NATIONAL LABOR RELATIONS BOARD v. UPMC, No. 2:2014mc00110 - Document 23 (W.D. Pa. 2014)
Court Description: MEMORANDUM OPINION on NLRB's Three Applications to Enforce Subpoena Duces Tecum. Signed by Judge Arthur J. Schwab on 8-22-14. (Attachments: # 1 Exhibit A - Subpoena, #(2) Exhibit B - Subpoena, #(3) Exhibit C - Subpoena) (nam)
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Ca e 2:14-mc-00111-AJS Document 1-3 Filed 03/20/14 Page 1 of 17 EXHIBIT B FORM NLRB·31 (12-12) SUBPOENA DUCES TECUII ·uNITeD S«TES OF AMERICA NATIONAL LABOR RELATIONS JOARD To Custod an of Street, 58th Flo~r, Pittsburgh, PA 15219 Claudia Davidson, Cowtsel for SE!U Healthcary Penll!y!vanfa crw CJ c whoseaddre5$ls 429 Fourth Ave-5th Flo.,r, Pittsburgh. PA 15219 (Slate) (City) (Sirael) (ZIP) REQUIRED AND DIReCTED TO·APPEAR BEFORE ~--------~------~1~0~00~L~i~b~e~r~t~~~~~~uu4~--------------------- mU.C~of~~~~~~h~P~A~--------------------------------------------ot 20-J..A. 1=1 00 (a.m.) (p.m.) or any adjourned s In accordance With C.F.R. Section 102. be filed as set forth Section 102.1 f 1(llJ e Board's Rules and Regulations, 29 C.F.R Section 102.31(b)(unta!r labor practice proceedings) and/or 29 6(c) (representation proceedings), objections to lhe subpoena muat be made by a peltlon to revoke and must ereln. Petition a to revoke must be received within Iva clays of your having received lhe aubpoena. 29 C.F.R. ). Failure to follow these regulations may resuflln the loss of anr ability to raiSe such objections In court Under lhe seal of 1he National Labor Relations Board, and by direction of the Board, ttde Subpoena Ia lasued at Pittsburgh, Penruylvan ia thla 2Sth day of October 20 13 ~~ ~ c:.;~, ~tlonal Labor Relatione Board L ESS. Witness fees for attendance, aubsfstence, and mileage under lhls subpoena ar'e payable by the party at whose request. e wltnesa Ia subpoenaed. A witness appearing at the rec:J~ett of the General Counsel of the National Labor Relations Bo rtf shall submit. tl'lls subpoena with the voucher when claiming reimbursement. PRIVACY ACTITATI!'III!NT Solialalion ollhe Info non tills form Is authoriZed by the National labor Relatlolls Ad (NL.RAI, 29 US.C. § 151 et seq. The prilclpal use ollhe Information Is to aseislthe Nallone! Labor elations Board (NLRB) In ptOC8SIIng repreaentallon and/or urlalr labor praclice proceedings and IBialad proceedings or Jllgallon. The ·routine usee ror tie Jnform Uon areiLjjy eet forth in !he Federal Aegiiler, 71 Fed. Reg. 74942-43 (Ot3e.13, 2006). The NlRB willlurthar explln lhese uses upon requeal. Dlaclosura ollhls ormation lo lhe NLRB Is mandllmy In that falluniiO supply tha lnfo~ma!ion My cause lhe NLAB to seek enforcement ollhe ldlpoena ... '-.Ia"" ....... Ca e 2: 14-mc-00111-AJS Document 1-3 Filed 03/20/14 Page 2 of 17 RESPONDENT UPMC SUBPOENA DUCES TECUM ATTACHMENT A DEFINITIONS A. RESPONDENT, YOU, YOUR, and ANYONE ACTING ON YOUR BEHALF includes espondent UPMC and all its directors, officials,. agents, supervisors, managers, , attorneys, accountants, investigators,. representatives, and anyone else acting or purportin to act on its behalf. B. UPMC PRESBYTERIAN SHADYSIDE refers to the non~profit corporation ess as UPMC Presbyterian Hospital and doing business as UPMC Shadyside (.., . d all its directors, officials, agents, supervisors, managers, employees, attorneys,· accoun , investigators, representatives, and anyone else acting or purporting to act on its behalf. C. UPMC-RELATED FACILITY OR OPERATION shall mean any entity in which UPMC, o any of its subsidiaries, joint venture partners or aff'Uiates maintains an ownership, PERSON includes a natural person, firm, association, organization, partnership, , business, trust, corporation, or government entity, and every other form and kind of rivate entity. Reference herein to any PERSON includes representatiVes, agents and employee of such PERSON. E. UNION refers to SEIU Healthcare Pennsylvania (including and regardless of ·whatever ames or designations by which that organization is referred to in documents responsiv to these Requests). UNION ORGANIZING CAMPAIGN refers to the UNION's or UPMC Pr sbyterian Shadyside's employees' efforts to persuade UPMC Presbyterian 1 Ca e 2:14-mc-00111-AJS Document 1-3 Filed 03/20/14 Page 3 of 17 Shadysid 's employees to support. assist, participate in or associate with the UNION, sign a UNION uthorization card or other expression of support or interest, select the UNION as their exclusi~e rei:>resentative under the National Labor Relations Act, or engage in any other protected concerted Section 7 activity under the auspices of the Union. F. · DOCUMENT(S) shall mean the· same as the words "writings and recordings" as defined · Rule 1001 of the Federal Rules of Evidence which provides: ~·writings'.and 'recordings' consist of letters, words, or numbers, or their equivalent, set down by handwriting, typewriting, printing, photostating, photographing, magnetic impulse, mechanical or electronic recording. or other form of data compilation. n DOC NTS thus includes, but is not limited to, any and all sound recorcliD.gs, tape recordings, recordings, SOWld and video recorclings, sound and film recordings, electronic mail ("E-mail' , voicemails, text messages, photographs, notes, note-books, memoranda, proposals, , schedules, timesheets, calendars, diaries, correspondeitce, letters, telexes, telegrams, facsimile ~l!mis'sions, reports, statements, policies, inanuals or binders, handbooks, books, business ecords, personal records, financial statements, audit reports, budget documents, ents, ledgers, employment applications, notices, warnings, medical records, , checks, check stubs, employment references, employment resumes, diplomas, , incident reports, patient logs, affidavits, declarations under penalty ofpetjmy, and ents. DOCUMENT also includes, as used herein, all drafts and non-identical document, including but not limited to those that contain markings, symbols, interlinea ·ons, comments, "post-it notes" or notations of any kind on the front or back thereof. DOC also includes ESI as defined below. 2 Ca e 2:14-mc-00111-AJS Document 1-3 Filed 03/20/14 Page 4 of 17 DOCUMENTS "RELATING TO" or "RELATED TO" includes all DOC NTS "concerning," "pertaining to," ''relating to," related to," "mentionmg," or in any way to," the matters ~pecified in the Request. COMMUNICATIONS includes all verbal and written contact, conversations, , ernails, electronic communic8tions, text messages, instant messages, social media, NTS conveyed to or from or between the persons designated in the Request -yv.L.,...... DISCIPLINE includes any and all fonns of corrective action taken by a or manager relating to an employee's work performance and employment by Respond nt, including without limitation, counseling, warning, reprimands, memo's, ce improvement plans, and tennination, regardless of whether such action was later COMPLAINT refers to the Second Amended Consolidated Complaint issued by the Regi na.l Director in this matter on January 9, 2014. ESI or ELECTRONICALLY STORED INFORMATION shall mean and include tion that is stored on any medium other than paper, including, but not limited to, flies, photographs, digital images, data of any sort, databases, word processing, emails, text mess es, instant messages, social media, metadata relating to any other data, and all informati n stored on electronic devices of any kinds, shape or category. ESI includes, but is not limited t , data stored on computers, networks, servers, PDAs, cell phones, smart phones, tablets, s, disks drives, flash memory, cameras, video, Blackberry devices (or similar other manufacturers), internet storage, backup media, and all other information stored, t, retrieved or read with the aid of electronic devices. 3 Ca e 2:14-mc-00111-AJS Document 1-3 Filed 03/20/14 Page 5 of 17 ~· Unless otherwise specified, the time periods included in this Document Request L. are from anuary 1, 2012 to the present date. If any document is withheld from your response on grounds of any privilege or objection you shall describe in full the nature of the information or document withheld and provide a detailed explanation of the basis for any cla.im of privilege or objection in a privitege log. In accordance with the attached subpoena, please produce the following documents: REQUESTS FOR DOCUMENTS Produce all non-privileged Docwnents relating to the allegations in 'ri!2(a) and (b) 1. plaint. This Request includes all non-privileged Documents relating to any denial of, ' to, any of the allegations in 'n2(a) and (b) of the Comphunt, and the bases therefore. ~oduce all non-privileged Documents relating to the allegations in ftf3(a) and(b) plaint. This Request includes all non-privileged Documents relating to any denial of, of the to, any of the allegations in ,-p(a) and (b) of the Complaint, and the bases therefore. Produce all non-privileged Documents relating to the Second through Eleventh Affinnati e Defenses in Respondent UPMC Presbyterian Shadyside's Answer to the Amended Consolid ted Complaint dated November 18, 2013. Produce all non-privileged Documents relating to Respondent's knowledge or tin any of the incidents or allegations in W8-55 of the Complaint This Request non-privileged Documents relating to any denial of, or defense to, any of the allegatio s in 'n8-55 of the Complaint, and the bases therefore, including that the incident did not occur on the date or in the manner or with the persons alleged in that .paragraph or that Respond t did not act with a discriminatory intention or motive. 4 Ca e 2:14-mc-00111-AJS Document 1-3 Filed 03/20/14 Page 6 of 17 5. Produce all non-privileged Documents relating to any of your officers, owners, directors, management and supervisors who are employed by or hold any position with UPMC Produce all non-privileged Documents relating to any labor or employment policy you have ormulated and/or administered with, by, for, or for the benefit of, UPMC Presbyterian Produce all non-privileged Documents relating to any premises or ~ilities ed or occupied by you in which UPMC Presbyterian Shadyside has any offices or y operations, and any premises or facilities owned, leased or occupied by UPMC Presbyte an Shadyside in which you have any offices or conduct any operations. L. Produce all non-privileged Documents relating to any services you have provided Presbyterian Shadyside, including but not limited to, information services, Human Resource , regulatory/compliance, finance, treasury, risk management, facilities, quality and Produce all non-privileged Documents relating to any services UPMC Presbyt an Shadyside has provided to you, including but not limited to the services set forth in Request Produce all non-privileged Documents relating to any facilities or operations in which yo and UPMC Presbyterian Shadyside share common system-wide technology resources. Produce all non-privileged Documents relating to any investment portfolios for UPMC sbyterian Shadyside. . 5 Ca e 2:14-mc-00111-AJS Document 1-3 Filed 03/20/14 Page 7 of 17 Produce all non-privileged Documents relating to any Revenue Bonds issued by · any pers n, including but not limited to the Allegheny County Hospital Development Authority, on whic you and UPMC Presbyterian Shadyside are jointly and severally obligated. Produce all non-privileged Documents relating to your joint or common owne · or leases of any real property with UPMC Presbyter1an Shadyside , including ·on of each property or lease and the respective percentage ownership of each. Produce all non-privileged Documents relating to any health and life insurance, pension, tock option, retirement or other benefit plans sponsored or administered by you for the . benefit o the employees UPMC Presbyterian Shadyside. Produce all non-privileged Documents relating to your joint or common or control of any bank accounts, _securities, notes, bonds, and/or other types of struments or assets with UPMC Presbyterian Shadyside. This Request includes Docume ts identifying the locations and account numbers of such accounts, instruments or assets an the individuals designated as authorized signators or having comparable authority with respectt Produce all non-privileged Documents relating to any liability insurance you provide t1 r UPMC Presbyterian Shadyside. Produce all non-privileged Documents relating to any contracts or agreements you have ente ed into with any third party vendors or consultants , or funding you have provided, relating providing quality improvement, technology. or patient safety consulting services for the bene t ofUPMC Presbyterian Shadyside or any other UPMC-Related Facility or Operation. Produce all non-privileged Documents relating to any contracts or agreements you have 'ente ed into with any third party vendors or consultants or funding you have provided 6 Ca e 2:14-mc-00111-AJS Document 1-3 Filed 03/20/14 Page 8 of 17 . relating t security services for the benefit ofUPMC Presbyterian Shadyside or any other UPMC·& lated Facility or Operation. Produce all non·privileged Documents related to the delegation of any authority or functio , including but not limited to policy making, from UPMC to UPMC Presbyterian Shadysid . This Request includes all Documents related to the implementation by you or UPMC Shadyside of such delegation. Produce all non-privileged Documents relating to the withdrawal of the delegation ority or functions to UPMC Presbyterian Shadyside . This Request i:ncludes all Documen related to the implementation by you of such withdrawal of delegation. ...., . Produce all non·privileged Documents relating to any actions of the UPMC Ethics and Co liance Committee of the UPMC Board concerning the review and approval of the Produce all non-privileged Docwnents relating to UPMC' s implementation, or withdrawal of the delegation of any labor or industrial relations functions to UPMC Produce all non-privileged Documents relating to UPMC's implementation, or withdrawal of the delegation of any employee relations functions to UPMC Shadyside. Produce all non-privileged Documents relating to UPMC's implementation, or withdrawal of the delegation of any human resources or personnel functions to sbyterian Shadyside. 7 Ca e 2:14-mc-00111-AJS Document 1-3 Filed 03/20/14 Page 9 of 17 25. Produce all non-privileged Documents relating to UPMC's implementation, delegatio or withdrawal of the delegation of any employee discipl~ functions to UPMC Presbyte 26 con Shadyside. · Produce all non-privileged Documents relating 1o policies and procedures UPMC's operation, administration and governance, including UPMC's human resources, personnel and labor relations. 27 Produce all non-privileged Documents relating to UPMC's policies and concerning its relationships or dealings with UPMC Presbyterian Shadyside. Produce all non-privileged Documents relating to UPMC's governance, or oversight ofUPMC Presbyterian Shadyside, including but not limited to any reports by UPMC Presbyterian Shadyside to UPMC. 29 Produce all non-privileged Documents relating to UPMC's creation, approval or oversight f, or participation in the formulation or implementation of, any strategic plans related byterian Shadyside, including but not limited to any reports by UPMC Shadyside to UPMC regarding such strategic ·plans. Produce all non-privileged Documents relating to UPMC's creation, approval or .( or participation in the formulation or implementation ot: any operating and capital budgets, rrowing or any transaction relating to indebtedness for UPMC Presbyterian Shadyside including but not limited to any reports by UPMC Presbyterian to UPMC regarding . This Request includes all Documents relating to any pledge of assets, major outside the approved budgets, and audited financial reports. 8 Ca e 2:14-mc-00111-AJS Document 1-3 Filed 03/20/14 Page 10 of 17 3 ¢ Produce all non-privileged Documents relating to UPMC's approval. oversight of, or inv lvement in, any UPMC Presbyterian Shadyside transactions involving the acquisition or sale o real property or improvements thereto, or material leases for the same. Produce all non-privileged Documents relating to UPMC's approval of, or t ~ 8J1Y amendments to the Articles of Incorporation or the Bylaws ofUPMC Presb Shadyside. Produce all non-privileged Documents relating to UPMC's approval of or involvem nt, in the hiring or appointment of any senior management staff: however structured or MC Presbyterian Shadyside. This Request include3 but is not limited to, approval for or in¥ lvement in, the hiring or appointment of, UPMC Presbyterian Shadyside's Senior l, Executiv , President, Chief Executive Officer. Chief Operating Officer, Chief Financial Officer, sing Officer, Medical Director, Department Chairpersons and Chiefs of Service, as terms of the employment or contractual relationship with each. Produce all non-privileged Documents relating to UPMC's approval of or involvem t in, any decisions regarding the provision of management services to UPMC Presbyte an Shadyside , including but not limited to services to be provided by UPMC or other Produce all non-privileged Documents relating to UPMC's approval of or t in any change in corporate structure or reorganization for UPMC Presbyterian Produce all non-privileged Documents relating to UPMC's approval of or :tin, UPMC Presbyterian Shadyside's major information systems and other systems. 9 Cas 2:14-mc-00111-AJS Document 1-3 Filed 03/20/14 Page 11 of 17 . . Produce all non~privileged Documents relating to UPMC ¢s approval of or ent in, UPMC Presbyterian Shadyside's contracts, including clinical, administrative or ployce benefits and compensation plans. Produce all non-privileged Documents relating to UPMC's Articles of tion and By Laws, including all amendments. Produce all non-privt1eged Documents relating to minutes of all UPMC Board of s and Board Committee meetings, including any other documents utilized in conjunction Produce all non-privileged Documents relating to the identities and employment of each member of the UPMC Board of Directors, each UPMC corporate officer, and MC executive or senior management employee. Produce all non-privileged Documents relating to each member of the UPMC Directors who is also a member of the Board of Directors ofUPMC Presbyterian S~ysi e. This Request includes all Documents identifying such common Board members by tle, employment and position held. Produce all non-privileged Documents relating to each UPMC corporate o:fflcer, , or member of senior management who is also employed by or who holds any position MC Presbyterian Shadyside. This Request includes all Documents identifying such officials and employees, and each position held with UPMC and with UPMC Produce all non-privileged Documents relating to the interpretation, application, 10 Cas 2:14-mc-00111-AJS Document 1-3 Filed 03/20/14 Page 12 of 17 HR. 071 ) relating to solicitations and distribution of literature not related to UPMC business, Produce all non-privileged Documents relating to the interpretation, application, ·on, enforcement or non-enforcement of any versi~ of the Solicitation Policy (HS relating to the use of the UPMC electronic messaging system to engage in solicitation, Produce all non-privileged Documents reLating to the interpretation, application, · tion, enforcement or non-enforcement of any versions of the Solicitation Policy (HS HR 071 ) relating to the wearing of non-UPMC approved buttons or insignia, from January 1, Produce all non-privileged Documents relating to the intetpretation, application, · tion, enforcement or non-enforcement of any versions of the Solicitation Policy (HS relating to the use ofUPMC bulletin boards for purposes not approved by or related C sponsored matters, from January 1, 20i2 to·the present. Produce all non-privileged Document3 relating to the interpretation, application, ·on. enforcement or non-enforcement of any versions of the Electronic Mail and Messag· g Policy (HS ISO 147) from January 1, 2012 to the present. Produce all non-privileged Documents relating to any traiDing, guidance, instructi n or directives provided to any UPMC manager or supervisors or UPMC Presbyterian Shadysi e manager or su{lervisor, relating to the enforcement or non-enforcement of any version 's Solicitation Policy (HS HR 0717) or the Electronic Mail and Messaging Policy (HS from January 1. 2012 to the present 11 Ca e 2:14-mc-00111-AJS Document 1-3 Filed 03/20/14 Page 13 of 17 Produce all non~privileged Docwnents which relate to any audit or investigation since January 2012 of the non~work use of the UPMC electronic messaging system . undertak by any ployees ofUPMC Presbyterian Shadyside and the results of same. Produce all non~privileged Documents relating to the interpretatio~ application, ·on, enforcement or non~ enforcement of any version of the UPMC Absenteeism and dis Tardiness Policy (HR.-03), including any audit or investigation 1mdertaken since January 2012 of the imple entation and/or enforcement of this Policy in any or all departments ofUPMC Pres an Shadyside and the results of same. 51. diss Produce all non-privileged Documents relating to the interpretation, application, ·on, enforcement or non..enforcement of any version of the UPMC Time Entry Subm.issi n Policy (HS HR-0741), including any audit or investigation undertaken since January e implementation and/or enforcement of this Policy in any or all deparbnents of UPMC sbyterian Shadyside and the results of same. Produce all non-privileged Documents relating to the interpretation, application, diss:em.J~· on, enforcement or non-enforcement of any version of the UPMC 'Supply Chain -Distribution and Materials Management Attendance Policy, including any audit tion undertaken since January 2012 of the implementation and/or enforcement of this y or all departments ofUPMC Presbyterian Sha4yside and the results of same. Produce all non-privileged Documents relating to the interpretation, application, dissemina ·on, enforcement or non-enforcement of any version of the UPMC Supply Chain -Distribution and Materials Management Tardiness Policy, including any audit or investiga 'on undertaken since January 2012 of the implementation and/or enforcement of this y or all departments ofUPMC Presbyterian Shadyside and the results of same. 12 Cas 2:14-mc-00111-AJS Document 1-3 Filed 03/20/14 · Page 14 of 17 Produce all non-privileged Doc1m1ents relating to the interpretation, application, tion, enforcement or non-enforcement of any versions of the Corrective Action and Policy (HS HR. 0704) from January 1, 2012 to the present. This Request also includes any other olicies relating to the placement and/or monitoring of employees placed on Produce all non-privileged Documents relating to the interpretation, application, ·on, enforcement or non-enforcement of any policies relating to job abandonment disse 1, 2012 to the present. Produce all non-privileged Documents relating to the interpretation, application, dissenlina~u·on, enforcement or non-enforcement of any versions of the UPMC Grievance Policy (HS-HR 0707) from January 1, 2012 to the present. Produce 1non-privileged Documents relating to the interpretation, application, dissemination, t or non-enforcement of the any policies governing the ll!!e of cell phones by of Presbyterian Shadyside in the Corporate Services/Employee Transit Department. Produce all non-privileged Documents relating to compliance with the National Labor Rei tions Act (NLRA), consequences of non-compliance with the NLRA. compliance with the s ttlement agreements in UPMC !(Case Nos. 06-CA-081896 et al), and consequences pliance with the settlement agreements in UPMC !(Case Nos. 06-CA-081896 et al). includes any training, guidance, directives or instruction given to or received by employed by or holding any position with UPMC Presbyterian Shadyside relating to 58 For each person identified in ~1[7 (a) and ~7 (b) of the Complaint, produce all non- privileged Documents relating to any Discipline imposed upon that person, relating to any ofthe 13 Ca e 2:14-mc-00111-AJS Document 1-3 Filed 03/20/14 Page 15 of 17 incident alleged in any of the Complaints in UPMC I (Case Nos. 06-CA-081896 et al) or the Compl · t in the instant case. This Request includes any training, guidance, directives or instructi n given to or received by each identified person. For each person employed and identified in ,7 (a) and ,7 (b) of the Complaint, . non-privileged Documents relating to any Discipline imposed by that person upon any emp · yees of Respondent Presbyterian Shadyside from January I, 2012 to the present. For each person identified in f7 (a) and ,7 (b) of the Complaint, produce all nonprivilege Documents relating to any training, guidance, directives or instruction given to or received y that person relating to the Union, the Union Organizing Campaign, Union avoidance, · g the Union from representing the employees ofUPMC Presbyterian Shadyside, or any activity · Su.pport of or opposition to the Union. Produce all non-privileged Documents relating to any meeting concerning the Union, e Union Organizing Campaign, Union avoidance, preventing the Union from the employees ofUPMC Presbyterian Shadyside, or any activity in support of or to the Union. This Request includes, but is not limited to, all minutes, recordings, notes, an materials disseminated at such meetings. Produce all non-privileged Documents relating to any training, guidance, directive , or instruction provided to employees ofUPMC Presbyterian Shadyside relating to the Union Organizing Campaign, Union avoidance, preventing the Union from the employees ofUPMC Presbyterian Shadyside, or any activity in support of or Produce all non-privileged Documents relating to any contract, agreement or arrangem nt with any consultant or vendor relating to the trB;ining of management and 14 Ca e 2:14-mc-00111-AJS Document 1-3 Filed 03/20/14 Page 16 of 17 sory personnel of UPMC Presbyterian Shadyside concerning the Union, the Union Org~mtg Campaign, union-avoidance or maintaining a "union free" workplace, preventing the m representing the employees ofUPMC Presbyterian Shadyside, or any activity in of or opposition to the Union. Produce all non-privileged Documents relating to any internal complaints or OhRerv:ttt'ons by any employee ofUPMC Presbyterian Shadyside concerning discrimination, retalia on, abusive treatment, or hostile work environment because of actual or perceived for the Union from January 1, 2012 to the present. Produce all non-privileged Documents relating to the Union and/or the Union Organi · g Campaign, including without limitation, electronic intranet postings, employee monitor screen savers, web pages, archived web pages, social media postings, ·cations between and among managers and supervisors, and Communications with employ es ofUPMC Presbyterian Shadyside or any other UPMC-related facility or operation. est includes all Documents relating to the creation, placement, transmission and ion of each computer monitor screen saver in each ofUPMC Presbyterian Shadyside's or at any other UPMC-related facility or operation, as well as the duration, timing, Produce all non-privileged Docwnents relating to the maintenance, operation, ent, and utilization of the UPMC Infonet website. This Request includes all Docum nts relating to any joint maintenance, operation, establishment, and utiliza:tion of the onet with UPMC Presbyterian Shadyside. Produce all non-privileged Documents relating to the incident which occurred in the cafe eria of Presbyterian Hospital on February 21,2013 as described in ffll-14 of the 15 Ca e 2:14-mc-00111-AJS Document 1-3 Filed 03/20/14 Page 17 of 17 ~· Complain . This Request includes but is not limited to, mcident reports, logs, telephone records, investig ons, directives, instructions, guidance, photographs and recordings relating to the incident. 68 Produce all non-privileged Documents relating to any incident, event or where UPMC Presbyterian Shadyside's agents or employees conducted surveillance or were Presbyteri tructed to conduct surveillance or appear to conduct surveillance upon any of UPMC Shadyside's employees concenung any matter related to the Union or the employee ' concerted activities. 69 Produce all non-privileged non-work-related ema.ils sent or received by, or from, each supe · or or manager ofUPMC Presbyterian Shadyside to any other employee ofUPMC Shadyside, using the UPMC email system from January 1, 2012 to the present. 16
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