UNION UNFAIR PRACTICES; DUTY OF FAIR REPRESENTATION – Mode or Adequacy of Representation/Advocacy

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No violation of duty of fair representation by the union’s failure to seek arbitration, where the record does not establish whether the case was even eligible for arbitration, as the charging party failed to appear at the meeting to review his termination. The record also did not establish that the charging party requested the union to seek arbitration within the time limit for doing so.