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Unlike ordinary federal pleading rules, where respondents must defend only against allegations naturally emanating from notice pleadings, complaints filed under the National Labor Relations Act can evolve from original charges filed by a complaining witness to much broader complaints against a respondent. Because the party plaintiff is a federal agency which takes the initial charge of NLRA violations as “the spark that leads to the investigation,” respondents are, arguably, unfairly asked to defend against a moving target.

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