THE DENVER AND RIO GRANDE WESTERN RAILROAD
COMPANY
STATEMENT OF CLAIM: Claim of the System Committee of the Brotherhood that:
(1) The Carrier violated terms of the current Agreement, and continues to violate said Agreement, when it requires or permits contract draymen (employes of Rio Grande Motor Way) and other individuals holding no rights under our contract, to perform work coming under same at the freight warehouse, Pueblo, Colorado, i.e., checking, receiving, trucking, sorting and delivering freight.
(2) That the senior qualified Group 1 employe, if any, be paid one day's pay at checker's rate for each day, commencing July 5, 1955, until violation is corrected.
(3) On any day or days that an employe is not available under Item (2) above, then a regularly assigned Group 1 employe shall be paid three (3) hours at punitive rate for such violation.
(4) That the senior qualified Group 2-3 employe if any, be paid one day's pay at stowman's rate for each day, commencing July 5, 1955, until violation is corrected.
(5) On any day or days that an employe is not available, under Item (4) above, then regularly assigned Group 2-3 employe shall be paid three (3) hours at punitive rate for said violation.
That the dispute was certified to the Third Division of the Adjustment Board ex parts by the complainant party; and
That no bearing thereon has been held, and under date of October 24, 1956, the complainant party addressed a formal communication to the Secre-