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Please read the legal filings listed in the matter of El Paso Electric Co. v. IBEW Local 960 and then submit your response to ONE of the following:

An Order, not to exceed 750 words, in which you decide the case as if you were the Judge. In conjunction therewith, please make a short ruling, based entirely upon the standards set forth in International Union of Petroleum & Industrial Workers v. Western Industrial Maintenance, Inc., 707 F.2d 425 (9th Cir. 1983), in which you grant or disallow an award of attorneys fees and costs in the case

OR

An internal corporate memorandum to the Companys Board of Directors, not to exceed 750 words, in which you, the Human Resources Director, make a candid recommendation as to whether litigation ought to have been commenced (or not) based on the facts and arguments set forth in the briefs. In conjunction therewith, include a discussion as to whether or not such litigation creates the possibility of an award of attorneys fees and costs as set forth in the Petroleum & Industrial Workers, supra.L08_ElPaso_Reply_to_Response.pdf

L08_IUPIW_v_WesternIndMaintenance.pdf

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