No one ever told me that I had to make this payment, but it was strictly understood by me and everyone in my crew that if anybody wanted to make a $3.50 contribution into local 706 to help defray the expenses of policing the job that they could do so or they could pay any other amount or they could pay none at all. While I was on the job I know of no one who was discriminated against for not paying this $3.50 per week. I know of no one who was ever fired or run off from the job for not paying it and it was understood by everyone concerned that it was a voluntary contribution.

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

NORWOOD DEAL.

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

My name is Walter J. Martin, Sr., and I live in Hot Springs, Ark. I have lived in Hot Springs all my life and now reside at 120 Mountain View Street. I have been a member of Local Union 454 of the United Association for many years and I was a member of Local 454 of the United Association from 1951 to 1954 when the Pine Bluff Arsenal job was being constructed at Pine Bluff, Ark., by Blaw-Knox Construction Co.

I worked on the above job approximately 22 months. I started out on this job as a foreman and was a foreman for approximately 6 months and then I was promoted to a general foreman. During the time I was a foreman on the project I collected $3.50 per week from everyone in my crew who desired to pay this amount. Everyone who desired to pay this amount was given a receipt by me and I turned this money over to Mr. J. C. Swailes who took it to the union office in El Dorado. I was never told by "Red" Yocum, Earl Griffin, J. C. Swailes, or anyone else, that every man in my crew must pay this assessment in order to continue to work on the job. In fact, I was told just the opposite that the moneys which were collected by me on the job were to be strictly a voluntary contribution from all of the men who were not members of local 706. I myself paid $3.50 per week into the treasury of local 706, but I did this strictly as a voluntary contribution, knowing full well that I was under no obligation to do so. I paid this money into local 706 due to the fact that local 706 had jurisdiction over the job and it was their duty to maintain the wages, hours, and working conditions on the job and, of course, they had to have money in order to police this job properly. There were some people in my crew who did not pay this voluntary contribution and to the best of my memory at the present time there were three or four who did not pay, but I do not remember their names at the present time. It would probably show on my record if I could find my old record, but at the present time I am not able to find it. The people who did not make this voluntary contribution into local 706 were never discriminated against in any way. They were never told that they had to pay up in order to work, but they worked on the job just the same as the other men who did make this voluntary contribution.

I remember very distinctly that Mr. J. C. Swailes, who was the president of local union 706 at that time and also my piping superintendent, that if there was anybody in my crew or anybody else on the job that did not want to pay the $3.50 voluntary contribution into local 706 that that was perfectly all right, that they were under no obligation to pay.

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

WALTER J. MARTIN, Sr.

C. H. USSERY,

Notary Public.

Subscribed and sworn to before me this 6th day of October 1960. [SEAL]

My commission expires September 4, 1963.

EXHIBIT No. 38

STATE OF ARKANSAS,

County of Garland, ss:

AFFIDAVIT OF JAMES E. GOODWIN

My name is James E. Goodwin and I am at the present time residing at Route 4, Box 106, El Dorado, Ark., and am now working at Hot Springs, Ark. I have been a member of local union 706 in El Dorado, Ark., since 1947. I was a member of local union 706 from 1951 through 1954 and during that period of time I worked on the Pine Bluff Arsenal job. I worked about a year as a foreman, about 6 or 8 months as a general foreman and some time as a journeyman pipefitter. I was one of the last people on the job.

I was instructed by the business office of local 706 while I was general foreman that the members of other local unions other than 706 and the nonmembers of any union who were working on the job were not required to pay $3.50 per week as the bylaws of local 706 require the members of 706 to pay when they are working. It was strictly understood by me and every other foreman that I know of on the job who was collecting this money that the money which they collected from members other than 706 was strictly on a voluntary basis and that the people who were working on the job were under no obligation or compulsion to make any payments into local 706 in order to work there.

During the time that I worked there I know of several people who did not make any voluntary contribution into local 706 and they worked on the job just exactly the same as anyone else without any discrimination or the like. I have been in fairly regular attendance at the union meetings of 706 and I always felt that I was free to get up on the floor and express my opinion upon any subject that came upon the floor for discussion or to bring up any subject that I might so desire. I know of no one in local 706 who does not feel that he is able to do so and I know of no one in local 706 who has ever been discriminated against for expressing his opinion on the floor upon any subject which might come before the body.

I remember two meetings which were held of the people who were working on the Pine Bluff Arsenal job in a park near the job site. I remember that the meeting was conducted by Mr. J. C. Swailes and Mr. Earl Griffin made a speech at this meeting. The purpose of the meeting was to inform all of the people on the job who were not members of local 706 that they need not pay any money into local 706 unless they chose to do so voluntarily. Mr. Earl Griffin specifically stated this to everyone present and there were several hundred of the men on the job in attendance. He stated that if anyone had paid any money into local 706 under coercion or with the misunderstanding that they had to pay any money into 706 in order to hold their job that if they would stand and be recognized that their money would be refunded to them immediately. Anyone who could understand the English language could certainly understand after Mr. Griffin got through talking that no one was to pay any money into local 706 under duress, but that if they did not desire to pay any money into local 706 they did not have to and if they chose to pay any money in to help defray the expenses of policing the job, it would be purely on a voluntary basis.

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

JAMES E. GOODWIN.

C. H. USSERY,

Notary Public.

Subscribed and sworn to before me this 6th day of October 1960. [SEAL]

My commission expires September 4, 1963.

EXHIBIT No. 39

STATE OF ARKANSAS,

County of Ouachita, ss:

AFFIDAVIT OF FRED J. DANIELS

I am Fred J. Daniels, and I live at Camden, Ark. My post office box is 445, and my telephone number is TE 4-4205. I am now working for the Arkansas Highway Department as job superintendent of division No. 7, with headquarters in Camden, Ark.

Between 1952 and 1954 I was employed at the Pine Bluff Arsenal job in Pine Bluff, Ark., for Blaw-Knox Construction Co. as a journeyman pipefitter and pipefitter foreman. I was a foreman for approximately 1 year and 3 months. During the time I was a foreman on this job Orris M. Nix was a journeyman pipefitter directly under my supervision. Nix had been goofing off on the job, and I told him several times he would have to stay on the job and do his work if he wanted to remain an employee there. After having warned him several times, I found him over in another building from where he was supposed to be. He had gone to lunch, and as he hadn't returned to his assigned work I began to look for him as I didn't know what had happened to him.

I

When I found him I asked him if he was working over where he was. don't remember exactly what he said, but he told me in effect he was supposed to be working on his assigned job over in building 51 where he was working before lunch. He finally came on back over to building 51, and I told him then if he couldn't stay on the job I couldn't use him or didn't need him. He told me that he didn't believe that I could terminate him so I started on to the office. He followed me on to the office and a man by the name of Red Lamb came to the office with Nix. I talked to the general foreman, George Stewart, and told him the whole story about Nix not working. Mr. Stewart then went and immediately wrote out Nix's time and gave it to him. Red Lamb also said

if I was going to give Nix his time to give him his also, which I did.

I don't

He was not discharged for not paying any union dues or assessments. remember whether Nix paid any assessments or not. There were some of the men in my crew who paid money into local 706 of El Dorado, but there were many who did not. I collected this money from the men in my crew who wanted to pay and turned this money over to the general foreman and the job steward. No one ever told me to collect $3.50 per week or terminate the ones who didn't pay. The men in my crew who paid and those who didn't pay were all treated alike.

I was a member of local 706 of the united association at the time I fired Nix and am still a member of that organization, but very seldom do I ever go to a meeting.

I have read the foregoing statement and it is true and correct.

FRED J. DANIELS.

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

We, Dan Dietrich of 2301 West 17th Street, Pine Bluff, Ark., and Henry Dietrich of 2110 Mulberry Street, Pine Bluff, Ark., desire to make the following statement:

We were both employed on the Pine Bluff Arsenal job for approximately 2 years during its construction between the years 1951 and 1954. We were both members of Local Union 665 of the United Association during that period of time and we are still members of Local 665 of the United Association.

We were both sent out on the Pine Bluff Arsenal job which was being constructed by Blaw-Knox Construction Co. by our then business agent, Ray Chambless.

During the time that we worked on this job we paid $3.50 per week into local 706 of El Dorado, Ark., as a voluntary contribution toward the payment of the costs for policing the job and maintaining the wages, hours, and working conditions, and to see that the rights of the employees were enforced.

It was strictly understood by us and by everyone else concerned that any moneys which we paid into local 706 was a voluntary contribution. We remember on one occasion when "Red" Yocum was coming by to collect this money

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.

EXHIBIT No. 41

AFFIDAVIT OF WILLIAM ROLAND MCADOO

STATE OF ARKANSAS,

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.

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