Intl. Assoc. of Machinists

National Labor Relations Board - Board Decisions

Jun 26, 1970

183 N.L.R.B. 1225 (N.L.R.B. 1970)

INTL ASSOC. OF
International Association of Machinists and
Aerospace Workers, AFL-CIO, and its Agent,
Juan L. Maldonado and General Electric Com-
pany, Circuit Protective Devices Department,
Caribe Plant Operations ; General Electric Power
Products , Inc.; General Electric Circuit Breakers,
Inc. Case 24-CB-718
June 26, 1970
DECISION AND ORDER
BY MEMBERS FANNING, BROWN , AND JENKINS
On April 7, 1970, Trial Examiner Owsley Vose
issued his Decision in the above-entitled proceed-
ing, finding that the Respondent had engaged in
and was engaging in certain unfair labor practices
and recommending that it cease and desist
therefrom and take certain affirmative action, as set
forth in the attached Trial Examiner's Decision.
The Trial Examiner also found that the Respondent
had not engaged in certain other unfair labor
practices alleged in the complaint and recom-
mended that these allegations be dismissed.
Thereafter, the Respondent filed exceptions to the
Trial Examiners Decision and a supporting brief.
Pursuant to the provisions of Section 3(b) of the
National Labor Relations Act, as amended, the Na-
tional Labor Relations Board has delegated its
powers in connection with this case to a three-
member panel.
The Board has reviewed the rulings of the Trial
Examiner made and finds that no prejudicial error
was committed. The rulings are hereby affirmed
The Board has considered the Trial Examiner's
Decision, the exceptions and brief, and the entire
record in the case, and hereby adopts the findings,
conclusions, and recommendations of the Trial Ex-
aminer
ORDER
Pursuant to Section 10(c) of the National Labor
Relations Act, as amended , the National Labor
Relations Board adopts as its Order the Recom-
mended Order of the Trial Examiner and hereby
orders that Respondent , International Association
of Machinists and Aerospace Workers, AFL-CIO,
and its agent Juan L Maldonado , Rio Piedras,
Puerto Rico, its officers , agents, and representa-
tives, shall take the action set forth in the Trial Ex-
aminer 's Recommended Order.
MACHINISTS 1225
TRIAL EXAMINER'S DECISION
STATEMENT OF THE CASE
OWSLEY VOSE, Trial Examiner: This case was
heard at Hato Rey, Puerto Rico, on January 21 to
23, 1970,' pursuant to a charge and amended
charges filed by the Charging Parties on October 30
and 31 and November 6, and a complaint issued on
November 26. The complaint as amended at the
hearing presents the question whether the Respon-
dents violated Section 8(b)(1)(A) by certain acts
and conduct during a strike at the plant of the
Charging Parties at Palmer, Puerto Rico.
Upon the entire record and my observation of
the witnesses, and after due consideration of the
briefs filed by the Charging Parties and the Respon-
dents, I make the following:
FINDINGS AND CONCLUSIONS
1. JURISDICTIONAL FINDINGS
The Charging Parties, General Electric Com-
pany, Circuit Protective Devices Department,
Caribe Plant Operations (Caribe); General Electric
Power Products, Inc. (Power Products); and
General Electric Circuit Breakers, Inc. (C B.I.),
hereinafter collectively referred to as the Company,
are Puerto Rico corporations operating plants at
Palmer, Puerto Rico, where they are engaged in the
manufacture of electrical products. All three cor-
porations constitute a single employer having its
labor relations policies centrally formulated, con-
trolled, and enforced. During the year preceding
the issuance of the complaint, the Company had
more than $50,000 worth of materials shipped to its
plant from places outside of Puerto Rico, and dur-
ing this same period shipped in excess of $50,000
worth of electrical products to destinations outside
of Puerto Rico.
Upon the foregoing facts I find that the Company
is engaged in commerce within the meaning of Sec-
tion 2(6) and (7) of the Act, and that it will effec-
tuate the policies of the Act to assert jurisdiction
over the unfair labor practices alleged in the com-
plaint.
II. THE LABOR ORGANIZATION INVOLVED
The Respondent, International Association of
Machinists and Aerospace Workers, AFL-CIO,
hereinafter called the IAM, is a labor organization
within the meaning of Section 2(5) of the Act.
III, THE UNFAIR LABOR PRACTICES
The IAM's Alleged Violations of Section
8(b)(1)(A) of the Act
' All date, mentioned hereinafter are in 1969, unless specified otherwise
183 NLRB No. 126
1226 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
A. Background
After the IAM won an election among the Com-
pany's employees which was conducted by the
Board's Regional Director at Hato Rey, the Com-
pany filed objections to the election based upon
certain preelection conduct of the IAM. While these
objections were pending before the Regional
Director, the IAM commenced distributing a series
of leaflets at the plant gates advocating that the em-
ployees go out on strike. As appears in a leaflet dis-
tributed outside the plant on October 9, a majority
of the employees at an IAM meeting on October 5,
voted to authorize strike action at some future date.
By a leaflet distributed by the IAM at the plant
gates on October 20, the IAM notified the em-
ployees that the Regional Drector had overruled
the Company's objections to the election and urged
full support for the strike at such time as it should
be called. On October 27 the IAM distributed
another leaflet at the plant gates announcing that
the Company had requested the Board to grant an
extension of time for filing an appeal from the Re-
gional Director's decision overruling the Com-
pany's objections to the election. This leaflet, which
was signed by Juan Maldonado as IAM representa-
tive, concluded with the following paragraph:
Why didn't [the Company] inform you that
they would appeal. I do not believe that I
should have to make any other comment.
The strike commenced during the early morning
hours of Tuesday, October 28. Although Mal-
donado, who is the IAM's special representative in
Puerto Rico, testified that he had not called the
strike at that particular time, he admitted that he
backed the strike as soon as it started.
B. Events During the Strike 2
1. Introduction ; the Company's facilities
The Company 's facilities consist of two main
buildings , one housing the operations of Caribe and
Power Products and the other the operations of
C.B.I. The plant area is surrounded by a chain link
fence. The main or front entrance to the plant area
is through a gate located on State Road 112. On
both sides of the private road leading from the main
gate into the plant are two large employee parking
lots. Each of these parking lots has two gates
through which employees can enter from State
Road 112 . The two nearest parking lot gates are
each less than 100 feet away from the main front
gate. The two farthest parking lot gates are about
200 feet further down the road in both directions.
Thus in a distance of about 600 feet along State
Road 112 there are five gates to the Company's
2 Since the IAM did not call any witnesses in its behalf, the facts found
below concerning the events during the strike are based upon the undemed
and credited testimony of witnesses called by the General Counsel , with the
exception of two incidents involving visits of IAM Representative Mal-
plant area. Access to the plant area is also afforded
by a back gate which is connected by an access
road, less than 300 feet long, to Old State Road 3.
The location of the employees' homes determines
whether they enter the plant area through the front
or back gates.
For the past 23 months the Company has kept all
these gates chained and padlocked in an open posi-
tion. Several weeks before the strike the Company
purchased and installed new padlocks. Another
union on strike at another employer 's plant had
recently adopted the strategy of locking the plant
gates closed, and the Company was aware through
the leaflets distributed at its gates that IAM
Representative Maldonado was advocating strike
action . This was the reason, as Caribe President
Davis testified, that the Company adopted the
precaution of keeping its plant gates locked in an
open position.
2. October 28
About 3 a.m. a guard informed Vincente Torres,
the supervisor of the night shift at the plant, that
someone had padlocked closed the front and the
back gates to the plant. Torres, after investigating
and verifying that this was true, notified higher
management and called the police. About this same
time, Torres observed two carloads of pickets arriv-
ing in the front gate area.
At 7 a.m. on October 28 Torres saw Roque
Escobar, a former company employee and a leader
in the IAM organizing campaign prior to the elec-
tion, open gate 8 in the south parking area to allow
the third-shift employees, some 10 to 12 in number,
to leave the plant. After they had left, Escobar
chained and padlocked the gate closed and joined
IAM Representative Maldonado who was standing
12 to 15 feet away. Gate 8 is adjacent to the front
main gate. There were some 300 persons in this
general area at the time, including pickets, em-
ployees seeking to go into work, policemen, and
bystanders.
Maldonado was in the area at 8 a.m., also, when
John Gibson, a tool and equipment specialist for
the Company, arrived at the main gate to go to
work. Observing a large number of persons stand-
ing around in the area, including a group of police-
men, and that the gates were chained closed,
Gibson left the area.
Shortly after 10 a.m. James Davis, plant manager
of Caribe, Arthur Ridolfi, manager of materials at
C.B.I., and Dale Wheeler, manager of engineering
and quality control at C.B.I., cut open the chain
with which the inner back gate had been padlocked
closed. Ridolfi and Wheeler continued on towards
the outer back gate intending to cut the chain on
donado to homes of nonstriking employees Maldonado was called as a wit-
ness by the General Counsel On a cross-examination by his counsel, Mal-
donado was questioned about these incidents and his testimony is con-
sidered in connection with my findings concerning these incidents
INTL. ASSOC. OF MACHINISTS
that gate also. However, they were greeted by the
strikers, who were outside the gate, with threats
and thrown rocks, and Davis instructed Ridolfi and
Wheeler to retreat before reaching the outer gate.
Later that morning Caribe Plant Manager Davis
and David Esperson, another of the Company's
plant managers , sought to approach the front gate,
but when they got within range they encountered
rocks thrown by the strikers. Esperson was hit on
the knee. Davis and Esperson then turned back.
That same day Davis overheard Nunez, a shop
manager who was approaching one of the parking
lot gates with a bolt cutter in his hand, being
warned by a striker nicknamed Cano, "Please get
back before you get hurt."
At 1:30 p.m. that day Ridolfi and Wheeler again
approached the outer back gate with a bolt cutter.
There were about 8 to 10 strikers, including Hector
Baez , a leader in the organizational campaign prior
to the election, in the vicinity of the gate at this
time, as well as about 4 policemen. As Wheeler and
Ridolfi neared the gate , Baez jumped up and went
to the fence, accompanied by four or five other
strikers. They all had sticks or clubs which they
poked through the wire mesh as Wheeler attempted
to cut the chain with a bolt cutter. They hit
Wheeler on the stomach, chest, and shoulder,
preventing him from cutting the chain. At the same
time Emilio Ramos, another striker, tossed a log 4-
or 5-feet long by 3 inches in diameter over the
fence, striking Wheeler in the head. While this was
going on, Ridolfi was attempting to persuade one of
the policemen to obtain reinforcements from a
nearby intersection where a larger number of police
were stationed. Baez goaded Wheeler into making a
second attempt and when he did so, he again was
struck with sticks through the fence. Baez then
signaled to another striker, who threw a bucket of
cold water on Wheeler. This other striker then
threw a small can of liquid on Wheeler which later
caused a warming sensation on his face and arms.
By this time about 25 additional strikers and 6 addi-
tional policemen had arrived. When Ridolfi asked
the assistance of the policemen in opening the gate,
their only reply was, "Wait." During this confronta-
tion, Samuel Rivera, one of the strikers, warned
Wheeler that he would kill Wheeler or Ridolfi if
either one attempted to cut the chain or step out-
side the gate.
3. October 29
Pursuant to assurances received from the police
earlier, additional policemen arrived at the plant
between 1:30 and 2 a.m. on October 29. There
were approximately 30 to 40 persons outside the
front gates at this time. Hector Baez waved his fist
in front of policemen and angrily yelled that "over
my body somebody is going to come in through this
gate." Later Baez , naming several supervisors,
threatened "that he would catch them outside; that
they were going to pay with their lives."
1227
About 7 a.m. IAM Representative Maldonado
was observed by company officials making a speech
to the 40 or 50 persons in the front gate area.
Shortly thereafter the Company received word from
the police that they were ready to give protection
to enable it to open the front gate. Caribe President
Davis and Materials Manager Ridolfi approached
the front gate with wire cutters. As Ridolfi started
to cut the chain, the crowd roared, "No, no, no, no.
... hand the scissors to Maldonado." A police of-
ficer instructed Ridolfi to give the cutters to Mal-
donado. Davis said, "No, we don't recognize Mr.
Maldonado," and instructed Ridolfi not to give up
the cutters. As the two men started backing away
from the gate, a stone arched over Ridolfi's head
and Davis was hit in the groin with a rock.
Approximately an hour later, word was received
from the police that additional policemen were on
duty at the front gate. A solid line of policemen was
set up in front of the gate and several supervisors
went down and were able to cut the chain, push the
gates back, and chain and padlock them in an open
position.
Around 9 a.m. John Gibson, a tool and equip-
ment specialist with the Company, drove to the
main gate and tried to enter. However, Maldonado
and a group of strikers stood around the car and
prevented him from entering the plant. Among the
strikers were Hector Baez and Juanita Hernandez.
The group, but not Maldonado, proceeded to shake
Gibson's car. The police refused to heed Gibson's
pleas for assistance and Gibson backed up and con-
tinued down the road.
A little later Plant Manager Esperson drove a sta-
tion wagon , in which four or five other manage-
ment officials were riding, up to the main gate and
attempted to drive in. A group of persons, some of
whom carried picket signs, were blocking the gate.
Among those in front of the station wagon were
Maldonado , Juanita Hernandez , and Hector Baez.
Police Lt. Col. Erosmos Lopez informed Esperson
that the pickets were blocking the entrance because
there were employees in the car. Esperson assured
Lopez that all persons in the car were members of
management. While this conversation was in
progress, a thrown bottle hit the window next to the
right front seat. Lt. Col. Lopez conferred briefly
with the pickets in front of the station wagon and
returned with the advice that they had better not
try to enter. Esperson followed this advice.
About 3:30 p.m. that day Materials Manager
Ridolfi attempted to drive Caribe President Davis,
C.B.I. President Kauffman, Engineering Manager
Wheeler, and one of the Company's attorneys, Mr.
Lugo, out of the front gate in a company station
wagon. There were approximately 15 to 20 pickets
standing by the gate at this time, including Juanita
Hernandez. Maldonado was standing in the
background talking to a policeman. Ridolfi told the
police officer in charge, "We don't want to create a
scene here. We don't want to get hurt and we don't
want to see anybody get hurt ... can you guarantee
1228 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
us safety passage through the picket line." The of-
ficer replied, "No sir, at this moment I don't have
enough troops around here to guarantee that." At
President Kauffman's direction, Ridolfi turned
back.
Having been frustrated in their efforts to leave by
the front gate, shortly thereafter Ridolfi and
Wheeler and a number of other supervisors left the
plant area by a side gate which opens out into
marsh land and open fields. Ridolfi and one group
went to the rear of the Rio Grande Industries plant,
located on an adjoining tract of land. Wheeler
made his way to Old State Road 3, and as he
neared the front of the Rio Grande Industries plant
a red Mustang screeched to a halt immediately be-
hind him. Wheeler jumped and started running for
the Rio Grande Industries plant. Nicholas Matta, a
leader in the IAM preelection organizing activities,
and three other men from the red Mustang chased
Wheeler into the building. He arrived there just
after Ridolfi and the other group who had witnessed
the men chasing Wheeler and had themselves de-
cided to retreat to the safety of the building.
Wheeler and the Ridolfi group entered the office of
the manager of the Rio Grande Industries. Matta
and the others followed them to the door of the of-
fice where they made threatening gestures, such as
to slash the throats of Wheeler, Ridolfi, and the
others. About this time about 15 more strikers en-
tered the building, all armed with clubs and they
brandished the clubs at the company officials and
shouted at them. Shortly thereafter the police came
and drove the company officials to a safe point.
When they left some 35 to 40 persons were milling
about in the street in front of Rio Grande Indus-
tries.
4. October 30
About 7:30 a.m. Ridolfi and C.B.I. President
Kauffman landed on Luquillo Beach in a rented
helicopter. Arrangements had been previously
made to have Attorney Lugo meet them there for a
lift into the plant. Not seeing Lugo anywhere in the
vicinity, Ridolfi got out of the helicopter to look for
him. As he reached a nearby road he observed Mal-
donado and three unidentified persons running
towards him around a corner. Ridolfi started
retreating backwards, step by step. As Ridolfi
backed away, Maldonado called him "a god
damned strike breaker" and told him "to get the
hell out of here." As he did so Maldonado lurched
forward and slapped Ridolfi in the face. One of the
other three men who was alongside Maldonado
started pushing Ridolfi back towards the helicopter
with his two hands. Ridolfi turned and went back to
the helicopter.
5. November 3
During the first week of the strike management
officials were able to enter the plant area only by
helicopter. About 6:30 a.m. on November 3 a
procession of four cars containing management of-
ficials arrived at the front gate. They were stopped
by a group of 40 to 50 strikers who were standing
around the gate. Numerous other persons were in
this general area. At this time Maldonado was
standing across the street about 50 feet away ob-
serving the scene. The first car, which Caribe Pre-
sident Davis was driving, was promptly surrounded
by pickets, including Hector Baez. A rock was
thrown completely through the left rear window of
the first car. A police officer motioned to Davis to
enter the plant. As he inched forward in the car
strikers beat on the car windows and the body with
clubs and rocks and the windshield was shattered
by clubs. As the next three cars passed by, the
strikers rained blows on all parts of the cars with
rocks, chains, and clubs, and shattered the
windshields of the other three cars. The occupants
of all four cars were showered with shards of shat-
tered glass and a few of the occupants received cuts
on their hands and faces from the flying glass. Mal-
donado, although he observed this violent conduct,
made no effort to stop it.
Later that morning, between 7 and 8 a.m., about
100 employees who were desirous of going to work
met in the plaza in the town of Palmer. When they
reached the point where Old State Road 3 meets
the access road to the back gate to the plant they
encountered a group of about 100 strikers armed
with clubs and chains. The strikers threatened and
cursed them, and about half of the employees seek-
ing work abandoned the effort. The rest continued
on down the access road to the back gate where
they were met by about 15 pickets, including Hec-
tor Baez, Nicholas Matta , and Juanita Hernandez.
The latter yelled "here by come, get them, hit
them, don't let them go." When the pickets started
waving sticks at them and cursing them, the em-
ployees gave up the attempt to go to work that
morning . While all this was going on Maldonado
was over to one side smiling broadly.
6. November 5
No employees made any attempt to go to work
on November 4. But on November 5 employees
seeking to go to work again gathered on the plaza
in Palmer. Damian Arocho went across the plaza to
the police station and asked for assistance for the
group in getting into the plant. When the group
neared the intersection of the access road and Old
State Road 3 they saw about 50 pickets scattered
on various corners. Juanita Hernandez was walking
back and forth in front of the pickets talking to
them. Among the other pickets were Hector Baez,
Nicholas Matta, and Nathaniel Lopez. IAM
Representative Maldonado was also talking to the
pickets. As the group reached the access road the
pickets commenced cursing the workers and mak-
ing threats, such as "Don't hurry, your wives and
children are alone in the house" and "We are going
INTL. ASSOC. OF MACHINISTS
to burn your car which is in the carport." Mal-
donado himself warned the workers that if they
went in they "would not come out." Then Mal-
donado stepped away and the pickets commenced
menacing the workers with the picket signs and
sticks. At this point some 15 or more policemen
who were in the vicinity forcibly cleared a path for
the workers , who were women for the most part.
They started running down the access road towards
the back gate to the plant . The pickets poked sticks
at them and threw stones at them as they ran.
Matta hit Rafael Gonzalez with a stick as Mal-
donado stood by laughing.
When the shift ended at 3 : 30 p.m . the workers
started walking down the access road . The police
sought to disperse pickets who were gathered
around the intersection of the access road and Old
State Road 3. Among the pickets were Juanita Her-
nandez, Matta , and Baez. Maldonado also was
present and he yelled " Now, now grab them, those
are the ones . . . . There are the strike breakers, hit
them hard ." A picket named Teresa , who had been
talking to Juanita Hernandez , hit a worker named
Diomina with a stick , as a result of which Diomina
fell down . Upon a hand signal from Maldonado,
Juanita Hernandez , Baez , and Matta started throw-
ing stones at the workers.
7. November 6
Employee Rafael Gonzalez was awaiting trans-
portation to the plant in the town of Rio Grande
early on November 6 when three cars drew up
alongside him, one containing Maldonado , Nicholas
Matta , Samuel Rivera , Nathaniel Lopez, and Car-
men Laura Cruz, and two others containing persons
whom he recognized as company employees, but
whose names he did not know . Maldonado, after
shouting , "There , that is the son of a bitch," got out
of the car and made a motion with his hand as if to
grab Gonzalez . Gonzalez started running and Mal-
donado commenced chasing after Gonzalez, ac-
companied by Carmen Laura Cruz and another girl.
Gonzalez ducked into a nearby laundry owned by
his father . Outside the laundry Maldonado sought
by gestures to get Gonzalez to come out , berated
him for going to work the previous day, and cursed
him. Maldonado and the others accompanying him
departed abruptly, just ahead of the police.
The workers assembled in the plaza on the morn-
ing of November 6 as they had the day before, and
again sought police protection . The workers en-
countered a solid mass of pickets at the intersection
with the access road , including Juanita Hernandez,
Matta , and Angel Fuentes . On this occasion Mal-
donado was sitting in his car addressing the pickets
over a loudspeaker. Among other things, Mal-
donado exhorted the pickets " to take the bags away
from the ladies and to hit [them], because the
women were the more daring ones ." Maldonado
also urged the pickets to "tear their clothes away."
The police managed to clear the way for the work-
1229
ers and they darted down the access road under a
barrage of rocks and bottles . Angel Fuentes hit
Josefa Lebron on the head with a stick.
Leaving the plant that aftrnoon the situation was
much the same . The pickets were gathered at the
intersection of the access road and Old State Road
3. Stones were flying and Jeremias Cabrera got hit
with a stone thrown by Samuel Rivera . Maldonado
was standing about 15 feet away from the pickets
laughing.
8. November 7
Fewer workers showed up at the plaza on the
morning of November 7. The pickets were at the
intersection as usual , as were a number of po-
licemen . However , Maldonado was not present.
Damian Arocho approached the pickets and
inquired who was in charge. Juanita Hernandez and
Hector Baez replied, "We are." Arocho sought per-
mission for himself and 15 girls, who had worked
November 5 and 6 , to enter the plant . He urged
that they needed the money, that they were not
going to do much production , and that they would
not undermine the strike in any significant way.
Finally Hernandez and Baez agreed . Arocho went
back to the plaza and brought his group to the
picket line . The pickets allowed the girls to pass
through , but, according to Arocho, as he passed
through " Hell broke loose. ... They closed in on
me. They hit me, they called me all kinds of names
.... son of a bitch, traitor , queer , bastard." The
police came and pulled off Arocho 's attackers and
he went on into the plant.
Coming out of the plant at 3:30 p . m. that day,
the pickets attacked the group with " hundreds of
stones." Leading the attack were Juanita Hernan-
dez, Matta, Baez, and Angel Fuentes . Fuentes
threatened to kill Arocho that day. The group fled
into the police station. Arocho waited there for
things to quiet down for about 2 hours. The
pickets, however , did not disperse . They were wait-
ing when Arocho left the police station in the com-
pany of a police officer who was driving him home
and again threatened to kill him. As soon as
Arocho arrived home , he put his family in the car
and left town . He explained , " I was scared that
time."
9. Maldonado 's visits to homes of workers
About a week after Arocho 's first return to work
Maldonado visited Arocho 's home in Rio Grande
with a group of men in three cars. According to
Arocho , Maldonado was accompanied by about 25
men, including Matta and Fuentes. Arocho testified
as follows about this incident:
I invited Mr. Maldonado to my place, then
he explained to me that he was having-lead-
ing the strike , because he wanted our welfare
and he tried to convince me to join them on
the strike and that he needed a little more time
to make the company sign, then I specifically
1230 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
told him that no dice , that I would not join
them . Then he changed from the sweet mellow
tones to telling me that he knew people in
Fajardo that would kill anybody for a dime, for
a nickel , that my life was in danger , and I said,
"I know those people , too, but I am still going
to work ." But finally I agreed with him. I said,
"I am going to stay home a week and then I am
going to move again and go to work if I can
because I got a family to support , and we were
talking for about forty -five minutes ... It was a
threatening visit , because he went with the
three carloads of people.
Then he left and I told him at the time when
I go back there is going to be some people with
me and I would hate for something bad to hap-
pen. "It is your responsibility to control your
people, not to throw stones or maybe kill
somebody , because when this happens, comes
up, anything can happen , and I think it is your
responsibility to control your people." And he
waved and left, waved like "I don 't care." .. .
On cross-examination by counsel for the Respon-
dent , Maldonado explained his visit to Arocho's
home as follows : He had been informed that
Arocho may have been the source of information
on which the newspaper , El Mundo , based an arti-
cle which referred to Maldonado as a Communist
and stated that as a result of his communistic prac-
tices certain employees of the Company had aban-
doned the IAM. Accordingly, he visited Arocho's
home to discuss the matter with Arocho. Mal-
donado testified that Arocho denied having given
the information to El Mundo and that " the theme
changed to [Arocho's] financial problems because
he had a large family...." Maldonado did not deny
that he was accompanied by three carloads of men
on his visit; nor did he deny Arocho's testimony
concerning Maldonado's mentioning men in Fajar-
do who would kill anybody for a dime or a nickel.
Under all the circumstances, I credit Arocho's
testimony concerning the portion of the conversa-
tion with Maldonado quoted above and find the
facts to be as therein stated.
Maldonado also visited the home of Rafael Gon-
zalez in Rio Grande under similar circumstances.
This visit occurred after the incident involving Mal-
donado 's chasing Gonzalez into his father 's laundry.
On this occasion Maldonado came with four car-
loads of "people ." The discussion concerned the
same El Mundo article as was involved in the visit
to Arocho's home. No threats were uttered on this
occasion.
On two or three other occasions at night Mal-
donado drove slowly past Gonzalez ' home in a car
in which Juanita Hernandez, Matta, Samuel Rivera,
and one other were riding . As the car drove past,
the occupants peered into Gonzalez ' house.
C. Conclusions
1. The law governing union responsibility for strike
misconduct
The IAM's contentions in general are discussed
below . Its principal contention is that the actions of
the pickets on the picket line were not authorized
by it and that consequently it is not responsible for
their conduct . In view of this contention it is ap-
propriate to discuss at the outset the general legal
principles governing union responsibility for strike
misconduct.
It is settled that where , as in this case , a picket
line is the scene of repeated acts of misconduct, to
the knowledge of the union conducting the picket-
ing, the union has the duty to take steps reasonably
calculated effectively to curb the misconduct, and
failing this the union may be held responsible for
resulting restraint and coercion of employees. Local
5881, United Mine Workers (Grundy Mining Co.),
130 NLRB 1181 , 1182, enfd . 296 F.2d 734 (C.A.
6); United Steelworkers of America ( Vulcan-Cincin-
nati, Inc.), 137 NLRB 95, 98 ; Local 3, International
Brotherhood of Electrical Workers , AFL-CIO (New
Power Wire and Electric Corp.), 144 NLRB 1089,
1091-92, enfd . 340 F.2d 71 (C.A. 2); Teamsters
Local 783, International Brotherhood of Teamsters
(Coca-Cola Bottling Company of Louisville), 160
NLRB 1776, 1779; Congreso de Uniones Industri-
ales de Puerto Rico, Ind. (Gayley Rico Company),
163 NLRB 448, 450-453.
Furthermore, even as to conduct occurring out-
side the presence of acknowledged union agents
and without the knowledge of the union conducting
the picketing, the union may be held responsible
for such conduct where it follows a pattern
established by acknowledged union agents . As held
in International Woodworkers of America, AFL-CIO
(W. T. Smith Lumber Co.), 116 NLRB 507,
508-509, enfd . 243 F.2d 745 (C.A. 5):
As to the misconduct by pickets .... we
agree with the Trial Examiner that the Respon-
dents were liable therefor. However, unlike the
Trial Examiner , we do not predicate such
responsibility on the absence of any evidence
that any picket captain sought to prevent such
misconduct . As it does not appear from the
record that any picket captains were in fact
present on such occasions , we impute responsi-
bility to the ... Local for such misconduct
rather on the fact that it conformed to a pat-
tern established by the officers and agents of
that Local through their own unlawful acts of
coercion and restraint....
More recently the Board in Teamsters Local 115,
International Brotherhood of Teamsters (E. J.
Lavino & Company), 157 NLRB 1637,1642-43,
stated the proposition as follows:
This attitude of the Respondent 's business
agent coupled with the restraint and coercion
practiced by the Union 's picket captains is suf-
ficient to make the Union legally responsible
for the restraint and coercion practiced by
other strikers who were but following the pat-
tern laid down by Respondent 's agents ....
That this proposition is applicable to conduct away
INTL. ASSOC. OF
from the picket line, as well as on the picket line, is
clearly stated in International Union of Electrical,
Radio and Machine Workers, AFL-CIO (The Sperry
Rubber & Plastics Company), 134 NLRB 1713,
1724.
2. Recapitulation
a. The IAM's chaining closed the gates to the plant
As found above, for some months the Company
had kept the gates to the plant chained and locked
with padlocks in an open position. In the early
morning hours of October 28, the night the strike
commenced-a strike previously advocated by the
IAM and supported by it from the start-the Com-
pany found its gates chained and padlocked in a
closed position, thus barring for the time being all
ingress to and egress from the plant. Caribe Pre-
sident Davis testified that several weeks before the
strike the Company had purchased new padlocks
for the plant gates and that the padlocks which he
found on the gates that day were not the Com-
pany's padlocks and that the Company did not have
keys for them. Roque Escobar, a former employee
and a leader in the [AM organizing campaign prior
to the election, was observed letting the night-shift
employees out of the south parking area through
gate 8. Immediately after doing so, Escobar joined
Maldonado who was standing 12 to 15 feet away.
Considering the foregoing facts in light of the
IAM's determined efforts in the following days to
bar all access to the plant, I conclude that the IAM
was responsible for the chaining and locking in a
closed position the various gates to the plant. I con-
clude further that by placing physical barriers
across the various entryways to the plant where
they were plainly visible to all strikers and non-
strikers alike, the IAM has restrained and coerced
the Company's employees in violation of Section
8(b)(1)(A) of the Act.3
b. The IAM's attacks on company officials and its
barring of officials from entering or leaving the plant
As found above, when tool specialist Gibson at-
tempted to drive into the plant at 9 a.m. on Oc-
Sec 8 provides in part as follows
(b) It shall be an unfair labor practice for a labor organization or its
agents-
(1) to restrain or coerce (A) employees in the exercise of the rights
guaranteed in Section 7
Sec 7 states that
MACHINISTS 1231
tober 29, the second day of the strike, Maldonado
and a group of strikers, including Baez and Hernan-
dez, stood around the car, and the group shook the
car and barred it from entering. Shortly thereafter a
car driven by Plant Manager Esperson was similarly
blocked from entering the plant by Maldonado,
Baez, Hernandez, and others. Maldonado having
himself participated in the 'blocking of these cars,
there can be no question of the IAM's responsibility
for this conduct. The blocking of access to super-
visors to the plant constituted an object lesson to all
witnessing it as to the IAM's determination to
prevent anyone from entering the plant. Such con-
duct constitutes restraint and coercion of em-
ployees in violation of Section 8(b)(1)(A) of the
Act. While the record does not show whether em-
ployees seeking to go to work were present at the
front gate on the morning of October 29 when the
Gibson and Esperson cars were blocked from enter-
ing the plant, the record does show that some 40 to
50 strikers were present. Even assuming that strik-
ing employees were the only employees observing
the blocking of the cars, Section 8(b)(I )(A) has
nevertheless been violated. As the Board has held,
such conduct has "the effect of coercively deterring
any of the strikers from abandoning the strike and
returning to work." International Woodworkers of
America, supra, 508. This holding was specifically
affirmed by the Court of Appeals for the Fifth Cir-
cuit in N.L. R.B. v. International Woodworkers of
America, AFL-CIO, 243 F.2d 745. See also Team-
sters, Local Union 327 (Hartmann Luggage Com-
pany), 173 NLRB 1403, enfd. in pertinent respects
419 F.2d 1282 (C.A. 6).
The action of the group of 15 to 20 pickets that
afternoon in standing around the front gate as
Materials Manager Ridolfi attemtped to leave in a
station wagon with three other management offi-
cials and a company attorney similarly violated Sec-
tion 8(b)(1)(A). Although Maldonado was on the
scene on this occasion, he did nothing, so far as the
record shows, to stop the obstruction of the vehicle.
The stoning of Caribe Plant Manager Davis and
Materials Manager Ridolfi as they were retreating
from attempting to cut open the front gate about 7
a.m. on October 29 further violated Section
8(b)(1)(A). Maldonado was standing immediately
outside the front gate together with 40 to 50
strikers when this rock throwing occurred. This
conduct, which was aimed at preventing the Com-
pany from opening the gates to nonstriking em-
ployees, underscored the willingness of the IAM to
use violence to prevent employees from entering
the plant, and necessarily restrained and coerced
Employees shall have the right to self-organization , to form, join, or
assist labor organizations , to bargain collectively through representa-
tives of their own choosing, and to engage in other concerted activities
for the purpose of collective bargaining or other mutual aid of protec-
tion, and shall have the right to refrain from any or all ofsuch activi-
ties [Emphasis supplied I
1232 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
strikers and any nonstriking employees who ob-
served it.4
Similarly violative of Section 8(b)(1)(A) of the
Act was the strikers' action in chasing company of-
ficials into the office of Rio Grande Industries late
in the afternoon of October 29 and in threatening
these officials with bodily harm. Nicholas Matta,
the leader of this threatening group of strikers was
the right-hand man of Maldonado. Damian Arocho
credibly testified that Matta "is always next to Mal-
donado wherever they go." Matta was involved
with Maldonado in chasing nonstriking employee
Rafael Gonzalez in the town of Rio Grande on the
morning of November 6. It is apparent from Mal-
donado's participation in the Gonzalez incident that
chasing and threatening employees was part of the
IAM's strategy for preventing nonstriking em-
ployees from attempting to go to work. In these cir-
cumstances I conclude that the IAM is responsible
for the chasing and threatening of the company of-
ficials in the office of Rio Grande Industries on Oc-
tober 29.
Wth respect to the incident of Maldonado's
slapping of Materials Manager Ridolfi on the morn-
ing of October 30 at Luquillo Beach, while such
conduct is not to be condoned, I find that in the cir-
cumstances of this case it did not violate Section
8(b)(1)(A) of the Act. This incident occurred
some miles from the plant, was not witnessed by
any employees, and occurred under such circum-
stances that it was not likely to come to the atten-
tion of employees. Local 1922, International
Brotherhood of Electrical Workers, AFL-CIO, 122
NLRB 850, 851. The allegation of the complaint as
amended based upon this attack on Ridolfi is
hereby dismissed.
As found above, strikers made a violent attack on
the procession of four cars containing management
officials on the morning of November 3. This at-
tack, in the presence of some 40-50 strikers, con-
stituted a flagrant violation of Section 8(b)(1)(A)
of the Act. The attack on the four cars with rocks,
chains, and clubs as they were entering the front
gate resulted in serious damage to the cars, includ-
ing four shattered windshields and broken windows,
and minor cuts to the occupants. Maldonado was
standing about 50 feet away during this incident ob-
serving what was going on. He did nothing to stop
the attack. Under the circumstances the IAM was
clearly responsible for this attack.
c. The attacks on employees attemtping to enter and
the leave
As found above, on the mornings of November 3,
5, 6, and 7, a number of nonstriking employees
The Company contends that the actions of the pickets on October 28,
the first day of the strike, in attacking company officials with sticks and
stones as they were attempting to cut open the gates to the plant and in
threatening them on these occasions constituted further violations of Sec
8(h)( I)(A) of the Act Such conduct of the pickets, if the IAM was respon.
sible therefor, would clearly violate Sec 8 (b)( I)(A) of the Act However,[
gathered in the town of Palmer to attempt to enter
the plant in groups. When the nonstrikers reached
the general area of the back gate to the plant, they
were confronted by numerous pickets who cursed
and threatened them with harm to themselves, their
families, and their property, menaced them with
clubs, sticks, and chains, and actually hit them with
sticks, thrown rocks, and other missiles.
As the employees sought to leave the plant at the
end of the shift pickets were waiting for them and
employees were subjected by the pickets to much
the same treatment.
Maldonado was present on each morning when
the nonstrikers attempted to go to work, except the
last morning, November 7. But instead of attempt-
ing to prevent the pickets from engaging in these
acts of violence, Maldonado at times himself
threatened the employees with physical harm or
sought to egg the pickets on to further violence. As
found above, on the morning of November 6, Mal-
donado went so far as to urge the pickets to tear
the clothes off the girls.
In these circumstances the IAM is clearly respon-
sible for the actions of the pickets against the non-
striking employees on November 3, 5, and 6. By
November 7, the pattern of action against the non-
strikers had been set by the pickets' actions on the
previous days, which Maldonado had either
directed or ratified. Consequently, the IAM is
responsible for the pickets' actions against non-
strikers on November 7 regardless of the fact that
Maldonado apparently was not on the picket line
that day. By the pickets' actions against the non-
strikers summarized above and by Maldonado's
threats against them , the Respondent has restrained
and coerced employees in violation of Section
8(b)(1)(A) of the Act. Teamsters, Local Union 327
(Hartmann Luggage Company), 173 NLRB 1403
enfd . in pertinent respects 419 F.2d 1282 (C.A. 6).
d. Restraint and coercion of employees away from
the plant
Two incidents involving actions by Maldonado
and other strikers against nonstrikers away from the
plant are discussed below. Although these incidents
were not specifically alleged in the complaint, they
fall within the general language of the first unnum-
bered paragraph of part V of the complaint alleging
that "Union agents engaged in various acts of
restraint and coercion against ... nonstriking em-
ployees for the purpose of intimidating them and
discouraging them from working during the strike."
And since these incidents were fully litigated at the
hearing , it is proper for me to consider these in-
find it unnecessary to reach the more difficult question of the IAM's
responsibility for such conduct, which occurred in the absence of Mal-
donado, for the reason that pickets subsequently engaged in similar con-
duct in the presence of Maldonado for which conduct I hold the IAM
responsible, and the order to be entered in this case would not be any dif-
ferent were I to make the findings requested by the Company
INTL. ASSOC OF MACHINISTS
cidents . Stokely-Van Camp , Inc. and Bordo Products
Co., d/b/a Stokely-Burdo , 130 NLRB 869, 872-873;
N.L.R.B. v. Thompson Transport Co., Inc., 421
F.2d 154 (C.A. 10).
As found above , Rafael Gonzalez was accosted
by Maldonado and a number of other strikers in
three cars as he was waiting for transportation to
the plant in Rio Grande on November 6. Mal-
donado , after making a threatening gesture towards
Gonzalez , commenced chasing after Gonzalez who
sought refuge in the nearby laundry of his father.
Maldonado , who was joined by other strikers, con-
tinued cursing and berating Gonzalez from outside
the laundry until the police approached . Such con-
duct by Maldonado and his cohorts plainly
restrained and coerced Gonzalez in the exercise of
his statutory rights and was violative of Section
8(b)(I)(A) of the Act.
In the second incident , in which Maldonado was
again accompanied by three carloads of strike sym-
pathizers , Maldonado visited Arocho 's home in Rio
Grande . On this occasion Maldonado sought to per-
suade Arocho in the course of a short discussion to
join the ranks of the strikers However, when
Arocho refused , Maldonado threatened Arocho in
thinly veiled terms that failure to join the strikers
might be fatal to him. This whole incident,
beginning with the arrival of about 25 men at the
home of Arocho some miles from the plant and cul-
minating in Maldonado 's veiled threat to have
Arocho killed if he persisted in attempting to go to
work , constituted another flagrant violation of Sec-
tion 8(b)(1)(A) of the Act. Cf. United Mechanics'
Union Local 150-F, 151 NLRB 386, 392-394.
3. The IAM's contentions
The IAM admits that it supported the strike from
its inception and that it is responsible for the con-
duct of its special representative, Maldonado. But
the IAM asserts that the evidence fails to establish
that Maldonado engaged in any conduct violative
of Section 8(b)(1)(A) of the Act. The facts sum-
marized above which, except for the two incidents
covered in section 2,d, are based upon the credited
and undented testimony of the General Counsel's
witnesses, establish that Maldonado himself en-
gaged in numerous acts of restraint and coercion in
violation of Section 8(b)(I)(A) The Respondent's
contention in this regard is wholly without merit.
With respect to the actions of the pickets during
the strike, the IAM denies all responsibility
therefor. In this connection the IAM relies on the
testimony of Maldonado that he did not designate
Baez, Matta, Hernandez, or any of the pickets as
strike captains or strike leaders, that none of these
pickets was a member or an officer of the IAM,
' Athough Maldonado used various channels in communications with
employees before the strike, such as distributing leaflets, using the radio
and mailing letters to the employees, Maldonado admittedly did not at-
tempt to use any of these means of communications in an effort to disavow
1233
and that none received any strike donations from it.
The [AM further cites Maldonado's testimony that
he instructed the pickets orally not to commit acts
of violence and informed them that both manage-
ment officials and employees had a right to enter
and leave the plant.
With respect to the latter testimony, I cannot be-
lieve that Maldonado sought to communicate to the
pickets any effective instructions to this effect. Mal-
donado's own conduct belies his testimony in this
regard. As found above, Maldonado personally par-
ticipated in the blocking of company officials' cars
as they were attempting to enter the plant, Mal-
donado personally threatened nonstriking em-
ployees as they were attempting to enter the plant,
and Maldonado was present during numerous in-
cidents of misconduct by pickets but did not protest
or attempt in any way to disassociate the IAM from
what was going on.5
But even if instructions of some sort were given
by Maldonado to the pickets, they obviously did
not fulfill his obligation as an authorized represent-
ative of the IAM to take steps reasonably calcu-
lated to stop the misconduct which occurred in his
presence. See the discussion in section 1 hereof.
As indicated above, it is immaterial that the IAM
may not have authorized the pickets to engage in
the acts of misconduct found above. The IAM, by
the inaction of its duly authorized agent, Mal-
donado, when the pickets engaged in misconduct
on the picket line in his presence, in effect adopted
and ratified the conduct of the pickets The con-
duct of the pickets on the picket line in the in-
cidents discussed above followed the pattern thus
established, or followed the example set by the ac-
tions of Maldonado himself. The IAM's contention
that it is not responsible for the actions of the
pickets in the incidents discussed above is rejected.
CONCLUSIONS OF LAW
1. By closing and padlocking the gates through
which employees enter the plant, by blocking cars
containing company officials from entering a plant
gate, by throwing stones at company officials after
they had attempted to cut open a gate to the plant,
by attacking and damaging with rocks, clubs, and
chains cars carrying company officials through a
plant gate, and by chasing company officials who
were leaving the plant and threatening them with
bodily harm, the IAM has engaged in restraint and
coercion of employees in violation of Section
8(b)(1)(A) of the Act.
2. By threatening employees seeking to enter or
leave the plant with bodily harm to themselves or
their families and with damage to their property, by
menacing employees seeking to enter or leave the
misconduct on the picket line Nor, as he further admitted , did Maldonado
seek to use the loudspeaker which was available to him at times on the
picket line, to prevent acts of misconduct which occurred in his presence
1234 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
plant with clubs, sticks, or chains, by hitting em-
ployees seeking to enter or leave the plant with
sticks and clubs and throwing rocks, bottles, and
other missiles at them, by chasing nonstriking em-
ployees and threatening them with bodily harm,
and by visiting the home of an employee under
coercive circumstances and threatening him with
bodily harm, the IAM has engaged in restraint and
coercion of employees in violation of Section
8(b)(1)(A) of the Act.
3. The aforesaid unfair labor practices affect
commerce within the meaning of Section 2(6) and
(7) of the Act.
THE REMEDY
In view of the serious nature and extent of the
IAM's violations of Section 8(b)(1)(A) of the Act,
my recommended order will direct the IAM not
only to cease and desist from such conduct, but
also to cease from in any otther manner restraining
or coercing employees in the exercise of their Sec-
tion 7 rights.
Upon the foregoing findings and conclusions and
the entire record , and pursuant to Section 10(c) of
the Act, there is hereby issued the following:
RECOMMENDED ORDER6
The Respondent, International Association of
Machinists and Aerospace Workers, AFL-CIO, its
officers, representatives, and agents, including Juan
L. Maldonado, shall:
1. Cease and desist from restraining or coercing
employees of General Electric Company, Circuit
Protective Devices Department, Caribe Plant Op-
erations; General Electric Power Products, Inc.,
and General Electric Circuit Breakers, Inc., in the
exercise of their rights as guaranteed in Section 7 of
the Act (including the right to refrain from joining or
assisting International Association of Machinists
and Aerospace Workers, AFL-CIO) by (a) locking
closed the gates to the plant of the above-named
corporations or by erecting any other kind of physi-
cal barrier across the entryways into the plant; (b)
blocking ingress to and egress from the plant of em-
ployees or officials and supervisors of the above-
named corporations; (c) threatening or inflicting
bodily harm upon employees or their families or
upon officials and supervisors of the above-named
corporations; (d) threatening or causing damage to
the property of employees or of the above-named
corporations; (e) chasing employees or officials or
supervisors of the above-named corporations in an
effort to prevent them from entering or leaving the
plant; (f) making coercive visits to homes of em-
ployees; and (g) or in any other manner.
2. Take the following affirmative action found
necessary to effectuate the poicies of the Act:
(a) Post in its business office and meeting hall
signed copies of the attached notice marked "Ap-
pendix," together with a Spanish language transla-
tion thereof,' on forms provided by the Regional
Director for Region 24, after being duly signed by
an authorized representative, shall be posted by the
Respondent immediately upon receipt thereof, and
be maintained by it for 60 consecutive says
thereafter, in conspicuous places, including all
places where notices to members are customarily
posted. Reasonable steps shall be taken by the
Respondent to insure that said notices are not al-
tered, defaced, or covered by any other material.
(b) Mail to he Regional Director for Region 24
signed copies of attached notice, together with a
Spanish language translation thereof, for posting by
General Electric Company, Circuit Protective
Devices Department, Caribe Plant Oerations;
General Eectric Power Products, Inc., and General
Electric Circuit Breakers, Inc., if they are willing, in
places where notices to their employees are
customarily posted. Copies of said notice in Spanish
and in English, to be furnished by said Regional
Director, shall, after being signed by the Respond-
ent as indicated, shall be forthwith returned for
disposition by him.
(c) Notify the Regional Director for Region 24,
in writing, within 20 days from the receipt of this
Decision, what steps have been taken to comply
herewith.'
6 In the event no exceptions are filed as provided by Section 102 46 of
the Rules and Regulations of the National Labor Relations Board, the
findings, conclusions , and Recommended Order herein shall, as provided
in Section 102 48 of the Rules and Regulations , be adopted by the Board
and become its findings , conclusions , and order , and all objections thereto
shall be deemed waived for all purposes
In the event that the Board's Order is enforced by a Judgment of a
United States Court of Appeals , the words in the notice reading " Posted by
Order of the National Labor Relations Board " shall be changed to read
"Posted Pursuant to a Judgment of the United States Court of Appeals
Enforcing an Order of the National Labor Relations Board "
s In the event that this Recommended Order is adopted by the Board,
this provision shall be modified to read . " Notify said Regional Director, in
writing , within 10 days from the date of this Order, what steps Respondent
has taken to comply herewith."
APPENDIX
NOTICE TO EMPLOYEES AND MEMBERS
POSTED BY ORDER OF THE
NATIONAL LABOR RELATIONS BOARD
An Agency of the United States Government
Section 7 of the National Labor Relations Act
guarantees all employees the right to join and assist
labor unions and also the right , with certain excep-
tions, to refrain from joining and assisting labor
unions, and to refrain from participating in union
activities , including strikes.
WE WILL NOT restrain and coerce the em-
ployees of General Electric Company, Circuit
INTL. ASSOC OF MACHINISTS 1235
Protective Devices Department, Caribe Plant
Operations; General Electric Power Products,
Inc., and General Electric Circuit Breakers,
Inc., in the exercise of their Section 7 rights.
WE WILL NOT lock or close the gates to the
plant of the above-named corporations and we
will not place any other physical barriers
across the gates to the plant.
WE WILL NOT block employees or officials
and supervisors of the above-named corpora-
tions from entering or leaving the plant.
WE WILL NOT threaten or inflict bodily harm
upon employees or their families or upon offi-
cials and supervisors of the above-name cor-
porations.
WE WILL NOT threaten or cause damage to
the property of employees or of the above-
named corporations.
WE WILL NOT chase employees or officials or
supervisors of the above-named corporations
in an effort to prevent them from entering or
leaving the plant.
WE WILL NOT make coercive visits to homes
of employees.
WE WILL NOT in any other manner restrain
or coerce employees in the exercise of their
rights under the National Labor Relations Act.
INTERNATIONAL
ASSOCIATION OF
MACHINISTS AND
AEROSPACE WORKERS,
AFL-CIO, AND ITS
AGENT, JUAN L.
MALDONADO
(Labor Organization)
Dated By
(Representative ) (Title)
This is an official notice and must not be defaced
by anyone.
This notice must remain posted for 60 consecu-
tive days from the date of posting and must not be
altered, defaced, or covered by any other material.
Any questions concerning this notice or com-
pliance with its provisions may be directed to the
Board 's Office, Seventh Floor , Pan Am Building,
255 Ponce de Leon Avenue, Hato Rey, Puerto Rico
00919, Telephone 809-765-0404.
427-258 O-LT - 74 - 79