O'Brien (P) was charged by a fellow union member with violating certain section of the IBEW constitution when he distributed literature that was detrimental to the union. Local 613 head the charges, fined P and suspended him from local union activities. Local 613's decision was rescinded when it was discovered that the IBEW (D) had jurisdiction over the charges. P was found guilty by D and fined $100. P sued D in that the charges, trials, and disciplinary measures violated P's rights to free speech and assembly guaranteed under 29 U.S.C. ¤411 (a)(2). Disputes then developed over the answering of interrogatories posed by P. (Interrogatory #4 is listed on page 76 of Field 7th).