We have read the foregoing statement and it is true and correct to the best of our knowledge and belief. W. W. WRIGHT H. C. BRATTON. Subscribed and sworn to before me this 4th day of October 1960. [SEAL] C. W. DANCER, Notary Public. My commission expires March 21, 1963. EXHIBIT No. 49 AFFIDAVIT OF M. MUCKELRATH, JR., VERNON BURSON, AND L. B. PRIDDY STATE OF ARKANSAS, County of Union, ss: We all live in and around El Dorado, Ark., and have been members of local union 706 for many years. We all worked on the Pine Bluff Arsenal job as employees of Blaw-Knox Construction Co. We were all either foremen or general foremen on this particular project. While we were general foremen on the project we did not collect any of the assessments, but while we were foremen we collected the assessments which were made against local 706 men on this project. During this job there was some misunderstanding about who was to pay the assessment and there was a meeting held by the then business agent, Mr. Earl Griffin, at a park near the project and several hundred of the men were in attendance. Mr. Griffin stated very plainly to the people in attendance that the men who were not members of local 76 were not required to pay this assessment that the members of local 706 were required to pay under their bylaws. Mr. Griffin plainly stated that no one, regardless of whether or not he was a member of 706, would be terminated from his job if he did not pay this assessment. He made it very clear that nonmembers of local 706 were in no way obligated to make any payments to local 706, but if they desired to make any payments in order to pay some of the expenses of policing the job and maintaining the wages, hours, and working conditions on the job that their money would be accepted as a voluntary donation. At no time did Earl Griffin, "Red" Yocum, or anyone else instruct us to collect $3.50 from every man working on the job or the men working under us or else see that they were let out from the job. Such was not the case and such never happened. Each of us know that some of the men on the job did not pay this assessment or did not contribute anything to local 706 in any way, shape, form, or fashion, and we can further state emphatically that nothing was ever done to try to terminate these men or to run them off the job in any manner, shape, or form. We also remember on many occasions when we attended the union meeting when our union hall used to be above the pool hall here in El Dorado that Earl Griffin would state at the union meetings that no nonmember of local 706 was required to pay this assessment. We know of no one who was ever discharged from their job at the Pine Bluff Arsenal for nonpayment of this assessment, but that several people who did not pay it remained on the job and worked and had the same rights and privileges and benefits as the people who did pay this assessment. We would also desire to state that nobody has ever been discriminated against in this local union because of any opinion that they have ever had or might have expressed on the floor. It is our firm belief that every member of this local union has the right and the privilege to get up on the union floor and express his opinion upon any subject and whether he agrees with Earl or Ermon Griffin or any other officers of the local union about any particular subject is immaterial and at no time has anyone that we know of ever been discriminated against for having a difference of opinion on any matter with Ermon or Earl Griffin. We are sure that everyone in this local union feels free to get up and express their opinions pro or con on any subject which might come upon the floor without fear of reprisal from Ermon Griffin, Earl Griffin, or any of the other officers of this local union. We can remember that upon almost every meeting night there is an argument or discussion on some subject which has come up before the local union and no one has ever been discriminated against for any position that they ever took on the floor or anywhere else or for any other reason. M. Muckelrath, Jr., and L. B. Priddy would like to state that they have been in meetings of the local union upon many occasions when the question of giving Christmas presents or presents to people who have assisted the members of the local union in securing employment over the United States, or have done the local union some favor in the past, has come up. Without exception the giving of Christmas presents to such people has been approved by the local union and, so far as we remember at this time, there was never any objection to it. We would like further to state that this matter was fully discussed and fully brought out and the membership of the local union was fully advised as to the practice of giving Christmas presents to various and sundry people. They all felt that it was for the best interest of the membership of the local union to do so, and most of us still feel that it is in the best interest of the local union to continue to do so. Mr. Vernon Burson was not present at any of the meetings where the Christmas present matter was discussed. Mr. Burson, however, would like to state that if he had been present at any of the meetings where Christmas presents were discussed and brought up, that he would have been in favor of buying the Christmas presents because he feels that it has been of great benefit to the membership of the local union to do this and he would be in favor of continuing this practice. We have read the foregoing statement and it is true and correct to the best of our knowledge and belief. M. MUCKELRATH, Jr. 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. 50 STATE OF ARKANSAS, County of Garland, ss: AFFIDAVIT OF O. B. CoONRADT My name is O. B. Coonradt and I reside at 2181⁄2 Tennessee Street in Hot Springs, Ark. I am the present business agent of local 454 of the United Association and I was the business agent of local 454 of the United Association from 1951 through 1954. Local 454 of the United Association has its headquarters in Hot Springs, Garland County, Ark. I remember very well the Pine Bluff Arsenal job in Pine Bluff, Ark., when Blaw-Knox Construction Co. was constructing this arsenal for the U.S. Government. There were several hundred plumbers and pipefitters working on this job and many of the men out of this local union went over there and worked on this job. To the best of my memory, I believe that we had about 60 men out of this local union working over there on the Pine Bluff Arsenal job between 1951 and 1954. With regard to the payment of assessments into local 706, which local was given jurisdiction over this job, I wish to state that the members of my local union who worked over there on that job, most of them, paid $3.50 into local 706 each week. They thought that it was nothing but right for them to do that inasmuch as local 706 had jurisdiction over the job and they thought and I thought, and I still think, that they should have borne their just share of the costs of policing the job and maintaining the wages and hours and working conditions on the job. During the time that the people from my local union were working over there it was understood by each one of them that this payment into local 706 was purely a voluntary contribution and that they did not have to pay this money into local 706 unless they desired. I remember being at an Arkansas State Pipe Trades Association meeting in El Dorado, Ark., when the Pine Bluff job was going on and the assessment question came up at this meeting and Mr. Earl Griffin stated at this meeting, which was attended by me and all of the other business agents and some of the officers of all of the local unions of the United Association in the State of Arkansas. I remember Mr. Earl Griffin stating explicitly at this meeting that the $3.50 assessment was for local 706 members only and that it was 62255-61- -17 an assessment according to the bylaws of local 706. He further stated at this meeting that all of the fitters who were working on the job who belonged to other locals or who did not belong to any local were not required to pay this assessment into local 706, but that local 706 would accept same only as a voluntary contribution. He made this statement very emphatically and everybody at this meeting understood it. I remember definitely that Ray Chambless, of Pine Bluff, Ark., and Dave Dove, of Little Rock, Ark., the business agents of the Pine Bluff and Little Rock locals, respectively, were there, and I am sure they heard Mr. Griffin make this statement concerning the payment of this $3.50 per week. I also remember attending another meeting at Pine Bluff, Ark., which was called by the officers of local 706. This meeting was held in a park near the jobsite and was attended by several hundred of the pipefitters who were on the job. Mr. J. C. Swailes, of local 706, presided at this meeting and he introduced Mr. Earl Griffin and Mr. Griffin then explained thoroughly to all of the people present that the nonmembers of local 706 were not required to pay the assessment of $3.50 per week in order to hold their jobs there. Mr. Griffin made this very plain to all persons present and there could be no misunderstanding of this. As a matter of fact, Mr. Griffin made the statement that if anyone on the job had paid any money into local 706 with the misunderstanding that they were required to do so that if they would give him their names then or come to the office and give him their names and how much they had paid in, that he would refund this money to them if they so desired. It was definitely understood by everybody who could understand English that nonmembers of local 706 were not required to pay any money into local 706 in order to hold their jobs there. I have read the foregoing statement and it is true and correct to the best of my knowledge and belief. O. B. COONRADT. Subscribed and sworn to before me this 5th day of October 1960. [SEAL] My commission expires September 4, 1963. C. H. USHERY, Notary Public. EXHIBIT No. 51 STATE OF ARKANSAS, County of Union, ss: AFFIDAVIT OF ROY A. YARBROUGH My name is Roy A. Yarbrough and I reside at 522 North Parkway in El Dorado, Ark. I am at the present time employed on the Blaw-Knox job at the International Paper Co. in Pine Bluff, Ark. During 1951 to 1954, I was a member of local union No. 665 and I worked for Blaw-Knox during the construction of the Pine Bluff Arsenal for approximately 6 weeks during its construction between 1951 and 1954. While I was working on the job I paid $3.50 per week to local 706 as a voluntary contribution to help defray the expenses of policing the job inasmuch as local union 706 had jurisdiction over the job and I felt it was right for me to make this voluntary contribution. At no time did anyone ever tell me that I had to pay this money. At no time was I ever approached and told that if I did not pay the money that I would not be permitted to work there and at no time was I ever discriminated against or threatened to be discriminated against because I did not desire to pay the money, but I paid the money voluntarily of my own free will and accord. I left the Blaw-Knox job on the arsenal to go back to Paducah, Ky., to work up there because they were working longer hours in Paducah, Ky., and I could make more money up there. I was working in the same crew with another man out there from Little Rock, Ark., who did not pay anything and nothing was ever done about him not paying anything and he was never discriminated against in any way, shape, form, or fashion. I have read the foregoing statement and it is true and correct to the best of my knowledge and belief. ROY A. YARBROUGH. HOMER C. WALTON, Notary Public. Subscribed and sworn to before me this 8th day of October 1960. [SEAL] My commission expires April 8, 1961. 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. Under the bylaws of local 706, each member, when he has been employed for a week, pays a $3.50 working assessment for that particular week. This working assessment is not due if the member does not work in any week. The members 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, County of Union, ss: EXHIBIT No. 54 AFFIDAVIT OF GEORGE MORGAN 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 |