A. Immediately, and in good faith, make all reasonable efforts to negotiate and
implement a single collective bargaining agreement with US Airways that will
implement the Nicolau Award seniority proposal unmodified, according to its terms;
B. Make all reasonable efforts to support and defend the seniority rights provided
by or arising from the Nicolau Award in negotiations with US Airways; and
Case 2:08-cv-01633-NVW Document 594 Filed 07/17/2009 Page 2 of 3
C. Not negotiate for separate collective bargaining agreements for the separate
pilot groups, but rather negotiate for a single collective bargaining agreement for both
pilot groups that incorporates the Nicolau Award. This injunction does not restrain
USAPA from pursuing its rights under Section 6 of the Railway Labor Act, consistent
with the previous sentence.
The Court retains jurisdiction to enforce, modify, or dissolve the permanent injunction
portion of this order. The Court retains jurisdiction to adjudicate the named Plaintiffs’
unadjudicated claims for damages and any claims for attorney fees.
DATED this 17th day of July 2009.