Lake Tahoe Unified School District (PERB 1361E)

STATE 	OF 	CALIFORNIA
DECISION OF 	THE
PUBLIC 	EMPLOYMENT 	RELATIONS 	BOARD
SOUTH TAHOE EDUCATORS ASSOCIATION,
CTA/NEA,
Charging 	Party,
v.
LAKE TAHOE UNIFIED SCHOOL DISTRICT,
Respondent.
)
)
)
) 	Case No. 	SA-CE-1896
PERB Decision No. 	1361
December 	1, 	1999
)
)
)
)
)
)
Appearances; 	California Teachers Association by Ramon E. 	Romero,
Attorney, 	for South Tahoe Educators Association, 	CTA/NEA; 	Girard
& Vinson by Allen R. 	Vinson, 	Attorney, 	for Lake Tahoe Unified
School District.
Before Caffrey, 	Chairman; 	Dyer and Amador, 	Members.
DECISION
CAFFREY, 	Chairman: 	This case is before the Public
Employment Relations Board 	(Board) 	on appeal by the South Tahoe
Educators Association, 	CTA/NEA 	(Association) 	of a Board agent's
partial 	dismissal 	(attached) 	of 	the Association's unfair practice
charge. 	In the 	charge 	the Association alleged that 	the 	Lake
Tahoe Unified School 	District 	(District) 	violated section
3543.5(a), 	(b) 	and 	(c) 	of the Educational Employment Relations
Act 	(EERA)1 when it 	engaged in surveillance of 	the Association's
1EERA is 	codified at Government 	Code 	section 3540 	et 	seq.
Section 3543.5 	states, 	in pertinent part:
It 	shall 	be unlawful 	for a public 	school
employer to do any of 	the 	following:
(a) 	Impose 	or threaten to impose reprisals
on employees, 	to discriminate or threaten to
discriminate against 	employees, 	or otherwise
to interfere with, 	restrain, 	or coerce
_____ )

executive 	board meetings 	and 	refused 	to provide 	requested
information.
employees because 	of 	their exercise 	of 	rights
guaranteed by this 	chapter. 	For purposes 	of
this subdivision, 	"employee" 	includes an
applicant 	for 	employment 	or 	reemployment.
(b) 	Deny to employee organizations 	rights
guaranteed 	to 	them by 	this 	chapter.
(c) 	Refuse or fail 	to meet and negotiate 	in
good 	faith with an exclusive 	representative.
The Board has 	reviewed the 	entire 	record 	in this 	case,
including 	the 	original 	and amended unfair practice 	charge, 	the
Board agent's partial warning and partial 	dismissal 	letters, 	the
Association's appeal 	and the District's 	response 	thereto. 	The
Board 	finds 	the warning and dismissal 	letters 	to be 	free 	of
prejudicial 	error and hereby adopts 	them as 	the 	decision 	of 	the
Board 	itself.
ORDER
The partial 	dismissal 	of 	the unfair practice 	charge 	in Case
No. 	SA-CE-1896 is AFFIRMED.
Members 	Dyer and Amador 	joined 	in 	this 	Decision.
22

STATE OF CALIFORNIA 	' 	GRAY DAVIS, Governor
PUBLIC EMPLOYMENT RELATIONS BOARD
Sacramento Regional Office
1031 18th Street, Room 102
Sacramento, CA 95814-4174
(916) 322-3198
August 	2, 	1999
Ramon E. 	Romero
California 	Teachers 	Association
P.O. 	Box 921
Burlingame, 	CA 	94 011-0921
Re: 	South Tahoe Educators Association, 	CTA/NEA v. 	Lake Tahoe
Unified 	School 	District
Unfair Practice Charge No. 	SA-CE-1896
PARTIAL 	DISMISSAL 	LETTER
Dear Mr. 	Romero:
The 	above-referenced 	unfair 	practice 	charge 	was 	filed with 	the
Public 	Employment 	Relations 	Board on April 	14, 	1999. 	The 	charge
alleges 	that 	the 	Lake 	Tahoe 	Unified 	School 	District 	violated 	the
Educational 	Employment 	Relations Act 	(EERA), 	Government 	Code
section 3543.5(a), 	(b) 	and 	(c), 	when it interfered with the
protected 	rights 	of 	the 	South 	Tahoe 	Educators 	Association
(Association) 	by engaging 	in 	surveillance 	of 	the Association's
Executive 	Board 	meetings 	and 	by 	refusing 	to 	provide 	requested
information.
I 	indicated to you, 	in my attached letter dated June 	25, 	1999,
that 	the 	above-referenced 	charge 	did not 	state 	a prima 	facie
case. 	You were 	advised that 	if 	there were 	any factual
inaccuracies 	or 	additional 	facts 	which would 	correct 	the
deficiencies 	explained 	in 	that 	letter, 	you 	should 	amend 	the
charge. 	You were 	further 	advised 	that 	unless 	you 	amended 	the
charge 	to 	state 	a prima 	facie 	case or withdrew 	it 	prior 	to
July 6, 	1999, 	the charge would be dismissed.
On June 	28, 	1999, 	your request 	for an extension of 	time 	to 	file
an amended charge was 	granted 	to July 20, 	1999. 	An amended
unfair practice 	charge 	was 	filed on July 	9, 	1999.
The 	amended 	charge 	alleges 	that 	the 	District 	engaged 	in
additional 	acts 	of 	"surveillance." 	On February 8, 	1999,
Association 	site 	rep 	Kristine 	Russell 	drafted 	a 	hand-written
letter 	to 	"Mike," 	Association 	President 	Mike 	Patterson, 	in which
she 	expressed 	concerns 	that 	the 	District 	was 	distributing
misleading 	information 	to 	the 	public 	regarding 	an 	upcoming 	school
bond ballot 	measure. 	Ms. 	Russell 	attached 	two 	letters 	written by
the 	District 	concerning 	the 	bond measure 	to 	her 	letter 	and placed
them 	in an 	inter-District 	reusable 	envelope. 	Ms. 	Russell
addressed 	the 	envelope 	to Mike 	Patterson and 	sent 	it 	through 	the
inter-District 	mail 	system.

Partial Dismissal 	Letter
SA-CE-1896
Page 2
On February 11, 	1999, 	Principal Mike Greenfield sent a note to
Ms. 	Russell 	requesting to meet with her the next morning. 	On
February 12, 	Ms. 	Russell and Mr. 	Patterson met with
Mr. 	Greenfield and District Maintenance Director Steve Morales.
Mr. 	Greenfield pulled out the letter Ms. 	Russell had written and
stated that 	he had called the meeting 	to clear up 	some
misconceptions about the bond measure. 	Ms. 	Russell asked
Mr. 	Patterson if he had received the letter. 	He stated he had
never seen it. 	Mr. 	Greenfield said, 	"Oh, 	I thought the letter
was to me. 	That's why I called this meeting." 	Mr. 	Morales
stated he 	found the 	letter to 	"Mike" 	on his desk after his
secretary opened the mail 	and he 	thought 	that Mr. 	Greenfield had
forwarded it 	to him.
On March 23, 	1999, 	the District convened a meeting of the Board
of Education. 	An item on the agenda was 	the adoption of the
1999/00 	school 	calendar. 	A Board member raised a concern about
the number of minimum days 	scheduled during the 	school year.
Superintendent 	Rich Alexander 	stated that 	all 	of 	the minimum days
in the proposed calendar were 	contractual 	except 	the minimum day
scheduled for December 17, 	1999, 	the day before the Christmas
holiday. 	The Board of Education voted to approve 	the 	1999/00
school calendar with the modification that December 17, 	1999 be
changed to a 	full work day. 	The charge alleges 	that 	the day
before 	Christmas vacation has been a minimum day by long standing
practice.
Following the District Board of Education meeting, 	Mr. 	Patterson
went 	home 	and sent 	a 	computer generated fax message 	to
Association Executive Board members 	and several members 	of 	the
Association's 	Organizing Team. 	The 	fax message 	informed
Association members of 	the District Board's 	action to eliminate
the minimum day scheduled for December 17, 	1999.
On March 29, 	1999, 	Mr. 	Patterson spoke with Mr. Alexander
concerning the Board of Education's 	action on the 	school
calendar. 	Mr. 	Patterson requested that Mr. 	Alexander talk to the
Board of Education about restoring December 17 	as a minimum day.
On April 14, 	1999, 	in a meeting with Mr. Alexander, 	Mr. 	Patterson
asked whether Mr. 	Alexander had spoken to the Board concerning
the December 17 minimum day. 	Mr. 	Alexander responded that 	the
Board was upset by Mr. 	Patterson's March 23, 	1999 	fax concerning
the elimination of 	the minimum day. 	Mr. 	Patterson asked how the
District Board had received a copy of 	the 	fax. 	Mr. 	Alexander
stated that 	"Middle 	School 	and High School 	teachers" 	had given
copies of the 	fax to the District.

Partial 	Dismissal 	Letter
SA-CE-1896
Page 3
The 	Association 	asserts 	that 	by 	the 	above 	conduct 	the 	District
interfered 	with 	its 	protected 	rights 	by 	unlawfully 	engaging 	in
surveillance 	of 	the Association's 	protected 	activities.
As 	I 	previously discussed 	in the 	attached 	letter, 	the National
Labor 	Relations 	Board 	(NLRB) 	has 	generally 	found 	that 	an 	employer
has 	engaged 	in 	unlawful 	surveillance 	when 	the 	employer
photographs 	or videotapes 	employees 	or 	openly engages 	in
recordkeeping 	of 	employees 	participating 	in union 	activities.
(F.W. 	Woolworth Co. 	(1993) 	310 NLRB 1197.)
The 	conduct 	described 	in the 	charge, 	where 	the District 	was 	given
copies 	of 	union 	meeting minutes 	and 	a 	fax by bargaining unit
members, 	and 	inadvertently obtained 	a 	letter 	intended 	for 	the
union president, 	do not 	demonstrate 	that 	the 	District 	engaged 	in
unlawful 	surveillance 	of 	union 	activities.
The 	cases 	cited 	by 	Charging 	Party describe 	conduct 	whereby 	an
employer 	stole 	union membership 	applications, 	removed union
authorization 	cards 	from an 	employee's 	jacket 	pocket 	and 	obtained
and 	reviewed 	a 	union 	business 	agent's 	file 	containing 	executed
authorization 	cards 	and 	employee 	statements 	concerning 	unfair
labor practices. 	(Strozer, 	Inc. 	(1977) 	232 NLRB 937; 	Micro Metl
Corporation 	(1981) 	257 NLRB 274; 	Tucker's Minit Markets 	(1978)
238 	NLRB 	1188.) 	There 	is 	no 	evidence 	in the present 	charge 	that
the 	District 	unlawfully obtained 	the 	documents 	described 	in 	the
charge.
Accordingly, 	based on 	the 	discussion 	above 	and 	in 	the 	attached
letter, 	the 	allegations 	that 	the District 	interfered with the
Association's 	protected 	rights 	by engaging 	in 	surveillance 	of 	the
Association's 	protected 	activities 	and 	refused 	to 	provide
requested 	information, 	fail 	to 	state 	a prima 	facie 	case 	and are
dismissed.
Right 	to Appeal
Pursuant 	to 	Public 	Employment 	Relations 	Board regulations, 	you
may obtain 	a 	review of 	this 	dismissal 	of 	the 	charge 	by 	filing
an appeal 	to 	the 	Board 	itself 	within twenty 	(20) 	calendar days
after service of this dismissal. 	(Cal. 	Code Regs., 	tit. 	8,
sec. 	32635 (a).) 	Any document 	filed with the 	Board must 	contain
the 	case name 	and number, 	and the 	original 	and five 	(5) 	copies 	of
all 	documents 	must 	be 	provided 	to 	the 	Board.
A document 	is 	considered 	"filed" 	when 	actually 	received 	before
the 	close 	of 	business 	(5 	p.m.) 	on the 	last 	day set 	for 	filing or
when mailed by certified or 	Express 	United 	States 	mail, 	as 	shown
on 	the 	postal 	receipt 	or postmark, 	or delivered 	to 	a 	common
carrier 	promising 	overnight 	delivery, 	as 	shown on 	the 	carrier's

Partial 	Dismissal 	Letter
SA-CE-1896
Page 4
receipt, 	not 	later than the 	last day set 	for filing. 	(Cal. 	Code
Regs., 	tit. 	8, 	sec. 	32135(a); see also Cal. Code Regs., 	tit. 	8,
sec. 	32130.)
A document 	is 	also 	considered 	"filed" 	when 	received &y facsimile
transmission before 	the 	close 	of 	business 	on 	the 	last 	day 	for
filing 	together 	with 	a 	Facsimile 	Transmission 	Cover 	Sheet 	which
meets the requirements of Cal. 	Code Regs., 	tit. 	8, 	sec. 	32135(d),
provided 	the 	filing party also places 	the 	original, 	together with
the 	required number of 	copies 	and proof of 	service, 	in the U.S.
mail. 	(Cal. 	Code. 	Regs., 	tit. 	8, 	secs. 	32135(b), 	(c) 	and 	(d) ;
see also Cal. 	Code Regs., 	tit. 	8, 	secs. 	32090 and 32130.)
The Board's 	address 	is:
Public 	Employment 	Relations 	Board
Attention: 	Appeals Assistant
1031 	18th Street
Sacramento, 	CA 	95814-4174
FAX: 	(916) 	327-7960
If you 	file 	a 	timely appeal 	of 	the 	refusal 	to 	issue 	a 	complaint,
any 	other party may 	file 	with 	the 	Board 	an 	original 	and 	five
copies 	of 	a 	statement 	in opposition within 	twenty 	(20) 	calendar
days 	following the date of 	service of 	the 	appeal. 	(Cal. 	Code
Regs., 	tit. 	8, 	sec. 	32635(b).)
Service
All 	documents 	authorized 	to 	be 	filed herein must 	also 	be 	"served"
upon all 	parties 	to 	the proceeding, 	and a 	"proof of 	service"
must 	accompany 	each 	copy of 	a 	document 	served upon 	a 	party or
filed with the Board itself. 	(See Cal. 	Code Regs., 	tit. 	8,
sec. 	32140 	for 	the 	required contents 	and a 	sample 	form.) 	The
document 	will 	be 	considered properly 	"served" 	when personally
delivered or deposited 	in 	the 	first-class 	mail, 	postage paid 	and
properly 	addressed. 	A 	document 	filed by 	facsimile 	transmission
may be 	concurrently 	served via 	facsimile 	transmission 	on 	all
parties to the proceeding. 	(Cal. 	Code Regs., 	tit. 	8, 	sec.
32135(c).)
Extension 	of 	Time
A request 	for an extension of 	time, 	in which 	to 	file 	a 	document
with 	the 	Board 	itself, 	must 	be 	in writing 	and 	filed with 	the
Board 	at 	the 	previously noted 	address. 	A 	request 	for 	an
extension must 	be 	filed at 	least 	three 	(3) 	calendar days 	before
the 	expiration 	of 	the 	time 	required 	for 	filing 	the 	document.
The 	request 	must 	indicate good cause 	for and, 	if 	known, 	the
position of 	each other party regarding 	the 	extension, 	and shall
(

Partial 	Dismissal 	Letter
SA-CE-1896
Page 5
be 	accompanied by proof of 	service of 	the 	request 	upon each
party. 	(Cal. Code Regs., 	tit. 	8, 	sec. 32132.)
Final Date
If no appeal 	is 	filed within the specified time limits, 	the
dismissal will 	become 	final when the time limits have expired.
Sincerely,
ROBERT THOMPSON
Deputy General 	Counsel
By Robin W. Wesley
Regional Attorney
Attachment
cc: 	Allen R. 	Vinson

STATE OF CALIFORNIA 	( 	GRAY DAVIS, Governor
PUBLIC EMPLOYMENT RELATIONS BOARD
Sacramento Regional Office
1031 18th Street. Room 102
Sacramento, CA 95814-4174
(916) 322-3198
June 25, 	1999
Ramon E. 	Romero
California 	Teachers 	Association
P.O. 	Box 921
Burlingame, 	CA 	94011-0 921
Re: 	South Tahoe Educators Association, 	CTA/NEA v. 	Lake Tahoe
Unified 	School 	District
Unfair 	Practice 	Charge No. 	SA-CE-1896
WARNING 	LETTER
Dear Mr. 	Romero:
The 	above-referenced 	unfair 	practice 	charge 	was 	filed with 	the
Public 	Employment 	Relations 	Board on April 	14, 	1999. 	The 	charge
alleges 	that 	the 	Lake 	Tahoe 	Unified 	School 	District 	violated 	the
Educational 	Employment 	Relations Act 	(EERA), 	Government 	Code
section 3543.5(a), 	(b) 	and 	(c), 	when it interfered with the
protected 	rights 	of 	the 	South 	Tahoe 	Educators Association
(Association) 	by 	engaging 	in 	surveillance 	of 	the Association's
Executive 	Board meetings 	and by 	refusing 	to 	provide 	requested
information.
During 	the 	Fall 	of 	1998, 	the Association and the District 	were
engaged 	in negotiations 	for 	a 	successor 	contract. 	On October 	5,
1998, 	the Association's 	Executive Board met 	and discussed the
contract 	negotiations. 	The minutes 	of 	the 	meeting were
subsequently 	distributed 	to 	Association members.
At 	a bargaining session held on November 24, 	1998, 	LeAnne Kankel,
Director of 	Human Resources, 	had a 	copy of 	the minutes 	of 	the
Executive 	Board meeting. 	Ms. 	Kankel 	informed the Association's
bargaining 	team 	that 	the 	District's 	governing 	board 	was 	"appalled
and 	outraged when 	they 	read 	the 	minutes." 	The 	charge 	alleges
that 	Ms. 	Kankel 	"threatened to bring 	a 	'lawyer' 	back 	into
negotiations 	to 	represent 	the 	District 	if 	STEA continued 	to
communicate 	with 	its 	members 	that 	way."
On December 	16, 	1998, 	Association President Mike 	Patterson sent 	a
letter to Ms. 	Kankel 	which stated:
It 	has 	come 	to 	my 	attention 	that 	management
brought 	a 	copy 	of 	STEA Executive 	Board
Minutes 	into 	negotiations 	on November 	24,
1998. 	During 	that 	meeting, 	you 	stated that
some 	school 	board members 	were 	upset 	and
==========-- 	-

Warning 	Letter
SA-CE-1896
Page 	2
agitated 	after 	reading 	some 	of 	the 	items 	in
the 	minutes.
Please 	submit 	the 	following 	information 	to
me, 	in writing, 	on or before January 	6, 	1999:
1) 	Who, 	specifically, 	gave 	you 	a 	copy of
the 	minutes?
2) 	If 	you 	received 	a 	copy 	from 	someone
other 	than 	an 	STEA member, 	who,
specifically, 	gave 	that 	person 	a 	copy 	of
the 	minutes?
3) 	Did 	school 	board members 	have 	copies 	of
the minutes, 	and if 	so, 	who,
specifically, 	gave 	them 	a 	copy?
In a 	letter dated December 	18, 	1998, 	Allen Vinson, 	counsel 	for
the 	District, 	responded 	to Mr. 	Patterson, 	stating 	that 	he 	was 	not
aware 	of 	any 	legal 	authority 	which 	required 	the 	District 	to
provide 	the 	information 	requested. 	Accordingly, 	the 	District
declined 	to 	provide 	the 	requested 	information.
Based 	upon 	the 	facts 	stated 	above, 	the 	charge 	fails 	to 	state 	a
prima 	facie 	case.
The 	Association 	contends 	that 	the 	District 	interfered 	with 	its
protected 	rights 	by 	unlawfully 	engaging 	in 	surveillance 	of 	the
Association's 	Executive 	Board 	meetings.
To 	state 	a 	prima 	facie 	case 	of 	interference, 	a 	charging 	party
must 	demonstrate 	that 	the 	employer's 	acts 	interfered 	with 	or
tended 	to 	interfere 	with 	the 	exercise 	of 	protected 	rights.
(Carlsbad 	Unified 	School 	District 	(1979) 	PERB 	Decision No. 	89.)
The 	National 	Labor 	Relations 	Board 	(NLRB) 	has 	generally 	found
that 	an 	employer 	has 	engaged 	in 	unlawful 	surveillance 	when 	the
employer 	photographs 	or 	videotapes 	employees 	or 	openly 	engages 	in
recordkeeping 	of 	employees 	participating 	in 	union 	activities.
(F.W. 	Woolworth Co. 	(1993) 	310 	NLRB 	1197.) 	The mere 	observation
of 	open, 	public 	union 	activity 	on 	or 	near 	the 	employer's
property, 	however, 	does 	not 	constitute 	unlawful 	surveillance.
(National 	Steel 	& 	Shipbuilding 	Co. 	(1997) 	324 	NLRB 	499.)
The 	Charging 	Party 	asserts 	that 	the 	facts 	demonstrate 	that 	the
District 	may 	have 	a 	secret 	means 	of 	obtaining 	inside 	union
information 	and 	that 	the 	District's 	access 	to 	this 	information
may 	continue. 	Charging 	Party 	contends 	that 	the 	District 	used 	its
access 	to 	the 	Association's 	meeting 	minutes 	in 	a 	threatening 	way,
by 	letting 	the 	Association's 	bargaining 	team 	know 	that 	the
(

Warning 	Letter
SA-CE-1896
Page 3
District 	had 	access 	to 	inside 	information 	concerning
negotiations.
The 	charge 	alleges 	only 	that 	the Association 	distributed 	copies
of 	its 	Executive 	Board meeting minutes 	to 	all 	Association members
and 	that 	the 	District 	obtained 	a 	copy of 	the 	minutes. 	There 	is
no 	indication 	from these 	facts 	that 	the 	District 	engaged 	in 	any
type 	of 	surveillance 	of 	the 	Executive 	Board meeting 	to 	obtain 	the
minutes. 	Nor do 	these 	facts 	demonstrate 	that 	the 	District 	caused
harm 	to 	the 	secrecy 	of 	the Association's 	bargaining 	position.
The Association 	itself 	distributed 	the 	minutes 	to 	its 	members 	at
the 	school 	facilities. 	There 	is 	nothing 	in the minutes
identifying 	them 	as 	confidential 	or 	directing Association 	members
to protect 	the 	confidentiality of 	the minutes. 	Accordingly, 	the
charge 	fails 	to 	state 	a prima 	facie 	case 	of 	interference.
The 	charging 	Party also 	alleges 	that 	the 	District 	refused 	to
provide 	requested 	information. 	Charging 	Party contends 	that 	it
has 	a 	right 	to 	know how 	the 	District 	obtained 	the 	meeting minutes
in order 	to 	identify 	security 	lapses 	and 	to protect 	its 	internal
processes.
The 	duty 	to bargain 	in good 	faith 	requires 	an employer 	to provide
information 	requested 	by 	an 	exclusive 	representative 	which 	is
necessary 	and 	relevant 	to 	collective 	bargaining 	and 	contract
administration, 	including grievance processing. 	(Stockton
Unified School 	District 	(1980) 	PERB Decision No. 	143; 	San
Bernardino 	City Unified 	School 	District 	(1998) 	PERB 	Decision
No. 	1270.)
Association President 	Mike 	Patterson 	sent 	a 	letter 	to Ms. 	Kankel
seeking 	the 	name 	of 	the 	individual 	who gave 	the 	District 	a 	copy
of 	the Executive 	Board meeting minutes. 	It 	is not 	apparent 	how
obtaining 	the 	name 	of 	the person who 	gave 	the 	District 	a 	copy of
the 	minutes 	is 	relevant 	and necessary to 	collective 	bargaining or
administration of 	the 	contract. 	Thus, 	this allegation 	fails 	to
state 	a prima 	facie 	case 	and must 	be 	dismissed.
For these 	reasons 	the 	charge, 	as presently written, 	does 	not
state 	a prima 	facie 	case. 	If 	there 	are 	any 	factual 	inaccuracies
in 	this 	letter 	or 	additional 	facts 	which would 	correct 	the
deficiencies 	explained above, 	please amend the 	charge. 	The
amended 	charge 	should be 	prepared 	on 	a 	standard 	PERB 	unfair
practice 	charge 	form, 	clearly 	labeled 	First 	Amended 	Charge,
contain all 	the 	facts 	and allegations you wish to make, 	and
be 	signed under penalty of 	perjury by 	the 	charging party. 	The
amended 	charge 	must 	have 	the 	case 	number written on 	the 	top 	right
hand 	corner 	of 	the 	charge 	form. 	The 	amended 	charge 	must 	be
served 	on 	the 	respondent's 	representative 	and 	the 	original 	proof
of 	service must 	be 	filed with 	PERB. 	If 	I 	do not 	receive 	an
-,

Warning 	Letter
SA-CE-1896
Page 4
amended charge or withdrawal 	from you before July 6, 	1999, 	I
shall dismiss your charge. 	If you have any questions, 	please
call me at 	(916) 	327-8385.
Sincerely,
Robin W. Wesley
Regional 	Attorney