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Gaetano Urgo

Gaetano’s practice focuses on litigation, primarily in the areas of management-side labor and employment matters, municipal law, and corporate law. Currently based in Davis & Campbell’s Chicago office, Gaetano is a member of the Chicago Bar Association, the Justinian Society of Lawyers and the Fenwick Bar Association.

Gaetano joined Davis & Campbell in 2021, following his graduation from DePaul University College of Law. At DePaul, Gaetano focused on litigation process and techniques, and took an interest in the latest developments in Sports law including NIL rights, athlete intellectual property, and the potential impact on labor relations. Gaetano authored a publication in the field and was later chosen to serve as Editor-in-Chief of DePaul’s Journal of Sports Law and Contemporary Problems.


  • University of Illinois at Urbana-Champaign (B.S., 2017)
  • DePaul University College of Law (J.D., magna cum laude, Order of the Coif; Certificate in Business Law)
    • CALI Excellence for the Future Awards – Advanced Civil Procedure; Consumer Protection Law; Entertainment Law
    • Editor-in-Chief – DePaul Journal of Sports Law and Contemporary Problems
      • Klawing for Protection: Kawhi Leonard’s Battle with Nike Over Intellectual Property Rights. (DePaul Journal of Sports Law, 2020)
    • Student Attorney – DePaul University College of Law Civil Litigation Clinic

Contact Gaetano Urgo

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Office Locations

Chicago, IL

333 S Wabash Avenue, Suite 2700
Chicago, Illinois 60604

Phone: (312) 995-7110
Fax: (312) 995-7102

Gaetano Urgo Practice Areas

Gaetano Urgo In the News

NLRB Clarifies Bargaining Obligations Under OSHA’s ETS

On November 5, 2021, OSHA issued an Emergency Temporary Standard (“ETS”) to protect workers from COVID-19. The ETS covers employers with 100 or more employees and requires covered employers to develop, implement, and enforce a mandatory COVID-19 vaccination policy unless the employer adopts a policy requiring employees to choose either to be vaccinated or undergo regular COVID-19 testing and wear a face covering at work.

When it comes to bargaining obligations that may arise under this ETS, the General Counsel for the NLRB weighed in on November 10, 2021, with a new Operations Memorandum. View Memorandum

The NLRB’s position is that covered employers will have decisional bargaining obligations regarding aspects of the ETS that affect terms and conditions of employment to the extent the ETS provides employers with choices regarding implementation. While an employer is relieved of its duty to bargain where a specific change in terms and conditions of employment is statutorily mandated, the employer may not act unilaterally so long as it has some discretion in implementing those requirements.

The ETS affects terms and conditions of employment including the potential to affect the continued employment of those who become subject to it. To the extent elements of the ETS do not give covered employers discretion, the employer is nonetheless obligated to bargain about the effects of the decision. Whether a covered employer may implement a mandatory policy prior to a valid impasse or agreement when bargaining over effects will depend on the facts of the situation. 

Moving forward on implementation of the ETS at union facilities may require an employer to analyze its collective bargaining agreement and notify the union of its implementation of the new OSHA requirement.

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