One argument the union wants U.S. Bankruptcy Judge Sean Lane to hear is that the pilots didn't cause the bankruptcy.

"We are in bankruptcy because of decisions management has made," Bates wrote. "The events of the past decade will be an evidentiary factor in court proceedings--documenting the fact that our pilots have a long history of acting in good faith to support this airline."

1. Crandall created the frequent flyer program. Said he wished he had not done so due the high administrative cost and the fact that it does not create significant customer loyalty.

2. Crandall created yield management for AA. Yield management was quickly copied by our competitors. He tried to undo yield management programs across the industry with his Value Pricing Plan (see item no. 13).

3. The purchase of 37/44/50 seat Regional Jets which Mr. Arpey acknowledged to the APA board were incredibly expensive and inefficient ,but purchased "to get around the pilots scope clause". (more than $2 billion of debt for aircraft no one else wants and we can't rid ourselves of.

4. The purchase of F-100 90 seat jets. This new fleet added incredible training and maintenance costs especially after Fokker went BK. Some of these aircraft were still having leases paid as late as the date of Ch-11 filing.

5. The high cost of first opening and then subsequently closing "hubs" at RDU and BNA.

6. The purchase of TWA and subsequent disposal of numerous assets and international routes leaving a poorly performing STL hub.

7. The purchase of Air Cal and subsequent disposal of all aircraft and most routes. The void remaining in the west coast is now proposed to be filled by a code share with Alaska.

8. The purchase of Reno and subsequent disposal of all aircraft and routes again furthering the west coast void. The strong arm tactics involved in the purchase resulted in a pilot job action and massive AMR revenue loss.

9. The intentional non-funding of the pilots' pension plan for 2 years rationalized by the FAA extending mandatory retirement age. This greatly exacerbated the current underfunding.

10. Operating 3 maintenance facilities for years, (MCI, TULE and Alliance) before finally closing MCI. The alliance facility is still greatly underutilized.

11. Numerous other conscious operational decisions that resulted in record FAA fines and the grounding at one point of the entire S-80 fleet. The wire bundle debacle. The hiding of faulty repairs on S-80 pressure vessels in the chop line at Roswell.

12. The failure to purchase the Pan Am pacific routes or merge with NWA thus denying the necessary Asian presence.

13. The value pricing debacle which was costly and unnecessary

14. The "more room throughout coach" scheme which resulted in less revenue and far higher revenue differential with direct competitors.

15. The failure to provide the French Airway system, SNCR, with a workable CRS system resulting in a large financial settlement.

16. The massive HR failure and management decision to provide bonuses to senior management less than 3 years after all of labor gave up $1.8 billion/yr to restructure outside of bankruptcy. With all labor groups working far more for far less when these bonuses were announced resulted in a first ever multi union grievance which restricted the cash component but allowed unrestricted stock. Despite the incredibly obvious labor problems created as AMR entered bargaining with all 3 unions, management continued to provide themselves with annual bonuses each subsequent April.

17. The inexplicable but destructive communication failure by AMR in failing to explain to their labor groups in 2011, the dire nature of their financial situation, and after filing for reorganization blaming their failings on labor.

18. Pulling out of 2nd tier European cities (Lyon, Dusseldorf, Munich, Stockholm, Glasgow) used to feed business to codeshare partners. This made AMR over reliant on the US-LHR market and hurt AMR when the financial industry collapsed twice in a decade: post 9/11 and again during the Global Financial Crisis (GFC).

19. A premature filing of Ch. 11 based on tactical concerns ( Dec pilot retirements, roll over of some debt instruments, internal senior management disagreement ) rather than first having a strategic plan that was based on major concerns such as the timing of re-fleeting and truly evaluating other options (merger, equity investment from BA or others, approaching labor re. a possible ESOP etc). This knee jerk reaction will prove costly especially with S-80 lessors who have been handed considerable leverage in renegotiation knowing AA will need the majority of these aircraft well into 2014)

20. A stock buy back plan costing billions in cash but inflating the stock price - THE key metric in the management bonus schemes.

21. SABRE. 1 billion spent on the system that was designed to give AMR control of ticket sales, initially through travel agents and later through the internet. AMR and SABRE were sued repeatedly by competitors to gain access, which they won. That SABRE failed to enhance AMR profits led to the attempt to kill it via the Value Pricing Plan. SABRE was spun off. AMR then began expensive litigation effort to control SABRE's global distribution system. AMR lost again.

22. Failure to bid on mail contracts, and subsequent loss thereof.

23. The sick jihad.

24. The investment of hundreds of millions in Canadian Air Int'l., which subsequently went BK and defaulted.