STEP 1 GREVANCE ‘American Postal Workers Union, AFL-CIO OUTUNEworssieer ig Revised 04/24/22 Hit ROBERT AS MAINST DARBY, PA 19023 ofr5124 cueRK Lindbergh Pant Phila. Pa 19176. 0 cant LETTER OF WARNING _|2.5.15,16,19 mou “eens viet adam |k Townes ERMS FAILURE TO REPORT AS SCHEDULED {A The Two 2) Sterns Fm ainant Designated Represent Levene Ea (2 tached STATEMENTS) indent hat NO ‘Sreciric INTENDED DISCIPLINE was lece io NEITHER of T WO (2) POIs Ged GAT aan -10am 88pm ‘oarngBOTIL POs ave and ingrop and telat ten ste spin defence aslo dP "scaly ‘Seance anda npg To cl sid and due PI Paperwork fo he eng Serer abate sve ‘Sd evens: NO SPECIFIC INTENDED DISCIPLINE ses! [vines xaiaion of Dip = where & when was rca ius «rope ofl susan" OR Ateiuce Review before ero Waring in conjuction with ave hed DEFECTIVE PDI ze tached evan Stee) (Cine cpt betwen fertve PI 617 and improper Sed unsaid" dcp ae S17 ale al gent ‘e"spcingo imei enone whee oe NOT ced eects had een CORRECTED fig o ee Ms iim) D)ALL led tees al nde SOs (hours te te ip) foe which under MOU BE (ae nacho he reat ‘tld NOT have bon cep Mot fl tan or appot Omi Even or il Let of Waring dated 816s 2 ‘ey 24uniy Bais, ee" EXACTLY what cements of ere unin, 2412s, Aas? Thre ee "bots nore () hour CORRECTLY docu a3 wits 24a, unis, 20ens ee Fao meat Mesh 2) story Bren of Dong Pan Pracce JCM p28 Ar Spl (emake) 1 Cty nd sseney2 Repettioe nd Loge; 3 Acepily:Lindersh Mths NO ley consist dentate th cqiab unde nfacemet of the ce nctoments ethan Dei as usin dpa eee, [ERAS not nei pervs votes At 16 nd Ar "A cane ina union ade the eval few Postar sper is nite ie juntos change rei ining pst act, «noted nh eos pang SEM ARS 3 (6 Dep the PDL and LOW etd exteneingcicurstancs: caging bookbag ple and cag ema sper (SDO ‘Serato del frase Retin f EO Camplin 11 D326. 107/16 gen PDL by New AdamsK Townes wines FATLURE TO INSTRUCTIONS, Os 1/16 SDO Newki: Aan inber random circa an array ates xfce "Yoke poc tat ONLY se stent efor Abn wiot wang angel o mean EMPLOYEES CANT TAKE [BOOKHAGS ON WHAT Sli: DEFINES AS THE WORKFLOOR. Even mae dlloned clckring 20mg" tengo ‘ated RF 1) 1king eo sean ALL OF THE ABOVE: spiny tenp.an ONLY bedemed PUNITIVE NOT Conesive CCorrestve action: Ltr of Warning be rescinded and expunged citing procedural and Art 16 defects: capricious, univ, cscrminstory and als the statutory burden of jst cause" Issuing ERMS NOT grievant immediate Supervisor failed to demansrate Later of Waring woul be proper based on PRE- DISCIPLINARY RESEARCH, GRIEVANTS entre ATTENDANCE DISCIPLINARY rocaré. bo ‘WIPED CLEAN" (any fur atlempt to cscpine ‘grievant for same Bagh with an ofl dscussion as per CBA). Management responseFAILURE TO REPORT AS SCHEDULED A) The Two (2) Statements from grievant & Designated Representative Lawrence Eaddy (se attached STATEMENTS) indicate that NO SPECIFIC INTENDED DISCIPLINE was included in NEITHER of TWO (2) PDI's dated 6/8/17 a)4:08am-4:10am b)8:S8pm-9:30pm rendering BOTH PDTs flawed and improper and therefore any attempt to issue disipline to ‘defendant based on said PDI's "structurally defective invalid and also improper. The Officially signed and dated PDI Paperwork from the Issuing Supervisor corroborates above stated evidence NO SPECIFIC INTENDED DISCIPLINE cited! B)Violates Escalation of Discipline : where & when was grievant issued a proper “offical discussion” OR Attendance Review before Letter of Warning in conjunction with the above cited DEFECTIVE PDI's (see atached grievant statement) ‘©) Time elapsed between defective PDI 6/8/17 and improperly issued ("unescalated") disciptine dated 6/15/17 failed to allow grievant the "spacing of time”: to demonstrate whether or NOT cited deficiencies had been CORRECTED failing to meet Mgts disciplinary statutory burden of ‘JUST CAUSE" D) ALL cited latenesss: fall under SOunts (hours as stated on the discipline) for which under LMOU 8.6E (see attached) the grievant should NOT have been charged. Most of les than or approx 10minutes. Even more Official Letter of Warning dated 6/15/16 cites 32 units, 24units, Zunits, 20unitsete ete : EXACTLY what increments of time are 32 units, 24units,12unts, 20units? There being 100units in one (1) hour. CORRECTLY documented as 32 units, 24units, units, 20units ete etc E) Fails to meet Mgts three (3) statutory burdens of Defining Past Practice JCIM pg28 Art 5 pel (see attached) 1 Clarity and consistency; 2 Repetition and Longevity ;3 Acceptability : Lindbergh Mgt bas NOT clearly consistently demonstrated the equitable "even handed” ‘enforcement of tie cited increments less than SOunits asa sustainable diseiplinar eriterion, F) ERMS not immediate supervisor violates Art 16 and Art §"A change in local union leadership or the arrival ofa new Postmaster or supervisor isnot, in itself, sufficient justification to change or terminate a binding past practice, as noted inthe previous paragraph”. p30 JCIM. Ar5 p3 G) Despite the PDI and LOW cited extenuating circumstances : changing bookbag policy and categorical immediate supervisory (SDO Serrano) denial of "makeups'in Retaliation of EEO Complaint #1C-191-0032-16. 10/7/16 given PDI by Newkirk Adams/K,Townes witness FAILURE TO INSTRUCTIONS. On 1/5/16 SDO Newkitk-Adams in her random, capricious and arbitrary atteraps to enforce a "bookbag" policy that ONLY she attempts to enforce. ‘Abruptly without warning changed to mean EMPLOYEES CANT TAKE BOOKBAGS ON WHAT SHE DEFINES AS THE WORKFLOOR. Even more disallowed clockrings on "makeup" attemps (see attached RFI) H) Taking into consideration ALL OF THE ABOVE: sai disciplinary attempt can ONLY be deemed PUNITIVE NOT Corrective