFORE THE COMMONWEALTH EMPLOYMENT RELATIONS BOARD REKEEKEEEEKREREEKEEEEEREREEEREEEEEKEERERKEEEEEEERREEEREEERE In the Matter of Case No. MUP-14-3961 Date Issued: February 29, 2016 + LEXINGTON SCHOOL COMMITTEE + + and + + LEXINGTON EDUCATION ASSOCIATION Board Members Participating: Marjorie F. Wittner, CERB Chair Elizabeth Neumeier, CERB Member Katherine G.
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS HREKEKKKRKEREREKEEEEEREKEKREEKEREEKEREEERERKAREEREREREREREE In the Matter of . LEXINGTON SCHOOL COMMITTEE . Case No. and : Date Issued: . October 19, 2015 LEXINGTON EDUCATION ASSOCIATION MUP-14-3961 Hearing Officer: Kerry Bonner, Esq. Appearances: Colby C.
Demarco, Shirley (DLR) From: EFile DLR (DLR) Sent: To: Ce: Subject: Thursday, March 21, 2019 10:55 AM tnorris@nmplabor.com Efile DLR (EOL) Electronic Service of DLR Case Filing The attached charge of prohibited practice and/or petition has been filed electronically with the Department ofLaborRelations.
Roberts Director Department ofLaborRelations 19 Staniford Street, First Floor Boston, MA RE: 02114 MUP-19-7226, Pathfinder Regional Vocational Technical School Committee Dear Mr. Roberts: The Pathfinder Education Association (PEA) decided not to pursue the arbitration to which the Department deferred in the above matter and withdrew it without precedent. therefore withdraws the Charge of Prohibited Practice on the same basis. Thank you.
Roberts, Director Department ofLaborRelations Charles F, Hurley Building 19 Staniford Street, 1 Floor Boston, MA Re: 02114 Pathfinder Education Association and Pathfinder Reg. Voc-Tech School Committee MUP-19-7226 Dear Mr. Roberts: This firm represents the Respondent, Pathfinder Regional Vocational School District in the above-referenced matter. Please allow this letter to serve as the Districts response to the order to show cause.
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS In the Matter of PATHFINDER REGIONAL TECHNICAL VOCATIONAL SCHOOL COMMITTEE, Case No. MUP-19-7226 and PATHFINDER EDUCATION ASSOCIATION.
VIA ELECTRONIC MAIL December 23, 2014 Department ofLaborRelations 19 Staniford Street Boston, MA 02114 Sean Lyman and the Silver Lake Education Association MUPL-14-4200 Dear Executive Secretary Srednicki: Enclosed please find the Response of the Silver Lake Education Association to the Charging Partys Charge of Prohibited Practice. Thank you. Very truly yours, Al Quesiyah Ah, Esq.
Wy f PLA Eustace, Kimberly (DLR) f From: Sent: dlr, efile (DLR) Wednesday, December 03, 2014 10:39 PM To: kimberlyorcuttslea@gmail.com Ce: Efile DLR (DLR) Subject: Electronic Service of DLR Case Filing The attached charge of prohibited practice and/or petition has been filed electronically with the Department ofLaborRelations.
On December 19, 2019, the Massachusetts Nurses Association (Union) filed a prohibited practice charge with the Department ofLabor Relations (DLR), alleging that the Commonwealth of Massachusetts, Department of Mental Health (DMH or Employer) violated Sections 10(a)(5) and derivatively, 10(a)(1) of Massachusetts General Laws, Chapter 150E (the Law).
Powalisz: On December 19, 2019, the Massachusetts Nurses Association (Union) filed a prohibited practice charge with the Department ofLaborRelations (DLR), alleging that the Commonwealth of Massachusetts, Department of Mental Health (DMH or Employer) violated Sections 10(a)(5) and derivatively, 10(a)(1) of Massachusetts General Laws, Chapter 150E (the Law).
Powalisz: The Massachusetts Nurses Association (MNA or Union) appeals from a Department ofLaborRelations (DLR) Investigators dismissal of the above-referenced prohibited practice charge that it filed against the Commonwealth of Massachusetts Department of Mental Health (Employer or Commonwealth) on December 19, 2019.
Respectfully submitted: Department of Conservation and Recreation By its Attorney: ______________________________ /s/Patrick Butler Labor Counsel Human Resources Division 100 Cambridge St, Suite 600 Boston, MA 02114 ph: (617) 878-9785 patrick.butler@mass.gov Dated: April 8,2020 Page 9 of 10 CERTIFICATE OF SERVICE I, Patrick Butler, hereby certify that on April 8, 2020, I e-filed the foregoing with the Department ofLaborRelations at Efile.DLR@massmail.state.ma.us
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS ___________________________________ } } } SUFFOLK COUNTY SHERIFFS } DEPARTMENT } } and } } JAIL OFFICERS AND EMPLOYEES } ASSOCIATION OF SUFFOLK COUNTY } ___________________________________ } In the Matter of Case Number SUP-20-7926 RESPONDENTS ANSWER TO COMPLAINT COUNT 1 The Suffolk County Sheriffs Department (Sheriffs Department and/or Respondent) answers the separately numbered paragraphs
Roberts, Director Commonwealth of Massachusetts Department ofLaborRelations Charles F. Hurley Building 19 Staniiord Street, 1st Floor Boston, Re: and MA 02114 Jail Officers and Employees Association of Suffolk County Suffolk County Sheriffs Department DLR Dear Mr. Case No.
COMMONWEALTH OF MASSACHUSETTTS DO NOT WRITE IN THIS SPACE DEPARTMENT OFLABORRELATIONS Case No. Date Filed CHARGE OF PROHIBITED PRACTICE 03/13/2020 SUP-20-7926 M.G.L. c. 150E INSTRUCTIONS: Answer all applicable questions. Failing to provide information may result in the dismissal of the charge. File an original and two (2) copies of this form with the Division.
The Department OfLaborRelations (DLR) Should Dismiss the Charge Pursuant to 456 C.M.R. 15.05 (7). As indicated in the charge, the Union did not try to resolve the issue before filing the instant charge. 456 C.M.R. 15.05 (7) states: The Department may decline to issue a complaint or may withdraw any complaint issued unless it is satisfied that the charging party has made reasonable efforts to resolve the matter.
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS ****************************************************** In the Matter of * * TOWN OF CHELMSFORD * * and * * N.E.P.B.A.
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS KARRI R KK RIOR KAR IK RRR R ARIK KE IK IKI EERIE EK NER ER In the Matter of * * TOWN OF CHELMSFORD Case No.: MUP-19-7227 * MUP-19-7361 and * Date Issued: July 3, 2019 NEPBA LOCAL 20 * RAR IIA RIOR R RKB RRR REIKI ER ER IBERIA IIIA IR CONSOLIDATED COMPLAINT OF PROHIBITED PRACTICE On March 22, 2019, the NEPBA (Union) filed a charge with the Department ofLabor Relations (DLR), alleging that
Roberts, Director Department ofLaborRelations 19 Staniford Street, 1st Floor Boston, MA 02114 Re: New England Police Benevolent Association, Inc. and Town of Chelmsford DLR Case No. : MUP- 1 9-7227 New England Police Benevolent Association, Inc. and Town of Chelmsford DLR Case No.: MUP-19-7361 Dear Mr.
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS ****************************************************** In the Matter of * * TOWN OF CHELMSFORD * * and * * N.E.P.B.A. Local 20 * * ****************************************************** Case No.: MUP-19-7227 MUP-19-7313 MUP-19-7361 Date Issued: September 8, 2020 Hearing Officer: Sara Skibski Hiller, Esq.
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS ****************************************************** In the Matter of * * Case No.: MUP-19-7227 TOWN OF CHELMSFORD * MUP-19-7313 * MUP-19-7361 and * * Date Issued: September 25, 2020 N.E.P.B.A. Local 20 * * ****************************************************** Hearing Officer: Sara Skibski Hiller, Esq.
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS ****************************************************** In the Matter of * * TOWN OF CHELMSFORD * * and * * N.E.P.B.A. Local 20 * * ****************************************************** Case No.: MUP-19-7227 MUP-19-7313 MUP-19-7361 Date Issued: September 8, 2020 Hearing Officer: Sara Skibski Hiller, Esq.
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS BEFORE THE COMMONWEALTH EMPLOYMENT RELATIONS BOARD ****************************************************** In the Matter of * * TOWN OF CHELMSFORD * * and * * NEPBA, Local 20 * * ****************************************************** Case No.: MUP-19-7227 MUP-19-7313 MUP-19-7361 Date issued: November 16, 2020 CERB Members Participating: Marjorie F.
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS In the Matter of Case No.: TOWN OF CHELMSFORD MUP-19-7227 MUP-19-7313 MUP-19-7361 and Date Issued: September 6, 2022 NEW ENGLAND POLICE BENEVOLENT ASSOCIATION, LOCAL 20 Hearing Officer: Sara Skibski Hiller, Esq.
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS Case Nos. MUP-19-7227, 7313, AND 7361 NEPBA, LOCAL 20, Charging Party, RESPONDENTS POST-HEARING BRIEF and TOWN OF CHELMSFORD, Respondent. I.
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS CHARGE OF PROHIBITED PRACTICE DO NOT WRITE IN THIS SPACE . Date Filed Case No. M.G.L. .150E INSTRUCTIONS: Answer all applicable questions.
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS Case No.: MUP-19-7227 MUP-19-7313 MUP-19-7361 TOWN OF CHELMSFORD and NEPBA LOCAL 20 UNIONS POST-HEARING BRIEF Now comes the Union, NEPBA Local 20, and submits its posthearing brief in the above-captioned matter.
THE COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS CHARLES F. HURLEY BUILDING COMMONWEALTH R EMPLOYMENT 19 STANIFORD STREET 15! FLOOR. CHARLES L D. BAKER PHONE: BOSTON, (617) MA GOVERNOR Fax: (617) 626-7157 KARYN E. POLITO efile.dir@mass.gov IEUTENANT GOVERNOR www.mass.gov/dir PHILIPT, ROBERTS 02114 626-7132 ELATIONS BOARD . MARJORIE F. WITTNER CHAIR KATHERINE G.
COMMONWEALTH OF MASACHUSETTS DEPARTMENT OFLABORRELATIONS FESO AIR ER ACRE MUP-19-7261 eee Case Number: FERRUCCIO ROMEO TOWN OF WINTHROP aU Vv. de go foe tek ded de oak doe eae ee ak ANSWER COUNT ONE 1. The Town admits Paragraphs 1, 2, 3, 4, 5 of the Complaint. 2. The Town denies Paragraph 6 of the Complaint. 3. The Town admits Paragraphs 7, 8, 9, 10, 11, 12, 13, 14, and 15 of the Complaint. 4. The Town denies Paragraph 16 of the Complaint. 5.
THE COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS CHARLES F. HURLEY BUILDING 19 STANIFORD COMMONWEALTH STREET EMPLOYMENT RELATIONS BOARD D. BAKER CHARLES GOVERNOR MA 02114 FLOOR. BOSTON. m PHONE: (617) 626-7132 MARJORIE F. WITTNER KARYN E. POLITO efile.dir@mass.gov KATHERINE G. LEv LIEUTENANT GOVERNOR www.mass.gov/dir FAX: (617) 626-7157 CHAIR Board MemBeR JOAN ACKERSTEIN PHILIP T.
COMMONWEALTH OF MASSACHUSETTS DO NOT WRITE IN THIS SPACE DEPARTMENT OFLABORRELATIONS CHARGE OF PROHIBITED INSTRUCTIONS: Answer all applicable questions. Note: Pursuant to 456 CMR PRACTICE M.G.L. .150E Case No.
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS BEFORE THE COMMONWEALTH EMPLOYMENT RELATIONS BOARD DLR Docket No. MUP-19-7261 FERRUCCIO ROMEO Charging Party, v. TOWN OF WINTHROP, Respondent ) ) ) ) ) ) ) ) ) ) CHARGING PARTY FERRUCCIO ROMEO'S REQUEST FOR REVIEW OF THE DISMISSAL OF CHARGE OF PROHIBITED PRACTICE I.
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS BEFORE THE COMMONWEALTH EMPLOYMENT RELATIONS BOARD DLR Docket No. MUP-19-7261 FERRUCCIO ROMEO Charging Party, v. TOWN OF WINTHROP, Respondent ) ) ) ) ) ) ) ) ) ) CHARGING PARTY FERRUCCIO ROMEO'S REQUEST FOR REVIEW OF THE DISMISSAL OF CHARGE OF PROHIBITED PRACTICE I.
Greenspan: Ferruccio Romeo (Romeo) appeals from two aspects of a Department ofLaborRelations (DLR) Investigators dismissal of the above-referenced charge of prohibited practice.
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS Case No. MUP-16-5329 In the Matter of Blackstone Police Union Local 442 MCOP and Town of Blackstone RESPONDENT TOWN OF BLACKSTONES MOTION TO RESCIND AND REVOKE THE MOTION TO STAY ORDER OF HEARING OFFICER AND NOTICE OF APPEAL AND SUMMARY STATEMENT FILED ON MARCH 2, 2018 .
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS Case No. MUP-16-5329 In the Matter of Blackstone Police Union Local 442 MCOP and Town of Blackstone RESPONDENT TOWN OF BLACKSTONES MOTION TO STAY ORDER OF HEARING OFFICER Now comes the Respondent, Town of Blackstone, and requests a stay of the Order of Hearing Officer Margaret Sullivan issued February 23, 2018.
' Kelley, Gwenn (EOL) From: EFile DLR (DLR) Sent: To: Tuesday, June 28, 2016 12:45 PM spfaff@Iccplaw.com Ce: Efile DLR (EOL) Subject: Electronic Service of DLR Case Filing The attached charge of prohibited practice and/or petition has been filed electronically with the Department ofLaborRelations.
Commonwealth of Massachusetts Department ofLaborRelations Case No. MUP-16-5329 In the Matter of Blackstone Police Union Local 442 MCOP and Town of Blackstone RESPONDENT TOWN OF BLACKSTONES RESPONSE TO CHARGE OF PROHIBITED PRACTICE The Respondent Town of Blackstone hereby answers the Charge of Prohibited Practice in the above entitled matter as follows: 1. The Town of Blackstone has violated G.L. c. 150E ??
Commonwealth of Massachusetts Department ofLaborRelations Case No. MUP-16-5329 In the Matter of Blackstone Police Union Local 442 MCOP and Town of Blackstone RESPONDENT TOWN OF BLACKSTONES RESPONSE TO COMPLAINT OF PROHIBITED PRACTICE The Respondent Town of Blackstone hereby answers the Complaint of Prohibited Practice in the above entitled matter as follows: 1. The Town is a public employer within the meaning of Section 1 of the Law.
F COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS FF HF In the Matter of Case No. MUP-16-5329 & OF BLACKSTONE + TOWN Date Issued: March 14, 2018 * * BLACKSTONE POLICE UNION, MCOP, LOCAL 442, AFL-CIO + & + and KEKKKKKKKEKERERERERKRERERERERRERREREREEEERREREEE Hearing Officer: Margaret M. Sullivan, Esq. Appearances: Stephen C. Pfaff, Esq. - Representing the Town of Blackstone Kareem A.
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS Case No. MUP-16-5329 In the Matter of Blackstone Police Union Local 442 MCOP and Town of Blackstone RESPONDENT TOWN OF BLACKSTONES POST-HEARING BRIEF I.
COMMONWEALTII OF MASSACIIUSETTS DEPARTMENT OFLABORRELATIONS An the Matter of TOWN OF BLACKSTONE 10.2 MUP-16-5329 and BLACKSTONE POLICE UNION, LOCAL 442, MASSCOP., AFL-CIO BRIEF ON BELALF OF THE BLACKSTONE POLICE PATROLMENS UNION STATEMENT OF THE CASE This case involves allegations by the Blackstone Police Patrolmens Union (Charging Party or Union) that the Town of Blackstone (Town) violated G.L.c. 150E 10(a)(3), and derivatively, 10(a)(1).
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS ************************************************) HOLYOKE PUBLIC SCHOOL SECRETARIES ) ASSOCIATION ) Charging Party ) and ) ) RECEIVER OF THE HOLYOKE PUBLIC SCHOOLS ) and HOLYOKE PUBLIC SCHOOL COMMITTEE ) Respondents ) ) ************************************************ ************************************************) HOLYOKE PARAPROFESSIONALS ASSOCIATION ) Charging Party ) and ) ) RECEIVER
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS ) ) Charging Party ) ) and ) ) RECEIVER OF THE HOLYOKE PUBLIC SCHOOLS ) AND HOLYOKE SCHOOL COMMITTEE ) Respondents ) HOLYOKE PUBLIC SCHOOL SECRETARIES ASSOCIATION Case No. MUP-15-4956 ) HOLYOKE PARAPROFESSIONALS ASSOCIATION ) Charging Party ) ) and ) Case No.
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS HOLYOKE PUBLIC SCHOOL SECRETARIES ASSOCIATION Charging Party ) ) ) ) and ) Case No. MUP-15-4956 ) RECEIVER OF THE HOLYOKE PUBLIC SCHOOLS ) AND HOLYOKE SCHOOL COMMITTEE ) Respondents ) ) HOLYOKE PARAPROFESSIONALS ASSOCIATION ) Charging Party ) ) and ) Case No.
Demarco, Shirley (DLR) From: EFile DLR (DLR) Sent: To: Tuesday, November 24, 2015 3:14 PM szrike@hps.holyoke.ma.us Cc: Efile DLR (EOL) Subject: Electronic Service of DLR Case Filing The attached charge of prohibited practice and/or petition has been filed electronically with the Department ofLaborRelations.
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OFLABORRELATIONS HRAAKKKKAAAEKEKEKEEREREEEEEEEEEEEEHREEEEEEREREEEREEREEEEREERERREEK In the Matter of HF Case Nos:.: MUP-15-4956 MUP-15-4957 MUP-15-4958 MUP-15-4959 & ASSOCIATION, and HOLYOKE TEACHERS ASSOCIATION, Charging Parties Date Issued: May 24, 2016 HOLYOKE PUBLIC SCHOOLS SECRETARIES ASSOCIATION, HOLYOKE PARAPROFESSIONALS ASSOCIATION, HOLYOKE EDUCATORS & and &F Respondents F&F &F FF HOLYOKE SCHOOL COMMITTEE
Respondents reserve the right to plead, assert and rely upon all additional and proper Affirmative Defenses lawfully available, including those which may be disclosed or discovered through further assertions ofthe Charing Parties or the Department ofLaborrelations. I' - ~~~ f i ! ~ ~ , ~ ~ ~ .~, ~ i~ By their Attorney, David M.