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when a person in our crew asked him, "Red, is it necessary for us to pay this money into local 706?" To this question "Red" Yocum replied as follows: "No, it is not necessary that you pay it into local 706." "Red" Yocum stated to us specifically that we were not required to pay any money into local 706 to hold our jobs or to maintain our position there with the Blaw-Knox Co. on this construction project. He specifically stated this on the above occasion which we both heard.

We remember two occasions where there was a meeting at the park near the jobsite which was attended by several hundred of the fitters on this particular job and at that meeting Mr. Earl Griffin made the statement that no one on the job was required to pay local union 706 any money in order to remain employed on that job, but that if anybody wanted to make a voluntary contribution, it would be accepted by local 706. Mr. Griffin thoroughly explained it to the audience on both occasions that if anybody had paid any money into local 706 with the misunderstanding that they were required to do so in order to hold their job with Blaw-Knox in building this arsenal at Pine Bluff that if they would raise their hand and come up to him or contact him in any way, he would see that any moneys which they paid under such a misunderstanding was promptly refunded.

It was understood by everyone concerned that no one on the job was required to pay local 706 any money to remain employed there.

We have read the foregoing statement and it is true and correct to the best of our knowledge and belief.

HENRY DIETRICH.
DAN DIETRICH.

Subscribed and sworn to before me this 8th day of October 1960. [SEAL]

My commission expires January 21, 1962.

K. N. ALEXANDER,

Notary Public.

STATE OF ARKANSAS,

EXHIBIT No. 41

AFFIDAVIT OF WILLIAM ROLAND MCADOO

County of Jefferson, ss:

I am William Roland McAdoo, and I reside at 11 Shirley Street in Pine Bluff, Ark., and I am at the present time employed by the Metropolitan Life Insurance Co.

During 1951 to 1954, the Blaw-Knox Construction Co. was constructing the Pine Bluff Arsenal near Pine Bluff, Ark., and I was employed on this job by Blaw-Knox Construction Co. as a journeyman pipefitter and as a foreman. During the time that I was working there I was working out of local 29 in Fort Smith, Ark.

During the time I was working there no one told me that we had to pay $3.50 per week working assessment to local 706 in order to hold our job there, but it was understood that if we desired to pay any money into local 706 it was a voluntary contribution.

I worked on this job 2 years, lacking 2 months, and during this period of time some weeks I would make a contribution to local 706 in the sum of $3.50 a week and some weeks I wouldn't make any contribution at all. The weeks that I didn't make any contribution I was not discriminated against in any way. No one ever told me that I had to make these $3.50 payments in order to hold my job there and I felt that the money that I paid to 706 was strictly a contribution on my part to help defray some of the expenses of policing the job and maintaining the wages, hours, and working conditions there on the job. I was working on the job when there was a meeting in the park near the jobsite in which Mr. Earl Griffin, the business agent of local 706, made a speech in which he told all of the hands present, and there were several hundred of the hands present, that if anyone had paid $3.50 a week or any other sum into local 706 with the misunderstanding that they were obligated to do so, that if they would come forward or raise their hand or contact him in any way, he would refund their money if they so desired. It was made very plain by Mr. Griffin at this meeting that no one on this job was required to pay any sum to maintain his job there at the Pine Bluff Arsenal.

I left this job of my own free will and accord and went to Saginaw, Mich., and went to work on a better job.

I have read the foregoing statement and it is true and correct to the best of my knowledge and belief.

Subscribed and sworn to before me this 10th day of October 1960.

WILLIAM ROLAND MCADOO.

HUBERT E. SLATEN, Jr.,
Notary Public.

My commission expires January 15, 1964.

EXHIBIT No. 42

AFFIDAVIT OF EARL W. ALEXANDER

STATE OF ARKANSAS,

County of Union, 88:

I am Earl W. Alexander and I reside at 3202 Violet Street in Pine Bluff, Ark. At the present time I am employed by the Southern Electric Pipefitting Corp. which is doing some construction work at the International Paper Co. in Pine Bluff, Ark. I have been employed on this job for several months. In 1951 I also worked on the Pine Bluff Arsenal job for Blaw-Knox Construction Co. I was a foreman and a general foreman on this job. I worked on this job from 1951 through 1954 as a foreman and as a general foreman. I was one of the last people to leave the job. I was initiated into local 706 in 1947 and remained a member of that local until I went to work on the Pine Bluff Arsenal job when I transferred into the Pine Bluff local which number is 665. While I was a member of the Pine Bluff local and working on the arsenal job I paid no assessments into local 706 during the time that I was there and a member of 665 as it was strictly understood by everyone on the job that nonmembers of 706 were not required to make any payments into 706. I did not make any payments into local 706 while I was a member of local 665, that is, from the latter part of 1951 through 1954 when I as working on the Pine Bluff Arsenal job. It was understood by everybody working on the job that those who wished to make a voluntary contribution or donation to local 706 might do so in order to help defray the expenses of local 706 in policing the job and maintaining our wages, hours, and working conditions. However, I did not choose to make any payments into local 706 and as a consequence I did not. No one ever told me that I had to make any payments into local 706. No one ever made any statement to me as foreman or general foreman to collect money from nonmembers or members of local 706 or run them off the job or fire them. It was understood by everybody that they would not be discriminated against in any way in the event that they did not make these assessments or payments. It was strictly understood by everybody concerned that if they were not a member of local 706 and they paid any money into local 706 that it was a voluntary contribution. Ray Chambless was the business agent of local union 665 during the construction of the Pine Bluff Arsenal job and he was also working on the job as a foreman. He collected some of this money for local 706, but I am sure that he knew it was a voluntary contribution and that the men that he collected from did not have to pay it. As a matter of fact, I am certain that Ray Chambless never paid any assessments into local 706 and he worked there almost as long as I did.

I was in regular attendance of the local union meetings of 665 during this period of time and no one ever expressed any opinion or got up and made any statement on the floor of our local union meetings about being required to pay an assessment into local 706 in order to hold their job. Everyone understood that if they did make any payment to 706 it was a purely voluntary contribution. Some of the men did make voluntary contributions in varying amounts up to $3.50 per week into local 706, but I know of many who did not. I remember on two occasions when meetings were held in the park near the Pine Bluff Arsenal job. This is a city park in Pine Bluff, Ark., and it is called Oakland Park. There were several hundred people in attendance at that meeting and I remember distinctly that Ray Chambless was at these meetings. These meetings were conducted by Mr. J. C. Swailes, who is now deceased, and he was president of local 706. After the meeting was called to order Mr. Earl Griffin, the business agent of 706, got up and told all of the hundreds of men present that it was not neces

sary for them to make a $3.50 per week payment to local 706 in order to hold their job at the arsenal. He explained this situation to them in detail and made it very plain that no one was required to make this payment into local 706 if they were not a member there. He stated that the bylaws of local 706 applied to the members of local 706 concerning a working assessment, but that the nonmembers of local 706 did not have to abide by this bylaw and were not required to pay anything into local 706 unless they so desired to make a voluntary contribution. That was thoroughly explained and it was explained to them that if they did not desire to make a voluntary contribution, they did not have to and would not be discriminated against in any way. Mr. Griffin further stated at this meeting that if anyone had paid an assessment into local 706 under the misunderstanding that they were required to do so, that if they would raise their hand and come forward and give him the name and the amount that they had paid, he would refund such sum if they so desired or they could write a letter or contact an officer of the local union and any moneys which they had paid under a misunderstanding would be refunded to them. I remember Mr. Chambless being at this meeting because Mr. Swailes specifically asked Mr. Chambless if he had anything to say and Mr. Chambless declined to say anything. He said that Brother Griffin had covered about everything.

I also remember attending the Arkansas State Pipe Trades Association semiannual convention at El Dorado, Ark., which began on November 15, 1952.

At this meeting Earl Griffin also made a statement concerning the Pine Bluff job and at that time stated that anyone who made a payment into local 706 'which was not a member of 706 did so voluntarily; that they were under no obligation to do so. I remember Mr. Ray Chambless being at this meeting and he made absolutely no comment on Mr. Griffin's speech or in any way intimated that anyone was being required to pay an assessment to local 706 in order to hold their job on the Blaw-Knox Construction Co. project at the Pine Bluff Arsenal.

At the time of the Pine Bluff Arsenal job I was on the executive board of local 665.

I have read the foregoing statement and it is true and correct to the best of my knowledge and belief.

EARL W. ALEXANDER.

VINEY CONGLETON,

Notary Public.

Subscribed and sworn to before me this 7th day of October 1960. [SEAL]

My commission expires February 23, 1963.

EXHIBIT No. 43

AFFIDAVIT OF R. W. BRUMMETT

STATE OF MISSISSIPPI,

County of Hines, ss:

I am R. W. Brummett and I reside at 4407 Jackson Highway, Jackson 9, Miss. I am a member of local union 681 of Jackson, Miss., and I was business agent of that local union from 1949 through 1959. At the present time I am employed as a superintendent by Blaw-Knox Construction Co.

I remember in 1951 through 1954 when the Blaw-Knox Construction Co. was constructing the Pine Bluff Arsenal at Pine Bluff, Ark. I remember that they needed men, particularly pipefitters, very badly on this job and I sent some of the members of local 681 of Jackson, Miss., over to the Pine Bluff Arsenal job to go to work. It was my understanding that local 706 had jurisdiction of this job. None of my members who worked on the Pine Bluff Arsenal job ever complained to me or ever stated to me that they were required to pay $3.50 per week into the treasury of local 706 in order to work on the job. It was my understanding that some of the men did make some voluntary contributions into the treasury of local 706 while they were working on the job and that some of the men who worked on the Pine Bluff job who were members of my local did not make any voluntary contribution. I know of no member of local 681 while I was business agent of that local who worked on the Pine Bluff job who was laid off or discharged from the job due to the fact that they didn't make any payments into local 706 while they were employed on the job.

I wish to also state that I was secretary of the Mississippi Pipe Trades Association during the period of the construction of the Pine Bluff Arsenal job at Pine Bluff, Ark., and that all of the local unions in Mississippi would meet and discuss various problems every so often. At no time was anything ever brought up before our Mississippi Pipe Trades convention or meeting that any of the people that went to work from any of the locals in Mississippi were required to pay a $3.50 per week or any other amount into local union 706 in order to hold their jobs on the Pine Bluff Arsenal.

I have read the foregoing statement and it is true and correct to the best of my knowledge and belief.

R. W. BRUMMETT.

Subscribed and sworn to before me this 5th day of October 1960. [SEAL]

My commission expires January 14, 1961.

WORDA R. BEASLEY,

Notary Public.

STATE OF ARKANSAS,

EXHIBIT No. 44

AFFIDAVIT OF R. K. SCHAEFFER

County of Union, ss:

I am R. K. Schaeffer and I live at Louann, Ark. I am now a member of local 706. However, during the time the Pine Bluff Arsenal was being constructed by the Blaw-Knox Construction Co. I was a member of 665 in Pine Bluff, Ark. I worked on the Pine Bluff Arsenal job as a journeyman pipefitter and I paid as a voluntary contribution the sum of $3.50 per week into local 706. I paid this voluntary contribution into local 706 although I was a member of local 665 because 706 had the expenses of policing the job and maintaining our wages, hours, and working conditions out there and I wanted to contribute my part because it was a good job and I wanted to maintain the conditions. Nobody ever told me that I had to pay the $3.50 a week working assessment, but it was strictly understood by me that it was a voluntary contribution. I was told this upon many occasions and I heard Mr. Griffin make two speeches that the money that nonmembers of local 706 paid into local 706 was strictly a voluntary contribution and no one was obligated to do so. My foreman on this job was George Wolfe. He was the one to whom I paid my contribution. George Wolfe explained to the people in our crew that the nonmembers of 706 did not have to pay the $3.50 per week unless they wanted to. I was there on the job until it closed and it was finished in 1954.

I would also like to state that in 1957 I cleared into local 706 and I have been a member of local 706 since that time. I have always felt that I could get up on the floor at the union meetings and express my opinion upon any question that might arise at the union meeting or bring up any subject which I desired to bring up without fear of being discriminated against or any reprisals taken against me. I know of no one in local 706 since I have been a member here and my observation of the local before I became a member who has been discriminated against. As a matter of fact, if I felt it was that kind of a local I would have never cleared into local 706 and become a member of it in 1957.

I have read the foregoing affidavit and it is true and correct to the best of my knowledge and belief.

Subscribed and sworn to before me this 4th day of October 1960. [SEAL]

My commission expires March 21, 1963.

R.K. SCHAEFFER.

C. W. DANCER,

Notary Public.

EXHIBIT No. 45

AFFIDAVIT OF J. E. CooK AND C. P. THOMPSON

STATE OF ARKANSAS,

County of Union, ss:

We both live in Camden, Ark., and we have been members of local 706 for a number of years. We both worked on the Pine Bluff Arsenal job in 1951 through 1954, at various times. Both of us were foremen on the job and made the collections of the assessments which were against local 706 men. Both of us told the men in our crews who were not members of local 706 that they did not have to pay this working assessment, but if they wished to donate something into local 706 to help defray the expenses of maintaining the wages, hours, and working conditions there that it would be accepted as a voluntary contribution. Some of the men in our crews made a voluntary contribution and some of them did not. J. E. Cook states that he only had one man in his crew who was not a member of local 706 and he was a member of the Pine Bluff local. This man never did make any payments into local 706 while he was working on the job. He made his payments to the Pine Bluff local No one ever discriminated against him for not making a contribution to local 706 and he worked on the job and had the same rights and privileges that anyone else did in the crew. J. E. Cook states that he left this job before it was over and this man out of the Pine Bluff local who never made any contribution to local 706 was still working at at that time. C. P. Thompson states that he had about 10 men in his crew. About five of them were from local 706 and members thereof and the other five were not members of local 706. C. P. Thompson further states that the five men in the crew who were not members of local 706 did not make any payment to him to give to local 706 as a voluntary contribution. That these people were treated the same as anybody else on the job and they were not discriminated against in any way for not making a voluntary contribution to local 706. We would further like to state that we remember a meeting which was held at the park near the jobsite in which Mr. Earl Griffin, the then business agent of 706, specifically stated that nonmembers of local 706 were not required to make any payment in order to hold their jobs out there, but if they wanted to make a voluntary contribution toward the expenses of local 706, it would be accepted. Mr. Griffin further stated at this meeting that if there was anyone there that had paid any money into local 706 with the misunderstanding that they were required to do so to hold their job that if they would come and give him their names or send their names in to the office, that any money that they had paid in would be refunded to them if they so desired.

We have read the foregoing statement and it is true and correct to the best of our knowledge and belief.

J. E. COOK,

C. P. THOMPSON.

Subscribed and sworn to before me this 4th day of October 1960. [SEAL]

My commission expires March 21, 1963.

C. W. DANCER,
Notary Public.

EXHIBIT No. 46

AFFIDAVIT OF W. A. MCMAHAN, A. A. MALLOCH, B. E. Craig, and W. T. “RED"

STATE OF ARKANSAS,

County of Union, ss:

HARRIS

Our names are W. A. McMahan, who lives on the Smackover Highway in Union County, Ark., A. A. Malloch, who lives in El Dorado, Ark., B. E. Craig, who lives in El Dorado, Ark., and W. T. "Red" Harris, who lives near Wesson, on the Wesson-El Dorado Highway.

We were all foremen or general foremen on the Pine Bluff Arsenal job which was being constructed by the Blaw-Knox Construction Co. during 1951 to 1953. We worked there at various times, but all of us worked on this job approximately 2 years. At the time we were foremen on this job we collected the assessments from the members of local 706 who were required to pay the

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