1 1 2 EMRE - ILEU 3 4 Collective Bargaining Agreement Negotiations 5 Thursday, May 13, 2021 Commencing at 9:05 a.m. 6 7 HELD REMOTELY VIA ZOOM 8 --- Day 56 --- 9 P R E S E N T: 10 EXXONMOBIL RESEARCH AND ENGINEERING COMPANY: 11 JEFFELEE McCLAIN, CLINTON SITE HR MANAGER 12 JOSH BRYANT, CLINTON SITE LABOR ADVISOR YUK LOUIE, R&D OPERATIONS MANAGER 13 INDEPENDENT LABORATORY EMPLOYEES' UNION: 14 STEVEN RAGOMO, PRESIDENT 15 THOMAS FREDRIKSEN, VICE PRESIDENT ETHAN SEBASCO, SECRETARY 16 DAVID LEBRON, ACT DELEGATE MICHAEL MOLINA, PO&T DELEGATE 17 PAUL MADIARA, DELEGATE MICHAEL STRASSER, CSR STEWARD 18 19 20 21 22 23 24 25 Rita Gardner ~ Court Reporter ~ (908) 319-1195 2 1 MR. FREDRIKSEN: Does the Company have 2 any information from any of the follow-ups that we 3 had last time? I know we had a couple. 4 MS. McCLAIN: So I know Josh -- we 5 followed up. You had asked about the Paulsboro 6 contract. 7 MR. FREDRIKSEN: Yes, IOW. 8 MR. BRYANT: Yes, I have that. I am 9 just going to send it to you and Steve, Tom, because 10 it is quite large. And then if you want to send it 11 further, that is fine. 12 MR. FREDRIKSEN: I have to check my 13 notes and see if there are any other follow-ups, but 14 if you don't have any other follow-ups, we are going 15 to get right into it. 16 MS. McCLAIN: Sure. 17 MR. FREDRIKSEN: Can you please refer 18 to the Union's last counteroffer dated May 6 that we 19 gave you at the last session? 20 MS. McCLAIN: Yes. Taking a look at it 21 now. 22 MR. FREDRIKSEN: Starting from the top, 23 we have our -- we have been proposing changes to the 24 Auto Mechanic to be reflective of what the Company 25 has proposed in the past, which is to have parity Rita Gardner ~ Court Reporter ~ (908) 319-1195 3 1 with Research Tech and Sr. Research Tech, rather of 2 all three levels, including Laboratory Technician. 3 Can you help me understand? So the 4 Company has said that they want the flexibility to 5 be able to have more rungs available to hire at, but 6 you have also said that it is not your intention to 7 hire only at that lowest rung. And the Company uses 8 the word "flexibility," but I just want you to know 9 moving forward that flexibility, the way that the 10 Company uses flexibility, you use it so often and in 11 so many different ways that I have what is called 12 somatic caseation when I hear that word and it 13 doesn't even make any sense to me anymore. 14 Can you please explain to me what 15 exactly it is that you mean when you say you want to 16 have that "flexibility"? Can you describe what that 17 is going to look like in practice? What is the 18 Company looking for Auto Mechanic? What kind of 19 expertise do they want on-site? Do you want to have 20 people come in at that lowest level? Do you not 21 really want to have that thing, but you don't want 22 to give it up? Like what is it going to look like 23 moving forward? Help us understand. 24 MS. McCLAIN: I think if we -- we 25 provided the job descriptions for all three levels Rita Gardner ~ Court Reporter ~ (908) 319-1195 4 1 and what we are looking for is -- and it is our 2 understanding that there are folks who, you know are 3 out there in the market when -- if we are looking to 4 hire, they may have the qualifications that meet 5 Advance Tech. If they meet those qualifications, 6 they get hired in at Advanced Tech. If they meet 7 the qualifications for the Tech, then, you know, 8 they will get hired in there. 9 So it really is based on when we are 10 looking to fill a role, what the candidates, you 11 know, which candidates come and who is the best fit. 12 Right, Yuk? 13 I mean, we have done this over the 14 course of hiring for Research Tech as well. You 15 know, not all Research Techs start at the lowest 16 levels, right. So we really base it on who is the 17 best fit for the job, the best qualifications that 18 we can find for what is needed at the time. So when 19 we say "flexibility," we want the flexibility to 20 adjust to that, to those, you know, which candidates 21 come who might be the best for the job that we need 22 filled at the time. And so having all three levels, 23 we believe is, you know, is prudent to do that. 24 MR. FREDRIKSEN: Now the problem is -- 25 well, Yuk, if you want to say something, I don't Rita Gardner ~ Court Reporter ~ (908) 319-1195 5 1 want to cut you off. 2 MS. LOUIE: I agree with everything 3 Jeffe says, and we do the same thing for Research 4 Techs. So, you know, we don't always hire 5 Technicians at the lowest ranks, but we have had it 6 and it was helpful and give us the flexibility to 7 bring in a Research Tech at the Technician level and 8 not the Research Tech level. 9 MR. FREDRIKSEN: I understand that. 10 And like you said, part of it probably has to do 11 with the job market, how competitive it is and what 12 is available at the time. 13 Now, one of the number one problems I 14 have is, the requirements are considerably higher, I 15 would say for the Auto Mechanic lowest level as 16 compared to the Technician lowest level. So the 17 minimum requirements for the Technician at the 18 lowest level is two years' experience or associate's 19 degree. For Auto Mechanics, the minimum 20 requirements that you have set up are three years' 21 experience. And an Automotive Diesel Mechanic 22 repairing an overall hydraulic pumps. So three 23 years' experience, formal automotive, and/or medium 24 heavy duty truck ASE certified training course or 25 equivalent certification. Rita Gardner ~ Court Reporter ~ (908) 319-1195 6 1 Can you tell me a little bit about 2 that? What is that? How long does it take to get 3 that, for example? 4 MS. McCLAIN: I have to go back and 5 take a look and talk with our, you know, subject 6 matter experts who looked at it and made the 7 determinations as to, you know, what experience 8 level is needed. Again, the folks that were working 9 in this area we referred to, I think we had some 10 conversations about that before. But you know, if 11 you want the specifics of what this, you know, 12 course entails, I would have to, you know, follow-up 13 with the SMEs who made that determination. 14 MR. FREDRIKSEN: That would be helpful. 15 Ultimately, from the Union's perspective, the 16 Company is proposing parity in terms of its pay 17 scales, but they are proposing a dissimilar amount 18 of requirements. And what it seems to be is, it 19 seems to be it is going to be more limiting -- it is 20 going to be more limiting for the Company in terms 21 of being able to hire at the Advanced Automotive 22 Technician, which is what you are saying is going to 23 be the Research Technician equivalent for Auto 24 Mechanic. Because it just seems like all three of 25 these positions have higher requirements than the Rita Gardner ~ Court Reporter ~ (908) 319-1195 7 1 Technician and Research Technician and Sr. Research 2 Technician. 3 Like for example, the Advanced 4 Automotive Technician requires five years' 5 experience. It requires the licensure. So I mean, 6 if I am wrong, and that this isn't actually an 7 elevated requirement compared to the Technician and 8 Research Technician, it would be helpful for the 9 Union to understand the Company's position and why 10 it is making it what it is. So if you could get 11 back to us from your subject matter expert or if you 12 want to talk about it now, Yuk, by all means. 13 MS. LOUIE: Yeah, I think as Jeffe 14 said, we did talk through it and we have subject 15 matter experts develop these requirements and they 16 know the market. They go to ASTM. They go to ASME. 17 They talk to the people. They know what are the 18 requirements. So I would defer to the SMEs. And 19 right now I don't believe that we are going to have 20 any difficulty in bringing on people with those job 21 qualifications. 22 MR. FREDRIKSEN: Well, it is not 23 difficulty, Yuk, so don't take my words the wrong 24 way. I would like not to see the Company end up 25 hiring like only Automotive Technicians moving Rita Gardner ~ Court Reporter ~ (908) 319-1195 8 1 forward. My understanding is that the Company's 2 intent is not to do that. You would like to have it 3 treated similar to the Research Technicians where 4 you are hiring Advance Automotive Technicians. So 5 people aren't coming in with 14 years of progression 6 in front of them. 7 MS. McCLAIN: Correct. That is our 8 intent. Is to -- again, I know you don't like the 9 word "flexibility," but to be able to react and be 10 nimble in making our hiring decisions and placing 11 people, you know, where their qualifications would 12 determine. That is exactly what our intent is. So 13 we don't foresee us bringing in only, you know, 14 Technicians, Auto Techs. You know, if somebody has 15 the qualifications and we go out there and we need 16 an Advanced Automotive Tech and they have the 17 qualifications, we will hire them. So that is our 18 intent. 19 MR. FREDRIKSEN: Okay. I mean, if that 20 is true, that is good. 21 But I know you said you had your 22 subject matter expert look at it, Yuk, and I respect 23 your subject matter expert, but I would like to hear 24 why you made it three years and how long that degree 25 takes -- certification takes to get. It would help Rita Gardner ~ Court Reporter ~ (908) 319-1195 9 1 me understand the Company's proposal in terms of 2 what that lowest level means and what the barriers 3 are to hiring at that level. Right? Because you 4 are saying you want flexibility, but you are setting 5 up limitations. So I need to know what those 6 limitations are to make me feel more comfortable. 7 MS. LOUIE: Yeah, so it is your 8 perspective that there are barriers for us to hire 9 them. We are saying that we don't have barriers. 10 MR. FREDRIKSEN: That is correct. It 11 is my perspective that there are barriers for you to 12 hire. 13 MS. LOUIE: Okay. But I am disagreeing 14 with you that I have barriers. So maybe right now 15 you could list your specific questions so that we 16 can be more pinpoint in being able to answer the 17 question for you. 18 MR. FREDRIKSEN: Yuk, I don't want you 19 to take this the wrong way, but it sounds like you 20 are not willing to provide answers to my information 21 requests. Like you are just saying we should just 22 be happy with it. 23 MS. LOUIE: No, I said put it in 24 writing so that I can answer your question 25 appropriately. Rita Gardner ~ Court Reporter ~ (908) 319-1195 10 1 MR. FREDRIKSEN: Okay. But when you 2 say stuff like -- 3 MS. LOUIE: No, obviously I am not 4 answering your question right now. So I want to 5 make sure that I can answer. So could you just put 6 it in writing so I can answer it? 7 MR. FREDRIKSEN: When you say stuff 8 like "that is what you want" and "that is not what 9 we believe is actuality," it is very adversarial and 10 it is really not conductive to having us understand 11 your proposal. So with all due respect, I would ask 12 you to not say stuff like that anymore. 13 MS. LOUIE: It is not my intent to be 14 adversarial. I am just asking for clarify. So 15 could you put it in writing so that I understand 16 what it is you are asking for? 17 MR. FREDRIKSEN: Sure. 18 All right, I am going to move on. 19 MS. McCLAIN: Okay. 20 MR. FREDRIKSEN: C2, we had some 21 changes in the proposal that the Company said 22 broadly speaking no to. We have talked about the 23 sentence a bunch where we crossed out, "For the 24 duration of this agreement, the Company may contract 25 any job families, for which it has proposed to Rita Gardner ~ Court Reporter ~ (908) 319-1195 11 1 permanently contract without objection from the 2 Union... those job families are." And it lists the 3 job families. 4 Can you explain to me what the 5 Company's intent is on retaining the language for 6 which it has proposed to permanently contract? 7 MS. McCLAIN: So you are asking what 8 our -- I am sorry. You are asking us, based on what 9 you have here, you put temporary. You know, what 10 our proposal says is, "The Company may contract any 11 job families, for which it has proposed to 12 permanently contract without objection from the 13 Union." 14 I think we lost Steve. 15 (Discussion off the record.) 16 MR. FREDRIKSEN: We seem to have a 17 misunderstanding. I am really trying very hard to 18 clear it up. The Union's intent is not to limit the 19 Company with its language in that sentence. It 20 really isn't. What we are trying to eliminate is 21 references to previous proposals, which is what the 22 Union is seeing for which it has proposed. 23 Can you just try to explain to me, if 24 you don't think I am right, if you think that is not 25 what it is, explain that. If you do think it is Rita Gardner ~ Court Reporter ~ (908) 319-1195 12 1 what it is, why is the Company insisting on keeping 2 it? 3 MS. McCLAIN: So is it just those words 4 that you are talking about, the "for which it has 5 proposed to permanently contract out"? 6 MR. FREDRIKSEN: Yes. 7 MS. McCLAIN: Okay. And again, the 8 reason why it is there and not -- we are proposing 9 to keep that in, is to reflect, you know, what we 10 have agreed to that, you know, about permanently 11 contracting. You we have had these discussions, you 12 know, over and over again. And that is really all 13 that is there to do is to reflect, you know, that we 14 have agreed that these specific jobs, you know, will 15 be permanently contracted out. And that we have 16 agreed to that. That is all it is there for. 17 MR. FREDRIKSEN: So the Company is 18 saying that having the language "for which it has to 19 permanently contract" means that if the Union agrees 20 to the proposal as the Company has proposed it, it 21 would be agreeing to permanently contracting out 22 Mechanics, Materials & Services Coordinator, 23 Maintenance & Operations, Audio Visual, Graphics 24 Design, Sr. Repro Tech, Repro Services Tech 25 Assistant, Services Trainee, Sr. Admin. Tech., and Rita Gardner ~ Court Reporter ~ (908) 319-1195 13 1 Tech Assistant? And that -- 2 MS. McCLAIN: If we don't agree to hire 3 -- if we don't need to hire employees into those 4 roles that we can utilize contractors in those 5 roles. Permanently contract into those roles. That 6 is what I believe we have talked about and said what 7 was our intent. 8 MR. FREDRIKSEN: But it is only as long 9 as the side letter exists, right? So in the future 10 if the Union and the Company agree to not renew the 11 side letter, what would happen? 12 MS. McCLAIN: I would have to check 13 into -- I don't know every letter of the law. 14 Right? 15 MR. FREDRIKSEN: It is not at law. It 16 is just a contract. 17 MS. McCLAIN: You know, where we are 18 here. Well, you know, just like if we decide not to 19 renew the agreement, we decide not to renew. If the 20 contract expires, which was a question we discussed 21 many moons ago, what would happen there? But -- 22 MR. FREDRIKSEN: That is not what I am 23 asking. 24 MS. McCLAIN: Okay. 25 MR. FREDRIKSEN: So what I am asking Rita Gardner ~ Court Reporter ~ (908) 319-1195 14 1 is, if the Company and the Union agrees not to renew 2 the side letter, what happens to any Mechanics that 3 they have contracted out? 4 MS. McCLAIN: It depends -- I don't 5 know. Actually, that is a good question. I will 6 have to follow-up on it. 7 What is your interpretation of that, 8 then? 9 MR. FREDRIKSEN: I don't have -- I am 10 not asking -- I am not trying to give an 11 interpretation, JeffeLee. 12 MS. McCLAIN: Oh, okay. 13 MR. FREDRIKSEN: This is the Company's 14 proposal, and the Union needs to understand it. 15 This is really me asking questions of the Company 16 and trying to understand your proposal. Okay? And 17 it is very important that you try to be transparent 18 and straightforward with us if we are ever going to 19 entertain any of the language that you are 20 proposing. I am trying to be as clear as I possibly 21 can. 22 MS. McCLAIN: No, I understand and, you 23 know, we will have to discuss, you know, caucus and 24 discuss that. 25 MR. FREDRIKSEN: Okay. Rita Gardner ~ Court Reporter ~ (908) 319-1195 15 1 MS. McCLAIN: Okay. Just so I am 2 clear. The question is what happens if the side 3 agreement with the language as the Company has 4 proposed and Mechanics, just using an example. 5 MR. FREDRIKSEN: As an example. It is 6 all the positions, but. 7 MS. McCLAIN: I know. Just as an 8 example, Mechanics, we have permanently contracted 9 out. 10 MR. FREDRIKSEN: Only according to the 11 side letter, right? 12 MS. McCLAIN: According to the side 13 letter. If we decide and mutually agree in the 14 future to not have this side agreement, what would 15 happen then to those positions? Is that the 16 question? 17 MR. FREDRIKSEN: What would happen or 18 what is the Company's intent for what would happen? 19 What you believe would happen. What you believe you 20 would do without us holding your feet to the fire. 21 MS. McCLAIN: So I know this is going 22 to sound -- you know, it is not going to be a 23 definitive answer on what you want, but this is all 24 predicated on the fact that, you know, we have 25 agreed to stop this side agreement and that we Rita Gardner ~ Court Reporter ~ (908) 319-1195 16 1 would, either through bargaining or something else, 2 and so we would, you know, bargain whatever at the 3 time. 4 MR. FREDRIKSEN: I understand that. 5 That is always a possibility. This is what 6 bargaining is for. 7 MS. McCLAIN: Right. 8 MR. FREDRIKSEN: I am asking you a very 9 specific question, though. And it is not -- and I 10 understand that we could bargain to have a 11 successorship agreement to this. I understand that. 12 But I am not asking about that because that could 13 look like anything. What I am asking about is, if 14 the Company and the Union were to mutually agree to 15 not renew the side letter, what does that mean for 16 the positions that you are saying are being 17 permanently contracted out? 18 MS. McCLAIN: Okay. I will have to get 19 back to you. 20 MR. FREDRIKSEN: Okay. 21 Going forward a little bit. The Union 22 proposed: "For any contractor in these positions, 23 the Company shall be required, as a condition of the 24 contractor's initial and continued service with 25 EMRE, to pay the Union a monthly service fee Rita Gardner ~ Court Reporter ~ (908) 319-1195 17 1 equivalent to Union membership dues for the length 2 of their service." 3 The Company didn't really say anything 4 about this sentence. The Union's proposal for this 5 sentence is that if these positions are to be 6 permanently contracted out, and especially given 7 what you are saying to me now, it is not only going 8 to be a significant financial loss to the Union -- 9 which you know that. You are not stupid -- but it 10 makes it -- if that language in there were to be 11 agreed upon by the Company, it would be helpful to 12 the Union and, you know, you also know that. 13 So I am -- basically what I am going to 14 ask you is, you understand the balance there. You 15 understand the calculus. So why wouldn't you 16 entertain it? 17 MS. McCLAIN: So, you know, we talked 18 about the length through which we were reviewing 19 proposals, right, and on this one, you are asking 20 the Company to commit to future financial obligation 21 that, you know, we -- where we don't know the 22 circumstance, the amounts, the, you know, of -- you 23 know, of what we are talking about here. So, you 24 know, that was something that we, you know, were 25 weren't interested in doing, and that is really the Rita Gardner ~ Court Reporter ~ (908) 319-1195 18 1 reason why. You know, for us it is, you know, a bit 2 unclear to us, and plus it is obligating the Company 3 to a future financial obligation and, you know, it 4 is something that we weren't interested in. 5 MR. FREDRIKSEN: Is the Company 6 financially obligated to pay people? 7 MS. McCLAIN: Of course we are. 8 MR. FREDRIKSEN: So why do you keep 9 using this "future financial obligations" as reasons 10 why you are not going to bargain with us? 11 MS. McCLAIN: It is not a reason to not 12 bargain. We are bargaining. It is why we are not 13 interested in a particular, you know, piece of 14 language or, you know, proposals that you are 15 putting on the table. There is a difference between 16 paying for work that is received, you know, which is 17 what we do when we pay a salary, right, or wages, 18 you know, versus, you know, what is proposed here. 19 MR. FREDRIKSEN: JeffeLee, I mean, it 20 sounds like when you keep using that phrase, it 21 really sounds like you are drawing a line in the 22 sand and that anything the Union proposes that costs 23 the Company any more money than its proposal, you 24 are not going to entertain. So why do you keep 25 saying -- Rita Gardner ~ Court Reporter ~ (908) 319-1195 19 1 MS. McCLAIN: It is not that at all. 2 We will -- 3 We lost Steve again. 4 (Discussion off the record.) 5 MS. McCLAIN: We will entertain, of 6 course, proposals, you know, but we do have to look 7 at and consider the financial implications of the 8 entire package here and to the entire proposal. So 9 that is what I meant when we say that, when I say 10 that. 11 MR. FREDRIKSEN: With the contracting 12 out proposal in any iteration, the Company or the 13 Union's, is that giving the Company the lower 14 financial obligation? Maybe that was unclear. Let 15 me try that sentence again. 16 Contracting out proposal, the C2, is 17 something that the Company has said that they need 18 as a cost savings measure, among other things, and 19 it gives the Company the flexibility to hire people 20 at a -- you know, on a temporary basis, 21 temporary/permanent their contractors. They don't 22 have benefits that they are getting from the 23 Company. They are not long-term employees. They 24 are at-will employees. The Company can cut them 25 lose at any time. There is an objectively lower Rita Gardner ~ Court Reporter ~ (908) 319-1195 20 1 financial burn on the Company to have these people 2 work on-site. That is only really afforded to them 3 through the proposal that is on the table. 4 Now, no matter what we do, the gravity 5 and the magnitude of the cost savings to the Company 6 is something that the Company has not been able to 7 demonstrate, but is -- it is clear to everyone who 8 reads that it is immense. It is large in magnitude 9 in terms of the cost savings. I believe that it 10 would dwarf, by many orders of magnitude, anything 11 that is even remotely related to this dues proposal 12 that we are saying, the fees rather, we will call 13 them fees, the service fees. So it is not saying 14 that Union is proposing an increased financial 15 obligation on the Company. What it is saying is the 16 Union is proposing a slightly less cost savings for 17 the Company. 18 That is what it is because the proposal 19 isn't something that the Company has right now. But 20 if you ever want to have the proposal be part of the 21 contract, the Union has to agree to it. So if you 22 want to make the Union try to agree to it, it could 23 be that you might want to consider not getting 24 everything that you want. You know, there is an 25 often-used expression that "compromise" means that Rita Gardner ~ Court Reporter ~ (908) 319-1195 21 1 both people walk away from a deal feeling slightly 2 unhappy and that means it is a successful deal. 3 MS. McCLAIN: I understand what you are 4 saying. And I -- you know, when we spoke, and you 5 guys put this on the table, we asked questions about 6 the intent and what this was meant to be, and so I 7 understand the Union's view. I do. 8 MR. FREDRIKSEN: Okay. So if I could 9 reiterate the Company's position on this language, 10 you only don't want to do it -- there are two 11 reasons why you gave me. One is that it is an 12 increased financial burden, which I don't agree with 13 because it is just a slightly less financial savings 14 to the proposal. 15 And two, it is because you don't know 16 what the dues amount could be. It could be 17 increased, it could be decreased. It could be 18 anything the Union decides. Am I right in 19 understanding why the company is not entertaining 20 the language? 21 MS. McCLAIN: So right now, yes. 22 MR. FREDRIKSEN: Okay. Thank you. I 23 am going to move on. 24 The Company proposed to have this 25 off-siting work, this outsourcing language. The Rita Gardner ~ Court Reporter ~ (908) 319-1195 22 1 Company believes that it has the right to do that 2 already. You want to put in the proposal this 3 language because you said you want it, you said it 4 looks good to you. You said you feel like it. 5 Nothing has come up since you implemented C2 that 6 made you need this. You have no specific reasons or 7 plans to use this in a different way. You just want 8 it. Am I understanding the Company's position on 9 that? 10 MS. McCLAIN: It isn't that we just 11 want it. What we have said is, you know, this 12 language, like you said, solidifies our current 13 practices. It provides us -- I know you hate the 14 word, but, the ability to adapt, I will use it 15 instead of flexibility, because that is what we mean 16 by flexibility. The ability to adapt to future 17 business challenges. You know, it is consistent 18 with what we have said. 19 MR. FREDRIKSEN: So you don't think it 20 is solid now? You said it solidifies your practice. 21 Do you not think that it is solid right now? 22 MS. McCLAIN: No, we think it is, but 23 it would be part of, you know, the language here 24 that we have where we are saying, you know, if 25 someone wants to understand the agreement between Rita Gardner ~ Court Reporter ~ (908) 319-1195 23 1 the Company and the Union of how we utilize 2 contracting at Clinton, and, you know, the Company's 3 rights with utilizing contractors, you know, they 4 look at this side agreement and the contract. And 5 so that is why, you know, we took a look and felt 6 that this language was -- it was a good add here to 7 bring clarity about how we utilize contractors, and 8 so that people looking at this can really understand 9 what the -- you know, the Company's rights are. 10 That is the whole purpose of an agreement, right? 11 MR. FREDRIKSEN: So the Company's 12 position that you already want to have the right to 13 do it. It is totally rock solid and there is 14 nothing jeopardizing it or threatening it. But you 15 need this language anyway for reasons that I still 16 don't understand. If you believe that you have the 17 right to do it and you have the right to do it 18 uninhibitedly, and that there is nothing that is 19 going to jeopardize that and it is totally rock 20 solid, why does that belief not stand on its own? 21 MS. McCLAIN: I mean, we -- we believe 22 that we have the right to do it. However, I mean, 23 you can admit, right, that there have been disputes 24 over contracting. We are still discussing this 25 issue for three years. You know, we want to make Rita Gardner ~ Court Reporter ~ (908) 319-1195 24 1 sure that the agreement is clear. 2 MR. FREDRIKSEN: I want to give you a 3 little bit of history because you weren't here for 4 three years. I was. We talked about Graphics 5 Design a lot, JeffeLee, and you weren't part of 6 those discussion at all. 7 MS. McCLAIN: I was not. You are 8 correct. 9 MR. FREDRIKSEN: When it came to the 10 Graphics Design, the Company wanted to move the 11 print shop off-site. And I can't ask you, but you 12 weren't there. But I am going to tell you that the 13 Union didn't -- the Union wanted to make sure that 14 any time the work was being done on-site, it was 15 being done by a represented employee. The Union 16 made that position clear in its proposals. Do you 17 at least know that? You don't know about that? 18 MS. McCLAIN: That is what you have 19 stated. Right? 20 MR. FREDRIKSEN: That is right. So you 21 understand we have talked about that. We have 22 talked about the Union's position are in regards to 23 stuff like that. But you still have this proposal 24 in here, which nothing has come up since October 25 when you declared impasse, that made you want to Rita Gardner ~ Court Reporter ~ (908) 319-1195 25 1 have it. 2 I don't -- I don't understand -- I 3 really don't -- like, explain to me like I am five 4 years old what difference having this language in 5 means to the Company. Like what is the difference 6 with and without it to you? 7 MS. McCLAIN: The difference is that, 8 you know, with it, we are very clear about what the 9 Company's rights are. Without it, there is still -- 10 there will be, likely, no misinterpretation about 11 what can and can't be done. And, you know, like we 12 said, with this -- with C2, you know, what the 13 Company has been looking for all the along is 14 clarity and flexibility. And to me, that is what it 15 means. Is that without -- you know, with this 16 language it is very clear about what he have agreed 17 to, what we have talked about, you know, what you 18 stated your intentions are to focus on roles at the 19 Clinton site. 20 You know, like you said, it wasn't part 21 of the conversations with Graphics Design. However, 22 you know, you made your intentions known as the 23 Union. We simply want to solidify that. That is 24 all it is. So, yes, that to me is the simple 25 answer. Rita Gardner ~ Court Reporter ~ (908) 319-1195 26 1 MR. FREDRIKSEN: So the Company has 2 said, when we first talked about this, that you 3 think you have the right to lay someone -- perform a 4 layoff and backdown or reassignment, right, and 5 continue doing the work that that employee did by 6 outsourcing it. Is that the Company's intention? 7 Is that the Company's belief that this language will 8 afford them the right to do it? 9 MS. McCLAIN: I mean, like you said 10 with Graphic Design, I believe that is the 11 conversations that have happened if we are no longer 12 in that work on-site. 13 MR. FREDRIKSEN: Right. No, actually 14 it was different. 15 MS. McCLAIN: Okay. 16 MR. FREDRIKSEN: The Company agreed to 17 not fire anybody with Graphics Design. What you 18 said to me last time we talked about it was that you 19 think you would be able to fire people and then send 20 their work off-site. Is that the Company's intent 21 with this language? 22 MS. McCLAIN: This would say that we 23 have the right to determine where work is done 24 on-site or off-site. You know, if there is lack of 25 work on-site, you know, we still have the Rita Gardner ~ Court Reporter ~ (908) 319-1195 27 1 provisions, you know, of the contract there. 2 MR. FREDRIKSEN: But if the work can be 3 done on-site, you have the equipment, right? That 4 is the other thing, is that the Graphics Design had 5 to do with the equipment. The equipment wasn't 6 on-site anymore. So if I work on a mass spec, I 7 work on a 15 Tessla FT-ICR and that FT-ICR still 8 existed on-site. There are still samples coming 9 into the lab for analysis. You decided you wanted 10 to fire me and have a university perform mass spec 11 for projects. Do you believe that that language 12 gives you the right to do that? 13 MS. McCLAIN: As it is written. 14 MR. FREDRIKSEN: Is it the Company's 15 intent to do that? 16 MS. McCLAIN: It is the Company's 17 intent to make decisions based on, you know, what 18 the business needs are at that time. You know, if 19 our business conditions require that we do work 20 elsewhere than Clinton, then this provides the 21 flexibility to do that, and that is what this 22 language is about. It is not that it is our intent 23 to. You know, right now, like I said, we have no 24 plans to do that, but it is correct that this 25 language allows the Company to make decisions about Rita Gardner ~ Court Reporter ~ (908) 319-1195 28 1 how and where work gets done. 2 MR. FREDRIKSEN: If the Union were to 3 propose that the Company cannot, for lack of work 4 on-site, do this. So for example, if any employees 5 that are in those jobs cannot lose their jobs as a 6 result of the Company's decision to send their work 7 off-site, is that a proposal the Company would 8 entertain or would that be an increased future 9 financial obligation? 10 MS. McCLAIN: Is that what you are 11 proposing? 12 MR. FREDRIKSEN: I am asking you. 13 MS. McCLAIN: I mean, you know, we 14 would take anything under consideration that the 15 Union is proposing. So I would ask -- 16 MR. FREDRIKSEN: Say I made that 17 proposal right now, what would be the Company's 18 response? 19 MS. McCLAIN: So I would rather talk in 20 -- again, if that is a proposal that you are, you 21 know, giving us, we will consider it. We will take 22 it under consideration and talk as a team. But you 23 know, right now, you know, I prefer not to talk in 24 hypotheticals about that. 25 MR. FREDRIKSEN: Don't think it is Rita Gardner ~ Court Reporter ~ (908) 319-1195 29 1 hypothetical, JeffeLee. This whole entire contract 2 is hypothetical. Russ used to always say, "Nothing 3 is agreed upon until everything is agreed upon." 4 Russ used to say that. This whole thing is 5 hypothetical. 6 MS. McCLAIN: So we would review and 7 consider, like I said, a proposal, if that is what 8 you are -- if that is what you are putting on the 9 table. 10 MR. FREDRIKSEN: Fine. Moving on. 11 "Anytime there is additional work, 12 overtime to Represented Employees will be the first 13 option consider before bringing in contractors. 14 "Unless there is a continuity issue of 15 the work being done, the contractors will only be 16 offered overtime after all qualified represented 17 employees have declined to work the overtime." 18 Just for some background, do you 19 recognize this language, JeffeLee? 20 MS. McCLAIN: In what way? What do you 21 mean? 22 MR. FREDRIKSEN: This language existed 23 in the MobilLab contract for Paulsboro for, I guess 24 decades. For a long time. And I know that that is 25 a different site and it doesn't exist anymore, to Rita Gardner ~ Court Reporter ~ (908) 319-1195 30 1 some extent in the same way that it did before. So 2 I don't need to hear that. But this language worked 3 for ExxonMobil and it worked and what it did is it 4 helped provide the MobilLab Union with the security 5 that it needed to allow the Company to have 6 contractors at their site. 7 You know, there are a lot of times in 8 different areas of the business on-site that 9 employees could do overtime. They are not offered 10 the overtime and they witness contractors performing 11 overtime instead and it creates a sense of animosity 12 between the employees and the contractors. 13 What the Union's proposal would do for 14 the Company is that it would reduce that sense of 15 animosity and probably allow for some, you know, 16 better relationship between employees that are in 17 similar jobs and to contractors. And we are not 18 saying that all the employees have to take the 19 overtime, just that they are offered the overtime 20 first. So that is the Union's intent with this 21 language. The Company didn't respond to it yet, but 22 I would like to hear any reasons as to why the 23 Company is not interested in this language. 24 MS. McCLAIN: Honestly, this is the 25 first time that I am hearing you say that that is an Rita Gardner ~ Court Reporter ~ (908) 319-1195 31 1 issue in the business. When we took a look at this, 2 this wasn't, at least from the knowledge that I 3 have, that that was an issue at our site. 4 MR. FREDRIKSEN: It definitely is. If 5 you need testimonies, I don't think we need to go 6 much further than the bargaining team. But if you 7 don't trust anything the bargaining team says, we 8 can bring in guests from throughout the business to 9 talk about this. Are you interested in that? 10 MS. McCLAIN: Of course I believe what 11 the bargaining team is saying. I was simply 12 responding that this is the first time we are 13 hearing about this. So I would like to hear more 14 and identify the areas that may be problematic and 15 folks are experiencing this, because this is the 16 first time, right, that I am hearing it, about it. 17 MR. FREDRIKSEN: It is -- the area is 18 the Independent Laboratory Employees Union and all 19 of the bargaining unit employees in it. That is the 20 area. Is that I am telling you that if you agree to 21 this language, it would be a -- it would go a long 22 way in making the employees at the site feel like 23 their work is more valuable to the Company. 24 And again, this isn't requiring the 25 Company to give us a bunch of overtime. That is not Rita Gardner ~ Court Reporter ~ (908) 319-1195 32 1 what it is saying. It just says that when the work 2 needs to get done, when you need to have people stay 3 for overtime to do it, if you will just offer it to 4 represented employees first. So is there any reason 5 the Company is not interested in that? 6 MS. McCLAIN: No, I understand what the 7 language, what you are saying the intent of the 8 Union is. I was simply saying that this is the 9 first time we are hearing about this, you know, when 10 we are talking about it. And so we -- you know, if 11 possible, if we could have some more conversation 12 about, you know, examples of where this is happening 13 so that we can understand better, because it just 14 could be a simple conversation that needs to happen, 15 right, because again, I am not aware of that. 16 Yuk, I have not heard this before. So 17 I don't know if Yuk -- it is raised to that level. 18 And of course, if we could, you know, manage things 19 within an organization and the business and fix it, 20 we want to do that, right. 21 MR. FREDRIKSEN: You guys can figure 22 that out on your own. You always say that you don't 23 want the Union to get involved in how you manage 24 your business. 25 MS. McCLAIN: But you are bringing up Rita Gardner ~ Court Reporter ~ (908) 319-1195 33 1 an issue. And so if you have knowledge, right, 2 please share that with us. 3 MR. FREDRIKSEN: I am sharing with you 4 the breadth of the knowledge that I have at this 5 time. If you want personal testimonies, like I 6 said, we will bring in guests to talk about this. 7 MS. McCLAIN: Okay. 8 Yuk? 9 MR. FREDRIKSEN: Is that what you want? 10 MS. McCLAIN: Sorry, Yuk, I couldn't 11 hear you if you said something. 12 MS. LOUIE: I am nodding my head. Yes, 13 that would be helpful to understand where the issues 14 are. 15 MR. FREDRIKSEN: Okay. So you want to 16 have somebody come in and tell you what I just told 17 you, which is that they want to have their overtime 18 be offered to them first? I can do that. I just 19 think it is waste of time. 20 MS. LOUIE: We are just looking for 21 specific examples where that is happening today that 22 they have been denied overtime. 23 MR. FREDRIKSEN: It is not that they 24 are denied it. It is that they are not offered it. 25 MS. LOUIE: Okay. So maybe that is Rita Gardner ~ Court Reporter ~ (908) 319-1195 34 1 where I am trying to say, where have they been not 2 offered and there are known cases where it was 3 offered to a contractor instead. 4 MR. FREDRIKSEN: I can get that 5 information for you. 6 MS. LOUIE: Okay. That would be good. 7 That will help us understand. 8 MS. McCLAIN: That is all I was asking. 9 MR. FREDRIKSEN: Basically what you are 10 saying is, you don't know that that is happening; 11 and if it was happening, you don't think it is 12 appropriate. Is that what I am understanding? 13 MS. McCLAIN: Well, again, initially we 14 didn't think that this was necessary because, again, 15 it wasn't something that we were aware of, you know. 16 You are bringing new information to us, so, you 17 know, let's get those examples and we will take it 18 under consideration of what you are saying. 19 MR. FREDRIKSEN: Now, it is not that I 20 am adverse to doing it. It is just that what I am 21 telling you is that the Union's proposal would just 22 fix it anyway. Like we can do that and we can spend 23 time going over that and have somebody come in and 24 talk to you for four hours, or, like, you could just 25 look at the proposal and tell us what is wrong with Rita Gardner ~ Court Reporter ~ (908) 319-1195 35 1 it, why you don't like it, where you think it limits 2 you in any way. You know. I think feel like that 3 would be a better use of our time. 4 MS. McCLAIN: Again, this is something 5 where we are hearing about it for the first time. 6 We like the additional information that you have and 7 we will take it under consideration. You asked -- 8 this started as to why, you know, we viewed this -- 9 our views of this language. And at the time -- 10 MR. FREDRIKSEN: It was that you didn't 11 think you needed it. Is that what you are saying? 12 MS. McCLAIN: Right. 13 MR. FREDRIKSEN: Okay. I understand. 14 MS. McCLAIN: There was no issue to our 15 knowledge. 16 MR. FREDRIKSEN: I understand. That 17 helps me. I didn't get it. Something didn't click, 18 but not it clicks. We will come back to you with 19 more information. 20 Okay. Let's get on to both of our 21 favorite parts of the C2 proposal, which is sarcasm, 22 because it is not out favorite part. 23 MS. McCLAIN: I know. 24 MR. FREDRIKSEN: "Any arbitrator ruling 25 regarding what positions may be contracted and/or Rita Gardner ~ Court Reporter ~ (908) 319-1195 36 1 duration of contracting shall be limited to the 2 terms of the entire CBA, past arbitrations involving 3 the ILEU, records of discussions between the ILEU 4 and EMRE management involving contracting, industry 5 standards, and any applicable labor laws and 6 regulations." 7 The Company has given us a lot of 8 moving goal posts in terms of the things that wants 9 this language to achieve for them, the requirements 10 that they have for -- what the language needs to be. 11 You said that it needs to give you flexibility. You 12 have said that you -- you have said that in the past 13 you believe you have already the right to 14 permanently contract out jobs and that nothing is 15 going to change that. You have said that you need 16 this language because it needs to provide clarity to 17 the arbitrator on what they can and can't look at. 18 Maybe it is all those things, JeffeLee, 19 and that is fine. Maybe the Company wants 20 everything and it is just the way the Company 21 behaves. But I want you to understand that the 22 Union wants to work with the Company in what it is 23 doing on contracting and they want to have something 24 that is comprehensive. They want to have something 25 that provides clarity on what can and can't be done Rita Gardner ~ Court Reporter ~ (908) 319-1195 37 1 moving forward. 2 The Union is not interested in giving 3 up its rights in terms of parts of the contract that 4 already exist in general and parts of the contract 5 that are specific to things like our job 6 descriptions and things like what the work is and 7 things like the glossary at the end of the contracts 8 that include definitions of words. 9 Like the Company's proposal is 10 extremely limiting. And it lists almost nothing 11 that an arbitrator could look at to make a 12 determination on all of the -- who knows what issues 13 could crop up in terms of the future. You know, 14 this is a new proposal. And in the Union's mind, if 15 the -- if anything resembling this proposal were to 16 make its way into the contract, it would radically 17 alter the Company's rights to contracting on what it 18 currently has. Maybe you don't agree with that. 19 That is fine. 20 But basically what I am saying is, you 21 can't -- you probably can't have everything in order 22 to, you know, get this contracting out proposal 23 through. Like, you are asking for too much with the 24 language that you have in the arbitrator ruling. 25 What we are doing, what we offered to Rita Gardner ~ Court Reporter ~ (908) 319-1195 38 1 you with this language was it was a fig leaf in 2 terms of having something that provides clarity for 3 an arbitrator, and it does. It provides clarity on 4 the things that they can look at. 5 We don't think it is limiting in terms 6 of the rest of the proposal, because what we have 7 said many times before is that the language above 8 it, "To the extent there is a dispute between the 9 side letter (sic) and any other provisions of the 10 CBA, the side letter shall govern." Because that 11 exists, it already means that if there is a dispute 12 with the rest of the contract, that the side letter, 13 the information in the side letter is more 14 important. We have already said that to you, like a 15 lot. 16 So help me understand. Let's dig into 17 this a little more specific. We have the first -- 18 the first thing that we have there is "shall be 19 limited to the terms of the entire CBA." 20 What is wrong with that? 21 MS. McCLAIN: You know, I understand 22 the Union's position. I understand where you are 23 coming from and, you know, I think you understand, 24 you know, what we have said before. And -- I -- 25 what I don't want us to do is just, you know, we Rita Gardner ~ Court Reporter ~ (908) 319-1195 39 1 take clause by clause, because it is the totality of 2 the language that, you know, we are interested in. 3 And what we have said all along is we have been 4 working on this issue. We have had disputes about 5 contracting. We want clarity about, in this 6 specific area of, the proposed Company paragraph on 7 the arbitrator language, you know, to really focus 8 on what it is that we have agreed to, what it is 9 that we have talked about here in this Article XVIII 10 and this side agreement. 11 And, you know, if there is something 12 contradictory within the rest of the CBA, because we 13 are not changing a whole lot in the CBA. I mean, 14 there is 60-odd pages. But what it is, is -- for 15 the Company, is this side agreement and Article 16 XVIII that really clarifies, that is our intent, 17 that would clarify how contractors can be used. 18 Right, that that is the intent of that language. We 19 have said that before. I know you have heard that. 20 I understand what the Union is saying. I totally 21 do, you know. 22 And this has been an area where we 23 remain, you know, oceans apart around, you know, 24 what it is that you want to maintain for the Union 25 and what it is that the Company is seeking with this Rita Gardner ~ Court Reporter ~ (908) 319-1195 40 1 language, which is, you know, clarity around use of 2 contractors that is outlined in Article XVIII and 3 this side agreement. And so, you know, I totally 4 understand that. I do. I understand where you guys 5 are coming from. But I know -- that is what the 6 Company is interested in with this language. 7 MR. FREDRIKSEN: So you are not willing 8 to hear any counterproposals that change that 9 language, it has to be what it is and that is it? 10 MS. McCLAIN: No, of course not. I am 11 just stating, you know, how we have gotten here and 12 what your intent is and what our intent is. 13 MR. FREDRIKSEN: You just told me we 14 are oceans apart. This is the first time we ever 15 proposed anything that started with any language 16 "any arbitrator ruling." So how are we still oceans 17 apart and no change has been made, no bridge has 18 been crossed, no divide has been even attempted to 19 be what the Union wants? 20 MS. McCLAIN: You guys have told us in 21 the past, right, that your intent -- because this 22 language, you know, says everything that you guys 23 have intended, which is you wanted -- you didn't 24 like the language that the Company was proposing 25 because you wanted all aspects of the contract, any Rita Gardner ~ Court Reporter ~ (908) 319-1195 41 1 prior arbitrations, any records. I mean, you have 2 talked about that, that those were the reasons why 3 you were concerned about the Company's language. 4 I mean, this -- this isn't -- I don't 5 see this as something totally new. You may have 6 proposed an arbitrator paragraph, but it states 7 exactly what you have been telling us was your 8 intent, was your needs in the language, and why you 9 didn't like the Company's proposed language. Am I 10 incorrect about that? 11 MR. FREDRIKSEN: That is how 12 counterproposals work, yes. 13 MS. McCLAIN: Okay. So that is why -- 14 I am still saying that, you know, this language 15 solidifies the Union's -- now captures, I shouldn't 16 say solidify. Now captures and reflects what the 17 Union has been telling the Company its intent has 18 been. 19 MR. FREDRIKSEN: So the Union has 20 counterproposals -- the Union will continue to make 21 counterproposals until it finds -- until we reach an 22 agreement. Like, I am not saying that this is what 23 it has to be. I have never said that. However, 24 like you said, we have finally -- we put it in 25 writing, this is what the Union's intent is. I need Rita Gardner ~ Court Reporter ~ (908) 319-1195 42 1 to understand the Company's intent better to make to 2 make a counterproposal that better suits your needs. 3 Because what I am telling you -- what I am hearing 4 from you is that you are going to entertain 5 counterproposals so that means you are going to get 6 counterproposals. 7 So in order for me to make a 8 counterproposal, you need to answer my questions. 9 So we are going to go through it iteratively. And I 10 know that is painful for you. But I can't make 11 another counterproposal to you if you don't answer 12 my questions. So can we go through the proposal and 13 talk about the things that you don't like? 14 MS. McCLAIN: Certainly. However, 15 again, you know, the things that I don't like about 16 it -- 17 MR. FREDRIKSEN: Are the whole thing. 18 I get it. It is the whole thing you don't like. 19 MS. McCLAIN: Yes, it is the whole 20 thing because -- 21 MR. FREDRIKSEN: It is not good enough. 22 It is not enough information for me to do -- 23 MS. McCLAIN: -- it contradicts, you 24 know, what the Company is looking to do, which is 25 have our understanding in Article XVIII and the side Rita Gardner ~ Court Reporter ~ (908) 319-1195 43 1 agreement. 2 MR. FREDRIKSEN: It is not information 3 for me to make the counterproposal, so I need to 4 continue asking you questions. Are you okay with 5 that? 6 MS. McCLAIN: You can, of course, ask 7 any questions. 8 MR. RAGOMO: And to try and bring the 9 oceans a little bit closer together, JeffeLee, 10 again, I am going to ask the question: Why not a 11 mediator to try and help us to get through this and 12 to broach the oceans, if we can? Can you give me a 13 definitive answer as to why the Company is so 14 adamant and opposed to a mediator? 15 MS. McCLAIN: We aren't adamant or 16 opposed to a mediator. We simply aren't interested 17 in one. 18 MR. RAGOMO: Why not? 19 MS. McCLAIN: Again, we prefer to 20 handle bargaining between the parties at the table. 21 MR. RAGOMO: JeffeLee, this is the 56th 22 session that we are going through. Doesn't it seem 23 to be a bit much? Don't you think that there is 24 something else that could potentially help us to 25 bridge this gap somehow? Rita Gardner ~ Court Reporter ~ (908) 319-1195 44 1 MS. McCLAIN: Again, you know, we are 2 interested in working it out at the table, you know, 3 between us. You know, I will talk with my team and 4 take it under consideration. 5 MR. RAGOMO: But I don't believe you 6 are interested because the methods that you are 7 conveying is, you either accept the proposal as we 8 put it to you or we are not interested in anything 9 else, and that is not bargaining. Bargaining is not 10 just one side saying, "We want it all and we are 11 going to give you nothing." That is not bargaining. 12 So if this position in terms of the 13 language that has to be in there, that the Company 14 has to have in there, we can't come to some type of 15 reconciliation, I believe a mediator might help us 16 to do that. 17 MS. McCLAIN: I understand the request 18 and we hear you, and I will talk with my team, like 19 I said, and consider it. 20 MR. RAGOMO: Thank you. 21 MR. FREDRIKSEN: "Any arbitrator ruling 22 regarding what positions may be contracted and/or 23 the duration of contracting shall be limited to the 24 terms of the entire CBA, past arbitrations involving 25 the ILEU, records of discussion between the ILEU and Rita Gardner ~ Court Reporter ~ (908) 319-1195 45 1 EMRE management involving contracting, industry 2 standards, and any applicable labor laws and 3 regulations." 4 Do you understand the Company's intent 5 with our language? You understand that -- you are 6 saying you understand. The Company's intent to not 7 limit the rest of what the proposal is doing with 8 its language. It is still directing an arbitrator 9 to look at the proposal. It has to look at the 10 proposal. And if there is a conflict with the rest 11 of the CBA, then it has to look at the proposal 12 first. You understand that. 13 Now, we didn't entertain the idea of 14 even having any limitation, like we did in the past. 15 Because like, frankly, honestly, it is because the 16 Company has done a very poor job of telling us why 17 they need it. So I am going to ask you again: What 18 else in the CBA is going to -- is problematic to the 19 Company's contracting out proposal? 20 MS. McCLAIN: So, again, I can't 21 enumerate every aspect of our contract, but I will 22 say that, and you can hear it if you want, but we 23 have been talking about contracting and what we 24 would like and what we are interested in having is 25 that this side agreement and the Article is what Rita Gardner ~ Court Reporter ~ (908) 319-1195 46 1 folks look at when determining how to understand the 2 use of contractors. And that is really the intent 3 of that language and there is nothing else that they 4 need to look at it. It is very simple. It is the 5 Article and it is this. And that way it is clear if 6 we, unfortunately, have to have other disputes in 7 the future, that these are the two things that 8 govern what someone needs to look at in order to 9 understand contracting. 10 MR. FREDRIKSEN: The Union, at this 11 time, is not interested in making a counterproposal 12 that is reflective of that in its entirety. 13 However, we are going to try and make a 14 counterproposal that meets the Company's needs 15 anyway. So I am trying to understand, you know, 16 ways to do that. So I am just going to move on 17 because you -- maybe that is too broad. 18 MS. McCLAIN: Okay. 19 MR. FREDRIKSEN: "Past arbitrations 20 involving the ILEU." I think that was pretty good. 21 It is limiting it now from arbitrations throughout 22 the history of time, including things that they 23 uncovered in ancient Egyptian tombs, and now it is 24 just the ILEU. 25 I thought that was a lot of movement. Rita Gardner ~ Court Reporter ~ (908) 319-1195 47 1 The Company didn't recognize that or reflect it. 2 You don't even seem to care. Are there any 3 arbitrations between the ILEU and EMRE management 4 that the Company has specific problems with? 5 MS. McCLAIN: Again, there is a whole 6 host of things that the Company, you know -- 7 MR. FREDRIKSEN: There aren't that many 8 arbitrations. 9 MS. McCLAIN: -- is clear and, you 10 know, in what we have talked about now and, like I 11 said, whether or not there are arbitrations that are 12 existing that are problematic or some that were in 13 our favor, you know, it really doesn't matter to us, 14 you know, where we are because we have been talking 15 about this and we want our, you know, contract 16 between the two of us to reflect, you know, our 17 agreement. 18 You know, we have had disputes. The 19 way to settle disputes is through bargaining, you 20 know, when there is an open contract. And so this 21 is the time to do that. And that is what the 22 Company, you know, is interested in making sure that 23 this side agreement and the Article is what somebody 24 would look at. 25 So, you know, I can't name every single Rita Gardner ~ Court Reporter ~ (908) 319-1195 48 1 arbitration or issue or grievance or, you know, 2 there, so I can't answer your question there. But I 3 go back to saying, you know, what the Company's 4 intent with this language is. So, you know, which 5 is, again, to focus on this Article XVIII and this 6 side agreement because we have worked really hard on 7 it together, you know, and to get the clarity around 8 what somebody looks at and how they interpret what 9 can and can't be done with contracting. So that is 10 -- 11 MR. STRASSER: Can you name one 12 arbitration? 13 MS. McCLAIN: There are many 14 arbitrations. 15 MR. STRASSER: Well, you said you 16 couldn't name them all. I am just asking you to 17 name one. 18 MR. FREDRIKSEN: There actually aren't 19 many arbitrations between the ILEU and the Company 20 involving contracting. To my knowledge, there is 21 only two. 22 MS. LOUIE: Tom and Jeffe, if you 23 wouldn't mind, I think part of the thing was in your 24 sentence, the way it -- the way I read it. Right. 25 It says -- you have, "past arbitration involving Rita Gardner ~ Court Reporter ~ (908) 319-1195 49 1 ILEU, record of discussion between ILEU and 2 management involving contracting." And then you 3 have the comma, it says "industrial standard and any 4 other applicable laws and regulation." 5 For me, the dispute between ILEU 6 management involving contract was just that subset. 7 Then when you said everything else "industrial 8 standard and applicable laws and regulation," that 9 opened it up to everything to me. So you are 10 basically saying that your language, even though you 11 said that you gave in by say limiting it to ILEU 12 disputes, the second part of your sentence says, to 13 me, it is opening up everything. 14 MR. STRASSER: I am sorry, but, yes -- 15 MR. FREDRIKSEN: Mike, stop. Mike, 16 stop. Thank you, Yuk. That was very helpful. We 17 are going to use that -- we are going to take that 18 into consideration. That was very helpful. That 19 was the most helpful thing either of you have ever 20 said about the language and the proposals. 21 I think we should take a caucus now. 22 We have been at this for a while. So we are going 23 to take a look at it. We are going to get back to 24 you. 25 MS. McCLAIN: Okay. Rita Gardner ~ Court Reporter ~ (908) 319-1195 50 1 (Remote negotiations recessed at 10:21 2 a.m. and resumed at 12:17 p.m.) 3 MR. FREDRIKSEN: So we had a question 4 from this morning about the -- well, we had a couple 5 of questions from this morning. One was about what 6 would happen if the Company and the Union mutually 7 agrees to discontinue the side letter, and that 8 request stands. 9 We have some additional questions, and 10 I am working on phrasing the question around the 11 Auto Mechanics in a better way as you -- the 12 question around the certification and rating, as you 13 requested, Yuk. So I will get back to you before 14 the end of the day. 15 But we had some additional follow-ups 16 and some things to ask about the rest of the 17 proposal. 18 MS. McCLAIN: Okay. 19 MR. FREDRIKSEN: It is not unrelated to 20 the proposal, but I want to talk about ETs for a 21 quick second. 22 MS. McCLAIN: I am sorry, what did you 23 say? 24 MR. FREDRIKSEN: Sorry. It is not 25 unrelated to the proposal, but I want to talk about Rita Gardner ~ Court Reporter ~ (908) 319-1195 51 1 ETs again for a quick second. 2 MS. McCLAIN: Okay. 3 MR. FREDRIKSEN: The Company has told 4 us that they have the intention to hire employees to 5 that role and that ET work is going to be performed 6 by represented employees. 7 There have been -- I know that times 8 are tough now, but non-represented employees have 9 been witnessed performing ET work. We know the 10 Company has a job offer out for an ET. My question 11 is, it was the stated intent of the Company for the 12 past few years to have this work be performed by 13 bargaining unit employees. So where do you stand on 14 hiring ETs? How many positions are you looking to 15 fill now? Like you don't have to give me a 16 commitment for the future. I am asking what you are 17 looking for right now. 18 And as a follow-up to that, how many 19 applicants has the Company considered in the past 20 month for these positions? 21 MS. McCLAIN: I don't have that data in 22 front of me as to how many applicants you have 23 considered in the last month that are personally in 24 the retreating process. So I have to go back and 25 ask those involved. Rita Gardner ~ Court Reporter ~ (908) 319-1195 52 1 MR. FREDRIKSEN: I think it would help 2 us understand how the Company intends to -- 3 especially now that you have a proposal that you 4 implemented, how the Company is going to really, you 5 know, actually, you know, utilize this and what they 6 are going to do. So that would help us to make a 7 counterproposal. So if you could get that back to 8 us, that would be helpful. 9 I have another question. The wage 10 survey, you said you submitted the data to Towers & 11 Willis for 2020. Is that right? 12 MS. McCLAIN: I know what I had said on 13 the record and then I texted you and Steve 14 separately to correct myself, that I had made a 15 mistake, that the survey with 2020 data isn't until 16 the third quarter of this year. So I apologize for 17 that. 18 MR. FREDRIKSEN: Okay. So that might 19 be okay. So you remember that the 2019 wage survey, 20 the Company didn't provide consistent data with 21 previous years. If the Company has started that 22 process, can you -- what has the Company done to 23 address that problem? Have you addressed it? 24 MS. McCLAIN: We addressed it with the 25 compensation group. Unfortunately, there has been a Rita Gardner ~ Court Reporter ~ (908) 319-1195 53 1 change in resources once again within that group. 2 And so we are making sure that their transition, you 3 know, the information that we provided and the 4 feedback on the input was transitioned appropriately 5 now that there are changes within that organization. 6 I know we have a meeting with them soon. 7 Right, Josh? 8 MR. BRYANT: Yes, we do, set up for 9 early next week. 10 MS. McCLAIN: We already met with them. 11 We provided them our feedback and what -- how the 12 data should be put in for future surveys. They 13 accepted our information. However, like I said, 14 there has been additional changes in resources since 15 then. And we are following up to make sure that we 16 discuss the same issues with the new resources. 17 Okay? 18 MR. FREDRIKSEN: Okay. Well, I am 19 going to ask you to keep us abreast to that 20 periodically because 2020 has come and gone, but it 21 is important that we use data and, you know, facts 22 to construct our wage proposals to the Company. It 23 is important to us. I don't know how you feel, but 24 it is important to us that we have it based on 25 evidence and facts and, you know -- Rita Gardner ~ Court Reporter ~ (908) 319-1195 54 1 MS. McCLAIN: I understand. 2 MR. FREDRIKSEN: This has been 3 troublesome. The wage survey process has been a 4 troublesome journey for the Union, because it is 5 what the Company said they are basing our wages off 6 of initially. 7 Yes, you said there are other aspects. 8 Some of those other aspects, JeffeLee, are gone. 9 Previously you used to always say it was about, you 10 know, the total wage compensation package, including 11 the Savings Plan Match. 12 MS. McCLAIN: As well as attrition 13 and -- 14 MR. FREDRIKSEN: Sure. Sure. Sure. 15 Yes, yes, yes. But I am saying that the calculus 16 has changed since then. That is what I am saying. 17 I mean, it looks like -- I mean, the calculus has 18 changed since then. We haven't had any wage survey 19 analysis from the Company since the Company 20 suspended the match. So it is important to the 21 Union. 22 So we will be asking -- we are not 23 waiting for it to give you a counterproposal, but I 24 am just stressing to you that as soon as you have 25 information, whether it is what you submit to Towers Rita Gardner ~ Court Reporter ~ (908) 319-1195 55 1 Willis & Watson or what you receive back, it would 2 be a courtesy to us if you could keep us abreast of 3 it concurrently. So like when you submit the data, 4 like just send it to us too. Is that a reasonable 5 request? 6 MS. McCLAIN: We will definitely take 7 it under -- again, we will have to work with our 8 comp group and make sure we understand your request 9 and we will work with them and get back to you. 10 MR. FREDRIKSEN: Okay. That is, I 11 guess, the best I can hope for. 12 MS. McCLAIN: Yeah. 13 MR. FREDRIKSEN: All right. There was 14 another thing. Just bear with me for a second. I 15 am looking at my notes. 16 MS. McCLAIN: I just want to clarify, 17 right. "We" meaning we at the table, me, Josh, Yuk, 18 we don't get told when that information is in or 19 not, but I will work with the comp group and let you 20 know. But that is why we won't just be able to say, 21 "Hey, we are submitting." We don't submit anything. 22 MR. FREDRIKSEN: The next time you talk 23 to them, you can be like, "Can you guys send it to 24 us?" 25 MS. McCLAIN: Exactly. Yes. We Rita Gardner ~ Court Reporter ~ (908) 319-1195 56 1 understand. 2 MR. FREDRIKSEN: I would appreciate 3 that. Thank you. 4 Okay. We were working this entire time 5 on discussing the things -- the questions that you 6 answered, it is very valuable information. We are 7 coming up with a counterproposal. 8 MS. McCLAIN: I have a couple questions 9 too, just to -- you know, we have been working as 10 well. 11 MR. FREDRIKSEN: Oh. Sure. Go ahead. 12 MS. McCLAIN: So on C2, just to 13 understand, you know, where you guys have the 14 monthly service fee, you know, what was -- what was 15 your thought process of how that would be paid? Is 16 it a direct payment to the Union? 17 MR. FREDRIKSEN: Well, we are not 18 looking to make it an administrative hassle to the 19 Company. You have made it clear from like the first 20 day that you are not interested in that. I heard 21 what you said today about how you weren't submitting 22 your responses regarding that and, you know, we are 23 going to use that information to come up with a 24 counterproposal for that language. 25 MS. McCLAIN: Okay. I mean, I can Rita Gardner ~ Court Reporter ~ (908) 319-1195 57 1 still try to answer your question, but does that -- 2 MS. McCLAIN: That is fine. If you 3 went to, you know, take the time, we will hold off 4 and -- 5 MR. FREDRIKSEN: I think maybe it will 6 help answer your question. 7 MS. McCLAIN: Okay. 8 MR. FREDRIKSEN: Do you have anything 9 else? 10 MS. McCLAIN: No. There were just 11 further questions to clarify that piece, so you go 12 ahead and consider. 13 MR. FREDRIKSEN: We are working. That 14 is one of the things that we are working on. It 15 looks like we will punch that out and we will get 16 that back to you. 17 Again, I will just point out it is 18 perhaps intentionally. It is tough to get 19 everything in order on these partial days. It is 20 easier on full days to come back with 21 counterproposals. But, you know, we thank you for 22 meeting with us anyway. 23 MS. McCLAIN: That is understandable. 24 MR. FREDRIKSEN: Full days are better 25 is what I am saying. Rita Gardner ~ Court Reporter ~ (908) 319-1195 58 1 MS. McCLAIN: Yes, we heard and that is 2 why we met when he could on the full days. So we 3 have definitely tried to move things around. 4 MR. FREDRIKSEN: Understand. But any 5 opportunity to meet is a good opportunity, so we are 6 glad that you are making every effort. 7 Do you have any more questions? 8 MS. McCLAIN: No. 9 MR. FREDRIKSEN: Okay. 10 Steve, are you with us? 11 Ethan or anyone else, do you guys have 12 anything else? Did I miss any questions that we 13 talked about that you can remember? 14 MR. LEBRON: I have nothing to add. 15 MR. FREDRIKSEN: Okay. 16 MR. SEBASCO: I think you were very 17 thorough. 18 MR. FREDRIKSEN: Okay. And again, I 19 will respond in writing with the Auto Mechanics 20 questions. There is no problem there. 21 MS. McCLAIN: Yeah, no problem. If you 22 can -- you know, if there is other things that come 23 up in questions, of course e-mail and we will get 24 back to you with whatever information we have. 25 MR. FREDRIKSEN: Sure. Rita Gardner ~ Court Reporter ~ (908) 319-1195 59 1 It is 12:30. It is lunchtime. If you 2 have no exception, we will break for the day. 3 MS. McCLAIN: Yes, that is fine. We 4 have time scheduled already next week, right? 5 MR. BRYANT: Yes, I will send the 6 invitations. Next Friday the 21st from 12:00 to 7 3:00. 8 MR. FREDRIKSEN: Okay. 9 MS. McCLAIN: All right, then, thank 10 you. 11 MR. FREDRIKSEN: Thank you. 12 (Remote negotiations concluded at 13 12:29 p.m.) 14 15 16 17 18 19 20 21 22 23 24 25 Rita Gardner ~ Court Reporter ~ (908) 319-1195 60 1 2 CERTIFICATE 3 4 I, RITA GARDNER, Notary Public of the 5 State of New Jersey and a Certified Court Reporter, 6 do hereby certify that the foregoing is a true and 7 accurate transcript of the remote testimony as taken 8 stenographically, to the best of my ability, by and 9 before me at the time and on the date hereinbefore 10 set forth. 11 I DO FURTHER CERTIFY that I am neither a 12 relative nor employee nor attorney nor counsel of any 13 of the parties to this action, and that I am neither 14 a relative or employee of such attorney or counsel, 15 and that I am not financially interested in the 16 action. 17 18 19 Notary Public of the State of New Jersey 20 21 Dated: May 14, 2021 22 23 24 25 Rita Gardner ~ Court Reporter ~ (908) 319-1195 1 10:21 [1] - 50:1 12:00 [1] - 59:6 12:17 [1] - 50:2 12:29 [1] - 59:13 12:30 [1] - 59:1 13 [1] - 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29:12, 31:18 EMPLOYEES' [1] - 1:13 EMRE [5] - 1:2, 16:25, 36:4, 45:1, 47:3 end [3] - 7:24, 37:7, 50:14 ENGINEERING [1] - 1:10 entails [1] - 6:12 entertain [7] - 14:19, 17:16, 18:24, 19:5, 28:8, 42:4, 45:13 entertaining [1] - 21:19 entire [7] - 19:8, 29:1, 36:2, 38:19, 44:24, 56:4 entirety [1] - 46:12 enumerate [1] - 45:21 equipment [3] - 27:3, 27:5 equivalent [3] - 5:25, 6:23, 17:1 especially [2] - 17:6, 52:3 ET [3] - 51:5, 51:9, 51:10 Ethan [1] - 58:11 ETHAN [1] - 1:15 ETs [3] - 50:20, 51:1, 51:14 evidence [1] - 53:25 exactly [4] - 3:15, 8:12, 41:7, 55:25 example [6] - 6:3, 7:3, 15:4, 15:5, 15:8, 28:4 examples [3] - 32:12, 33:21, 34:17 exception [1] - 59:2 exist [2] - 29:25, 37:4 existed [2] - 27:8, 29:22 existing [1] - 47:12 exists [2] - 13:9, 38:11 experience [5] - 5:18, 5:21, 5:23, 6:7, 7:5 experiencing [1] - 31:15 expert [3] - 7:11, 8:22, 8:23 expertise [1] - 3:19 experts [2] - 6:6, 7:15 expires [1] - 13:20 explain [5] - 3:14, 11:4, 11:23, 11:25, 25:3 expression [1] - 20:25 extent [2] - 30:1, 38:8 extremely [1] - 37:10 EXXONMOBIL [1] - 1:10 ExxonMobil [1] - 30:3 F fact [1] - 15:24 facts [2] - 53:21, 53:25 families [4] - 10:25, 11:2, 11:3, 11:11 favor [1] - 47:13 favorite [2] - 35:21, 35:22 fee [2] - 16:25, 56:14 feedback [2] - 53:4, 53:11 fees [3] - 20:12, 20:13 feet [1] - 15:20 felt [1] - 23:5 few [1] - 51:12 fig [1] - 38:1 figure [1] - 32:21 fill [2] - 4:10, 51:15 filled [1] - 4:22 finally [1] - 41:24 financial [11] - 17:8, 17:20, 18:3, 18:9, 19:7, 19:14, 20:1, 20:14, 21:12, 21:13, 28:9 financially [2] - 18:6, 60:15 fine [6] - 2:11, 29:10, 36:19, 37:19, 57:2, 59:3 fire [4] - 15:20, 26:17, 26:19, 27:10 first [15] - 26:2, 29:12, 30:20, 30:25, 31:12, 31:16, 32:4, 32:9, 33:18, 35:5, 38:17, 38:18, 40:14, 45:12, 56:19 fit [2] - 4:11, 4:17 five [2] - 7:4, 25:3 fix [2] - 32:19, 34:22 flexibility [16] - 3:4, 3:8, 3:9, 3:10, 3:16, 4:19, 5:6, 8:9, 9:4, 19:19, 22:15, 22:16, 25:14, 27:21, 36:11 focus [3] - 25:18, 39:7, 48:5 folks [4] - 4:2, 6:8, 31:15, 46:1 follow [7] - 2:2, 2:13, 2:14, 6:12, 14:6, 50:15, 51:18 follow-up [3] - 6:12, 14:6, 51:18 follow-ups [4] - 2:2, 2:13, 2:14, 50:15 followed [1] - 2:5 following [1] - 53:15 foregoing [1] - 60:6 foresee [1] - 8:13 formal [1] - 5:23 forth [1] - 60:10 forward [5] - 3:9, 3:23, 8:1, 16:21, 37:1 four [1] - 34:24 frankly [1] - 45:15 FREDRIKSEN [108] - 1:15, 2:1, 2:7, 2:12, 2:17, 2:22, 4:24, 5:9, 6:14, 7:22, 8:19, 9:10, 9:18, 10:1, 10:7, 10:17, 10:20, 11:16, 12:6, 12:17, 13:8, 13:15, 13:22, 13:25, 14:9, 14:13, 14:25, 15:5, 15:10, 15:17, 16:4, 16:8, 16:20, 18:5, 18:8, 18:19, 19:11, 21:8, 21:22, 22:19, 23:11, 24:2, 24:9, 24:20, 26:1, 26:13, 26:16, 27:2, 27:14, 28:2, 28:12, 28:16, 28:25, 29:10, 29:22, 31:4, 31:17, 32:21, 33:3, 33:9, 33:15, 33:23, 34:4, 34:9, 34:19, 35:10, 35:13, 35:16, 35:24, 40:7, 40:13, 41:11, 41:19, 42:17, 42:21, 43:2, 44:21, 46:10, 46:19, 47:7, 48:18, 49:15, 50:3, 50:19, 50:24, 51:3, 52:1, 52:18, 53:18, 54:2, 54:14, 55:10, 55:13, 55:22, 56:2, 56:11, 56:17, 57:5, 57:8, 57:13, 57:24, 58:4, 58:9, 58:15, 58:18, 58:25, 59:8, 59:11 Friday [1] - 59:6 front [2] - 8:6, 51:22 FT [2] - 27:7 FT-ICR [2] - 27:7 full [3] - 57:20, 57:24, 58:2 FURTHER [1] - 60:11 future [11] - 13:9, 15:14, 17:20, 18:3, 18:9, 22:16, 28:8, 37:13, 46:7, 51:16, 53:12 G gap [1] - 43:25 GARDNER [1] - 60:4 general [1] - 37:4 given [2] - 17:6, 36:7 glad [1] - 58:6 glossary [1] - 37:7 goal [1] - 36:8 govern [2] - 38:10, 46:8 Graphic [1] - 26:10 Graphics [6] - 12:23, 24:4, 24:10, 25:21, 26:17, 27:4 gravity [1] - 20:4 grievance [1] - 48:1 group [4] - 52:25, 53:1, 55:8, 55:19 guess [2] - 29:23, 55:11 guests [2] - 31:8, 33:6 guys [8] - 21:5, 32:21, 40:4, 40:20, 40:22, 55:23, 56:13, 58:11 H handle [1] - 43:20 happy [1] - 9:22 hard [2] - 11:17, 48:6 hassle [1] - 56:18 hate [1] - 22:13 head [1] - 33:12 hear [9] - 3:12, 8:23, 30:2, 30:22, 31:13, 33:11, 40:8, 44:18, 45:22 heard [4] - 32:16, 39:19, 56:20, 58:1 hearing [6] - 30:25, 31:13, 31:16, 32:9, 35:5, 42:3 heavy [1] - 5:24 HELD [1] - 1:7 help [11] - 3:3, 3:23, 8:25, 34:7, 38:16, 43:11, 43:24, 44:15, 52:1, 52:6, 57:6 helped [1] - 30:4 helpful [9] - 5:6, 6:14, 7:8, 17:11, 33:13, 49:16, 49:18, 49:19, 52:8 helps [1] - 35:17 hereby [1] - 60:6 hereinbefore [1] - 60:9 higher [2] - 5:14, 6:25 hire [12] - 3:5, 3:7, 4:4, 5:4, 6:21, 8:17, 9:8, 9:12, 13:2, 13:3, 19:19, 51:4 hired [2] - 4:6, 4:8 hiring [6] - 4:14, 7:25, 8:4, 8:10, 9:3, 51:14 history [2] - 24:3, 46:22 hold [1] - 57:3 holding [1] - 15:20 honestly [2] - 30:24, 45:15 hope [1] - 55:11 host [1] - 47:6 hours [1] - 34:24 HR [1] - 1:11 hydraulic [1] - 5:22 hypothetical [3] - 29:1, 29:2, 29:5 hypotheticals [1] - 28:24 I ICR [2] - 27:7 idea [1] - 45:13 identify [1] - 31:14 ILEU [13] - 1:2, 36:3, 44:25, 46:20, 46:24, 47:3, 48:19, 49:1, 49:5, 49:11 immense [1] - 20:8 impasse [1] - 24:25 implemented [2] - 22:5, 52:4 implications [1] - 19:7 important [6] - 14:17, 38:14, 53:21, 53:23, 53:24, 54:20 include [1] - 37:8 including [3] - 3:2, 46:22, 54:10 incorrect [1] - 41:10 increased [4] - 20:14, 21:12, 21:17, 28:8 Independent [1] - 31:18 INDEPENDENT [1] - 1:13 industrial [2] - 49:3, 49:7 industry [2] - 36:4, 45:1 information [16] - 2:2, 9:20, 34:5, 34:16, 35:6, 35:19, 38:13, 42:22, 43:2, 53:3, 53:13, 54:25, 55:18, 56:6, 56:23, 58:24 initial [1] - 16:24 input [1] - 53:4 insisting [1] - 12:1 instead [3] - 22:15, 30:11, 34:3 intended [1] - 40:23 intends [1] - 52:2 intent [30] - 8:2, 8:8, 8:12, 8:18, 10:13, 11:5, 11:18, 13:7, 15:18, 21:6, 26:20, 27:15, 27:17, 27:22, 30:20, 32:7, 39:16, 39:18, 40:12, 40:21, 41:8, 41:17, 41:25, 42:1, 45:4, 45:6, 46:2, 48:4, 51:11 intention [3] - 3:6, 26:6, 51:4 intentionally [1] - 57:18 intentions [2] - 25:18, 25:22 interested [18] - 17:25, 18:4, 18:13, 30:23, 31:9, 32:5, 37:2, 39:2, 40:6, 43:16, 44:2, 44:6, 44:8, 45:24, 46:11, 47:22, 56:20, 60:15 interpret [1] - 48:8 interpretation [2] - 14:7, 14:11 invitations [1] - 59:6 involved [2] - 32:23, 51:25 involving [9] - 36:2, 36:4, 44:24, 45:1, 46:20, 48:20, 48:25, 49:2, 49:6 IOW [1] - 2:7 issue [8] - 23:25, 29:14, 31:1, 31:3, 33:1, 35:14, 39:4, 48:1 issues [3] - 33:13, 37:12, 53:16 iteration [1] - 19:12 iteratively [1] - 42:9 J Jeffe [3] - 5:3, 7:13, 48:22 JeffeLee [9] - 14:11, 18:19, 24:5, 29:1, 29:19, 36:18, 43:9, 43:21, 54:8 JEFFELEE [1] - 1:11 jeopardize [1] - 23:19 jeopardizing [1] - 23:14 Jersey [2] - 60:5, 60:19 job [12] - 3:25, 4:17, 4:21, 5:11, 7:20, 10:25, 11:2, 11:3, 11:11, 37:5, 45:16, 51:10 jobs [5] - 12:14, 28:5, 30:17, 36:14 JOSH [1] - 1:12 Josh [3] - 2:4, 53:7, 55:17 journey [1] - 54:4 K keep [6] - 12:9, 18:8, 18:20, 18:24, 53:19, 55:2 keeping [1] - 12:1 kind [1] - 3:18 knowledge [5] - 31:2, 33:1, 33:4, 35:15, 48:20 known [2] - 25:22, 34:2 knows [1] - 37:12 L lab [1] - 27:9 labor [2] - 36:5, 45:2 LABOR [1] - 1:12 Laboratory [2] - 3:2, 31:18 LABORATORY [1] - 1:13 lack [2] - 26:24, 28:3 language [57] - 11:5, 11:19, 12:18, 14:19, 15:3, 17:10, 18:14, 21:9, 21:20, 21:25, 22:3, 22:12, 22:23, 23:6, 23:15, 25:4, 25:16, 26:7, 26:21, 27:11, 27:22, 27:25, 29:19, 29:22, 30:2, 30:21, 30:23, 31:21, 32:7, 35:9, 36:9, 36:10, 36:16, 37:24, 38:1, 38:7, 39:2, 39:7, 39:18, 40:1, 40:6, 40:9, 40:15, 40:22, 40:24, 41:3, 41:8, 41:9, 41:14, 44:13, 45:5, 45:8, 46:3, 48:4, 49:10, 49:20, 56:24 large [2] - 2:10, 20:8 last [5] - 2:3, 2:18, 2:19, 26:18, 51:23 law [2] - 13:13, 13:15 laws [4] - 36:5, 45:2, 49:4, 49:8 lay [1] - 26:3 layoff [1] - 26:4 leaf [1] - 38:1 least [2] - 24:17, 31:2 LEBRON [2] - 1:16, 58:14 length [2] - 17:1, 17:18 less [2] - 20:16, 21:13 letter [12] - 13:9, 13:11, 13:13, 14:2, 15:11, 15:13, 16:15, 38:9, 38:10, 38:12, 38:13, 50:7 level [10] - 3:20, 5:7, 5:8, 5:15, 5:16, 5:18, 6:8, 9:2, 9:3, 32:17 levels [4] - 3:2, 3:25, 4:16, 4:22 licensure [1] - 7:5 likely [1] - 25:10 limit [2] - 11:18, 45:7 limitation [1] - 45:14 limitations [2] - 9:5, 9:6 limited [3] - 36:1, 38:19, 44:23 limiting [6] - 6:19, 6:20, 37:10, 38:5, 46:21, 49:11 limits [1] - 35:1 line [1] - 18:21 list [1] - 9:15 lists [2] - 11:2, 37:10 long-term [1] - 19:23 look [22] - 2:20, 3:17, 3:22, 6:5, 8:22, 16:13, 19:6, 23:4, 23:5, 31:1, 34:25, 36:17, 37:11, 38:4, 45:9, 45:11, 46:1, 46:4, 46:8, 47:24, 49:23 looked [1] - 6:6 looking [12] - 3:18, 4:1, 4:3, 4:10, 23:8, 25:13, 33:20, 42:24, 51:14, 51:17, 55:15, 56:18 looks [4] - 22:4, 48:8, 54:17, 57:15 lose [2] - 19:25, 28:5 loss [1] - 17:8 lost [2] - 11:14, 19:3 LOUIE [13] - 1:12, 5:2, 7:13, 9:7, 9:13, 9:23, 10:3, 10:13, 33:12, 33:20, 33:25, 34:6, 48:22 lower [2] - 19:13, 19:25 lowest [8] - 3:7, 3:20, 4:15, 5:5, 5:15, 5:16, 5:18, 9:2 lunchtime [1] - 59:1 M MADIARA [1] - 1:17 magnitude [3] - 20:5, 20:8, 20:10 mail [1] - 58:23 maintain [1] - 39:24 Maintenance [1] - 12:23 manage [2] - 32:18, 32:23 management [5] - 36:4, 45:1, 47:3, 49:2, 49:6 MANAGER [2] - 1:11, 1:12 market [3] - 4:3, 5:11, 7:16 mass [2] - 27:6, 27:10 Match [1] - 54:11 match [1] - 54:20 Materials [1] - 12:22 matter [7] - 6:6, 7:11, 7:15, 8:22, 8:23, 20:4, 47:13 McCLAIN [102] - 1:11, 2:4, 2:16, 2:20, 3:24, 6:4, 8:7, 10:19, 11:7, 12:3, 12:7, 13:2, 13:12, 13:17, 13:24, 14:4, 14:12, 14:22, 15:1, 15:7, 15:12, 15:21, 16:7, 16:18, 17:17, 18:7, 18:11, 19:1, 19:5, 21:3, 21:21, 22:10, 22:22, 23:21, 24:7, 24:18, 25:7, 26:9, 26:15, 26:22, 27:13, 27:16, 28:10, 28:13, 28:19, 29:6, 29:20, 30:24, 31:10, 32:6, 32:25, 33:7, 33:10, 34:8, 34:13, 35:4, 35:12, 35:14, 35:23, 38:21, 40:10, 40:20, 41:13, 42:14, 42:19, 42:23, 43:6, 43:15, 43:19, 44:1, 44:17, 45:20, 46:18, 47:5, 47:9, 48:13, 49:25, 50:18, 50:22, 51:2, 51:21, 52:12, 52:24, 53:10, 54:1, 54:12, 55:6, 55:12, 55:16, 55:25, 56:8, 56:12, 56:25, 57:2, 57:7, 57:10, 57:23, 58:1, 58:8, 58:21, 59:3, 59:9 mean [18] - 3:15, 4:13, 7:5, 8:19, 16:15, 18:19, 22:15, 23:21, 23:22, 26:9, 28:13, 29:21, 39:13, 41:1, 41:4, 54:17, 56:25 meaning [1] - 55:17 means [9] - 7:12, 9:2, 12:19, 20:25, 21:2, 25:5, 25:15, 38:11, 42:5 meant [2] - 19:9, 21:6 measure [1] - 19:18 Mechanic [5] - 2:24, 3:18, 5:15, 5:21, 6:24 Mechanics [7] - 5:19, 12:22, 14:2, 15:4, 15:8, 50:11, 58:19 mediator [4] - 43:11, 43:14, 43:16, 44:15 medium [1] - 5:23 meet [4] - 4:4, 4:5, 4:6, 58:5 meeting [2] - 53:6, 57:22 meets [1] - 46:14 membership [1] - 17:1 met [2] - 53:10, 58:2 methods [1] - 44:6 mICHAEL [1] - 1:16 MICHAEL [1] - 1:17 might [4] - 4:21, 20:23, 44:15, 52:18 Mike [1] - 49:15 mike [1] - 49:15 mind [2] - 37:14, 48:23 minimum [2] - 5:17, 5:19 misinterpretation [1] - 25:10 miss [1] - 58:12 mistake [1] - 52:15 misunderstanding [1] - 11:17 MobilLab [1] - 29:23 MOLINA [1] - 1:16 money [1] - 18:23 month [2] - 51:20, 51:23 monthly [2] - 16:25, 56:14 moons [1] - 13:21 morning [2] - 50:4, 50:5 most [1] - 49:19 move [5] - 10:18, 21:23, 24:10, 46:16, 58:3 movement [1] - 46:25 moving [6] - 3:9, 3:23, 7:25, 29:10, 36:8, 37:1 MR [120] - 2:1, 2:7, 2:8, 2:12, 2:17, 2:22, 4:24, 5:9, 6:14, 7:22, 8:19, 9:10, 9:18, 10:1, 10:7, 10:17, 10:20, 11:16, 12:6, 12:17, 13:8, 13:15, 13:22, 13:25, 14:9, 14:13, 14:25, 15:5, 15:10, 15:17, 16:4, 16:8, 16:20, 18:5, 18:8, 18:19, 19:11, 21:8, 21:22, 22:19, 23:11, 24:2, 24:9, 24:20, 26:1, 26:13, 26:16, 27:2, 27:14, 28:2, 28:12, 28:16, 28:25, 29:10, 29:22, 31:4, 31:17, 32:21, 33:3, 33:9, 33:15, 33:23, 34:4, 34:9, 34:19, 35:10, 35:13, 35:16, 35:24, 40:7, 40:13, 41:11, 41:19, 42:17, 42:21, 43:2, 43:8, 43:18, 43:21, 44:5, 44:20, 44:21, 46:10, 46:19, 47:7, 48:11, 48:15, 48:18, 49:14, 49:15, 50:3, 50:19, 50:24, 51:3, 52:1, 52:18, 53:8, 53:18, 54:2, 54:14, 55:10, 55:13, 55:22, 56:2, 56:11, 56:17, 57:5, 57:8, 57:13, 57:24, 58:4, 58:9, 58:14, 58:15, 58:16, 58:18, 58:25, 59:5, 59:8, 59:11 MS [113] - 2:4, 2:16, 2:20, 3:24, 5:2, 6:4, 7:13, 8:7, 9:7, 9:13, 9:23, 10:3, 10:13, 10:19, 11:7, 12:3, 12:7, 13:2, 13:12, 13:17, 13:24, 14:4, 14:12, 14:22, 15:1, 15:7, 15:12, 15:21, 16:7, 16:18, 17:17, 18:7, 18:11, 19:1, 19:5, 21:3, 21:21, 22:10, 22:22, 23:21, 24:7, 24:18, 25:7, 26:9, 26:15, 26:22, 27:13, 27:16, 28:10, 28:13, 28:19, 29:6, 29:20, 30:24, 31:10, 32:6, 32:25, 33:7, 33:10, 33:12, 33:20, 33:25, 34:6, 34:8, 34:13, 35:4, 35:12, 35:14, 35:23, 38:21, 40:10, 40:20, 41:13, 42:14, 42:19, 42:23, 43:6, 43:15, 43:19, 44:1, 44:17, 45:20, 46:18, 47:5, 47:9, 48:13, 48:22, 49:25, 50:18, 50:22, 51:2, 51:21, 52:12, 52:24, 53:10, 54:1, 54:12, 55:6, 55:12, 55:16, 55:25, 56:8, 56:12, 56:25, 57:2, 57:7, 57:10, 57:23, 58:1, 58:8, 58:21, 59:3, 59:9 mutually [3] - 15:13, 16:14, 50:6 N name [4] - 47:25, 48:11, 48:16, 48:17 necessary [1] - 34:14 need [17] - 4:21, 8:15, 9:5, 13:3, 19:17, 22:6, 23:15, 30:2, 31:5, 32:2, 36:15, 41:25, 42:8, 43:3, 45:17, 46:4 needed [4] - 4:18, 6:8, 30:5, 35:11 needs [11] - 14:14, 27:18, 32:2, 32:14, 36:10, 36:11, 36:16, 41:8, 42:2, 46:8, 46:14 Negotiations [1] - 1:4 negotiations [2] - 50:1, 59:12 never [1] - 41:23 New [2] - 60:5, 60:19 new [4] - 34:16, 37:14, 41:5, 53:16 next [4] - 53:9, 55:22, 59:4, 59:6 nimble [1] - 8:10 non [1] - 51:8 non-represented [1] - 51:8 Notary [2] - 60:4, 60:19 notes [2] - 2:13, 55:15 Nothing [1] - 29:2 nothing [9] - 22:5, 23:14, 23:18, 24:24, 36:14, 37:10, 44:11, 46:3, 58:14 number [1] - 5:13 O objection [2] - 11:1, 11:12 objectively [1] - 19:25 obligated [1] - 18:6 obligating [1] - 18:2 obligation [5] - 17:20, 18:3, 19:14, 20:15, 28:9 obligations [1] - 18:9 obviously [1] - 10:3 oceans [5] - 39:23, 40:14, 40:16, 43:9, 43:12 October [1] - 24:24 off-site [4] - 24:11, 26:20, 26:24, 28:7 off-siting [1] - 21:25 offer [2] - 32:3, 51:10 offered [8] - 29:16, 30:9, 30:19, 33:18, 33:24, 34:2, 34:3, 37:25 often [2] - 3:10, 20:25 often-used [1] - 20:25 old [1] - 25:4 on-site [11] - 3:19, 20:2, 24:14, 26:12, 26:24, 26:25, 27:3, 27:6, 27:8, 28:4, 30:8 once [1] - 53:1 one [10] - 5:13, 17:19, 21:11, 43:17, 44:10, 48:11, 48:17, 50:5, 57:14 Opalet [1] - 30:4 open [1] - 47:20 opened [1] - 49:9 opening [1] - 49:13 Operations [1] - 12:23 OPERATIONS [1] - 1:12 opportunity [2] - 58:5 opposed [2] - 43:14, 43:16 option [1] - 29:13 order [4] - 37:21, 42:7, 46:8, 57:19 orders [1] - 20:10 organization [2] - 32:19, 53:5 outlined [1] - 40:2 outsourcing [2] - 21:25, 26:6 overall [1] - 5:22 overtime [12] - 29:12, 29:16, 29:17, 30:9, 30:10, 30:11, 30:19, 31:25, 32:3, 33:17, 33:22 own [2] - 23:20, 32:22 P p.m [2] - 50:2, 59:13 package [2] - 19:8, 54:10 pages [1] - 39:14 paid [1] - 56:15 painful [1] - 42:10 paragraph [2] - 39:6, 41:6 parity [2] - 2:25, 6:16 part [8] - 5:10, 20:20, 22:23, 24:5, 25:20, 35:22, 48:23, 49:12 partial [1] - 57:19 particular [1] - 18:13 parties [2] - 43:20, 60:13 parts [3] - 35:21, 37:3, 37:4 past [9] - 2:25, 36:2, 36:12, 40:21, 44:24, 45:14, 48:25, 51:12, 51:19 Past [1] - 46:19 PAUL [1] - 1:17 Paulsboro [2] - 2:5, 29:23 pay [4] - 6:16, 16:25, 18:6, 18:17 paying [1] - 18:16 payment [1] - 56:16 people [12] - 3:20, 7:17, 7:20, 8:5, 8:11, 18:6, 19:19, 20:1, 21:1, 23:8, 26:19, 32:2 perform [2] - 26:3, 27:10 performed [2] - 51:5, 51:12 performing [2] - 30:10, 51:9 perhaps [1] - 57:18 periodically [1] - 53:20 permanently [13] - 11:1, 11:6, 11:12, 12:5, 12:10, 12:15, 12:19, 12:21, 13:5, 15:8, 16:17, 17:6, 36:14 personal [1] - 33:5 personally [1] - 51:23 perspective [3] - 6:15, 9:8, 9:11 phrase [1] - 18:20 phrasing [1] - 50:10 piece [2] - 18:13, 57:11 pinpoint [1] - 9:16 placing [1] - 8:10 Plan [1] - 54:11 plans [2] - 22:7, 27:24 plus [1] - 18:2 PO&T [1] - 1:16 point [1] - 57:17 poor [1] - 45:16 position [8] - 7:9, 21:9, 22:8, 23:12, 24:16, 24:22, 38:22, 44:12 positions [10] - 6:25, 15:6, 15:15, 16:16, 16:22, 17:5, 35:25, 44:22, 51:14, 51:20 possibility [1] - 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14:18 STRASSER [4] - 1:17, 48:11, 48:15, 49:14 stressing [1] - 54:24 stuff [4] - 10:2, 10:7, 10:12, 24:23 stupid [1] - 17:9 subject [5] - 6:5, 7:11, 7:14, 8:22, 8:23 submit [3] - 54:25, 55:3, 55:21 submitted [1] - 52:10 submitting [2] - 55:21, 56:21 subset [1] - 49:6 successful [1] - 21:2 successorship [1] - 16:11 suits [1] - 42:2 survey [5] - 52:10, 52:15, 52:19, 54:3, 54:18 surveys [1] - 53:12 suspended [1] - 54:20 T table [7] - 18:15, 20:3, 21:5, 29:9, 43:20, 44:2, 55:17 team [6] - 28:22, 31:6, 31:7, 31:11, 44:3, 44:18 Tech [13] - 3:1, 4:5, 4:6, 4:7, 4:14, 5:7, 5:8, 8:16, 12:24, 12:25, 13:1 Technician [12] - 3:2, 5:7, 5:16, 5:17, 6:22, 6:23, 7:1, 7:2, 7:4, 7:7, 7:8 Technicians [5] - 5:5, 7:25, 8:3, 8:4, 8:14 Techs [3] - 4:15, 5:4, 8:14 temporary [2] - 11:9, 19:20 temporary/ permanent [1] - 19:21 term [1] - 19:23 terms [13] - 6:16, 6:20, 9:1, 20:9, 36:2, 36:8, 37:3, 37:13, 38:2, 38:5, 38:19, 44:12, 44:24 Tessla [1] - 27:7 testimonies [2] - 31:5, 33:5 testimony [1] - 60:7 texted [1] - 52:13 third [1] - 52:16 THOMAS [1] - 1:15 thorough [1] - 58:17 threatening [1] - 23:14 three [9] - 3:2, 3:25, 4:22, 5:20, 5:22, 6:24, 8:24, 23:25, 24:4 throughout [2] - 31:8, 46:21 Thursday [1] - 1:5 today [2] - 33:21, 56:21 together [2] - 43:9, 48:7 Tom [2] - 2:9, 48:22 tombs [1] - 46:23 took [2] - 23:5, 31:1 top [1] - 2:22 total [1] - 54:10 totality [1] - 39:1 totally [5] - 23:13, 23:19, 39:20, 40:3, 41:5 tough [2] - 51:8, 57:18 Towers [2] - 52:10, 54:25 Trainee [1] - 12:25 training [1] - 5:24 transcript [1] - 60:7 transition [1] - 53:2 transitioned [1] - 53:4 transparent [1] - 14:17 treated [1] - 8:3 tried [1] - 58:3 troublesome [2] - 54:3, 54:4 truck [1] - 5:24 true [2] - 8:20, 60:6 trust [1] - 31:7 try [8] - 11:23, 14:17, 19:15, 20:22, 43:8, 43:11, 46:13, 57:1 trying [7] - 11:17, 11:20, 14:10, 14:16, 14:20, 34:1, 46:15 two [6] - 5:18, 21:10, 21:15, 46:7, 47:16, 48:21 type [1] - 44:14 U ultimately [1] - 6:15 unclear [2] - 18:2, 19:14 uncovered [1] - 46:23 under [6] - 28:14, 28:22, 34:18, 35:7, 44:4, 55:7 understandable [1] - 57:23 unfortunately [1] - 46:6 Unfortunately [1] - 52:25 unhappy [1] - 21:2 uninhibitedly [1] - 23:18 Union [43] - 7:9, 11:13, 11:22, 12:19, 13:10, 14:1, 14:14, 16:14, 16:21, 16:25, 17:1, 17:8, 17:12, 18:22, 20:14, 20:16, 20:21, 20:22, 21:18, 23:1, 24:13, 24:15, 25:23, 28:2, 28:15, 30:4, 31:18, 32:8, 32:23, 36:22, 37:2, 39:20, 39:24, 40:19, 41:17, 41:19, 41:20, 46:10, 50:6, 54:4, 54:21, 56:16 UNION [1] - 1:13 Union's [14] - 2:18, 6:15, 11:18, 17:4, 19:13, 21:7, 24:22, 30:13, 30:20, 34:21, 37:14, 38:22, 41:15, 41:25 Union.. 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