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Settlement Withdrawal

Town of Winthrop · from StateReference · 3 pages · 280 KB
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COMMONWEALTH OF MASSACHUSETTS
DIVISION OF LABOR RELATIONS

JERE AO ICR RARE Ra

WINTHROP LIBRARY STAFF
ASSOCIATION, MLSA, LOCAL 4928
vs. Case No. MUP-16-5079

TOWN OF WINTHROP

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FI ICR IR ROI TOR EGE BOR

SETTLEMENT AGREEMENT

This Agreement is entered into by and between the Winthrop Library Staff
Association, MLSA, Local 4928, and the Town of Winthrop.

This Agreement is executed as a means of resolving certain disputed claims
concerning the Union and the Town regarding case no. MUP-16-5079 as well as
American Arbitration Association case no. 01-16-0000-9044 in a manner that avoids
costly and lengthy litigation.

The parties understand and agree that this Agreement is not and shall not be
construed as an admission or assignment of fault, liability, or wrongdoing by either party
hereto.

The parties agree to the following in order to fully and finally resolve these
matters:

1. The Town of Winthrop acknowledges that neither the Union nor its member,
Mary Connolly, violated the Collective Bargaining Agreement on or about
August of 2015 and more particularly in connection with Article 7-Union Activity
on Department Property.

2. The Town will remove from Richard Allen’s personnel file a written warning for

allegedly sleeping at the job on or about October 29, 2015 while attending a
Noble technical services mecting.

3. The Union will withdraw with prejudice MUP-16-5079.

4. The Union will withdraw with prejudice its demand for arbitration referenced at
AAA no. 01-16-0000-9044 with prejudice.

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5. This Agreement shall be non-precedent setting and shall not be introduced, used
or referenced in any future proceeding betwcen the parties except for the purpose
of enforcing the terms of this agreement.

6. This Agreement may not be modificd, altered, or changed except upon expressed
written consent of the parties wherein specific reference is made to this
Agreement.

In witness whereof, the parties hereto knowingly and voluntarily executed this
Agreement as of the date set forth below.

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/fdwn of Winthrop Winthrop Library Staff Association’
} MLSA, Local 4928

pate: / vb Date JE

AFL-CIO

May 2, 2016

BY EFILE AND BY MAIL

Kathleen Goodberlet, Esq.

Investigator

Massachusetts Department of Labor Relations
19 Staniford St., 18 Floor

Boston, MA 02114

RE: Winthrop Library Staff Association, MLSA
Local 4928, AFT Massachusetts, AFL-CIO
and
Town of Winthrop
GR: Anti-Union Discrimination
WITHDRAWAL OF CHARGE/SETTLEMENT AGREEMENT

Dear Ms. Goodbert:

The Charging Party in the above — referenced matter, having reached a Settlement
Agreement with the Respondent (copy enclosed for your file) hereby withdraws its Charge in
this case.

Thank you.
Very truly yours,
Joseph RVLettiere
Associate Counsel
JL/mj
Enclosure
Co: Howard Greenspan, Esq.
Mary Frances Best
Richard Allen
Mary Connolly

Shawn P. Flood

AMERICAN FEDERATION OF TEACHERS MASSACHUSETTS
38 Chauncy Street, Suite 402

Massachusetts Boston, MA 02111

(617) 423-3342 / 1-800-279-2523
Fax: (617) 423-0174

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