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
- An internal corporate memorandum to the Company’s 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.