NATIONAL LABOR RELATIONS BOARD
Division of Contempt
Litigation & Compliance Branch
Washington, DC

The function of the Contempt Litigation and Compliance Branch is to conduct civil and criminal contempt litigation in the U.S. courts of appeals to coerce compliance or to punish non-compliance with judgments enforcing orders of the Board; to obtain protective orders to ensure that assets will not be dissipated in an effort to avoid the payment of back pay judgments; to institute and monitor ancillary collection proceedings; to assist the Regional Offices in bankruptcy proceedings filed by respondents; and to obtain other injunctive relief pendente lite. Contempt litigation is nation-wide in scope, affects all segments of industry and applies to all unfair labor practices proscribed by law. Through this litigation, the Branch seeks to obtain compliance with orders of the Board that have been enforced by judgments of the U.S. courts of appeals and other orders of the courts of appeals, and thereby effectuate the policies enunciated in the National Labor Relations Act and the orders of the courts.

Work in the Contempt Branch is centered in four primary areas: civil contempt, criminal contempt, protective order/collection work and compliance guidance. Civil contempt actions involve, among other things, evidentiary investigations, the drafting of internal legal memoranda and court pleadings, civil discovery (document production, requests for admissions, depositions, interrogatories), motions practice, settlement negotiations, bench trials, the drafting of appellate briefs and the presentation of appellate arguments. Criminal contempt actions involve, in addition to much of the work detailed above, federal grand jury work and jury trials.

The Contempt Branch is also responsible for obtaining injunctive relief in order to ensure compliance with enforced Board orders, engaging in affirmative bankruptcy litigation and collection work, and providing guidance and assistance to the Board's Regional Offices in enforcement and compliance matters.

The Peggy Browning Fund intern, where possible, will participate in discovery proceedings and assist attorneys at trial. Every effort will be made to give the intern an opportunity to perform legal work done by some of the other offices that are also within the Division of Enforcement Litigation and to attend meetings with the General Counsel and the Board Members where active cases are considered. The summer intern will be provided with as much diversity in litigation assignments as possible.

Students interested in applying to the above NLRB division for a Peggy Browning Fund internship should submit an application package to:

Kenneth Shapiro, Esquire, Deputy Assistant General Counsel
National Labor Relations Board
Contempt Litigation and Compliance Branch
Office of General Counsel
1099 14th Street, N.W.
Washington, DC 20570-0001
202-273-3742

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