UNITED STATES OF AMERICA
                     BEFORE THE NATIONAL LABOR RELATIONS BOARD
                                      REGION 2


_____________________________________
WBAI Pacifica Foundation,            |
                                     |
         Employer-Petitioner,        |             Case Nos. 2-UC-496 and
                                     |                       2-UC-517
                                     |
                                     |
and                                  |
                                     |
United Electrical, Radio & Machine   |
Workers of America (UE), and its     |
Local 404,(1)                        |
                                     |
         Union                       |
                                     |
_____________________________________|



                   BRIEF ON BEHALF OF UNITED ELECTRICAL, RADIO &
                        MACHINE WORKERS AND ITS LOCAL 404

1.       INTRODUCTION

         On November 1, 1995, the Petitioner, WBAI Pacifica Foundation ("WBAI" or the 

"Employer-Petitioner' herein), filed a unit clarification petition in Case No. 2-UC-496

seeking to exclude as managerial or confidential employees the following positions: development 

director, business director, crafts fair director, business manager, and bookkeeper.

         On May 3, 1996(2), the Employer-Petitioner filed the unit clafification petition in

Case 2UC-517 seeking to exclude "unpaid volunteers, temporary employees, guards, and 

supervisors" as
_______________________________________________________
     (1)   The Union moves to amend the name of the exclusive bargaining representative to
correctly reflect the United Electrical, Radio and Machine Workers of America (UE) and its Local
404.

     (2)   All dates referred to herein are in 1996, unless expressly stated otherwise.

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