San Joaquin Delta Community College District (PERB 0261E)

STATE 	OF 	CALIFORNIA
DECISION 	OF 	THE
PUBLIC 	EMPLOYMENT 	RELATIONS 	BOARD
CALIFORNIA 	SCHOOL 	EMPLOYEES
ASSOCIATION 	and 	its 	DELTA COLLEGE
CHAPTER 	359,
Charging 	Party,
v.
SAN 	JOAQUIN 	DELTA COMMUNITY
COLLEGE DISTRICT,
Respondent.
Case 	No. 	S-CE-360
PERB Decision No. 	261
November 	30, 	1982
Appearances; 	Peter 	A. 	Janiak, 	Attorney 	for 	the California
School Employees 	Association 	and 	its 	Delta 	College 	Chapter 	359;
and Mark 	F. 	Ornellas, 	Attorney 	for 	the 	San Joaquin Delta
Community 	College 	District.
Before Gluck, 	Chairperson, Jaeger 	and Jensen, Members.
DECISION
JENSEN, 	Member: 	This case 	is 	before 	the Public Employment
Relations 	Board 	(PERB or 	Board) 	on exceptions 	to 	the proposed
decision of 	the Administrative Law Judge 	(ALJ) 	filed 	by San
Joaquin Delta Community College District 	(District). 	The ALJ
found 	that 	the 	District 	violated 	subsections 	3543.5(a) 	and 	(b)
of 	the 	Educational 	Employment 	Relations 	Act 	(EERA or 	the 	Act)
by 	discriminatorily 	transferring 	Burton 	Gray 	from 	his 	former
position as 	a campus police 	officer 	to a position on 	the
grounds 	crew. 	He dismissed 	the 	allegation 	that 	certain
unilateral 	schedule 	changes 	by 	the 	District 	were 	undertaken 	in
violation of subsection 3533.5(c), 	and 	that the District
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violated 	subsection 	3543.5(d) 	by 	encouraging 	or 	lending 	support
to 	an 	attempt 	by members 	of 	the 	campus police 	force 	to withdraw
from California 	School 	Employees 	Association 	and 	its 	Delta
College Chapter 	359 	(CSEA). 	Further, 	he dismissed 	the
allegation 	that 	the 	rescheduling 	of 	Shirley Gray 	from 	the
graveyard 	shift 	to 	a 	rotating 	shift 	violated 	subsections
3543.5(a) 	and 	(b).1
CSEA filed no exceptions. 	Thus, 	the only conclusion of 	the
ALJ 	subject 	to 	review 	concerns 	the 	transfer 	of 	Burton 	Gray.
For 	the 	reasons 	set 	forth, 	infra, 	we 	affirm that 	conclusion.
1 BERA 	is 	codified 	at 	Government 	Code 	sections 	3540
et 	seq. 	All 	statutory 	references 	are 	to 	the 	Government 	Code,
unless 	otherwise 	noted. 	Subsections 	3543.5(a) 	through 	(d)
provide 	as 	follows:
It 	shall 	be 	unlawful 	for 	a 	public 	school
employer 	to:
(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
employees 	because 	of 	their 	exercise 	of
rights 	guaranteed 	by 	this 	chapter.
(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.
(d) 	Dominate 	or 	interfere 	with 	the
formation 	or 	administration 	of 	any 	employee
organization, 	or 	contribute 	financial or
other 	support 	to 	it, 	or 	in 	any 	way encourage
employees 	to 	join 	any 	organization 	in
preference 	to 	another.
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FACTS
We 	find 	the ALJ's 	statement of 	facts 	to be 	free of
prejudicial error, 	and 	adopt 	that portion of his 	decision,
which 	is 	incorporated 	by 	reference herein, 	as 	the decision of
the 	Board.
DISCUSSION
The ALJ's 	decision 	in 	this case 	was 	issued prior 	to 	the
Board's 	decision 	in 	Novato 	Unified 	School 	District 	(4/30/82)
PERB Decision No. 	210. 	Under 	the Novato test, 	a party alleging
discrimination within 	the meaning 	of 	subsection 3543.5(a) 	has
the 	burden 	of 	making 	a 	showing 	sufficient 	to 	support 	the
inference 	that protected 	conduct was 	a motivating 	factor 	in 	the
employer's 	decision 	to 	take 	adverse 	personnel 	action. 	In
recognition of 	the 	fact 	that 	direct 	evidence of motivation 	is
seldom available, 	we have held 	that 	it may be demonstrated
circumstantially. 	In accord 	is Republic Aviation Corp. 	v. 	NLRB
(1945) 	324 U.S. 	793 	[16 LRRM 620]. 	If 	the charging party is
able 	by direct 	or 	circumstantial evidence 	to raise 	the
inference 	that 	the 	employer 	was 	in 	any 	way 	motivated 	to 	take
adverse 	personnel action 	by 	its 	knowledge 	of 	the 	employee's
protected 	activity, 	the 	burden 	shifts 	to 	the 	employer 	to
demonstrate 	that 	it 	would 	have 	acted 	as 	it 	did 	regardless 	of
the 	employee's participation 	in protected 	activity. 	Novato,
supra; Wright Line, A Division of Wright Line, 	Inc. 	(1980) 	251
NLRB 1083 	[105 LRRM 1169].
W	3

To 	justify 	such 	an 	inference, 	charging party must
demonstrate, 	initially, 	that 	the employer 	had 	knowledge of 	the
employee's 	protected activities. 	NLRB v. 	South 	Shore 	Hospital
(1st Cir. 	1978) 	571 F.2d 677 	[97 LRRM 3004]. 	In the 	instant
case, 	it 	is undisputed 	that Burton Gray was a CSEA activist,
and 	that 	the 	employer 	had 	knowledge 	thereof. 	Prior 	to 	becoming
a 	union officer, 	Gray was 	instrumental 	in 	urging CSEA to become
active 	in 	urging 	the District 	to 	sanction 	the carrying of guns
by campus officers. 	As 	noted by 	the ALJ, 	Gray became 	a 	job
steward 	for 	CSEA in 	1978, 	vice president of 	the 	local chapter
in 	1979 	and campus 	chapter 	president at 	the 	outset of 	1980. 	As
a 	job 	steward 	and 	union officer, 	Gray 	filed approximately 	29
grievances, 	nearly half of 	which 	involved 	formal procedures.
This 	represented 	a 	400 	percent 	to 	500 	percent 	increase 	in
grievance 	filing 	over 	that of 	Gray's predecessor.
During 	his 	service as CSEA officer, 	and 	in 	accordance with
the 	wishes 	of 	unit 	employees, 	Gray actively agitated 	for 	a
liberalized 	gun 	policy 	which 	would 	allow 	officers 	on 	foot
patrol 	as well as 	those driving patrol vehicles 	to carry guns.
In his 	role 	as 	CSEA president, 	Gray 	expressed his 	criticism of
the campus 	student officer 	(CSO) 	program to District Vice
President 	DeRicco 	in a meeting 	during 	February of 	1980, 	stating
that 	he 	felt 	that 	the 	money 	utilized 	for 	that program could 	be
better 	spent 	on 	upgrading 	equipment 	and 	hiring 	regular 	officers.
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It 	is 	undisputed 	that 	the District 	had knowledge 	of Gray's
extensive 	participation 	in 	protected 	activities 	noted 	above.
In 	fact, 	there 	is direct evidence 	that 	the District 	bore
anti-union animus 	against Gray 	due 	to 	the 	heightened 	frequency
and 	more 	aggressive 	character 	of 	grievance 	activity 	engaged 	in
by him on behalf of CSEA. 	Thus, 	as 	noted by 	the ALJ, 	the
District vice 	president 	complained 	to Gray 	in 	November 	of 	1979
that 	the 	District 	was 	having 	more 	trouble 	with 	CSEA than with
the 	exclusive 	representative 	of 	the 	certificated 	employees 	over
grievances, 	and 	that 	if 	such 	activity continued 	CSEA might
tarnish 	its 	image 	with 	the District's 	governing 	board.
Just prior 	to 	initiation of 	disciplinary 	activity against
him, 	Burton Gray 	was 	instrumental 	in 	filing an affirmative
action 	complaint 	and 	a 	contractual grievance 	on 	behalf 	of
Shirley Gray. 	The 	record 	reflects 	that 	these 	grievances 	became
a cause 	celebre 	both 	in 	the police department 	and on campus at
large.
The 	Discipline 	of 	Burton Gray
The discipline 	to which 	Gray 	was 	subjected must 	be 	examined
against 	the 	background 	of his 	extensive 	pattern of protected
activity, 	the District's knowledge 	thereof, 	and 	the 	District's
expression of 	anti-union animus. 	For 	the 	reasons 	described 	by
the ALJ, 	we 	agree 	that 	the 	District's discipline of Gray was
suspiciously 	severe 	in 	light of 	the 	transgressions 	of which he
was 	found 	guilty.
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It 	is 	noted 	that 	the District dismissed 	the most 	severe
allegations 	of misconduct 	against Gray, 	those 	related 	to misuse
of a 	firearm.
The 	District 	disciplined 	Gray 	severely 	for 	alleged
insubordination on 	the 	grounds 	that 	he 	unjustifiedly criticized
and monitored 	the CSO's, 	refused 	to follow orders, 	and
inadequately 	responded 	to an 	unspecified 	crisis. 	The 	record 	of
the 	disciplinary 	hearing 	upon which 	the 	District 	based 	its
conclusions was not made a part of 	this 	record. 	However, 	the
ALJ 	did 	have 	before 	him 	extensive 	testimony 	regarding 	the
incidents 	which 	formed 	the 	basis 	for 	the District's 	finding
that 	Gray was 	insubordinate. 	For 	the 	reasons 	set forth 	by 	the
ALJ, 	we 	agree 	that 	the 	evidence presented at 	the PERB hearing
reveals 	little 	basis 	for 	characterizing 	Gray's 	conduct 	as
insubordination 	Gray 	criticized 	the 	CSO program 	in 	his
official capacity as 	a CSEA officer, 	clearly a 	protected
activity. 	Further, 	all officers 	had 	the 	responsibility 	to
generally observe 	and 	instruct 	the 	CSO's 	as part 	of 	the 	CSOs'
training. 	Regarding 	the allegation 	that he 	refused 	to 	follow
orders 	unless 	they 	were 	in writing, 	the 	evidence 	indicates
that, 	while he 	may have 	stated 	that he would 	not 	follow 	such
orders, 	he always did 	in 	fact follow 	them. 	As 	the ALJ noted,
there 	was 	no evidence 	that Gray 	ever 	refused 	to 	follow 	a single
order 	by a superior, 	either 	written or 	verbal. 	The 	incident
relied 	upon 	by 	the 	District 	involved 	a 	request 	by a 	fellow
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officer, 	and 	not an order by a supervisor. 	Further, 	we 	agree
with 	the 	ALJ's 	findings 	regarding 	Gray's 	alleged 	refusal 	to
correctly respond 	to a crisis. 	During 	the 	incident 	in
question, 	Gray 	was 	not 	armed 	and 	refused personally 	to disarm a
butcher-knife-wielding 	suspect, 	deferring 	instead 	to an armed
officer 	who was 	also on 	the 	scene.
Thus, 	we 	find 	that 	the District's 	basis 	for 	concluding 	that
Gray was guilty of any misconduct 	at 	all was 	suspect. 	It was
based 	in part 	upon unsubstantiated allegations. 	Further, 	at
least one 	aspect of Gray's conduct, 	his criticism of 	the 	CSO
program, 	was 	itself protected 	activity.
In 	evaluating 	the 	reasonableness 	of 	the discipline of Gray,
it 	is 	important 	to note 	that, 	prior 	to 	the action which 	is 	the
subject of 	this 	charge, 	Gray 	had 	an 	unblemished 	record 	during
his 	almost 	six-year 	tenure 	as 	a campus police 	officer.
Based 	upon 	the 	questionable 	finding 	of 	insubordination
analyzed 	above, 	the District disciplined Gray 	in a manner 	which
it 	seeks to characterize as benign but which, 	in context, 	was
extremely 	severe. 	The 	record 	reflects 	that Gray was 	a career
police officer, by virtue of inclination, 	training, 	and
extensive 	experience. 	Transferring 	him 	to 	the 	grounds 	crew,
while 	it may 	not 	have 	immediately deprived 	him of 	earnings,
deprived 	him 	of 	the 	opportunity 	to practice 	his 	chosen
profession.
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The 	ALJ 	extensively 	described 	and 	analyzed 	the 	evidence
regarding 	the 	District's 	reaction 	to misconduct 	by officers
other 	than Burton Gray. 	We 	affirm his 	finding 	that 	the
District's 	severe 	discipline of 	Burton Gray 	amounted 	to
disparate 	treatment of a 	known union activist, 	when measured
against 	the 	District's 	response 	to 	known misconduct 	by
employees 	who were 	not 	union 	activists. 	We 	rely 	in 	this 	regard
on 	the 	first 	two 	incidents 	cited 	by 	the 	ALJ 	involving 	misuse 	of
a 	firearm 	by 	Chief 	Hale2 	and 	the 	firearms 	incidents 	and 	other
alleged 	misconduct 	by Officer 	Oki.
In addition 	to 	those 	incidents 	relied 	upon by 	the ALJ, 	we
find 	that 	the 	District's 	indifferent 	response 	to 	reported 	acts
of 	harassment 	of 	Shirley 	Gray 	constitutes 	further 	indication of
a 	generally 	lax 	disciplinary 	attitude 	on 	the 	part 	of 	the
District. 	In sum, 	the 	record 	reflects 	that 	the District and
its 	supervisory 	and 	managerial 	agents 	investigated 	accusations
2In this 	regard 	it 	should 	be 	noted 	that 	we 	do 	not 	rely
upon 	the 	third 	incident 	involving 	Hale 	which 	occurred 	in June
or 	July of 	1979, 	in which 	he 	allegedly pointed 	his 	revolver 	at
Officer 	Schiano 	and 	told 	him he 	was 	going 	to make 	him dance,
because 	there 	is 	no evidence 	that 	the 	District 	had 	knowledge 	of
this 	incident.
Further 	we 	do 	not 	affirm 	the 	ALJ's 	conclusion 	that 	Hale 	was
"not 	disciplined" 	for 	the 	first 	firearms 	incident. 	We 	view 	the
30-day 	involuntary 	commitment 	to 	an 	alcohol 	treatment 	facility
which 	followed 	that 	incident 	as 	a 	disciplinary 	as well 	as
therapeutic measure. 	Although 	disciplinary, 	it 	was 	certainly
a 	benign 	response 	to a 	serious 	transgression, 	and we continue
to 	rely on 	it 	in 	part 	for 	our 	conclusion of disparate 	treatment.
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of 	misconduct 	by 	employees 	without 	a 	known 	history 	of protected
activity 	less 	vigorously, 	and 	punished 	such 	persons 	found 	to
have 	engaged 	in misconduct 	far 	less 	severely 	than 	they did 	in
the case of Burton Gray, 	a known union activist.
Thus, 	charging party has 	demonstrated 	that Burton Gray
engaged 	in 	protected 	activity with 	the 	knowledge 	of 	the
District, 	that 	the 	District 	harbored 	anti-union animus 	against
Gray, 	and 	that 	its 	basis 	for 	disciplining 	him at all was
extremely 	weak.
Further, 	we 	find 	that 	the 	District 	disciplined 	Gray more
severely 	than 	it 	did others 	accused 	of misconduct. 	This 	is
more 	than 	sufficient 	to 	raise 	the 	inference 	that 	the 	District
was 	improperly 	motivated 	to discipline 	Gray as 	it 	did.
In 	light of our 	finding 	of disparate 	treatment, 	we 	conclude
that 	the 	District 	has 	failed 	to demonstrate 	that 	it 	would 	have
disciplined 	Gray 	as 	it 	did 	notwithstanding 	its 	knowledge 	of his
protected 	activity. 	Thus, 	pursuant 	to 	the 	test 	for 	unlawful
discrimination set forth 	in Novato, 	supra, we conclude 	that the
discipline 	of 	Burton Gray 	herein 	was 	violative 	of 	subsection
3543.5(a). 	Wright Line, 	supra. 	As noted by the ALJ, 	unlawful
discrimination 	against 	an 	employee 	organization 	officer 	and
activist 	constitutes 	a 	concurrent 	violation of 	subsection
3543.5(b) 	as 	well. 	San Francisco Community College District
(10/12/79) 	PERB Decision No. 	105.
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REMEDY
The 	remedy 	o r d e r e d 	by 	t h e 	ALJ 	is 	h e r e b y 	a d o p t e d 	by 	t h e
Board, 	with the additional provision that the District must
remove 	from Burton Gray's personnel record any reference to the
investigation or disciplinary action taken against Burton Gray
by the District which formed the basis of the 	instant
allegations.
ORDER
Upon 	the 	foregoing 	findings 	of 	fact, 	conclusions 	of 	law and
the 	entire 	record 	of this 	case, 	and pursuant 	to Government 	Code
subsection 	3541.5(c) 	of 	the 	Educational 	Employment 	Relations
Act, 	it 	hereby 	is ORDERED that 	the 	San Joaquin Delta Community
College District, 	board of 	trustees, 	superintendent 	and 	their
respective 	agents 	shall:
A. 	CEASE AND DESIST 	FROM:
Imposing 	or 	threatening 	to 	impose 	reprisals 	on Burton 	Gray,
discriminating 	or 	threatening 	to 	discriminate 	against
Burton Gray or 	otherwise 	interfering 	with, 	restraining, 	or
coercing Burton 	Gray because 	of his 	exercise 	of 	his 	rights 	to
form, 	join, 	and participate 	in 	the 	activities of employee
organizations 	of his 	own 	choosing 	for 	the purpose 	of
representation 	in 	all matters 	of employer-employee 	relations,
including 	the 	right 	to 	file 	grievances 	and otherwise 	serve 	as
CSEA chapter 	president, 	by discriminatorily disciplining,
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demoting, 	and 	transferring 	Burton 	Gray 	from his 	position 	as 	a
campus 	police 	officer 	to 	the 	position 	of 	maintenance 	worker.
B. 	TAKE 	THE 	FOLLOWING 	AFFIRMATIVE ACTION WHICH 	IS
NECESSARY 	TO 	EFFECTUATE 	THE 	POLICIES 	OF 	THE EDUCATIONAL
EMPLOYMENT 	RELATIONS ACT:
(1) 	Immediately offer 	to 	fully 	reinstate 	Burton 	Gray 	to
his 	former 	job, 	or, 	if 	the 	job no 	longer 	exists, 	to a
substantially equivalent 	position, 	without 	prejudice 	to 	his
seniority or 	other 	rights, 	benefits 	and privileges previously
enjoyed;
(2) 	Make 	Burton Gray 	whole 	for 	any 	loss 	of pay 	and 	other
benefit(s) 	he 	may 	have 	suffered 	by 	tendering 	to 	him 	a 	back 	pay
award 	equal 	to 	an 	amount 	that 	he 	would 	have 	been 	paid, 	absent
his 	unlawful 	demotion 	and 	transfer 	on or 	about 	August 	1 2 , 	1980,
until 	the 	date 	of 	the 	offer 	of 	reinstatement; 	this 	total amount
to 	be 	offset 	by 	Gray's 	earnings 	as 	a 	result of 	his 	other
employment 	with 	the 	District 	during 	this 	period 	and 	augmented
by 	payment 	of 	interest 	of 	7 	percent 	per 	annum of 	the 	net 	amount
due;
(3) 	Remove 	from Burton Gray's 	personnel 	records 	any
material 	relating 	to 	the 	disciplinary 	procedures 	which 	were 	the
subject 	of 	the 	instant 	charge;
(4) 	Within 	seven 	(7) 	workdays 	following 	the 	date 	of
service of 	this 	Decision, 	post 	at 	all 	work 	locations 	where
notices 	to 	employees 	customarily 	are 	placed, 	copies 	of 	the
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notice 	attached 	as 	an 	appendix hereto 	signed 	by 	an 	authorized
agent of 	the 	employer. 	Such posting 	shall be maintained 	for 	a
period 	of 	thirty 	(30) 	consecutive 	workdays. 	Reasonable steps
shall 	be 	taken 	to 	insure 	that such 	notices 	are 	not 	altered,
defaced 	or 	covered 	by 	any other 	material 	or 	reduced 	in size;
(5) 	Within forty-five 	(45) 	workdays following 	service of
this Decision, 	notify the 	regional 	director 	of 	the Public
Employment Relations Board 	in writing 	of 	what 	steps 	the
employer 	has 	taken 	to 	comply with 	the 	terms 	of 	this 	decision.
Continue 	to 	report 	in writing 	to 	the 	regional 	director
periodically 	thereafter 	as 	directed. 	All 	reports 	to 	the
regional 	director 	shall 	be 	served 	concurrently on 	charging
party 	herein.
Chairperson Gluck 	and Member 	Jaeger 	joined 	in 	this 	Decision.
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APPENDIX NOTICE 	TO 	EMPLOYEES
POSTED 	BY 	ORDER OF 	THE
PUBLIC 	EMPLOYMENT 	RELATIONS 	BOARD
An 	Agency 	of 	the 	State 	of 	California
After 	a hearing 	in 	Unfair 	Practice Case 	No. 	S-CE-360,
California 	School 	Employees 	Association 	and 	its 	Delta 	College
Chapter 	359 	v. 	San 	Joaquin 	Delta 	Community College 	District, 	in
which 	all parties 	had 	the 	right 	to participate, 	it 	has 	been
found 	that 	the 	San 	Joaquin 	Delta 	Community 	College 	District
violated 	the 	Educational 	Employment 	Relations 	Act, 	Government
Code section 3543.5(a) 	and 	(b).
As 	a 	result 	of 	this 	conduct, 	we 	have 	been ordered 	to post
this 	Notice 	and 	we 	will 	abide 	by 	the 	following:
A. 	CEASE AND 	DESIST 	FROM:
Imposing 	or 	threatening 	to 	impose 	reprisals 	on 	Burton 	Gray,
discriminating 	or 	threatening 	to 	discriminate 	against
Burton Gray or 	otherwise 	interfering 	with, 	restraining, 	or
coercing 	Burton 	Gray because 	of 	his 	exercise 	of 	his 	rights 	to
form, 	join, 	and participate 	in 	the 	activities of employee
organizations 	of 	his 	own 	choosing 	for 	the 	purpose 	of
representation 	in 	all matters 	of 	employer-employee 	relations,
including 	the 	right 	to 	file 	grievances 	and 	otherwise 	serve 	as
CSEA chapter 	president, 	by 	discriminatorily disciplining,
demoting, 	and 	transferring 	Burton 	Gray 	from his 	position 	as 	a
campus 	police 	officer 	to 	the 	position 	of maintenance 	worker.
B. 	TAKE 	THE 	FOLLOWING 	AFFIRMATIVE ACTION WHICH 	IS
NECESSARY 	TO 	EFFECTUATE 	THE 	POLICIES 	OF 	THE 	EDUCATIONAL
EMPLOYMENT 	RELATIONS ACT:
(1) 	Immediately offer 	to 	fully 	reinstate 	Burton 	Gray 	to
his 	former 	job, 	or, 	if 	the 	job no 	longer 	exists, 	to a
substantially equivalent position, 	without prejudice 	to 	his
seniority or 	other 	rights, 	benefits 	and 	privileges previously
enjoyed;
(2) 	Make 	Burton Gray 	whole 	for 	any 	loss 	of pay 	and 	other
benefit(s) 	he 	may 	have 	suffered 	by 	tendering 	to 	him a 	back 	pay
award 	equal 	to an 	amount 	that 	he 	would 	have 	been 	paid, 	absent
his 	unlawful demotion 	and 	transfer 	on or 	about 	August 	12, 	1980,
until 	the 	date 	of 	the 	offer 	of 	reinstatement; 	this 	total amount
to 	be 	offset 	by Gray's 	earnings 	as 	a 	result 	of 	his 	other
employment 	with 	the 	District 	during 	this 	period 	and 	augmented
by 	payment 	of 	interest 	of 	7 	percent 	per 	annum of 	the 	net 	amount
due;
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(3) 	Remove 	from Burton Gray's personnel 	records 	any
material relating 	to 	the 	disciplinary 	procedures 	which 	were 	the
subject of 	the 	instant 	charge;
SAN 	JOAQUIN 	DELTA COMMUNITY COLLEGE DISTRICT
Dated: 	By
Authorized 	Representative
THIS 	IS 	AN OFFICIAL NOTICE. 	IT MUST REMAIN POSTED FOR 30
CONSECUTIVE WORKDAYS FROM 	THE DATE OF 	POSTING AND MUST 	NOT BE
ALTERED, REDUCED 	IN 	SIZE, 	DEFACED OR COVERED WITH ANY OTHER
MATERIAL.
N	
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