Are you persuaded that there is a difference between "mere negligence" in failing to file a grievance and "egregious disregard" in failing to file a contractual time limit for submission of a grievance to arbitration. Where the timeliness of the union's notice is arbitrated-there being a dispute over the contract's use of the word "receipt' for the notice-and the submission is held to be untimely, can the union have been in breach of its duty of fair representation? Burnett v. Washington Metropolitan Area Transit Auth., 58 F. Supp. 3d 104 (D.D.C. 2014).