v3237x-37
SUBJECT INDEX
Page
Statement of the Case _ . . 1
Specification of Error No. 1 4
Specification of Error No. 2- 4
Argument: 5
- Preliminary Contention 5
It is not per se an unfair labor practice to
picket to enforce a subcontractor's clause.
- Arbitration Contention 6
(a) The issue involved hereunder is one
of first impression to the courts of this
nation 6
(b) The evidence compels a finding that
arbitration was the immediate and
sole objective of the picketing 7
(c) Policy is strongly in favor of arbitrat-
ing labor disputes 8
(d) The so-called "an object" test must be
interpreted in conjunction with the
"primary picketing" provision of the
law 9
(e) Mills was not "powerless to prevent"
the picketing as is required by the
Denver Building Trades case 12
- Insubstantial Evidence Contention 13
There is no substantial evidence to support
the Board's findings and order.
Specification of Error No. 3 16
Specification of Error No. 4 16
Specification of Error No. 5 16
Argument: Erroneous Exclusion of Evidence and
Reliance Thereon 17
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