[jrflowers]

This is a good point. Aside from the 3 specific incidents where they claim exactly that on page 13 of the document, the first amendment doesn’t get brought up. If you choose to skip reading those bits it is as if it isn’t mentioned at all.

[fUCp62]

Respectfully disagree. The sparse mention of alleged 1A violations is just how the pleading stage of pretrial litigation works. This pleading (Defendant's Answer to Complaint) serves to (among other things) (1) explicitly respond to each of the allegations that the Plaintiff raises in their initially filed complaint (p. 1-10), and (2) preserve any defenses that they might raise in the subsequent proceedings here (p. 13). You shouldn't read any correlation between how much a certain defense is discussed in this doc and how strong they perceive that argument to be- at trial (or in the summary judgement motions that Amazon will inevitably file here), they could focus their entire argument alleging 1A violations, or dispose of this argument entirely. Point is, they preserved that choice with this single, albeit short paragraph.

Dropping it here for posterity:

> 3. The meeting referenced in Complaint ¶ 13 was voluntary, but in any event, any Board Decision and Order concluding that it is unlawful to conduct mandatory meetings about unionization or unions or any particular union or about the actual subjects of the meeting in question would violate the First Amendment to the U.S. Constitution and Section 8(c) of the Act.