KATHERINE FOLDES Contract Attorney 503-641-7010 Project List to 2000 CONTRACT LAW Application of Arbitration to Joint Venture Book Publishing Contract Restitution-Appropriate Remedy Where There is an Underlying Express Contract Waiver of Building Contract Provision Requiring All Supplemental Agreements to be in Writing Effect on Bailment Contract of Unreasonable Terms Included in Disclaimer of Liability Shipper Liability Under the Uniform Bill of Lading Act Where Shipper and Broker Have Contract Varying the Terms Thereof Are Standardized Contracts Binding? Is There a Cause of Action for Unfair Specification or Unfair Procedures in Developing Specifications in Public Contract Bidding? Counterclaim-Breach of Contract Remedies for Breach of Contract for Sale of a Business Breach of Contract for Sale of Business for Non-payment of Installment Answer and Counterclaim for Breach of Contract, Conversion and Unlawful Trade Practices Complaint- Amount Owing After Termination of Distribution Agreement Validity of Option, Promissory Note and Contract in Connection with Purchase of Professional Practice Complaint-Breach of Contract to Manage a Business Complaint- Breach of Covenant of Good Faith, Price Discrimination Complaint- Breach of Distributorship Agreement Complaint- Breach of Attorney Fee Agreement Pre-hearing Statement of Proof- contractor damage to property Complaint- negligent installation of oil tank Demand for Arbitration- poor workmanship in constructing barn Trial memo- attorney fee provision Punitive damages under NY law in breach of contract action Trial memo- breach of contract and negligence arising from underground fuel tank installation A Gift Horse REAL PROPERTY LAW Easements- Does an Implied Promise to Share Maintenance Costs Accompany an Express Easement? Complaint- Foreclosure Constructive Notice to Trust Deed Holder in County Where Property is Located Where Deed Not Recorded. Who Owns the Property? Easement Rights for Private Railroad Crossings BFP Where Title Insurance showed Clear Title but Judicial Lien Was Recorded Can the Beneficiary's Assignor Sue the Beneficiary of a Trust Deed For a Deficiency? Statute of Limitations in Real Estate Transactions Validity of By-law Dedicating One Unit of Condominiums to Management Office Validity of l0-year Commercial Lease-Renewability Lease/Option Where Lessor Seeks to Repudiate Contract but Accept Rent on a Month to Month Basis Defenses to Suit by Mortgagee of Purchaser's Interest in Land Sale Contract Elements of Condemnation for Limiting Access to Commercial Property During Highway Maintenance Grounds for Terminating Residential Lease by Tenant Response to Motion To Dismiss Complaint-Breach of Contract for Sale of Real Property Plat as Establishing Boundaries in Adverse Possession Case Subordination of Vendor's Lien Notice Required by Land Sale Contract Before Foreclosure Memorandum on Mandamus, Injunction, Writ of Review To Require City to Enforce Condition of Approval Complaint-to Force City to Enforce Condition of Approval of Development Permit Response to Motion to Dismiss Mandatory Injunction Response to Motion for Summary Judgment- Action to Enforce Condition Draft of Judgment- Land Use Case Sale of Houseboat, Lease of Slip Where No Proper Zoning Approval Defenses to Suit by Mortgagee of Purchaser's Interest in a Land Sale Contract Valuation by Lot in Condemnation Proceeding for Preliminary Subdivision Counterclaims to FED Delay in Seeking Foreclosure Execution on co-Vendor's Interest in Land Sale Contract Vendor's Duty of Disclosure to Vendee Memo in Opposition to Motion to Dismiss Slander of Title Claim Cross-claim for Destruction of Easement Complaint-Rent and Damage to Premises Encroachment of Real Property Boundary Supplemental Memo in Support of Contempt Motion- Land Use Agreement to Release Mutual Easements When Does an Agreement to Donate Property Become Effective so as to Give Donee a Right to Proceeds of Sale? Adverse Possession of Mutual Patio- Broker Liability Municipal Liability for Negligent Building Inspection Is Self-Help a Remedy in Enforcing a Restrictive Covenant? Constructive Eviction from co-tenant’s smoke odor Municipality’s duty upon discovery of asbestos in city hall DEBTOR/CREDITOR LAW Statute of Limitations in California for Fraudulent Conveyance Action Commingling Lienable and Nonlienable Items Defense of Failure of Consideration Against Holder of a Note Perfection of Security Interest in Shares of Stock Under the U.C.C. Elements of Fraudulent Conveyances Prior to the Uniform Act Future Earnings From Insurance Renewals as Part of the Bankrupt's Estate Standards for Waiver of Liability for Veterans Who Allow Assumption of V.A. Loan Where Transferee Defaults Prior Bankruptcy of Co-Debtor as Bar to Lawsuit on the Debt Where Debt Was Not Scheduled Interest on Physician's Bills Is an Assignment Made and Signed on the Back of a Promissory Not an Indorsement? Writ of Execution, Petition for Sale of a Residence Lien Foreclosure Complaint Complaint-Fraudulent Conveyance Best Method to Enforce Judicial Lien that Survived Bankruptcy Execution on Assets of Judgment Debtor Including Wage Order and Charging Partnership Order Can a Creditor Attach the Bank Account of the Judgment Debtor's Wife? Notice Provisions for Re-opening Bankruptcy; Effect and Sanctions for Violation of Injunction Against Further Proceedings on Discharged Debt Did Judgment Lien on Family Home Survive Separate Bankruptcies of Divorced Spouses? Preparation of Questions for Debtor's Exam Complaint-Validity of Lien in Bankruptcy Notice to Estate of Claim Based on Pending Lawsuit Investigation of Reasonableness of Amount of Construction Lien Lien on Pension Does Not Survive Spouse's Bankruptcy Response to Rule 2l Motions on Unreasonable Delay in Disposition of Collateral Under U.C.C. Validity of Option, Promissory Note and Contract in Connection with Purchase of Professional Practice Answer based on Fair Debt Practices Act Fraudulent Conveyances- Reasonably Equivalent Value and Transfers in the Ordinary Course Complaint-Claim and Delivery Based on Lease of Medical Equipment; A Series of Contracts; Provisional Process Documents Motion for Summary Judgment: Claim and Delivery Pre-Hearing Statements of Proof in Collection Cases Renewal of Judgment Jury Instructions: Fraudulent Conveyance, Veil Piercing Drafted Commercial Loan Documents, Pledge Agreement, UCC Statement Answer-Fraudulent Conveyance Enforcing Oregon Money Judgment in Washington Renewing and Reviving Debt & Enforcement of Equitable Lien Duty of Subsequent attorney to contest prior attorney’s lien in current case Wrongful imposition of lien Does automatic stay apply to individual when his corporation files for bankruptcy? Priority in hospital liens DOMESTIC RELATIONS LAW Trial Memo on Willful Desertion and Neglect in Contested Adoption Jurisdiction Under the UCCJA Are Veterans' Benefits Subject To State Court Orders for Spousal Support? Are Assets Purchased With Them Marital Assets? Attorney Fees in Contempt Case Where Contemnor Purges Before Trial Can a Third Party be Joined as a Party Defendant in a Dissolution and Can That Party's Property be Encumbered? Past Support as Part of Child Support in Paternity Case Response to Motion- Civil Contempt Enforceability of Marital Property Settlement Agreement for Half Equity in Family Home Defense of Inability to Pay on Contempt for Failure to Pay Child Support Trial Memo- Contested Custody, Child Support, Restricted Visitation Circumstances Justifying Restriction of Visitation or Supervised Visitation Index Deposition- Dom. Rel. Grandparents Custodial Rights in Juvenile Court Dependency Case Contempt for Failure to Pay Property Taxes on Time How to Enforce Support Order Where Respondent Lives in England Supplementary Response on Distinction Between Civil and Criminal Contempt Validity of Uncle/Niece Marriage Effect of Remarriage on Permanent Spousal Support and on Custodial Parent's Child Support Trial Memo-Status-Quo Order Digest Deposition- Domestic Relations Guardianship Proceeding- Notices Trial Memo-Contested Custody Petition, Show Cause, Restraining Order for Maintenance of Status Quo in Dissolution Guardianship Petition Court's Authority to Award Support for Adult Child Attending School Contempt Procedure for Failure to Designate Beneficiaries in Life Insurance Per Dissolution Decree Short-term Marriage but Long-term Cohabitation- Inheritance as a Marital Asset Motion to Dismiss, Order and Affidavit- Property Division Not Modifiable Valuation of Stock Options and Unvested Pension Rights Draft Separation Agreement Emancipation of Minors Complaint- Dissolution of Domestic Partnership Joint Venture Agreement for Domestic Partnership Valuing Pension Rights in Divorce Trial Memorandum- Dissolution Memorandum in Support of Motion to Dismiss Based on UCCJA , Improper Procedure, No Proof of Mediation Pension Benefits in Short-term Marriage; Allocation of Appreciation of Assets Voluntary Payment of Extra Child Support- Effect on Arrearage Motion to Set Aside Modification of Spousal Support Right to Claim 5th Amendment Immunity in Domestic Relations Deposition Execution on Real Property of Husband co-owned with Girlfriend; Duties of Title Company to Notify Judicial Lienholder of Sale Trial Memo-Inheritance During Separation,7 yr. Marr., Sp. Supp. Motion to Dismiss- UCCJA Motion to Dismiss-Lack of Personal Jurisdiction & Failure to Meet Domicile or Residency Requirement. Trial Memo- Contested Custody Veterans Benefits, Are they Subject to State Court Orders? Are Assets Purchased With Them Marital Assets? Discovery of Parent's Living Beyond Means Trial Memo-One Spouse Incarcerated for Assault on the Other, Effect on Property Division, Spousal Support Ability of a Spouse To Adopt Without the Consent of the Other Show Cause Re: Modification Based on Custodial Parent's Move From the State Custody to Grandparents in Juvenile Court Dependency Case. Trial Memo- Restricted Visitation Writ of Execution, Sale of a Residence Validity of Antenuptial Agreement Memo in Opposition to Motion to Dismiss Based on UCCJA Memo in Opposition to Rebuttal of Support Formula Hearing Memo-Duty of Non-Custodial Parent to Support Adult Disabled Child Inheritance as Marital Property Motion to Dismiss Contempt Trial Memo- Oral Promise to Reconvey Real Property to Parent, Community Property and Conflict of Laws Trial memo- non-authorized criteria to rebut child support guideline amount Status Quo Order Trial memo-contempt for failure to comply with decree re: COBRA Renewal of Spousal support when decree and property settlement don’t agree on duration Contempt Proceeding-Disobedience of visitation provision Right to Child Support under Wash. decree that did not provide any for ages 18-21 Petition for Guardianship of a Minor Personal Injury Recoveries- Marital Property or Not Can rights to insurance, cost of birth be recovered in administrative hearing for filiation? Recent cases on valuation of a business Expectation of an inheritance- marital property or not? Habeas Corpus in child custody Can wife be complainant for crime of bigamy if husband took more another wife in country where this is legal? Dissolution or annulment- immigration fraud claim Step-parent visitation PERSONAL INJURY LAW Assignment of Claim of Plaintiff Against Second Tortfeasor Complaint- Non-auto Negligence Against City Defendant Case Evaluation-Breach of Confidentiality , Invasion of Privacy and Defamation of Media by Opinion with Unstated Defamatory Facts Complaint- Non-auto Negligence Against City Defendant Privilege to Slander in Affidavit Interference With Economic Relations-Effect of Sexual Relationship Between the Parties Complaint- Personal Injury Non-auto, on Public Property Duties of Parent-Accessibility of Minors to BB Guns Witness Interviews-Timber Trespass Witness Interviews- Boating Accident, Auto Accident, Bus Accident, Loss of Wages Complaint- False Arrest, Malicious Prosecution, Battery, Negligence Find and Interview Witnesses to Phantom Vehicle Accident Preparation of Deposition Questions in Deposition of Lawyer in Legal Malpractice Witness Interview- Personal Injury Liability for City for Failure to Inspect Sidewalks Publicity of Private Facts Rule 2l Motion and Answer to Trespass and Removal of Vegetation Claim Malpractice Liability for Hospital and Psychiatrist for Minor Who Runs Away While on Leave from Hospital 40 Tort Complaints for Subrogation Law of Nuisance for Interference with Aesthetic Sensibilities Elements of Common Law Indemnity and Relation to Contribution Effect of Obtaining a Judgment Against One Tortfeasor on a Separate Action Against a Concurrent Tortfeasor Negligent Entrustment-Dog Bite Case Act of God in Relation to Personal Injury Does Worker's Comp. Have a Lien Against a Worker's Malpractice Claim? Standard of Car for Highway Repair Contract Workers Jury Instructions-Federal Court Personal Injury Case Statute of Limitations in Washington for Emotional Distress Claim Punitive Damages for Herbicide Spill Liability of Landowner to Tenant's Child for Defect on Grounds Counterclaim and Cross-claim in Fraud Case Involving Jointly Owned Rental Property Jury Instructions-Wrongful Death Motions in Limine- Evidence of Safety Violations at Other Plants, Physical Evidence That Has Been Materially Changed Seat Belt Restraints on City Buses Applicability of OSHA Standards in Oregon and Oregon Safety Code Punitive Damages for Conversion Complaint- Personal Injury, Auto Business Torts- Exclusion from Joint Venture. Damages. Demand Letter for Psychiatric Malpractice Elements of Tortious Interference With Prospective Business Advantage Complaint- PI auto with Negl. Entrustment and Family Purpose Motion for Summ. Jud.-Assault, Battery & Trespass Client Preparation for Trial- whiplash Products Liability-is Modifier of Product Liable? Subsequent Injury Caused By Impaired Physical Condition due to Negligence Liability of Wa. Hotelowner for Near Drowning Admissibility of evidence of Tavern Owner Serving Others Later Arrested Appropriateness of Special Verdict Form in Dram Shop Case Products Liability-Liability of Bailor of Machinery Complaint- Dog Bite Effect of Black Ice on Liability for Collision Slip and Fall Standards in Washington Response to Rule 21 Motion- Legal Malpractice. Amended Complaint. Witness Interviews: Boat Accident Apportionment Among Dependents of Wrongful Death Settlement Complaint-Consumer Fraud Complaint- Domestic Tort Loss of Consortium Liability of Franchisor for Injuries Sustained on Franchisee's Premises Complaint- Nuisance, Trespass and Intentional Infliction of E.D. Complaint- Personal Injury and Product Liability Complaint- False Arrest, Malicious Prosecution Apportionment of Wrongful Death Settlement Complaint- Non-auto Injury against Municipality Ski Accident Liability Burden of Proof in PIP Arbitration Intentional Infliction of Emotional Distress: Showing Video of Plaintiff's Accident Slip and Fall-Non-Delegable Duty Complaint and Response to Rule 21 - Negligent Entrustment and Punitive Damages Obese Patient and Hospital Negligence Does Brush Regulation Apply to Nonresidential Property? Complaint- Handicap Discrimination and Hospital Negligence Complaint- auto- pedestrian Response to Mot. for Summ. Jud-family purpose doctrine applicable to 20 year old with no permanent address Response to Summ. Jud- master/servant relationship? Non-delegable duty of landlord to injured worker of tenant; control of premises during improvements Response to Mot. to Dismiss- Strict liability for Ultra hazardous activity Liability for Dog Knocking Down Bicyclist PARTNERSHIP AND CORPORATIONS Piercing the Corporate Veil Exclusive Use of Surname as Assumed Business Name Shareholder's Rights Vis-à-vis Equal Shareholder. Breach of Fiduciary Duty of Corporate President Construction Corporation’s Duty to Pay for Worker's Compensation Motion for Summary Judgment-Partnership Status and Date of Dissolution Piercing the Corporate Veil Buy-Sell Agreement Considerations for Closely Held Corporation Right to Use of Business Names in Oregon Buy-Sell Agreement Piercing the Corporate Veil Complaint-Breach of Joint Venture Agreement, Accounting, Inducing a Breach of Fiduciary Duty, Conversion Business Torts- Exclusion from Joint Venture, Damages Answer based on Piercing Corporate Veil Non-profit Corporation Restriction on Proxy Voting Rule 21 Motion-Piercing the Corporate Veil Application of Arbitration to Joint Venture Effect of Sexual Relationship on Interference with Economic Relations Claim Rule 21 Motion- Covenant Not to Compete Procedures to Establish Trademark Inducing a Competitor's Employee to Leave: Exploiting Customer List PROBATE/TRUSTS Apportionment Among Dependents of Wrongful Death Settlement Petition and Notice for Sale of Residence by Conservator Ethics of Contingent Fee Agreements in Probate Cases Apportionment Among Dependents , Wrongful Death Settlement Inheritance Tax Consequences of Will Contest Settlement Does Estate Owe Reasonable Compensation to Non-relative Caretaker? Revision of Inter-vivos Trust to Include Standby Trust Provisions Plaintiff's Recovery of Costs of Litigation for Recovery of Assets Into Probate Estate Ambiguous Designation of Beneficiary of Life Insurance Policy Transfer of Stock to Heirs Upon Termination of Trust; Proper Probate of Estate of Beneficiary of Trust; Termination of Trust Causes of Action Where Decedent Transfers All of Estate to One Adult Child During Her Lifetime Order for Purchase of Real Property by Conservator Interview P.R. re: Estate, Care Plan for P.R. Directive to Physician, Durable Power of Attorney For Health Care Petition and Inventory for Probate Washington State Spendthrift Clause Guardianship for Minor Temporary Guardianship for Incapacitated Person Objection to Appointment of Parent as P.R., Apportionment of Wrongful Death Award to Custodial/Non-custodial parent Right of State to Impose Lien on wife’s small estate for nursing home costs of husband Procedure for staying ancillary probate Letter denying claim When is partial distribution of an estate appropriate and how is it done? Calculation of Surviving Spouse’s Elective Share MISCELLANEOUS INS Access to Police Computerized Criminal Offender Information Witness Interviews- Special Education Case Grounds for Dismissing Pesticide Regulation Citation Valuation by Lot in Condemnation Proceeding For Preliminary Subdivision Sovereign Immunity and Jurisdiction in Civil Case Where Defendant is an Indian Tribe Research City Ordinance Re: Drive Yourself Car Agencies Grounds for Dismissing Pesticide Law Citation Fair Use Privilege for Copying Video Cassettes Retroactive Effect of Statutes Interpleader Complaint Discovery Documents- Review,Organize, and Identify Relevant Documents in Legal Malpractice Case; Index Depositions Jury Instructions-State Court Wrongful Death Case Timeliness in Motion for New Trial Based on New Court of Appeals Criminal Decision Assignment of Judgment Draft Municipal Water Ordinance Automatic Interest on Judgments Denial of Disability Insurance by Private Insurer for Pre-existing Condition Can a Corporation of Majority Stockholder Force a Minority Shareholder to Tender His Shares? City Ordinance re: Drive Yourself Car Agencies Grounds for Dismissing Pesticide Law Citation Continuing Care Contracts Draft Petition-Expungement of Class C Felony DEFENSES AND PROCEDURAL ISSUES Response to Rule 2l Motion- Interference with Economic Relations, Civil Conspiracy, Inducing a Breach of Fiduciary Duty Statute of Limitations on Damage to Personal Property Defense of Laches Duty of Good Faith and Fair Dealing in Contracts; Waiver and Estoppel as Applied to Government Entities Part Payment and Improvements on Land as Affecting Statute of Frauds Res Judicata and Estoppel of Dissolution findings in Interspousal Tort Case Motion to Dismiss-Defenses to Attorney Malpractice Uncollectibility Defense to Legal Malpractice Attorney Fee Motion- Federal Court Trial Consulting- Several Personal Injury Plaintiff's and Witnesses Response to Summary Judgment Motion- Auto Dealer Fraud Motion to Dismiss Based on Amount in Controversy- Diversity Jurisdiction Motion to Compel Discovery-Work Product and Attorney/Client Privilege Motion and Memorandum to Compel Deponent to Answer Questions Re; Consent Decree and Prior Lawsuit in Federal Copyright Case Subpoena; County in Which Person Must Appear Minimum Contacts-Can Judge Rule One Type of Claim Meets Requirement But Not Another? Venue in Action for Indemnification Memorandum in Support of Motion to Compel Production of Tangible Thing; Motion in Limine Motion and Order for Perpetuating Testimony Reply to Federal Court Motion to Dismiss Motion, Order and Affidavit to Compel Deposition and For Sanctions Motion, Order and Affidavit to Restore to Trial Calendar Motion, Order, Affidavit to Dismiss-Res Judicata Motion , Order and Affidavit to Postpone Trial Motion for Production; Motion for Admissions Two Motions for Psychiatric Exam Objection to Motion for Perpetuation Testimony by Phone Standing for Claim on Insurance Bond Against Auto Dealership Ability to Limit Testimony of Expert Who did Not Prepare During Discovery Period Request for Admissions Statute of Limitations for Emotional Distress Claim in Washington Response to Motion for Summary Judgment for Failure to Join Proper Party Motion for Leave to Amend to Substitute Proper Party Reply to Objection for Leave to Amend Judge's Discretion to Control Order of Proof Fees for Deposition of IME Physician Voluntary Dismissal and Attorney Fees Discovery of Customer List By Defendant Alleged to Have Taken List Statute of limitations as Bar to Recovery if Mailing After DMV Service Isn't within 60 Days Proper Forum and Statute of Limitation for Negligent Act Between Oregon Residents but Occurring in California Motion to Consolidate Request for Production, Supplemental Memo in Support of Motion for Leave to Amend Response to Motion to Dismiss for Failure to Produce Medical Records Federal Standard for Admissibility of Scientific Facts Is the Same Jury Necessary in Bifurcated Personal Injury Trial? Effect of Default Judgment on Defendant who is Vicariously Liable Summ Judgment Motion Based on Issue Preclusion and Failure to Meet Elements of Interference with Contract Subpoena Duces Tecum- Witness Fees for a Party? Review Pre-Trial Order Motion to Compel Deposition in ERISA case Motion For Emergency Relief to Oregon Supreme Court Motion for Protective Order Motion to Compel Substitution of Proper Defendant After Statute of Limitations Has Run Motion in Limine-other injuries, alcoholism and court marshall Admission of Subsequent Bad Acts Discovery of Witness Lists Admissibility of Admission of a Party’s Employee Admissibility of Owner’s Opinion of diminution of value due to poor workmanship Dismissal for Improper Venue? How to Subpoena Records from a Federal Agency Waiver of Work Product Privilege Personal Jurisdiction in state and federal court for Non-resident defendant Response to Motion to Quash Subpoena CRIMINAL LAW Memorandum in Support of Objection to Refusal of Diversion Trial brief-DUII Prosecutorial Immunity, Does it Apply to Probation Officer's Failure to Rescind Warrant? Demurrer Based on Statute of Limitations Where Time-barred Prior to Extension of the Statute EMPLOYMENT LAW Considering Pension Eligibility in RIF of U.S. employees Elements of State Tort Claims for Sexual Harassment Fringe Benefits as Part of Back Pay Award; Computing Award What Constitutes Constructive Rather Than Actual Discharge in At- Will Employment? Waiver and Estoppel as Applied to Union Trust Funds Admissibility of Statements of Employees As Admissions By Party Opponent Witness Interviews- Discrimination Remedy for Violation of Reinstatement Rights of Union Post-strike Employees Rule 2l Motion-Wrongful Discharge Based on Safety Violation Affidavit Preparation for Summary Judgment Motion Complaint- Wrongful Discharge, Race Discrimination Employment Discrimination- Case Evaluation , Preparation of Response to Defenses Analysis of Contract Rights of At-Will Employee Answer-Sex Discrimination Effect of Worker's Compensation Claim on Sexual Harassment Remedies Summary Judgment- Union Caused Supervisor's Discharge Review and Comment on Proposed Personnel Manual for Non-profit Corporation Constructive Discharge Law in Oregon Can a Union File for Bankruptcy Protection? Under What Circumstances will an International Union Take Over a Local Union? Response to Union's Summary Judgment Motion in Same Action Are Personnel Files Discoverable in a Sexual Harassment Case? Motion for Summary Judgment Where Supervisor Terminated for Failure to Pay Union Dues Eleventh Amendment as a Bar to Indemnification Claim for State Employee Charged with Sexual Harassment Are Attorney Fees Available to Defendants Under 42 USC l988? Enforceability of Covenants Not To Compete Injunction to Enforce Non-competition agreement Where Contract Calls for Arbitration Complaint- Sexual Harassment and Retaliation State tort Claims for Sexual Harassment Is Worker's Comp Procedure Exclusive Remedy for Termination for Filing Worker's Comp Claim? Constructive Discharge in Oregon Can A Union File For Bankruptcy? Under What Circumstances can an International Union Take Over a Local? Motion for Summary Judgment and Response to Opposing Motion- ERISA Longterm Disability Benefit Denial Complaint- Age Discrimination and Sexual Harassment Legislative History of Tort Claims Act and ORS 17.035 in Regard to Validity of Release of Claim Complaint-Breach of Duty of Fair Representation Complaint- wrongful Discharge- Refusal to Reinstate Injured Worker Response to Mot. for Summ Jud- Duty of Fair Rep. Can International Union be Joined in Whistleblower Suit? Response to Mot. for Summ. Jud- Is meeting of minds required on personnel policy handbook?
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