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Contempt, Compliance, and Special Litigation Branch Briefs | NLRB | Public Website Skip to content Find Your Regional Office Directory 1-844-762-NLRB Español NLRB.gov Search form Search Search Tools Toggle the Main Menu ▼✘Rights We ProtectLawJurisdictional StandardsWhat's the Law?RightsEmployee RightsEmployer/Union Rights and ObligationsRetaliation Based on Exercise of Workplace Rights Is UnlawfulThe NLRA and the Right to StrikeThe NLRB and Social MediaEnforcement Activity10(j) ActivityProtected Concerted ActivityContact Us▼✘About NLRBWho We AreThe BoardThe General CounselRegional OfficesDivision of JudgesOrganization ChartOur HistoryInspector GeneralAcquisitionsCareersWhat We DoConduct ElectionsDecide CasesEnforce OrdersFacilitate settlementsInvestigate ChargesContact Us▼✘Cases & DecisionsCasesCase SearchCases and Organizations of InterestResearchFilingE-File Charge / PetitionFile Case DocumentsInvitations to File BriefsDecisionsAdministrative Law Judge DecisionsAppellate CourtBoard DecisionsContempt, Compliance, and Special Litigation Branch BriefsInformation on Decisions Issued by January 4, 2012 Board Member AppointeesNotable Board DecisionsRegional Election DecisionsUnpublished Board DecisionsContact Us▼✘News & OutreachNewsAnnouncementsNews ReleasesPublicationsBrochuresEmployee Rights PosterFact SheetsForeign Language PublicationsMaterials from NLRB Information ProgramsMore InformationContact the Office of Congressional and Public AffairsFOIANLRB Mobile AppsSunshine Act NoticesContact Us▼✘How We WorkResearch and Functional GuidanceAddendum to the Revised Memorandum of Understanding between the Departments of Homeland Security and Labor Concerning Enforcement Activities at WorksitesAdvice MemosCitenetCollaboration with Foreign EmbassiesGeneral Counsel MemosManualsOperations-Management MemosRules & RegulationsFillable FormsDemographic Information ApplicantsE-FOIA Request FormInspector General HotlineOIG Contractor Reporting FormPoliciesRequest a SpeakerRequest for InformationSite FeedbackContact Us▼✘ReportsNLRB Performance ReportsAnnual ReportsAnnual Review of Revised R-Case RulesDecisionsElection ReportsGraphs & DataLitigationsRemediesSummary of OperationsWeekly Summaries of DecisionsNLRB Case Activity Reports10J Activity in FY 2017Charges and ComplaintsPetitions and ElectionsRecent FilingsTally of BallotsRegulatory Reports and NoticesBuy American ActCommon Identification IssuanceFederal Employee Viewpoint SurveyNo Fear ActPlan for Retrospective Analysis of Existing RulesPublic NoticesRepresentation Election Regulations Request for Information ResponsesService Contract InventoriesInspector General ReportsOIG Audit ReportsOIG Inspection ReportsOIG Semiannual ReportsFOIA ReportsFOIA Annual ReportsFOIA Quarterly ReportsContact Us▼✘eFilingE-File Case DocumentsE-File Charge / PetitionSign up for E-ServiceContact Us✘ Rights We ProtectLawJurisdictional StandardsWhat's the Law?RightsEmployee RightsEmployer/Union Rights and ObligationsRetaliation Based on Exercise of Workplace Rights Is UnlawfulThe NLRA and the Right to StrikeThe NLRB and Social MediaEnforcement Activity10(j) ActivityProtected Concerted ActivityAbout NLRBWho We AreThe BoardMembers of the NLRB since 1935The General CounselRegional OfficesDivision of JudgesOrganization ChartOur HistoryInspector GeneralAcquisitionsCareersWhat We DoConduct ElectionsDecide CasesEnforce OrdersFacilitate settlementsInvestigate ChargesCases & DecisionsCasesCase SearchCases and Organizations of InterestResearchFilingE-File Charge / PetitionFile Case DocumentsInvitations to File BriefsDecisionsAdministrative Law Judge DecisionsAppellate CourtBoard DecisionsContempt, Compliance, and Special Litigation Branch BriefsInformation on Decisions Issued by January 4, 2012 Board Member AppointeesNotable Board DecisionsRegional Election DecisionsUnpublished Board DecisionsNews & OutreachNewsAnnouncementsNews ReleasesPublicationsBrochuresEmployee Rights PosterFact SheetsForeign Language PublicationsMaterials from NLRB Information ProgramsMore InformationContact the Office of Congressional and Public AffairsFOIANLRB Mobile AppsSunshine Act NoticesHow We WorkResearch and Functional GuidanceAddendum to the Revised Memorandum of Understanding between the Departments of Homeland Security and Labor Concerning Enforcement Activities at WorksitesAdvice MemosAdvice Memoranda Dealing with Handbook Rules post-BoeingRecently Released Advice MemosCitenetCollaboration with Foreign EmbassiesGeneral Counsel MemosManualsOperations-Management MemosRules & RegulationsFillable FormsDemographic Information ApplicantsE-FOIA Request FormInspector General HotlineOIG Contractor Reporting FormPoliciesRequest a SpeakerRequest for InformationSite FeedbackReportsNLRB Performance ReportsAnnual ReportsStatistical Tables - 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RCRecent FilingsTally of BallotsRegulatory Reports and NoticesBuy American ActCommon Identification IssuanceFederal Employee Viewpoint SurveyNo Fear ActPlan for Retrospective Analysis of Existing RulesPublic NoticesCustomer Service StandardsExecutive Order 13166GILs RecordsInformation on Quality GuidelinesPrivacy Impact AssessmentsSmall Business Regulatory Enforcement Fairness ActSystem of Records NoticesRepresentation Election Regulations Request for Information ResponsesService Contract InventoriesInspector General ReportsOIG Audit ReportsOIG Inspection ReportsOIG Semiannual ReportsFOIA ReportsFOIA Annual ReportsFOIA Quarterly ReportseFilingE-File Case DocumentsE-File Charge / PetitionSign up for E-ServiceContact Us You are hereHome » Cases & Decisions » Decisions Contempt, Compliance, and Special Litigation Branch Briefs The Contempt, Compliance, and Special Litigation Branch (CCSLB) represents the Board and the General Counsel in all suits not statutorily based on Sections 10(e) and (f) of the Act, and conducts starchy and criminal contempt litigation to obtain compliance with Board orders. These matters may include deportment to restrain or hogtie issuance of complaint by the General Counsel, deportment to restrain or hogtie particular Board proceedings, deportment to review Board rulemaking, deportment to hogtie disclosure under the Freedom of Information Act or payment of shyster fees under the Equal Access to Justice Act, subpoena enforcement proceedings under Section 11 of the National Labor Relations Act, filing objections to subpoenas issued versus Agency personnel, or proceedings and assistance to Regions to protect the Board's remedial orders in bankruptcy courts or versus attachments, garnishments or liens.   In addition, based on the recommendation of the General Counsel, and upon passport by the Board, CCSLB may initiate an whoopee or intervene in ongoing litigation in federal district magistrate in order to protect the Board's jurisdiction and the primacy of its decisions. In conjunction with the Justice Department, CCSLB moreover assists defending Agency employees in suits filed versus them in their individual topics for deportment they have taken within the telescopic of their validity and employment.    CCSLB moreover conducts starchy and criminal contempt litigation in the U.S. Courts of Appeals to coerce compliance or to punish non-compliance with judgments enforcing orders of the Board; obtains protective orders to ensure that resources will not be prodigal in an effort to stave the payment of backpay judgments; institutes and monitors synchronous hodgepodge proceedings, including deportment under the Federal DebtHodgepodgeProcedures Act to garnish and obtain other injunctive relief pendente lite. CCSLB moreover provides investigative assistance to the Regions related to obtaining compliance with Board and magistrate orders, including investigating entities and/or individuals that may be derivatively liable under the Act.   CCSLB litigation is nation-wide in scope, affects all segments of industry and applies to all unfair labor practices proscribed by law. Through this litigation, compliance with orders of the Courts of Appeals is obtained, and the policies enunciated in the National Labor Relations Act and the orders of the courts are effectuated.    Selected CCSLB briefs are misogynist below, listed by topic.     Rulemaking Litigation Representation-Case Procedure Rule (Dec. 2014 rule): Baker DC, LLC v. NLRB, No. 1:15-cv-00571 (D.D.C.)  Defendant NLRB’s Opposition to Plaintiff Baker’s Motion for Temporary Restraining Order as to Irreparable Harm  Defendant NLRB’s Opposition to Plaintiff Baker’s Motion for Temporary Restraining Order as to Likelihood of Success and the Merged Balance of Harms/Public Interest Factors Chamber of Commerce et al. v. NLRB, No. 15-cv-00009-ABJ (D.D.C.)Memorandum (i) in Support of Partial Motion to Dismiss and Cross-Motion for Summary Judgment, and (ii) in Opposition to Plaintiffs’ Motion for Summary Judgment Reply in Support of Partial Motion to Dismiss and Cross-Motion for Summary Judgment   Associated Builders and Contractors of Texas, Inc. et al. v. NLRB, No. 15-50497 (5th Cir.) (appeal from No. 15-cv-00026-RP (W.D. Tex.)  Memorandum (i) in Support of Partial Motion to Dismiss and Cross-Motion for Summary Judgment, and (ii) in Opposition to Plaintiffs’ Motion for Summary Judgment Reply in Support of Partial Motion to Dismiss and Cross-Motion for Summary Judgment  Brief of Appellee National Labor Relations Board (5th Cir.) Notice Posting Rule:  NAM et al. v. NLRB et al., No. 12-5068 (D.C. Cir.) (appeal from No. 1:11-01629 (D.D.C.)) Memorandum in Support of Cross-Motion for Summary Judgment and Motion to Dismiss Cross-Opposition to Plaintiffs’ Cross-Motions for Summary Judgment Opp. to Emergency Motion for Injunction PendingRequestand/or for Expedited Consideration (D.C. Cir.) Principal and Response Brief of Appellees/Cross-Appellants (D.C. Cir.) Reply Brief of Appellees/Cross-Appellants (D.C. Cir.) Appellees/Cross-Appellants’ Petition for Rehearing and Rehearing En Banc (D.C. Cir.) Chamber of Commerce et al. v. NLRB et al., No. 12-1757 (4th Cir.) (appeal from  No. 2:11-cv-02516 (D.S.C.)) Memorandum in Support of Cross-Motion for Summary Judgment Memorandum in Opposition to Cross-Motion for Summary Judgment Brief of the National Labor Relations Board (4th Cir.)    Reply Brief of the National Labor Relations Board (4th Cir.) Defendants-Appellants’ Petition for Rehearing and Rehearing En Banc (4th Cir.) Representation-Case Procedure Rule:  (Dec. 2011 rule)  Chamber of Commerce et al. v. NLRB, No. 1:11-cv-02262-JEB (D.D.C.), request dismissed, No. 12-5250 (D.C. Cir.) Memorandum in Support of Motion for Summary Judgment Opposition to Plaintiffs’ Motion for Summary Judgment Motion to Alter or Amend Judgment Reply Supporting Defendant’s Rule 59(e) Motion Brief of the National Labor Relations Board (D.C. Cir.) Reply Brief of the National Labor Relations Board (D.C. Cir.)   Bankruptcy Litigation   Unite Here Local 54 v. Trump Entertainment Resorts, Inc., No. 14-4807 (3d Cir.)  Brief for the NLRB as Amicus Curiae   Litigation Challenging AgencyDeportmentBased on Noel Canning All American School Bus Corp. v. Paulsen et al., No. 13-cv-3762 (KAM)(RER) (E.D.N.Y.) Cross-Defendants’ Opposition to Motion for Temporary Restraining Order and Preliminary Injunction Counterclaim /Third Party Defendants’ Memorandum of Points and Authorities in Support of Motion to Dismiss Counterclaim /Third Party Defendants’ Reply Memorandum of Points and Authorities in Support of Motion to Dismiss In re Jeanette Geary, In re SFTC, LLC, d/b/a Santa Fe Tortilla Co., In re Encino Hospital Medical Center, Nos. 13-1-29, 13-1048, 13-1130 (consolidated) (D.C. Cir.) Brief for the NLRB in Opposition to the Petitions for Writs of Mandamus Ozburn-Hessey Logistics, Inc. v. NLRB, No. 13-1170 (D.C. Cir.) Response of the NLRB in Opposition to Emergency Motion for Stay In re SFTC, LLC, d/b/a Santa Fe Tortilla Co., No. 13-1048 (D.C. Cir.) Response of the NLRB in Opposition to Petition for Writ of Mandamus or Writ of Prohibition Response of the NLRB In Opposition toEmergency Motion for Stay In re CSC Holdings, LLC, and Cablevision Systems New York City Corp., No. 13-1191 (D.C. Cir.) Response of the NLRB in Opposition to Emergency Motion to Stay Agency Action Schwarz Partners Packaging, LLC v. NLRB, No. 13-343 (D.D.C.) Defendants' Memorandum of Law in Support of Their Motion to Transfer Venue or, in the Alternative, to Dismiss for Lack of Subject-Matter Jurisdiction, and in Opposition to Plaintiff’s Motion for Summary Judgment Defendants' Reply Brief in Support of Their Motion to Transfer Venue or, in the Alternative, to Dismiss for Lack of Subject-Matter Jurisdiction In re Jeanette Geary, No. 13-1029 (D.C. Cir.) Response of the NLRB in Opposition to Petition for Writ of Mandamus or Writ of Prohibition Laboratory Corp. of America Holdings v. NLRB, No. 13-276 (RBW)(D.D.C.), transferred to D.N.J. as No. 13-cv-00276-RBW NLRB’s Memorandum of Law in Support of Motion to Dismiss and in Opposition to Motion for a TRO or PI, or, in the Alternative, Motion to Transfer Venue Pursuant to 28 U.S.C. 1404(a) Reply Memorandum in Support of Defendant’s Motion to Dismiss or Alternatively to Transfer Venue R & S Waste Services, LLC v. NLRB, No. 13-1042 (D.C. Cir.) NLRB’s Motion to Dismiss for Lack of Jurisdiction Reply of the NLRB to Petitioner’s Response to Motion to Dismiss   Preemption Cases  Int’l Union of Operating Engineers, Local 399 v. Village of Lincolnshire, Illinois, No. 16-cv-02395 (N.D. Ill.)Brief of the NLRB as Amicus Curiae in Support of Plaintiffs’ Motion for Summary Judgment Brief for the NLRB as Amicus Curiae in Support of Plaintiffs-Appellees and Affirmance of the District Court’s Decision on Preemption (7th Cir.)  UAW v. Hardin County, Kentucky, No. 3:15-cv-66 (DJH) (W.D. Ky.) Brief of the NLRB As Amicus Curiae in Support of Plaintiffs Brief of the NLRB as Amicus Curiae in Support of Plaintiffs-Appellees, No. 16-5246 (6th Cir.) Brief of Amicus Curiae NLRB in Support of Petition for Rehearing En Banc, No. 16-5246 (6th Cir.) NLRB v. State of Arizona, No. 2:11-cv-00913 (D. Az.) Opposition to Motion to Dismiss   Motion for Summary Judgment and Memorandum of Law in Support   Opp. to Defendant and Intervenor-Defendants’ Motions for Summ. Judg. Reply Brief in Support of Motion for Summary Judgment   Board Subpoena Matters Sanderson Farms, Inc. v. NLRB, No. 15-60820 (5th Cir.) Brief of Plaintiff-Appellee NLRB     NLRB v. UPMC Presbyterian Shadyside, No. 14-4523 (3d Cir.) Brief for Appellee NLRB     NLRB v. Interbake Foods, LLC, No. 09-2245 (4th Cir.)Brief Reply Brief Petition for Rehearing or Rehearing En Banc   Other DistrictMagistrateLitigation Little River Band of Ottawa Indians v. NLRB, No. 1:09-cv-141-JTN (W.D. Mich.) Response to Plaintiff’s Motion for Summary Judgment Sur-Reply Saginaw Chippewa Indian Tribe v. NLRB et al., No. 1:11-cv-14652 (E.D. Mich.) Brief in Support of Motion to Dismiss and Opposition to Motion for a TRO and/or Preliminary Injunction Brief in Reply The Chickasaw Nation v. NLRB et al., No. 5:11-cv-00506-W (W.D. Okla.) Memo in Support of Motion to Dismiss and in Opp. to Motion for a TRO and/or Preliminary Injunction Reply in Support of Motion to Dismiss Amerijet Int’l v. NLRB et al., No. 1:11-cv-22919 (S.D. Fla.) Motion to Dismiss Reply to Plaintiff’s Brief Opposing Defendants’ Motion to Dismiss Opposition to Motion for Summary Judgment Brief of Appellees NLRB et al.   Other AppellateMagistrateLitigation  Bekele v. Lyft, Inc., No. 16-2109 (1st Cir.)Brief for the NLRB as Amicus Curiae Urging Reversal in Support of Plaintiff-Appellant  DHSC, LLC d/b/a Affinity Medical Center v. California Nurses Ass’n/Nat’l Nurses Organizing Comm., No. 16-3737 (6th Cir.)Brief of Amicus Curiae NLRB Urging Affirmance of the Judgment onRequestin Support of Defendant-Appellee Patterson v. Raymours Furniture Co., Inc., No. 15-2820 (2d Cir.)Brief for the NLRB as Amicus Curiae Urging Reversal in Support of Plaintiffs-Appellants    Lewis v. Epic Systems Corp., No. 15-2997 (7th Cir.) Brief for the NLRB as Amicus Curiae Urging Reversal in Support of Plaintiff-Appellant      Morris v. Ernst & Young, LLP, No. 13-16599 (9th Cir.) Brief for the NLRB as Amicus Curiae Urging Reversal in Support of Plaintiffs-Appellants      Sanderson Farms, Inc. v. NLRB, No. 15-60333  (5th Cir.)   Brief of Appellees NLRB, et al.   Cazorla v. Koch Foods of Miss., LLC (EEOC v. Koch Foods of Miss., LLC), No. 15-60562 (5th Cir.)  Brief for the NLRB as Amicus Curiae Urging Partial Reversal in Support of Appellant Cross-Appellee U.S. EEOC Pacific Maritime Ass’n v. NLRB, No. 13-35818 (9th Cir.)Reply Brief for the Defendant-Appellant NLRB Brief for Defendant-Appellant NLRB DiPonio Constr. Co. v. Int’l Union of Bricklayers & Allied Craftworkers, Local 9, No. 11-1034 (6th Cir.)Brief of Intervenor National Labor Relations Board   Connect with Us FacebookRSSTwitterYoutube Sign up for NLRB Updates News NLRB Region 21 Office in Los Angeles Moving to New Location, Office to be Closed to the Public Friday and Monday for Move November 1, 2018 NLRB Extends Time for Submitting Comments on Proposed Joint-Employer Rulemaking October 30, 2018 NLRB Selects Roxanne Rothschild as Executive Secretary October 25, 2018 NLRB Region 4 Office in Philadelphia Moving to New Location, Office to be Closed to the Public Friday and Monday for Move October 17, 2018 Board Suspends Briefing in Loshaw Thermal Technology October 15, 2018   1 of 131 ›› Resources Chief FOIA Officer ReportFederal Activities Inventory Reform ActGovernment Performance and ResultsNLRB Sustainability PlanPerformance Budget Justification Footer Site Map Policies OpenGov USA.gov FOIA Privacy About Rights We Protect Who We Are What We Do Resources Inspector General Fact Sheets Forms Related Agencies E-file via FOIAOnline Accessibility Employee Rights Poster Other Site Feedback FAQ Contact Us   NLRB Employees Only Employee Password Reset Download the NLRB Mobile App   Site Map Policies OpenGov USA.gov FOIA Privacy About Rights We Protect Who We Are What We Do Resources Inspector General Fact Sheets Forms Related Agencies E-file via FOIAOnline Accessibility Employee Rights Poster Other Site Feedback FAQ Contact Us NLRB Employees Only Employee Password Reset   Contact: 1-844-762-NLRB Search form Search Rights We Protect LawJurisdictional Standards What's the Law? 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