Bradford's deposition sure stirred up a hornets nest. I wonder why..........
Excerpts:
25· · · ·Q.· ·I'm going to show you, Mr. Bradford, and
·1· this may be our last document, what I've identified
·2· as Exhibit 1062, e-mail from you to Mr. Pauley and
·3· others, April 25, 2013.
·4· · · · · · Did you write this e-mail?
·5· · · ·A.· ·Apparently so, yes.
·6· · · ·Q.· ·You write in the first paragraph, Jess,
·7· Jess raised the question of the dismissal of the
·8· pled, P-L-E-D, preliminary injunction in Addington I.
·9· Here is that decision.· In Addington II, Roman
10· numeral two, the court dismissed the company because
11· they were not in cohorts with USAPA.
12· · · · · · Then you continue to write, here the union
13· and the company are in concert.· We have agreed to a
14· new seniority process that does not include the
15· Nicolau award.
16· · · · · · What did you mean by that?
17· · · ·A.· ·We've just -- just what it says.· We
18· have -- the company and the union and APA and the
19· parties to the MOU have agreed on a new process for
20· seniority that is not tied to the old transition
21· agreement.
22· · · ·Q.· ·It does not include the Nicolau?
23· · · ·A.· ·It -- it -- that could be a misstatement.
24· It includes a new process.· If the board wants the
25· Nic, they could have the Nic.
·1· · · ·Q.· ·But that didn't -- that's not what you
·2· wrote.· You -- you wrote you're in cohorts -- cohorts
·3· with the --
·4· · · · · · MS. AXEL:· Cahoots.
·5· · · ·Q.· ·-- cahoots with the company, Airways,
·6· because you agreed to a new seniority process that
·7· does not include the Nicolau.
·8· · · ·A.· ·We factored --
·9· · · ·Q.· ·Those were your -- those are your words --
10· · · ·A.· ·No, the words are --
11· · · ·Q.· ·No, let me -- let me, let me.· Those are
12· your words and your e-mail on April 25, 2013,
13· correct?
14· · · ·A.· ·Incorrect.
15· · · ·Q.· ·Why?
16· · · ·A.· ·We're not in cahoots with the company,
17· we've acted in concert with the company.
18· · · ·Q.· ·Concert.
19· · · · · · What's the difference?
20· · · ·A.· ·We sat at the table, negotiated, arrived
21· at an MOU with all the parties which provides for a
22· new seniority process.
23· · · ·Q.· ·And you still believe that?
24· · · ·A.· ·Yes.· And that process --
25· · · ·Q.· ·That does not include the Nicolau?
·1· · · ·A.· ·Well, it's neutral on its terms.
·2· · · ·Q.· ·You say it eliminated the -- the
·3· requirement to use the -- the Nicolau.· So how can
·4· that be neutral?
·5· · · ·A.· ·Because the Nicolau award or date of hire
·6· or any other seniority solution and outcome does
·7· not appear in the document.
·8· · · ·Q.· ·Just because it doesn't appear, it's
·9· neutral?
10· · · ·A.· ·Yes.
11· · · ·Q.· ·But the effect of it is -- from your point
12· of view is to take away the requirement to use the
13· Nicolau?
14· · · ·A.· ·Yes, the transition agreement has been
15· amended, that is correct.
16· · · ·Q.· ·All right.· And to set up a process where
17· the majority is going to rule what's presented to the
18· McCaskill-Bond committee?
19· · · ·A.· ·Without any negotiation, yes.