United Teachers of Los Angeles (Buller) (PERB 0438E)

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STATE OF CALIFORNIA
DECISION OF THE
PUBLIC EMPLOYMENT RELATIONS BOARD

JOSEPH GORDON BULLER,
Charging Party, Case No. LA-CO-287

Vv. PERB Decision No. 438

UNITED TEACHERS OF LOS ANGELES, November 21, 1984

Respondent.

eee Nae Nee Neat Nea Senet Nemett Sue Se “nee

Appearance: Joseph Gordon Buller, on his own behalf.
Before Hesse, Chairperson; Jaeger and Morgenstern, Members.*
DECISION

This case is before the Public Employment Relations Board
on an appeal by Joseph Gordon Buller of the Board agent's
dismissal, attached hereto, of his charge alleging that the
United Teachers of Los Angeles violated sections 3543.6(b),
3544.9, and 3543 of the Educational Employment Relations Act
(Government Code section 3540 et seq.).

We have reviewed the dismissal and, finding it free from
prejudicial error, adopt it as the Decision of the Board itself.

ORDER
The unfair practice charge in Case No. LA-CO-287 is

DISMISSED WITHOUT LEAVE TO AMEND.

By the Board

*Members Tovar and Burt did not participate in this Decision.

STATE OF CALIFORNIA 	GEORGE DEUKMEJIAN, Governor
PUBLIC EMPLOYMENT RELATIONS BOARD
LOS ANGELES REGIONAL OFFICE
3470 WILSHIRE BLVD., SUITE 1001
105 ANGELES, CALIFORNIA 90010
(213) 736-3127
May 10, 1984
Joseph Gordon Buller
Leo Geffner, Esq.
Geffner & Satzman
3055 Wilshire Blvd., Suite 900
Los Angeles, CA 90010
RE: 	LA-CO-287, Joseph Buller v. United Teachers of
Los Angeles, DISMISSAL OF UNFAIR PRACTICE CHARGE
Dear Parties:
The above charge was filed on February 14, 1984. Briefly
stated, it alleges that United Teachers of Los Angeles breached
its duty of fair representation and violated Government Code
sections 3543.6 (b) and 3544.9 in the manner in which it
processed Joseph G. Buller's grievance, the manner in which it
presented his grievance to management (lack of effective
advocacy) and by refusing to take his case to arbitration.
Charging Party has provided the following facts. Joseph Gordon
Buller had been teaching at Jane Addams Continuation High
School since February, 1979. In July, 1983, Buller received
word from Jack Thompson, Los Angeles Unified School District
Staff Relations consultant, that Lucille Caruso, Principal,
would be issuing a Notice of Unsatisfactory Performance against
him, and that he should arrange to receive it during the summer
months. Buller immediately attempted to find out the basis for
the Notice and protested the fact that he be required to
receive the notice during his vacation.
Buller contacted UTLA Representative Will Mechem on August 1,
1983, and generally explained the problems. 	Buller told Mechem
that, if the District filed an unsatisfactory notice against
him, that he wanted to file a grievance. He also asked Mechem
to appear with him at the meeting where he was to receive the
Unsatisfactory Notice. Mechem informed Buller that he (Buller)
did not have to appear on his vacation time to receive the
Notice.

May 10, 1984
LA-CO-287
Page 2
On August 3, 1983, a short meeting took place, at which time
Buller provided Mechem with copies of correspondence relating
to the problems, and at which time Mechem read and discussed
their contents with Buller. The same day, UTLA lawyer Larry
Trygstad's office and Buller arranged a meeting with attorney
Rich Schwab for the purpose of exploring the possibility of
filing an unfair practice charge against the District.
On August 10, 1983, a school official informed Buller that the
meeting where he was to receive the Notice had been rescheduled
to September 12, 1983, the first day of duty for the school
year. Buller stated that he did not know whether the
rescheduling resulted from UTLA pressure against the District.
On August 15, 1983, Buller went to the UTLA office, and spoke
to Francis Haywood, UTLA Vice President, regarding his case,
outlining what he considered to be anti-union harrassment
against him, since he was the union's Chapter Chairman at Jane
Addams High. Buller explains that Mechem and Richard Estes are
the main persons who handle grievances, with Richard Segure
being the head of the grievance office. But his main reason
for speaking directly to Haywood was "to make sure Mechem would
follow up on my problem with vigor". Haywood suggested that
Buller call Gerald Canales, a teacher in one of the other
continuation schools so he could give Buller information or
help with his problem.
Buller received a letter from UTLA on August 31, 1983 advising
him to attend the September 12 meeting, but not to say anything
to the District, just to receive the Notice, and to forward it
to them to determine if a grievance was advisable. Buller
explains that he realizes that it is standard UTLA procedure
not to attend these meetings with members, but feels that UTLA
should have sent a representative because the school principal
"could have made a statement or blunder" that he (Buller) could
use later. I
1
Buller explains that he has filed two previous
grievances through Mechem in September, 1981 against this same
principal. Both grievances were won.

May 10, 1984
LA-CO-287
Page 3
Therefore, on September 12, 1983, Buller attended the meeting
with a non-employee friend, and received the Notice of
Unsatisfactory Performance without much comment. The purpose
of the meeting, according to Buller, was simply to officially
receive the Notice, and to verify that the papers containing
the allegations (50+ pages) were included. There was no
discussion regarding the merits of the charges. 	Soon after
being issued the Notice, Buller was transferred to Venice High
School on September 20, 1983.
On September 16, 1983, Buller personally presented to Mechem's
secretary the documents he'd received at the September 12
meeting, and included an outline of what he believed to be
violations of the contract, including articles dealing with
District reprisals, discrimination, and transfers. He included
a list of possible remedies, since it was Buller's wish that
UTLA proceed to file a grievance on his behalf.
On about September 19, 1983, Buller , received a letter from
Mechem, attaching a grievance form, stating that UTLA intended
to file the grievance as Buller had insisted. The letter
advised him that the union needed specific evidence, not
arguments, refuting the 37 allegations against him. It further
admonished him that, in the absence of such evidence, Mechem
would advise that the grievance not be processed by the union
beyond Step 1 of the procedure. 2
Attached to the letter was
a grievance form which was completed, except for Buller's
signature, in substantially the same form that Buller had
suggested, and stating that UTLA was representing him.
A few days later, Buller wrote to Mechem, telling him that he
had specific written evidence to provide, and that Mechem
should not agree to "toll the time" with the District. 3
Will Mechem appeared on behalf of Buller at the grievance Step
1 meeting held on October 13, 1983, with District
representatives Anne Falotico and Principal Caruso. Buller,
2Buller claims that he'd already given Mechem voluminous
documents dating from 1982 and 1983 to support his claim of
harrassment.
3principal Caruso was on sick leave due to an operation.

May 10, 1984
LA-CO-287
Page 4
also present, explains that although Mechem brought up some of
the points he had told Mechem about, he mentioned them "with no
vigor at all, and no drive". Buller also complains that Mechem
did not aggressively emphasize the District's failure to
provide him with a pre-notice conference, and that Mechem did
not refer to Buller's earlier memos in response to previous
complaints from his principal. Buller states that Mechem asked
questions, "but not the probing-type questions that would have
put them on the spot". Mechem's refusal to adhere to Buller's
continuous insistence on tape-recording the session is another
source of Buller's dissatisfaction with the representation he
received.
Admittedly, Buller explains, he met with Mechem at a
preparatory meeting before this conference, where they went
over the stack of documents, including Buller's exhibits, "in a
fair amount of detail". The documents number some 81 sheets of
paper, including charges by the District and responsive memos
from Buller. 4
Buller's main claim is that Mechem did not use
these materials "aggressively or effectively", that he was "not
an agressive advocate". Buller further complains that the
October 13 meeting was improper because it was held one day or
so beyond the contract time limits due to Mechem's agreement to
toll the time, contrary to his wishes.
After the one-hour meeting, the District representatives stated
that they would think about the grievance, but no decision was
immediately rendered.
On October 17, 1983, Buller wrote to Mechem asking that he
strongly press for immediate rescission of the Notice. He
attached copies of two letters from Buller's colleagues,
praising Buller's organizational and cooperative qualities.
These letters were forwarded for the purpose of helping to win
the grievance.5
4The District's charges against Buller range from failure
to perform assigned duties, not doing curriculum development,
failure to accept suggestions, et al, occurring during
1982-1983.
5Between the first and second levels of the grievance,
Mechem told Buller, on more than one occasion, that he had a
weak case.

May 10, 1984
LA-CO-287
Page 5
A Step II grievance meeting was held on November 7, 1983 with
District representatives, including the Superintendent of the
high school division, Paul Possemato. Prior to the meeting,
Mechem met with Buller and discussed strategy, tactics, what
items "to go light on", and "things that an advocate and a
client would talk about". 	It was agreed at this preparatory
meeting that the strategy would be "not to give away all their
ammunition".
Once the meeting was underway, Mechem went through the
enumerated accusations against Buller. He would refer to each
and explain how each underlying order to Buller by the District
was unreasonable. Mechem referred to the contract, stated what
sections were violated, and explained why there was a
violation. He also asked questions. Buller was allowed to
participate as well, to ask questions, and provide
explanations. Possemato also asked Buller a good deal of
questions, though Buller concedes that they were reasonable
ones, and therefore not objected to by Mechem.
With respect to this meeting, Buller contends that Mechem's
questions were not "probing ones", that the questions were not
on the points he (Buller) thought should be brought out.
Additionally, Buller argues that they (he and Mechem) had so
much "ammunition" that they could have made more arguments.
The Step II meeting ended with no resolution. On about
November 28, 1983, Buller received a copy of a letter from the
District, sent to Mechem, wherein Mechem and the District
agreed to "toll the time at Step Three". Buller claims that he
had no contact with Mechem between November 7 and the date he
received the letter. He asserts that the tolling of the time
was improper and hurt him because every day he was forced to
work at Venice High School was prejudicial to him since the
transfer was a disciplinary one based upon the Notice of
Unsatisfactory Performance and because Venice High School
required a longer commute (21 miles v. 6 miles).
Subsequent to his receipt of the letter, Buller states that he
called Mechem to find out the reasons for the tolling. It
should be noted that November 28, 1983 was the date that Step
III (arbitration) would have been invoked if the Union had
decided to proceed to arbitration.

May 10, 1984
LA-CO-287
Page 6
Although Buller states that he does not recall Mechem's
response to his question, nor whether he merely left such a
message with his secretary, Mechem did write a responsive
letter, dated December 6, 1983, to Buller. The letter states
the following:
Your grievance has been processed through Steps 1 and
2 of the grievance procedure and is now being tolled
at Step 3. 	I am confident that the District will
continue to deny the allegations at that step as
well. I have reviewed the materials relevant to the
charges contained in the Notice of Unsatisfactory
Service and have concluded that the matter should not
be processed beyond Step 3 to arbitration. I have
presented this recommendation to the Grievance
Committee, which has offered you the opportunity to
appeal this decision at 4:00 p.m. on January 4, 1983
at UTLA headquarters.
Should you wish to accept this opportunity, you are
advised to bring specific factual evidence that would
refute the specific charges in the Notice of
Unsatisfactory Service. If there are witnesses who
would be willing to appear before an arbitrator to
refute the charges, it is important that you bring
written, signed statements from them indicating
exactly what factual testimony they would be willing
to offer in person at some later date.
Please be advised that the committee will allot thirty
minutes to hear your appeal and to ask you questions
related to your presentation. Therefore, it is
advisable that you organize your presentation with
that in mind. Bring 15 copies of any documents you
wish the committee to consider.
If you intend to accept this invitation, please
indicate that in writing to Sam Kresner, Director of
Negotiations and Staff Services, prior to December 16,
1983.
According to Buller, there are some 13-14 members on UTLA's
Grievance Committee. He explains that the existence of. such a
Committee is a new concept, and that the 30 minute appeal
meeting is of standard duration for UTLA members.

May 10, 1984
LA-CO-287
Page 7
Buller thus accepted the offer to appear before the committee,
by letter dated December 9, 1983, and further requested that
Sam Kresner do some preliminary inquiry on his own. UTLA
responded by stating that it was up to Buller to investigate or
present material to the Committee which may refute a staff
member's (Mechem) recommendation to the Committee.
On January 4, 1984, Buller had the meeting with the Grievance
Committee. Some 7-8 members were present, and Buller was not
able to provide the copies of documents he wanted to present,
but did provide copies of what he believed to be key items.
Mechem and Mike Bennet, UTLA Grievance Committee Chairperson
were also present.
Although Buller was granted his allotted time with the
Committee, he contends that because his is a "non-standard
case", he should have been given more time. However, Buller
admits that he did not ask for a longer period. He admits that
he outlined his theory of retaliation and provided the
Committee with copies of pertinent documents during the first
15 minutes. Then, he took questions from the Committee.
Buller claims that the Committee's questions indicated that
they did not understand his case. He adds that he became
involved in an argument about whether the grievance should
proceed to arbitration, with Union representatives arguing that
an aribtrator would credit an administrator over him, and
asking Buller whether he had witnesses. Buller further
concedes that his was one of several other cases scheduled to
be heard in 1/2-hour slots that day by the Committee. 	However ,
he believes that his appeal did not receive proper
consideration.
On January 5, 1984, the Chairman of the Grievance Committee
wrote to Buller, informing him that his presentation and all
available data had been considered, but that the Committee had
voted to concur with the recommendation that the matter not be
pursued to arbitration. After receiving this notice, Buller
wrote to Committee Chairman Mike Bennet and to Will Mechem on
January 13, asking that the Committee provide him with another
meeting so he could appeal the decision. 6
6Buller has stated that he is not aware of an appeal
process from a Committee decision internal within the Union.

May 10, 1984
LA-CO-287
Page 8
Mike Bennet responded, on January 20, 1984, writing that
Buller's January 13 letter had been received, that the
Committee had met on January 18 and carefully reviewed all of
the facts in his case, including evidence presented "jointly
and severally", and decided to let the Committees' decision
stand. 7
The Union followed-up this notice by informing the
District on February 28, 1984, that it had decided not to.
pursue the case to arbitration, that any hearing dates, if any,
be cancelled, and that the matter be considered closed.
Charging party has alleged that UTLA violated his section
3544.9 right of fair representation and thereby violated
section 3543.6 (b) . The fair representation duty imposed on the
exclusive representative extends to grievance handling (Fremont
Teachers Association (King) (4/21/80) PERB Decision No. 124;
United Teachers of Los Angeles (Collins) (1/17/83) PERB
Decision No. 258). However, PERB has held that an employee
does not have an absolute right to have a grievance taken to
arbitration and that an exclusive representative's reasonable
refusal to proceed with arbitration is essential to the
operation of a grievance and arbitration system. Castro Valley
Unified School District (12/17/80) PERB Decision No. 149; Los
Angeles Unified School District (5/20/83) PERB Decision No.
311. Additionally, PERB explicitly has followed decisions of
the federal courts and the National Labor Relations Board
(NLRB) interpreting the National Labor Relations Act (NLRA)
duty of fair representation (Fire Fighters Union v. City of
Vallejo (1974) 12 Cal. 3d 608 [16 Cal. Rptr. 507 [; and see
SEIU, Local 99 (Kimmett) (10/19/79) PERB Decision No. 106).
For example, PERB has adopted the standard that, whether a
union has met its duty depends upon whether the union's conduct
in processing or failing to process the grievance was
discriminatory, arbitrary, or in bad faith. United Teachers of
Los Angeles, supra.
7Bennet's letter noted that one of several considerations
that the Committee reviewed was Buller's failure to provide
written evidence of who his witnesses were and what they would
say, as Buller had promised to provide to the Committee. 	There
was a dispute during the January 4 hearing as to whether two
"character references" had been provided. Therefore, Buller
told the Committee he would provide them by the end of the
business day on January 4. Buller did not do so because he
felt "tired and discouraged".

May 10, 1984
LA-CO-287
Page 9
Mere negligence or poor judgment in handling a grievance does
not constitute a breach of that duty. Ibid. The NLRB has
pointed out that the relationship between the union
representative and an employee is not that of attorney and
client. Beverly Manor Convalescent Center, 229 NLRB 629, 95
LRRM 1156 (1977). If a contract provision supports the
employee under one interpretation, and the Union reasonably
gives the contract another interpretation, the fact that the
union's interpretation may be "wrong" does not establish the
violation. Washington-Baltimore Newspaper Guild (CWA) , 239
NLRB No. 175 (1979) .
In Buchanan v. NLRB (1979) , the U.S. Court of Appeals for the
Fourth Circuit stated that:
"The duty to avoid arbitrary conduct does not require
a union to take every employee grievance to
arbitration, and it has considerable discretion in
sifting out grievances which it regards as lacking
merit. Without such discretion, a union's
effectiveness as bargaining agent would be
undermined - 	. That a grievance was meritorious or
that the union was negligent in not taking the
grievance to arbitration does not, per se, constitute
a showing that the union engaged in arbitrary
conduct." 	111 LRRM 3142, at 3146.
Nor are unions required to obtain explanations from every
grievant or discharged employee regarding facts that are
ambiguous and susceptible of more than one interpretation, in
deciding whether to proceed to arbitration. San Francisco Web
Pressmen and Platemakers Union No. 4 (1980) 249 NLRB No. 23.
In the above case, discharged employees claimed that a Union's
processing of their grievance was arbitrary and perfunctory
because it accepted as fact "accounts of a dispute which are
ambiguous and susceptible of more than one interpretation
without making at least an effort to obtain the grievant's
explanation of his conduct." In dismissing that claim, the
Board held, inter alia, that: where a union undertakes to
process a grievance, but decides to abandon the grievance short
of arbitration, the finding of a violation turns on whether the
union's disposition of the grievance was perfunctory or
motivated by ill will or other invidious considerations.
The facts of this particular case, even if viewed in the light
most favorable to Charging Party, indicate that the Union's

May 10, 1984
LA-CO-287
Page 10
handling of the grievance came to less than negligence, judged
by legal precedent. The quality of representation, while less
agressive than Buller would have liked, did not reach the level
of arbitrariness or bad faith, especially since PERB does not
judge the Unions' effectiveness by comparing it to what an
attorney would have done for his/her client.
The facts show that the Union presented Buller's grievance at
two levels, discussed the case with him at length, received
documents from him and submitted them in support of his case,
asked questions of adverse witnesses, and argued that the
District had violated the contract. When the Union found that
there were weaknesses and problems with the case, it admittedly
did not hesitate to bring them to Buller's attention to give
him a chance to correct deficiencies. Having reached a level
where it was necessary to decide whether it should continue to
press the grievance to more formal levels, including binding
arbitration, the Union provided Buller with an opportunity to
convince the Grievance Committee why it should reverse a staff
recommendation not to go to arbitration.
Although Buller claims he was prejudiced by the Union's
agreement to "toll the time", such claim is unfounded because
tolling the time in actuality gave him an opportunity to submit
his appeal to the Union's Grievance Committee, rather than the
Union simply informing him that his grievance was being .
dropped. Under the contract, UTLA must submit the grievance to
arbitration, not Buller. Whether or not the Union "tolled the
time", Buller would still have been forced to remain working at
Venice High School, because the Union ultimately chose not to
proceed further with the grievance.
Finally, the evidence produced by Charging Party indicates that
the Union's handling of the grievance and its refusal to submit
it to arbitration was not motivated by ill will. Although
Buller states that the Union may have had cause to discriminate
him because, for example - he has openly spoke out against
forced busing in 1981 (some Union officials strongly favor
busing) ; he once told Will Mechem (September - December 1983)
that the Union sometimes gets too involved in politics and not
enough with standing up for principles; he is a National
Education Association affiliate (whereas the top UTLA hierarchy
are allegedly affiliated with the American Federation of
Teachers); and he told Will Mechem that he (Buller) had told
Union President Judy Solkovitz that he (Mechem) was not being
assertive enough and effective enough in handling the grievance,

May 10, 1984
LA-CO-287
Page 11
to which Mechem reacted angrily - the evidence which Buller
provided himself fails to establish any inference that the
Union's attitude towards him was discriminatory.
Mechem has represented Buller on two prior grievances and won
those. 	Buller has never filed charges against the Union
before. 	He has been a union chapter chairperson since
December, 1981, and handled minor union matters prior to the
grievance stages at his school site. Indeed, his underlying
grievance was based on a theory of discrimination by the
District because of Buller's strong UTLA activity.
Additionally, not only was Buller provided with a consultation
appointment with UTLA lawyer Schwab on August 3, 1983 for the
purpose of filing an unfair practice charge, but he was also
given a free Consultation with another union-retained attorney,
Roberta Coyl for the purpose of filing what is termed a
"verification of charges", on September 8, 1983. Again on
August 4, 1983, he was granted another half-hour meeting with
Roberta Coyl for the purpose of filing a reverse sex
discrimination suit against principal Lucille Caruso. 	Later,
attorney Schwab called Buller to discuss the difficulty of
establishing the sex discrimination case.
Although Buller has never been in the Union hierarchy so as to
be involved directly in negotiations, he has done many things
to support the Union cause. In November, 1983, he gave Union
President Judy Solkovitz a copy of a speech made by the
District's Paul Possemato, which proved to be helpful to the
Union in determining the administrations approach toward the
bargaining unit. He wrote articles and submitted them to the
Union's newsletter. He participated in "Boycott Day" on
September 16, 1983 with other union members against the
District. He attended Union meetings, and participated in a
massive District-wide strike in 1970. He has written to the
union president to promote unity among teachers.
Although Buller is opposed to forced busing, he admits he is
just one of many others that openly oppose it. And, although
he told Mechem that the Union got too involved in politics,
Buller explains that this was a "philosophical" discussion, and
Mechem did not get outwardly angry. And, although Buller has
spoken out against UTLA endorsing political candidates, he adds
that other union members have spoken out at union meetings
sharing that view.

May 10, 1984
LA-CO-287
Page 12
UTLA members are free to affiliate with either AFT or NEA,
explains Buller. He states that there are some 13,000 NEA
affiliates in UTLA and some 3,000 AFT affiliates. However,
Buller adds the AFT people are activists. He admits that union
officials such as Frances Haywood and Cathy Jensen are also NEA
affiliates, but claims that there is an "uneasy alliance"
between these groups in UTLA. Nevertheless, Buller's theory of
retaliation based on his NEA affiliation was unsupported by
evidence and is tenuous at best, further disapproved by the
many instances where UTLA has gone out of its way to provide
him with benefits, including legal services.
He concedes that Mechem's attitude toward representing him did
not change before or after he made the comments to Mechem about
the quality of advocacy he was providing nor when he told him
that the Union involved itself too much in politics. Even if
Mechem had cause to feel angry at Buller, he provided Buller
with an opportunity to convince a third, neutral body, the
Grievance Committee, to proceed to arbitration.
In view of the Union's efforts on Buller's behalf, both before
and after his receipt of the Notice of Unsatisfactory
Performance and his transfer, and in view of the above facts
provided solely by him, Buller has failed to establish that
UTLA handled his grievance in a way other than in good faith
and without hostility or discrimination. For all of the
foregoing reasons, the charge is hereby dismissed for failure
to establish a prima facie violation of the EERA.
Pursuant to Public Employment Relations Board regulation 32635
(California Administrative Code, title 8, part III) , you may
appeal the refusal to issue a complaint (dismissal) to the
Board itself.
Right to Appeal
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 Notice (section 32635 (a).
To be timely filed, the original and five (5) copies of such
appeal must be actually received by the Board itself before the
close of business (5:00 p.m. ) on 	, or sent by
telegraph or certified United States mail postmarked not later
than 	(section 32135). The Board's address is:
Public Employment Relations Board
1031 18th Street
Sacramento, CA 95814

May 10, 1984
LA-CO-287
Page 13
If you file a timely appeal of the refusal, any other party may
file with the executive assistant to the Board an original and
five (5) copies of a statement in opposition within twenty (20)
calendar days following the date of service of the appeal
(section 32635 (b) ) .
Service
All documents authorized to be filed herein except for
amendments to the charge must also be "served" upon all parties
to the proceeding, and a "proof of service" must accompany the
document filed with the Regional Office or the Board itself
(see section 32140 for the required contents and a sample
form) . The documents will be considered properly "served" 	when
personally delivered or deposited in the first-class mail
postage paid and properly addressed.
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
executive assistant to the Board at the previously noted
address. A request for an extension in which to file a
document with the Regional Office should be addressed to the
Regional Attorney. A request for an extension must be filed at
least three (3) calendar days before the expiration of the time
required for filing the subject document. The request must
indicate good cause for the position of each other party
regarding the extension and shall be accompanied by proof of
service of the request upon each party (section 32132) .
Final Date
If no appeal is filed within the specified time limits, the
dismissal will become final when the time limits have expired.
Very truly yours,
Dennis Sullivan
General Counsel
Manuel M. Melgoza
Regional Attorney
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