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The members of local 706 were obligated to pay this $3.50 per week working assessment because that is a provision of our bylaws. The men who were working on this project, who were not members of local 706, thoroughly understood that they were under no obligation to pay this $3.50 per week to local 706, but they were told that if they desired to pay the $3.50 per week to local 706 in order to police the job and maintain the wages, hours, and working conditions on the job, it would be received as a voluntary contribution.

Some of the men in my crew, who were not members of local 706, did not make these payments. I do not remember who they were or their names at the present time, but I am sure that I would recognize them if I saw them. I do not know of anybody who was discharged, terminated, transferred, laid off, or discriminated against because they did not pay this $3.50 per week, whether they be members or nonmembers. The people who paid the $3.50 and the people who did not pay the $3.50 were treated exactly alike and the men who did not pay the $3.50 per week were not discriminated against in any way.

I remember two meetings which were held in a park near the jobsite in which Mr. Earl Griffin emphatically stated to the hundreds of people at these meetings that the people who belonged to local 706 were obligated to pay the $3.50 a week working assessment under the bylaws of the local union, but that the people who were working on the job who were not members of local union 706 were not obligated to make this payment, but if they desired to make a voluntary contribution toward the expenses of policing the job that it would be received. Mr. Griffin made this statement on two occasions.

No one ever told me or no one ever intimated to me that I was to discharge or have discharged anybody that did not make this $3.50 per week payment. It was understood by everyone that the members of local 706 were obligated to make the payment under the bylaws, but that the nonmembers of local 706 were under no obligation to make this payment. Some of these people paid and some of them did not.

I have always felt free to get up on the floor at the local union meetings and express my opinion on any subject which came before the meeting. I know of no one in the local union who does not feel free to do so. I know of no one in the local union who has been discriminated against for expressing an opinion upon any subject which has come before the local union meeting without fear of being discriminated against or punished for doing so in any way.

Several times that I can remember there have been strong arguments on the floor about various and sundry subjects and the people that took a viewpoint opposite from that of Earl or Ermon Griffin certainly were not discriminated against for expressing their opinion. I have not always agreed with the Griffins myself, but I have never been discriminated against.

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 1st day of October 1960. [SEAL]

My Commission expires July 28, 1963.

J. R. BURNS.

LOU CRAIG,
Notary Public.

STATE OF ARKANSAS

County of Union, ss:

EXHIBIT No. 58

AFFIDAVIT OF J. M. JOHNNY TELFORD

I live 12 miles south of El Dorado, Ark., and am a member of local union 706 of the United Association. I have been a member of this local union since 1941. I worked on the Pine Bluff Arsenal job which was being constructed by BlawKnox Construction Co. I started out as a journeyman pipefitter and worked for 3 or 4 months as a journeyman and then I was promoted to a pipefitter foreman and during the time that I worked as a pipefitter foreman I collected the $3.50 weekly assessment from the members of local 706 who were working in my crew. I had an average of 10 to 12 men in my crew. All of my crew was not composed of members of local 706, but were either members of other local unions or were not members of any union. It was understood and I explained to

the men who were not members of local 706 that they were not obligated to pay the $3.50 per week assessment, but that the members of local union 706 were obligated to pay the $3.50 per week assessment because of the bylaws of the local union. I told the men that were not members of local 706 that if they wanted to make a voluntary contribution to local 706 to pay the expenses of policing the job and maintaining and securing better hours, wages, and working conditions, that such money would be accepted by me to turn over to the local union. It was definitely understood that any moneys which they paid would be in the form of a voluntary contribution. To the best of my memory, all of the members of my crew paid the $3.50 a week into local union 706. As long as I was out on the job "Red" Yocum, Earl Griffin, or no one else ever told me to collect the $3.50 from each man in my crew or to see that they did not work. It was not necessary that anybody working in my crew pay the $3.50 per week in order to hold their jobs there.

I was working nights at the time that they had the meetings over at the park to get this matter straightened out among all of the people on the job and I did not attend the meetings because I was working. I do know that the men who attended the meetings strictly understood that they were not required to pay any money into local 706 in order to maintain or hold their jobs there at the BlawKnox Construction Co., which was building this project.

I have been in fairly regular attendance at the local union meetings and I have always been able to get up on my feet and express any opinion which I may have, whether it agreed with the opinion of someone else or not. Everybody in this local union has always been able to get up and express their opinion at the local union meetings and there have been some strong arguments in the local union meetings among the membership over various questions which have arisen. I know of no one who has been discriminated against in any way for expressing an opinion or voting contra to the way or to the thinking of Earl Griffin or Ermon Griffin or anybody else in the local union.

I can remember occasions when the purchasing of Christmas gifts to give to various people who had assisted in the employment of members of local 706 on jobs around the country came up. The membership always voted to send the Christmas presents to such people as a token of appreciation of the membership for helping them to secure employment on various jobs around the country. The membership always approved of this practice and, so far as I know, there was no dissent voiced on the floor when this matter would come up.

I have read the foregoing statement and it is true and correct to the best of my knowledge and belief. J. M. "JOHNNY" TELFORD.

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

My commission expires July 28, 1963.

LOU CRAIG,
Notary Public.

STATE OF ARKANSAS,

EXHIBIT No. 59

AFFIDAVIT OF JOHN HENRY ARMER

County of Union, ss:

I am John Henry Armer and I live in El Dorado, Ark., and I have been a member of local union 706 for a number of years. During the Pine Bluff Arsenal job in Pine Bluff, Ark., I was employed by the Blaw-Knox Construction Co. which was doing this construction work for the U.S. Government. I worked there about 16 or 17 months during this construction. After I had been there about 2 months I was made a foreman. As foreman I had about an average of 10 to 12 men under my jurisdiction and supervision. During this job I collected the assessment money for local 706 from the members and I asked all the other men in my crew who were not members of local 706 if they wanted to make a donation to local 706. Some of the men in my crew who were not members of local 706 would make a voluntary contribution to local 706 and each man in my crew understood thoroughly that it was a voluntary contribution. I remember distinctly that there were two men in my crew, one by the name of Branton and another by the name of Young, who were from Beaumont, Tex., who did not wish to contribute to local 706 and they worked on the project as long as anybody else. As a matter

of fact, these men worked until the job went on a 40-hour week and at that time they quit because they could go to other jobs and work on overtime.

At no time did "Red" Yocum, Earl Griffin, or anyone else tell me to collect money from everybody in my crew and if anybody didn't pay to see that they were discharged. Such was not the case. If the people did not desire to make a voluntary contribution who were not members of local 706, that was perfectly all right and no one ever said anything to them about it or criticized them or discriminated against them in any way for not making this voluntary contribution. It is an absolute fact that no one had to make this payment in order to work at Blaw-Knox. I did not attend either one of the meetings that were held in the park to discuss this situation, but I have heard what was said at these meetings.

I have always felt free to express my opinion on any subject that has ever come before the local union meeting and I have always felt that I had the right to get up and bring anything before the local union meeting that I desired to do. I feel that I can express my opinion, regardless of whether or not Earl or Ermon Griffin or anyone else agrees with it, and I know of no one in the local union who doesn't feel the same way. I don't know of a soul who has ever been discriminated against by Earl or Ermon Griffin for disagreeing with them or for any other reason.

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

JOHN HENRY ARMER.

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

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I went to work on the Pine Bluff Arsenal job for Blaw-Knox Construction Co. as a journeyman pipefitter sometime in 1952, and worked there, to the best of my memory, approximately 18 months. At the time that I went to work at the Pine Bluff Arsenal job I did not belong to local 706 or any other local union in the United Association. As a matter of fact, I did not belong to any union at the time that I went to work on this job. Mr. Earl Griffin sent me up on the job and told me to make my application up there, which I did, and I was hired as a journeyman pipefitter. I was not told that I had to pay any initiation fees, dues, working assessment, or anything else in order to go to work up there. However, I did not become a member of local 706 until October 7, 1952, at which time I paid my initiation fees and have been paying my dues regularly into local 706 since that time. During the time that I was working on the Pine Bluff Arsenal job before I became a member of local 706, I paid a $3.50 a week working assessment to local 706 as a voluntary contribution. No one told me that I had to make this payment into local 706 in order to keep my job or if I didn't make this payment that I would be terminated. I was sent up there without being obligated in any way, shape, form, or fashion to local union 706.

While I was employed on the Blaw-Knox job I attended two meetings held at the park which were called by Mr. Earl Griffin to explain to the people on the job that they were not obligated to pay the $3.50 working assessment which was made upon the members of local 706. I know of some men on the job who paid this $3.50 per week into local 706 who were not members of local 706, but they did so as a voluntary contribution of their own free will. I also know of other people who did not pay this voluntary contribution who were not members of local 706 who worked on the job throughout the time that I was there and they were never discriminated against, threatened, terminated, or treated any differently than the other people on the job. I remember specifically one man by the name of Pat O'Neal, of Kansas City, Mo., who never made any of these assessments, and he was not terminated, discriminated against, or treated any differently than any other men on the job who did make these

voluntary contributions. I remember a meeting which was held in a park near the jobsite in which Earl Griffin emphatically stated to all people present, and there were several hundred people present, that no one on the job was required to pay the $3.50 per week working assessment in order to hold their job and only the men of local 706 were required to pay this assessment and they were required to pay it under the terms and provisions of the bylaws. They were not required to pay it in order to hold their jobs at the Pine Bluff Arensal. I know of another meeting which was held at the same place when the rumor persisted that everybody was required to make this payment and Mr. Griffin at that time made another speech at the same place and emphatically told the people that no one on the job was required to pay this $3.50 working assessment; that if the people who were not members of 706 desired to make a voluntary contribution of $3.50 per week or any other sum that it would be accepted and would be used to pay the expenses of policing the job to see that the wages, hours, and working conditions were bettered.

I have always felt like I could express my opinion on the floor upon any subject which was under discussion or bring up any subject on the floor. I know of no one in the local union who does not feel the same way because I remember we have had some very strong arguments on the floor about various and sundry matters. Sometimes I agreed with the Griffins and sometimes I did not agree with the Griffins and I have always felt free to express my opinion, and have expressed my opinion, regardless of how the Griffins might have felt. I have never been discriminated against by the Griffins or anyone else in this local union and know of no one else who has been discriminated against in this local union because of any views that they might have expressed on the floor at a regular meeting or at any other time, nor do I know of anyone else who has been discriminated against for any reason whatsoever.

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

FRED MURPHY.

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

My commission expires January 21, 1961.

W. A. SPEER, Notary Public.

STATE OF ARKANSAS,

EXHIBIT No. 61

AFFIDAVIT OF RALPH KELLY

County of Union, ss:

My name is Ralph Kelly. I live at El Dorado, Ark., and I have been a member of local union 706 of El Dorado, Ark., since March of 1942. I worked on the Pine Bluff Arsenal job for Blaw-Knox Construction Co. and I started out on this job as a journeyman. I worked as a journeyman for approximately 6 weeks and then I was promoted to foreman. I had approximately 10 men in my crew while I was a foreman on this job. I was the one who collected the $3.50 per week assessment from all local 706 men and other men who wanted to pay any moneys into the treasury of local 706. I did not tell anyone that they would have to pay this amount into local 706 in order to hold their jobs and no one ever told me that I was to collect $3.50 per week from the men in my crew or to discharge them. "Red" Yocum or Earl Griffin never made any such statement to me and I collected the money if the men wanted to pay me and if they didn't want to pay me, they worked just like anyone else. I remember one man specifically from Fort Smith who did not pay the $3.50 per week. He did not make any voluntary contribution and he worked there just like anybody else. As a matter of fact, this man was there when I left the job. I do not remember this man's name at the present time. This man was a tall, slim fellow, about 45 years of age and I am sure that I could identify him if I saw him again. I know of no one who was working on the Blaw-Knox job who was terminated, run off, or discharged because they did not pay this $3.50 per week. It as understood by all men on the job that they did not have to pay this money in order to hold their jobs. It is in the bylaws of local 706 that the members of local 706 when they are working pay $3.50 per week working assessment in addition to their dues. However, if they do not pay that money, it is up to the business agent of the local union to collect it and not up to the people or foremen on the job to see that they

pay it.

I know of no one who is a member or nonmember of local 706 on any job who has ever been terminated for not paying this assessment.

I know nothing about a meeting which was held to discuss this payment. I did not attend any such meeting, but I knew that no one had to pay the $3.50 per week working assessment who did not want to. While I was collecting this money for local 706 everybody who paid me any money received a receipt, regardless of whether or not he was a member of local 706 or a member of some other local union of the United Association, a nonunion member, or belonged to some other local other than in the United Association. When I collected this money I took it to "Red" Yocum, the job steward, who in turn took it to the union headquarters.

I have been in regular attendance at the meetings of local union 706 when I have been in town and I know of no one who has not been permitted to get up and make any statement he desired or express any opinion that he desired on any subject which was on the floor for discussion. I know of no one who was ever denied the right or privilege to bring upon the floor for discussion any subject which they so desired. I know of no one ever being discriminated against by Earl or Ermon Griffin or anyone else in local 706 for disagreeing with them. I have often gotten up on the floor and expressed my opinion contra to the opinion expressed by either Earl or Ermon Griffin and I have never been discriminated against in any way by Earl or Ermon Griffin, or any other officer or member of local union 706. The vast majority of the union members all know—as a matter of fact, all of the union members all know that they can get up on the floor and make any statement that they so desire and not be discriminated against in any way.

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

RALPH KELLY.

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

LOU CRAIG, Notary Public.

My commission expires July 26, 1963.

STATE OF ARKANSAS,

EXHIBIT No. 62

AFFIDAVIT OF HOMER ANDRESS

County of Union, ss:

My name is Homer Andress and I have been a member of local 706 since 1942. I was an employee of Blaw-Knox on the Pine Bluff Arsenal job during 1951 and 1952. Part of the time I was a journeyman pipefitter and the last part I was a foreman over the journeymen pipefitters. I had approximately 8 to 10 men in my crew over which I was a foreman. While I was a foreman on this Pine Bluff Arsenal job I collected the $3.50 weekly assessment from the local 706 men. However, it was strictly understood by the members in my crew who were not members of local 706 that they were not obligated to pay the $3.50 a week working assessment as were the men in 706 under bylaws of 706 and all of the men in my crew who were not members of 706 understood this implicitly. I had men in my crew from local 19 in Fort Smith, local 155 in Little Rock, and local 665 in Pine Bluff. Some of these men voluntarily paid the $3.50 and they realized when they paid it that it was a voluntary contribution to local 706 and that they were under no obligation to pay it. No one in my crew was ever discharged for not paying local 706 this $3.50 weekly assessment and I know of no one on the job who was ever discharged, terminated, or otherwise eliminated from the job for not paying this weekly assessment. I remember distinctly that some of the men in my crew did not pay the $3.50 per week working assessment and they were never eliminated from the job or any action taken against them whatsoever, inasmuch as this was a voluntary contribution. I do not remember the names of these men at the present time and I have attempted to search my records to find out if I could ascertain the names of these men, but I have been unable to do so.

However, I do know that some of the men in my crew did not pay the $3.50 per week and nothing was ever said or done about it inasmuch as it was their privilege not to. I do remember very distinctly that Lance Grey, who was a general foreman on the job, paid to me $2.50 per week to be turned in to the El

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