EXHIBIT No. 52

AFFIDAVIT OF BRUCE COTTRELL

STATE OF ARKANSAS,

County of Union, ss:

I am Bruce Cottrell and I reside at El Dorado, Ark. Since May 16, 1956, I have been employed by the National Life & Accident Insurance Co. I am now, and have been, a member of local 706 of the United Association of Plumbers & Steamfitters.

I was a general foreman for Blaw-Knox on the so-called Pine Bluff Arsenal job which was under construction from 1951 to 1954. At the time I was general foreman, I had an average of six or seven foremen under my supervision.

The members of local 706 were required by the bylaws of the local union to pay a working assessment of $3.50 per week for each full week they worked. There were members of other local unions of the United Association working on this project at Blaw-Knox, as well as people who did not belong to any union of the United Association, who were not required to pay this $3.50 per week working assessment.

At no time was I ever told by anyone that the people working on the project were required to pay this $3.50 per week, other than members of local 706. These nonmembers of local 706 were told repeatedly that the local union would accept a voluntary contribution from them in such sums as they wanted to donate in order to defray the expenses of local union 706. In spite of the fact that these people were advised that they were not required to make any payments to local 706, a rumor persisted that such was the requirement.

In an effort to dispel this rumor, Mr. Earl Griffin, then the business agent of local 706, called a meeting of all the people working on the job at a park near the job. As a matter of fact, there were two such meetings, but I attended only one of them. I remember that Mr. Jerry Ryan, general organizer of the United Association, was present at the meeting which I attended at the park. At that meeting there were several hundred men on the job present. Mr. Griffin stated to all persons present in plain language that no one was required to pay the $3.50 working assessment except the men on the job who were members of local 706. Mr. Griffin also stated that persons on the job, other than local 706 members, who desired to make a voluntary contribution to local 706, that such would be accepted by the local union, but it must be a voluntary contribution. Mr. Griffin also stated at that meeting that if anyone, other than members of local 706, had paid any moneys into local 706 under the misunderstanding that they were required to do so, that such moneys would be refunded to them if they would make application for it.

At no time were there any men in my crew who were discharged for nonpayment of this payment, whether he was a member of local 706 or not. There was an average of eight men in each crew over which there was a foreman.

I have not worked at the trade since I have been with the above-mentioned insurance company, and I attend business meetings at the present time very irregularly. However, it is well understood in the local union that any man who has anything to say there is free to do so at any meeting. I have always felt free to express myself openly on any matter that came up in any meeting concerning the local union and any one man in the local is free to do the same thing.

I know that in the past it has been the practice of the local union to buy Christmas presents for other business managers and general organizers who have been instrumental in securing employment for local 706 when there was not sufficient work in the area of local 706 to keep the members employed in the area. These matters have come up in the meetings and have been approved by the members.

With regards to the $3.50 which was collected from the members of local 706, the foremen under me, as general foreman, would collect these assessments from the men and they would turn the money over to me and I would turn it over to "Red" Yocum, the job steward, and he would bring it to the office.

I have read the foregoing in the presence of Mr. Rush Hooten, the circuit clerk of Union County, and state that the same is true and correct to the best of my knowledge and belief on this 28th day of September 1960.

BRUCE COTTRELL.

Subscribed and sworn to before me this 28th day of September 1960, at the courthouse in Union County, Ark.

[SEAL]

RUSH HOOTEN, Circuit Clerk.

EXHIBIT No. 53

AFFIDAVIT OF JACK GOODWIN

STATE OF ARKANSAS,

County of Union, ss:

My name is Jack Goodwin. I am a resident of El Dorado, Union County, Ark., and I am a member of local 706 of the United Association.

During parts of the years 1952, 1953, and 1954, I was a general foreman for Blaw-Knox Construction Co. on the Pine Bluff Arsenal job which was being constructed just north of Pine Bluff on the Little Rock highway. There were several hundred pipefitters employed on this job at one time and some of these pipefitters were members of local 706 of El Dorado, other locals of the United Association and some were not members of any local union.

employed for a This working The members

Under the bylaws of local 706, each member, when he has been week, pays a $3.50 working assessment for that particular week. assessment is not due if the member does not work in any week. of local 706 working on the Pine Bluff Arsenal job were required to pay this $3.50 per week working assessment under the bylaws of the local union, but some of them did not pay this assessment and some of them got many weeks behind in payment. I know of no member of local 706 who was discharged from this job because he did not pay this working assessment as required by the bylaws. The men working on the job who were not members of local 706 who were doing pipefitting work were told emphatically that they were under no obligation to pay this $3.50 working assessment because the bylaws of local 706 did not apply to them. They were further told that if they desired to make a voluntary contribution to local 706 in the amount of $3.50 per week or any other amount that this money would be accepted by the local union to help defray the expenses of policing the job and securing to the employees their proper standing concerning wages, hours, and working conditions.

At no time was I told or was anybody else told in my presence that any one could not work on this job unless they paid the $3.50 per week working assessment.

I know of no one who was let out from the job because they did not pay this $3.50 per week.

I have been in fairly regular attendance of local union meetings and have always felt free to discuss any question which came up on the floor and express my opinion upon it regardless of who might be for or against the particular proposal. The members of local union 706 have always had the privilege of expressing their opinion upon any question or bringing any question upon the floor that they desired and having a full discussion thereof, and I know of no one who has ever been discriminated against for expressing his views or opinions or for any other reasons.

On several occasions I have attended local union meetings when the proposition of giving Christmas presents to various people has come up on the floor and the officers of the local union have always been authorized to give such persons suitable Christmas presents. This has been the practice of the local union for many years.

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

JACK GOODWIN.

C. W. DANCER,

Notary Public.

Subscribed and sworn to before me this 28th day of September 1960. [SEAL]

My commission expires March 23, 1963.

STATE OF ARKANSAS,

EXHIBIT No. 54

AFFIDAVIT OF GEORGE MORGAN

County of Union, ss:

I am George Morgan of El Dorado, Ark., and I have been a member of local 706 for many years. In 1951 or 1952 I worked as a journeyman on the Pine Bluff Arsenal job for Blaw-Knox Construction Co. At no time while I was on the job did any one ever tell me that all the people on the job were required to pay to local 706 a $3.50 working assessment. As a matter of fact, I was a steward on

this job for about a week during the absence of Red Yocum, and it was plainly understood by all concerned that the members of local 706 were supposed to pay $3.50 per week working assessment under the bylaws of the local union, but it was also understood that the nonmembers of local 706 were not obligated to make this payment but that they could make a voluntary contribution to local 706 if they so desired. Many of the nonmembers on this job made voluntary contributions, some in the sum of $3.50 per week and some in lesser amounts. These people all understood that they were not obligated to make these payments, as were the members of local 706. However, several of the members of local 706 did not make these working assessment payments and none were ever terminated for not doing so. I know of no person on the job who was terminated for not making this $3.50 per week assessment.

I heard about the meeting held by Mr. Earl Griffin to inform the people who were not members of local 706 that they were not required to make these payments but that the union would accept a voluntary contribution from them if they desired to make same, but I did not attend this meeting.

I know of no one who has ever been discriminated against in local 706 because of any views he took which were opposite to any other views expressed at any meeting or for any other reason.

In September or October of 1955 I cleared into Tulsa local 798 and went to work under the jurisdiction of that local union on the pipeline. I cleared back into local 706 in the latter part of 1956. I did not vote in the local 798 election held in December of 1955 as the men on the job where I was working discussed going to vote and as they all had different ideas about who they were going to vote for and it was discovered that they would merely kill each others vote if they went to vote, we decided not to go and vote in this election.

I have been in fairly regular attendance of local union meetings held by local 706 and remember a discussion coming up on the floor wherein the officers of the local union were authorized to buy Christmas presents for various people. This has been done almost every year that I can think of and it has always been approved by the membership of the local union.

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

GEORGE MORGAN.

Subscribed and sworn to before me this 28th day of September 1960. [SEAL]

My commission expires March 23, 1963.

C. W. DANCER,
Notary Public.

STATE OF ARKANSAS,

EXHIBIT No. 55

AFFIDAVIT OF GEORGE WOLFE

County of Union, ss:

My name is George Wolfe, and I reside at El Dorado, Ark. I am a member of local 706 of the United Association of El Dorado, Ark. I have been a member of this local union for many years.

I was an employee of Blaw-Knox Construction Co. on the Pine Bluff Arsenal job during its construction for about 2 years. I was a foreman. During the period of time that I was employed on this project local union No. 706 was collecting $3.50 per week working assessment from the members of local 766. This collection was made in accordance with the bylaws of said local union. Local union 706 also received voluntary contributions from other men on the project who were doing pipefitting work who were not members of local 706. but this money which local 706 received from nonmembers thereof was strictly on a voluntary basis. At no time was anyone, member or nonmember of local 706, told that if they did not pay this $3.50 working assessment they could not work on the project. In fact, the men working on the project were told directly opposite to that. There was a rumor on the job that such men would be required to pay it, but our then business agent, Mr. Earl Griffin, called a meeting of all of the people on the project in a park nearby where the construction work was being performed. I remember that Mr. Jerry Ryan, the general organizer for the international union, was present at this meeting. Mr. Earl Griffin stated flatly that the bylaws of local 706 required that the members of local 706 work

ing on the project pay a $3.50 per week working assessment, but that this did not apply to any person who was not a member of local 706. Mr. Griffin emphatically stated that no one, whether he was a member of local 706 or not, who did not pay this $3.50 a week working assessment would be terminated from the job. Mr. Griffin further stated that if anybody who was not a member of local 706 had paid this $3.50 per week working assessment with the idea that they were required to do so, and if they wanted a refund of this money which they had paid, they could obtain a refund by making an application for it.

Some of the men who were members of local 706 paid their working assessment directly into the office in El Dorado and some of them paid their assessment by the envelope. It is true that the nonmembers of local 706 who made a voluntary contribution to local 706 were not given a receipt therefor as a general rule. However, on many occasions such people were given receipts.

I attend the union meetings of local 706 regularly and it is not true that people are not permitted to express their opinions upon any question which comes upon the floor. It is further not true that people have been denied the right to bring up questions on the floor.

On many occasions long and heated arguments have been held in the union meetings on various questions which have been brought up at the meetings and I know of no one who has ever been discriminated against by any person in local 706 for expressing an opinion at any union meeting.

At no time during the Pine Bluff job did anyone make the statement to me or in my presence that all persons who wanted to keep their job on this project must pay this $3.50 assessment. There were some men in my crew who did not pay the $3.50 assessment and I know that they were not discharged or laid off.

At the union meetings every year it is brought up about giving Christmas presents to various people who have assisted the members of local 706 in the previous year and upon each occasion it has been voted that the business agent secure an appropriate gift for such persons and see that they were delivered to them.

I have read the foregoing in the presence of Mr. Rush Hooten, the circuit clerk of Union County, and state that the same is true and correct to the best of my knowledge and belief on this 28th day of September 1960.

GEORGE WOLFE. Subscribed and sworn to before me on this 28th day of September 1960, at the courthouse in Union County, Ark. [SEAL] RUSH HOOTEN, Circuit Clerk.

EXHIBIT No. 56

STATE OF ARKANSAS,

County of Union, ss:

AFFIDAVIT OF LAWSON REASOR HOLMES

I am Lawson Reasor Holmes and I have been a member of local union 706 of the United Association since March of 1942. I reside in El Dorado, Ark., and have lived here for a number of years. I worked on the Pine Bluff Arsenal job for approximately 23 months as a foreman for Blaw-Knox Construction Co. who was constructing the project there. I started out on the project as a journeyman and worked as a journeyman for approximately 3 or 4 months before I was promoted to foreman.

During the time that I was a foreman on the job I collected the $3.50 per week assessment which the members of local 706 were required to pay under the terms and provisions of the bylaws of local 706. It was strictly understood that the men on the job who were not members of local 706 were not required to pay this assessment. When I was a foreman on the job about half of my crew was local 706 men and the other half was not. The people who were nonmembers of local 706 in my crew understood that they were not required to pay this assessment in order to keep their jobs. Some of them said that they didn't desire to pay it and I told them that I thought that if they wanted to enjoy the benefits that local 706 had gotten for them that they should pay it and help defray some of the expenses of policing the job. After I talked with them all except one went ahead and contributed as a voluntary contribution the sum of $3.50 per week to local 706 even though they were not members thereof. The one man who did not was a fellow by the name of Smith from

Texarkana. This man was about 6 feet, weighed about 170 or 175 pounds and was a blond. He was about 26 or 27 years old at that time. Although Smith did not pay this $3.50 per week he worked on the job and under me without any discrimination in any way, shape, form, or fashion and he was not terminated from the job due to the fact that he did not contribute to local 706 to help defray the expenses of policing this job. At no time did Earl Griffin or "Red" Yocum ever tell me or anyone else in my presence that everyone on the job was required to pay this $3.50 per week or be run off of the job. This is just not true. No one that I know of on the job who did not pay this assessment was ever let out for nonpayment of the assessment, that is, whether they were a member of local 706 or not.

Several years ago I was elected to the executive board of this local union and Earl Griffin was the business agent at that time. I told Earl Griffin at that time that if I had any opinion different from him that I was going to feel free to express it and that if he had any opinion that was different from mine that he should feel free to express it and we would talk all matters of importance to the local union out and thoroughly discuss same and try to reach a conclusion on them.

I have been in fairly regular attendance of the meetings of local 706 up until about 3 months ago. I have not been in regular attendance for the last 3 months due to illness, but while I was in regular attendance at the meetings I always felt free to get up on the floor and express my opinion about any subject which came before the local union or to bring up any subject which I felt like the local union ought to know about and have it thoroughly discussed on the floor. Everyone that I know of in the local union feels exactly the same way about the situation, that they can come to the local union and express their opinions or bring up anything before the local union that they desire to do without fear of being discriminated against in any way, shape, form, or fashion by anyone with whom they might disagree. I know of no one who has been discriminated against because they disagreed with Earl or Ermon Griffin on the floor and I remember on many occasions they have been disagreed with on the floor by various and sundry people. I have not always agreed with Earl and Ermon Griffin about all of the proposals which have come up before the union meeting, but I expressed my opinion on these matters and I felt that I had been dealt with fairly concerning the work in this and other areas. I know of no time that anybody who was a member of local 706 was kept sitting on the bench and men who would come by from other locals seeking work who would be sent out in preference to local 706 men. It has always been Mr. Griffin's idea to send local 706 men out first if there were jobs for them in the area and I know of no discrimination against anyone in this respect.

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

LAWSON REASOR HOLMES.

LOU CRAIG, Notary Public.

Subscribed and sworn to before me this 1st day of October 1960. [SEAL]

My commission expires July 28, 1963.

EXHIBIT No. 57

AFFIDAVIT OF J. R. BURNS

STATE OF ARKANSAS,

County of Union, ss:

My name is J. R. Burns and I live at El Dorado, Ark., and I have been a member of local 706 in El Dorado, Ark., since it was organized. I went to work on the Pine Bluff Arsenal job, which was being constructed by Blaw-Knox Construction Co., and worked there about 13 or 14 months. I believe that I went to work there in about May of 1952 and quit about June or July of 1953. When I first started working upon this job I started out as a journeyman pipefitter and worked 3 or 4 weeks as a journeyman pipefitter and then I was promoted to a pipefitter foreman. During the time that I was a pipefitter foreman I had an average of perhaps 10 pipefitters working under me on this job. I would collect the money that was due from the members of local 706 and turn my collections over to the job steward, "Red" Yocum, to bring into the office. It was understood by all the members of my crew that no one was obligated to pay this $3.50 working assessment in order to hold his job there.