Clarence D. Kightlinger - Page 4

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               appropriate period of time but not less than the                       
               duration of the current contract * * *.                                
               In February 1992, the Union, its local chapter, and several            
          individuals (the Plaintiffs) filed a class action against AHP and           
          various other individuals and entities (the Defendants) in the              
          District Court.  The class action complaint (the Complaint)                 
          stated in its preliminary statement that the Defendants:                    
               did unlawfully and without justification violate federal               
               Racketeering laws and intentionally interfere with the                 
               protected right of Plaintiffs, including the prospective               
               economic advantages, enjoyed by the herein described class             
               of former Elkhart * * * employees.                                     
               The Complaint identified several individual plaintiffs as              
          typical class representatives.  An example of a paragraph                   
          identifying an individual class member is as follows:                       
                    Defendants' decision to relocate and transfer jobs to             
               Puerto Rico has caused [individual class representative] a             
               great personal loss consisting of his being terminated in              
               December, 1989.  [Individual class representative] has since           
               found no steady work and is forced to maintain temporary               
               employment with no medical benefits.  Defendants' actions,             
               which provoked his unemployment, caused him great emotional            
               distress, feelings of low self esteem and self worth.                  
               [Individual class representative] now earns much less and              
               lost fringe benefits due to his being terminated by                    
               Other individual class representatives were similarly                  
          identified.  The Complaint alleged factually in great detail that           
          the Defendants, in the course of a scheme reasonably calculated             
          to defraud the plaintiffs, to evade State and Federal taxes, and            
          to avoid compliance with various other Federal and Puerto Rican             
          laws, violated Federal racketeering laws and interfered with the            

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