Communication Workers of America

October 30, 2007

Bruce Nigro, Director, Director
Essex County Division of Welfare
18 Rector Street , Floor 9
Newark , NJ , 07102

Step II Class Action Contractual Grievance
Administrative Interference in Negotiations
Article I. Purpose
Article XXV. Non-Discrimination
Article XXV. Negotiation Procedure

Dear Mr. Nigro:

CWA Local 1081 submits this Step II Class Action Contractual Grievance on behalf of all of our members who have received the attached two letters mailed to their respective abodes, on October 9, 2007 and October 25, 2007, as authored by Essex County Administrator Joyce Wilson Harley, Esq.

Within her letter of October 9, 2007, Ms. Wilson Harley alludes to a purported "financial crises" regarding "the cost of providing health and prescription benefits" and how her office "in conjunction with our benefits consultants and other experts is now drafting options that will be presented to each Union leader" and that "I need your help and partnership in working cooperatively to make the changes needed to protect the financial stability of our benefit plans for years to come".

Within Ms. Ms. Wilson Harley's letter of October 25, 2007, she alludes to the Administration having "met on two separate occasions with the leadership of the various unions" and that "In order to respond to the many questions that have been raised in the two meetings and in casual meetings in the halls of Essex County, I have developed the attached Fact vs. Fiction Sheet".

CWA Local 1081 held our Union's first formal negotiations session with the Administration of Essex County Executive Joseph DiVincenzo on Tuesday, October 23, 2007, or two days prior to the construct and mailing of Ms. Wilson Harley's letter of October 25, 2007 sent all employees of the County of Essex .

No matter perhaps how well they might have been intended, CWA Local 1081 considers both of Ms. Wilson Harley's abovementioned letters to be violative of the above cited articles of our contract and the applicable statutes of the State of New Jersey inasmuch as they may influence our Union's members' decisions regarding their currently-being-negotiated contract, particularly and specifically regarding their health benefits and prescription coverage.

The resolution CWA Local 1081 respectfully demands to this grievance consists of the following:

1. Ms. Wilson Farley, and all representatives of the Administration, shall cease and desist from issuing any further mailings to the members of CWA Local 1081 that reference in any manner matters that are part of the negotiations process.

2. Ms. Wilson Farley, and all representatives of the Administration, shall cease and desist from holding any "casual meetings in the halls of Essex County " or anywhere else with members of CWA Local 1081 that entail in any manner matters that are part of the negotiations process.

3. The County of Essex shall herein acknowledge that its failure to abide by the first two parts of the resolution of this grievance demanded by our Union may result in our litigating the topic within the appropriate venue.

Sincerely,

David H. Weiner, President CWA Local 1081

C: Joseph DiVincenzo
Joyce Wilson Harley, Esq.
Dolores Capetola, Esq.
Anibal Ramos
Bruce Nigro
Lynn Buckley
Stephen Weissman, Esq.