California Union of Safety Employees (Trevisanut) * * * PARTIALLY OVERRULED by Downey Unified School District (2026) PERB Decision No. 3018 * * * (PERB 1029S)

STATE 	OF 	CALIFORNIA
DECISION 	OF 	THE
PUBLIC 	EMPLOYMENT 	RELATIONS 	BOARD
VIC TREVISANUT, 	et al.,
Charging 	Parties,
v.
CALIFORNIA UNION OF 	SAFETY
EMPLOYEES,
Respondent.
Case No. 	S-CO-132-S
PERB Decision No. 	1029-S
December 13, 	1993
Appearances: 	Van Bourg, 	Weinberg, 	Roger & Rosenfeld by Stewart
Weinberg, 	Attorney, 	for Vic Trevisanut, 	et al.; 	Sam A. McCall,
Jr., 	Attorney, 	for California Union of Safety Employees.
Before Blair, 	Chair; 	Hesse and Caffrey, 	Members.
DECISION
BLAIR, 	Chair: 	This 	case 	is before the Public Employment
Relations 	Board 	(PERB or Board) 	on appeal 	by the 	California Union
of 	Safety Employees 	(CAUSE) 	to a PERB administrative 	law judge's
(ALJ) 	proposed decision. 	The ALJ found that 	CAUSE unlawfully
interfered with State Bargaining Unit 	7 	(Unit 	7) 	employees'
rights 	in violation of sections 	3513 (i) 	and 3515 	of 	the Ralph C.
Dills Act 	(Dills Act)1 by refusing to honor signed withdrawal
1The Dills Act 	is 	codified at 	Government 	Code 	section 3512
et 	seq. 	Unless 	otherwise indicated, 	all 	statutory references
herein are 	to the Government Code. 	Section 3513(i) 	states:
"Maintenance of membership" 	means 	that all
employees who voluntarily are, 	or who
voluntarily become, 	members 	of a recognized
employee 	organization shall 	remain members 	of
such 	employee 	organization 	in good 	standing
for a period as 	agreed 	to by 	the parties
pursuant 	to a memorandum of 	understanding,
commencing with 	the 	effective 	date 	of 	the
memorandum of 	understanding. 	A maintenance
@}
* * * PARTIALLY OVERRULED by Downey Unified School District (2026) PERB
Decision No. 3018 * * *

forms 	and letters 	that 	the union admittedly received. 	The Board
has 	reviewed 	the 	entire 	record 	in 	this 	case and 	finds 	that 	CAUSE
violated sections 	3531(i) 	and 3515 	of 	the Dills Act.
FACTUAL 	BACKGROUND
In June 	1991, 	Vic Trevisanut 	(Trevisanut) 	launched a
campaign against 	CAUSE by 	soliciting Unit 	7 members 	to withdraw
from CAUSE. 	The parties' 	agreement permitted employees 	to
withdraw 30 	calendar days prior to 	the expiration of 	the
contract.2 Additionally, 	Dills Act section 3513 (i) 	requires
of membership provision 	shall 	not 	apply 	to
any employee who within 30 	days prior to 	the
expiration of 	the memorandum of understanding
withdraws 	from the 	employee 	organization by
sending a 	signed withdrawal 	letter to 	the
employee 	organization and a 	copy to 	the 	State
Controller's 	office.
Section 3515 	states:
Except 	as 	otherwise 	provided by 	the
Legislature, 	state employees 	shall have
the right to form, 	join, 	and participate
in 	the 	activities 	of 	employee 	organizations
of 	their own choosing 	for the purpose 	of
representation on all matters 	of 	employer-
employee 	relations. 	State employees 	also
shall 	have 	the 	right 	to 	refuse 	to join or
participate 	in 	the activities 	of 	employee
organizations, 	except 	that nothing shall
preclude 	the parties 	from agreeing 	to a
maintenance of membership provision, 	as
defined in subdivision 	(i) 	of Section 3513,
or a 	fair share 	fee provision, 	as defined in
subdivision 	(k) 	of Section 3513, 	pursuant to
a memorandum of understanding. 	In any event,
state 	employees 	shall 	have 	the 	right 	to
represent 	themselves 	individually 	in 	their
employment 	relations with the 	state.
2Article 	3.1 	of 	the 	1988-91 	contract 	between CAUSE 	and 	the
state 	provided:
22

the 	employee 	to 	send a 	signed withdrawal 	letter 	to 	the 	employee
organization and a 	copy to 	the 	State Controller's 	office. 	The
CAUSE/state 	contract was 	to expire on June 30, 	1991, 	which would
have made 	the window period 	for withdrawals 	from June 	1 	to
June 30. 	However, 	the parties agreed to extend the 	contract
one month to July 30. 	Thereafter, 	the contract 	expired before
the parties 	reached agreement 	on a 	successor contract.
Trevisanut 	solicited members 	to withdraw 	their membership
by 	sending 	them a 	form entitled 	"Request 	to 	Terminate 	CAUSE
Membership." 	He 	then 	forwarded the withdrawal 	forms 	to CAUSE.
Other Unit 	7 	employees mailed their requests 	directly to CAUSE.
Some withdrawals 	were 	received by CAUSE 	during 	the month 	of 	June,
some were 	received 	in July, 	and some were 	received in August.
Upon receipt 	of 	the withdrawal 	forms 	CAUSE 	sent 	an
acknowledgment 	form to the members. 	In addition to this 	form,
CAUSE 	included a 	flyer advising 	that 	services 	and benefits
available 	to nonmembers 	would be 	reduced 	effective 	July 	1.
Employees who submitted written withdrawals 	to CAUSE, 	but did
not 	return the acknowledgment 	forms 	to CAUSE were not 	removed
A written 	authorization 	for 	CAUSE 	dues
deductions 	in effect 	on the 	effective 	date 	of
this 	Contract 	or 	thereafter 	submitted 	shall
continue 	in 	full 	force and effect 	during 	the
life of this Contract; 	provided, 	however,
that 	any 	employee may withdraw 	from CAUSE 	by
sending a 	signed withdrawal 	letter 	to 	CAUSE
within thirty 	(30) 	calendar days prior to the
expiration of 	this 	Contract. 	Employees who
withdraw 	from CAUSE 	under 	this 	provision
shall 	be 	subject 	to paying a CAUSE 	Fair Share
fee as 	provided above.
33

from the membership 	rolls 	and dues 	continued 	to be 	deducted 	from
their pay 	checks.
On August 	20, 	Trevisanut 	filed a 	charge with PERB alleging
that 	CAUSE violated 	the Dills Act 	by 	refusing 	to honor withdrawal
letters 	that 	it 	received during the window period. 	In addition,
Trevisanut 	sent 	another 	form to Unit 	7 	employees 	who had 	returned
their withdrawals 	to him. 	This 	form asked the members 	to
authorize 	legal 	action requiring 	CAUSE 	to 	refund 	the 	difference
between membership dues 	and 	fair share 	fees. 	Ninety-seven 	(97)
employees 	returned 	the authorization 	form. 	Those 	individuals
were named as 	charging parties 	in this unfair practice 	charge.
Position 	of 	the 	Parties
The 	charging parties 	contended 	that 	employees 	who 	submitted
withdrawal 	forms 	in June 	had complied with the 	contract window
period and 	the Dills 	Act 	requirements. 	They 	further 	contended
that 	CAUSE 	improperly added 	the 	requirement 	that 	employees 	return
the 	acknowledgment 	form to 	confirm their withdrawal 	and 	that 	the
refusal 	to honor withdrawal 	requests 	that 	did not 	include 	the
additional 	form violated the 	employees' 	statutory right 	to 	refuse
to participate 	in CAUSE activities. 	They stated that July
withdrawals 	were valid because 	California 	State 	Employees'
Association 	(Fry) 	(1986) 	PERB Decision No. 	604-S 	(CSEA 	(Fry))
prohibits 	the parties 	from extending 	the 	contract without 	also
extending 	the window period. 	They 	claim that August 	withdrawals
were valid because 	there 	is 	no 	requirement 	of maintenance 	of
membership 	in the 	absence 	of a 	contract. 	(Ibid.)
4

At 	the beginning 	of 	the 	hearing 	the 	charging parties moved
to amend 	the 	complaint and certify 	it 	as 	a 	class 	action. 	The ALJ
denied 	class 	action status.
CAUSE 	contended 	that 	the 	requirement 	that members 	return
the 	acknowledgment 	form, 	which 	confirmed 	that 	they were 	aware
of 	the impact of withdrawing, 	was reasonable. 	CAUSE stated
that 	it 	reasonably presumed 	that 	individuals 	who did not 	return
the 	acknowledgment 	had 	changed 	their minds 	in light 	of 	the 	new
information contained in 	the 	flyer, 	and 	that 	its 	intention was
to 	insure 	that 	no member was 	unwittingly harmed by withdrawing.
CAUSE 	further contended that, 	although the window period
would have been during the month of 	June, 	once 	the parties 	agreed
to extend the 	contract 	for another month, 	the window period
shifted forward to the month of July. 	Thus, 	withdrawals 	that
were 	submitted 	in June were premature 	and untimely.
ALJ'S 	DECISION
The ALJ 	framed 	the 	issue 	as 	whether CAUSE violated the Dills
Act by 	interfering with charging parties' 	rights 	to withdraw from
union membership.
She 	states 	that 	an alleged 	interference with 	the 	exercise
of 	protected 	rights 	by either an 	employer 	or an 	employee
organization 	is 	analyzed under 	Carlsbad Unified 	School 	District
(1979) 	PERB Decision No. 	89.3 She notes 	that Carlsbad does not
3The 	Board has 	held 	that 	the 	standard applied 	to 	cases
involving 	employer misconduct 	is 	appropriate 	in 	cases 	involving
employee 	organization misconduct. 	(State 	of 	California
(Department of Developmental 	Services) 	(1983) 	PERB Decision
No. 	344-S.
55

require 	that 	the 	respondent 	act with unlawful motive.
As 	to 	the window period, 	the ALJ notes 	that 	PERB has
held that under CSEA 	(Fry) 	an exclusive 	representative and
employer 	are 	prohibited 	from extending 	the 	agreement 	without
also 	extending 	the 	time within which a union member 	could 	resign.
Therefore, 	any signed withdrawals 	that 	were 	received by CAUSE
during both June 	and July 	1991 	were 	timely 	filed.
The 	ALJ determined 	that 	withdrawal 	requests 	received after
the 	expiration of 	the 	contract were also valid. 	She 	states 	that
maintenance 	of membership provisions 	are 	creatures 	of 	contract.
Therefore, 	absent a valid contract, 	members 	cannot be 	forced to
maintain their membership. 	Thus, 	withdrawal 	requests 	received by
CAUSE 	in June, 	July or August were valid.
As 	to 	the acknowledgment 	form, 	the ALJ states 	that 	although
CAUSE was 	entitled 	to 	send out 	the 	notices 	advising members 	that
their services would be 	cut 	if 	they withdrew, 	CAUSE was not
entitled 	to 	require 	employees 	to 	submit 	an additional 	form in
order 	to make 	their withdrawals 	effective.
The ALJ determined 	that 	the appropriate 	remedy was 	to
compensate all 	employees 	who made 	timely withdrawal 	requests
in the amount 	of 	the 	dues wrongly withheld from their paychecks.
This 	remedy was 	granted 	to all 	employees 	who had properly
submitted 	requests 	to withdraw, 	whether or not 	they had joined
as parties 	in this unfair practice charge. 	Thus, 	in addition
to 	the 	97 	named charging parties, 	the 	remedy was 	granted to an
unknown number of 	other employees.
6

EXCEPTIONS
In its appeal, 	CAUSE excepts 	to the ALJ's 	finding of a 	60-
day window period 	for withdrawal, 	arguing 	that 	once 	the 	contract
was 	extended 	the 	window period merely 	shifted 	forward 	so 	that 	it
was 	still 	the 	final 	30 days of 	the contract. 	CAUSE bases 	this
argument 	on 	the 	contention that 	the 	contract 	does 	not 	anticipate
or authorize 	a window period 	longer 	than 	30 	days.
Further, 	CAUSE 	contends 	that 	employees who subsequently
retired or were 	separated 	from 	state 	employment 	lack 	standing 	to
file 	an unfair practice 	charge 	(because 	they are 	not 	employees)
and 	thus 	are 	not 	entitled 	to a 	remedy.
CAUSE 	contends 	that 	the 	class 	of 	employees 	to whom the
remedy was 	granted is 	too broad. 	CAUSE 	states 	that 	harm could
result 	if 	employees 	who had decided not 	to withdraw once 	they
learned 	they would 	lose 	benefits--and 	for 	that 	reason 	chose 	not
to 	join as 	charging parties--were 	involuntarily withdrawn 	from
membership.
The 	charging parties agree with the ALJ's 	decision, 	adding
that 	no harm will 	result 	from nonparties 	being 	granted 	the 	remedy
as 	there 	is 	nothing 	to prevent 	them from refusing 	to accept 	the
refunded dues.
DISCUSSION
Validity of 	Requests 	to Withdraw
We agree with 	the ALJ's 	finding 	that 	CAUSE violated 	the
charging parties' 	right 	to withdraw from membership.
We 	disagree with CAUSE'S 	argument 	that 	withdrawals 	submitted
27

in June were premature. 	When the 	contract 	(including section
3.1) 	was written, 	there was a date 	certain upon which the
contract would expire. 	That 	date 	established the 	last 	day of
the window period. 	Based on the circumstances 	of 	this 	case, 	the
30-day window period 	established by 	the 	terms 	of 	that 	contract
cannot be 	changed. 	When the parties 	agreed to a 	contract
extension, 	they 	created a new contract 	expiration date which
results 	in a 	different window period by operation of 	Dills Act
section 3513(i). 	If the extension is for 30 days or less, 	the
window period 	is 	open during the 	entire 	extension. 	If 	the
extension is 	longer than 30 	days, 	the window period is 	open
during the 	final 	30 	days 	of 	the 	extension. 	We 	cannot permit
the 	contracting parties 	to use 	contract 	extensions 	to 	deprive
members 	of 	their right to withdraw from union membership. 	It
is 	unreasonable 	to 	require 	an employee who withdrew during 	the
original 	window period to 	comply with a new window period. 	In
this 	case, 	the window period would be 	akin to a moving target.
Contrary to CAUSE'S assertion, 	there 	is nothing 	in the 	contract
which suggests 	that 	the window period is 	strictly limited to 	30
days 	if 	the parties agree 	to extend the 	contract. 	Therefore,
.
withdrawals 	received 	in June are valid as 	they 	complied with 	the
original 	contract window period. 	Withdrawals 	received 	in July
are 	valid because 	they 	complied with 	the 	additional 	window period
required when the 	contract was 	extended. 	Withdrawals 	filed 	in
August were valid because, 	as 	the ALJ explained, 	no contract was
in 	force 	and 	thus 	no maintenance 	of membership agreement 	was 	in
8

force.
Standing---------	of 	Retired 	and 	Separated 	Employees
In 	regard 	to employees 	who 	retired or were 	separated 	from
state 	service 	after the unlawful 	denial 	of 	their withdrawal
requests, 	we believe 	that 	they have 	standing. 	CAUSE 	contends
that 	former employees 	have no 	standing 	to bring a 	charge because
they were not 	employees 	at 	the 	time of 	filing. 	Dills Act 	section
3514.5(a) 	states, 	in pertinent part:
Any employee, 	employee organization, 	or
employer shall 	have 	the 	right 	to 	file an
unfair 	practice 	charge 	. . . .
We 	interpret 	this 	section to mean that, 	in order 	for a person to
have 	standing 	to 	file an unfair practice 	charge, 	that person must
have been an employee 	at 	the 	time 	the unfair practice 	occurred.
To 	require a 	charging party to have 	the 	status 	of 	an employee at
any time after that 	could have undesirable 	results. 	For example,
such a 	rule 	would prevent 	an unlawfully 	terminated 	employee 	from
filing a 	charge because 	that person would not be 	an 	employee 	at
the 	time he/she came to PERB to file. 	Thus, 	there 	is only one
reasonable 	interpretation of when a person's 	status 	as 	an
employee 	is 	to be 	examined--at 	the 	time 	that 	the 	alleged unlawful
conduct 	occurred.
Finding 	that a violation has 	occurred, 	we must 	now determine
who 	is 	entitled to a 	remedy.
Remedy
We 	believe 	that 	only named parties 	should be 	granted a
remedy. 	To grant a 	remedy to employees 	not named as parties
--- 	----- - 	-
9

amounts 	to amending the 	complaint.
Here, 	the complaint 	lists the names of 	97 	charging parties.
At 	the beginning 	of 	the 	hearing 	the 	charging parties made 	a
request 	that 	the 	case be 	certified as 	a 	class 	action and 	the ALJ
denied the 	request. 	The 	case was 	litigated with all 	parties
understanding 	that 	the 	case 	involved only 	the 	97 	named 	charging
parties. 	No 	subsequent 	determination was made as 	to whether this
case met 	the 	requirements 	of a class action. 	However, 	in her
proposed decision the ALJ essentially treated the 	case as. a 	class
action by granting 	the 	remedy not 	only 	to 	the 	97 	named 	charging
parties, 	but 	also to nonparties who made 	timely requests 	to
withdraw which were not 	honored. 	After denial 	of 	the motion
for a 	class 	action the parties proceeded on the basis 	that 	the
case was 	limited to the 	97 named charging parties. 	It would
be 	inappropriate 	to 	change 	this 	fact at 	this 	stage 	of 	the
proceedings.
For the 	foregoing reasons, 	we grant 	the 	remedy only to
the 	named 	charging parties.
CONCLUSION
We affirm the ALJ's 	findings 	that withdrawals 	submitted
in June, 	July or August were valid and that 	CAUSE'S 	additional
requirement 	that 	employees 	return 	the 	acknowledgment 	form was
unlawful. 	We 	grant 	the 	remedy only to 	the named 	charging
parties.
REMEDY
We 	find 	that 	the 	charging parties 	who 	submitted valid
10

withdrawal 	requests 	are 	entitled 	to be 	reimbursed 	in 	the 	amount
of 	the money wrongfully withdrawn 	from their paychecks, 	with
interest.
ORDER
Upon the 	foregoing 	findings 	of 	fact 	and conclusions 	of 	law,
and the entire record in this 	case, 	the Board finds 	that 	the
California Union of 	Safety Employees 	(CAUSE) 	violated the
Ralph C. 	Dills Act 	(Dills Act), 	Government Code section 3513(i)
and 	3514.5(c) 	by unlawfully 	interfering with State 	Bargaining
Unit 7 employees' 	rights.
Pursuant to section 3514.5(c) 	of 	the Dills Act, 	it is hereby
ORDERED 	that 	CAUSE and its 	representatives 	shall:
A. 	CEASE AND DESIST FROM:
1. 	Unlawfully 	interfering with State 	Bargaining Unit 	7
employees' 	rights 	to withdraw from union membership.
B. 	TAKE 	THE 	FOLLOWING AFFIRMATIVE ACTIONS 	DESIGNED TO
EFFECTUATE THE 	POLICIES 	OF THE DILLS ACT:
1. 	Make whole all 	charging parties who 	filed timely
written withdrawals 	from membership 	in CAUSE. 	CAUSE will 	refund
to 	each qualifying 	charging party the 	amount 	of 	dues 	unlawfully
deducted 	from his/her paychecks 	beginning with 	the 	date 	on which
the withdrawal 	request 	should have been given effect. 	The amount
due 	each 	charging party shall 	include 	interest 	at 	the 	rate 	of 	ten
(10) 	percent per annum pursuant 	to Code of 	Civil 	Procedure
section 685.010.
2. 	Within thirty-five 	(35) 	days 	following the date
this Decision is no longer subject 	to reconsideration, 	post at
11

all 	work 	locations where 	notices 	to 	employees 	are 	customarily
placed, 	copies 	of 	the 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 	this
Notice 	is not 	reduced in size, 	defaced, 	altered or covered by any
material.
3. 	Written notification of 	the 	actions 	taken to
comply with this 	Order shall 	be made 	to 	the 	Sacramento Regional
Director 	of 	the 	Public 	Employment 	Relations 	Board 	in accordance
with his 	instructions.
Member 	Caffrey 	joined 	in this 	Decision.
Member Hesse's 	concurrence begins on page 	13.
12
.

Hesse, 	Member, 	concurring: 	I concur only in the result of
the majority decision. 	I write 	separately because 	I wish to
affirmatively distance myself 	from the majority discussion 	of
"Standing 	of 	Retired and Separated Employees," 	particularly 	the
reference 	to undesirable 	results.
Relying upon San Leandro Unified School District 	(1984) 	PERB
Decision No. 	450 	(San Leandro); 	Hacienda La Puente Unified School
District 	(1988) 	PERB Decision No. 	685 	(Hacienda LaPuente) 	and its
progeny, 	Los Angeles Unified School District 	(1988) 	PERB Decision
No. 	686, 	the California Union of Safety Employees argues 	that
since 	some 	of 	the 	charging parties 	separated or 	retired 	from
state 	service prior to the 	Public 	Employment Relations 	Board
(Board) 	complaint 	being 	issued and 	some parties 	departed after
the 	complaint was 	issued, 	those 	individuals who are no longer
actively 	employed with the 	state 	have 	no 	standing 	to bring 	an
unfair practice 	charge and consequently, 	have no standing 	to
obtain 	relief.
In San Leandro, 	the Board held that 	the 	charging party, 	the
retired 	employees 	association was 	not 	an 	employee 	association
within 	the meaning 	of 	the 	Educational 	Employment 	Relations Act
(EERA or Act) 	and none of 	the 	retired employees 	association
members were 	employees within the meaning of 	the Act.
Furthermore, 	the 	charging party lacked standing 	to 	challenge 	the
collective 	bargaining 	agreement 	as 	the 	association 	did not
represent 	any 	employees 	who had 	retired or would 	retire under 	the
13

new collective bargaining agreement 	which was 	the 	issue 	in 	the
unfair practice 	charge before 	the 	Board.
In Hacienda 	La 	Puente,1 the 	Board held 	first 	that 	a 	former
employee's 	denial 	of 	a leave 	of 	absence and resignation occurred
outside 	the 	Board's 	jurisdictional 	six-month statute 	of
limitations 	and 	secondly, 	that 	the 	charging party now an
applicant 	lacked 	standing 	to 	file 	a 	charge 	to subsequent 	alleged
discriminatory 	conduct because 	he was 	not 	an employee within 	the
meaning of 	the Act 	at 	the 	time 	the alleged misconduct 	took place.
In both San Leandro and Hacienda La 	Puente, 	the 	charging
parties 	were 	not 	an 	employee 	organization or employees 	at 	the
time 	the 	alleged unlawful 	conduct 	occurred. 	Under California
civil procedure, 	the 	cause of action accrues when the wrongful
act is done. 	(See 3 Witkin, 	Cal. 	Procedure 	(3d ed. 	1985)
Actions, 	sec. 	351, 	p. 	380.) 	Regardless of the employment status
of 	the 	charging parties 	subsequent 	to 	the 	filing of 	the 	charges,
the 	charging parties 	in this 	case were 	employees 	at 	the 	time 	the
unlawful 	conduct occurred. 	Therefore, 	I 	conclude that 	the
charging parties 	had 	standing 	to 	file 	charges 	and were 	entitled
to relief.
EERA 	is 	codified at Government 	Code 	section 3540 	et 	seq.
Unless 	otherwise 	indicated, 	all 	statutory references 	are 	to 	the
Government 	Code. 	A 1989 	amendment 	to EERA section 3543.5 	extends
EERA protection 	to applicants 	against 	the actions 	of 	an 	employer.
No parallel 	protection exists 	for applicants 	against 	the 	actions
of 	an employee 	organization.
14

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-CO-132-S,
California Union of Safety Employees v. 	Vic Trevisanut. 	et al..
in which all parties had the 	right 	to participate, 	it has been
found 	that 	the 	California Union of 	Safety Employees 	(CAUSE)
violated the Ralph C. 	Dills Act 	(Dills Act), 	Government Code
sections 	3513(i) 	and 	3515 	by unlawfully 	interfering with State
Bargaining Unit 7 	(Unit 7) 	employees' 	rights.
As 	a 	result 	of 	this 	conduct, 	we have been ordered to post
this 	notice and we will:
A. 	CEASE AND DESIST FROM:
1. 	Unlawfully interfering with Unit 	7 	employees'
rights 	to withdraw from union membership.
B. 	TAKE 	THE 	FOLLOWING AFFIRMATIVE ACTIONS 	DESIGNED TO
EFFECTUATE THE 	POLICIES 	OF THE DILLS ACT:
1. 	Make whole all 	charging parties who 	filed timely
written withdrawals 	from membership 	in CAUSE. 	CAUSE will 	refund
to 	each qualifying 	charging party 	the 	amount 	of 	dues 	unlawfully
deducted 	from his/her paychecks 	beginning with 	the 	date 	on which
the withdrawal 	request 	should have been given effect. 	The amount
due 	each 	charging party shall 	include 	interest 	at 	the 	rate 	of 	ten
(10) 	percent per annum pursuant 	to Code of 	Civil 	Procedure
section 685.010.
Dated: 	CALIFORNIA UNION OF 	SAFETY
EMPLOYEES
By: Authorized 	Agent
THIS 	IS AN OFFICIAL NOTICE. 	IT MUST REMAIN POSTED 	FOR AT LEAST
THIRTY 	(3 0) 	CONSECUTIVE WORKDAYS FROM THE DATE OF POSTING AND
MUST NOT BE REDUCED 	IN SIZE, 	DEFACED, 	ALTERED OR COVERED BY ANY
MATERIAL.
'@I 	•
'