EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; NEGOTIATIONS; INDICIA OF SURFACE OR BAD FAITH BARGAINING; TOTALITY OF CIRCUMSTANCES – Inflexible Position

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* * * OVERRULED IN PART ON OTHER GROUNDS by The Accelerated Schools (2023) PERB Decision No. 2855 * * *
Employer's counter-proposals may be viewed as evidence of bad faith; p. 38.