MEMORANDUM AND ORDER
BRIEANT, District Judge.
On August 30, 1976 the Committee of Interns and Residents ("CIR") commenced four separate proceedings in the New York State Supreme Court, New York County, pursuant to Article 78 of the New York Civil Practice Law and Rules ("CPLR") to review and annul orders of the State Labor Relations Board ("State Board"). Three of these orders had dismissed charges of unfair
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