relation to the protected activity; triviality of reasons, or shifting and inconsistent reasons, given by the employer; disparate treatment; an employer's deviation from past practices; expressions of animus or hostility towards a union or the protected activity. or Town of Carver, 35 MLC at 48 (citing Melrose School Committee, 33 MLC 61, 69, MUP-02-3549 (September 27, 2006)); Lawrence School Committee, 33 MLC 90, MUP-02-3631 (December 13, 2006); Cape

Town of Carver, 35 MLC at 48 (citing 2 Melrose School Committee, 33 MLC 61, 69, MUP-02-3549 (September 27. 2006)); 3 Cape Cod Regional Technical High School District Committee, 28 MLC 332, 4 335, 5 26 MLC 105, 109, MUP-21 00 (January 28, 2000).

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Decision (cont'd) employer, disparate MUP-17-6211 treatment, an employer's deviation from and 18-6679 past practices, expressions of animus or hostility towards a union or the protected activity. or Town of Carver, 35 MLC at 48 (citing Melrose School Committee, 33 MLC 61, 69, MUP-02-3549 (September 27, 2006)); Cape Cod Regional Technical High School District Committee, 28 MLC 332, 335, MUP-2541 (May 15, 2002).

Decision (cont'd) employer, disparate MUP-17-6211 treatment, an employer's deviation from and 18-6679 past practices, expressions of animus or hostility towards a union or the protected activity. or Town of Carver, 35 MLC at 48 (citing Melrose School Committee, 33 MLC 61, 69, MUP-02-3549 (September 27, 2006)); Cape Cod Regional Technical High School District Committee, 28 MLC 332, 335, MUP-2541 (May 15, 2002).

Town of Carver, 35 MLC at 48 (citing Melrose School Committee, 33 MLC 61, 69, MUP-02-3549 (September 27. 2006; Cape Cod Regional Technical High School District Committee, 28 MLC 332, 4 335, MUP-2541 (May 15, 2002) Bristol County,5 26 MLC 105, 109, MUP-2100 (January 28, 2000). 25.

Town of Carver, 35 MLC at 48 (citing Melrose School Committee, 33 MLC 61, 69, MUP02-3549 (Sept. 27, 2006)); Cape Cod Regional Technical High School District Committee, 28 MLC at 335; Bristol County, 26 MLC 105, 109, MUP-2100 (Jan. 28, 2000); Town of Andover, 14 MLC 1582, MUP-6443 (H.O. March 3, 1988), affd 17 MLC 1475, 1482, MUP6443 (Feb. 6, 1991). Timing alone is insufficient to establish that the employer was unlawfully motivated.

Several factors may suggest unlawful employer motivation, including timing of the alleged discriminatory act, triviality of reasons given by the employer, an employer's deviation from past practices, or expressions of hostility toward a union or the protected activity. .Town of Carver, 35 MLC at 48; Cape Cod Regional Technical High School District Committee, 28 MLC 332, 335, MUP-2541 (May 15, 2002); Bristol County, 26 MLC 105, 109, MUP-2100 (Jan.