NOTICE:  This opinion is subject to formal revision before publication in the bound volumes of NLRB decisions.  Readers are requested to notify the Executive Secretary, National Labor Relations Board, Washington, D.C.  20570, of any typographical or other formal errors so that corrections can be included in the bound volumes.

Inter-Disciplinary Advantage, Inc. and International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW), AFL–CIO.  Case 7–CA–48706

March 15, 2007

DECISION AND ORDER

By Members Liebman, Kirsanow, and Walsh

On August 8, 2006, Administrative Law Judge George Alemàn issued the attached decision.  The Respondent filed exceptions and supporting argument, the General Counsel filed cross-exceptions and an answering brief opposing the Respondent’s exceptions, and the Respondent filed an answer to the General Counsel’s cross-exceptions and a reply to the answering brief.

The National Labor Relations Board has delegated its authority in this proceeding to a three-member panel.

The Board has considered the decision and the record in light of the exceptions1 and briefs and has decided to affirm the judge’s rulings, findings,2 and conclusions3 and to adopt his recommended Order.

ORDER

The National Labor Relations Board adopts the recommended Order of the administrative law judge and orders that the Respondent, Inter-Disciplinary Advantage, Inc., Midland, Michigan, its officers, agents, successors, and assigns, shall take the action set forth in the Order.4

Dated, Washington, D.C.   March 15, 2007

 

______________________________________

Wilma B. Liebman,                                   Member

 

______________________________________

Peter N. Kirsanow,                                   Member

 

______________________________________

Dennis P. Walsh,                                     Member

 

(seal)            National Labor Relations Board

APPENDIX

Notice To Employees

Posted by Order of the

National Labor Relations Board

An Agency of the United States Government

 

The National Labor Relations Board has found that we violated Federal labor law and has ordered us to post and obey this notice.

federal law gives you the right to

Form, join, or assist a union

Choose representatives to bargain with us on your behalf

Act together with other employees for your benefit and protection

Choose not to engage in any of these protected activities.

 

We will not maintain or enforce a confidentiality rule that restricts you from fully exercising the rights accorded to you under Section 7 of the National Labor Relations Act; we will not create the impression that your union activities are being kept under surveillance; we will not threaten you with discharge for engaging in union activities; we will not coercively interrogate you about your union activities; we will not prohibit you from talking about the union at the workplace while allowing other nonwork-related discussions; we will not unlawfully solicit and impliedly promise to remedy your grievances in order to discourage your support for a union; we will not coercively question you about discussions you may have had with agents of the National Labor Relations Board; and we will not ask you to provide us with copies of affidavits you may have given to the Board.

We will not discharge or otherwise discriminate against employees Kelly Lashbrook, Linda Foran, Marie Abrakian, or any of you for supporting International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW), AFL–CIO, or any other union.

We will not in any like or related manner interfere with, restrain, or coerce you in the exercise of the rights guaranteed you by Section 7 of the Act.

We will rescind and cease giving effect to the overbroad confidentiality statement.

We will, within 14 days from the date of this Order, offer Kelly Lashbrook, Linda Foran, and Marie Abrakian full reinstatement to their former jobs or, if those jobs no longer exist, to substantially equivalent positions, without prejudice to their seniority or any other rights or privileges previously enjoyed.

We will make Kelly Lashbrook, Linda Foran, and Marie Abrakian whole for any loss of earnings and other benefits resulting from their unlawful discharge, less any net interim earnings, plus interest.

We will, within 14 days from the date of this Order, remove from our files any reference to the unlawful discharges of Kelly Lashbrook, Linda Foran, and Marie Abrakian, and we will, within 3 days thereafter, notify each of them in writing that this has been done and that the discharges will not be used against them in any way.

 

Inter-Disciplinary Advantage, Inc.

 

Linda Rabin Hammell, Esq. and Jennifer Y. Brazeal, Esq., for the General Counsel.

Daniel A. Gwinn, Esq., for the Respondent.

Georgi-Ann Bargamian, Esq., for the Charging Party.

DECISION

Statement of the Case

George Alemán, Administrative Law Judge.  Pursuant to a charge filed on June 22, 2005, and amended on July 28, 2005,1 by the International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW), AFL–CIO (the Union), the Regional Director for Region 7 of the National Labor Relations Board (the Board), on August 12, issued a complaint alleging that Inter-Disciplinary Advantage, Inc. (the Respondent) had, in various manner, violated Section 8(a)(1) and (3) of the National Labor Relations Act (the Act).

Specifically, the complaint alleges that the Respondent violated Section 8(a)(1) by maintaining an overly broad confidentiality rule;2 prohibiting employees from engaging in union talk while allowing other nonwork-related discussions; threatening to discharge employees who supported or discussed the Union at the workplace; interrogating employees about their union activities or sympathies; creating the impression that it was keeping employee union activity under surveillance; by soliciting employee complaints and grievances and implicitly promising to remedy them in order dissuade them from supporting the Union; and questioning employees about discussions they had with Board agents regarding this case, and asking employees to provide it with copies of affidavits they may have given to the Board.3  The complaint also alleges that the Respondent violated Section 8(a)(3) and (1) by discharging employees Linda Foran, Kelly Lashbrook, Marie Abrakian, and Tammy Bibbee because of their union activities, and to discourage employees from engaging in such activities.  By answer dated August 16, the Respondent denied engaging in any unfair labor practices.

A hearing in this matter was held in Detroit, Michigan, on separate dates between October 31 and December 15, at which all parties were afforded a full and fair opportunity to be heard, to present oral and written evidence, to examine and cross-examine witnesses, and to argue orally on the record.  Based on the entire record in this proceeding, including my observation of the demeanor of the witnesses, and after considering the briefs filed by the General Counsel, the Respondent, and the Charging Party, I make the following

Findings of Fact

i.  jurisdiction

The Respondent, a corporate entity with its main office in Midland, Michigan, is in the business of providing licensed adult foster care services in the State of Michigan.  During the fiscal year ending September 30, 2004, a representative period, the Respondent had gross revenues in excess of $200,000, and during the same period, purchased and received at its Michigan facilities goods and materials valued in excess of $50,000 directly from points located outside the State of Michigan.  The Respondent admits, and I find, that it is an employer engaged in commerce within the meaning of Section 2(2), (6), and (7) of the Act, and that the Union is a labor organization within the meaning of Section 2(5) of the Act.

ii.  the relevant facts

A.  General Background

The Respondent operates four residential homes for adults with disabilities and/or mental illnesses, including the Morowske Home located in Shelby township, Michigan, the site of the alleged complaint violations.  The Respondent is managed and run by its executive director, Deborah Pettyplace.  Below Pettyplace in the managerial/supervisory chain of command is a program coordinator who has supervisory responsibility over several homes.  Each home is, in turn, managed and directly supervised by a home supervisor.  At all times relevant herein, Diane Haack served as the home supervisor for the Morowske Home, and answered to Diane Davis, the program coordinator for the Morowske Home and Lillian House, another of Respondent’s homes.  Alleged discriminatees Lashbrook, Foran, Abrakian, and Bibbee, all worked at the Morowske Home prior to discharge.  Employees Randi Schwark, Mariana Jenkins, Kelly Hibbs, and Tracy Gevedon were also employed at the Morowske Home at the time.  The Respondent also has a medical coordinator at the  Morowske home.  Foran was medical coordinator until April 1, at which time she was replaced by Lashbrook. (Tr. 61.)  The medical coordinator’s duties include recording medications prescribed by doctors to Morowske’s consumers into the Home’s medication records.

The Morowske Home houses approximately six consumers or residents who are cared for and looked after on a 24-hour basis by a direct care staff of 10 employees who work either a morning shift (6 a.m.–2 p.m.), an evening shift (2–10 p.m.), or a night shift (10 p.m.–6 a.m.)  Employees are expected to record the time they begin and end their particular shift on a payroll or log sheet prepared by the Morowske Home supervisor twice a month.4  They are also required to sign the timesheet.  Pettyplace and Davis both testified that under established Company policy, employees are required to sign the payroll sheet at the end of the pay period.  (Tr. 888; 1611.)  While the Company’s employee handbook does indeed state that employees “must sign the timesheet,” it makes no mention of when the signing was to occur, e.g., beginning or ending of the pay period.  Further, Haack testified that when she was first hired, she was instructed by the former Home manager, Stephanie Gore, to sign the timesheet at the beginning of the pay period, that she has always done it this way, and that, when she became Home manager, she and other employees adhered to this practice.  Haack’s testimony in this regard was corroborated by employees Lashbrook and Foran.  (Tr. 66; 87; 335; 401.)  Thus, while employees were obviously required under the employee handbook to sign the payroll timesheet, I am not convinced, particularly since the handbook is silent on the matter, that they were expected or required to do so at the end of the pay period, as claimed by Pettyplace and Davis.  As more fully discussed infra, neither Pettyplace nor Davis were particularly credible witnesses.  I find instead that, as testified to by Haack, Lashbrook, and Foran, employees were told and expected to sign their names on the payroll timesheets at the start, rather than the end, of the pay period, and that this has been the accepted practice at the Morowske Home.

The direct care employees’ functions and duties include bathing the Morowske Home residents, cooking for them, providing them with medication, occasionally scheduling medical appointments for residents and, when necessary, taking residents to medical appointments and other locations, including a facility known as the clubhouse or friendship house, in a Company-owned van.5  Employees utilizing the company van are required to record in a van log kept inside the vehicle their destination, the amount of gas in the vehicle at the time, the number of miles on the odometer before and after the trip, and his or her initials.

In March, Foran was the medical coordinator at the Morowske Home.  Haack testified that sometime in March, Pettyplace asked her to prepare a health care chronological for Dugal showing his doctors’ appointments for the month.  Pettyplace admits making such a request, explaining that she did so “just to look at them, to scan them to see what was on them, to see where the consumers had gone.” (Tr. 854.)  According to Pettyplace, the chronological form has been in use at the Morowske Home for as long as she could remember.  She contends Haack seemed to know what form she was referring to when she made the request.  Lashbrook, however, testified that she had not seen the health care chronological form before April, when she became the medical coordinator.6

Haack nevertheless complied with Pettyplace’s directive and instructed Foran, the Morowske Home medical coordinator at the time, to complete the health care chronological for Dugal.  Foran testified that in late March, as instructed by Haack, she filled out a health care chronological for Dugal showing doctors’ appointments that had taken place or were scheduled to occur from March through April.  (See GC Exh. 4.)  In completing the health care chronological, Foran obtained the information regarding scheduled doctors’ appointments from a large calendar that was generally used to record appointments and other matters.  Regarding General Counsel Exhibit 4, Foran testified that the entry therein showing Dugal scheduled for a physical examination with a Dr. Lovy was entered long before the date of the appointment, and that the appointment itself, like most other such appointments, are scheduled a month, sometimes two months, in advance.

In late February or early March, Abrakian, Lashbrook, and Foran began discussing among themselves the benefits of having, and the need for, a union to represent them.  In late March, Abrakian called several of the Union’s Regional offices to get information on how she and the others could organize themselves.  As a result of those phone calls, Abrakian agreed to meet on April 4, with a representative of the Union at the Union’s Local 155 office.  On March 28 and 29, Abrakian contacted all of her coworkers at the Morowske Home to advise them of the meeting, and, with the exception of Jenkins who did not return her call, received positive responses from all.  Abrakian testified that she also left a note in each employee’s mailbox at Morowske Home notifying them of the time and place of the union meeting.  The meeting was to be held on April 4, at the Union’s local hall situated some 22 miles round trip by car from the Morowske Home.  Lashbrook and Foran corroborated Abrakian’s account of having had a discussion in March about organizing themselves, and of being told by Abrakian of the April 4 union meeting.  Bibbee likewise admits receiving a call from Abrakian advising her of the April 4 union meeting.

In late March, Haack received from Davis a copy of the Morowske Home budget, something she had been requesting from Davis for some time.  Haack claims that she, and Lashbrook, who preceded her as Morowske Home supervisor, had been asking to see the budget because of concerns they had that things were not being taken care of the way they should have been.  (Tr. 634; see GC Exh. 5.)  Haack recalls Davis handing her the budget, along with several other documents, and stating, “I finally got the budget for you.”  Other than asking Haack to look over the budget and to tell her what she thought about it, Davis did not instruct Haack on how or where it should be retained.  As she was preparing to leave the Home for the day when she received the budget and other documents, and had consequently locked her office, Haack took the items given to her by Davis that were labeled “confidential” in red and slid them under her office door.  As to the budget, which was not marked confidential, Haack simply placed it on a counter situated between the kitchen and a sitting room, an area generally open to all other employees, as well as consumers and visitors, and where items such as a stapler, fax machine, stamp pads, etc., are kept.  The next day, she reviewed the budget with Lashbrook and made some notations on it.

Abrakian testified that, while working her shift, she came across the budget on the counter where Haack had left it.  She reviewed it and found it of some interest because of suspicions she had that funds were being misappropriated at the Morowske Home.  Abrakian believed that the budget was a public document because, in her view, the Respondent was a nonprofit organization.  Abrakian photocopied the budget and took the copy home with her, leaving the original on the counter.  Abrakian denied sharing or showing the budget with anyone else.  She did admit that when first hired, she signed a confidentiality statement.  She also recalls seeing a copy of the employee handbook containing Respondent’s policies but claims she never actually received a copy.  One policy in the handbook prohibits the removal by employees of property, equipment, or supplies belonging to the Respondent without express permission from the employer or supervisor.  Because of her belief that the Respondent was a nonprofit organization and that information pertaining to the Home was a matter of public record, Abrakian did not believe her taking the budget amounted to a violation of the above policy.

The April 4 union meeting was scheduled for 11 a.m.  Lashbrook, Foran, and Home Supervisor Haack reported for their morning workshift that day at 7 a.m.  Both Lashbrook and Foran asked and received permission from Haack to leave early that day as both planned on attending the 11 a.m. union meeting.  Lashbrook told Haack her reason for leaving early was to attend to some banking problems, while Foran did not cite any specific reason for wanting to do so.  The record reflects that Abrakian, on Saturday, April 2, left a note for Haack in the staff log stating that resident Daniel Dugal seemed ill that day and had complained of having an earache and that she or someone else would check on Dugal again the following day.  (R. Exh. 6.)7  Haack corroborated Lashbrook’s and Foran’s account that they requested and were granted permission to leave work early on April 4.  (Tr. 587–588.)

On arriving to work on Monday, April 4, and learning of Dugal’s earache complaint, Haack advised Lashbrook and Foran that, when Dugal woke up, they should question him to see if anything was wrong, and try to schedule him to be seen by his doctor. Lashbrook testified that because Dugal already had a doctor’s visit scheduled for April 7, for a physical exam, she called the doctor’s office between 8:30–9 a.m. on April 4, to see if Dugal’s April 7 appointment could be moved up to April 4, so that Dugal could be seen that day.8  The doctor’s receptionist, however, told Lashbrook that if she could get Dugal into the office between 10–10:30 a.m., she might be able to get Dugal seen by a different doctor, but that any such visit could not be combined with Dugal’s April 7 scheduled physical exam.  (Tr. 72.)  Around 8:30 a.m. that morning, Haack was told by Foran that Lashbrook had been unable to secure an appointment for Dugal with his physician that morning.  Foran recalls Lashbrook passing on this information to her around 8 a.m.  Lashbrook admitted conveying this information to Foran but not to Haack.

Both Lashbrook and Foran testified that between 9:30 and 10 a.m. that morning, they used the Company van to drive Dugal and three other residents to the clubhouse.9  They testified that they went directly to the clubhouse and nowhere else.  Lashbrook could not recall filling out the van log, but believes she may have done so on April 4.  She explained, without contradiction, that employees do not always record every stop they may make in the Company van.  By way of example, Lashbrook pointed out that employees may, at times, take residents to a K-Mart to cash their checks, or to get cigarettes and not record these stops in the van log.  She could not recall, however, any employee ever being disciplined for recording inaccuracies in the van log.

On arriving at the clubhouse, Lashbrook and Foran helped the residents off the van, and handed them their lunches and cigarettes.  The whole process, according to Lashbrook and Foran, took only a few minutes.  They then drove back to Morowske Home, arriving around 10:30 a.m.  When they returned to Morowske Home, Lashbrook gave Haack her set of Company keys.  Both Lashbrook and Foran testified, without contradiction, that, shortly thereafter, they got into Lashbrook’s car and drove to the union meeting.  Although she and Foran signed the log sheet when they first reported for work that morning, neither signed out for the day on April 4.  Haack testified that she, in fact, filled in Foran’s exit time for April 4, on April 15, the end of the payroll period because Foran, at the time, was out of town and could not be reached.  She explained that, when she did so, she did not pay attention to the fact that Foran had left early on April 4.

Lashbrook and Foran arrived at the union meeting some 15 minutes late, e.g., around 11:15 a.m.  Lashbrook observed that employees Abrakian, Bibbee, and Schwark, were already there, as were the union representatives.  Abrakian gave employee Schwark a ride to the union meeting in her car.  Abrakian admits taking the copy of the budget with her to the meeting along with some other documents, and claims that, when she arrived at the meeting, she placed the additional papers she carried with her on top of the budget and that the budget remained hidden from view during the entire meeting.

At the meeting, employees discussed the need for a union and the changes they would like to see regarding wages, benefits, etc.  Abrakian does recall telling one of the union representatives at the meeting, Tanya Mahn, that she had a copy of the Respondent’s budget with her and expressing her belief that funds were being misappropriated, but that Mahn said she did not want to see it.  (Tr. 466–471.)  At some point during the meeting, Lashbrook and most of the employees signed authorization cards for the Union.  (GC Exh. 6.)  She and other employees also picked up some union stickers which they placed on their vehicles following the meeting which ended around 1 p.m.

Lashbrook and Foran both testified, without contradiction, that, after the union meeting, they drove back to Morowske Home in Lashbrook’s car where Lashbrook’s mother was waiting to accompany Lashbrook to the bank.  Lashbrook and her mother drove to the bank in the latter’s car and, after taking care of the banking business, drove back to Morowske Home so Lashbrook could retrieve her car.

Following the meeting, Abrakian drove Schwark to work.  Abrakian worked the afternoon shift on April 4, and was the one who picked up and returned Dugal and the other residents from the clubhouse to the Morowske Home later that afternoon.  She testified that she and Romain were the ones who prepared lunch for the residents that day.  She further recalls that after returning to Morowske Home, she worked the afternoon shift with Romain and that, at one point as they were preparing meals, Romain asked her how the union meeting had gone, and that she answered it had gone fine.  Abrakian had not previously told Romain about the meeting.  (Tr. 475.)  Romain was not asked about, and consequently did not deny, Abrakian’s testimony in this regard.  Accordingly, I credit Abrakian’s above testimony.

Lashbrook testified that on arriving at the Morowske Home, she had a conversation with Romain initiated by the latter.  She claims that after asking her about her banking problems, Romain asked Lashbrook if she had attended the union meeting earlier that day.  Lashbrook did not recall having previously told Romain about the meeting.  When Lashbrook replied that she had, Romain stated that he did not think the Union was a good idea.  Lashbrook, who characterized her relationship with Romain as somewhat friendly, commented that she was all for the Union.  Romain then told Lashbrook that his father or uncle hated the union, that despite paying money the union was not doing anything for them, and that they wanted to get rid of the union but were having trouble doing so.  Lashbrook remarked that she had no problem with that.  Romain went on to say that he was telling her this so that she would understand that she was not going to get anything from the Union, and that she should not expect a raise simply because the Union was around.  Lashbrook replied that it can’t get any worse than what it already was, and that Romain was alone in his views because everyone wanted the Union.  Romain responded that employee Randi Schwark was not sure about it.  Romain then told Lashbrook that he was worried, and that she should be careful.  (Tr. 105.)

Romain recalled having a conversation with Lashbrook about the Union sometime in April.  He testified, however, that it occurred while they were both on break on the porch of the Morowske Home, and that it was Lashbrook, not he, who initiated the discussion.  According to Romain, Lashbrook began the conversation by asking him what he thought of the Union and how it worked, and whether he thought it would be good for the Company.  Romain purportedly told Lashbrook that he had discussed the Union with his father, that his father explained he had not had good experiences with the Union, and that there were pros and cons to having a union.  The conversation, he contends, ended at that point.  Romain denied knowing what precipitated this particular conversation with Lashbrook, and denies having any further conversations with her about the Union, including presumably the April 10 or 11 phone conversation Lashbrook claims she had with Romain about telling employees they could be fired for supporting the Union.  (Tr. 1404–1405.)

Prior to this April 4 conversation with Lashbrook, Romain, in late March or the beginning of April, had union-related discussions with other employees.  Foran, for example, testified that in late March, before employees began expressing any interest in a union, Romain approached her and remarked that he didn’t know why Foran wanted to have a union come in because it wouldn’t do the employees any good.  (Tr. 266.)  Foran admitted to having previously told Romain, about a year earlier, of her interest in having a union.  In response to Romain’s query, Foran stated that a union would be good for the employees working there, and would be good for employees even if she were no longer employed at the facility.10

Romain recalled having a conversation with Foran about the Union, but claims it occurred sometime in April, and was initiated by Foran as they drove together in the Morowske van.  He testified that Foran commented that she wanted to make a better place at Morowske for the next people that came to work there.  Romain claims he simply told Foran that that was a nice way to look at it, and that the conversation ended at that point.  (Tr. 1401.)  Romain’s version makes little sense.  From his limited version of what Foran purportedly said to him, it is difficult to see how Romain would have understood what Foran was referring to.  One might reasonably have expected Romain to ask Foran what she meant by her remark or seek some clarification as to its meaning, for while Romain testified that Foran was referring to a union, I fail to see how he could have gleaned as much from his description of what Foran said to him.  His alleged response to Foran, that what the latter had said was a “nice way to look at it,” makes even less sense.  I found Romain’s version of his conversation with Foran unconvincing and credit Foran over Romain.

Bibbee testified that, in late March, while she, Hibbs, Gevedon, and Romain were engaged in casual conversation either in the sitting room or the med room at Morowske Home, Romain remarked that if the Company found out they were for a union, they could be terminated.  (Tr. 411.)  Bibbee did not respond to Romain’s comment.  Hibbs similarly testified to being in the Morowske kitchen late one evening in March while Bibbee, Gevedon, and Romain were present, and commenting that it was not a good idea that employees didn’t get raises or any holiday pay or other perks.  Romain, she recalls, responded that the company would try to mess with, or fire them.  Hibbs also claims to have had another conversation with Romain about the Union a few days later on the back patio of the Morowske Home.  She testified that Romain initiated this conversation by asking how she felt about the Union, and that she replied that it was a good idea.  Romain then told her that he and his father had discussed the Union, and that his father expressed the view that the Union would not be able to help the employees because the Respondent was not a big organization.  (Tr. 527–528.)

Romain denied having any discussion with Bibbee about the Union, but claims to have heard Bibbee say that “everybody better be careful with their jobs so they don’t get fired due to the Union.”  Bibbee made this comment, he contends, sometime in April in the Morowske kitchen.  He claimed at the hearing that he did not respond to Bibbee’s comment and simply walked away.  However, in an affidavit he gave to the Board prior to the hearing, and shown to him during cross-examination, Romain admitted he responded to Bibbee’s comment by stating that his father had said the Union would not be a good idea.  Romain denied ever asking Hibbs how she felt about the Union, saying that she could be fired for joining a union, or stating that the Company would “mess with them” if it found out employees were interested in a union.  (Tr. 1403; 1416; 1431.)  I credit Bibbee and Hibbs over Romain.  From a demeanor standpoint, Romain came across as insincere and as less than candid in his description of events.  His long pauses before responding to questions, particularly during cross-examination, reflected a certain insecurity and unwillingness on his part to give the answer required to the questions posed to him.  In sum, I found Romain not to be particularly credible.

Following their conversations with Romain, Bibbee and Hibbs each separately called and asked Haack if they could be fired for supporting the Union.  Bibbee recalls Haack saying that she did not know but did not think so, while Hibbs recalls Haack assuring her she could not be fired.  According to Hibbs, Haack then posted a short note on the Company bulletin board stating that no one could be fired for supporting the Union.  (Tr. 529.)

Bibbee’s and Hibbs’ above accounts, that they called Haack for advice were corroborated by Haack.  Thus, Haack testified that both called her on separate occasions on April 8, to ask if they could be fired for joining a union, mentioning that Romain had conveyed this to them.  Haack recalls telling Bibbee that she did not know and that Bibbee should ask Lashbrook about it.  Haack, however, told Hibbs that she was not going to lose her job.  Haack contends that following her phone conversations with Bibbee and Hibbs, she called Romain and told him that he should not be telling people that they could be fired for joining a union, that what employees did was really “none of our business,” and that “we needed to just stay out of it and let them do what they needed to do.”  Romain, she further contends, denied making such comments to Bibbee or Hibbs.  (Tr. 116.)  Romain was not asked about, and consequently did not deny, being told by Haack to refrain from telling employees they could be fired for joining a union, and not to get involved in the employees’ organizational activities.

In response to Bibbee’s and Hibb’s concerns, Haack, on April 9, posted a notice on the Morowske Home bulletin board notifying employees that they could not be fired for trying to start a union.  (Tr. 613.)  She contends the posting remained for 1 or 2 days after which it was taken down.  She denied removing the posting or knowing who might have done so.

B.  The Alleged Employee Complaints

Davis testified that for weeks prior to April 14, employees had been expressing concerns and complaining to her about policies and procedures not being followed at the Morowske Home.  As more fully discussed below, an employee meeting to address these concerns was held on April 14.  According to Davis, these complaints came in the form of phone calls to her, and in written form, and included allegations that Haack was not at the Home during various times of the day, that she showed favoritism to certain staff members, that a staff member was babysitting for the supervisor and receiving favors in return, that Haack was fudging the timesheet and signing people in and out, that staff members were getting paid for not being in attendance at the Home, and that the Morowske van was being used for personal business.  Regarding the personal use of the van, Davis testified to receiving phone calls stating that the van was seen at a Wal-Mart, and that the Morowske consumers were all standing outside the Wal-Mart with no staff around, and that the van had been seen at another location when consumers were supposed to be at a doctor’s appointment.  (Tr. 1462–1463.)  Davis, however, could not recall who reported these two incidents to her, or when she purportedly received these reports.

Davis also testified to receiving a phone call from Schwark reporting that she had seen the Morowske van at the April 4 union meeting, and that Romain reported to her that Schwark told him she had seen the van at that meeting.  Davis had no recollection of when she actually received these reports from Schwark and Romain.  However, if these reports to Davis by Schwark and Romain were in fact made, presumably they would have occurred on or after the April 4 union meeting, and no later than April 8, since both Davis and Pettyplace claimed to have discussed this alleged incident at a meeting held between them on April 8.  Davis testified that on receipt of Schwark’s phone call, she notified Pettyplace about the van being seen at a union meeting.  Davis could not recall when she may have notified Pettyplace, and stated only that it would have occurred “promptly” after her conversation with Schwark.11  She contends that what concerned her about Schwark’s report was not that the van was at a union meeting, but rather “that there were no consumers in the van.”  (Tr. 1475; 1557.)  Davis claims that she asked Schwark to prepare a written statement setting forth her concerns and observations, and that Schwark did so.  The written statement allegedly prepared by Schwark was received into evidence as General Counsel Exhibit 33.12  Not only was Davis unable to say when she purportedly received General Counsel Exhibit 33, she was likewise unable to recall when she allegedly received written reports from Romain and Hibbs, stating, as she initially did regarding General Counsel Exhibit 33, that she did not recall if they were given to her before or after the April 14 employee meeting.  (Tr. 1461; 1554–1557; 1572; 1596.)

Davis testified that she began looking into these complaints and kept Pettyplace abreast of her investigation.  She claimed that, during her investigation, she learned from Haack, presumably sometime after April 4, that Dugal was taken to the doctor on April 4, by Lashbrook and Foran for an earache and stomach ailment.  Davis, however, had no recollection when she might have been told this by Haack, that is, whether Haack told her before or after the April 14 employee interviews.  It is not clear, therefore, if Haack’s information about this alleged April 4 doctor’s visit was what prompted Davis to look into the visit itself.  Obviously, if she obtained the information from Haack after the April 14 interviews, then that information from Haack could not have been what prompted Davis to look into the April 4 doctor’s visit.  Davis does contend that on April 6, she asked Lashbrook about the doctor’s visit, and that Lashbrook told her she and Foran had taken Dugal to the doctor on April 4, and that Dugal had been prescribed some Senokot for his bowel problem.  Lashbrook, however, denied saying any such thing to Davis.  The parties stipulated at the hearing that Dugal was, in fact, not taken to the doctor on April 4.

Davis nevertheless claims that based on the above information, she reviewed the documents that would normally be associated with a doctor’s visit, and became suspicious about the alleged April 4 doctor’s visit.  Thus, on reviewing the health care chronological where doctors’ visit were generally recorded, she found a notation for an April 4 doctor’s visit, but noticed that the date “April 4,” appeared to have been squeezed in between other dates as if it had been inserted after the fact to reflect that such a visit occurred.  (See GC Exh. 4.)  The manner in which the date entry was made, according to Davis, seemed out of place and not consistent with the other entries.  She claims she also looked for a physician’s order or script to see if Dugal had been prescribed some medication as a result of the April 4 visit, but found none.  She likewise found no entry on the “med” sheet for April 4, but did find that an entry for “Senokot” had been made pursuant to another visit by Dugal to the doctor on April 7.  Davis purportedly also reviewed the van log to see if a trip to the doctor had been made on April 4.  The van log did contain an entry showing a purported trip to the doctor that day.  (See GC Exh. 3.)  She claims, however, that when she reviewed the communications and staff logs (R. Exh. 26), which would normally show that a doctor’s visit had been scheduled for April 4, she found they contained no such entries.

According to Davis, if, as she purportedly was told by Lashbrook, Dugal received the medication Senokot during the alleged April 4 visit, then an entry for the Senokot medication should have been recorded in the medical log, and there should have been a doctor’s script showing that Dugal was prescribed Senokot during the April 4 visit.  She claims that following her discussion with Lashbrook, she searched the medicine cabinet for the Senokot and, on not finding any, discussed it with Haack and recommended that Lashbrook be written up for not following proper procedure.  Lashbrook was indeed issued a write-up by Haack on April 7, which Lashbrook signed on April 8, for failing to record the Senokot medication in the medication book which, according to the write-up, Dugal allegedly received on April 4.  (See R. Exh. 30.)13

As to the write-up she received from Haack on Davis’ instructions, Lashbrook testified that she was not at work on April 7, but did sign it the following day, April 8, because, as medical coordinator, she was the one responsible for ensuring that such entries are made.  She claimed that Haack was simply following Davis’ directive to issue her a write-up and did not know why she was asked to do so.  She further contends that on learning that she (Lashbrook) had not worked on April 7, Haack unsuccessfully sought to contact Davis for explanation.  Lashbrook contends that she did not pursue the matter because the write-up was never actually placed in her personnel file.  (Tr. 245; 248.)

Davis contends that as part of her investigation into the April 4 doctor’s visit, she called the doctor’s office and was told by the receptionist that the doctor was not in on that date and that no such visit occurred.  Davis had no recollection of when she made those calls to the doctor’s office.14  She further claims to have gone to the friendship house and spoken with the director who reviewed the sign-in sheet and confirmed that Dugal had arrived and signed in at the facility at 10 a.m. on April 4, the time when Dugal purportedly was at the doctor’s office.  Davis purportedly also received a copy of the friendship house sign-in sheet.  (See R. Exh. 10.)  Davis, however, could not recall when she had this conversation with the director at friendship house, explaining only that it occurred before Lashbrook and Foran were fired on April 25, nor did she recall when she first saw Respondent Exhibit 10.  (Tr. 1560.)  Davis contends that on April 8, she met with Pettyplace to discuss her investigation, and that, following that meeting, she continued her investigation by double-checking the documents she had earlier reviewed, calling the doctor’s office one more time to confirm that no visit occurred on April 4, and by asking employees if they knew whether or not such a visit had taken place.  She recalls asking Schwark what she knew about the visit but Schwark purportedly had no information to give her.  Based on her review of the above-described documents and discussions with the doctor’s office, Davis concluded that there had been no doctor’s visit on April 4.

C.  The Events of April 8

On the morning of April 8, Davis met with Pettyplace at the latter’s office to discuss the progress of Davis’ investigation into employee complaints.  Davis claims that at this meeting, she provided Pettyplace with the documents she obtained during her investigation, including the written statements she had obtained from employees.  Davis recalls that at one point during the meeting, Pettyplace phoned Haack to discuss several matters, including the amount of overtime being worked at Morowske Home.  Davis claims she was able to hear what Haack was saying to Pettyplace during that phone conversation because Pettyplace placed the call on speakerphone.  She recalls Pettyplace asking Haack to fax her copies of various documents, including the health care chronologicals, the van logs, and consultation referral forms so that she could determine if the overtime was justified.  At the hearing, Davis identified Respondent Exhibit 31 as the set of documents Haack faxed to Pettyplace that day.  According to Davis, at one point during their phone conversation, Pettyplace asked Haack if Dugal was seen by a doctor on April 4, and Haack answered that Dugal “must have went [sic] to the doctor,” that Lashbrook and Foran took him to the appointment, and that she didn’t do so because she was busy at a meeting.  (Tr. 1481.)  After some discussion with Haack about the doctor’s appointment and being told by Haack that she knew little of what had gone, Pettyplace, according to Davis, commented that Haack did not even know where the van was on that day.  (Tr. 1481; 1486.)  Davis testified that after she and Pettyplace reviewed the faxed documents they had gotten from Haack, they agreed to hold a meeting with employees on April 14, to fully look into the employee complaints.  Pettyplace, according to Davis, then called Prevatt “and gave her some information” as to the employee meeting.  Davis subsequently instructed Haack by phone to notify the Morowske staff of the meeting.

Pettyplace provided the following account of her April 8, meeting with Davis.  Davis came to see her that day to discuss the employee complaints, and to provide her with various documents which Davis purportedly obtained in the course of her investigation into the employee complaints.  Davis also told Pettyplace of the report she had received about the Company van having been seen at a union meeting on April 4, and about Abrakian having had a copy of the budget with her at that meeting.  Pettyplace could not recall when she first learned of the van being spotted at the union meeting, claiming initially that Davis told her during their April 8 meeting, but stating, on cross-examination, that she was not sure when she first learned of it.  Although she believes Davis identified the individual who had given her the report about the van, Pettyplace was unable to recall or name the individual.  (Tr. 995.)  Pettyplace contends she instructed Davis to ask Schwark to provide a written statement about seeing the van at a union meeting, and that Schwark in fact did so in the form of General Counsel Exhibit 33.

Pettyplace’s testimony on when she first saw General Counsel Exhibit 33 was confusing and seemingly contradictory.  Thus, on direct examination, Pettyplace identified General Counsel Exhibit 33 as one of the documents she and Davis reviewed and discussed in deciding whether or not to hold a meeting among Morowske Home employees.  (Tr. 846.)  Both Davis and Pettyplace agree that the decision to conduct an employee meeting on April 14, was made during their April 8 meeting.  Consequently, if Pettyplace is to be believed, then she and Davis first saw and discussed General Counsel Exhibit 33 on April 8.  General Counsel Exhibit 33, however, is dated April 11.  Although Schwark was not called to authenticate the document as her own or to confirm when it was prepared, a reasonable inference is that it was prepared on the date shown therein, e.g., April 11, 3 days after Pettyplace implicitly claimed she and Davis had reviewed and discussed it.  However, on cross-examination, Pettyplace, apparently recognizing the inconsistency between her testimony that Davis showed her General Counsel Exhibit 33 on April 8, and the April 11 date on General Counsel Exhibit 33, altered her testimony and admitted that she, in fact, did not see General Counsel Exhibit 33 until April 15, when she returned from a 3-day trip to Arizona.  She nevertheless testified that while in Arizona, she had Davis read the contents of General Counsel Exhibit 33 to her over the phone.15  Davis, however, made no mention in her testimony of ever having read General Counsel Exhibit 33 to Pettyplace, and, in fact, had no recollection of reading or showing General Counsel Exhibit 33 to any management official, which presumably includes Pettyplace.  Pettyplace’s testimony regarding General Counsel Exhibit 33 struck me as fully contrived and not particularly credible.

As to her phone conversation with Haack, Pettyplace gave the following account.  She testified that she called Haack because Davis had reported to her that the Morowske van was seen offsite on April 4, at a union meeting.  Pettyplace claims that when she asked Haack “if she knew where her van was on April 4,” Haack replied that “the staff had taken the consumer, Daniel Dugal, to the doctor that day, that morning, then they took him to the clubhouse.”  Pettyplace claims that she probed Haack further about her latter response by asking Haack if she was certain the van had only gone to the doctor and the clubhouse that day, reiterating that the van had been spotted at a union meeting.  Haack, she contends, became angry at that point and told Pettyplace that she cannot be expected to know where the van is every minute of the day.  Pettyplace responded that as the person in charge at the Morowske Home, she was responsible for the van, and again asked Haack if she knew anything about the van being used to take staff to a union meeting.  Haack answered no.  Although unclear from Pettyplace’s account, at some point either before or during this exchange, Pettyplace asked Haack to fax her the Morowske van log and the health care chronological for all the consumers, and any documents confirming Dugal’s visit to the doctor on April 4.  Pettyplace contends that shortly thereafter, she received a fax from Haack containing all the documents which make up Respondent Exhibit 31.16  (Tr. 848; 851; 999.)  As to the consultation referral form found on the last page of Respondent Exhibit 31, Pettyplace testified that she received it as is from Haack, e.g., with both the top and bottom halves of the form filled in.  According to Pettyplace, this was the only phone conversation she had with Haack in which the Union was discussed.

Haack provided a much different version of her April 8, phone conversation with Pettyplace.  Thus, she testified that Pettyplace called her that day to tell her that the van had been spotted at a union meeting on Van Dyke and Thirteen Mile Road at 11 a.m. on April 4, and then instructed her to let the “staff know that, if they were participating in the union involving the company time at all, they would be terminated.”  (Tr. 614.)  Haack recalled asking Pettyplace if she wanted her instructions written down on the communication log for employees to read, but that Pettyplace answered, “No.”  Pettyplace, Haack contends, went on to say that “the union could not do anything for the staff at Morowske, they would not get raises    . . . they would not get benefits, and that politicians up north were trying to stop the direct care workers from unionizing,” and further commented that employees at Central State, another of Pettyplace’s companies, were trying to get rid of the Union.  Haack responded that this was simply Pettyplace’s opinion.  (Tr. 615.)  At one point during their conversation, Pettyplace asked Haack to fax certain documents over to her.  With the exception of the last document attached to Respondent Exhibit 31, a “Consultation Referral” form, Haack identified the other documents in that exhibit as the ones she faxed to Pettyplace on April 8.  However, as to the consultation referral form attached to Respondent Exhibit 31, Haack insisted that the one she faxed to Pettyplace that day had only the top half filled in, but that the bottom half of the form which the attending physician fills in, was blank except for the initials “NS” written on it.17

The General Counsel at the hearing produced the original consultation referral form, received into evidence as General Counsel Exhibit 38, which Haack testified as being identical to the one she faxed, along with the other documents in Respondent Exhibit 31, to Pettyplace on April 8.18  When shown General Counsel Exhibit 38, Pettyplace expressed “shock” and “surprise” on learning that another (original) version of the consultation referral form existed, and wondered aloud where General Counsel Exhibit 38 had come from.  (Tr. 859.)  Although she had no explanation for this discrepancy between what she claimed she received from Haack, and what Haack claims she faxed to her on April 8, Pettyplace nevertheless gratuitously speculated that Haack must have mistakenly run two documents through the fax machine simultaneously, causing the filled-in bottom half of the consultation referral form to be inadvertently transmitted along a similar one containing a blank bottom half.  (Tr. 863.)  Pettyplace’s willingness to engage in such speculation, and to, at times, ramble on and volunteer information not asked of her, served only to further undermine her credibility.  (See, e.g., Tr. 870–871; 899; 910; 912.)

Haack testified that this April 8 phone call from Pettyplace was one of several she received from Pettyplace that same week.  She recalled that during one of these other calls from Pettyplace, Lashbrook was with her in her office.  Pettyplace, she contends, told her during this conversation that she wanted Foran removed from the medical coordinator’s position, that the employees’ work hours should be reduced to 32 hours per week, and that there were to be only two staff persons working a shift, with Haack being one of the two.  Haack admits that Pettyplace upset her during that conversation, and that, following the phone call, Lashbrook asked her what was wrong.  Haack told Lashbrook that this was the third time in a week that Pettyplace had called her and that she seemed angry every time she called.  Lashbrook then explained that Pettyplace was angry because employees were trying to organize a union at Morowske Home.  (Tr. 609.)

Lashbrook corroborated Haack’s testimony regarding the phone conversation the latter had with Pettyplace during which Lashbrook was present.  According to Lashbrook, based on the comments and responses Haack gave to Pettyplace during that phone conversation, she surmised that the Union was being discussed.  Lashbrook, for example, recalled hearing Haack tell Pettyplace that she knew nothing about “a meeting,” and that “they didn’t take the van, it was here.”  There was also some discussion between Haack and Pettyplace about overtime during that conversation.  At one point, Lashbrook heard Haack refuse to do something Pettyplace asked her to do, offering instead to write down whatever Pettyplace was asking her to do in the staff log.  Following the phone call, Haack explained to her that Pettyplace wanted her to tell employees that “they could be terminated if they practiced union business,” that she had refused to do so and had, instead, offered to write the directive down on the staff log for employees to see, and that Pettyplace declined the suggestion.  Following the conversation, Lashbrook, noticing that Haack seemed upset, revealed to Haack that Pettyplace may have been angry because of the union meeting that was held on April 4.  She cautioned Haack that, based on her own experiences, the Respondent was now going to start harassing Haack, and told Haack to watch out for herself.  According to Lashbrook, Haack mentioned to her on at least two other occasions that Pettyplace had called her at other times to discuss the Union.

Following the April 8 Pettyplace-Davis meeting, Prevatt was asked by Pettyplace to assist Davis in the investigation.  According to Prevatt, Pettyplace wanted her and Davis “to look into concerns that some employees had about other employees at Morowske House and to get to the truth regarding those concerns.”  (Tr. 1169.)  Pettyplace testified that she asked Davis to conduct the investigation because she was Respondent’s program coordinator, and that Prevatt was asked to participate as a witness, explaining that she generally has two management persons taking part in the investigation, and that, more often than not, one of the investigators will do the talking while the other takes notes.  She contends that she had faith in Prevatt’s ability to conduct a fair and honest investigation because Prevatt had conducted similar investigations in the past, was very thorough, and knew the legal boundaries.  (Tr. 958.)

 Later that day, the Union faxed to Pettyplace a letter notifying her that a majority of the Respondent’s direct care workers had selected it to represent them for collective-bargaining purposes, and asking for recognition.  (See GC Exh. 22.)   On cross-examination, Pettyplace claimed to have no recollection of having received or even seen the Union’s letter.  A fax transmission entry on the top of General Counsel Exhibit 22 reflects that it was faxed to Pettyplace at 2:51 p.m. on April 8.  Pettyplace did recall that also on April 8, she phoned her attorney, Greg Bator, to notify him that the Company van had been seen at a union meeting, but did not recall ever discussing the Union’s recognition demand letter with him.  Pettyplace’s claimed inability to recall receiving or seeing the Union’s April 8 recognition demand letter or having discussed such a demand with her attorney rings hollow.  I find it somewhat incredulous that Pettyplace, who has received training in labor relations matters, and who acknowledged the importance of the Union’s demand for recognition in the conduct of her operations, would recall calling her attorney to inform him about a rumor that the van had been seen at a union meeting, but not recall informing him of the Union’s claimed majority status or to seek advice on what to do regarding the Union’s demand for recognition.

Following the April 8 meeting, Prevatt and Davis purportedly met to arrange when and how the employee meeting was to be conducted.  Prevatt claims she reviewed Dugal’s health care chronological and the van log that Davis provided to her before the April 14 meeting.  She further recalls Pettyplace and Davis telling her sometime before the April 14 employee meeting that the van had been seen at a union meeting, and learning that the Company budget being removed by Abrakian from the Morowske Home.  Based on her discussions with Davis, Prevatt prepared a list of the concerns that had to be addressed, as well as a different set of questions that were to be asked of employees and supervisors during the interviews.

D.  The April 14, Employee Meeting

1.  The pre-interview conduct

The record reflects that Davis informed Haack that a mandatory employee meeting was to be held on April 14, and instructed her to notify employees of the meeting.  Haack apparently did so within days of the meeting.  As required, on April 14, employees gathered at the Morowske Home for the mandatory meeting to be conducted by Prevatt and Davis.  As the Morowske Home was normally staffed by 2–3 direct care workers per shift, some of the employees who attended the mandatory meeting were not scheduled to work during the time the interviews were to be conducted and were there solely for the meeting.  According to Davis, on arriving at Morowske Home on April 14, she and Prevatt told employees they were there to investigate certain allegations, and that Prevatt told employees they were to sit and watch a video on blood-born pathogens and engage in no “sidebar” conversations with each other as they waited to be interviewed separately.  Davis recalls Lashbrook saying aloud to employees that they did not have to tell Davis or Prevatt anything about the union, and Prevatt replying that they were not there to talk about the Union.  (1525.)

Prevatt testified that on arriving at Morowske Home for the employee meeting, Davis introduced her to the waiting employees, told them about the video they were expected to watch as each was being interviewed, and that they were not to engage in any discussion among themselves about the investigation.  She contends that she instructed Haack and Romain to watch the group to ensure that no such discussions about the investigation took place.  (Tr. 1187.)  Lashbrook, she recalls, then stood up and told employees they did not have to answer any questions about the Union, and that she (Prevatt) then told employees that there was to be no “sidebar” conversations.  Prevatt admits she did not explain to employees what she meant by “sidebar” conversations.  Asked if employees were prohibited from engaging in any other type of conversation unrelated to the investigation, Prevatt stated they were not, and that she only wanted them to refrain from discussing or speculating about the investigation.  Thus, she claimed that employees were free to discuss other matters, including the video, family matter, etc.  (Tr. 1188.)  Her testimony in this regard, however, squarely conflicts with a statement made by her in a sworn pre-hearing affidavit given to the Board, wherein she recalled telling employees that “there should be no sidebar conversations or nonwork-related conversations while I was conducting the investigation.”  (Tr. 1357.)

Haack testified that at the April 14 employee meeting, Davis appeared with Prevatt and that Romain and an assistant manager from Lillian House, Eva Hemphill, were also present for management.  Davis introduced Prevatt to the employee group and then had the employees identify themselves.  Haack recalls that either Davis or Prevatt then told employees “there was going to be an investigation and we were not to talk to anybody about the investigation and they would be taking us into my office one-by-one and interviewing us, and we would watch a blood borne pathogen tape while they were doing that.”  She further recalled either Davis or Prevatt instructing employees that “they were not to talk about anything.  We were on company time.  We were not to talk to each other, and that Eva Hemphill would be watching over us to make sure we didn’t talk to each other.”  Prevatt, she contends also told employees that they were not allowed to discuss what transpired during their interviews with anyone.  At one point, Lashbrook, she contends, told the group that they did not have to discuss anything about the Union with Prevatt and Davis, and that Prevatt responded by telling employees that “there would be no talk about the Union and if there was any talk about the Union, you’d be terminated.  She further claims that she and Romain were instructed by Prevatt “not to let anyone talk to each other.”  (Tr. 618–620.)

Romain recalls being present for the April 14 meeting, and Prevatt introducing herself and instructing employees they were to sit and watch a video on blood-borne pathogens as they waited to be interviewed.  At one point, Lashbrook, he contends, told employees that they did not have to say anything about the Union, to which Prevatt responded that there was to be no “closed-bar” conversations between employees.  (Tr. 1409.)

In addition to Haack and Romain, several other employees testified as to what Davis and/or Prevatt told the employee group just prior to the individual interviews.  Lashbrook recalled Davis saying that she was conducting an investigation, and that employees were all going to be called into the room individually but did not explain what the investigation was about.  Davis, she contends, further told them they were not allowed to discuss the subject matter of the investigation with each other or anyone else outside the Home, nor were they permitted to discuss anything with each other while we were sitting out in the living room waiting or we could be terminated.  Lashbrook claims that when employees were asked if they had any questions, she stood up and told employees they did not have to answer any questions about the Union.  In response, Prevatt, she contends, told employees that “there will be no more talking about a union or union business on company time in this Home or you will be terminated.”  (Tr. 119–120.)

Foran’s recollection is that at the start of the meeting just before the interviews, Prevatt told employees that “this was an investigation, and we were going to be taken into Diane Haack’s office one-by-one, and we were not to speak to each other or we would be terminated.”  Prevatt also told employees that they “were not to speak to each other” as they watched a video on blood pathogens, and that, after being interviewed, they were to leave immediately, unless we were working.  Foran further recalled Lashbrook telling employees that they did not have to answer any questions about the Union, and Prevatt responding that “there’ll be no more union talk on company time, or we could get terminated.”  (Tr. 305–306.)

Abrakian testified that Prevatt told employees they were “not to discuss the contents of the investigation with each other or anyone else or we would be terminated.”  On cross-examination, Abrakian noted that Prevatt’s prohibition on speaking applied to all subject matters, not just the investigation itself.  She also recalled Lashbrook telling employees they did not have to answer any questions about the Union, and Prevatt responding that the employees “were on IDA company time and from that point on, there was to be no discussion of union or union activity or we would be terminated.”  (Tr. 479; 502.)

Hibbs recalled Davis telling employees gathered for the April 14 meeting that they were to watch a video while other employees were being interviewed, “and that there was to be no side talking while this was going on or we could be terminated.”  Lashbrook then commented that employees did not have to answer any questions about the Union, to which, she contends, Prevatt responded that this “was to be the last statement about the union.  There was to be no more discussion about the union or we could be terminated.”  (Tr. 531.)

Bibbee testified that Davis first addressed the group, telling them each employee was to be questioned individually, and that “they were not to discuss with each other what was talked about in our meeting.”  She recalled Lashbrook, at one point, telling employees that “we did not have to discuss the meeting with them,” and Prevatt responding that “union talk would not be allowed on IDA’s time.”  (Tr. 421–422.)

I am convinced, based on a composite of the employees’ testimony, that Prevatt told employees just prior to the interviews that they were not to discuss any nonwork-related matters among themselves as they waited to be interviewed, and, in response to Lashbrook’s comment that employees did not have to answer any questions about the Union, further told employees that they could be terminated if they engaged in any talk about the Union.  Prevatt’s claim that she simply told employees only that they were not to engage in any “sidebar” conversations is not credible, as it is contradicted by her own pretrial affidavit wherein she admits telling employees that they were prohibited from engaging in “sidebar” as well as other nonwork-related conversations.  I also reject as not credible, and as inconsistent with the mutually corroborative testimony of several employee witnesses, that Prevatt did not threaten employees with discharge if they discussed the Union among themselves.

2.  The individual employee interviews

After instructing employees, Prevatt and Davis summoned each employee into Haack’s office to be interviewed.19  Haack remained outside with the other employees while the interviews were conducted.  Davis apparently took charge of calling in each employ