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Tom Godar
Welcome to Husch 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 Hirsch 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;55;15
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. It is great to have you back for part two of our discussion regarding labor arbitrations, those arbitrations, which primarily arise in the context of a collective bargaining agreement we have with us. And, you know, these fellows, if you listen to part one two consummate insiders regarding arbitrations, my friend and colleague and partner Jon Anderson, who has worked in the labor law world for, gosh, about the same amount of time as I have.
00;01;55;15 - 00;02;20;22
Tom Godar
In fact, we graduated the same year, Jon, down at Marquette. I was at the University of Wisconsin, and we are just children in this area. Compared to the true dean of arbitrations in this state, Wisconsin. And quite honestly, around the nation, people speak with respect of Howard Bellman, his experience, his insights and the way in which he works towards a resolution.
00;02;20;25 - 00;02;41;11
Tom Godar
Howard and Jon, welcome back. Thank you so much for joining us on the Labor Law Insider. I want to begin with a question for you, Howard. What's your role in helping parties, even before you quote go on the record? Maybe it's even after you've gone on the record. But to find a resolution that they shake hands with on the way out of the room before they get a decision.
00;02;41;13 - 00;03;02;22
Tom Godar
And I guess the second part is too many of the hearings, in my estimation, are no longer face to face. Jon is not driving to Minneapolis to try that case. It's now tried as we're doing right now, virtually. We're not in the same room. You can take it in any stretch you want, but I guess it is. You often find a resolution before you have to write a decision.
00;03;02;25 - 00;03;08;29
Tom Godar
Is that impeded at all by the fact that we've now become a virtual sort of world?
00;03;09;02 - 00;03;32;06
Howard Bellman
Well, it's not a world I'm particularly comfortable in. And I hear my swansong being rehearsed in the wings, if you know what I mean. And that's okay with me. And this is one of the reasons, although I think I may have said to you earlier, I do feel from listening to lots of my colleagues that the parties are beginning to drift back towards having hearings in person.
00;03;32;08 - 00;03;34;04
Howard Bellman
Some of the assets of
00;03;34;07 - 00;03;35;19
Howard Bellman
virtual hearings
00;03;35;22 - 00;04;02;27
Howard Bellman
will persist for certain parties, but I think others that I think may be more sophisticated, value the kinds of things that only happen when people are together in a room. To get back to your original question, if you're an ad hoc arbitrator, as I often have been, and don't really have the opportunity to have much sense of the parties, advocates working as individuals, I don't know them by reputation.
00;04;02;28 - 00;04;27;27
Howard Bellman
I might know their firm by reputation, and I certainly haven't had the opportunity to spend much time with them in the past. I'm a little reluctant to become aggressive about a settlement so much of my career as a mediator. I have a great confidence in my gut, and I don't have a gut when I'm with a stranger and I don't know how it's going to be received.
00;04;27;29 - 00;04;49;20
Howard Bellman
So I become careful. And I don't really like to go through ritual behavior in which I always say the same thing in the beginning of the hearing. I try to let things proceed organically based on the feelings that I get. As I spend more and more time in the room with people, so I don't say something automatically at the beginning about have you tried hard to settle this or something?
00;04;49;20 - 00;05;28;23
Howard Bellman
I don't know, it's going to take offense at that. I don't know who's going to worry about their client or their member when that conversation comes up. I just feel too naive and uninformed, and I don't want to touch a nerve with it. I didn't even know it was exposed. I worry about that. There does come a time that I'm just speaking for myself, that arbitrators in general, when I have this really strong sense that people are wasting their resources, and the case that I'm hearing that there's an obvious so almost mutual gains kind of conclusion that they can reach, if nothing else, to save paying me and paying each other.
00;05;28;23 - 00;05;55;25
Howard Bellman
And so on and so forth, because it's obvious how the case is going to come out, and it's obvious that it's not a case of great moment. It's just a case that somebody feels they have to proceed with in order to protect something. They have to go through the motions. And if I say, I think that this is the you wasting resources, somebody in the room who's sensitive to wasting resources might hear me say that, and it might proceed accordingly.
00;05;55;25 - 00;06;27;28
Howard Bellman
And if they want me to help them, I'll help them as a mediator. But I'm also not going to be aggressive about that, because I know that people have a variety of feelings about using a decision maker in a settlement effort when you're going to have ex party communications and stuff like that. So I hopefully am sensitive to those opportunities, and I think they can be valuable to the parties, but I handle those in a gingerly way, because I really want to know who in the hell I'm dealing with when that's going on.
00;06;27;28 - 00;06;50;21
Howard Bellman
And what their sensitivities are, particularly their internal politics. I think part of my training was to be very respectful, what was going on? I couldn't expect anybody to explain to me that there are things going on that I'm not going to know, and that those things are important and I should not. Fools rush in. And I didn't want to be that kind of a fool.
00;06;50;24 - 00;07;10;19
Tom Godar
But it also makes me want to have another go at this sometime in the future. I would rather we talked more about mediation, because then your attitude can be quite different in the way you prepare for it. Think about it. But let me keep on the arbitration track, because your insights are really helpful for the practitioners that are listening, the HR reps and so forth as to how to approach this.
00;07;10;21 - 00;07;30;15
Tom Godar
If you, Howard, I'm going to give you Jon, a chance to answer the same question. If you said, what are just 2 or 3 best practices or pointers or things that have been helpful to me as a neutral to make decision, what would you tell the lawyer or the HR person, or the union rep, or the union lawyer that's presenting to you?
00;07;30;17 - 00;07;33;21
Tom Godar
Make sure you try to do this thing or these two things.
00;07;33;23 - 00;07;56;21
Howard Bellman
To me, the most important thing when I'm in the presence of those parties. In other words, at the hearing, is that they need to be working as hard as they can to make sure I understand what's going on. Okay, they can't be talking to each other. They can't be using jargon. They have to know that I might screw up if I don't understand.
00;07;56;24 - 00;08;06;05
Howard Bellman
I mean, I might screw up, even if I do understand that it's more likely, I think if I don't understand it, it's up to them to make me understand. That's one thing.
00;08;06;07 - 00;08;09;25
Tom Godar
I love that that's great advice. I can't tell you how many times yeah.
00;08;09;27 - 00;08;31;29
Howard Bellman
I think it's the reason why I ask questions. It's not always because I really want the answer. It's because I want you to know whether or not I'm understanding what's going on in. My question should indicate to you whether or not I understand what's going on. So it's my sort of subtle way of saying that you advocate, I don't know if I'm keeping up here.
00;08;32;02 - 00;08;50;23
Howard Bellman
I play, that's why I'm asking this question. And next to having the record reporter screw up the transcript, it's the worst thing that seems to me that can happen. The other thing that I think plagues arbitration, that I would speak to people about, and this is more on the union side, but I think it can happen on both sides.
00;08;50;25 - 00;09;12;11
Howard Bellman
This is what I would call a conclusion area questions. I mean, I really just want the facts, and I want you to understand that I'm going to reach the conclusions. And if you ask the witness, did that violate the contract? You talk about something that happened, then you say, did that violate the contract? Union people do this all the time.
00;09;12;14 - 00;09;38;21
Howard Bellman
Why do you not? Somebody thinks that that's evidence of something. There's a slippage between what I think are my responsibilities and what they think of their spots, what they think is affecting how I work. Those two things think to me to be really fundamental to how a hearing is concluded, to just let me have the facts and then argue in the brief or in your final arguments.
00;09;38;24 - 00;10;00;18
Howard Bellman
Just let me have the facts. Unless you're speaking to somebody other than me, don't be asking conclusion questions. And the other thing is worry about whether or not I'm keeping up during the course of the hearing. Don't let me come home with the transcript and briefs and then figure out what the case was about, and all of those things happen.
00;10;00;21 - 00;10;20;16
Tom Godar
I cannot tell you how many times after I've presented a case, the client would say, how did we do? And my answer was, we've associated the case with all of the facts that I think are necessary for me to argue for our position. And so that's really what I want to do. Jon, your turn. 1 or 2 things that you think are just essential, important, overlooked.
00;10;20;23 - 00;10;22;14
Tom Godar
How are you want to take that question?
00;10;22;17 - 00;10;44;22
Jon Anderson
Well, I think from a practitioner's standpoint I think there's three things. One is understand your case and working with witnesses. Make sure that they understand. And I work with witnesses individually and as a group. I want them all to hear what the case is about. I understand their role in reaching the decisions that were made and how we're going to present it.
00;10;44;22 - 00;11;05;21
Jon Anderson
So understanding the case is important for the advocate and for the witnesses, too, I think. Know your weaknesses. No cases. Perfect. No case is so good that it can't be lost. So no, we are weaknesses and I frequently want to be the person that talks about the weakness. In my case making before it comes out from the other side.
00;11;05;27 - 00;11;25;20
Jon Anderson
I'd rather have it brought forward and disclosed, and then just deal with it in a brief and then the last thing I think we grew up in this age of Perry Mason and the witness examination stuff, that's not the way it is. As much as you want to ask a question, don't ask questions that you don't know the answer to.
00;11;25;20 - 00;11;50;26
Jon Anderson
So I always tell people, lawyers that work with cases, and I've used this in my own cases that use cross-examining very sparingly. Most cases are not one. Through cross-examination, many cases can be lost through cross-examination. And the witness that you're examining is not going to help you with detailing the facts necessarily. So make sure that, you know, get the facts from your own witnesses.
00;11;50;26 - 00;12;10;13
Jon Anderson
Don't cross-examine to get facts. Cross-examine. If somebody is lying and you can prove it, the arbitrator doesn't need to hear that testimony twice, but use it very sparingly. In some cases, my client doesn't understand that. They say, well, why didn't you ask questions? And I said, well, because I didn't have any questions. There's nothing he would have said was going to help us.
00;12;10;14 - 00;12;24;21
Jon Anderson
Nothing. So all it does is prolong the hearing. And, you know, the lawyer pounds their chest and feels really good about it. They went through a cross-examination, they made somebody cry. But that doesn't advance the cause at all, necessarily.
00;12;24;23 - 00;12;47;17
Tom Godar
Yeah, I remember a case way back when and I had had a really excellent cross. I had really undermined the report of an expert. The question that was lingering is, so now that you don't really support your own report, what would the report be that you'd submit? Because I undid all of the facts that he relied upon. But I was afraid to ask a question I wasn't smart enough not to ask.
00;12;47;17 - 00;12;53;12
Tom Godar
I was afraid of it. But the other side should have been more afraid because they asked the question, who became my expert? At that moment.
00;12;53;15 - 00;12;54;28
Jon Anderson
I hear you.
00;12;55;00 - 00;13;18;09
Tom Godar
So yeah, knowing when to stop is that important? You know, one of the things. And then we could continue on for a while, but really briefly, do you want to do a, obviously an arbitration statement, which is, you know, what is the issue? That's pretty typical. Howard, do you want to have an opening statement that summarizes what John or his union counterpart thinks they're going to do, or do you want to just jump into the hearing?
00;13;18;16 - 00;13;39;19
Howard Bellman
I want opening statements. I really think they're extremely helpful when they're well done. I don't want the opening statement to sound like the closing statement with all the conclusions in it. I want to hear what you think you're going to prove and maybe some contract provisions that you're relying on or something like that. But in my practice, most of the time, I have no idea what the case is about.
00;13;39;19 - 00;13;59;00
Howard Bellman
Until you start to talk. And so that's really, really important for me as I move forward. And also, frankly, it's useful to me when the advocate, after the opening statement asked me if I have any questions because I'm likely to have questions about the opening statement. And if they're important to me, they're important to you.
00;13;59;00 - 00;14;06;15
Tom Godar
Those questions that tells me that a whole bunch of advocates don't spend enough time on their opening statement. What do you think, Jon?
00;14;06;17 - 00;14;28;08
Jon Anderson
Well, I think that's probably true. I'm not one of those. I, I think it's the roadmap. And I recall a case. There is an arbitrator again, that Howard knows. Well, one of the most impatient people I've ever met in my life. He lives here in Madison. I was doing a case in Sheboygan, and we presented our opening statement and I said, here's what we're going to prove.
00;14;28;10 - 00;14;32;08
Jon Anderson
Here's the issue. We were stipulated to the issue. I've explained.
00;14;32;15 - 00;14;33;25
Howard Bellman
The facts.
00;14;33;27 - 00;14;57;24
Jon Anderson
To which the arbitrator needs some introduction. And then I shut up. And then the union said, well, I'd like to do my opening statement, too. So the union did their opening statement, and then the arbitrator said, well, let's take a time out here. Can I see the contract? And the arbitrator pulled up the contract at the contract and said, well, I'm ready to rule based on based on the opening statements of the parties here.
00;14;57;26 - 00;15;14;10
Jon Anderson
And I'd like to give you a bench decision. And we agreed to the bench decision and we prevailed in that case, which is kind of a milestone for me, is the only time I've ever really had a bench decision and certainly didn't go in there with the intent of getting one. But it was, I heard what you've said.
00;15;14;10 - 00;15;37;08
Jon Anderson
There's no dispute on what happened here. I look at the contract employer, you prevail. And, so that's the importance of that opening statement is I will, you know, give the gist of my arguments in an opening statement. But I think Howard's right. He really wants facts. And the arguments are either an oral argument at the end or written brief.
00;15;37;14 - 00;16;06;10
Howard Bellman
You are. I think you are. I think you also asked about the framing, the issue. Yeah, yeah. And what I would say is that if you was in agreement on the issue, that's fine. I think it's a waste of time to spend a lot of time arguing about the issue in the hearing. I think the best practice is to enable, for both of the parties to present what they believe the issue is and then agree that the arbitrator will frame the issue ultimately, in terms of first frame.
00;16;06;10 - 00;16;34;10
Howard Bellman
But what I want to say is mostly if you we get enamored of the notion of the issue, then it's going to be a sort of fancy footwork. It goes on where people are making word choices and linguistic nuances and so on, so forth that are going can ultimately trap the arbitrator one way or another. And I don't care to answer yes or no to a question that is formulated with that kind of gamesmanship.
00;16;34;13 - 00;16;35;21
Howard Bellman
And I get that.
00;16;35;23 - 00;16;56;13
Tom Godar
I think that it's not unusual process. I worked for a pretty large firm here in Wisconsin when I started my career, and at this might have been my first arbitration and not surprisingly, I was given a dog. Right. We're going to lose anyhow, so you might as well lose sheep or get the sheep. New lawyer in there. And I worked my tail off and but I knew that I had a loser.
00;16;56;13 - 00;17;19;16
Tom Godar
And so I went in and we put in our evidence and the arbitrator said, gentlemen, I think it was two gentlemen, a gentleman and a lady. Would you like to submit written briefs, or would you like to close with an argument here? And I thought, well, since I'm doing this on the cheap, the client would probably appreciate it if I save them a couple bucks by not going through and getting the transcripts and then writing out an argument and still lose.
00;17;19;18 - 00;17;50;23
Tom Godar
So I said, yeah, I'll offer an oral argument if it's acceptable to Union. Yes, we did. I submitted the oral argument, and I think and I did get a bench decision, which we won. So that's a little bit of break story, right. But having said that, when do you decide and what would you recommend to our listeners as to whether you would like to go to, you know, getting the transcript and organizing over what can be an expensive process to put together a written argument, or when you might choose to have an oral argument summary immediately after close of evidence.
00;17;50;26 - 00;18;13;09
Howard Bellman
It's hard not to walk away from a hearing after it's over with, thinking that you are inclined in one way or another. I think it's just human nature to do that, and I don't know if I can convince you of this or not, but it's not unusual at all to change your mind that that first impression is that what more thoughtful consideration provides?
00;18;13;11 - 00;18;46;19
Howard Bellman
Okay, there are nuances and complexities and things that may seem like minutia that turn out to be important. And you wind up deciding the case in a completely in the opposite direction of what your first impression is. So I think it's a risky business. Not to give the arbitrator the full treatment of the transcript and briefs, because with those documents as well as the record that you have this opportunity to get it right.
00;18;46;21 - 00;19;07;04
Howard Bellman
And I think that unless the cases have very little consequence, not doing that is what I would call a false economy. And just as a footnote to that, arbitrators and not good stenographers. And if you don't have a transcript by the time the hearing is over, if it takes a few hours, the notes are going to be lousy, okay?
00;19;07;04 - 00;19;30;16
Howard Bellman
They're not going to be of any value when you get home two months later and you got the brief and I and you don't really have a record. So I think it's also very useful to have a transcript rather than depend on the arbitrator. Now, I know arbitration takes place. Is you've said already in lots of other settings and, and lots of other settings and commercial cases and so on and so forth.
00;19;30;16 - 00;19;55;13
Howard Bellman
The protocols and the expectations and the mores are different than they are and the work that the three of us do. But in the work that the three of us do, I think when you have a case of consequence, you know, I did apply sufficient resources to the case to allow the arbitrator a real opportunity to make the right decision based on all the appropriate factors.
00;19;55;16 - 00;19;56;11
Howard Bellman
Good, good.
00;19;56;13 - 00;20;00;09
Tom Godar
Jon, any further thoughts on that, briefing or oral argument?
00;20;00;11 - 00;20;15;08
Jon Anderson
No, I done oral arguments. I don't like them. There's a lot of pressure. You're tired after going through a hearing. You're going to miss some things. You can chart it out. Early in my career, I used to write the brief before I went to the hearing, because that told me what I had to prove. I don't do that anymore.
00;20;15;11 - 00;20;32;24
Jon Anderson
I have no star and witness checklist and things like that. But I think if you're trying a case that's worth trying, so it's a case of significance, you're going to have a court reporter there. Certainly there's no reason to have a court reporter. If you're going to ask for a bench decision, there's no reason to have a court reporter.
00;20;32;24 - 00;20;52;11
Jon Anderson
If you're not intending on briefing, say, I want to brief, I win cases based on my briefs. I love writing briefs. I'm a weird duck as it relates to that. But I think the ability to write something that's persuasive, grounded in the facts is the goodness of our work. And I think that that makes the difference in the right cases.
00;20;52;18 - 00;21;14;02
Jon Anderson
And I think you can point things out that may not be obvious from a cold transcript, but I agree with Howard. I'd rather have a transcript. I'd rather have a written argument. I mean, if you're concerned about time and expense, you can agree on limiting the number of pages and having it filed quicker than the typical month. And it gets extended three times by agreement of the parties.
00;21;14;04 - 00;21;20;03
Jon Anderson
I mean, all of those things are considerations here, but if it's worth fighting about and you're spending the money on it, let's do it right now.
00;21;20;03 - 00;21;59;00
Tom Godar
Love it, love it fellas, I'm going to end with something that's sort of a postscript to this, because we've really been talking about the process itself. But the process can sometimes be a substitute for what the National Labor Relations Board would decide, or at least the issue that might come before the board. And for all the time that I've been practicing, which is 45 years or so, there's been, an issue of potential deference to an arbitrator's decision or something that might otherwise be under the jurisdiction of the NLRB and consequently, one of the choices that parties can make.
00;21;59;00 - 00;22;33;01
Tom Godar
And if the hearing is conducted in an appropriate way and established in an appropriate way, you're never going to see the National Labor Relations Board. There is a deferral. For instance, an employee, talks about discipline that may certainly be under the contract, but it also may implicate whether there was discriminatory treatment because the employee's action to support a union, for instance, or there could be questions that come up in discrimination that's even broader than that, that might go to some other process.
00;22;33;03 - 00;22;52;18
Tom Godar
But, Jon, is that under the various changes we have from the Obama administration to, Trump one to the Biden administration, now the beginnings of Trump to is that opportunity for bringing an arbitration rather than going through the board process is still alive and well?
00;22;52;21 - 00;23;18;00
Jon Anderson
I think it is. I think that, you know, public policy favors arbitration as a dispute resolution process. And the law changed in 2014, then changed back in 2019. But there's the ability to have pre arbitral deferral. You know are you to the NLRB because there's a joint jurisdiction issue. And when there's a claim of a contract violation it's a violation of the contract subject to a grievance procedure.
00;23;18;07 - 00;23;48;07
Jon Anderson
It's also a violation of the law. And so the NLRB will defer if you agree to have the dispute resolved at the arbitration level. But oftentimes disputes include not only allegations of contract violation, but also allegations of discrimination or interference with section seven rights and section seven. Right. So the rights of employees under the law and the NLRB is particularly persnickety, if you will, about making sure that those issues get resolved.
00;23;48;07 - 00;24;33;16
Jon Anderson
So under the standards that exist today, the board will allow for pre arbitral deferral or they will defer to an arbitrator's decision when the proceedings were fair and regular, when the parties, all parties have agreed that that's the way they want to go and where the arbitrator specifically considers the unfair labor practice issue, which is the question of a violation of the law and the arbitrators decision at the end, when rendered, is not clearly repugnant to the act standards that I think the parties have a good deal of experience in dealing with, you know, the question of whether it's a good idea or a bad idea remains the current NLRB is changing the prosecutorial focus,
00;24;33;16 - 00;25;06;12
Jon Anderson
and the emphasis on enforcement is changed with the new general counsel. The board will eventually change with presidential appointments might be a good way to have issues balled up and for a long, long time because you can always appeal board decisions the court as a way of prolonging the resolution. But if you're looking for a quick, cheap, efficient reason to resolve disputes between two parties in a relationship that continues, I think going to the arbitrator is the way to go.
00;25;06;12 - 00;25;10;01
Jon Anderson
If you get the parties to agree to that and you avoid duplicate hearings.
00;25;10;06 - 00;25;25;08
Tom Godar
Jon, thank you. I'm curious. Howard, you started out your career with the National Labor Relations Board, board agent and attorney. What's your thoughts on processes that also include that is arbitration processes that also include a deferral portion to the lower level?
00;25;25;08 - 00;25;43;26
Howard Bellman
Answer A more practical answer is if you're going to present to me and argue about a case in which I have some responsibility for knowing the law, you better make sure I know the law. Don't rely on meeting other law. Okay? That's all I would say about that. I've been at it long enough to know how things change.
00;25;43;29 - 00;26;01;06
Howard Bellman
It was a time in my life when I read what was called advanced sheets that, I mean, I don't think they exist anymore. And so every day we would look at the NLRB Advanced Sheets and we would know where we are and all of that kind of thing. And I don't do that anymore. And I think most arbitrators don't do that at all.
00;26;01;09 - 00;26;39;02
Howard Bellman
So I think you have to assume the role of educating me as to what you think the law is with regard to the issue to which the law pertains. Otherwise, I would say that not only is arbitration cheaper and more efficient, take less time and not appealable. And all of those things that Jon was saying, I would also say frankly, it's more sophisticated in its own sort of way because my experience with the NLRB, having been there and observed that, is that the people there may have never been to a bargaining table.
00;26;39;04 - 00;27;14;04
Howard Bellman
They have notions of good faith bargaining, which I had to purge from my brain when I became a mediator. I remember investigating good faith bargaining complaints or charges when I was at the NLRB and thinking that I knew what bargaining was about from taking affidavits of the parties who had participated in it. And then when I spent those years as a mediator at the WRC, I saw something entirely different and much more subtle and much more nuanced and much more complicated than what we were considering it to be at the NLRB.
00;27;14;06 - 00;27;37;26
Howard Bellman
So I think that you're going to get a better analysis, a more incisive analysis from an arbitrator, then you're going to get from a regional office. And I think that comes along with all of the virtues and or strengths that Jon was indicated, as well. But I know that there are cases in which there are reasons to be battle.
00;27;37;28 - 00;27;54;27
Howard Bellman
And if you want a battle for one reason or another, cynical reasons or why these reasons or whatever the NLRB is a better place to have a battle, that's up to you. To me, you can sustain it and you can spend other people's money and all that sort of thing. It's litigation.
00;27;55;04 - 00;28;14;16
Tom Godar
Excellent. This I predict that before we went on the podcast that we could have a five hour discussion. You fellows, I know that if we were over a beer and a steak or something like that, the war stories that I would allow that take place would be a blast. For instance, I didn't say, what was your quirkiest arbitration?
00;28;14;18 - 00;28;35;05
Tom Godar
I didn't say, Jon, who was your weirdest witness either side union or cop or manager. That would be a blast. But even without that, we've been talking for a while and it has been a delight to have you, Howard Bellman, and you Jon Anderson, as guests on the Labor Law Insider podcast. Oftentimes I say, what's a practical pointer?
00;28;35;12 - 00;28;55;09
Tom Godar
I think you've laced our discussion with that. We're practitioners for people who were saying, I want to avoid those darned arbitrations at all costs. Well, like you've already anticipated, it's about communication even before you get to a grievance. So folks, thanks so much for joining us. Howard, we really appreciate your participation in the Labor Law Insider.
00;28;55;13 - 00;28;57;08
Howard Bellman
Thanks for having me.
00;28;57;08 - 00;29;05;19
Tom Godar
And Jon, it's always great to have my friend and my colleague join us and share a little bit of that wisdom learned over these past 40 plus years. Thank you so much.
00;29;05;21 - 00;29;07;25
Jon Anderson
Well thank you. It was wonderful to be here.
00;29;07;27 - 00;29;19;04
Tom Godar
And thank you for joining us on the Labor Law Insider podcast. I look forward to joining you again soon. Take care.