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.

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

My commission expires February 23, 1963.

VINEY CONGLETON,

Notary Public.

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.

R. K. SCHAEFFER.

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. 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

assessments under the bylaws of the local union. We also collected voluntary contributions of other people who were working on this job in the pipefitting trade, who were not members of local 706, when they desired to make a voluntary contribution to the local union. It was understood by all of the people on the job and all of the men under us that the members of local 706 were required to pay this money because of the bylaws and that the nonmembers of local 706 were under no obligation to make any voluntary contribution to local 706. Many of the people under us there on the job made voluntary contributions and we collected same and turned it in to the local union. There were many men on the job who did not make a voluntary contribution and they kept working just as well as the men that did make the voluntary contribution. We told the people on the job who were not members of 706 if they desired to make a voluntary contribution to help defray the expenses of policing the job and paying for the expenses of maintaining our wages, hours, and working conditions, that it would be welcome and everyone understood that they were not under an obligation to pay anything to local 706 in order to hold their jobs there. Each of us can remember people who worked on the job who did not pay anything into local 706 who worked there as long as anybody else.

At no time did the job steward, "Red" Yocum, or Earl Griffin, the then business agent of local 706, or anyone else ever tell us that we had to collect $3.50 per week from every man on the job or that the man would not be working on the job. No one ever intimated such to us and we never intimated such to the

men.

We remember a meeting which was held in a park near the jobsite one evening when the business agent of local 706, Earl Griffin, made a talk in order to definitely establish the fact that men who were not members of local 706 were not required to make any payment into local 706. At this meeting it was definitely understood by everyone concerned, and there were several hundred people at the meeting, that no one was required to pay to local 706 any amount in order to held his job there on the Pine Bluff Arsenal.

We would also like to state that any member of local 706 can express his opinion upon any subject that he would like to on the floor of any local union meeting without fear of any discrimination or reprisal. All of the members of local union 706 have that right and on many occasions there have been some very strong arguments pro and con on various matters which have come before the local union meetings. None of us have ever been afraid to express our opinions on the various subjects at the local union meetings and none of us have ever been discriminated against in any way, shape, form, or fashion, although all of us have at times disagreed with both the ideas of Earl and Ermon Griffin on various subjects.

We all remember on various occasions that the question would come up before the local union as to whether or not we would give Christmas presents to various people who had assisted in employing members of local union 706 in various parts of the United States. This question would come up and it would always be voted upon that the Christmas presents would be given and the officers were authorized to secure the Christmas presents and present them to the various people that the members of the local union desired.

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

W. A. McMAHAN.

A. A. MALLOCH.
B. E. CRAIG.

W. T. "RED" HARRIS.

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

C. W. DANCER,

My commission expires March 21, 1963.

Notary Public.

EXHIBIT No. 47

AFFIDAVIT OF H. J. WEBB AND J. B. SWILLEY OF EL DORADO, ARK.

STATE OF ARKANSAS,

County of Union, ss:

We, H. J. Webb and J. B. Swilley, hereby wish to make the same affidavit as has been made by McMahan, Malloch, Craig, and Harris, with the exception that we did not attend the meeting which was held at the park near the jobsite as they did and we do not know what was said at that meeting. Otherwise, our affidavits are the same.

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

H. J. WEBB.
J. B. SWILLEY.

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

My commission expires March 21, 1963.

EXHIBIT No. 48

C. W. DANCER,
Notary Public.

AFFIDAVIT OF W. W. WRIGHT AND H. C. BRATTON

STATE OF ARKANSAS,

County of Union, ss:

We, W. W. Wright of Camden, Ark., and H. C. Bratton of Louann, Ark., are members of local 706 and have been for a number of years. Both of us worked on the Pine Bluff Arsenal job and desire to make the following statement:

We both state that we worked on this job in Pine Bluff as journeymen pipefitters for several months. While we were there no one ever made the statement that anyone was required to make any weekly assessment payments into local 706 in order to hold their job there. We were members of local 706 and our bylaws provided that we pay a working assessment. However, it was understood and strictly explained to the men who were working on this job in our crews who were not members of local 706 that they were not required to pay this working assessment, but that if they desired they could make a voluntary contribution. At no time was anyone ever discriminated against or criticized or in any way penalized because they did not desire to make this voluntary contribution. We know that there were several men in our crews who did not make this voluntary contribution and they were never discharged or discriminated against in any way. We cannot recall their names right now, but there were several working on the job who did not make this voluntary contribution. We have both been in meetings where Mr. Griffin made speeches stating emphatically that no one had to pay the $3.50 a week working assessment to work on the Pine Bluff Arsenal job and that if anyone had paid the working assessment under the misunderstanding that they were required to pay it, that if they would give him his name that the money would be refunded to him.

We both remember discussions on the floor concerning the giving of Christmas presents to various persons who have assisted the membership of local 706 in going to work. The officers were always authorized to buy these Christmas presents by the membership and give them to the persons who have assisted the membership as a token of the appreciation of the membership.

Both of us wish to state that at no time have we ever been denied the privilege to express any opinion that we may have upon any subject which has come before local 706 meetings. We have always felt free to bring up anything at the meeting which we so desire and to express our opinion, regardless of whether or not anybody else agreed with it. We have never been discriminated against for doing so and we know of no one else who has ever been discriminated against for expressing his opinion on the floor of a meeting, whether or not he agreed with the Griffins or not. We know of no member of local union 706 who has been discriminated against for this or any other reason.