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Virtually all appearances by the Buffalo Jills have been canceled, leading the cheerleaders' union to conclude that the women have been fired.

In a federal complaint, the National Football League Cheerleaders Association alleges that Jills members are being punished by their employer for voting overwhelmingly last month to become the first members of the nation's first cheerleaders union.

The women's employer, Buffalo Jills Cheerleaders Inc. of Amherst, is owned by Andrew Gerovac, who also is co-owner of the Jills' principal sponsor, the Mighty Taco restaurant chain. There are 35 members of the cheerleading squad; all are represented by the union.

Gerovac and his attorney, Joseph L. Randazzo, could not be reached to comment Wednesday.

The cheerleaders union charges that Gerovac violated the National Labor Relations Act by refusing to negotiate a contract, discriminating against Jills members and unilaterally changing working conditions.

Since the Feb. 23 union representation vote, "The employer has refused to schedule any appearances, whether paid or unpaid, for any Jill who supported or supports the NFL Cheerleaders Association," W. James Schwan, the union's attorney, said in papers filed with the Buffalo regional office of the National Labor Relations Board.

Because the Jills' work effectively has been eliminated, Schwan said, "The employer has constructively discharged every known association member."

Sources say that Jills management has told clients that scheduled appearances had to be canceled because the cheerleading group is facing sizable legal bills stemming from its attempt to fight the union organizing campaign.

Jills management also has broken with tradition and charged a charity for an appearance by the cheerleaders, sources say. Union leaders reportedly are furious at what they see as management's attempt to portray them as money-grubbing.

Each Jill is generally paid $25 an hour for appearances that aren't charity-related. They do not receive weekly wages or salaries.

The other union charges include:

Termination of the Jills' choreographer, also a union member, after the representation election.

Advertising for a replacement choreographer without first considering current Jills.

Failure to communicate with Jills members on crucial issues, such as the April 15 tryouts for the 1995-96 squad.

Allowing an anti-union cheerleader to make an appearance in New York City and paying her expenses and those of her family, while at the same time prohibiting appearances by other Jills.

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