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FOLEY & LARDNER LLP ONE MARITIME PLAZA, SIXTH FLOOR SAN FRANCISCO, CA 94111-3409 TELEPHONE: 415.434.4484 FACSIMILE: 415.434.4507 LAURENCE R. ARNOLD, CA BAR NO. 133715 EILEEN R. RIDLEY, CA BAR NO. 151735 SCOTT P. INCIARDI, CA BAR NO. 228814 Attorneys for STANFORD HOSPITAL & CLINICS and LUCILE PACKARD CHILDREN'S HOSPITAL
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
STANFORD HOSPITAL & CLINICS and LUCILE PACKARD CHILDREN'S 12 HOSPITAL,
11 13 14 15 16
Case No: 5:07-CV-05158-JF DECLARATION OF LAURIE J. QUINTEL IN SUPPORT OF STANFORD HOSPITAL AND CLINICS' AND LUCILE PACKARD CHILDREN'S HOSPITAL'S MOTIONS FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATION OF CLAIMS OR DEFENSES Date: Time: Dept: Judge: August 29, 2008 9:00 A.M. Ctrm. 3, 5th Floor Hon. Jeremy Fogel
Petitioners, vs. SERVICE EMPLOYEES INTERNATIONAL UNION, LOCAL 715, Respondent.
17 18 19 20
SERVICE EMPLOYEES 21 INTERNATIONAL UNION, LOCAL 715 Petitioner and Counter22 Respondent,
23 24
Case No: 5:08-CV-00213-JF
vs.
STANFORD HOSPITAL & CLINICS and 25 LUCILE PACKARD CHILDREN'S HOSPITAL
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QUINTEL DECLARATION IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT/ADJUDICATION CASE NOS. 5:07-CV-05158-JF, 5:08-CV-00213-JF, 5:08-CV-00215-JF; 5:08-CV-00216-JF; 5:08-CV-01726-JF; 5:08-CV-01727-JF
SFCA_1424159.3
Respondents and CounterPetitioners.
Judge:
Hon. Jeremy Fogel
Case 5:08-cv-00213-JF
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SERVICE EMPLOYEES INTERNATIONAL UNION, LOCAL 715 Petitioner,
Case No: 5:08-CV-00215-JF
3
vs.
4 5 6
STANFORD HOSPITAL & CLINICS and LUCILE PACKARD CHILDREN'S HOSPITAL Judge: Respondents. Hon. Jeremy Fogel
7 8 9 10 11
SERVICE EMPLOYEES Case No: 5:08-CV-00216-JF INTERNATIONAL UNION, LOCAL 715 Petitioner, vs.
STANFORD HOSPITAL & CLINICS and LUCILE PACKARD CHILDREN'S 12 HOSPITAL
13 14 15 16 17 18 19 20 21 22 23 24
Judge: Respondents. SERVICE EMPLOYEES INTERNATIONAL UNION, LOCAL 715 Petitioner, vs. STANFORD HOSPITAL & CLINICS and LUCILE PACKARD CHILDREN'S HOSPITAL Judge: Respondents. SERVICE EMPLOYEES INTERNATIONAL UNION, LOCAL 715 Petitioner, vs.
Hon. Jeremy Fogel
Case No: 5:08-CV-01726-JF
Hon. Jeremy Fogel
Case No: 5:08-CV-01727-JF
STANFORD HOSPITAL & CLINICS and LUCILE PACKARD CHILDREN'S 25 HOSPITAL
26 27 28
QUINTEL DECLARATION IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT CASE NOS. 5:07-CV-05158-JF, 5:08-CV-00213-JF, 5:08-CV-00215-JF; 5:08-CV-00216-JF; 5:08-CV-01726-JF; 5:08-CV-01727-JF
Respondents.
Judge:
Hon. Jeremy Fogel
Case 5:08-cv-00213-JF
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I, Laurie J. Quintel, declare as follows: 1. I am employed by Stanford Hospital & Clinics and Lucile Packard Children's
Hospital (the "Hospitals"). I was hired in July of 2001 as the Hospitals' Manager of Employee and Labor Relations. About two (2) years ago, I assumed the position of Director of Employee and Labor Relations. I have personal knowledge of the following facts. If called as a witness I could and would competently testify as follows. 2. 3. The Hospitals operate two acute care hospitals located in Stanford, California. In my capacity as Director of Employee and Labor Relations, I manage day-to-
day employee and labor relations matters, including oversight of the Hospitals' collective bargaining agreements with labor unions representing Hospital employees. Among these collective bargaining agreements is an agreement between the Hospitals and Service Employees International Union, Local 715 ("Local 715"), a union that, at the time the agreement was signed represented a unit of Hospital employees (the "Bargaining Unit"). This agreement will be referred to herein as the "CBA". Anesthesia Techs Grievance And Arbitration 4. The Hospitals employ persons in a job category known as "Anesthesia
Technician" or "Anesthesia Tech." Anesthesia Techs are within the Bargaining Unit governing by the collective bargaining agreement. Anesthesia techs work in various parts of the Hospitals, including in an area known as the "Main Operating Room" or "Main O.R." Anesthesia techs are sometimes asked to carry communication devices called "Spectralink telephones" ("Spectralinks"). 5. Under Article 9 of the CBA, Bargaining Unit employees may become entitled to
premium payments known as "relief in higher classification pay" or "RHC pay" under certain circumstances set forth in Article 9. Under the CBA, anesthesia techs do not become entitled to RHC pay by virtue of being assigned to carry a Spectralink. 6. On or around April 25, 2006, I received a document titled "SEIU Grievance
Form" setting forth a grievance (the "Grievance") filed on behalf of "All Affected Anesthesia Techs" and alleging that the Hospitals violated "Article 9 and the contract as a whole" on the 1
QUINTEL DECLARATION IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT CASE NOS. 5:07-CV-05158-JF, 5:08-CV-00213-JF, 5:08-CV-00215-JF; 5:08-CV-00216-JF; 5:08-CV-01726-JF; 5:08-CV-01727-JF
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grounds that "Employer not paying 5% Relief in Higher Classification Differential to Anesthesia Techs carrying the Spectra-Link Phone." 7. After holding a "Second Step Grievance Hearing" on the matter on July 21, 2006,
the Hospitals determined that the Grievance was without merit and notified Local 715 that they were denying the Grievance. 8. On or around September 19, 2006, the grievance was moved to arbitration. Local 715 Status 9. In early 2006, Greg Pullman, Local 715's Staff Director, informed me that I
should work with a woman named Ella Hereth on matters relating to Local 715's representation of the Bargaining Unit. When I received written correspondence from Ms. Hereth, I noticed that she identified her position as "Field Representative, SEIU United Healthcare Workers West." I am aware that Service Employees International Union, United Healthcare Workers West ("UHW") is a labor organization. However, UHW does not represent any employees of the Hospital. 10. In late February, 2006, Ms. Hereth brought to my office a woman named Rachel
Deutsch. Ms. Deutsch informed me that she was a representative of UHW. She told me that UHW was now representing the Hospital employees who had hitherto been represented by Local 715. I responded that the employees in question were represented by Local 715 and that, as Ms. Deutsch was a representative of UHW, she and I had nothing to discuss. 11. The events referenced above left me unsure as to the status of Local 715.
Therefore, on March 1, 2006, I sent an e-mail to Mr. Pullman referencing Ms. Hereth's identification of herself as an employee of UHW and my conversation with Ms. Deutsch and requesting clarification. A true and correct copy of this e-mail is attached hereto as Exhibit A. 12. Mr. Pullman responded to my e-mail on March 1, 2006. In his e-mail he stated
that Local 715 represented the employees covered by the CBA, but that Local 715 had entered into an agreement with UHW "to help service the Local 715 members at the Hospital" and that "Local 715 has asked SEIU UHW to service this unit in many ways on a day to day basis." He specifically identified Ms. Hereth and Ms. Deutsch as among the "individuals from SEIU UHW 2
QUINTEL DECLARATION IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT/ADJUDICATION CASE NOS. 5:07-CV-05158-JF, 5:08-CV-00213-JF, 5:08-CV-00215-JF; 5:08-CV-00216-JF; 5:08-CV-01726-JF; 5:08-CV-01727-JF
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providing these services." A true and correct copy of the e-mail I received is attached hereto as Exhibit B. 13. The Hospitals initially accepted Mr. Pullman's representation that Local 715
remained the entity representing Bargaining Unit employees at face value. However, in the following months, I became aware of various facts causing me to doubt that Local 715 continued to act as the representative of the Bargaining Unit, and that Local 715 continued to exist at all. 14. Around March 10, 2006, I received a letter from Ms. Hereth on UHW stationery.
The letter requested that I direct "all SEIU correspondence" to "Ella Hereth and Rachel Deutsch, SEIU United Healthcare Workers West." A true and correct copy of the letter I received is attached hereto as Exhibit C. 15. In April and May, 2006, I received notices of grievances and information requests
filed on behalf of Bargaining Unit employees pursuant to the CBA. Although the employees in question were purportedly represented by Local 715, the notices were printed on UHW letterhead, submitted by UHW employees, and, in some cases, were expressly filed "on behalf of SEIU-UHW" or referred to the employees as members of UHW. Copies of notices relating to nine (9) grievances and two (2) information requests are attached hereto as Exhibit D. 16. In or around early April, 2006, I received a telephone call from Phyllis Willett,
who identified herself as an employee of UHW. Ms. Willett told me that when the Hospitals remitted union dues, they needed to provide the social security numbers for the employees because, due to the large number of employees represented by UHW, the employees sometimes could not be distinguished by name alone. I responded that UHW did not represent any of the Hospitals' employees. 17. Around April 17, 2006, I received a letter from William A. Sokol of the law firm
Weinberg Roger & Rosenfeld (the "Weinberg Firm"). The Weinberg Firm had represented Local 715 ever since it was certified in 1998. However, Mr. Sokol stated in the letter that he was writing "on behalf of SEIU United Healthcare Workers West" with respect to a request that the Hospitals provide information to UHW on dues deducted from employees of the Hospitals "represented by UHW," including the social security numbers of bargaining unit employees. 3
QUINTEL DECLARATION IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT/ADJUDICATION CASE NOS. 5:07-CV-05158-JF, 5:08-CV-00213-JF, 5:08-CV-00215-JF; 5:08-CV-00216-JF; 5:08-CV-01726-JF; 5:08-CV-01727-JF
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The letter referred to the Hospitals as "Stanford University Medical Center," a frequently used, but incorrect, name for the Hospitals.. A true and correct copy of the letter that I received is attached hereto as Exhibit E. 18. On or around May 1, 2006, I received a letter from Mr. Pullman in which he
stated that, pursuant to a "service agreement," UHW was handling "all representational matters at Stanford and Lucille (sic) Packard Hospitals," including approval of contract language and the handling of grievances. He also stated that, in addition to Ms. Deutsch and Ms. Hereth, Jocelyn Olick was also assigned to the Hospitals pursuant to the service agreement. A true and correct copy of the above-referenced letter is attached hereto as Exhibit F. 19. By mid-May, 2006 I observed that nearly all written union correspondence
regarding the Bargaining Unit was issued by UHW employees and printed on UHW letterhead. On May 24, 2008, I e-mailed a letter to Mr. Pullman dated May 18, 2006. The letter informed Mr. Pullman that the Hospitals "[did] not recognize UHW as having any relationship with the Hospitals" and that, accordingly, all correspondence relating to representational issues at the Hospitals would be directed to Local 715, but not to UHW. A true and correct copy of the email I sent and the attached letter is attached hereto as Exhibit G. 20. In late May, 2006 I received a copy of an e-mail string from May Sun-Young, one
of the Hospitals' Senior Employee and Labor Relations Specialists. The string contained a May 22, 2006 e-mail from Ms. Olick written to Ms. Sun-Young. In that e-mail, Ms. Olick wrote, "I and Ella Hereth do not work for SEIU Local 715. SEIU-UHW is doing the representation work at Stanford Hospital." The string also contained a May 22, 2006 e-mail from Mr. Pullman to Ms. Sun-Young in which he stated that "Jocelyn Olick, Rachel Deutch (sic) and Ella Hereth out of the SEIU UHW San Francisco office are handling all representation matters for SEIU Local 715." A true and correct copy of the e-mail string I received is attached hereto as Exhibit H. 21. On May 26, 2006, I received an e-mail from Ms. Olick in which she purported to
accept a revision to Article 5 of the CBA. On May 30, 2006 I informed Mr. Pullman that Ms. Olick was not an appropriate person to make a decision regarding revisions to the CBA. A true and correct copy of the above-referenced e-mails is attached hereto as Exhibit I. 4
QUINTEL DECLARATION IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT/ADJUDICATION CASE NOS. 5:07-CV-05158-JF, 5:08-CV-00213-JF, 5:08-CV-00215-JF; 5:08-CV-00216-JF; 5:08-CV-01726-JF; 5:08-CV-01727-JF
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22.
On June 14, 2006, I used the internet browser on my computer to access the
website of Service Employees International Union, Local 707, a then-existing SEIU local. On the website I located a link to a document dated June 9, 2006 and titled "HEARING OFFICERS' JOINT REPORT AND RECOMMENDATIONS." On page 16, the report states that "UHW is actually servicing employees in these facilities represented by Locals 707, 715, and 2028 pursuant to servicing agreements." The report also detailed a plan to reorganize California SEIU local unions by, among other things, merging Local 715 into other locals, including UHW. A true and correct copy of the report is attached hereto as Exhibit J. 23. While on the Local 707 website I also located a link to memorandum dated June
11, 2006 from Andrew L. Stern, President of the Service Employees International Union (the "International") to "Affected SEIU Local Unions in California." The memorandum announced the approval of a "jurisdictional plan" for California SEIU Locals. On its fourth page, the memorandum states, "Private Sector Hospital units currently represented by Local 535,707, 715, 2028 and 4988 will merge into UHW. (Emphasis in original.) A true and correct copy of the memorandum is attached hereto as Exhibit K. 24. On August 15, 2006, I received a fax transmission from "Greg P." who I believed
to be Greg Pullman. The fax cover-sheet was printed on Local 715 stationery. However, I noted that the fax information line printed at the top of the document indicated that the fax originated from "Local 250 San Francisco." Service Employees International Union Local 250 was the predecessor organization to UHW. To my knowledge, Local 715 has never had a San Francisco office. Behind the fax cover sheet was a three (3) page document titled "SERVICING AGREEMENT." The Servicing Agreement was signed by Sal Roselli, the president of UHW, and Kristy Sermersheim, the executive secretary of Local 715. Ms. Sermersheim's signature was dated February 20, 2006. The Servicing Agreement, whose effective date is March 1, 2006, provides that UHW will provide "professional services" to Local 715 including representation in grievances and arbitrations, representation at labor-management meetings, and assistance appearing before the NLRB. The Servicing Agreement further provides that, in the event that it is challenged or rejected by the Hospitals, Local 715 and UHW will process legal actions 5
QUINTEL DECLARATION IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT/ADJUDICATION CASE NOS. 5:07-CV-05158-JF, 5:08-CV-00213-JF, 5:08-CV-00215-JF; 5:08-CV-00216-JF; 5:08-CV-01726-JF; 5:08-CV-01727-JF
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necessary to its enforcement, including by filing unfair labor practice charges with the NLRB. A true and correct copy of the above-referenced document is attached hereto as Exhibit L. 25. After reviewing the Servicing Agreement, the Hospitals concluded that it was
invalid, and informed Local 715 that the Hospitals rejected the Servicing Agreement. Thereafter, the Hospitals refused to deal with UHW employees acting pursuant to the Servicing Agreement. The Hospital employees who had been appointed shop stewards prior to March 1, 2007 became the principal point of contact between the Hospitals and the purported Local 715 after that point. 26. On or around September 25, 2006, a Hospital employee who was a member of the
Bargaining Unit faxed me a four (4) page document. The first page of the document contained voting and mailing instructions for a vote on the "SEIU California Unite To Win Reorganization Plan." The second page of the document contained a summary of the plan, which stated in part, "Hospital workers at . . . Stanford/Lucille (sic) Packard Children's Hospital . . . will change their affiliation to United Healthcare Workers West." The third page of the document contained a "Local Union Assignment Chart" stating "Stanford/Lucille (sic) Packard Hospitals workers to UHW." The fourth page of the document contained the ballot. A true and correct copy of the above-described document is attached as Exhibit M. 27. On or around June 10, 2006, I used my computer's internet browser to access a
website at http://www.caunitetowin.org. On that website, I located a page containing a report stating "Unite to Win Plan wins by 88% margin." I printed a copy of this web page, a true and correct copy of which is attached hereto as Exhibit N. 28. On January 31, 2007, I was copied on an e-mail from Robert W. Rutledge, Chief
Steward for the Bargaining Unit to Valerie Jeffries, a Senior Employee and Labor Relations Specialist. In the course of the e-mail, Mr. Rutledge stated, "SEIU 715 no longer exists and a service agreement between the former 715 and UHW has been in place since March first of 2006." A true and correct copy of the e-mail I received is attached hereto as Exhibit O. The email was also sent to Ms. Olick, and Kim Tavaglione, at that time an employee of UHW. To my knowledge, neither Ms. Olick nor Ms. Tavaglione responded to contradict Mr. Rutledge's statement that Local 715 had ceased to exist. 6
QUINTEL DECLARATION IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT/ADJUDICATION CASE NOS. 5:07-CV-05158-JF, 5:08-CV-00213-JF, 5:08-CV-00215-JF; 5:08-CV-00216-JF; 5:08-CV-01726-JF; 5:08-CV-01727-JF
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29.
On February 2, 2007, I attended a meeting with Mr. Rutledge. The purpose of the
meeting was to follow up on an earlier meeting regarding planned layoffs at Lucile Packard Children's Hospital. During the meeting, Mr. Rutledge informed me that he wanted to bargain over the layoffs. I told Mr. Rutledge that the purpose of the meeting was not to bargain over the layoffs, but rather for the Hospitals to give notice of the layoffs and discuss them, pursuant to the CBA with Local 715. Mr. Rutledge responded that Local 715 no longer represented employees at the Hospitals, that Local 715 had ceased to exist, and that UHW now represented the Bargaining Unit. I told Mr. Rutledge that the CBA was with Local 715, and that Local 715 was the only representative with whom the Hospitals would discuss the layoffs. 30. In late January and early February, 2007, I used my computer's internet browser
to access Local 715's website at http://www.SEIU715.org. When I did so, I observed a statement on the website that read, "We are in the process of transitioning to our new Local 521. This web site will be taken down on Feb. 28. On March 1, our new Local's web site www.seiu521.org will have your chapter pages and other information." The web page continued numerous other references to "our new local" and a reference to the "California Unite To Win Plan." On February 12, 2007, I used my e-mail program to e-mail a copy of the web page containing the above-described statements to various Hospital employees. A true and correct copy of the e-mail containing the image of the web page is attached hereto as Exhibit P. 31. On February 19, 2007 I sent a letter to Ms. Sermersheim. I described Mr.
Rutledge's January 31 and February 2, 2007 statements regarding the existence of Local 715, as well as the statement on the Local 715 website. I informed Ms. Sermersheim that these statements raised questions concerning the representation of the Bargaining Unit that required clarification. I requested that Ms. Sermersheim provide such clarification. A true and correct copy of the letter that I sent is attached hereto as Exhibit Q. 32. Starting on March 1, 2007, I began regularly accessing the website of Local 715
at http://www.SEIU715.org in an effort to gain information as to the status of the local. I discovered that when I entered the above-referenced address into my internet browser, I was automatically redirected to the homepage of Local 521 at http://www.SEIU521.org. In browsing 7
QUINTEL DECLARATION IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT/ADJUDICATION CASE NOS. 5:07-CV-05158-JF, 5:08-CV-00213-JF, 5:08-CV-00215-JF; 5:08-CV-00216-JF; 5:08-CV-01726-JF; 5:08-CV-01727-JF
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the Local 521 website, I located a web page stating that five local unions, including Local 715 "have come together . . . by forming one larger, more powerful local." Another web page referenced benefits available to "former SEIU Local 715 members." On March 2, 2007, I printed copies of web pages from the Local 521 website, true and correct copies of which are attached hereto as Exhibit R. 33. I regularly continued to attempt to access the Local 715 website after March 1,
2007, and I continued to be redirected to the Local 521 website. However, in or around midMay, 2007, I was once again able to access the Local 715 website without being redirected to the Local 521 website. However, I observed that the Local 715 website was now largely devoid of content. 34. On March 2, 2007. I accessed the website of UHW at http://www.SEIU-
UHW.org. On the website, I located a page that allowed users to search the facilities that UHW claimed to represent. I typed "Stanford" into the search field. The search results listed "Stanford University Medical Center." I printed a copy of the search result, a true and correct copy of which is attached hereto as Exhibit S. 35. Bargaining Unit employees authorize deduction of union by means of a written
authorization form. A true and correct copy of the form used for the Local 715 dues deductions is attached hereto as Exhibit T. 36. By March 2, 2007 I had not received any response from Ms. Sermersheim, or
anyone else, regarding my February 19, 2007 request for clarification. Therefore, On March 2, 2007, I sent a second letter to Ms. Sermersheim. I reiterated my request for clarification of the status of Local 715. Additionally, I informed Ms. Sermersheim that, in light of the evidence that Local 715 had formally or effectively ceased to exist, the Hospitals, could no longer remit union dues absent clarification as to Local 715's status or as to what entity, if any, was purportedly representing the Bargaining Unit. A true and correct copy of the letter that I sent is attached hereto as Exhibit U. 37. Effective March 1, 2007, the Hospitals ceased remitting the dues they formerly
remitted to Local 715. The Hospitals continued to deduct union dues from Bargaining Unit 8
QUINTEL DECLARATION IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT/ADJUDICATION CASE NOS. 5:07-CV-05158-JF, 5:08-CV-00213-JF, 5:08-CV-00215-JF; 5:08-CV-00216-JF; 5:08-CV-01726-JF; 5:08-CV-01727-JF
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employees pursuant to the CBA. Those funds were held in a separate bank account established for that purpose. The Hospitals have continued this procedure to this date. 38. In December, 2007, I requested a report from Jackie Villa, the Hospitals'
Manager of payroll, showing the date and amount of the last remittance of dues made by the Hospitals to Local 715. Ms. Villa sent me a Bank of America report. The third entry on the report (reference number 13940541) shows a payment wired on March 8, 2007 in the amount of $21,949.35, which represents the last remittance of dues to Local 715 to date, which was for dues deducted in February, 2007. A true and correct copy of the report is attached hereto as Exhibit V. 39. On March 5, 2007, I received a letter from Mr. Sokol responding to my March 2,
2007 letter to Ms. Sermersheim. Mr. Sokol stated that Local 715 "continues to exist" and that there "has been no change in Local 715's status." A true and correct copy of the abovereferenced letter is attached hereto as Exhibit W. 40. On March 5, 2007, I again accessed the Local 521 website. On the website I
located a web page containing the statement, "Five locals (415, 535, 700, 715, and 817) have come together to cover the North Central region by forming one larger, more powerful local. On January 2, 2007, our new local received its charter. On March 1, 2007, the resources of all five locals were transferred to Local 521." I printed a copy of the above-referenced web page, a true and correct copy of which is attached hereto as Exhibit X. 41. On March 6, 2007, I sent a letter responding to Mr. Sokol's letter of the previous
day. I informed Mr. Sokol that, in light of the mounting evidence regarding the changes to Local 715, the Hospitals required more than Mr. Sokol's assurance regarding its continued existence. I requested that Mr. Sokol provide more detailed information regarding Local 715's status, as stated in my March 2, 2007 letter to Ms. Sermersheim. A true and correct copy of the abovereferenced letter is attached hereto as Exhibit Y. 42. On March 14, 2007, I received a letter from Mr. Sokol bearing that date. Mr.
Sokol did not provide detailed information as I had requested, but continued to assert that "Local 715 continues to exist, it continues to have assets, and it continues to operate as a labor 9
QUINTEL DECLARATION IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT/ADJUDICATION CASE NOS. 5:07-CV-05158-JF, 5:08-CV-00213-JF, 5:08-CV-00215-JF; 5:08-CV-00216-JF; 5:08-CV-01726-JF; 5:08-CV-01727-JF
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organization." A true and correct copy of the above-referenced letter is attached hereto as Exhibit Z. 43. On March 29, 2007, I sent a letter to Ms. Sermersheim formally requesting
information concerning the status of Local 715, and the extent of any changes to its employees, officers, assets, and corporate structure in light of its announced affiliation with Local 521. The letter requested a response by April 9, 2007. A true and correct copy of the letter is attached hereto as Exhibit AA. 44. On or around April 9, 2007, I received a letter from Bruce A. Harland, an attorney
with the Weinberg Firm, stating on behalf of Local 715 that none of the information requested in My March 29, 2007 information request would be provided. A true and correct copy of the letter I received is attached hereto as Exhibit BB. 45. Also on April 9, 2007, I again accessed the Local 521 website. On the website I
located a web page containing the statement, "Five locals (415, 535, 700, 715, and 817) have come together to cover the North Central region by forming one larger, more powerful local. On January 2, 2007, our new local received its charter. On March 1, 2007, the resources of all five locals were transferred to Local 521." I printed a copy of the above-referenced web page, a true and correct copy of which is attached hereto as Exhibit CC. 46. On or around April 16, 2007, I executed an unfair labor practice charge against
Local 715. The charge alleges that Local 715 violated Section 8(b)(3) of the NLRA by refusing to provide the Hospitals with the information they requested regarding the status of Local 715. I caused the charge to be filed with Region 32 of the NLRB. The charge was designated Case Number 32-CB-6273. A true and correct copy of the Charge is attached hereto as Exhibit DD. 47. On May 15, 2007, I sent a letter to Mr. Harland responding to his letter of April 9,
2007. I reiterated my request for information on the status of Local 715 and the reasons why the Hospitals believed that Local 715 was legally required to provide the information. A true and correct copy of the letter that I sent is attached hereto as Exhibit EE. 48. On June 14, 2007, I received a letter from a person named Bruce W. ("Rusty")
Smith (sometimes referred to herein as the "Trustee"). In the letter, Mr. Smith stated that 10
QUINTEL DECLARATION IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT/ADJUDICATION CASE NOS. 5:07-CV-05158-JF, 5:08-CV-00213-JF, 5:08-CV-00215-JF; 5:08-CV-00216-JF; 5:08-CV-01726-JF; 5:08-CV-01727-JF
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International President, Andrew Stern took control of all operations of Local 715 on June 8, 2007. He further stated that all officers of Local 715 had been removed and that he (Mr. Smith) had been appointed as "Trustee with full authority to act on behalf of Local 715." Mr. Smith indicated that all servicing agreements remained in effect and that Ms. Tavaglione, Ms. Olick, and Ms. Hereth would "continue to be the representative responsible for servicing your facility." Attached to Mr. Smith's letter was a copy of a June 8, 2007 letter from Mr. Stern announcing the appointment of Mr. Smith as trustee. I received the above-referenced letter by fax. I noted that the fax information line indicated that the fax originated from "SEIU 521." A true and correct copy of the letter I received is attached hereto as Exhibit FF. 49. Between January 31, 2007, when Mr. Rutledge informed me that Local 715 no
longer existed, and June 14, 2007, when I received Mr. Smith's letter, I did not receive any communications from, or otherwise have any discussions with, any person representing him or herself as an employee of Local 715. 50. Around June 18, 2007 I received a letter from Mr. Smith in the mail. The content
of the letter was substantially similar to the content of the June 14, 2007 letter. However, this letter was printed on Local 715 stationery. A true and correct copy of the letter I received is attached hereto as Exhibit GG. 51. In mid-June, 2007, I learned that Barbara J. Chisholm of the law firm of Altshuler
Berzon LLP (the "Altshuler Firm") was now representing Local 715 through its trustee, Mr. Smith. On or around June 18, 2007, I received a letter from Ms. Chisholm reiterating Local 715's refusal to provide the information originally requested in my letter of March 29, 2007. A true and correct copy of the letter is attached hereto as Exhibit HH. 52. On or around July 26, 2007, I received a letter from Mr. Smith requesting to add
Michelle ("Chelli") Guzman to "the list of authorized representatives of Local 715 pursuant to the servicing agreement with United Healthcare Workers West. A true and correct copy of the letter I received is attached hereto as Exhibit II. 53. On August 1, 2007, I sent a letter to Mr. Smith responding to his letters of June 14
and July 26, 2007. I informed Mr. Smith that the Hospitals had not received information 11
QUINTEL DECLARATION IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT/ADJUDICATION CASE NOS. 5:07-CV-05158-JF, 5:08-CV-00213-JF, 5:08-CV-00215-JF; 5:08-CV-00216-JF; 5:08-CV-01726-JF; 5:08-CV-01727-JF
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sufficient to assure them, contrary to known evidence to the contrary, that Local 715 continued to exist. I further informed him that his appointment as trustee did not change the Hospitals' rejection of the Local 715 / UHW Servicing Agreement. A true and correct copy of the letter I sent is attached hereto as Exhibit JJ. 54. On or around August 22, 2007, I received a letter from Vincent A. Harrington, Jr.,
an attorney with the Weinberg Firm, in which Mr. Harrington requested to bargain with the Hospitals over a Hospital substance abuse policy on behalf of Local 715. A true and correct copy of the letter that I received is attached hereto as Exhibit KK. 55. On November 5, 2007, I received a letter from Mr. Sokol dated November 1,
2007. Mr. Sokol objected on behalf of Local 715 to the Hospitals' refusal to remit dues and threatened to "report this to the proper authorities." A true and correct copy of the abovereferenced letter is attached hereto as Exhibit LL. 56. On or around December 14, 2007, I received a letter from Mr. Smith. In the
letter, Mr. Smith stated that, as trustee, he was confirming that "Local 715 authorizes the law firm of Weinberg, Roger & Rosenfeld to represent the Union all (sic) aspects of the arbitration process." The letter did not state, however, whether the Weinberg Firm was authorized to represent Local 715 directly, or whether its authorization was pursuant to the Servicing Agreement, which the Hospitals had rejected. A true and correct copy of the above-referenced letter is attached hereto as Exhibit MM. 57. Local 715. 58. In or around late November, 2007, I received a video recording of a November To date, I have never been informed that the Altshuler Firm no longer represents
26, 2007 meeting of the Palo Alto City Council from Adam Alberti, an employee of a company known as "Singer & Associates" ("Singer"), which has contracted with the Hospitals to gather and provide information to the Hospitals on various issues. When I reviewed the video recording, I observed that Hospital employee Chuck Fonseca, a union steward and former member of the Executive Board of Local 715, spoke on the record at the meeting. In the course of his statement to the Council, Mr. Fonseca said that the Hospitals' employees were represented 12
QUINTEL DECLARATION IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT/ADJUDICATION CASE NOS. 5:07-CV-05158-JF, 5:08-CV-00213-JF, 5:08-CV-00215-JF; 5:08-CV-00216-JF; 5:08-CV-01726-JF; 5:08-CV-01727-JF
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by SEIU-UHW. 59. After reviewing the video recording, I asked Mr. Alberti to create a transcript of
the City Council meeting. Mr. Alberti created the transcript and sent it to me. I reviewed the portions of the transcript reflecting Mr. Fonseca's statement to the Council, and the transcript accurately reflects the content of the video recording that I viewed. A true and correct copy of the above-referenced transcript is attached hereto as Exhibit NN. Mr. Fonseca's statement appears at pages 36-38 of the transcript. 60. The Hospitals have continued to receive correspondence relating to grievances
printed on UHW stationery. In some cases, the Hospitals have received letters on UHW stationery and later received identical letters on Local 715 stationery. Attached hereto as Exhibit OO are three (3) letters received by the Hospitals in early January, 2008 on UHW stationery and/or accompanied by UHW fax cover pages. 61. On December 27, 2007, I received a letter dated December 19, 2007 from Mr.
Smith in which Mr. Smith stated that he was appointing a person named Myriam Escamilla as "an Assistant to the Trustee of Local 715 with the authority to represent bargaining unit members at Stanford Hospital and Lucile Packard Children's Hospital." A true and correct copy of the above-referenced letter is attached hereto as Exhibit PP. Simien, Dues, Satuito, Acosta And Andrade Grievances 62. On or around March 9, 2007, the Hospitals received a grievance filed on behalf of
a former Bargaining Unit employee named James Satuito (herein the "Satuito Grievance"). The Satuito Grievance alleged that Mr. Satuito was terminated in violation of the CBA. A true and correct copy of the above-referenced grievance is attached hereto as Exhibit QQ. 63. The Hospitals denied the Satuito Grievance, and have refused to arbitrate it
insofar as Local 715 has ceased to exist and/or has invalidly attempted to transfer its representational rights to UHW. 64. On or around March 17, 2007, the Hospitals received a grievance filed on behalf
of a former Bargaining Unit employee named Victor Acosta (the "Acosta Grievance"). The Acosta Grievance alleged that Mr. Acosta's termination violated the Agreement CBA. A true 13
QUINTEL DECLARATION IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT/ADJUDICATION CASE NOS. 5:07-CV-05158-JF, 5:08-CV-00213-JF, 5:08-CV-00215-JF; 5:08-CV-00216-JF; 5:08-CV-01726-JF; 5:08-CV-01727-JF
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and correct copy of the above-referenced grievance is attached hereto as Exhibit RR. 65. The Hospitals denied the Acosta Grievance. On or around April 16, 2007, I
received a letter from Jesus Andrade demanding that the Acosta Grievance be moved to binding arbitration. A true and correct copy of the above-referenced letter is attached hereto as Exhibit SS. 66. On or around April 2, 2007 the Hospitals received a grievance filed on behalf of a
Bargaining Unit employee named John Simien (the "Simien Grievance"). The Simien Grievance alleged that Mr. Simien received a warning and was forced to change his shift in violation of the CBA. A true and correct copy of the above-referenced grievance is attached hereto as Exhibit TT. 67. The Hospitals denied the Simien Grievance, and have refused to arbitrate it
insofar as Local 715 has ceased to exist and/or has invalidly attempted to transfer its representational rights to UHW. 68. On or around May 22, 2007, the Hospitals received a grievance filed on behalf of
"all affected" employees in the Bargaining Unit. The grievance alleged that the Hospitals violated the CBA by failing to remit dues to Local 715 (herein the "Dues Grievance"). A true and correct copy of the grievance is attached hereto as Exhibit UU. 69. On May 30, 2007, I sent a letter to Chief Steward Jesus Andrade by fax and mail
informing him that the Hospitals did not intend to process the Dues Grievance. A true and correct copy of the above-referenced letter is attached hereto as Exhibit VV. 70. On or around November 6, 2007, the Hospitals received a grievance filed on
behalf of a former Bargaining Unit employee named Jesus Andrade (the "Andrade Grievance"). The Andrade Grievance alleged that Mr. Andrade was terminated in violation of the CBA. A true and correct copy of the above-referenced grievance and a cover letter to which the grievance was attached is attached hereto as Exhibit WW. 71. The Hospitals denied the Andrade Grievance, and have refused to arbitrate it
insofar as Local 715 has ceased to exist and/or has invalidly attempted to transfer its representational rights to UHW. 14
QUINTEL DECLARATION IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT/ADJUDICATION CASE NOS. 5:07-CV-05158-JF, 5:08-CV-00213-JF, 5:08-CV-00215-JF; 5:08-CV-00216-JF; 5:08-CV-01726-JF; 5:08-CV-01727-JF
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I declare under penalty of perjury under the laws of the State of California and the United States of America that the foregoing is true and correct. Executed on this ____ day of July 2008 at Palo Alto, California.
________________________________________ LAURIE J. QUINTEL
15
QUINTEL DECLARATION IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT/ADJUDICATION CASE NOS. 5:07-CV-05158-JF, 5:08-CV-00213-JF, 5:08-CV-00215-JF; 5:08-CV-00216-JF; 5:08-CV-01726-JF; 5:08-CV-01727-JF
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Filed
Free Declaration in Support - District Court of California - California
| File Size: | 5,320.2 kB |
| Pages: | 389 |
| Date: | September 9, 2008 |
| File Format: | |
| State: | California |
| Category: | District Court of California |
| Author: | unknown |
| Word Count: | 10,798 Words, 65,541 Characters |
| Page Size: | Letter (8 1/2" x 11") |
| URL |
https://www.findforms.com/pdf_files/cand/200698/54.pdf |
| Download Declaration in Support - District Court of California ( 5,320.2 kB) |
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