As the Charging Party noted in the cover letter to the appeal, the Charging Party and the Respondent had reached a settlement agreement before the Dismissal of MUP-16-5571 was issued. That settlement agreement is attached to this letter. The Charging Party continues to contend that the Dismissal was based on factual errors and mistakes of law and that the Dismissal was unsupported by the record of the in-person investigation.

Note: The DLR may decline to issue a complaint unless reasonable settlement efforts have been made by the charging party 456 CMR 15.04(1). The Division may refer the charge to a Division mediator for settlement discussions. INFORMATION ON CHARGING PARTY 39. The Charging Party is an Individual (I), Employee Organization (O), Employer (E): 40. Name | - Brookline Fire Fighters Association Local 950 IAFF, AFL-CIO 41.

However, please note that the parties reached a settlement agreement on January 9, 2016, the day before the dismissal was issued, resolving the charge of prohibited practice. Nevertheless, the Charging Party was compelled by the factual and legal errors contained in the dismissal to challenge the Hearing Officers conclusions. If this issue arises again, it is imperative that the charging party not be prejudiced by the erroneous dismissal.

It was agreed ess" upon to remain in abeyance barr ing a settlement. I was wrongful ly support my right to statutory arbi tration. The union president during the process decided to incl executive board as to whether I ude the would be able to access arbitrat ion. This was due to the conflict members within the union.

The Hearing Officer correctly determined that the Union, by agreeing to a settlement that reduced the Union Presidents discipline from a verbal warning to a counseling letter, did not waive its right to file an unfair labor practice charge alleging that the discipline interfered with employees Section 2 rights.

Leo. and Wallace Kisiel are Assistant a member of bargaining (11) The Executive Director caucused with his staff and agreed to Attorney DeLoreys settlement proposal, stating that he believed the point had been sufficiently made and that there was no need for the dispute to continue. On August 12, 2010, as part of a negotiated settlement (the terms of which were proposed by the union), Mr.

Thompsons discipline must be dismissed due to the Parties settlement of the matter as described above, the established legal authority used by the Hearing Officer in analyzing the Sanford letter was correct, as well as the authority in addressing this current challenge, and the Union has failed to establish an error of law on part of the Hearing Officer.

ARTICLE.xxxJ:\T ...APPENDICES 78 ARTICLE XXXV SCOPE ANi) DURATION 79 APPENDIX A UNIT A POSITIONS 80 APPENDIX B UNIT A SALARY AND CLASSIFICATION PLAN, JULY 1, 1992 THROUGH JUNE 30, 1994 83 ~ APPENDIX C .PRIOR PRACTICES APPENDIX D REORGANIZATION MEMORANDUM OF AGREEMENT, WITH SUPPLEMENTAL AGREEMENT, SUPPLEMENTAL AGREEMENT (NO.2), AND SUPPLEMENTAL AGREEMENT (NO.3) 90 SETTLEMENT AGREEMENT (MIS) 1 02 APPENDIX E 87 APPENDIX F APPENDIX G APPENDIX H SETTLEMENT

[| Yes No No, the Union is concerned that further retaliation will start once settlement discussions commence, Note: The DLR may decline to issue a complaint unless reasonable settlement efforts have been made by the charging party. 456 CMR 15. 04/7). INFORMATION ON CHARGING PARTY 17. Name AFSCME Council 93 19. 18. Representative to contact 20.

No, the Union is concerned that further retaliation will start once settlement discussions commence. Note: The Division may decline to issue a complaint unless reasonable settlement efforts have been made by the charging party. 456 CMR 15.04 (1) INFORMATION ON CHARGING PARTY 18. Name 19. Representative to contact 21. Telephone Number AFSCME Council 93 Joseph DeLorey 617-367-6025 20. Address (street and No., city/town, state, and ZIP code) 22.

In addition, the Parties are directed to confer as to whether they are willing to engage the services of a DLR Mediator for possible settlement. Utilization of a mediator will not delay the commencement of the Hearing .

It is also my position that the Union brokered a settlement with the Citys Labor Relations Department behind my back in an effort to create a new position that would benefit the Union. Attorney Magner admitted to meeting with the city to negotiate a settlement to keep the position within the Union and had discussions about how much I would get paid.

Note: The DLR may decline to issue a complaint unless reasonable settlement efforts have been made by the charging party 456 CMR 15.04(1). The Division may refer the charge to a Division mediator for settlement discussions. INFORMATION ON CHARGING PARTY 39. The Charging Party is an Individual (1), Employee Organization (QO), Employer (E): |! 40. Name 41. Representative to contact 42.

Gates Associate Counsel cc: Wendy Chu, Esq. 90 North Washington St 3" Floor Boston, MA 02114 WWW.MOSES-MA.ORG Telephone: (617) 367-2727 (800) 845-1141 Centrex (617) 727-9170 Fax (617) 367 9371 COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF LABOR RELATIONS ) MASSACHSUETTS ORGANIZATION OF STATE ENGINEERS AND SCIENTISTS, Charging Party ) ) ) ) and ) SUP-14-3910 ) COMMONWEALTH OF MASSACHUSETTS (Department of Public Safety), Respondent } ) ) ) SETTLEMENT

16. ves VV) LI No 7 .04(1). been made by the charging party 456 CMR int unless reasonable seitlement efforts have Note: The Division may decline to issue a compla mediator for settlement discussions. The Division may refer the charge to a Divison INFORMATION ON CHARGING PARTY Name 17. Mass. Organ. of State Engineers and Scientists 18. Representative to contact 20. Telephone Number Eric P.

All documents constituting any settlement agreement between an identified person and the Town referenced in a news article on March 16, 2018 and in a copy of civil litigation complaint (complaint) filed in Essex Superior Court; 2. All documents and correspondence received or sent to settle the matters raised in the complaint (including any payment; copy of any checks, etc); 3.

The parties have agreed to a settlement in principle in which Messrs. Hurley and Ford have agreed to accept a significantly reduced amount of damages in return for being promptly promoted to such sergeant positions. In order to effectuate this settlementall parties are jointly requesting the Civil Service Commission, acting pursuant to its powers 5 set forth in Chapter 310 of the Acts of 1993, to order that Mr. Hurley and Mr.

2 Note: The DLR may decline to issue a complaint unless reasonable settlement efforts have been made by the charging party 456 CMR 15.04(1). The Division may refer the charge to a Division mediator for settlement discussions. INFORMATION ON CHARGING PARTY 39. The Charging Party is an Individual (I), Employee Organization (O), Employer (E): O 40. Name United Auto Workers, Local 1596 42. Telephone Number 781-821-8100 41.

SIEGEL (RETIRED) www.segalroitman.com _______ *Also admitted to the New York Bar **Also admitted to the New Hampshire Bar ***Also admitted to the District of Columbia Bar ****Also admitted to the New Jersey Bar January 20, 2023 By E-File Department of Labor Relations Lafayette City Center 2 Avenue de Lafayette Boston, MA 02111-1750 Re: Withdrawal of MUP-22-9035, MUP-22-9348, CAS-22-9349, and CAS-22-9449 To whom it may concern: Pursuant to a settlement

Yes No Note: The DLR may decline to issue a complaint unless reasonable settlement efforts have been made by the charging party. 456 CMR 15.04(1). INFORMATION ON CHARGING PARTY 17. Name United Auto Workers, Local 1596 19. 18. Representative to contact 20. Telephone Number C.J. Barber, Business Agent 781-821-8100 Address (street and No., city/town, state, and ZIP code) 21. Fax Number 960 Turnpike Street, Suite 2C Canton MA 02021 22.