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only guess at what that would total.(13) According to the two invoices provided the Union 
(supplement to the record), one unpaid staff member received $125 for work performed on July 12, 
13, and 14. Another received $40.00 for four hours work on June 15.  Based on payroll records
for the past year alone, several unpaid employees were paid substantial sums of money, For
example, Matthew Finch is an unpaid worker substituting for announcer Sheldon Walden
on a temporary basis.  (Ex.  E-2 ). In the six months from 12/29/95 through 6/30/96, he was
paid for each of the 12 pay-periods included and received a total of $6,627.41. During one
two week pay period, Finch received $1705.59. See week 20, page 12, period ending 05/15/96.
(Payroll records; unnumbered supplemented Employer Exhibit) Michael Haskins, an unpaid
staff who is not listed on the Employer's list of people who performed substitute work
during the period covered by the payroll records, appears regularly in the payroll records.
During the six month period from 1/51/96 to 6/30/96, he was paid $5047.54. In the two week
pay period ending 1/31/96 his gross pay exceeded $2300.00. Amy Goodman, who was not
included in the Employer's list of paid staff, full or half time (Ex. E-2), and does not appear
on the list of unpaid staff (Ex. E-4), is recorded on the payroll records as having received
$21,559.05 during the period 1/15/96 through 6/30/96.  Utrice Lead, described as an unpaid
staff doing interim work four days a week (T., p. 78 L. 24 -- p. 79 L. 2), received $15,000
during the same period.  Delphine Blue, an unpaid staff in an interim placement (Ex. E-2),
which by definition must end

_________________________________________________________________________

         13   As of 4:30 p.m., Tuesday, August 13, the Union had not received this information,
making it impossible for the Union to analyze or include this information in its brief Employer-
Petitioner's counsel told the Union in a telephone conversation on Monday, August 12, that the
material would be sent by fascimile later that same day.  Because the Employer-Petitioner has
not complied with the reasonable orders of the Hearing Officer, the Union moves to dismiss the
petitions in the instant case.


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