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Tom Godar
Welcome to Blackwell's Labor Law Insider podcast. This is your host, Tom Godar. I've been practicing in the labor law sector for more than 40 years, and I can tell you that in no time of my practice has labor law had greater changes than in the last five, six years. We began the podcast in May of 2021, following the election of President Biden.
00;00;23;25 - 00;00;49;12
Tom Godar
And the elections have consequences. And under the Biden administration, a new National Labor Relations Board with the new general counsel reshaped labor policies. And they were very consequential during that time because it was so important to stay on top of liberal issues. The family of Husch Blackwell, labor law counsel, more than doubled in its coast-to-coast reach to assist our client.
00;00;49;15 - 00;01;18;11
Tom Godar
Well, we've since had another election. In the January of 2025, President Trump was inaugurated to his second but now continuous term. And once again, we're seeing significant changes in how the National Labor Relations Board and its appointed members. But Jake, right now an acting general counsel, and the board members are going to interpret the National Labor Relations Act and its associated laws.
00;01;18;14 - 00;01;39;22
Tom Godar
So once again, we're continuing a wild ride of labor law. That's not likely to change soon. So buckle up and enjoy the Labor Law Insider podcast. It is great to have you joining us today, and it is really going to be fun to talk about a subject that many of you brush up against regularly. Some of you less frequently.
00;01;39;25 - 00;02;11;04
Tom Godar
But even if you hardly ever experience arbitration, you're going to find this discussion fascinating because it well, honestly has so much to do with the way in which disputes are resolved. And while I use the a word arbitration so often, it is preceded by mediation. And even when your party is going into a neutral decision maker to find a decision, I cannot tell you how many times people like Howard Bellman, who was going to be one of our featured guest.
00;02;11;04 - 00;02;27;00
Tom Godar
This found a way to say, folks, do you really want to go all the way through this process? Is there a way that you can meet? And I'm not going to stay in the middle because that means different things to different people, but a way that you can meet. And so without much more ado, we're going to talk about arbitration.
00;02;27;00 - 00;02;45;28
Tom Godar
We're going to talk a lot about it today. And I have two guests are going to be terrific to help us walk through that. Jon Anderson, one of my partners, one of my colleagues, one of my friends is joining us. He, sits in the Madison office of Husch Blackwell, but practices throughout the state and indeed throughout the country.
00;02;45;28 - 00;03;21;24
Tom Godar
And it's not unusual. And Jon and I are talking about issues that he's engaged in everywhere. Jon and I graduated at the same time in 1981, but we're still youngsters compared to the experience that Howard Bellman brings. Jon anchored his learning down at Marquette. I was at the University of Wisconsin and until we became colleagues a half decade or so ago, we would see each other in passing because we were mostly working the same side of the fence that is representing management, recognized as one of my best colleagues and one of the best resources and labor and employment law in this region.
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Tom Godar
Jon, welcome to the Labor Law Insider.
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Jon Anderson
Thanks, Tom. I'm glad to be here.
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Tom Godar
Well, it's great to have you here, and it's great to have you here with Howard Bellman. Howard, I mentioned your name a couple of times already. Welcome. You are certainly the first time you've had a chance to be on the labor Law Insider. Jon's had that chance before, but Howard Bellman has been the dean of Wisconsin mediators and arbitrators for some time.
00;03;45;10 - 00;04;08;24
Tom Godar
Before I started going through his resumé, talking about how he started out in the field attorney at the National Labor Relations Board back in the 60s, how he was really instrumental in making the WERC the important place to initiate mediation and arbitration for U. Of the uninitiated, Howard, what is the WERC stand for?
00;04;08;26 - 00;04;15;05
Howard Bellman
It stands for Wisconsin Employment Relations Commission. And thanks for inviting me. I'm really glad to be here with you.
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Tom Godar
Well, and Howard has been worked as the secretary of the Department of Industry, Labor and Human Relations here in Wisconsin. He has served as the permanent arbitrator on so many different organizations and labor agreements, and he's really been engaged in mediating as well as arbitrating and virtually every type of dispute that you can imagine. Multi party matters, matters of public concern such as voter redistricting, controversial land use determinations.
00;04;46;11 - 00;05;11;03
Tom Godar
He's been engaged in mediated rulemaking for the US, EPA, the Department of Interior recognized by a number of states as a go to guy outside of Wisconsin. But much of his experience and what I recognize him for primarily is with labor disputes that arise mostly under collective bargaining agreements. And you had some early experiences through your
00;05;11;03 - 00;05;12;04
Tom Godar
career
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Tom Godar
that helped format how you look at those kinds of disputes and what drives you to come up to the right answer. Why don't you share that a little bit, Howard?
00;05;21;18 - 00;05;50;11
Howard Bellman
Sure, I began, as you indicated, at the National Labor Relations Board regional office in Detroit at the height of labor activity in our lifetime. It was the era when Walter Ruther and Jimmy Hoffa were both active in Detroit. And so. And they got a real taste for it. I was a field attorney and eventually a trial attorney, but I recognized in myself a disinclination towards joining one party or the other.
00;05;50;11 - 00;06;20;20
Howard Bellman
I found that there were folks on both sides that I really didn't want to be loyal to and in Detroit. And so I came here to the Wisconsin Employment Relations Commission at the dawn of public sector bargaining here. And the job that I took was as a mediator and arbitrator, and what has come to be known as an administrative law judge on the staff of the agency that only had maybe eight professional employees.
00;06;20;23 - 00;06;49;07
Howard Bellman
And I stayed there for 11 years, the last few years as a commissioner, by appointment of the governor. But I learned there because that's really where I was trained in the work that we're talking about. What I learned there was a startup ethic that was prevalent in an agency where we offered services if at the taxpayers expense, we were arbitrating and mediating, we were not cultivating a clientele.
00;06;49;10 - 00;07;15;13
Howard Bellman
And that, I feel, changed the perspective that we had so that for example, it relieved us of any anxiety about the impression that we were leaving on people and they won and lost, but it also left us with the sense that the dispute belonged to the parties, that we had no proprietary interest in their conflict, and that if they settled cases, that's what we wanted them to do.
00;07;15;13 - 00;07;50;06
Howard Bellman
We didn't think of it as diminishing our practices when there were settlements. So we had a very sort of, I would say, frankly lofty, kind of perspective and the work that we did. So those of us who are alumni of the Agency of that era, which was the 1960s, mainly in the 70s, have just came out into private practice with a perspective that was a little odd or is a little different from those who entered the field working for a fee.
00;07;50;09 - 00;08;14;16
Howard Bellman
And it gives us a different perspective, not only on our responsibilities, but how we market our services and how we feel about it when the parties get along. Without us, which is essentially that we want them to be able to get along without us. It's sort of, I suppose, like being a certain kind of physician where you hope the people that you might serve don't need you.
00;08;14;18 - 00;08;37;01
Howard Bellman
So now that I've been out in the field now for 60 years, I know a lot of colleagues around the country and around the world. It's a different perspective than most of them have. And without getting too detailed about it, I think it makes our perspective a little more professional, a little less commercial, the terms that I would use.
00;08;37;03 - 00;08;45;28
Howard Bellman
And so I think that that perspective probably also sort of seeps into the decisions that we make.
00;08;46;00 - 00;09;11;28
Tom Godar
Well thank you, I love that. And Jon and I have both had the opportunity to see you at work when we were advocates. Of course, we won or lost. Your win was when a issue was resolved without us having to have you write a decision. But let me sort of step back, just for a moment. Of course, everyone, I believe on the podcast understands that arbitration is a private conflict resolution system.
00;09;12;00 - 00;09;34;07
Tom Godar
In your case, that the WRC might not have been private in that same way, but it was outside of that judicial track, and the parties generally agree to enter it. And in the public sector, you agreed by statute that this was part of the track that you had to enter. Usually an employment arbitration is of two sorts. One is the one that we're going to focus on primarily today.
00;09;34;07 - 00;10;10;07
Tom Godar
That is one. There's a collective bargaining agreement. I've never seen a collective bargaining agreement in my work that does not have a grievance arbitration procedure, so that disputes that are not resolved among the parties have the opportunity to move into a third party neutral, into a private decision maker, who would allow the parties to present evidence in a variety of ways and then ultimately be called upon to choose which of the arguments or portions of the arguments they would find credible and enforce.
00;10;10;07 - 00;10;34;07
Tom Godar
Usually a collective bargaining portion. When it's an employee who says that they were fired without just cause, or when it's an employer who says that they were treated unfairly because of their illness and all that, and it might touch upon therefore other laws as well. Of course, there is private arbitration of any number of disputes, so it's often resolving commercial disputes and construction and so forth.
00;10;34;10 - 00;10;59;17
Tom Godar
And then there's arbitrations in the employment area that are oftentimes entered by the executives, so that oftentimes the CEO might have an arbitration resolution. If there's a dispute with his board or with his company or her company. But again, we're primarily going to focus on that arbitration that comes out of a collective bargaining agreement that's tied to the agreement.
00;10;59;17 - 00;11;19;11
Tom Godar
And the terms and conditions of that agreement. So let me ask, though, before we get that much further, Jon, what do you see as some of the advantages of having this private dispute resolution, rather than having the parties and other contracts, they just run off to court if they think there's a breach of contract or of course, try to work it out themselves.
00;11;19;13 - 00;11;22;14
Tom Godar
Do you see as some of the positives of this type of arrangement?
00;11;22;17 - 00;11;46;24
Jon Anderson
Well, clearly, I think one of the positives is that it's your process. You've agreed to it, you set the standards for having these disputes resolved. You know, the collective bargaining agreement between the parties is really kind of the foundation of their relationship. And, central to those agreements is this process that the parties have voluntarily entered into. And that's one of the important aspects of the arbitration sort of mediation.
00;11;46;27 - 00;12;22;01
Jon Anderson
And you set up a set, a standard for resolution of disputes quickly, quietly, and with the goal of preserving industrial peace and stability and finality, I guess I think are the standards and there, of course, law in Wisconsin, the National Labor Relations Act. There's great deference to this process. So I think the main things though, time are speed and efficiency and finality and again, contributing to the overall goal of ensuring labor peace, especially while that collective bargaining agreement is in place.
00;12;22;03 - 00;12;40;00
Tom Godar
Howard, have you seen some of that display itself in your practice as a neutral? That is the speed of efficiency and allowing the parties to actually come to agreements, even if sometimes they can't come to an agreement with that. You're pending a decision. How have you seen some of those goals achieved that Jon was just discussing?
00;12;40;02 - 00;13;19;24
Howard Bellman
Well, I think that whether you're talking about mediation or arbitration, the governing value or the transcendent value of it all is a sort of protection of the underlying relationship between labor and management. There's a sensitivity to that, it seems to me, or there ought to be that you're not likely to find in a trial court. And I think that for those that would allow or suggest that the forum, the arbitrator understands the values that are placed on speed and that are placed on settlement and in their place that efficiencies of the process.
00;13;19;24 - 00;13;53;11
Howard Bellman
But it also sort of, ironically, also means that people get a day in court, which I think is significant to them, even when they lose. There's lots of sort of empirical evidence of that. It means that you're dealing with a forum that is cognizant that there are internal politics, so to speak, on both sides, that sometimes and the performative styles of the advocates win reflects more than trying to impress you as an arbitrator that's legitimate, needs to be factored in, and you're also getting a forum.
00;13;53;11 - 00;14;20;04
Howard Bellman
And this is an old fashioned term that has some sensitivity or some astuteness about what is to be referred to as a sociology of the workplace by trial judges, as you both know for sure, have a very broad variety of responsibilities. Some of them are met because they were experts before they got to the bench, and other ones they're picking up as they go along.
00;14;20;05 - 00;14;45;23
Howard Bellman
But labor arbitrators typically get pretty well steeped in the realities of the plant floor, even if the plant floor is populated with musicians or teachers or whoever it is that comes before us, that may not be perceived by someone who's just sort of in and out of the field in occasional cases. So I think there's a lot of wisdom to it.
00;14;45;25 - 00;15;16;00
Howard Bellman
And I would also note that the goal of lots of American labor relations policy is referred to as labor peace. And I think that there was a period, maybe in the 1940s when there were strikes over grievances and and display of what may be called statesmanship. Large unions and large employers agreed that they would get no straight clauses and they would get arbitration provisions and all not in the interests, if I may say so, of equity.
00;15;16;00 - 00;15;27;20
Howard Bellman
But in the interest of stability and keeping a lid on things between contract negotiations and none of that, I think it's accomplished in formal litigation.
00;15;27;26 - 00;15;48;13
Tom Godar
That's a great point. There's a bit of a quid pro quo there. I, I often try to describe to folks who don't practice in this area, just people in the community that the collective bargaining relationship is much more akin to a marriage than purchasing a car. I mean, if you don't like the car that you looked at at that lot, you go to the next lottery.
00;15;48;13 - 00;16;09;03
Tom Godar
You didn't like the price, you didn't like the color. But in a collective bargaining relationship, you're in it for the long run. We all know that it can be disrupted by a plant closure or really rarely by some employees choosing to go to the National Labor Relations Board and conducting an election, or occasionally when a union walks away from a relationship.
00;16;09;03 - 00;16;34;25
Tom Godar
But 95% of the time or more, this is a long term relationship. And to try to find ways in which that relationship is preserved in the midst of dispute is not an easy thing. And I think that the arbitration process preceded by the grievance process does that. At the same time. It's really important. Jon, I think you must do too often what I do when you're going to go and take on the next three year term of a collective bargaining agreement, you say, so what's been going on?
00;16;34;25 - 00;16;49;00
Tom Godar
Tell me about each of the grievances you've had this year. What are the hot buttons for your employees? Have you had any arbitrations? What was the resolution? That's part of the way in which we look at the relationship. This is a barometer of the relationship, isn't it?
00;16;49;03 - 00;17;07;09
Jon Anderson
Yeah. Oh, absolutely. Absolutely. I love your analogy to a marriage. I've often said the same thing. You have to work at it to make it work, and you don't want to take advantage of the other side you want to enforce, they understand, is the expectations that in a labor dispute are listed in the collective bargaining agreement. But you don't want to take advantage.
00;17;07;09 - 00;17;31;11
Jon Anderson
You don't want to do too well. You you just want to carry on. But I do when I'm getting ready for arbitration or getting ready to go into collective bargaining, which is a wonderful process. I love collective bargaining. It's one of the most fun things I do. A lot of people hate it, but I love it. It's just, you know, solving problems, trying to find solutions, listening to people and understanding that what's put on paper is often not what people really want.
00;17;31;13 - 00;17;50;03
Jon Anderson
It is the fascinating dynamic, but I clearly want to know what's happened during the course of the existing contract and in many cases, I'll have been there dealing with contract disputes that arise during that term. In some cases not. But you still want to know what's been driving the relationship here. How's the business doing? What are the disputes about?
00;17;50;03 - 00;18;00;19
Jon Anderson
Have there been any significant terminations? Those are all factors that go into understanding the dynamic and then shaping how you approach the issues. When you get to collective bargaining.
00;18;00;22 - 00;18;20;11
Tom Godar
I'm going to keep talking to you a little bit, Jon, now that you've introduced that, Howard already said that the grievance arbitration procedure, falls in most contracts and it's sometimes a trade off for the no strike clause. That is, we will resolve the dispute. But that means that somebody has to have drafted and agreed to that procedure in the collective process itself.
00;18;20;13 - 00;18;30;28
Tom Godar
What have you seen as best practices or things that were really odd, but maybe worked or didn't work at all? As people are lining up a grievance arbitration process?
00;18;31;00 - 00;18;54;20
Jon Anderson
Well, in terms of drafting, I mean, Howard's absolutely right that judges have no idea they approach labor contracts like any other contract. And that, I think, is a mistake to begin with. So when I draft a grievance process, first thing I start with is what is the definition of what is agreement. And that's so important to have it nailed down with some measure of precision.
00;18;54;23 - 00;19;21;05
Jon Anderson
I don't want to say that when the employer and the union disagree on something, it goes to the arbitrator. That's not giving the arbitrator anything concrete to work with. What I write, one typically is that, you know, a grievance is a dispute concerning the application or interpretation of the terms of this collective bargaining agreement. I've narrowed it down to this 15, 16, 20 sometimes 80 page document.
00;19;21;11 - 00;19;22;23
Tom Godar
It's a symphony orchestra, Jon.
00;19;22;23 - 00;19;23;10
Howard Bellman
We know that.
00;19;23;16 - 00;19;47;21
Jon Anderson
Yeah, exactly. That is concrete that the parties have agreed to, that the arbitrator can then interpret, if necessary. So definition is important. The next thing that's really important for me as the lawyer. And this is of course all about the lawyers, not the parties, is that we understand what it is that they're grieving. You know, what happened, who was involved, how did that violate the contract?
00;19;47;24 - 00;20;29;21
Jon Anderson
And what do you want? The who's what somewheres are really important to get all that in the context of a grievance. And when did that happen? So that you can assess whether it's been filed in a timely manner. Typical grievance processes are sequential. It starts with the immediate supervisor, then might go to a department head and then might end up at the air officer's desk, or some vice president of some division, usually three different parties, and then often to arbitration and clearly, when we get to the arbitration level, I like to define what it is that we expect the arbitrator to do, that the costs will be split between the parties, that the arbitrator has
00;20;29;21 - 00;20;48;08
Jon Anderson
the authority to render a decision based upon the language of the contract, but doesn't have the authority to render a remedy that isn't grounded somewhere in the contract. I think most arbitrators respect that. I don't like timelines, and I suspect Howard doesn't like timelines based on the arbitrator must decide this case within 15 days.
00;20;48;08 - 00;20;50;03
Howard Bellman
I particularly just like that one.
00;20;50;07 - 00;21;18;29
Jon Anderson
Yeah, exactly, exactly. And that's the process. Sometimes it's A23 step process. Sometimes it's four steps, but different than a courtroom. When you go into court to fight about a dispute, you'll have discovery in depositions and requests for admissions, the whole panoply of stuff. You don't know what that case is about in the grievance process. You frequently don't. And that's why we have the steps, is to learn as much as we can about the case before you get to that arbitrator.
00;21;18;29 - 00;21;49;18
Jon Anderson
And it's very important that employers respect the process and gain as much information as they can, because most cases settle before they get to arbitration or they're not appealed to arbitration by the union after they had the dialog, which is the ideal world, is that everybody explains where they're going and what they're doing. But listening is really important in this process is important in any relationship to listen to what the other side is saying, because oftentimes what they put on paper, the you can't solve, that's a problem that you can't solve.
00;21;49;18 - 00;22;04;09
Jon Anderson
But when you listen, you listen, you hear what the problem is. And that's something that's solvable. And that's where, oftentimes arbitrators can help in the role of a mediator prior to actually rendering a decision. But I'm getting ahead of myself.
00;22;04;09 - 00;22;24;23
Tom Godar
Here, Jon. That's really helpful. And I wanted to ask Howard a question most often when I've tried in arbitration, all of the steps, at least the written portions of the steps are submitted, because that helps define what that dispute is. It helps define what the parties believe happened or didn't happen that should have happened or shouldn't have happened.
00;22;24;25 - 00;22;40;02
Tom Godar
Howard, when you get the documents that lead, not the substantive documents, but those documents that relate to the process itself, how does that inform you, if at all, about what you're going to decide and what the parties are looking for?
00;22;40;05 - 00;23;01;03
Howard Bellman
If I have those in advance of the hearing, I look at them because I don't like driving to my hearing with no idea whatsoever of what the hearing is going to be about in my practice. And again, this is just because this is how I was trained. It's typical for me not to have anything in advance. I don't ask for anything in advance.
00;23;01;03 - 00;23;33;15
Howard Bellman
I don't think of an arbitration procedure as I read some sort of replication of a hearing in court with discover and all of that sort of motion practice and things like that. You're hearing now from an old guard kind of person. And I understand that most arbitrators who are have been at it long, that I don't necessarily agree with that and do practice more as if they were judges with all kinds of preliminary conferences and discovery and motion practice.
00;23;33;15 - 00;24;06;09
Howard Bellman
But I don't do that. I just show up and they hand me the papers and I come over first of all, I want to say with regard to what Jon says, not almost, but all of which I agree, is that as I listen to Jon, I think that he would make a wonderful mediator. I wouldn't be surprised if I found out that when he's working with his client, he is a mediator, because what it's all about is getting to the bottom of things and not dealing with the manifestations and the performances, but you're presenting about that which you're sure is the subject of the case.
00;24;06;11 - 00;24;29;08
Howard Bellman
I'm afraid that I would report, however, that I'm not sure that happens as often as it ought to. I'm sure it does not happen as often as it ought to, and I think that may be due to some false economies, frankly, in terms of what people are willing to pay for and whether they're just willing to say no, no, no to one another and then hand it off to whoever represents them in the hearing.
00;24;29;11 - 00;24;54;07
Howard Bellman
But I think that a well implemented grievance procedure does exactly what Jon was saying in terms of finding the parties. But somewhere, somehow, and this is not where I live. Someone has to explain to those who implement the procedure exactly what's intended by the grievance procedure. And I think often some there's some slippage in in that exchange, which I'm not person for.
00;24;54;10 - 00;25;20;04
Tom Godar
That's a great point. And I wholly agree with you that Jon and some of the best lawyers I know are practicing mediation within their own party, because we've got somebody in the C-suite that's looking at big picture stuff. We've got a supervisor who thinks that she or he has been dishonored, disrespected, but maybe they weren't really doing their job as well as they could, and we might come to an agreement even before we show up with you.
00;25;20;04 - 00;25;40;13
Tom Godar
Or you might suggest, you know, to the parties, do you have anything that you can stipulate to so that we can move this thing along rather than proving that there's a collective bargaining agreement? And so usually, right, there's a whole bunch of stipulated items that you admit, even if you don't admit that they are necessarily admitted to the truth asserted in a grievance and that sort of thing.
00;25;40;15 - 00;26;01;02
Tom Godar
So we do try to move that forward. And those of us who have practiced lawyer, I hope, find that a little bit easier process. So I know that I was a doe, you know, with my eyes and the headlights of the car coming the first couple times I did this, as to what should I do. But we hope that with the steady hand of Howard Bellman and the experience that Jon might have, that that's easier.
00;26;01;04 - 00;26;25;07
Tom Godar
But why don't we sort of move towards that a little bit? Jon, you haven't been able to work with your client because you've been introduced in the process, late to work with them to find a mediated or an agreed upon resolution before it gets to you. And you don't really have much of an opportunity, although sometimes you pick up the phone, I suspect, to call the union business agent or the lawyer and say, do we really have to go to arbitration on this?
00;26;25;10 - 00;26;42;27
Jon Anderson
But I often call the lawyer on the other side and talk about the case and my you know, our question is, how do you think you're going to win this case? Because the language is crystal clear, even when it's not crystal clear. I always start that way and we talk about it okay.
00;26;42;27 - 00;26;45;00
Tom Godar
So that's an insider step. All right.
00;26;45;05 - 00;27;07;18
Jon Anderson
What is it that you really want here. You know I think you can win this case under the right circumstances. But I don't think those circumstances are present. And I have a client in Minneapolis that I do a fair amount of work with. And the attorney on the other side, and I have a pretty good working relationship. Then we call each other, let each other know, okay, heads up on things that are going on in the in the business.
00;27;07;20 - 00;27;32;28
Jon Anderson
And we also talk about the grievances that are on filed and we've had five grievances in the last year all set for arbitration arbitrators selected. And we settled four of them before we got to arbitration just by talking through the issues. And the last one was settled at arbitration. We had come up with a solution, but we couldn't offer that to our clients.
00;27;33;01 - 00;27;59;10
Jon Anderson
We had to have the independent third party, the neutral, suggested as a resolution, and it was had a little bit wired, if you will. But having those relationships are important to understanding that this relationship continues. So we don't need to go through each other in the process. Let's figure out a solution. So, you know, it's phone calls. Sometimes it's contract language that says the parties should attempt to mediate.
00;27;59;10 - 00;28;18;26
Jon Anderson
Sometimes we package five grievances together with the hopes of settling three of them. I mean, there's lots of different ways to approach this, but the idea is let's get this resolved because it's dragging a lot of people away from work that needs to be done. And it's creating animosity, which is never good in the workplace.
00;28;18;28 - 00;28;38;05
Tom Godar
Jon, thanks so much for this thoughtful answer. I'm particularly interested in talking about bundling and and resolving these types of grievances long before they get all the way to Howard, who listened for a half a day, a day, two days or whatever for an arbitration and then renders a decision. So why don't we put a pin in it right there, fellas?
00;28;38;05 - 00;29;04;28
Tom Godar
Thank you so much, Jon. Howard, what I'd like to do is pick up with a question for you, Howard, when we come back and learn a little bit more about your, you know, sort of insights into what's happening with arbitrations today and still how, if at all, do arbitrators play a role or how do you see them playing a role in resolving grievances even before you go on the record or after you've begun but not completed the hearing?
00;29;05;01 - 00;29;25;12
Tom Godar
Good stuff. Stuff that we've experienced, and I really appreciate all of the comments that you've made so far. It really helps me think more deeply, more, I guess carefully about the ways in which we move towards this special form of litigation and maybe avoid it, this form of litigation called arbitration. So again, Jon, Howard, thanks a lot.
00;29;25;18 - 00;29;40;11
Tom Godar
And thank you so much for listening to the Labor Law Insider podcast. Share it with your friends. And then join us for part two, where we learn a little bit more from two super insiders in the world of arbitration.