At all times relevant to this proceeding, respondent Teamsters Local 264 (hereinafter Local 264) represented a comprehensive bargaining unit consisting of various individuals employed by petitioners. In May 1994, respondent Erie County Sheriff's Police Benevolent Association (hereinafter the PBA) filed a petition with respondent Public Employment Relations Board (hereinafter PERB) seeking permission to "carve out" a new bargaining unit for...
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