Attorneys for Plaintiffs - Leonidas

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4. A message entitled “Merger Committee Update for Tuesday,
September 30th, 2008” that is posted on the USAPA website states the USAPA
Merger Committee and Negotiating Advisory Committee “met with Company
representatives at the Company’s Tempe headquarters … to pass to the Company
our date of hire seniority list” and adds that this meeting was “another large step
towards the creation of a Date of Hire airline.” (Exhibit B.) According to the
“USAPA Officer, BPR and Committee Directory,” Defendant Diorio is the Chairman
of the “Negotiating Advisory (sub-Committee)” and Defendant Frear is a member of
that committee and Defendant Mowery is a consultant to that committee. (Exhibit
C).
5. On April 15, 2008, Defendant Stephan, as US Airways MEC
Chairman, issued a “Chairman’s message to the pilots,” stating that if ALPA wins
the NMB election the US Airways MEC will refuse to approve any CBA that would
implement the Nicolau Award. (Exhibit D)
6. Defendant Theuer is the Chairman of USAPA’s “Communications
Committee” and its “Electronic Communications (sub-committee).” Serving in this
capacity, he has posted numerous messages on the USAPA website that promote
the East Pilot wrongdoing complained of in this action. (Exhibit E).
I declare under penalty of perjury under the laws of the State of Arizona that
the foregoing is true and correct. Executed this 5th day of December, 2008, at
Phoenix, Arizona.
CERTIFICATE OF SERVICE
/s/
_____________________________
Andrew S. Jacob
I hereby certify that on December 5, 2008, I electronically transmitted the
foregoing document to the U.S. District Court Clerk’s Office by using the CM/ECF
System for filing and transmittal of a Notice of Electronic Filing.
/s/
________________________________
Andrew S. Jacob
Jacob Case Declaration 2:08-cv-01728-NVW Document 27 Filed 12/05/2008 Page 2 of 25
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