15. On October 9, 1978, the Montgomery County Committee visited the job site where it met with Frank Bartolotti.
16. Ralph Williams acted as chief spokesman for the Committee, and attempted to question Bartolotti about the complaints of the various Committee member unions. Bartolotti advised the Committee that they should communicate with Bartolotti's superior in Seco, William Spector. Marvin James was the only Local 135 member attending the October 9th job site meeting.
17. As a result of the October 9th meeting, the Committee decided to set up an area wages and standards picket at the Seco job site. Ralph Williams implemented the decision by notifying member locals of the planned picketing and requesting them to supply picketers.
18. On October 10, 1978, the Council picketed Seco on the Alan Wood Steel job site. Ralph Williams was present throughout the picketing.
19. Local 135 and other affiliated local craft unions supplied picketers who carried signs supplied by Ralph Williams. The signs read:
SPECTOR [handwritten] CONTRACTOR
Building Industry Standards
WE PROTEST AGAINST
WAGES AND STANDARDS
Building and Construction Trades Council
A.F.L. - C.I.O.
20. Approximately fifty men, half of whom carried signs, picketed the entrance gate to the Seco job site. Seco employees did not cross the picket line to go to work on that day.
21. Williams decided to order no picketing of the Seco site on October 11 because of a conversation he had with Hal King, supervisor of the entire Alan Wood Steel site. King advised Williams that Seco's employees would not be on the job site on October 11.
22. In November, Al Rolli, a delegate of the Operating Engineers, a Council affiliate, advised Ralph Williams that Seco employees were again working on the Alan Wood Steel job site. Williams ordered picketing by the Council on November 13, 1978.
23. The Council picketed Seco at the Alan Wood Steel job site on November 13, 1978. The picketing was conducted in a manner identical to that which occurred on October 10. Picketers were members of various locals affiliated with the Council. They carried the same signs.
24. Council rules dictate that the Council will establish a picket line only if two or more local affiliates are affected by what the Council perceives to be problems on a job site.
25. Local 135 officers have no authority to authorize any picketing by Local 135 independent of the Council.
26. Council picketing ended after November 13 following a telephone conversation between Williams and William Spector. From this conversation Williams concluded that the only Council affiliate that had an outstanding problem with Seco was Local 135.
27. In late November, 1978, Local 135 representatives learned that Seco's employees were represented by Local 734, a sister local of the Laborers' International Union.
28. From November 1978, until March 12, 1979, Woodall drove past the Seco job site but saw no activity by any Seco workers except Bartolotti. On March 12, 1979, he saw Seco employees on the site, and, on March 13, advised William Goodman of this fact.
29. Woodall, James, and William and Tom Goodman visited the Seco job site on March 13 for the purpose of seeking compliance by the Seco employees with the transfer provision of Article XX, Section 9, of the Laborers International Union Constitution, which provides as follows:
When a good standing member of a Local Union is working within a territorial jurisdiction of another Local Union outside of the same metropolitan area, for a period of more than thirty days, the Local Union in whose area the man is working may demand a transfer from that member.