LOS ANGELES COUNTY

EMPLOYEE RELATIONS COMMISSION

500 West Temple Street
Hall of Administration, Room 374
Los Angeles, CA 90012-2718
ERCOMfilings@bos.lacounty.gov
213-974-2417

CHARGE ALLEGING UNFAIR EMPLOYEE RELATIONS PRACTICE

AGAINST MANAGEMENT

INSTRUCTIONS: DO NOT WRITE IN THIS SPACE

CASE NO. __________________

A. This charge may be filed pursuant of the Employee Relations
Ordinance No. 9646, Section 5.04.240 (a)(b). DATE FILED ________________
B. Complete this form and submit an electronic .pdf copy to
ERCOMfilings@bos.lacounty.gov.
C. Charging Party is responsible for the notification to Respondent within (3) calendar days of filing
and shall provide proof of service to ERCOM via ERCOMfilings@bos.lacounty.gov.

Charge Against:
County of Los Angeles District Attorney’s Office;
District Attorney George Gascón
Name:__________________________________ 211 West Temple St., Suite 900, L.A., CA 90012
Address:____________________________________________

The above named _____________________________

Employer has engaged in and/or is engaging in unfair employee
(employer)
relations practices within the meaning of Section _______
5.040.240 subsection(s) __________
A(1) and A(2) of the Employee Relations
Ordinance or Section ____ subsection(s) __________ of the Commission Rules and Regulations.

Basis of Charge: (Be specific as to facts/actions, names, addresses, dates, etc. Attach additional pages if required)
On or about February 22, 2022, the Association of Deputy District Attorneys (“ADDA”) sought input from its
membership regarding the current campaign to recall George Gascón, the sitting District Attorney. The ADDA
called for a vote of the membership on the issue in a simple up or down vote - Yes to recall Gascón, or No to not
recall Gascón.

After the membership vote, it was determined that fully 98% of the membership voted to endorse the recall of
District Attorney Gascón. This fact was widely circulated throughout the local media, as well as the national
press corps. Thereafter, in the normal course of business, on March 3, 2022, the ADDA through its Executive
Director, John Rees, sought to commence mid-term bargaining as required by the MOU between the parties.
The issues to be resolved were:

● Increasing the number of Grade IV Deputy District Attorneys;

● Compensatory time;
● Special pay adjustment for selected Grade IV Deputy
● Environmental protocol; and
● Metal detectors.

See attached for continuation.

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Rev. 8/24/21 (ERC-4a)
 BASIS OF THE CHARGE, continued

Accompanying this notice was a request by the ADDA for bargaining related information to
assist the ADDA in preparation for bargaining. After receiving no response from the District
Attorney’s Office, a second request was made by the ADDA on or about on March 10, 2022.
Thereafter, a third request was made by the ADDA on March 17, 2022.

As of the date of the filing of this Unfair Labor Practice charge, the Gascón administration
has simply ignored the ADDA’s request for mid-term bargaining and has failed to provide the
bargaining related material requested by the Union. It is of note that there has been
absolutely no response from the Gascón administration, not a phone call, not a letter, not an
email; neither has the Gascón administration taken issue with the legitimacy of the Union’s
request for mid-term bargaining, nor has the administration voiced any objections to the
material requested by the Union, or the need therefore.

In engaging in this conduct, District Attorney Gascón has retaliated against the ADDA for its
position on the recall of Mr. Gascón; failed to bargain as required by the MOU; and failed in
its statutory duty to provide the material necessary for the Union to go forward with
meaningful and productive negotiations for a mid-term agreement.

VIOLATION OF THE ORDINANCE

In doing these things hereinabove alleged, District Attorney Gascón has violated State law, the
Meyers-Milias-Brown Act, Government Code § 3500, et seq., and the Los Angeles County
Employee Relations Ordinance Section 5.04.240A(1)(2).
Requested Remedy (if applicable):
Charging Party requests the Commission issue a cease and desist order; including an order for publication.

Charging Party requests the Commission order the Employer to immediately produce the requested materials
necessary for the Union to effectively bargain.

Charging Party requests the Commission order the Employer to participate in bargaining.

Charging Party:

Full Name of Party(ies) filing charge: (If Employee Organization give full name, including local and and/or number)
____________________________________________________________________________________
Association of Deputy District Attorneys for Los Angeles County (ADDA) BU 801

Contact Person: _________________________________

Richard A. Shinee, Esq., Green & Shinee, A P.C. Email: _________________________________________
GSRAS2017@gmail.com

Cell Phone: ___________________________________

(818) 266-1773 Office Phone:____________________________________

Mailing Address (include zip code): ________________________________________________________________

11333 Moorpark Street, Suite 387, Studio City, CA 91602

Additional Relevant Information:

Declaration

I declare that I have read the above charge(s) and verify under penalty of perjury that the statements therein are true
to the best of my knowledge and belief.

Richard A. Shinee
Signature________________________________________

Printed Name ____________________________________

Richard A. Shinee, Esq., Green & Shinee, A P.C.

Title: ___________________________________________
General Counsel

For: ____________________________________________
Association of Deputy District Attorneys

April 26, 2022

Date: ___________________________________________

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Rev. 8/24/21 (ERC-4a)
 PROOF OF SERVICE

STATE OF WASHINGTON )
) ss.
COUNTY OF THURSTON )

I am a citizen of the United States and a resident of the County aforesaid; I am over the
age of eighteen years and not a party to the within action; my business address is 811 Wilshire
Boulevard, 17th Floor, Los Angeles, California, 90017.

On the date written below, I served the within

UNFAIR LABOR PRACTICE CHARGE

on the interested parties in said action, by placing a true copy thereof enclosed in a sealed
envelope with postage thereon fully prepaid in the United States mail at Los Angeles, California,
addressed as follows:

Julie Dixon Silva, Director

Los Angeles County District Attorney’s Office
Employee Relations Division
Hall of Justice
211 West Temple Street, Suite 900
Los Angeles, CA 90012

I declare under penalty of perjury that the foregoing is true and correct.

Executed on April 27, 2022 at Olympia, Washington.

Peggy L. Madsen