Crimptex, Inc.

National Labor Relations Board - Board Decisions

Jun 21, 1974

211 N.L.R.B. 855 (N.L.R.B. 1974)

CRIMPTEX, INC. 855
Crimptex, Inc. and its affiliates French -Tex of Puerto
Rico, Inc ., Hamlet Industries, Inc. and Emtine, Inc.
and Union de Trabajadores de la Crimptex, Inc.
Afiliada at Sindicato Puertorriqueno de Trabaja-
dores de la Amalgamated Meat Cutters and Butch-
ers Workmen of North America , AFL-CIO. Case
24-CA-3367
committed the violations of the Act alleged . Upon due
notice, the case was tried before me at Hato Rey, Puerto
Rico, on January 17, 1974. Representatives of all parties
were present and participated in the hearing.
Based on the entire record , including the stipulations of
the parties , I make the following:
FINDINGS AND CONCLUSIONS
June 21, 1974
DECISION AND ORDER
BY MEMBERS FANNING, KENNEDY, AND
PENELLO
On March 26, 1974, Administrative Law Judge
Jennie M. Sarrica issued the attached Decision in
this proceeding. Thereafter, Respondent filed excep-
tions and a supporting brief.
Pursuant to the provisions of Section 3(b) of the
National Labor Relations Act, as amended, the
National Labor Relations Board has delegated its
authority in this proceeding to a three-member panel.
The Board has considered the record and the
attached Decision in light of the exceptions and brief
and has decided to affirm the rulings, findings, and
conclusions of the Administrative Law Judge and to
adopt her recommended Order.
ORDER
Pursuant to Section 10(c) of the National Labor
Relations Act, as amended, the National Labor
Relations Board adopts as its Order the recommend-
ed Order of the Administrative Law Judge and
hereby orders that Respondent Crimptex and its
affiliates French-Tex of Puerto Rico, Inc., Hamlet
Industries, Inc., and Emtine, Inc., San German,
Puerto Rico, their officers, agents, successors, and
assigns , shall take the action set forth in the said
recommended Order.
DECISION
STATEMENT OF THE CASE
JENNIE M. SARRICA , Administrative Law Judge: This is a
proceeding under Section 10(b) of the National Labor
Relations Act, as amended (29 U.S.C. § 151, et seq. ),
hereinafter referred to as the Act. Based on charges filed
on June 22 , 1973,1 as thereafter amended , a complaint
issued December 12, and amended at the hearing herein,
presenting allegations that Crimptex , Inc. and its affiliates
French-Tex of Puerto Rico , Inc., Hamlet Industries, Inc.,
and Emtine , Inc., hereinafter collectively referred to as the
Respondent , committed unfair labor practices within the
meaning of Section 8(a)(1) and (5) and Section 2(6) and (7)
of the Act. The Respondent filed an answer denying that it
I Unless otherwise indicated , all dates are in 1973.
I. JURISDICTION
Respondent admits and I find that Crimptex, Inc.,
French-Tex of Puerto Rico, Inc., Hamlet Industries, Inc.,
and Emtine, Inc., all Puerto Rican corporations, are and at
all times material herein have been, affiliated businesses
with common officers, owners, directors, and operators,
and constitute a single integrated business enterprise. At all
times material herein, Respondent has maintained an
office and place of business at San German, Puerto Rico,
where it is and has been at all times material herein,
engaged in the processing, sale, and distribution of nylon
yarn and related products.
During the past year, which period is representative of its
annual operations generally, Respondent, in the course
and conduct of its business, purchased and caused to be
transported and delivered to its San German plant, goods
and materials valued in excess of $500,000, of which goods
and materials valued in excess of $50,000 were transported
and delivered to its plant in interstate commerce directly
from States of the United States.
Respondent is, and has been at all times material herein,
an employer engaged in commerce within the meaning of
Section 2(2), (6) and (7) of the Act.
II. THE LABOR ORGANIZATION
Respondent admits, and I find, that the Charging Party,
Union de Trabajadores de la Crimptex, Inc., Afiliada al
Sindicato Puertorriqueno de Trabajadores de la Amalga-
mated Meat Cutters and Butchers Workmen of North
America, AFL-CIO, hereinafter called the Union, is now,
and has been during all times material herein, a labor
organization within the meaning of Section 2(5) of the Act.
III. THE ALLEGED UNFAIR LABOR PRACTICE
A. The Issues
Inj substance, it1 is,alleged thatd Respondent . has refused,
and is, unlawfully refusing, to bargain within the meaning of
the Act by refusing; to execute the agreedupon,collective-
bargaining contract and by adopting and announcing the
position that the Union is no longer the majority
representative of the employees in the existing unit.
Respondent affirmatively defends its position as lawful on
the grounds that the Union repudiated their agreement by
engaging in a material breach thereof before the contract
could be executed, through striking in the face of an agreed
upon contract no-strike clause, and that the Union lost its
majority status through permanent strike replacements.
211 NLRB No. 152
856 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
B. The Events Involved
According to the stipulation of the parties , the Respon-
dent and the Union have been parties to several successive
agreements , the last of which expired on March 5.
Negotiations for a new agreement were undertaken and on
March 23 , the Respondent and the Union reached
agreement on a collective-bargaining contract encompass-
ing all terms and conditions of employment covering
employees in the established appropriate unit . Respondent
reduced that agreement to writing on March 28 and
submitted a copy to the Union with a covering letter on
March 29 .2 On March 28, employees at Respondent 's plant
began a strike3 which lasted until May 9 . By letter dated
April 27, the Respondent advised the Union that it viewed
the strike as a direct violation and repudiation of their
agreement4 and that it was, therefore , rescinding the
written but unexecuted agreement reached on March 23.
By its terms the contract which included a no-strike clause
was to "become effective on the date of its execution
"
On May 9, Respondent and the Union signed a strike
settlement agreement , entitled stipulation , in which it was
agreed, inter alia, that:
The economic terms and conditions of the Collective
Bargaining Agreement agreed upon by the parties the
23rd of March 1973, shall become effective for the
striking employees who may return to work from the
date of their return to work.
Immediate reinstatement of all strikers was thereupon
requested . Pursuant to this strike settlement agreement 42
strikers were reinstated. On March 28, when the strike
began there were 103 unit employees , 85 of whom were
union members pursuant to a union shop clause contained
in the expired contract ; the 18 nonmembers being at that
time within their first 30 days of employment. When the
strike ended on May 9, there were 71 working replace-
ments .5 Respondent 's general manager, Henry Pelletier,
testified that the economic terms and conditions of the
March 23 agreement were made effective for all returning
strikers and new employees (presumably striker replace-
ments).
s That letter reads as follows:
Attached you will find a copy of the contract proposal to be signed by
and between [Respondent and the Union ] , which we trust contains all
the agreements reached at [sic ] by the parties dur.ng the negotiations.
We will appreciate that you give us your approval of same and the date
when it can be signed.
The letter and drafted contract were received as joint exhibits
9 It was stipulated that the strike was for the purpose of obtaining
removal of a supervisor.
4 On April 2, the Respondent had filed a charge against the Union, later
withdrawn , alleging violation of Section 8(bX3), refusal to bargain by
refusing to execute a collective-bargaining agreement. No other charges,
petitions, or other proceedings in connection with the matters related
herein , were initiated by the Respondent against the Union with the
National Labor Relations Board.
3 These are all the statistics supplied by the stipulation of the parties and
no other evidence was presented on this question . Respondent's counsel
indicated in the course of argument that more than 80 percent of the strike
replacements were currently working, and that it was only after hiring such
Thereafter, by letters dated May 11 and June 18 and 29,
the Union requested the Respondent to sign the agreed-
upon written but unexecuted collective -bargaining agree-
ment . Receipt of these letters is acknowledged but
Respondent made no reply and has not to date executed
said agreement.
C. Analysis and Findings
The burden of Respondent 's defenses to the charges
herein rests on the legal effect of the Union's conduct after
bargaining for a new contract culminated in an oral
agreement which had not yet been executed . It is settled
law that the existence of a strike does not suspend the
obligation on the part of an employer to bargain with the
bargaining representative of its employees .6 Even assuming
that union actions in delaying execution of the written
contract submitted by the Respondent was in violation of
Section 8(bX3), and that the strike was an unlawful one
because of its purpose, the employer's duty to bargain with
the incumbent Union was not removed , but only suspend-
ed for the duration of the unlawful conduct . ? Nor can the
employer challenge the Union's majority on the ground
that the strike was in violation of the agreed upon no-strike
provision and therefore unprotected activity, for even if
Respondent had a right to discharge striking employees for
that reason it did not do so, they remained employees,8 and
the Union remained their representative.
Considering first the Union's poststrike majority status,
contrary to the import of Respondent 's contention strike
replacements do not displace striking employees from the
unit for purposes of determining the Union's continued
majority and the employer's continuing duty to bargain.
For, under established precedent, even though economic
strikers are permanently replaced , they must be counted as
employees for unit representation purposes .9 Further, there
is a presumption that the majority status of an incumbent
union continues and it is the burden of the party
challenging that status to establish loss of majority or
reliance on objective grounds for a good faith doubt.10
Here, absent evidence to the contrary, it is assumed that
there were 103 strikers , none of whom have been shown by
Respondent to have withdrawn from the Union the right to
represent them . It cannot be assumed that the 18 non-
replacements in early May that the parties entered into strike settlement
negotiations.
6 See General Electric Company, 163 NLRB 198, 213, and cases cited
therein , enfd. in pertinent part 400 F .2d 713 (C.A. 5, 1968)
r See International Shoe Corporation of Puerto Rico, 152 NLRB 699, 702;
423 F.2d 503 (C.A. 1, 1970); Litho-Graphic Press, Inc., 159 NLRB 1, 4.
6 The employee status of strikers, within the meaning of the Act, is not
automatically severed because a strike is in violation of their agreement.
Dorsey Trailers, Inc., 80 NLRB 378.
9 See Cantor Bros., Inc, 203 NLRB No. 116, quoting pertinent parts of
C H. Guenther & Son, Inc , d/b/a Pioneer Flour Mills, 174 NLRB 1202,
enfd. 427 F .2d 983 (C.A. 5, 1970), and other relevant cases . The court
decision in Pioneer specifically approved the Board 's reversal of the Stoner
Rubber Company, Inc., 123 NLRB 1440, practice of excluding permanently
replaced economic strikers in ascertaining majority status, on the basis of
rationale underlying the 1959 amendments and Section 9(c)(3) of the Act.
See also Dobbs House, Inc., 188 NLRB 546; Keystone Trucking Co., 196
NLRB 574, 575 , fn. Il. Accordingly, Respondent's argument based on
Higgins Inc., 90 NLRB 184, is without merit.
io Nu-Southern Dyeing & Finishing, Inc., 179 NLRB 573, enfd . in part 444
F.2d 11 (C .A. 4, 1971 ); also see discussion in Cantor Bros., Inc., supra.
CRIMPTEX , INC. 857
members who had been employed less than 30 days when
the strike began did not desire that the Union represent
them. Even assuming that none of the 71 strike replace-
ments desired the Union to represent them, they are only
part of an overall employee complement of 174 employ-
ees.11 Respondent has therefore not demonstrated that the
Union no longer represented a majority of the employees
nor has it established that objective considerations existed
on which it entertained a good faith belief that the Union
lost its majority.
Since the strike settlement , Respondent has not replied
to the various communications from the Union but has
withheld recognition and bargaining. Accordingly, I find
that Respondent has refused to bargain with the statutory
representative of its employees in violation of Section
8(a)(5) and (1) of the Act.
There remains the question of whether, as alleged in the
complaint, the Respondent also violated Section 8(a)(5)
and (1) of the Act by refusing, after the strike ended, to
sign the previously negotiated contract. As noted above,
Respondent relies upon the Union's alleged refusal to
execute the written contract and breach of the no-strike
provision of their agreement as not only a material breach
thereof but also a repudiation of the agreement which
justified Respondent's own rescission of that agreement.
For the proposition that such actions on the part of the
Union and its election to rescind relieved it of any further
obligation with respect to the agreement, Respondent
relied on a case involving a Section 301 suit to recover
damages for breach of contract. 12 In that case, the United
States Court of Appeals for the Ninth Circuit held that:
[A]t the time immediately after the strike began when
Boeing elected to terminate the contract the union had
been guilty of a material breach which fell short of
abandonment or total repudiation of the contract. The
power of termination which accrues to the wronged
party as a result of such a breach and was exercised by
Boeing in this case is a right of rescission which leaves
neither party with any basis thereafter to complain of
the conduct of the other as a breach of the contract.
However, that decision clearly is limited to actions
involving private rights in breach of contract and liability
under the contract, and is not dispositive of any question
concerning fulfillment of the duty to bargain, which
involves a public issue.
It is well settled that technical rules of contract law are
not necessarily controlling in cases arising under the Act.13
11 The 174 consists of 71 replacements , 42 reinstated strikers and 61
replaced strikers . The figure of 61 replaced strikers is arrived at by
subtracting the 42 reinstated strikers from the total complement of 103
employees when the strike began all of whom presumably went on strike. It
is not clear from the record whether the excess of 10 replacements over the
number not yet reinstated represents an increase in total employment or the
number of replacements who did not remain in Respondent's employ,
alluded to by counsel. (See In . 5, supra. ) In any event, these figures are the
most favorable to Respondent 's position.
12 Boeing Airplane Co. v. Assn. of Machinists, 188 F.2d 356, affg. 91
F.Supp. 596, cert . denied 342 U.S. 821. However, also in a Section 301 suit
involving the rights of the parties to a contract , it has been held that the
alleged violation of a no -strike clause does not automatically entitle an
employer to repudiate the contract . The issue of whether the Union evinced
an intent to repudiate the agreement, or whether they violated it at all must
Clearly absent mitigating circumstances, the Respondent
was obligated to sign the agreement reached with the
statutory representative of its employees, and failure to do
so upon request violated Section 8(a)(5) of the Act.14 This
obligation is not merely a ministerial act, but encompasses
liability for benefits provided by the agreement.15
As to whether such mitigating circumstances exist, the
General Counsel asserts that neither the Union's earlier
refusal to execute the agreement, nor any breach of the no-
strike clause has any legal consequence, for the "unclean
hands" doctrine is not a defense to allegations of unfair
labor practices 16 and, in any event, there could have been
no breach of the agreement because, by its terms, the
contract was to take effect only upon execution.
While the first proposition advanced by the General
Counsel reflects a correct statement of the general rule in
labor law, and the second is factually correct, I do not
believe such conclusions adequately meet the total implica-
tions of the Respondent's defense. Unfortunately, I do not
have the benefit of briefs to elucidate the arguments
supporting the opposing positions.
If the reasoning of Respondent's position is that by the
Union's conduct in failing to arrange for execution of the
written contract submitted by Respondent and, at the same
time, engaging in a strike which was contrary to a contract
clause it had just agreed to, the Union demonstrated an
intent to repudiate that agreement, I must reject such
contention. It could as logically be argued that the Union
delayed signing the agreement, which by its terms took
effect upon execution, precisely because it did not wish to
repudiate that agreement.
As Respondent took steps to specifically rescind the
agreement, it would appear that Respondent is contending
that the Union's conduct created changed circumstances
which warranted its rescission of contract proposals
previously agreed to. I believe such a position to be without
merit. For, there is no question but that the parties had
reached a full understanding and that no further negotia-
tions were contemplated. Therefore, cases involving
changed circumstances warranting withdrawal of contract
proposals or concessions previously made are not applica-
ble.17
In view of the fact that the last preceding contract
between the parties had expired, and there is no evidence
herein of any provisions thereof, Respondent's allegation
that the strike was a violation of the no-strike clause agreed
to by the Union suggests the assertion that until the written
contract could be prepared and executed the parties were
bound by the provisions of an oral agreement which took
be determined in the first instance . See Cast Optics Corp v. Textile Workers,
75 LRRM 2169.
13 See Restaurant Association of the State of Washington, Inc., 190 NLRB
133, 138-139, and cases cited therein.
14 H. J Heinz Company v. N .LR.B, 311 U.S. 514, 525, Sec 8(d) of the
Act.
15 See, e.g., Ogle Protection Service Inc., 149 NLRB 545, enfd 375 F 2d
497 (C A. 6, 1967); Roesch Transportation Co., 157 NLRB 44; Tanner Motor
Livery, Ltd., 160 NLRB 1669.
16 The General Counsel relies upon Plumbers Union of Nassau County,
Local 457, 131 NLRB 1243.
17 Cf. Caroline Farms Division of Textron, Inc, 163 NLRB 854,
enforcement denied 401 F.2d 205 (C.A. 4, 1968), for varying views of the
effect of intervening events.
858 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
effect when bargaining was concluded on March 23.
However, relinquishment of statutory rights such as the
right to strike are not lightly inferred, but must be clearly
and unmistakably established . Although the Board has had
occasion to find that a no-strike commitment existed based
on an oral interim agreement governing terms and
conditions of employment between contracts, it did so only
on specific evidence not only as to intent but also evidence
of a quid pro quo commitment to make any wage increases
retroactive to the expiration of the preceding contract.18
There is no such evidence here . Significantly, Respondent
is not contending that it was bound by and obligated to put
into effect immediately the terms and conditions of
employment it had agreed to at the same time . I conclude
that the parties clearly intended none of the provisions of
their bargain to become operative until the final written
contract was executed . Accordingly, I find that the strike
did not bestow on Respondent a right to rescind the
bargaining agreement previously reached with the Union
and that by failing to comply with the Union's requests of
May 11, June 18 and June 29, Respondent violated Section
8(a)(5) of the Act.
CONCLUSIONS OF LAW
1. Respondent is an employer engaged in commerce
within the meaning of Section 2 (2), (6), and (7) of the Act.
2. Union de Trabajadores de la Crimptex, Inc., afiliada
al Sindicato Puertorriqueno de Trabajadores de la Amalga-
mated Meat Cutters and Butchers Workmen of North
America, AFL-CIO is a labor organization within the
meaning of Section 2 (5) of the Act.
3. All production and maintenance employees em-
ployed by Respondent at its plant located at San German,
Puerto Rico, including mechanics and chauffeurs; but
excluding executive employees , professional and adminis-
trative employees , office clerical employees, foremen,
guards and supervisors as defined in the Act, constitute a
unit appropriate for the purposes of collective bargaining
within the meaning of Section 9(b) of the Act.
4. By refusing to execute the agreement consummated
as a result of negotiations between the Respondent and the
Union, and by withdrawing and withholding recognition
from the Union as the collective-bargaining representative
of its employees in the appropriate unit, Respondent has
engaged in and is engaging in unfair labor practices within
the meaning of Section 8(a)(5) of the Act.
5. By the foregoing conduct Respondent has interfered
with, restrained, and coerced its employees in the exercise
of their statutory rights within the meaning of Section
8(a)(l) of the Act.
6. The aforesaid unfair labor practices are unfair labor
practices within the meaning of Section 2(6) and (7) of the
Act.
THE REMEDY
Having found that Respondent engaged in and is
engaging in unfair labor practices, it will be recommended
that it cease and desist therefrom and take certain
affirmative action necessary to effectuate the policies of the
Act.
Having found that Respondent unlawfully withdrew and
withheld recognition from the Union as the exclusive
representative of its employees in the appropriate unit I
recommend that Respondent be ordered to recognize and
bargain with the Union upon request . As I have found that
Respondent unlawfully refused to execute a contract
encompassing the terms and conditions of employment on
which it and the Union had mutually reached complete
accord, I recommend that the Respondent be ordered to
execute such contract upon request by the Union. Because
the Respondent , pursuant to the strike settlement agree-
ment entered into before the Union 's request for execution
of contract , placed into effect the economic terms of their
agreement , I shall not require that Respondent give
retroactive effect to that agreement . 19 I also recommend
that the Respondent post at its place of business the notice
attached to this Decision marked "Appendix."
Upon the foregoing findings of fact, conclusions of law,
and the entire record, and pursuant to Section 10(c) of the
Act, I hereby issue the following recommended:
ORDER 20
The Respondent, Crimptex , Inc., and its affiliates
French-Tex of Puerto Rico, Inc., Hamlet Industries, Inc.,
and Emtine, Inc., its officers , agents, successors, and
assigns, shall:
1. Cease and desist from:
(a) Refusing to bargain collectively by withdrawing and
withholding recognition of Union de Trabajadores de la
Crimptex, Inc., affiliada al Sindicato Puertorriqueno de
Trabajadores de la Amalgamated Meat Cutters and
Butchers Workmen of North America, AFL-CIO, as the
collective-bargaining representative of its employees in the
appropriate unit and by refusing to sign the agreement
negotiated with the said Union.
(b) In any like or related manner interfering with,
restraining, or coercing its employees in the exercise of
rights of self-organization, to form, join, or assist any labor
organization, to bargain collectively through representa-
tives of their own choosing, and to engage in concerted
activities for the purposes of collective-bargaining or other
mutual aid or protection , or to refrain from any or all such
activity except to the extent that such right may be affected
by an agreement requiring membership in a labor
organization as a condition of employment, as authorized
by Section 8(aX3) of the Act.
2. Take the following affirmative action which is
necessary to effectuate the policies of the Act:
(a) Recognize and bargain with the above -named Union
is See The Kroger Co. (Cleveland Div.), 177 NLRB 769, enfd. sub nom. Rules and Regulations of the National Labor Relations Board, the findings,
Alvin Silbaugh v. N.LR. B., 429 F .2d 761 (C.A.D.C., 1970). conclusions , and recommended Order herein shall, as provided in Sec.
19 Cf. Roesch Transportation Company, 157 NLRB 441 ; Ogle Protection 102.48 of the Rules and Regulations , be adopted by the Board and become
Service, Inc., 149 NLRB 545, enfd . 375 F.2d 497 (C.A. 6, 1967). its findings , conclusions , and order, and all objections thereto shall be
20 In the event no exceptions are filed as provided by Sec. 102.46 of the deemed waived for all purposes.
CRIMPTEX, INC. 859
as the exclusive representative of its employees in the
appropriate unit ' and, upon request , execute with the
above-named Union the collective-bargaining agreement
negotiated by them and concluded on March 23, 1973.
(b) Post at its place of business in San German, Puerto
Rico, copies of the attached notice marked "Appendix." 21
Copies of said notice, in English and Spanish to be
furnished by the Regional Director for Region 24, after
being signed by an authorized representative of Respon-
dent, shall be posted by Respondent immediately upon
receipt thereof, and be maintained by it for 60 consecutive
days thereafter , in conspicuous places, including all places
where notices to employees are customarily posted.
Reasonable steps shall be taken by Respondent to insure
that said notices are not altered , defaced, or covered by
any other material.
(c) Notify the Regional Director for Region 24, in
writing, within 20 days from the date of this Order, what
steps the Respondent has taken to comply herewith.
21 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."
APPENDIX
NOTICE To EMPLOYEES
POSTED BY ORDER OF THE
NATIONAL LABOR RELATIONS BOARD
An Agency of the United States Government
After a trial at which all sides had the chance to give
evidence , it has been decided that we, Crimptex, Inc., and
its affiliates French-Tex of Puerto Rico, Inc., Hamlet
Industries, Inc., and Emtine , Inc., have violated the
National Labor Relations Act and we have been ordered
to post this notice.
WE WILL, upon request , recognize and bargain with
Union de Trabajadores de la Crimptex, Inc., affiliada
al Sindicato Puertorriqueno de Trabajadores de la
Amalgamated Meat Cutters and Butchers Workmen of
North America, AFL-CIO, as the exclusive bargaining
representative of all employees in the unit consisting
of:
All production and maintenance employees
employed by us at our plant located at San
German, Puerto Rico , including mechanics and
chauffeurs; but excluding executive employees,
professional and administrative employees, office
clerical employees, foremen, guards and supervi-
sors as defined in the Act,
with respect to rates of pay, wages, hours of employ-
ment and other terms and conditions of employment.
WE WILL, upon request, execute with the above-
named Union, the collective-bargaining agreement
negotiated by us and concluded on March 23, 1973.
WE WILL NOT refuse to bargain collectively with your
bargaining representative by withdrawing and with-
holding recognition or by refusing to execute an agreed
upon contract, or in any like or related manner
interfere with, restrain, or coerce our employees in the
exercise of their rights to self-organization, and to
bargain collectively through representatives of their
own choosing.
CRIMPTEX, INC., AND ITS
AFFILIATES FRENCH-TEX OF
PUERTO RICO, INC.,
HAMLET INDUSTRIES, INC.,
AND EMTINE, INC.
(Employer)
Dated By
(Representative) (Title)
This is an official notice and must not be defaced by
anyone.
This notice must remain posted for 60 consecutive days
from the date of posting and must not be altered, defaced,
or covered by any other material.
Any questions concerning this notice or compliance with
its provisions may be directed to the Board's Office, Pan
Am Building - 7th Floor, 255 Ponce de Leon Avenue, Hato
Rey, Puerto Rico 00919, Telephone 622-0247.