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Appendix D: Facilitated Grievance Process re: Vacation Scheduling

January 6, 2004
Steven P. Richards, President
BNG Local 31245

Re: Side letter on Facilitated Grievance Process (Article V, Section 2E, 'Vacation Scheduling')

Dear Steve:

This will confirm that the parties have agreed to the following special grievance/arbitration process for grievances filed pursuant to Article V, Section 2E, Vacation Scheduling:

1. Grievances arising under this section shall be filed and heard pursuant to Article XI, Sections 2(D) and 3.

2. If the grievance is denied, and the Union wishes to facilitate the arbitration process pursuant to steps 3 through 6 below, the Union shall file for arbitration with the AAA within 7 days of the Globe's response. Otherwise, the parties shall follow Article XI, Section 3 and the AAA's then Rules for Labor Arbitration.

3. The AAA shall provide the parties with one list of 5 arbitrators, which the parties must rank in order of preference pursuant to AAA Rules for Labor Arbitrations.

4. The selected arbitrator shall schedule the case promptly but in no event shall it be scheduled later than 30 days after he/she is selected.

5. The parties may file written closing statements of no more than 10 pages within 3 business days of the close of the hearing.

6. The arbitrator shall issue his/her decision within 3 business days of the close of the hearing or the filing of written statements, whichever is later. Very truly yours,

Gregory L. Thornton

AGREED:_____________________
Steven P. Richards, President
BNG Local 31245

January 25, 2001