UNITED STATES OF AMERICA
`BEFORE THE NATIONAL LABOR RELATIONS BOARD
`REGION 28
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`RED ROCK RESORTS, INC.;
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`and
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`STATION HOLDCO LLC;
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`and
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`STATION CASINOS LLC;
`
`
`and
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`FP HOLDINGS, L.P. d/b/a
`PALMS CASINO RESORT AND PALMS PLACE, and
`FIESTA PARENTCO, L.L.C., General Partner;
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`
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`NP BOULDER LLC d/b/a
`BOULDER STATION HOTEL & CASINO;
`
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`and
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`and
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`NP FIESTA LLC d/b/a
`FIESTA RANCHO HOTEL & CASINO;
`
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`and
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`NP LAKE MEAD LLC d/b/a
`FIESTA HENDERSON CASINO HOTEL;
`
`
`and
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`NP PALACE LLC d/b/a
`PALACE STATION HOTEL & CASINO;
`
`
`and
`
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`NP RED ROCK LLC d/b/a
`RED ROCK CASINO, RESORT & SPA;
`
`
`and
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`

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`NP SANTA FE LLC d/b/a
`SANTA FE STATION HOTEL & CASINO;
`
`
`and
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`NP SUNSET LLC d/b/a
`SUNSET STATION HOTEL & CASINO;
`
`
`and
`
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`NP TEXAS LLC d/b/a
`TEXAS STATION GAMBLING HALL AND HOTEL;
`
`
`and
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`STATION GVR ACQUISITION, LLC d/b/a
`GREEN VALLEY RANCH RESORT SPA CASINO;
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`collectively, a Single Employer and
`Single Integrated Enterprise
`
`
`and
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`LOCAL JOINT EXECUTIVE BOARD OF LAS VEGAS a/w
`UNITE HERE INTERNATIONAL UNION
`
`and
`
`THOMAS STALLINGS, an Individual
`
`Party in Interest
`
`Cases 28-CA-228052
`28-CA-228944
`28-CA-247602
`28-CA-248464
`28-CA-249203
`28-CA-249576
`28-CA-251083
`28-CA-251254
`28-CA-251803
`28-CA-252404
`28-CA-252964
`28-CA-256630
`28-CA-257778
`28-CA-260167
`28-CA-260169
`28-CA-260187
`28-CA-260199
`28-CA-260207
`28-CA-260209
`28-CA-260216
`28-CA-261666
`28-CA-262465
`28-CA-262973
`28-CA-262977
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`

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`28-CA-262980
`28-CA-262982
`28-CA-262987
`28-CA-263582
`28-CA-264135
`28-CA-264297
`28-CA-264465
`28-CA-264469
`28-CA-264476
`28-CA-264612
`28-CA-264619
`28-CA-264626
`28-CA-264631
`28-CA-264638
`28-CA-266556
`28-CA-266987
`28-CA-267067
`28-CA-268930
`28-CA-268957
`28-CA-268958
`28-CA-268960
`28-CA-269516
`28-CA-269517
`28-CA-269519
`28-CA-269520
`28-CA-269959
`28-CA-269962
`28-CA-269965
`28-CA-271251
`28-CA-271608
`28-CA-273812
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`RED ROCK RESORTS, INC.;
`
`
`and
`
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`STATION HOLDCO LLC;
`
`
`and
`
`
`STATION CASINOS LLC;
`
`
`and
`
`
`NP SUNSET LLC d/b/a
`
`

`

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`
`
`Casess 28-CA-239331
`28-CA-247230
`28-CA-260724
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`
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`SUNSET STATION HOTEL & CASINO;
`
`and
`
`
`FP HOLDINGS, L.P. d/b/a
`PALMS CASINO RESORT AND PALMS PLACE, and
`FIESTA PARENTCO, L.L.C., General Partner;
`
`collectively, a Single Employer and
`Single Integrated Enterprise
`
`
`and
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`INTERNATIONAL UNION OF OPERATING ENGINEERS,
`LOCAL 501, AFL-CIO
`
`and
`
`THOMAS STALLINGS, an Individual
`
`
`Party in Interest
`
`
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`RED ROCK RESORTS, INC.;
`
`
`and
`
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`STATION HOLDCO LLC;
`
`
`and
`
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`STATION CASINOS LLC;
`
`
`and
`
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`NP TEXAS STATION LLC d/b/a TEXAS STATION
`GAMBLING HALL AND HOTEL;
`
`collectively, a Single Employer and Single Integrated
`Enterprise
`
`
`

`

`and
`
`
`MARIA SANJUANA ORTIZ, AN INDIVIDUAL
`
`Case 28-CA-245467
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`RED ROCK RESORTS, INC.;
`
`
`and
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`STATION HOLDCO LLC
`
`
`and
`
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`STATION CASINOS LLC;
`
`
`and
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`NP PALACE LLC LLC d/b/a PALACE STATION HOTEL &
`CASINO
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`collectively, a Single Employer and
`Single Integrated Enterprise
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`Case 28-CA-273936
`
`and
`
`BLAKE SAARI, AN INDIVIDUAL
`
`
`
`
`COUNSEL FOR THE GENERAL COUNSEL’S
`OPPOSITION TO RESPONDENT’S MOTION FOR PARTIAL
`RECONSIDERATION OF ORDER DENYING BILL OF PARTICULARS
`
`Counsel for the General Counsel (CGC) opposes Respondent’s Motion for Partial
`
`Reconsideration of Order Denying Bill of Particulars dated August 5, 2021. As discussed more
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`fully below, Respondent continues to seek information for which it is not entitled claiming that
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`its due process rights are jeopardized because it is unable to prepare a defense, citing
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`
`
`1
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`

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`Administrative Law Judge Amita B. Tracy’s1 Order dated July 29, 2021, which denied its initial
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`request for a bill of particulars, as authority for reconsideration. CGC requests that the ALJ,
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`again, deny Respondent’s attempt to obtain additional information as the Complaint in this
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`matter comports with the Board’s pleading requirements which puts Respondent on notice of the
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`serious nature of the unfair labor practice allegations lodged against it.
`
`I.
`
`BACKGROUND
`
`As described in the numerous pre-trial motions and responses filed thus far, this matter
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`involves allegations that Respondent engaged in serious and pervasive unfair labor practices
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`spanning an approximate three-year period in response to employees’ union organizing efforts,
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`in retaliation for other protected activity, and contrary to its obligation to bargain in good-faith
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`with employees’ exclusive collective-bargaining representatives, including Local Joint Executive
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`Board (LJEB) and the International Union of Operating Engineers, Local 501 (IUOE). The
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`Complaint, which issued on April 12, 2021, is extensive and Respondent denied that it engaged
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`in any unfair labor practices while raising 26 affirmative defenses in its Answer dated May 10,
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`2021.
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`On July 15, 2021, Respondent filed its Motion for a Bill of Particulars or, in the
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`Alternative, to Strike Allegations Not Pled with Sufficient Particularity to Provide Respondents
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`with Adequate Notice. In doing so, Respondent claimed countless complaint allegations were
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`woefully insufficient under the Board’s pleading standard while requesting information
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`evidentiary in nature much like a pre-trial discovery request. CGC filed an opposition to
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`Respondent’s request for a bill of particulars on July 27, 2021, which was joined by Charging
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`Party LJEB that same date.
`
`
`1 Hereinafter referred to as “the ALJ” or “Judge Tracy.”
`
`
`
`2
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`

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`On July 29, 2021, Judge Tracy issued an Order Denying Respondent’s Bill of Particulars
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`(Order), in sum, noting that the Complaint:
`
`“identifies the specific acts engaged in by Respondent that underlie the allegations
`and the dates on which such acts are alleged to have occurred; thus, it provides a
`clear and concise description of the particular acts which form the basis of the
`complaint. As such, I find that the complaint as drafted complies with the dictates
`of Section 102.15 of the Board’s Rules and is sufficiently precise to allow
`Respondent to investigate and prepare for trial.”
`
`Order at 7.
`
`On August 5, 2021, Respondent filed its Motion for Partial Reconsideration of Order
`
`
`
`
`Denying Bill of Particulars (Respondent’s Motion). Respondent generally seeks reconsideration
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`of its requests for additional information related to allegations that it discriminated against
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`employees through a host of adverse actions such as discharge, suspension, discipline, closer
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`supervision, failing to recall or rehire, or subjecting employees to more onerous working
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`conditions. Motion at 4-7. The majority of Respondent’s requests seek the identity of its
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`supervisors and/or agents that were involved in or responsible for the alleged conduct, asserting
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`that the National Labor Relations Board’s Rules and Regulations require the General Counsel to
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`disclose such information. Motion at 4-7 (Requests 1, 4-25). The remaining information sought
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`by Respondent includes more specific information about named actors2 (Requests 2-3), dates3
`
`
`2 Requests 2 and 3 seek the full names of the individuals identified by their first names as having engaged in conduct
`independently violating Section 8(a)(1) of the Act. The Complaint states that their last names are unknown. As
`recently discussed between CGC and Respondent’s Counsel, CGC’s best guess is that Complaint ¶ 6(ccc) refers to
`Alma Knight, a Porter in Internal Maintenance. However, this is not confirmed. Regardless, Respondent’s requests
`for the last names of individuals for which the Complaint clearly states are unknown to the General Counsel should
`be denied because CGC cannot provide what they do not have.
`
` The Complaint provides approximate dates for all allegations and as such, Respondent’s requests seeking more
`specific information about dates should be denied.
`
`
` 3
`
`
`
`3
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`

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`(Requests 8, 24), and locations4 (Requests 1, 10, 12, 15). CGC opposes Respondent’s Motion
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`for Reconsideration as the Complaint plainly comports with the Board’s notice-pleading
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`requirements. As discussed below, the General Counsel is not required to name actors in
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`conjunction with alleged discriminatory conduct as the breadth of Respondent’s Motion
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`contends.
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`II.
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`
`
`
` RESPONDENT’S MOTION FOR RECONSIDERATION SHOULD BE DENIED
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`A. The Complaint Comports with the Board’s Pleading Requirements
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`Respondent continues to seek information to which it is not entitled. In its pared-down
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`request for a bill of particulars, Respondent seeks the identity of supervisors responsible for in
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`the discriminatory conduct alleged in the Complaint, including who issued various disciplinary
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`actions,5 who announced or implemented rules allegedly used to discriminate against
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`employees,6 those “involved in” discharging named discriminatees,7 and the identity of
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`supervisors that took other specified adverse actions such as removing tip jars and subjecting
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`certain discriminatees to more onerous working conditions.8 Respondent seeks similar
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`information for 23 of its 25 requests. Motion at 4-7. In sum, Respondent claims that the ALJ
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`erroneously denied its initial request for a bill of particulars because, according to Respondent,
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`the black letter of Section 102.15 of the Board’s Rules and Regulations “explicitly establishes
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`4 The Complaint provides information about the locations of the alleged unfair labor practices by identifying which
`of Respondent’s facilities the conduct occurred, at a minimum. This is sufficient under the Board’s pleading
`standard. See Affinity Medical Center, 364 NLRB No. 67, slip op. at 2 (2016) (identifying which of the several
`medical centers the alleged conduct occurred was sufficient under Rule 102.15).
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` 5
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` Requests 1, 5 through 7, 11, 13, 15 through 17, 19, 20 and 23.
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` Request 4.
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` 6
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` 7
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` Requests 1, 4 through 7, 11, 13, and 23.
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`8 Requests 8 through 10, 12, 14, 18, 20 through 24.
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`4
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`

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`what factual pleadings are required to be included in a complaint,” including the names of its
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`supervisors and agents who committed the unfair labor practices. Motion at 3. Respondent also
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`cites Affinity Medical Center, 364 NLRB No. 67 (2016), and the ALJ’s order denying its request
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`for a bill of particulars as authority for its position. Motion at 3. However, although Respondent
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`claims that it “cannot be disputed” that all alleged conduct, including allegations of
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`discrimination in violation of Section 8(a)(3) of the Act, must include the “names of
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`Respondent’s agents or representatives accused of wrongdoing,”9 Respondent’s recitation of
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`Board law falls short of supporting its position.
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`Aside from highlighting the plain language in Section 102.15 of the Board’s Rules and
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`the ALJ’s summation of the rule, Respondent only offers Affinity Medical Center, 364 NLRB
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`No. 67 (2016) to support its position that names of supervisors are necessary in conjunction with
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`each allegation. Motion at 3-4. However, contrary to Respondent’s position, the Board’s ruling
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`in Affinity Medical Center does not go that far and is consistent with the authority cited in CGC’s
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`Opposition to Respondent’s Motion for a Bill of Particulars on this issue showing that the
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`General Counsel need not allege which one of Respondent’s personnel implemented the adverse
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`action or those that were involved in the decision making. CGC July 27 Opposition at 13-14
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`(relying on Florio Food Corp., 2017 WL 1462121 (Case No. 29-CA-187620) and Pro Custom
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`Solar LLC, 2021 WL 779991 (Case No. 22-CA-254647)); see also Mid-Atlantic Restaurant
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`Group LLC v. NLRB, 722 Fed. Appx. 284, 287 (3d Cir. 2018) (unpublished decision finding that
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`ALJ did not abuse discretion by denying bill of particulars despite omission of named actors for
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`discharge allegation).
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`9 Notably, the Complaint sets forth Respondent’s supervisors and agents within ¶4, which comports with the plain
`language of Section 102.15 of the Board’s Rules.
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`
`
`
`5
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`

`

`As Respondent points out, in Affinity Medical Center, the ALJ initially granted a
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`respondent’s request for a bill of particulars and the General Counsel provided additional
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`information regarding the names of the supervisors involved with the unilateral change
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`allegations at issue by way of offering a written amendment to the complaint. After the ALJ
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`dismissed the General Counsel’s written amendment, upon special appeal from the General
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`Counsel, the Board considered whether the ALJ erred in dismissing the amendment, and whether
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`the written amendment complied with the Board’s pleading requirements. According to
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`Respondent, the Board only reversed the ALJ’s ruling granting the bill of particulars because the
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`General Counsel’s amendment provided “necessary ‘names’ of supervisors and other details”
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`which mooted the need for a bill of particulars. Motion at 4.
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`However, Respondent’s interpretation of the Board’s ruling in Affinity Medical Center
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`ignores a crucial procedural point: The General Counsel did not challenge the ALJ’s initial ruling
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`on the obligation to provide more information through a bill of particulars. Id. at slip op. 1 n.4.
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`Thus, the sufficiency of the initial pleading that omitted the names of supervisors in conjunction
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`with the unilateral change allegation was not before the Board, nor was it considered to any
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`extent. Rather, the Affinity Medical Center Board merely decided that the subsequent written
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`amendment should have been received, and because the amendment contained the information
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`sought by the respondent in its request for a bill of particulars, reversed the ALJ’s order directing
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`the General Counsel to provide such information. Id. at slip op. 2-3. For this reason, Affinity
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`Medical Center is not controlling on the issue of whether supervisors and/or agents that are
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`otherwise identified in a complaint, as is the case here, must be specifically identified in
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`conjunction with allegations of discriminatory conduct or unlawful unilateral changes.
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`
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`6
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`

`

`Accordingly, the ALJ should, respectfully, reject Respondent’s reliance on Affinity Medical
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`Center in its continued effort to obtain information for which it is not entitled.10
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`Specifically, the ALJ should deny the following requests set forth in Respondent’s
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`Motion for Reconsideration seeking information identifying the supervisor(s) involved in
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`allegations of discriminatory conduct: Request 1 and Requests 4 through 25. The ALJ should
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`also, respectfully, deny Respondent’s requests for additional and more specific information
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`regarding Requests 2 and 3 because the Complaint already provides the information known to
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`the General Counsel. Similarly, the ALJ should deny Requests 1, 8, 10, 12, 15, and 24 seeking
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`additional and more specific information related to dates and locations because the information
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`contained in the Complaint provides Respondent notice of the approximate dates and locations of
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`the alleged conduct consistent with the Board’s pleading standard. In sum, the ALJ got it right
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`the first time by rejecting Respondent’s ploy to obtain impermissible pre-trial discovery and
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`should similarly deny Respondent’s motion for reconsideration.
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`
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`B. Respondent’s Due Process Claims Do Not Withstand Scrutiny
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`Respondent claims that it cannot prepare defenses to the allegations raised by the
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`Complaint because dozens of allegations “fail to provide the requisite ‘name’ of any alleged
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`agent or representative.” Motion at 8. According to Respondent, this leaves it to guesswork as
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`to who may have been involved in the incidents underlying the allegations at issue. Motion at 8.
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`Respondent further claims that because the Complaint covers conduct spanning over the course
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`of three years, its review of some records is difficult. Motion at 8. According to Respondent, the
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`10 Similarly, the ALJ should disregard Respondent’s haphazard attempt to distort CGC’s reliance on Affinity Medical
`Center to begin with. Aside from the proposition that identifying one of several facilities is sufficient notice to a
`respondent in terms of location (CGC July 27 Opposition at 8 n.6), CGC only cited to this case when describing the
`Board’s general pleading standard (CGC July Opposition at 5). As noted above, CGC relied on authority that
`actually controls this issue. See CGC July 27 Opposition at 13-14. Thus, Respondent’s whole argument suggesting
`that the ALJ’s ruling was erroneously decided because of “CGC’s prominent reliance on Affinity” (Motion at 2-4) is
`just another strawman worthy of flat rejection.
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`
`
`7
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`

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`forgoing, coupled with only general information about the location of various incidents, prevents
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`Respondent from mounting a coherent defense. Motion at 8. However, as discussed below,
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`Respondent’s claims are overblown.
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`First, although Respondent contends that reviewing some records is difficult given the
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`three-year period in which the allegations arise, Respondent failed to identify a single allegation
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`for which it is unable to locate relevant records. And, although Respondent highlights that some
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`allegations relate to verbal warnings, which it insinuates is even more difficult to lodge a defense
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`against (Motion at 8 n.3), Respondent is well-aware that it documents verbal warnings as part of
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`its progressive discipline policy. For example, Respondent presented a disciplinary record in the
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`recent Red Rock litigation showing a recorded verbal warning. See Exhibit A, attached. In fact,
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`Respondent’s disciplinary form includes a specific selection for verbal warnings. Id. Notably,
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`the form also includes the issuing supervisor’s signature along with the signature of a witness,
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`presumably present when the discipline is issued. Id. With operations as sophisticated as
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`Respondent’s, one would expect the ability to easily retrieve similar disciplinary records related
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`to the named discriminatees in the Complaint. Thus, Respondent can hardly contend that it is
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`left guessing how to defend against such allegations. Respondent need only retrieve the
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`record(s) and investigate the underlying circumstances based on the information it maintains.
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`Similarly, Respondent is capable of investigating the circumstances underlying
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`allegations that certain discriminatees were subjected to other forms of adverse actions that may
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`not be formally recorded within a progressive disciplinary record. For example, in Request No.
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`8, Respondent seeks the name of the person(s) who gave a certain discriminatee lower ratings on
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`her room inspections as alleged in Complaint ¶ 7(g). Based on the pleadings, Respondent knows
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`the name of the discriminatee, the position the discriminatee worked in, the facility at issue, the
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`
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`8
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`

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`approximate date that the conduct is alleged to have occurred, and the nature of the alleged
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`conduct (i.e., giving lower ratings on room inspections). But, according to Respondent, it is left
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`guessing as to what happened unless CGC provides the identity of its supervisors that were
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`involved which is nonsense because Respondent should be able to discern the individuals it
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`authorized to perform room inspections during a certain time period, at a specified facility,
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`related to a named discriminatee.
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`The same is true for all the other allegations Respondent claims it cannot mount a
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`defense. Respondent can start with determining who supervised the discriminatee or who it
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`authorized to perform certain duties within the departments the discriminatees were assigned.
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`Then, Respondent can interview those individuals and/or search for related records (which are
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`also likely subject to CGC’s subpoena duces tecum) to formulate “an explanation of events that
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`refutes the charge of unlawful behavior.” Pergament United Sales, Inc. v. NLRB, 920 F.2d 130,
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`135 (2d Cir. 1990). “The primary function of notice is to afford respondent an opportunity to
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`prepare a defense by investigating” and “fashioning an explanation.” Id. Courts have held that
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`providing the identity of discriminatees, the nature of the alleged conduct, and a timeframe,
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`provides such notice. Id. Thus, Respondent’s bare assertions that it cannot mount a defense
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`without the General Counsel deviating from the Agency’s pleading practices, consistent with the
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`Board’s pleading standard, is insufficient to support its request for a bill of particulars.
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`Furthermore, Respondent’s discussion about its inability to mount a defense shows that it
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`is not concerned with defending against the allegations it identified in its specific requests for
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`information. As noted above, Respondent is positioned to determine which supervisors were
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`involved in the discriminatory conduct at issue. And Respondent failed to identify a single
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`allegation that it is unable to make such a determination for or explain how that could be given
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`
`
`9
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`

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`the information it maintains. Rather, Respondent harps on the fact that 183 individuals are
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`identified in the Complaint as statutory supervisors and/or agents and it cannot figure out what
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`the bulk of them are alleged to have done. Motion at 8. Thus, Respondent’s concern appears to
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`be why certain supervisors and agents are identified in Paragraph 4 of the Complaint, not with
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`how it can defend against the actual alleged conduct set forth in the Complaint. Respondent’s
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`concern drives at what evidence – potentially through the testimony of the identified supervisors
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`and agents – CGC intends to present. Essentially, Respondent is seeking a witness list,
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`delineated by issues raised in the Complaint. Respondent is not entitled to such information and
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`its continued attempts to obtain pre-trial discovery should be rejected
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`III. CONCLUSION
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`Respondent’s Motion for Reconsideration is not supported by Board law and should,
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`respectfully, be denied. The ALJ’s Order denying its initial request for a bill of particulars is
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`consistent with, and grounded by, the Board’s pleading standard. In other words, the ALJ got it
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`right the first time and should similarly deny Respondent’s instant motion which is merely a
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`watered-down version of its original attempt to obtain impermissible pre-trial discovery.
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`Dated August 11, 2021.
`
`
`
`____________
`
`/s/ Sara Demirok
`
`
`
`Sara Demirok
`Counsel for the General Counsel
`National Labor Relations Board, Region 28
`2600 North Central Ave., Suite 1400
`Phoenix, AZ 85044
`Email: sara.demirok@nlrb.gov
`
`
`
`
`10
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`
`
`
`
`/s/ Kyler Scheid
`
`
`
`Kyler Scheid
`Counsel for the General Counsel
`National Labor Relations Board, Region 28
`2600 North Central Ave., Suite 1400
`Phoenix, AZ 85044
`Email: kyler.scheid@nlrb.gov
`
`
`

`

`
`
`Exhibit A
`Exhibit A
`
`

`

`IXssources
`/ FEB 22 2019
`/
`Received
`
`Print Form
`
`i
`
`1
`
`1
`
`i
`
`RECORD OF PROGRESSIVE DISCIPLINE
`
`Team Member Name:pesus Garda
`
`Department:|902T4
`
`Position:|cook
`
`Issuing Supervisor:[lVlonica Dempsey
`
`TM Number:|l 13576
`
`Date of Occurrence.^ 1/2019
`
`Date of lssuance]2/22/20i9
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`TM's Days Off:|sun/Mon
`
`Please check Type of Violation:
`
`Cash Variance J~ Attendance |x Job Performance
`Previous coaching given on the following dates (if applicable):
`
`r AML
`
`First
`Pl ease check which action applies:
`f" *Final Written Warning
`jx *Verbal Warning
`*Written Warning
`,r“ Suspension Pending Investigation J- Extend Introductory Period 30 days
`
`Third
`
`Second |
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`Previous progressive discipline given within the past six months and dates on which they occurred:
`1“ Written j"
`
`I" Final
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`F Verbal
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`Company Statement: Describe in detail the occurrence prompting this discipline, including the specific policy
`or procedure which was violated, the date and time of the incident, etc. (Use additional sheets as necessary)
`
`HEALTH VIOLATION - 2/21/2019 TM improperly labeled multiple non-food items, kitchen tools & equipment with the RTE, PHF (TCS)
`Food 7-day shelf life, violating SNHD Regulation 3-501.17(A).
`
`Team Member Comments: (Use additional sheets as necessary)
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`Indicate anyfollow-up action to be taken:
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`TM as a certified Food Handier, needs to adhere to all Southern Nevada Health Department standards & regulations;
`specifically 3-501.17 (A).
`
`*TOTHETEAM MEMBER; You are given this notice in order that you may have an opportunity to correct unacceptable behavior. If you fail to
`correct this behavior as addressed above, or engage In any other violation of company rules or conduct, you will subject yourself to further
`disciplinary action, up toand Including termination of your employment. PLEASE NOTE that by signing this form, you are simply
`acknowledging that you had this discussion, were shown this document and had the opportunity to respond to it.
`
`i
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`TeawXWember'sSignature /Date
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`Supervisor's Sfgnatuiw Date
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`Team Member Contact Number
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`... C>. X-tjk. 2/22/^
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`Witness'Signature/Date ^applicable) '
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`’
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`\
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`R00016225
`
`R. Exh. 16
`
`Exhibit A (Opposition to Respondent's
`Motion for Reconsideration of
`Order Denying Bill of Particulars)
`
`

`

`CERTIFICATE OF SERVICE
`
`I hereby certify that COUNSEL FOR THE GENERAL COUNSEL’S OPPOSITION TO
`RESPONDENT’S MOTION FOR PARTIAL RECONSIDERATION OF ORDER DENYING
`BILL OF PARTICULARS in RED ROCK RESORTS, INC. et al., Cases 28-CA-228052 et al., was
`served via E-Filing and E-Mail, on this 11th day of August, 2021, on the following:
`
`Via E-Filing:
`
`Honorable Amita B. Tracy
`Administrative Law Judge
`NLRB – Division of Judges
`901 Market Street, Suite 300
`San Francisco, CA 94103-1735
`
`Via Electronic Mail (On Following Page):
`
`Douglas R. Sullenberger, Attorney at Law
`Joshua H. Viau, Attorney at Law
`Fisher & Phillips LLP
`1075 Peachtree Street, NE - Suite 3500
`Atlanta, Georgia 30309
`dsullenberger@fisherphillips.com
`jviau@fisherphillips.com
`
`Timothy Scott, Attorney at Law
`Fisher & Phillips LLP
`201 St. Charles Avenue - Suite 3710
`New Orleans, LA 70170
`tscott@fisherphillips.com
`
`Eric B. Myers, Attorney at Law
`A. Mirella Nieto, Attorney at Law
`Richard Treadwell, Attorney at Law
`McCracken, Stemerman & Holsberry, LLP
`595 Market Street, Suite 800
`San Francisco, CA 94105
`Email: ebm@msh.law
`Email: amnieto@msh.law
`Email: rtreadwell@msh.law
`
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`Kevin Kline, Director of the Gaming Division
`Local Joint Executive Board of Las Vegas a/w UNITE HERE
`International Union
`1630 South Commerce Street
`Las Vegas, NM 89102
`Email: kkline@unitehere.org
`
`David A. Rosenfeld, Attorney at Law
`Weinberg, Roger & Rosenfeld, PC
`1375 55th Street
`Emeryville, CA 94608
`Email: drosenfeld@unioncounsel.net
`
`International Union of Operating Engineers, Local 501, AFL-CIO
`301 Deauville Street
`Las Vegas, NV 89106-3912
`Email: jsoto@local501.org
`
`Ms. Maria Sanjuana Ortiz
`309 Wildrose Street
`Las Vegas, NV 89107-2216
`Email: juanyzz70@yahoo.es
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`Mr. Blake Saari
`7477 Edgecove Court
`Las Vegas, NV 89139
`Email: readi702@gmail.com
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`/s/ Sara Demirok
`
`
`
`Sara Demirok
`Kyler Scheid
`Counsel for the General Counsel
`National Labor Relations Board, Region 28
`2600 North Central Avenue, Suite 1400
`Phoenix, AZ 85044
`Email: kyler.scheid@nlrb.gov
`Email: sara.demirok@nlrb.gov
`
`