Clarence D. Kightlinger - Page 3

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               While employed at Whitehall, petitioner was a member of a              
          labor union named the Oil, Chemical and Atomic Workers                      
          International Union (the Union).                                            
               During the 1980's, AHP initiated a plan to relocate part of            
          its operations to Guayama, Puerto Rico.  As a result of this                
          plan, AHP closed various plants operated by Whitehall and Wyeth-            
          Ayerst, including the plant operated by Whitehall in Elkhart, by            
          the end of 1991 or early 1992.  The plant closings caused                   
          approximately 1,100 Whitehall and Wyeth-Ayerst employees to be              
          laid off and eventually lose their jobs.  Petitioner was one such           
               In January 1991, the Union filed suit against AHP and                  
          various other entities and individuals in the United States                 
          District Court for the District of Puerto Rico (the District                
          Court).  During that same year, the Union determined that a class           
          action should be brought against AHP and other defendants on                
          behalf of the employees that were laid off.  Consequently, in               
          November 1991, the Union sent a notice entitled "Keep Whitehall             
          Open" to the affected Whitehall employees.  The notice stated               
          that it had become appropriate to seek individual damages for the           
          laid off members of the Union "under the RICO [Racketeer                    
          Influenced and Corrupt Organization] complaint".  The notice                
          provided further as follows:                                                
               the remedy that we would be asking for [is]                            
               compensation for losses in wages and benefits for some                 

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