Protest Decisions

IN RE: ALEXANDRA POPE, 
Protest Decision 2000 EAD 1
Issued: August 1, 2000
OEA Case No. PR060501AT

Alexandra Pope, a member of Local 805, filed a pre-election protest pursuant to Article XIII, Section 2(a) of the Rules for the 2000-2001 IBT International Union Delegate and Officer Election ("Rules").[1]  Pope alleges that Waymon Stroud, president of Local 728 since November 1, 1999, terminated five business agents: (1) in retaliation for their support of Doug Mims, candidate for southern region Vice President in the 1999 southern rerun election; and (2) in order to chill opposition to Hoffa and his supporters in the 2000-2001 delegate and officer election. The business agents that were terminated were: (a) Doug Mims, candidate for southern region Vice President in the 1996 election, 1998 rerun election and 1999 southern rerun election; (b) Jimi Richards, assigned mostly to the Overnite organizing campaign and business agents for two small shops; (c) Greg Charron, a business agent since June, 1990, an elected trustee of Local 728 and recently appointed vice president of Local 728; (d) Doris Sanders, an organizer since August, 1996 and a Local 728 business agent since March, 1998; and (e) Benny Stephenson, a business agent since September, 1996. The protestor further alleges that the five business agents were terminated upon the advice, support and direction of Vince Hickman, the personal representative of General President Hoffa to Local 728. The protestor asserts that these actions violated Article VII, Section 11(a) & (g) and the provisions of Title I of the Labor-Management Reporting & Disclosure Act of 1959 ("LMRDA") incorporated in Article XII of the Rules.

Stroud denies that the termination of the five business agents was retaliation for Mims' candidacy in 1999, or an effort to chill opposition to the Hoffa campaign in 2000-2001. Instead, Stroud asserts that the terminations of Mims, Richards and Charron were layoffs, motivated by financial considerations, and that the terminations of Stephenson and Sanders were due to poor job performance. Further, Stroud and Hickman assert that the termination decisions were made by Stroud, with Hickman providing advice to Stroud because he was a new and inexperienced local union president.

Election Administrator representative J. Griffin Morgan investigated the protest.

Findings of Fact

Background. Local 728 is the second largest local in the southern region. It is located in Atlanta, Georgia. Local 728 and Local 528 have separate union offices and separate union halls located immediately adjacent to each other in what is now known as the Mathis Labor Center. They share a common parking lot.

Weldon Mathis was the principal officer of Local 728 in the 1980s. Weldon Mathis was also the Secretary-Treasurer of the IBT at the time the 1989 Consent Order was entered. In 1991, he chaired almost all of the Teamster convention because of General President McCarthy's ailing health. The 1991 convention was the first convention to which delegates were elected and the Election Officer was present to conduct the nominations for international officers.

Donald Scott and Doug Mims led a political drive that replaced the Mathis Administration in Local 728. On June 1, 1990, Scott was installed as the president of Local 728, along with Mims as vice president, Richard Black as secretary-treasurer and Stroud as recording secretary. Ken Redding, Dennis Moore and Greg Charron were also hired as business agents on June 1, 1990.

In 1991 and again in 1996, Doug Mims was elected as southern regional Vice President on the Carey slate. He was an unsuccessful candidate for southern regional Vice President in the 1998 rerun election and the 1999 southern rerun election. Further, Mims stated on many occasions following the 1999 southern rerun, including to Stroud, that he planned to run for International office again in 2001.[2]

Following Hoffa's election in 1998, Waymon Stroud and Ken Redding shifted their support from Doug Mims to Charlie Gardner, the Hoffa Slate candidate in the 1999 southern rerun election. Subsequent to the rerun election, on or about June 12, 1999, Waymon Stroud filed charges against Donald Scott for giving himself a $200 per week raise without receiving prior approval of the executive board. Three days later, Donald Scott fired Waymon Stroud for allegedly signing a contract with a small bakery employer that allowed the employer to replace retiring union members with temporary employees. After his termination from Local 728, Waymon Stroud was employed by the IBT to work as an assistant trustee of Local 1129, under Ken Hilbish, president of Local 528.

The charges brought by Stroud against Scott were not heard by the local executive board or the Florida/Georgia Conference, but by a three-person committee appointed by General President Hoffa. The hearing was in August 1999. In October 1999 the hearing panel re-instated Waymon Stroud to his job with Local 728 and suspended Don Scott from membership in the IBT for one year. On October 27, 1999, General President Hoffa appointed Vince Hickman as his personal representative to Local 728.

Upon the removal of Scott from membership and as president of Local 728, the local's executive board consisted of six members: Richard Black, secretary-treasurer; Waymon Stroud, vice president; Ken Redding, recording secretary; and Greg Charron, Gwynetta Brown and Robert A. Wood, trustees. The by-laws of Local 728 do not provide for an automatic successor if the office of the president is vacated. The executive board was split in its choice of a successor. Stroud, Redding and Brown supported Stroud for president. Black, Wood and Charron supported Charron.

On October 29, 1999, Hickman met with the executive board. He told them that in his opinion, since there was no provision in the by-laws as to who Scott's successor should be, it was his experience that the vice president succeeded the president. He then told the executive board that if they did not elect Stroud as president, he would strongly recommend to General President Hoffa that Local 728 be placed in trusteeship.

Although it is the practice of Local 728 to tape executive board meetings and take minutes of those meetings, recording secretary Ken Redding neither taped the October 29, 1999 meeting nor kept minutes of that meeting. Redding explained that even though Charron flew from Savannah to Atlanta for the meeting, he thought it was just an opportunity for Hickman to personally meet the members of the executive board and not a meeting of the board.

The October 29 executive board meeting broke up with the executive board still evenly split on the successorship issue. Subsequently, Black changed his position and decided to support Stroud for president. Black stated that the basis for changing his decision was that he would lose his job if the local were placed in trusteeship. He said he could not afford to lose his job and that after conversation with Stroud; he was assured that under Stroud's presidency, he would keep his position as a business agent with the local and his salary.

On November 1, 1999 at a specially called meeting of the executive board, Stroud was elected president. Stroud, Black, Redding and Brown voted in favor of Stroud. Charron voted against Stroud and Wood abstained. On November 5, 1999, upon the motion of Stroud, Charron was chosen as the new vice president. On November 15, 1999, Mims and Richards were terminated as employees of Local 728.

On March 9, 2000, southern regional Vice Presidents Ken Wood and Tyson Johnson met with the business agents of Local 728 and then met privately with Hickman and Stroud. On March 11, 2000, Charron was terminated. On March 20 and 29, 2000, Sanders and Stephenson, respectively, were terminated.

Termination of Doug Mims and Jimi Richards. Doug Mims was the vice president of Local 728 from June 1, 1990 through January 1999. He chose not to run for reelection in 1998. Mims was a full time business agent for Local 728 from June 1, 1990 until January 1992, when he assumed the duties of southern regional Vice President. At that point, he became a "part-time" business agent and was paid $100 a week, so that he could maintain his enrollment in the Central States Health and Welfare Pension Fund. Mims maintains that he worked as a business agent on a limited basis when he was in the Atlanta area from 1992 through June 1999. After he lost the election in the southern rerun, he returned to his status as a full-time business agent on June 14, 1999. From 1990 through his termination in November 1999, Mims was responsible for representing over-the-road drivers under the National Master Freight Agreement and some small employers units that did not have master agreements.

In 1993, Mims was appointed to the national UPS negotiating committee. In 1994, he was appointed to the national freight negotiating committee. From 1994 through 1999, he was director of the tank haul division with responsibility for negotiating contracts with the three major employers in that division.

Mims and Sanders jointly represented the over-the-road drivers under the National Master Freight Agreement. Since August 1996, Sanders had been employed as an organizer, but the IBT reimbursed Local 728 for her salary. Sanders' employment with Local 728 as a business agent began in March 1998. Mims had more experience than Sanders. His seniority as a business agent dated to June 1990, although from January 1992 through June 1999, his service to the local was minimal.

Stroud and Hickman both stated that the only basis for Mims being selected for termination was the financial need of the local to eliminate unnecessary business agents and that Mims was the business agent most recently hired. At the same time Mims (and Richards) were terminated, however, Local 728 hired Earl Parker, a long time Hoffa supporter, as an organizer. The protestor argues that Parker's hiring establishes that the reason offered for Mims' termination is a pretext. Standing alone, this fact does not establish a Rules violation, since Parker was paid considerably less than Mims and since the IBT subsidized a portion of his compensation.

More important is Charron's credible contradiction of Hickman. Charron spoke with Hickman on October 29, 1999, following the executive board meeting. During their conversation Hickman received a phone call from an IBT attorney. Hickman asked Charron to leave the room. Charron paced outside the door to the office being used by Hickman. Charron heard Hickman tell the attorney that it looks like a split board and that it was all Mims' fault. Hickman stated that Mims had his nose in everything and that Hickman would see him out no matter what. Charron reduced what he heard to writing in a notarized statement two weeks before Mims was terminated.

Richards was employed by the Florida/Georgia Conference as an organizer. The Conference, Local 528 and Local 728 jointly paid his salary. At some point during his employment, Local 528 refused to continue to pay its share. Richards' salary was then split between the conference and Local 728. On August 11, 1999, Richards became a full-time employee of Local 728 working as an organizer and a business agent.

Mims and Richards were terminated on November 15, 1999. Stroud stated unequivocally that the only reason Richards and Mims were selected for lay-off was that they were the last two business agents hired. Stroud asserts that the only two considerations for their termination were seniority and finances. Richards had less seniority than Mims, even if Mims' date of return to full time employment for Local 728 is used.

Visit to Local 728 by Southern Region Vice-Presidents Johnson and Wood on March 9, 2000. In the last week of February, 2000 there was a southern regional meeting in Orlando, Florida. At that meeting, Pat Szymanski, IBT General Counsel, asked southern regional Vice President Johnson if he had heard of problems in Atlanta. Southern regional Vice President Wood also heard that Stroud was having some problems as a new president of a local, but does not recall from whom he heard of Stroud's problems.

Johnson and Wood stated that they went to Local 728 to offer their support and assistance to Stroud. Johnson also stated that there was a concern about a clash between Stroud and Hickman. Johnson recalled sitting in on a business agents' meeting and then meeting with Hickman, Stroud and Wood. Wood recalled meeting with Stroud, Hickman and Johnson, but did not remember sitting in on a business agents' meeting.

Johnson stated that he had received complaints from freight members regarding Doris Sanders' job performance before arriving at Local 728. He discussed freight issues with the business agents responsible for freight during the business agents' meeting.

Both Johnson and Wood stated that the meeting with Hickman and Stroud was to encourage Stroud and to provide him advice on how to run the local. They both stated that they had heard that Stroud was getting isolated at the local and staying in his office. Their advice was to get out of the office and meet with the members. They further advised him to make sure that grievances were properly handled, but did not make a specific reference to Sanders. They told him to have a plan for the local and to share his plan with the staff and executive board. They said they told him he was the president and had to make the hard decisions, but did not discuss terminating specific individuals or terminating non-loyal business agents in general. Neither Johnson nor Wood recalled using the term "getting your house in order." "Getting your house in order" is the term Stroud used when reporting the meeting to others.

Termination of Greg Charron. Charron had worked as a business agent for Local 728 since June 1990. From June 1990 through his termination in March 2000, Charron was responsible for the membership in southern Georgia. He shared that responsibility with Dennis Moore, who worked the same region and had been hired on the same day as Charron.

Stroud and Hickman stated that the purpose for terminating Charron was because they did not believe there was a need for two business agents to serve the approximately 700 members in south Georgia. Stroud stated that he chose Moore over Charron because Moore came from UPS and most of the members in southern Georgia were UPS employees. Moore only represented UPS employees in the Southern Region, and only has UPS experience. Charron worked for UPS for 14 years and worked for Yellow Freight for ten years. He represented members at UPS, freight and industrial employers in south Georgia.

Moore attended all the UPS grievance panel meetings along with Redding (UPS business agent for Atlanta) and was a substantially more active and experienced UPS agent than Charron. A review of Moore's work assignment shows that he represents 1,115 members (not 700) in the south Georgia region. Of that number, 976 work for UPS and 139 for freight and industrial employers. Charron has not been replaced.

Charron was the candidate who was nominated to run against Stroud in the executive board meeting that split the executive board in half. At the November 1, 1999 executive board meeting, Charron was the only executive board member to vote against Stroud. After Stroud became president of the Local, Charron was nominated by Stroud to succeed him as vice president. The executive board unanimously approved the motion.

Following his termination, Charron and Hickman got into a shouting match prior to an executive board meeting at the local union hall. Charron filed charges with the IRB and criminal charges with the Atlanta police department against Hickman as a result of this altercation. Charron also filed charges with the Florida/Georgia conference regarding his discharge.

Termination of Benny Stephenson. Stephenson was hired as a business agent for Local 728 in September 1996. He was employed as such until he was terminated by Stroud in March 2000. Stroud and Hickman state that Stephenson was terminated for poor job performance. Stroud stated that Stephenson had been lying to the members and that many members had complained about Stephenson. When asked for the names of members or copies of any written complaint, Stroud did not produce any documents nor recall any specific names.

One month before his termination, on February 29, 2000, Stephenson attended a Yellow Freight meeting along with several organizers working on the Overnite campaign. The purpose of the meeting was to encourage Teamsters working at Yellow Freight to assist with the Overnite campaign. After the meeting was over, the four organizers and Stephenson went to breakfast. One of the organizers, Ron Goulet then rode back to the union hall with Stephenson. On the ride back, Goulet questioned Stephenson about the political situation in Local 728. Stephenson's response was to state that he kept his nose out of politics and just did his business agent job. Goulet then stated that "brother Hoffa is trying to clean things up. The IBT is going to clean up Local 728 and get rid of the TDU bastards." Stephenson, who is a member of TDU, did not respond to Goulet's comment. Stephenson wrote down the comment immediately and told numerous friends at Local 728 about it.[3]

Secretary-treasurer Black did not corroborate Stroud's view that Stephenson was doing a poor job. Black stated that Stephenson did a great job as a business agent. Tyson Johnson also did not corroborate Stroud's statement that Stephenson was doing a poor job. Johnson was specifically asked in his interview if he had received any complaints regarding Stephenson. He stated that he had not received complaints about Stephenson. Earl Parker, who had been working as an organizer following the termination of Richards and Mims on November 15, 1999, replaced Stephenson.

Termination of Doris Sanders. When Mims became southern regional Vice President in January 1992, Robert Stanifer was hired as a business agent to represent the road drivers. Stanifer worked as a business agent until January 31, 1999, when he retired. Byron Wise, who was employed as a business agent in March 1994 and worked until March 1998, assisted Stanifer. Wise was not Stanifer's equal as a business agent, doing mostly clerical, computer and office work. When Wise retired in March 1998, Sanders, who began her employment as a business agent in March 1998, replaced him.

On December 9, 1999, approximately 3½ weeks after Mims was terminated, Sanders wrote a letter to Local 728 President Stroud expressing her inability to properly do the job of representing road drivers, which historically had been represented by two business agents.

When Hickman read Sanders' December letter, he immediately recommended to Stroud that she be terminated. Hickman recommended that Benny Stephenson, who was representing the mechanics and city drivers under the National Master Freight Agreement, replace her. Stroud did not follow Hickman's recommendation.

Stroud stated that Sanders worked well with him at first, and that even after he received the letter he was hoping that she would work out. However, he stated that after she wrote the letter, she did very little work except for suspensions and terminations. Secretary-treasurer Black, who stated that Sanders' work performance was not so great and that she basically laid down on the job after writing the December letter, corroborated Stroud's perception of Sanders' work performance. Southern regional Vice President Tyson Johnson, who is the southern regional freight chair, received complaints from members regarding Sanders. Sanders was terminated in March 20, 2000, her first day back from sick leave, and replaced by new business agent Jimmy Walker.

Analysis and Conclusion

The Rules protect the right of IBT members, including those employed by the International Union or any IBT subordinate body, to run for International office and to support the candidates of their choice for such offices, as well as the correlative right to refuse to support the candidacy of any person. As the Election Officer has stated:

Since the Rules protect campaign activity as a personal right of members, the exercise of that right cannot be interfered with by labor organizations or employers, including the IBT as an employer.

Hoffa, P812 (August 16, 1996). Therefore, the IBT and all IBT subordinate bodies, including Local 728, are prohibited from using the electoral preferences or activities of its employees as factors in any employment-related decision. Article VII, Section 11(g) of the Rules states this protection: "Retaliation or threat of retaliation by the International Union, any subordinate body, any member of the IBT, any employer or other person or entity against a Union member, officer or employee for exercising any right guaranteed by this or any other Article of the Rules is prohibited."

In cases where Article VII, Section 11(g) (formerly Article VIII, Section 11(f)) applies, to prevail on an improper retaliation claim, a protester must show that conduct protected by the Rules was a motivating factor in the adverse decision or conduct in dispute. The Election Officer will not find retaliation if he concludes that the union officer or entity would have taken the same action even in the absence of the protester's protected conduct. Gilmartin, P32 (January 5, 1996), aff'd, 95 EAM 75. See Leal, P51 (October 3, 1995), aff'd, 95 EAM 30; Wsol, P95 (September 20, 1995), aff'd, 95 EAM 17.

We find Local 728's termination of Mims violated Article VII, Section 11(g) of the Rules because the termination was in retaliation for Mims' past and planned future electoral opposition to the Hoffa slate, including his plan to run for southern regional Vice President in the 2001 elections.[4]  We base this finding on our conclusion that the reasons given for Mims' (and Richards') discharge are pretextual, given Hickman's overheard statement that Mims had his nose in everything and that Hickman would see him out no matter what. This evidence, more than anything else, shows the true intention for the terminations. Further supporting our conclusion is the fact that Mims' removal followed promptly after Stroud's selection as Local 728 president and Hickman's appointment as General President Hoffa's personal representative. Finally, we place some reliance upon the fact that the local hired another person at the time Mims and Richards were let go for allegedly "financial" reasons.

We reject the claim of the IBT that the Election Administrator lacks jurisdiction to consider the claims of retaliatory discharge made with respect to Mims and Richards. The IBT asserts that this protest could have and should have been filed with Election Officer Cherkasky, since it alleges retaliation for Mims' 1999 candidacy activities. As indicated above, however, prior to his termination, Mims made known to Stroud and others his intent to run for International office in the 2000-2001 elections. We find that his termination (and that of Richards) was motivated at least in part by a desire chill Mims' planned candidacy, and that of others in the anti-Hoffa camp.

We deny the remaining protest allegations because we find insufficient evidence of improper, electoral-related retaliation. The other three terminations took place approximately nine months after the southern rerun election and four months after Stroud became president of Local 728. Those terminations also took place approximately one year before Local 728's delegate elections. There is no clear nexus in time between the terminations of Charron, Sanders and Stephenson and protected election activity. There is also no clear nexus in time between the terminations of Charron, Sanders and Stephenson and Stroud's acquisition of the authority to terminate them.

The termination of Sanders does not appear to have been motivated by retaliation for her support of Mims in his past and planned future campaign activity, or of other dissident candidates. Nor does her termination appear to be motivated by an attempt to chill opposition to the Hoffa campaign. Sanders was retained in November 1999, when Mims was terminated. Sanders was retained by Stroud in December 1999, after she wrote her letter stating that she could not perform the job by herself, and her termination was recommended by Hickman. Black corroborated the reason provided by Stroud for her termination: poor work performance. The evidence adduced in our investigation does not establish that Sanders would not have been terminated even in the absence of her support for Mims or anti-Hoffa candidates in the upcoming elections.

The evidence fails to show that the terminations of Charron and Stephenson would not have occurred but for protected activity. There is no protected activity on their part closely related in time to the discharge. Against this, we do not find the visit of Tyson and Wood to Local 728, and their advice to Stroud to "get your house in order," establishes a Rules violation. As with Sanders, there is a significant distance in time between the discharges and either (1) the 1999 southern rerun election or (2) the 2001 delegate elections. Thus, it is difficult to conclude that the terminations were based on activity protected under the Rules and would not have occurred because of non-protected Local 728 and IBT political motives.[5]

Accordingly, the protest is GRANTED as to the terminations of Mims and Richards, and DENIED as to the terminations of Charron, Stephenson and Sanders.

Remedy

When the Rules have been violated, the Election Administrator "may take whatever remedial action is appropriate." Article XIII, Section 4. In fashioning the appropriate remedy, the Election Administrator considers the nature and seriousness of the violation, as well as its potential for interfering with the election process. Based on the foregoing, the Election Administrator orders the following:

1. Local 728 shall reinstate Mims and Richards to their former positions and responsibilities and make them whole for the loss of wages and benefits that they have suffered, with interest.

2. Local 728 and the IBT shall restore Mims and Richards to their membership in good standing with Local 728 and the IBT, retroactive to the date of their termination form Local 728 employment.

3. Within five (5) days of receipt of this decision, Local 728 President Wayman Stroud shall have the attached "Notice To Local Union 728 Members and Employees" posted at the Local Union office. Within that same time period, Mr. Stroud shall post the attached "Notice to Local Union 728 Members and Employees" on all bulletin boards at Local Union 728 worksites.

4. Within two (2) days after making the postings required in Paragraph 3 above, Mr. Stroud must submit an affidavit to the Election Administrator attesting to his compliance with this order.

An order of the Election Administrator, unless otherwise stayed, takes immediate effect against a party found to be in violation of the Rules. Lopez, 96 EAM 73.

Any interested party not satisfied with this determination may request a hearing before the Election Appeals Master within two (2) working days of receipt of this decision. The parties are reminded that, absent extraordinary circumstances, no party may rely upon evidence that was not presented to the Office of the Election Administrator in any such appeal. Requests for a hearing shall be made in writing, shall specify the basis for the appear, and shall be served upon:

Kenneth Conboy

Election Appeals Master

Latham & Watkins

Suite 1000

885 Third Avenue

New York, New York 10022

Fax: 212-751-4864

Copies of the request for hearing must be served upon the parties listed above, as well as upon the Election Administrator for the International Brotherhood of Teamsters, c/o International Brotherhood of Teamsters, 25 Louisiana Ave., NW, Washington, DC 20001, all within the time period prescribed above. A copy of the protest must accompany the request for hearing.

William A. Wertheimer, Jr.

William A. Wertheimer, Jr.

Election Administrator

cc: Kenneth Conboy

J. Griffin Morgan

2000EAD1

NOTICE TO TEAMSTERS LOCAL UNION 728

MEMBERS AND EMPLOYEES

The Rules for the 2000-2001 IBT International Union Delegate and Officer Election ("Rules") protect IBT members against retaliation or threat of retaliation by your Local Union, the International Union, any subordinate body, any member of the IBT, any employer or other person or entity for exercising any right guaranteed by the Rules.

The Election Administrator will not permit any such improper retaliation.

The Election Administrator has concluded that Local 728 improperly retaliated against IBT members Doug Mims and Jimi Richards by terminating them from their appointed positions with Local 728 in November 1999. Local 728 has been ordered to reinstate Mims and Richards to their former positions and responsibilities and make them whole for the loss of wages and benefits that they have suffered.

Local 728 and the IBT have also been ordered to restore Mims and Richards to their membership in good standing with Local 728 and the IBT, retroactive to the date of their termination from Local 728 employment.

Any protest you have regarding your rights under the Rulesor any conduct by any person or entity which violates the Rulesshould be filed with William A. Wertheimer, Jr., Office of the Election Administrator, 25 Louisiana Ave., NW, Washington, DC 20001, telephone 800-565-VOTE, telecopier (202) 624-8711

___________________________

Wayman B. Stroud, Sr., President

IBT Local 728

This is an official notice and must remain posted for thirty (30) consecutive days from the day of initial posting, and must not be altered, defaced or covered by any other material.

Prepared and approved by William A. Wertheimer, Jr., Election Administrator for the International Brotherhood of Teamsters.

DISTRIBUTION LIST VIA UPS NEXT DAY AIR:

Alexandra Pope Doug Mims

322 North Fullerton Avenue 1645 Brantford Drive

Mountclaire, NJ 07042 Tucker, GA 30084

Waymon B. Stroud, Sr. Vince Hickman

President, Local 728 International Representative

2540 Lakewood Ave., S.W. 25 Louisiana Ave., N.W.

Atlanta GA 30315 Washington, DC 20001

J. Douglas Korney Greg Charron

Korney & Heldt 345 Oak Pointe Dr.

30700 Telegraph Rd. Richmond Hills, GA 31324

Suite 1551

Bingham Farms, MI 48025 Jimi Richards

2875 Ackworth Due West Rd.

Doris Sanders Kennesaw GA 30152

287 Greenwood Lane

Peachtree, GA 30269 Benny Stephenson

c/o Alexandra Pope

Patrick Szymanski 322 North Fullerton Avenue

IBT General Counsel Mountclaire, NJ 07042

25 Louisiana Ave. NW

Washington, DC 20001

Bradley T. Raymond

Finkel, Whitefield, Selik, Raymond,

Ferrara & Feldman

32300 Northwestern Hwy.

Farmington Hills, MI 48334