Blagojevich's Illinois Department of Employment Security: Appeal of Determination

Update: October 3, 2006

I talked to Ms. Efia Goosby, Illinois Department of Employment Security (IDES) Supervisor on October 2, 2006 requesting she recuse herself from judging my IDES Appeal. Ms. Goosby refuses to include the Illinois Department of Corrections in my appeal, even though I have persisted in requesting their inclusion because they locked me out from my employment, and that they are the "indirect employer" in this matter. I have also left a message with Ms. Goosby's supervisor Hilda Whittington.

I informed Ms. Goosby one of her line items for discussion in my pre-hearing of September 28, 2006 was "Whether the Administrative Law Judge, Efia Goosby, must disqualify herself from hearing this matter." Ms. Goosby informed me on October 2, 2006 that this issue will be discussed on October 12, 2006 at my "hearing." This is absurd.

STATE OF ILLINOIS
DEPARTMENT OF EMPLOYMENT SECURITY
LABOR DISPUTE DETERMINATION
U.I. PROGRAM SUPPORT DIVISION, LABOR DISPUTE SECTION
33 SOUTH STATE STREET, 9TH FLOOR
CHICAGO, ILLINOIS 60603

APPEAL OF DETERMINATION

I, Fred Nance Jr. (Nance), am an employee of Gateway Foundation (Gateway) working as a Counselor III at Sheridan Correctional Center (Sheridan), a subsidiary of the Illinois Department of Corrections (IDOC). On June 6, 2006 AFSCME (The Union) caused a strike at Sheridan. The Illinois Department of Corrections (IDOC) locked out some Gateway employees, which I am locked out from my employment at Sheridan. Subsequently, I filed for unemployment benefits under the Illinois Unemployment Insurance Act (The Act), Sections 601 and 604. I will address the following to support my eligibility for unemployment benefits.

The Illinois Department of Employment Security (IDES) has decided I am ineligible for unemployment benefits due to a stoppage of work pursuant to Section 604 of The Act. The Act reports, in part, “An individual shall be ineligible for benefits for any week with respect to which it is found that his total or partial unemployment is due to a stoppage of work which exists because of a labor dispute at the factory, establishment, or other premises at which he is or was last employed…For the purpose of disqualification under this Section the term “labor dispute” does not include a lockout by an employer, and no individual shall be denied benefits by reason of a lockout….” I am appealing the decision and/or determination of IDES issued on August 4, 2006.

FINDINGS OF FACT by IDES

1. The COMPANY (Gateway) is engaged in providing substance abuse counseling and treatment services. The COMPANY has a contract with the Illinois Department of Corrections (“IDOC”) to provide substance abuse counseling and treatment services to the inmates of the Sheridan Correctional Center (“SCC”), a facility controlled and operated by IDOC for incarcerating convicted felons.

2. The Union is the recognized collective bargaining representative of counselors employed by the COMPANY to provide substance abuse counseling and treatment services at SCC (“WORKERS”).

3. On June 6, 2006, when negotiations between the COMPANY and the UNION regarding the initial collective bargaining agreement between them ended in an impasse, the WORKERS ceased work and established picket lines at SCC.

4. Some of the workers attempted to cross the picket lines and enter SCC in order to work (“NON-PARTICIPATING WORKERS”), but were refused entry by IDOC. IDOC continues to refuse to let the NON-PARTICIPATING WORKERS into SCC. Some of the NON-PARTICIPATING WORKERS are not members of and do not support the UNION.

5. The COMPANY wants the NON-PARTICIPATING WORKERS to enter SCC and work, but can do nothing about the situation since IDOC has sole and complete authority over who is or is not allowed to enter SCC.

6. IDOC states it refuses to allow entry to SCC to the NON-PARTICIPATING WORKERS because various AFSCME bargaining units are the recognized collective bargaining representatives of correctional officers (i.e., security staff) and other IDOC employees at SCC, and therefore the safety and security at SCC could be disrupted if it allowed the NON-PARTICIPATING WORKERS into SCC in order to work before the differences between the UNION and the COMPANY is resolved.

NANCE’S ARGUMENT

IDES does not address the eligibility requirement of Section 601, therefore, Section 601 is satisfied for Nance. Also, number 2 of IDES’s “Findings of Fact” reports “The Union is the recognized collective bargaining representative of counselors employed by Gateway.” In a newspaper article, The Times, Ottawa, dated July 12, 2006, it reports “ Derek Schnapp, a spokesman for the Illinois Department of Corrections, said he could not discuss the case in detail, as it involves personnel. “All we can say is their case is under review, but they have not yet been cleared to enter the facility,” he said. And AFSCME spokesman Anders Lindall said his union would likely do nothing to help the workers, though Council 31 represents them as the official bargaining unit.” How can AFSCME be my bargaining unit, when their spokesman Anders Lindall reports they will not support or help the “Non-Participating Workers” of Gateway?

The next most compelling issue here in determining eligibility for Nance is Section 604’s “stoppage of work.” IDES reports “There was a stoppage of work because of a labor dispute between the Company (Gateway) and the Workers…”, supporting this statement suggesting the operations of Gateway are not substantially normal since it has not provided any substance abuse counseling and treatment services at Sheridan since The Union ceased work and established picket lines. First, this is not found in IDES’s “Findings of Fact.” Second, this statement supporting IDES’s determination is troubling. The legislature did not include substantially normal in the language of Section 604 to define or described stoppage of work. Also, Gateway has continued providing substance abuse and treatment services pursuant to their contractual agreement with the State of Illinois/IDOC.

In addition, IDES reports “Section 604 of the Illinois Unemployment Insurance Act provides that an individual shall be ineligible for benefits for any week with respect to which it is found that his total or partial unemployment is due to a stoppage of work which exists because of a labor dispute at the factory, establishment or other premises at which he is or was last employed. Case law establishes that for purposes of Section 604, a stoppage of work exists when an employer’s operations are not substantially normal.” Where is the case law cite? This is an arbitrary and biased statement if there is no case law leading to or from the quote of IDES. Additionally, if in the future IDES does provide case law to support this “substantially normal” statement, I should be afforded the right to challenge the “case law” with further research of that case law.

When speaking of their position in this matter, IDES reports on page 4 of their determination “The most straightforward answer requires a reading of Section 604 using the plain and ordinary meaning of the language it contains…Although there do not appear to be any controlling Illinois appellate court or Supreme Court cases….” This is contradictory to their statement of established case law for the language “substantially normal.”

The principles of statutory construction are well established, as the Illinois Supreme Court observed in Bridgestone/Firestone, Inc. v. Aldridge, 179 Ill. 2d 141 (1997): " 'It is a primary rule in the interpretation and construction of statutes that the intention of the legislature should be ascertained and given effect. This is to be done primarily from a consideration of the legislative language itself, which affords the best means of its exposition, and if the legislative intent can be ascertained there from it must prevail and will be given effect without resorting to other aids for construction. There is no rule of construction which authorizes a court to declare that the legislature did not mean what the plain language of the statute imports.’ " Bridgestone/Firestone, 179 Ill. 2d at 149, quoting Illinois Power Co. v. Mahin, 72 Ill. 2d 189, 194 (1978).

IDES does not define “substantially” normal, neither does Section 604. As a matter of “fact” The Act, specifically, Section 604 does use the words “substantially normal.” These words appear to be “created” by IDES. Nevertheless, substantially can be defined as consisting of or relating to substance, not imaginary or illusory, real, true, important, essential; ample to satisfy and nourish, full (a substantial meal); possessed of means (well-to-do), considerable in quantity, significantly great (as a substantial wage), firmly constructed, sturdy (a substantial house), and being largely but not wholly that which is specified (a substantial lie). This is a definition from Merriam-Webster Online, a reference used by IDES to define “due to.” Generally, an issue of this nature is defined by case law or legal reference, which, apparently, IDES does not have to support their claim of denial for a “stoppage of work.”

Gateway has been providing substance abuse counseling and treatment services before and after the strike. For the present argument, pursuant to IDES’s “Findings of Fact” Gateway has a contract with IDOC to provide substance abuse counseling and treatment services. Of course, there are more elements to Gateway’s contractual agreement with IDOC. Illinois Governor Blagojevich spokeswoman Rebecca Rausch reported to the media on Friday, August 4, 2006, that the labor dispute is between Gateway and its employees, so the governor would only step in if the organization's counseling services slipped at Sheridan. Ms. Rausch was quoted as saying “We are monitoring this situation very closely to make sure this vendor is meeting its contractual obligations,” Rausch said. If there was a “stoppage of work” the Governor’s office would have proclaimed it.

On July 26, 2006 the Chicago Tribune headlines “Strike not affecting prison, state says” report, “New inmates are coming in as normal,” said Derek Schnapp, a spokesman for the Illinois Department of Corrections. “It’s been the same business as usual.” In another article by the Chicago Tribune on July 26, 2006 headlined as “Prison Enduring 7th week of strike” it reports, “The Sheridan Correctional Center, one of the nation’s largest drug-treatment prisons, continues to function effectively despite the absence of about 40 striking drug counselors, state officials said Tuesday as the strike entered its seventh week.” Mr. Schnapp made the same statement written above for this article also.

In addition, the article “Prison enduring 7th week of strike” reports “Gateway President Michael Darcy said his company is caring for the prison’s roughly 850 inmates using 22 drug treatment specialist who were previously in supervisory positions and 14 counselors who have crossed the picket line. The people that have crossed the line and our clinical supervisors are able to produce at a higher productivity level than all the striking counselors put together,” Darcy said.”

In the Associated Press release of July 25, 2006 “Prison workers urged to reject union bid” it reports, “Lindall said drug programs for inmates have slipped during the walkout. But prison spokesman Derek Schnapp said Gateway is fulfilling its contract and the state is pleased with services that have been provided since the strike began.”

In addition, the State of Illinois conducted an audit to assure Gateway was in compliance with their contractual agreements. The Governor’s office continuously reports to the media Gateway is living up to its contractual agreements. Therefore, Gateway is “substantially” normal providing substance abuse counseling and treatment services at Sheridan defeating IDES’s claim of “stoppage of work.”

IDES’s heading Determination, states in part, “On the basis of information received, the claims adjudicator determines that the Workers (Gateway employees) in employment with the Company (Gateway) up to June 6, 2006, including the Non-Participating Workers, are ineligible for Unemployment Insurance Benefits under the terms and provisions of Section 604 of the Illinois Unemployment Insurance Act…for as long as their unemployment remains due to a stoppage of work caused by a labor dispute….” There is no stoppage of work by Gateway at Sheridan.

In addition, On August 9, 2006 Gateway called me reporting another counselor has crossed the picket lines and come to work. They report two other counselors have contacted them reporting they will cross the picket lines and come to work later this week or early next week.

If IDOC is allowing striking counselors (“Workers”) to cross the picket lines and go to work the striking “Workers” become “Non-Participating Workers, then the other “Non-Participating Workers” should be allowed to cross the picket lines and come to work. IDES discusses and defines "Workers" and "Non-Participating Workers" in their determination.

IDES's definition of a "Workers", in this matter, is one who works for Gateway at Sheridan; who organized and set up picket lines; and is participating in the strike. IDES's definition of "Non-Participating Workers" is one who works for Gateway and is not participating in the strike.

When the counselors mentioned here for August 9, 2006 cross the picket lines and go to work, they went from "Workers" to "Non-Participating Workers". IDOC is discriminating against Kathy, Lisa, and I. We should be allowed to cross the picket lines and go to work.

To repeat the IDES statement offered by IDOC: "IDOC states it refused to allow entry to Sheridan to the Non-Participating Workers because The Union has various bargaining units that are recognized collective bargaining representatives of correctional officers, i.e., security staff and other IDOC employees at Sheridan, and therefore the safety and security at Sheridan could be disrupted if it allowed the Non-Participating Workers into Sheridan in order to work before the differences between The Union and Gateway is resolved." With the information provided here, I think this just went out the window. IDOC is discriminating against the "original" “Non-Participating Workers” of Gateway.

Next IDES reports “Section 604 provides an exception to the ineligibility for benefits it imposes. Individuals are not ineligible for benefits under Section 604 if they: A) are not participating in, or financing, or directly interested in the labor dispute which caused the stoppage of work; and B) do not belong to the same grade or class of workers of which immediately before the commencement of the stoppage of work there were workers employed at the premises at which the stoppage of work occurs, any of whom are participating in, or financing, or directly interested in the labor dispute.

IDES conveniently leaves out the rest of B, which states, “provided, that a lockout by the employer or an individual’s failure to cross a picket line at such factory, establishment, or other premises shall not, in itself, be deemed to be participation by him in the labor dispute.”

IDES also takes this exception of Section of 604 and reverses it reporting it as positive requirements stating “The Non-Participating Workers are ineligible for benefits under either A or B even if they did not participate in the labor dispute or finance the labor dispute through union dues or other means. First, they clearly have a direct interest in the labor dispute since the terms and conditions of their jobs will be determined by whatever terms and conditions of the Company and Union ultimately agree to.” This is ludicrous.

IDES is putting the cart before the horse. The Non-Participating Workers have no direct interest at the time of filing for unemployment benefits or this appeal determination. IDES cannot predict the future. With this statement, IDES is involved with AFSCME in compulsory unionism.
In addition, IDES states, “Second, they just as clearly belong to a class of workers which immediately before the work stoppage contained members employed at Sheridan….” This is not true in my case. There is no counselor III striking. I am a counselor III. There are numerous civil rights cases, which define and clarify a class of workers. To satisfy the “similarly situated” prong of the prima facie case, an employee must be “directly comparable in all material respects.” Sartor v. Spherion Corp., 388 F.3d 275, 279 (7th Cir. 2004) Being a counselor III is certainly a material aspect of Section 604.

IDES attempts to survive their determination stating the Non-Participating Workers of Gateway are not locked out of Sheridan by their employer because IDOC is not their employer. IDES states in their “Findings of Fact” paragraph 1 “The COMPANY has a contract with the Illinois Department of Corrections (“IDOC”)….” IDOC is there employer!!!

IDES does not discuss the employment relationship as it applies to de facto and/or indirect employer. Gateway is contracted to provide services at Sheridan. This is a given. This contract is provided by IDOC, pursuant to IDES’s statement in their “Findings of Fact.”

Fundamentally in nature, the employer has locked us out of Sheridan. IDOC is not a “third-party” as IDES describes in their determination letter. IDES contradicts itself continuously. IDOC is the “de facto and/or indirect” employer, evidently, with the right to lockout who they please as stated by IDES in their “Findings of Fact” reports “…a facility controlled and operated by IDOC….” IDES presents no precedent law neither cites any legal language to support their position. IDES is clearly misinterpreting their policies promoting the agenda of AFSCME.

Nevertheless, IDES reports IDOC states it refused to allow entry to Sheridan to the Non-Participating Workers because The Union has various bargaining units that are recognized collective bargaining representatives of correctional officers, i.e., security staff and other IDOC employees at Sheridan, and therefore the safety and security at Sheridan could be disrupted if it allowed the Non-Participating Workers into Sheridan in order to work before the differences between The Union and Gateway is resolved.

In General Motors Corp. v. Bowling, 85 Ill. 2d 539, 542 (1981) this court rejected a claim that the members of a union representing the shop clerks at General Motors' plants in Chicago and LaGrange, Illinois, had a direct interest in a labor dispute between General Motors and the members…representing the production workers at the plants. The court recognized that certain parts of the production workers' agreement with General Motors would customarily be copied into the shop clerks' own agreement. The shop clerks, therefore, might anticipate that the strike by the production workers would influence their terms of employment. That, however, was at most an indirect interest. The court explained: "All they had was a hope, not any assurance. A mere expectancy without any legal right, subject to GM's views on the fairness and convenience of adopting parts of another agreement, does not disqualify the shop clerks for unemployment benefits." General Motors Corp., 85 Ill. 2d at 543. This is similar to IDOC’s claim of having a right to lockout Gateway employees because of the expectancy of other union members.

The Illinois Supreme Court in International Union of Operating Engineers, Local 148, AFL-CIO v. Illinios Department of Employment Security et al. (2004) discussed direct interest in a labor dispute under Section 604.

Citing section 604 of the Unemployment Insurance Act (820 ILCS 405/604 (West 1994)), the Department and CIPS maintain that the members of Engineers' Union were not eligible for unemployment compensation benefits because their unemployment was due to a stoppage of work resulting from a labor dispute. Conversely, Engineers' Union maintains that the relieving proviso of section 604 applies, and the members of Engineers' Union were eligible for unemployment compensation benefits.

This Supreme Court stated “Section 604 of the Act provides: "Labor dispute. An individual shall be ineligible for benefits for any week with respect to which it is found that his total or partial unemployment is due to a stoppage of work which exists because of a labor dispute at the factory, establishment, or other premises at which he is or was last employed. This Section shall not apply if it is shown that (A) the individual is not participating in or financing or directly interested in the labor dispute which caused the stoppage of work and (B) he does not belong to a grade or class of workers of which immediately before the commencement of the stoppage there were members employed at the premises at which the stoppage occurs, any of whom are participating in or financing or directly interested in the dispute; provided, that a lockout by the employer or an individual's failure to cross a picket line at such factory, establishment, or other premises shall not, in itself, be deemed to be participation by him in the labor dispute." 820 ILCS 405/604 (West 1994).”

This Supreme Court states, “Where the union has a mere expectancy in the outcome of another union's dispute, such as where the employer historically patterns its collective bargaining agreements with each of its unions after each other, our courts have not found a direct interest.” The court explained: "All they had was a hope, not any assurance. A mere expectancy without any legal right, subject to GM's views on the fairness and convenience of adopting parts of another agreement, does not disqualify the shop clerks for unemployment benefits." General Motors Corp., 85 Ill. 2d at 543.

To be eligible for unemployment insurance benefits under the relieving proviso of section 604, an employee must prove both that he is not directly interested in the labor dispute and that he is not of the same grade or class as employees who are participating in, financing or who hold a direct interest in the labor dispute.

IDES results in looking to the dictionary for definitions to legislative language. Definitions for legislative language are found in the legislature. When discussing stoppage of work with Ms. Cheryl Howard, she reports that supervisors and managers are replacing Non-Participating Workers doing their work, therefore, constituting a stoppage of work. I disagree.
I am a counselor III with Gateway. The Gateway Job Description for Counselor III reports, in part, “completes comprehensive assessments and treatment planning for caseload, and provides counseling services to clients. Develops and implements complex treatment and discharge plans for clients with dual diagnoses, social or mental health issues. Serves as professional resource to other Counselors in resolving complex case problems, and provides clinical supervision and guidance as needed. Develops and conducts in-service and continuing education programs for treatment staff; assumes responsibility for overseeing Counselors in absence of supervisor, and may assume responsibility for supervision of Counselors in absence of supervisor.”

Section 604 of the Act operates to disqualify an employee from receiving unemployment benefits when the employee is voluntarily unemployed because of a labor dispute at the place where he or she was last employed. Section 604 " 'evinces the legislative determination that the State is to remain neutral in labor disputes and collective bargaining, rendering assistance to neither the employer nor labor.' " Bridgestone/Firestone, 179 Ill. 2d at 156, quoting Local 7-641 v. Department of Labor, 96 Ill. 2d 94, 98 (1983). The plain language of section 604 requires an individuals’ unemployment be "due to a stoppage of work which exists because of a labor dispute." (Emphasis added.) 820 ILCS 405/604 (West 1992). Again, there is no stoppage of work.

Section 604, commonly referred to as the "labor dispute disqualification" section, provides in pertinent part: "Labor Dispute. An individual shall be ineligible for benefits for any week with respect to which it is found that his total or partial unemployment is due to a stoppage of work which exists because of a labor dispute at the factory, establishment, or other premises at which he is or was last employed." 820 ILCS 405/604 (West 1992).

The primary purpose of the Unemployment Act is to lessen the burden of unemployment upon unemployed workers. Wadlington v. Mindes, 45 Ill. 2d 447, 452 (1970), quoting Illinois Bell Telephone Co. v. Board of Review of the Department of Labor, 413 Ill. 37, 43 (1952) ("The primary purpose of the Illinois Unemployment Insurance Act is to relieve 'economic distress caused by involuntary unemployment' ").

IDES ends their report stating “Therefore, is their unemployment due to the work stoppage caused by the labor dispute at SCC (Sheridan)? If yes, they are disqualified from benefits under Section 604; if no, they are not disqualified.” IDES continues wondering if the stoppage of work is due to the labor dispute. As discussed earlier in this writing, there is no stoppage of work by Gateway at Sheridan, and therefore, the answer to IDES’s question is no and I am not disqualified from receiving unemployment benefits.

Conclusion

IDES wants us to believe there are no controlling Illinois appellate or Supreme Court cases. In paragraph 5 of IDES’s “Finding of Fact” it reports “…since IDOC has sole and complete authority over who is or is not allowed to enter SCC”; In paragraph 6 of IDES’s “Finding of Fact” it reports “IDOC states it refuses to allow entry to SCC to the Non-Participating Workers…”; and on page 3 of IDES’s report it states “…Section 604 provides that the term “labor dispute” does not include a lockout by an employer, and that no individual shall be denied benefits under Section 604 by reason of a lockout. Therefore, if the Non-Participating Workers had been denied access to SCC by the Company rather than IDOC, there would be clear justification for not finding them ineligible for benefits under Section 604 because they had been “locked out” of SCC by their employer.”

IDOC and Gateway, both entities, usefully could be deemed employers in such a situation as presented here. Gateway has contractual obligations with IDOC as stated in IDES’s “Findings of Fact”, where those contractual obligations are satisfied with IDOC at Sheridan. Therefore, IDOC/Sheridan is the “de facto or indirect” employer in this instance because they are exercising sole and complete authority and control over Gateway employees.

IDOC is the “De facto or Indirect” EMPLOYER. In addition, IDOC has discriminated against the Non-Participating Workers. There is a 'control test' to determine whether an entity is an 'employer'." Russo v. Ryerson, No. 01-CV-4458 2006 U.S. Dist. LEXIS 10447, at (D.N.J. Feb. 27, 2006) (citing Graves, supra, 117 F.3d at 723.2) Other circuits have followed suit. Ass'n of Mexican-American Educators, supra, 231 F.3d at 582-83; Mangram v. General Motors, 108 F.3d 61, 62-63 (4th Cir. 1997); E.E.O.C. v. Illinois, 69 F.3d 167, 169 (7th Cir. 1995).

The control test as it relates to a “de facto” employer "is appropriately used where it is clear that a putative (assumed) defendant does not directly employ the plaintiff, but nevertheless controls the plaintiff's employment to the point that it would contravene the intent of Title VII for the putative defendant to avoid liability for its own discriminatory actions." Kerr v. WGN Cont'l Broad. Co., 229 F. Supp. 2d 880, 886 (N.D. Ill. 2002); see e.g., Conroy v. City of Phila., 421 F. Supp. 2d 879 (E.D. Pa. 2006) (explaining how "City's ability to place its own requirements upon the hiring process," as well as "its control policy is to look to Title VII for guidance when interpreting provisions…and to federal precedent governing Title VII "'as a key source of interpretative authority.'" Pukowsky, supra, 312 N.J. Super. At 178 (quoting Lehmann, supra, 132 N.J. at 600-01).

Indirect liability results when the defendant employer "so far control[s] the plaintiff's employment relationship that it [is] appropriate to regard the defendant as the de facto or indirect employer of the plaintiff . . . ." E.E.O.C., supra, 69 F.3d at 169. In other words, "[d]e facto or indirect employer liability depends on the amount of the control a putative Title VII defendant exerts over the plaintiff's employment." Kerr, supra, 229 F. Supp. 2d at 886. It "addresses the situation where a formal employment relationship may be absent, but the putative defendant is so extensively involved with the plaintiff's day to day employment that the putative defendant is the 'real' employer for all intents and purposes, including Title VII liability." Ibid.; see E.E.O.C., supra, 69 F.3d at 171 (explaining how entities that "pull the strings in the background", and retain employment decision making power, are de facto employers pursuant to Title VII).

In Sibley Mem'l Hosp. v. Wilson, 488 F.2d 1338 (D.C. Cir. 1973) Control over access to the job market may reside, depending upon the circumstances of the case, in a labor organization, an employment agency, or an employer as defined in Title VII; and it would appear that Congress has determined to prohibit each of these from exerting any power it may have to foreclose, on invidious grounds, access by any individual to employment opportunities otherwise available to him. To permit a covered employer to exploit circumstances peculiarly affording it the capability of discriminatorily interfering with an individual's employment opportunities with another employer, while it could not do so with respect to employment in its own service, would be to condone continued use of the very criteria for employment that Congress has prohibited. [Id. at 1341.]

I have proven I deserve unemployment benefits pursuant to Section 604.

Respectfully submitted,

Fred L Nance Jr., ABD, MA, CADC, NCRS

cc: Honorable Rod R. Blagojevich, Governor of Illinois
Ms. Judith Boone, Investigator National Labor Relations Board
Mr. W. James Young, Staff Attorney-National Right To Work Legal Defense Foundation, Inc.
Mr. Gregg Dockins, Director Gateway/Sheridan
http://clickforjusticeandequality.blogspot.com/
C.L.I.C.K. for Justice and Equality

18 Supporting documents attached