f the Act. 29 U.S.C. 156. A determination of necessity under Section 6 made by the Board, as administrator of the NLRA, is entitled to deference. See Ragsdale v. Wolverine World Wide, Inc., 535 U.S. 81, 86 (2002). Furthermore, even in the absence of express rulemaking authority, “the power of an administra

encrypted disks containing the exhibits referenced in er written response, and has emailed other exhibits that were not included on the disks. Mr. Ragsdale's letter also requested background information concerning Villafaiia's professional background and experience. The remainder of this letter provides

on, for example, le]xplain why the USAO decided to initiate a federal grand jury investigation" (id. at 2). 15.Mprepared a 58-page response to Mr. Ragsdale's letter ("Response"), along with a 51-page timeline ("Timeline"), a 14-page chart summarizing victim notifications ("Chart"), a 10-page exhibit li

for example, "[e]xplain why the USAO decided to initiate a federal grand jury investigation" (id. at 2). 16. I prepared a 58-page response to Mr. Ragsdale's letter ("Response"), along with a 51- page timeline ("Timeline"), a 14-page chart summarizing victim notifications ("Chart"), a 10-page exhibit li

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ncrypted disks containing the exhibits referenced in her written response, and has emailed other exhibits that were not included on the disks. Mr. Ragsdale's letter also requested background information concerning AUSA Villafafia's professional background and experience. The remainder of this letter pro