U.S. DISTRICT COURT
FILED NORTHERN DISTRICT OF TEXAS
IN THE UNITED STATES DISTRICT Co RT

FOR THE NORTHERN DISTRICT OF T XAS

DALLAS DIVISION

Jt\N i 2 2006

MARK WOODALL, MICHAEL P. MCMAHON,
PAUL J. MADSON,
Individually and on behalf of a class of all similarly situated persons,
Plaintiffs,
v.
AMERICAN AIRLINES, INC.,
Defendant.

CLERK, U.S. DISTRICT COURT
By _ _ _ ~ _ _ __
Deputy
Civil Action No. - - - - - -
3-06CV-0072M

COMPLAINT. CLASS ACTION
Plaintiffs, Mark Woodall, Michael P. McMahon, and Paul J. Madson ("Plaintiffs"), on
behalf of themselves and a class of all similarly situated persons, by the undersigned attorneys, make the following averments: 1. This is a civil action brought pursuant to the Uniformed Services Employment and
Reemployment Rights Act of 1994,38 U.S.C. §§ 4301 et seq. ("USERRA"). JURISDICTION AND VENUE· 2. This Court has jurisdiction over the subject matter of this action pursuant to
38 U.S.C. § 4323(b). 3. Venue is proper in this district under 38 U.S.C. § 4323(c)(2) and 28 U.S.C.
§ 1391(b), because Defendant, American Airlines, Inc. ("American Airlines"), maintains a place of business in this judicial district.

PARTIES 4. PlaintiffMark Woodall ("Woodall") resides in Carrollton, Texas. He is currently
employed by American Airlines as a pilot. Woodall is also a Captain in the United States Naval Reserve. S. Plaintiff Michael McMahon ("McMahon") resides in Arnold, Maryland. He is a former employee ofAmerican Airlines where he was employed as a pilot. McMahon is a member of the United States Naval Reserve and served as a Captain between 1998 and 2005. In 2005, McMahon was recalled to active duty and is currently a Commander. 6. Plaintiff Paul Madson ("Madson") resides in Chicago, Illinois. He is currently employed by American Airlines as a pilot. Madson is also a Lieutenant Colonel in the Ready Reserve of the South Dakota Air National Guard. 7. Defendant American Airlines maintains its headquarters at 4333 Arnon Carter Blvd, Fort Worth, Texas 76155, within the jurisdiction of this Court. CLAIMS FOR RELIEF 8. American Airlines is a global air passenger carrier whose passenger division is the largest scheduled passenger airline in the world, employing over 10,000 pilots, of whom approximately 1,000 are members of the United States Anned Forces serving in National Guard and Reserve units. 9. Pursuant to the 1997 and 2003 Collective Bargaining Agreements between American Airlines and the Allied Pilots Association (the "Collective Bargaining Agreements"), American Airlines has calculated earned vacation time for pilots based on their accumulated service time with American Airlines, as well the pilots' service time during the previous calendar year. Pursuant to the Collective Bargaining Agreements,
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American Airlines has calculated earned sick leave time based on the pilots' service time during the previous calendar year. The Collective Bargaining Agreements have required that a pilot be "in service" for fifteen (15) days in a calendar month in order for that month to be counted in figuring the pilot's service time. 10.. Pursuant to the Collective Bargaining Agreements. American Airlines has allowed pilots who are "in service" to bid on flight schedules for the upcoming month based on their seniority status. Pilots who are considered to be on "leaves of absence" may not bid for flight schedules. 11. Pursuant to the 1997 Collective Bargaining Agreement, American Airlines was required to credit each pilot with 1.33 days of sick leave for each month the pilot was "in service" during the year. Pursuant to the 2003 Collective Bargaining Agreemerit, American Airlines must credit each pilot with five (5) hours of sick leave for each month the pilot is "in service" during the year. 12. Upon information and belief, in January 2002, American Airlines conducted an audit of the flight records of pilots who took military leave during 2001. Based on that audit, American Airlines reduced the service time for pilots who had taken military leave during 2001, regardless of whether those pilots were scheduled to work on the days they took military leave. This reduction of service time resulted in the reduction of earned vacation time for certain pilots who had taken military leave, including the named plaintiffs Woodall and McMahon. American Airlines did not reduce earned vacation time for pilots who had taken comparable types of non-military leave. 13. Upon information and belief, from 2001 through 2002, American Airlines placed
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pilots who took military leave; including the named plaintiffs Woodall, McMahon, and

Madson, on "leave of absence" status, which effectively denied them the ability to bid on

flight schedules based on their seniority status and to earn other employment benefits,

including earned paid vacation time and earned sick leave. American Airlines continues

to place pilots who take military leave on "leave of absence" status, thereby denying them

.

.

the ability to bid on flight schedules based on their seniority status and to earn other

employment benefits, including earned paid vacation time and earned sick leave.

14. Upon information and belief, in 2001 and 2002, American Airlines did not deny to pilots

who took comparable types of non-military leave, including but not limited to sick leave,

union service leave or jury duty leave, the ability to bid on flight schedules based on their

seniority and to earn other employment benefits, including earned paid vacation time and

earned sick leave. Similarly, American Airlines did not deny to pilots who conducted

other non-military activities andlor business on days when they were not scheduled to fly,

but were not technically considered to be "on leave," the ability to bid on flight schedules

based on their seniority status and to earn other employment benefits, including earned

paid vacation time and earned sick leave.

Mark Woodall

15. American Airlines has employed Woodall as a pilot since 1991. He joined

American Airlines directly from active duty as a pilot with the United States Navy.

16. In 2001, pursuant to the 1997 Collective Bargaining Agreement and his seniority,

Woodall was entitled to twenty-one (21) paid vacation days based on his ten (10) years of

total service with American Airlines and twelve (12) months of service time in 2001.

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17. Woodall took sixteen (16) days of military leave for annual reserve training with the United States Naval Reserve, June 9-24, 2001.
18. In February 2002, Woodall learned that he would only accrue nineteen (19) paid vacation days in 2002 because American Airlines considered him on a "leave of absence" in June 2001 during his sixteen (16) days ofmilitary leave and thus American Airlines would not credit him with being in service in June.
19. As a result of American Airlines' 'denial of two earned days ofpaid vacation time to
.~.-,\
Woodall due to his military service, Woodall has suffered a loss of his benefits of employment.
~ichael~c~ahon
20. American Airlines employed McMahon as a pilot from 1998 to 2005. McMahon is a member of the United States Naval Reserve. In June 2005, he was recalled to full-time active duty and is currently a Commander.
21. In 2001, pursuant to the Collective Bargaining Agreement and his seniority, McMahon was entitled to fourteen (14) paid vacation days based on his three (3) years of total service with American Airlines and twelve (12) months of service time in 2001.
22. McMahon took fourteen (14) days of military leave for annual reserve training with the Naval Reserve, February 4 - 17,2001.
23, In 2002, McMahon learned that American Airlines had audited the flight records of pilots who tODk military leave and that he would be awarded .only thirteen (13) paid vacation days in 2002 because American Airlines cDnsidered him on a "leave of absence" in February 2001, covering his fourteen (14) days of military leave, and thus American, Airlines wDuld not credit him for being in service for the month ofFebruary.
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24. As a result of American Airline's denial of an earned day ofpaid vacation time to McMahon due to his military service, McMahon has suffered a loss of his benefits of employment.
Paul Madson 25. American Airlines has employed Madson as a pilot since 1989. He joined American
Airlines directly from active duty as a pilot with the United States Air Force. 26. In 2002, pursuant to the 1997 Collective Bargaining Agreement, Madson was
entitled to accrue 1.33 days of sick leave for each month he was "in service" with American Airlines. Pursuant to the 1997 Collective Bargaining Agreement and his seniority, he was also entitled to bid on his flight schedule in order of seniority. 27. Madson was on military leave for twenty (20) days, December 1-21, 2002. While on military leave, Madson served on active duty with the U.S. Air Force deployed to Turkey for Operation Northern Watch. 28. Upon his return from active duty, Madson completed his full-time flying schedule for American Airlines for the month of December, from December 22-31,2002. 29. American Airlines placed Madson on "leave of absence" status while he was on military duty in Turkey. Due to this status, Madson was not allowed to earn sick leave nor was he permitted to submit a flight schedule request for the month of January 2003. 30. As a result of American Airlines' placement of Madson on "leave of absence" status, he was denied 1.33 days of accrued sick leave and was placed on "reserve" flight status for the month of January. 31. Madson was further denied twenty-seven (27) hours of paid flight time in January 2003 because he was placed on reserve flight status instead ofbeing awarded his December
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2002 bid for a flight schedule based on his thirteen (13) years of seniority at American Airlines. 32. The acts and practices of American Airlines, set forth in paragraphs 12-14,18-19,23-24 and 29-31 above, constitute violations ofUSERRA, with respect to the named plaintiffs Woodal1, McMahon, and Madson, and a class of similarly situated present and fonner pilots who have taken military leave while employed by American Airlines. CLASS ACTION ALLEGATIONS 33. Plaintiffs bring this action pursuant to Rule 23(a) and (b)(2) of the Federal Rules of Civil Procedure on behalf of a class of all past and present pilots of American Airlines who are or were members ofthe United States Anned Services and who have taken military leave from January 2001 to the present while employed by American Airlines. Plaintiffs are members of the class they seek to represent. 34. The members of the class are sufficiently numerous that joinder of all members is impracticable. Plaintiffs are infonned and believe that the class exceeds 100 present and fonner pilots of American Airlines. 35. There are questions oflaw and fact common to the class, and these questions predominate over individual questions. Such questions include, without limitation: whether American Airlines has placed pilots who have taken military leave since 2001 on "leave of absence" status for the periods of their military leave; whether American Airlines has not placed pilots who have taken comparable types of non-military leave since 2001, including sick leave, union service leave or jury duty leave on "leave of absence" status for their periods of such non-military leave; whether American Airlines' acts 'and practices have violated USERRA by discriminating against American Airlines
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pilots who are members of the Armed Forces and have taken military leave; and whether injunctive and other equitable remedies for the class are warranted. 36. The claims alleged by Plaintiffs are typical of the claims of the class. 37. The named Plaintiffs will fairly and adequately represent and protect the interests of the class. 38. Class certification is appropriate pursuant to Fed. R. Civ. Proc. Rule 23(b)(2) because American Airlines has acted on grounds generally applicable to the class, making appropriate declaratory and injunctive relief to Plaintiffs and the class as a whole. The class members are entitled to injunctive relief to end American Airlines' acts and practices that have treated pilots who have taken military leave differently and less favorably than pilots who have taken comparable types of non-military leave. PRAYER FOR RELIEF WHEREFORE, Plaintiffs, on behalfof themselves and the members of the class, pray for judgment against American Airlines, its officers, agents, employees, successors and all persons in active concert or participation with it as follows: 39. Determine that this action may proceed and be maintained as a class action, designating Plaintiffs as Lead Plaintiffs, and c,ertifying Plaintiffs as class representatives under Rule 23 of the Federal Rules of Civil Procedure and their counsel as lead counsel, and designating Plaintiffs as representatives of the class and their counsel of record as Class Counsel; 40. Declare that the acts and practices complained ofherein are unlawful and are in violation ofUSERRA, 38 U.S.C. § 4301, et seq.;
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41. Require that American Airlines fully comply with the provisions ofUSERRA by providing Plaintiffs and class members all employment benefits denied them as a result of the unlawful acts and practices under USERRA described herein, including, but not limited to, lost earned vacation time and lost earned sick leave (or the monetary equivalent), and pay lost due to the inability to bid on.flights commensurate with their levels of seniority;
42. Enjoin American Airlines from taking any action against Plaintiffs and members of the
class that fails to comply with the provisions ofUSERRA; 43. Award Plaintiffs prejudgment interest on the amount oflost wages or employment
benefits found due; 44. Grant such other and further relief as may be just and: proper.

45. Plaintiffs further pray for their costs and disbursements in this action. ALBERTO R. GONZALES Attorney General WANJ.KIM Assistant Attorney General Civil Rights Division
BY: OJd~ DAVID J. PALMER (DC Bar No. 417834) Chief
Christin M. Roth (DC BarNo. 464815) Deputy Chief John Cunningham (VA Bar No. 43973) Trial Attorney Andrew Braniff(IN Bar No.23430-71) Trial Attorney U.S. Department ofJustice Civil Rights Division Employment Litigation Section 950 Pennsylvania Avenue, NW Patrick Henry Building, Room 4036 Washington, DC 20530 Telephone: (202) 514·3831 Facsimile: (202) 514-1005
Attorneys for Plaintiff
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Page 1

Briefs and Other Related Documents

Woodall

v.

American

Airlines,

Inc.N.D.Tex.,2006.Only the Westlaw citation is

currently available.

United States District Court,N.D. Texas, Dallas 


Division. 


Mark WOODALL, Michael P. McMahon, Paul J.


Madson, Individually and on behalf of a class of all


similarly situated persons, Plaintiff, 


v. 


AMERICAN AIRLINES, INC., Defendant.


No. 3-06-CV-0072-M.

Oct. 6, 2006.

MEMORANDUM OPINION AND ORDER LYNN, J. *1 Before the Court is Defendant's Motion for Dismissal of Plaintiffs' Complaint, and, Alternatively, to Strike, filed on April 2, 2006. The Court finds that Plaintiffs have properly stated claims for damages related to the accrual of sick and vacation leave, but have not met their pleading burden with respect to claims concerning trip bidding procedures. As described below, Defendant's Motion to Dismiss and, Alternatively, to Strike are DENIED. Plaintiffs are granted leave to amend their Complaint concerning trip bidding so as to bring them in compliance with the pleading requirements of Fed.R.Civ.P. 8(a)(2).

Background
Plaintiff Mark Woodall is a pilot for American Airlines. He joined American directly from active duty as a pilot in the United States Navy. He is currently a Captain in the United States Naval Reserve. From June 9, 2001 until June 24, 2001, Woodall took sixteen days of military leave for annual reserve training with the Naval Reserve.
Plaintiff Michael McMahon was a pilot for American from 1998 to 2005, when McMahon was recalled to full-time active duty in the Naval Reserve. McMahon served as a Captain from 1998 to 2005, and currently serves as a Commander. From February 4, 2001 to February 17, 2001, McMahon took fourteen days of military leave for annual reserve training with the Naval Reserve.

Plaintiff Paul Madson has been a pilot for American since 1989. He joined American directly from active duty as a pilot with the United States Air Force. Madson was on military leave for twenty days from December 1 through December 21, 2002, during which time he was deployed to Turkey for Operation Northern Watch. Madson returned to American and completed his full-time flying schedule for American in the month of December 2002, from December 22­ 31.
American placed Woodall, McMahon, Madson and every other American pilot who took military leave after January 2001 on “leave of absence” status pursuant to the 1997 Collective Bargaining Agreement (“CBA”) that was negotiated by American and the Allied Pilots Association (“the Association”), which represented American's pilots. The CBA provides that pilots who are “in service” may bid on flight schedules for the upcoming month based on their seniority status. The CBA also provides that earned vacation time for pilots is calculated based on the pilots' accumulated service time with American, as well as the pilots' service time during the previous calendar year. Under the 1997 CBA, a pilot on leave of absence due to military service does not accrue vacation and sick leave, and a pilot who has not returned from military leave before the close of trip selection cannot bid for flight schedules for the upcoming scheduling period. The 1997 CBA also provides for circumstances when a pilot who is not available for flying duties due to certain circumstances is nevertheless entitled to accrual of benefits. These circumstances include absences within accrued sick leave, participation in American training programs, authorized vacation, and jury duty. Military service is not such a circumstance. Def.'s App. at 32.
*2 In 2003, a new CBA, superseding the 1997 CBA, was negotiated by American and the Association. Under the 2003 CBA, pilots on military leave are still placed on leave of absence status, in contrast to those pilots relieved of flying duties due to the enumerated circumstances. However, under the 2003 CBA, “current and qualified” pilots who will be “available on the first day of the next contractual month” may participate in the flight bidding process even if they have not returned from military leave before the close of the bidding process. Def.'s App. at 371.

© 2006 Thomson/West. No Claim to Orig. U.S. Govt. Works.

Slip Copy Slip Copy, 2006 WL 2914135 (N.D.Tex.) (Cite as: Slip Copy)
Woodall, McMahon and Madson seek injunctive and declaratory relief on behalf of themselves and all similarly situated persons for alleged violations by American of the Uniformed Services Employment and Reemployment Rights Act of 1994, 38 U.S.C. § § 4301 et seq. (“USERRA”). Plaintiffs seek all the employment benefits allegedly denied them, including lost pay due to the inability to bid on flights (the “Trip Bidding Claim”), and lost earned vacation time and lost earned sick leave (the “Vacation and Sick Leave Accrual Claim”).
American's Motion to Dismiss or, Alternative Motion to Strike, asserts that Plaintiffs have failed to state a claim upon which relief may be granted. American contends that Plaintiffs' claims flatly contradict the documents upon which the claims are based. Alternatively, American argues that any claims under the 2003 CBA should be stricken as immaterial and impertinent, as Plaintiffs have failed to allege any damages sustained, or anticipated, as a result of the 2003 CBA.
Standard of Review
I. Failure to State a Claim for Relief

Page 2
be live both at the time the class action complaint is filed and at the time of class certification.” Dallas Gay Alliance v. Dallas County Hospital Dist., 719 F.Supp. 1380, 1384-85 (N.D.Tex.1989) (Sanders, J.) (citing Geraghty, 445 U.S. at 418 n. 12).
II. Motion to Strike
*3 Pursuant to Fed.R.Civ.P. 12(f), “upon motion made by a party ... or upon the court's own initiative at any time, the court may order stricken from any pleading any insufficient defense or any redundant, immaterial, impertinent, or scandalous matter.” Motions under Rule 12(f) are “viewed with disfavor and are infrequently granted.” F.D.I.C. v. Niblo, 821 F.Supp. 441, 449 (N.D.Tex.1993) (Cummings, J.) (citing Augustus v. Board of Public Instruction of Escambia County, Florida, 306 F.2d 862, 868 (5th Cir.1962). To succeed on a motion to strike, the movant must show that “the allegations being challenged are so unrelated to [the non-movant's] claims as to be unworthy of any consideration as a defense and that their presence in the pleading ... will be prejudicial to the moving party.” Id. (citing Augustus, 306 F.2d at 868). “The Court must deny a motion to strike if there is any question of fact or law.” Id. (citing Augustus, 306 F.2d at 868).

A motion filed under Fed.R.Civ.P. 12(b)(6) should be granted only if the nonmovant can prove no set of facts in support of his claims that would entitle him to relief. Guenther v. Cadle Co., No. 03-CV-3009, 2004 WL 1238194 at *2 (N.D. Tex. June 3, 2004) (Fish, C.J.) (citing Conley v. Gibson, 335 U.S. 41, 45­ 46 (1957)). Although the Court must accept all wellpleaded facts as true and view them in the light most favorable to the nonmovant, conclusory allegations and unwarranted factual deductions will not defeat a motion to dismiss. Id.
An example of a claim upon which relief cannot be granted is a moot claim. Pursuant to Article III of the United States Constitution, the jurisdiction of federal courts is limited to “cases and controversies.” Clark v. Bowles, No. 3:02-CV-2057-M, 2003 WL 21500425, *2 (N.D.Tex. Apr. 22, 2003) (Lynn, J.) (citing United States Parole Comm'n v. Geraghty, 445 U.S. 388, 396 (1980)). “A case becomes moot when the issues presented are no longer live or the parties lack a legally cognizable interest in the outcome of the proceedings.” Id. at *2 (citing Geraghty, 445 U.S. at 396). In the context of a class action, the named plaintiffs' individual claims “must

III. Class Actions Brought Under 23(b)(2)
Fed.R.Civ.P. 23(b)(2) provides that a class may be certified when “the party opposing the class has acted or refused to act on grounds generally applicable to the class, thereby making appropriate final injunctive relief or corresponding declaratory relief with respect to the class as a whole.” Certification of a class is only appropriate under Fed.R.Civ.P. 23(b)(2) if class members will benefit from the injunctive relief they request. Monetary relief may be asserted under 23(b)(2) so long as it is “incidental,” meaning that such relief is computable “by means of objective standards and not dependent in any significant way on the intangible, subjective differences of each class member's circumstances.” In re Monumental Life Ins. Co., 365 F.3d 408, 416 (5th Cir.2004) (citing Allison v. Citgo Petroleum Corp., 151 F.3d 402, 415 (5th Cir.1998). The monetary relief “must flow directly from liability to the class as a whole on the claims forming the basis of the injunctive or declaratory relief.” Id. (citing Allison, 151 F.3d at 415).
Analysis

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I. Failure to State a Claim for Relief
Plaintiffs first argue that American violated and continues to violate USERRA because both the 1997 CBA and the 2003 CBA (collectively, the “CBAs”) deny pilots on military leave the right to bid on flight schedules, thereby denying them appropriate seniority status (the “Trip Bidding Claim”). Second, Plaintiffs argue that American violated and continues to violate USERRA because Plaintiffs were, and continue to be, denied their rights to accrue nonseniority benefits, such as vacation time and sick leave, while pilots on non-military leave are permitted to accrue such benefits (the “Vacation and Sick Leave Accrual Claim”).
In response to the Trip Bidding Claim, American asserts that the 2003 CBA renders moot any claim and request for injunctive relief, as the 2003 CBA changes the trip bidding process under the 1997 CBA, under which at least one Plaintiff has allegedly suffered damages. Second, American argues that the terms of the CBAs distinguish between military leaves of absence and non-military leaves, and that those leaves are thus not comparable.
*4 USERRA is the most recent in a series of laws enacted to protect veterans' employment and reemployment rights. Rogers v. City of San Antonio, 392 F.3d 758, 762 (5th Cir.2004).FN1 Generally, to bring a claim under USERRA, a plaintiff must allege that “(1) [a] person is entitled ... to employment or reemployment rights or benefits with respect to employment by an employer; and (2)(A) such employer has failed or refused, or is about to fail or refuse, to comply with the provisions of this chapter.” 38 U.S.C. § 4322(a). Pursuant to section 4316(a) of USERRA, a person who is absent from employment due to military leave:
FN1. The large body of case law that developed under USERRA's precursor statutes, such as the Selective Training and Service Act of 1940 and the Veterans' Reemployment Rights Act (“VRRA”), is relevant to the extent it is consistent with USERRA. Rogers, 392 F.3d at 762.
is entitled to the seniority and other rights and benefits determined by seniority that the person had on the date of the commencement of service in the uniformed services plus the additional seniority and

rights and benefits that such person would have attained if the person had remained continuously employed. 38 U.S.C. § 4316(a).FN2 For rights determined by seniority, USERRA codifies the “escalator principle”-that is, a returning service member does not step back on the “seniority escalator” at the point he stepped off; rather, he returns “at the precise point he would have occupied had he kept his position continuously.” Rogers, 392 F.3d at 763 (quoting Fishgold v. Sullivan Drydock and Repair Corp., 328 U.S. 275, 284-85 (1946)).
FN2. Section 4303(12) of USERRA defines “seniority” as “longevity in employment together with any benefits of employment which accrue with, or are determined by, longevity in employment.”
In its Motion and Reply, American repeats its contention that Plaintiffs have failed to state a claim upon which relief may be granted because both the 1997 CBA and the 2003 CBA clearly delineate different types of leave. American argues that military leave that falls under the “leave of absence” umbrella is not comparable to other types of leave (e.g., sick leave) that fall within the ambit of “relieved of flying duties.” American points to a number of ways in which leave for military duty differs from leave during which pilots continue to accrue benefits. For example, a pilot who is relieved of flying duties for the purpose of participating in union activities continues to accrue vacation benefits. The union must reimburse American for that pilot's salary, etc. during his absence. American urges the Court to follow settled law under the Railway Labor Act, 45 U.S.C. § 181, which provides that courts are not to disturb the terms of a collectively bargained labor agreement.
USERRA does not supersede any federal or state law, contract, agreement, or plan “that establishes a right or benefit that is more beneficial to, or is in addition to, a right or benefit provided for such person in this chapter.” Section 4302(b). However, if Plaintiffs successfully demonstrate that, labels and titles assigned to various types of leave within the CBAs notwithstanding, the 1997 CBA and/or the 2003 CBA deny Plaintiffs rights assured to them under USERRA, then USERRA does and will supersede that CBA(s).
American further urges that Plaintiffs have failed to state a claim for monetary compensation for alleged

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violations of USERRA stemming from the 1997 CBA's trip bidding provisions. In their Complaint at ¶ 41, Plaintiffs pray for “pay lost due to the inability to bid on flights commensurate with [Plaintiffs'] levels of seniority.” In the Court's view, this is a sufficiently clear statement that Plaintiffs intend to pursue monetary damages, as well as injunctive relief. However, it is the Court's view that Plaintiffs have failed to state a factual basis on which to seek prospective injunctive relief with respect to the 2003 CBA's trip bidding procedures. Plaintiffs bring their claims pursuant to Fed.R.Civ.P. 23(b)(2), and monetary relief under Rule 23(b)(2) may only be incidental to the injunctive or declaratory relief requested. Thus, without pleading properly a claim for injunctive relief under Rule 23(b)(2), Plaintiffs' claim for monetary relief is deficient. Since the 2003 CBA provides for trip bidding by a pilot on military leave who will return to service at the beginning of the following month, it is not clear what injunctive relief Plaintiffs are seeking.
*5 Pursuant to Fed.R.Civ.P. 8(a)(2), Plaintiffs need only provide American with a short and plain statement of their claims. Swierkiewicz v. Sorema N.A., 534 U.S. 506, 512 (2002). That the CBAs attach different labels to different types of leave does not, as American urges, mean that Plaintiffs have failed to state a claim upon which relief may be granted. It is the Court's understanding that the 2003 CBA does not modify the provisions of the 1997 CBA concerning sick leave and vacation accrual, under which Plaintiffs claim to have suffered damages. Though Plaintiffs have failed to do so with respect to the remedies sought by the Trip Bidding Claim, Plaintiffs have sufficiently pled their Vacation and Sick Leave Accrual Claim, with respect to both the 1997 and 2003 CBAs.
VI. CONCLUSION
As to Plaintiffs' Vacation and Sick Leave Accrual Claim, American's Motion to Dismiss is DENIED. Plaintiffs have until October 30, 2006 to amend their Trip Bidding Claim, properly to state a claim for injunctive relief, or to seek monetary damages via an avenue that does not require that Plaintiffs' claim for monetary relief be incidental to a claim for injunctive relief, as is required by Rule 23(b)(2). Failure to so amend will result in the dismissal of Plaintiffs' Trip Bidding Claim. All other relief not expressly granted herein is DENIED.
SO ORDERED.

N.D.Tex.,2006. 
 Woodall v. American Airlines, Inc. 
 Slip Copy, 2006 WL 2914135 (N.D.Tex.)

Briefs and Other Related Documents (Back to top)
• 2006 WL 1794494 (Trial Motion, Memorandum and Affidavit) American Airlines, Inc.'s Reply Brief in Support of its Motion for Dismissal of Plaintiffs' Complaint, and, Alternatively, to Strike (Jun. 27, 2006) Original Image of this Document (PDF) • 2006 WL 1967025 (Trial Motion, Memorandum and Affidavit) American Airlines, Inc.'s Reply Brief in Support of its Motion for Dismissal of Plaintiffs' Complaint, and, Alternatively, to Strike (Jun. 27, 2006) Original Image of this Document (PDF) • 2006 WL 1734035 (Trial Motion, Memorandum and Affidavit) Plaintiffs' Opposition to Defendant's Motion for Dismissal of Plaintiffs' Complaint, and, Alternatively, to Strike (Jun. 12, 2006) Original Image of this Document (PDF) • 2006 WL 1967031 (Trial Motion, Memorandum and Affidavit) Plaintiffs' Opposition to Defendant's Motion for Dismissal of Plaintiffs' Complaint, and, Alternatively, to Strike (Jun. 12, 2006) Original Image of this Document (PDF) • 2006 WL 1191677 (Trial Motion, Memorandum and Affidavit) Defendant American Airlines, Inc.'s Motion for Dismissal of Plaintiffs' Complaint, And, Alternatively, to Strike (Apr. 12, 2006) Original Image of this Document (PDF) • 2006 WL 1191682 (Trial Motion, Memorandum and Affidavit) American Airlines, Inc.'s Brief in Support of its Motion for Dismissal of Plaintiffs' Complaint, And, Alternatively. to Strike (Apr. 12, 2006) Original Image of this Document (PDF) • 2006 WL 1433581 (Trial Motion, Memorandum and Affidavit) American Airlines, Inc.'s Brief in Support of its Motion for Dismissal of Plaintiffs' Complaint, and, Alternatively, to Strike (Apr. 12, 2006) Original Image of this Document (PDF) • 2006 WL 1182492 (Trial Pleading) Complaint ­ Class Action (Jan. 12, 2006) Original Image of this Document (PDF) • 2006 WL 160304 (Trial Pleading) Complaint Class Action (Jan. 12, 2006) • 2006 WL 425551 (Trial Pleading) Complaint Class Action (Jan. 12, 2006) Original Image of this Document with Appendix (PDF) • 3:06cv00072 (Docket) (Jan. 12, 2006)
END OF DOCUMENT

© 2006 Thomson/West. No Claim to Orig. U.S. Govt. Works.

 
 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION

MARK WOODALL, MICHAEL P. McMAHON, PAULl MADSON,
Individually and on behalf of a class of all similarly situated persons,
Plaintiffs,
v.
AMERICAN AIRLINES, INC.,
Defendant.

Civil Action No. 3:06-CV-0072-M ECF Judge Barbara M.G. Lynn
Jury Trial Demanded

. SECOND AMENDED COMPLAINT - CLASS ACTION Plaintiffs Mark Woodall, Michael P. McMahon,and Paul J. Madson ("Plaintiffs"), on behalf of themselves and a class of all similarly situated persons, by the undersigned attorneys, make the following averments: 1. This is a civil action brought pursuant to the Uniformed Services Employment and Reemployment Rights Act of 1994, 38 U.S.C. §§ 4301 et seq. ("USERRA"). JURISDICTION AND VENUE 2. This Court has jurisdiction over the subject matter ofthis action pursuant to 38 U.S.C. § 4323(b). 3. Venue is proper in this district under 38 U.S.C. § 4323(c)(2) and 28 U.S.C. § 1391(b), because Defendant, American Airlines, Inc. ("American Airlines"), maintains a place ofbus~ness in this judicial district.

PARTIES 4. Plaintiff Mark Woodall ("Woodall") resides in Carrollton, Texas. He is currently
employed by American Airlines as a pilot. Woodall is also a Captain in the United States Naval Reserve. 5. Plaintiff Michael McMahon ("McMahon") resides in Arnold, Maryland. He is a former employee of American Airlines where he was employed as a pilot. McMahon is a member of the United States Naval Reserve and served as a Commander between 1998 and 2005. ill 2005, McMahon was recalled to active duty and is currently a Captain. 6. Plaintiff Paul Madson ("Madson") resides in Chicago, Illinois. He is currently employed by American Airlines as a pilot. From 1995 to 2003, Madson served as a Guardsman and Lieutenant Colonel in the South Dakota Air National Guard. From 2003 to 2005, Madson was detailed as a Liaison Officer for the Air Force Academy and Air Force ROTC as a member of the United States Air Force Reserve. He retired from the military in July 2005. 7. Defendant American Airlines maintains its headquarters at"4333 Amon Carter Blvd, Fort Worth, Texas 76155, within the jurisdiction of this Court. CLAIMS FOR RELIEF 8. American Airlines is a global air passenger carrier whose passenger division is the largest scheduled passenger airline in the world, employing over 10,000 pilots, of whom approximately 1,000 are members ofthe United States Armed Forces serving in National Guard and Reserve units. 9. Pursuant to the 1997 and 2003 Collective Bargaining Agreements between
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American Airlines and the Allied Pilots Association (the "Collective Bargaining Agreements"), American Airlines has calculated earned vacation time for pilots based on their accumulated service time with American Airlines, as well the pilots' service time during the previous calendar year. Pursuant to the Collective Bargaining Agreements, American Airlines has calCulated earned sick leave time based on the pilots' service time during the previous calendar year. The Collective Bargaining Agreements have required that a pilot be "in service" for fifteen (15) days in a calendar month in order for that month to be counted in figuring the pilot's service time. 10. Pursuant to the 1997 Collective Bargaining Agreement, American Airlines has allowed pilots who are "in service" to bid on flight schedules for the upcoming month based on their seniority status. Pilots who are considered to be on "leaves of absence" may not bid for flight schedules. 11. Pursuant to the 1997 Collective Bargaining Agreement, American Airlines was required to credit each pilot with 1.33 days of sick leave for each month the pilot was "in service" during the year. Pursuant to the 2003 Collective Bargaining Agreement, American Airlines must credit each pilot with five (5) hours of sick leave for each month the pilot is "in service" during the year. 12. Upon information and belief, in January 2002, American Airlines conducted an audit ofthe flight records of pilots who took military leave during 2001. Based on that audit, American Airlines reduced the service time for pilots who had taken military leave during 2001, regardless of whether those pilots were scheduled to work on the days they took military leave. This reduction of service time resulted in the reduction of earned vacation time for certain pilots who had taken military leave, including the named
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Plaintiffs Woodall and McMahon. American Airlines did not reduce earned vacation time for pilots who had taken comparable types of non-military leave. 13. Upon information and belief, from 2001 through 2002, American Airlines placed pilots who took military leave, including the named Plaintiffs Woodall, McMahon, and Madson, on "leave of absence" status, which effectively denied them the ability to bid on flight schedules based on their seniority status and to earn other employment benefits, including earned paid vacation time and earned sick leave. American Airlines continues to place pilots who take military leave on "leave of absence" status, thereby denying them the ability to earn employment benefits, including earned paid vacation time and earned sick leave. 14. Upon information and. belief, in 2001 and 2002, American Airlines did not deny to pilots who took comparable types of non-military leave, including but not limited to sick leave, union service leave, or jury duty leave, the ability to bid on flight schedules based on their seniority and to earn other employment benefits, including earned paid vacation time and earned sick leave. Similarly, American Airlines did not deny to pilots who conducted other non-military activities andlor business on days when they were not scheduled to fly, but were not technically considered to be "on leave," the ability to bid on flight schedules based on their seniority status and to earn other employment benefits, including earned paid vacation time and earned sick leave. Mark Woodall 15. Anlerican Airlines has employed Woodall as a pilot since 1991. He joined American Airlines directly from active duty as a pilot with the United States Navy. 16. In 2001, pursuant to the 1997 Collective Bargaining Agreement and his seniority,
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Woodall was entitled to twenty-one (21) paid vacation days based on his ten (10) years of total service with American Airlines and twelve (12) months of service time in 2001. 17. Woodall took sixteen (16) days of military leave for annual reserve training with the United States Naval Reserve, June 9-24, 2001. 18. In February 2002, Woodallieamed that he would only accrue nineteen (19) paid vacation days in 2002 because American Airlines considered him on a "leave of absence" in June 2001 during his sixteen (16) days of military leave and thus American Airlines would not credit him with being in service in June. 19. As a result of American Airlines' denial ~ftwo earned days of paid vacation time to Woodall due to his military service, Woodall has suffered a loss of his benefits of employment. Michael McMahon 20. American Airlines employed McMahon as a pilot from 1998 to 2005. McMahon is a member ofthe United States Naval Reserve. In June 2005, he was recalled to full-time, active duty and is currently a Captain. 21. In 2001, pursuant to the Collective Bargaining Agreement and his seniority, McMahon was entitled to fourteen (14) paid vacation days based on his three (3) years of total service with American Airlines and twelve (12) months of service time in 2001. 22. . McMahon took fourteen (14) days of military leave for annual reserve training with the Naval Reserve, February 4 - 17,2001. 23. In 2002, McMahon learned that American Airlines had audited the flight records of pilots who took military leave and that he would be awarded only thirteen (13) paid vacation days in 2002 because American Airlines considered him on a "leave of absence"
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in February 2001, covering his fourteen (14) days of military leave, and thus American Airlines would not credit him for being in service for the month of February. 24. As a result of American Airlines' denial of an earned day of paid vacation time to McMahon due to his military service, McMahon has suffered a loss of his benefits of employment. Paul Madson 25. American Airlines has employed Madson as a pilot since 1989. Rejoined American Airlines directly from active duty as a pilot with the United States Air Force. 26. ill 2002, pursuant to the 1997 Collective Bargaining Agreement, Madson was entitled to accrue 1.33 days of sick leave for each month he was "in service" with American Airlines. Pursuant to the 1997 Collective Bargaining Agreement and his seniority, he was also entitled to bid on his flight schedule in order of seniority. 27. Madson was on military leave for twenty (20) days, December 1-21,2002. While on military leave, Madson served on active duty with the U.S. Air Force deployed to Turkey for Operation Northern Watch. 28. Upon his return from active duty, Madson completed his full-time flying schedule for American Airlines for the month ofDecember, from December 22-31, 2002. 29. American Airlines placed Madson on "leave of absence" status while he was on military duty in Turkey. Due to this status, Madson was not allowed to earn sick leave
a nor was he permitted to submit flight schedule request for the month of January 2003.
30. As a result of American Airlines' placement of Madson on "leave of absence" status, he was denied 1.33 days of accrued sick leave and was placed on "reserve" flight status for the month of January.
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31. Madson was further denied twenty-seven (27) hours of paid flight time in January 2003 because he was placed on reserve flight status instead of being awarded his December 2002 bid for a flight schedule based on his thirteen (13) years of seniority at American . Airlines.
32. The acts and practices of American Airlines, set forth in paragraphs 12-14, 18-19,23-24 and 29-31 above, constitute violations ofUSERRA with respect to the named Plaintiffs Woodall, McMahon, and Madson, and a class of similarly situated present and former pilots who have taken military leave while employed by American Airlines.
CLASS ACTION ALLEGATIONS 33. Plaintiffs bring this action pursuant to Federal Rule of Civil Procedure ("Rule") 23(a), on
behalf of a class of all past and present pilots of American Airlines who are or were members of the United States Armed Services and who have taken military leave from January 2001 to the present while employed by American Airlines. Plaintiffs seek class certification of their leave accrual claim under Rules 23(b)(2) and 23(b)(3). They seek class certification of their trip bidding claim under Rule 23(b)(3). Plaintiffs are members of the class they seek to represent. 34. Plaintiffs satisfy Rule 23(a)'s procedural prerequisites for bringing a class action because: a. The members of the class are sufficiently numerous that joinder of all members is
impracticable. Plaintiffs are informed and believe that the class exceeds 100 present and former pilots of American Airlines. b. There are questions of law and fact common to the class, and these questions predominate over individual questions. Such questions include, without limitation: whether American Airlines has placed pilots who have taken military
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leave since 2001 on "leave of absence" status for the periods oftheir military leave; whether American Airlines has not placed pilots who have taken comparable types of non-military leave since 2001, including sick leave, union service leave, or jury duty leave on "leave of absence" status for their periods of such non-military leave; whether American Airlines' acts and practices have violated USERRA by discriminating against American Airlines pilots who are members ofthe Armed Forces and have taken military leave; and whether injunctive and other equitable remedies for the class are warranted. c. The claims alleged by Plaintiffs are typical of the claims of the class. d. The named Plaintiffs will fairly and adequately represent and protect the interests of the class. 35. Class certification of Plaintiffs' leave accrual claim is appropriate pursuant to Rule 23(b)(2) because: a. American Airlines has acted on grounds generally applicable to the class, making appropriate declaratory and injunctive relief to Plaintiffs and the class as a whole, and monetary damages are incidental to the declaratory and injunctive relief sought. b. The class members are entitled to injunctive relief to end American Airlines' acts and practices that have treated pilots who have taken military leave differently and less favorably than pilots who have taken comparable types of non-military leave. For example, Plaintiff Woodall and other similarly situated pilots who are currently employed by American Airlines and serving as military reservists, will continue to suffer harm due to the written policies ofthe 2003 Collective
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Bargaining Agreement, specifically 2003 CBA §§ 5.A and Il.A & E.I-II, which define all pilots on military leave as being on "Leave of Absence," thereby limiting their ability to accrue certain employment benefits, such as paid sick leave and vacation leave, while allowing such accrual for pilots on comparable types of non-military leave. c. Plaintiff Woodall, and other similarly situated pilots who are currently employed by American Airlines and serving as military reservists, have suffered and will continue to suffer harm as a result ofthe contested provisions of the 2003 Collective Bargaining Agreement with respect to leave accrual because they have attended, or will be required to attend, military training or military exercises in the near future and have been or will be subject to the discriminatory policies and practices set forth in the 2003 Collective Bargaining Agreement. 36. Class certification of Plaintiffs' leave accrual and trip bidding claims is appropriate pursuant to Fed. R. Civ. Proc. Rule 23(b)(3) because questions oflaw and fact cominon to the putative class of pilots predominate over any questions affecting only individual members of the class, and a class action is superior to other available methods for the fair and efficient adjudication of this lawsuit. PRAYER FOR INJUNCTIVE AND MONETARY RELIEF WHEREFORE, Plaintiffs, on behalf of themselves and the members ofthe class, pray for judgment against American Airlines, its officers, agents, employees, successors and all persons in active concert or participation with it as follows: 37. Determine that this action may proceed and be maintained as a class action, designating Plaintiffs as Lead Plaintiffs, and certifying Plaintiffs as class representatives under Rule
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23 ofthe Federal Rules of Civil Procedure, and their counsel as lead counsel, and designating Plaintiffs as representatives of the class and their counsel of record as Class Counsel; 38. Declare that the acts and practices complained of herein are unlawful and are in violation ofUSERRA, 38 U.S.C. §§ 4301 et seq.; 39. Require that American Airlines fully comply with the provisions ofUSERRA by providing Plaintiffs and class members all employment benefits denied them as a result of the unlawful acts and practices under USERRA described herein, including, but not limited to, lost earned vacation time and lost earned sick leave (or the monetary equivalent), and pay lost due to the inability to bid on flights commensurate with their levels of seniority; 40. Enjoin American Airlines from taking any action against Plaintiffs and members of the class that fails to comply with the provisions ofUSERRA; 41. Award Plaintiffs prejudgment interest on the amount of lost wages or employment benefits found due; 42. Grant such other and further relief as may be just and proper.
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43. Plaintiffs further pray for their costs and disbursements in this action. ALBERTO R. GONZALES Attorney General WANJ.KIM
BY:·

Chief

t.-"

/ I

,

Christine M. Roth (DC Bar No. 464815)

Deputy Chief

Christine.Roth@usdoj.gov

John P. Cunningham (VA Bar No. 43973)

Trial Attorney

John.Cunningham4@usdoj.gov

Esther G. Tamburo (DC Bar No. 461316)

Trial Attorney

Esther. Tamburo@usdoj.gov

Andrew Braniff(lN Bar No. 23430-71)

Trial Attorney

Andrew .Braniff@usdoj.gov

U.S. Department of Justice

Civil Rights Division

Employment Litigation Section

950 Pennsylvania Avenue, NW

Patrick Henry Building, Room 4036

Washington, DC 20530

Telephone: (202) 514-3831

. Facsimile: (202) 514-1005

Attorneys for Plaintiffs

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CERTIFICATE OF SERVICE I hereby certify that on this 16th day of January 2007, I ~lectronically submitted the foregoing Second Amended Complaint-Class Action with the clerk of court for the U.S. District Court, Northern District of Texas, using the electronic case files system of the court. The electronic case files system sent a "Notice of Electronic Filing" to the following individuals, who have consented in writing to accept this Notice as service ofthis document by electronic means. I hereby certify that I have also served the foregoing document on the following individuals by electronic mail.
Ralph I. Miller Michelle Hartmann Weil, Gotshal & Manges LLP 200 Crescent Court, Suite 300 Dallas, TX 75201-6950 Telephone: (214) 746-7700 Facsimile: (214) 746-7777 Nicholas J. Pappas Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153 Telephone: (212) 310-8000 Facsimile: (212) 310-8007
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 Case 3:06-cv-00072-M Document 44 Filed 04/17/08 Page 1 of 4 PageID 1791

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION

MARK WOODALL, MICHAEL P. MCMAHON, PAUL J. MADSON, Individually and on behalf of a class of all similarly situated persons,
Plaintiffs,
v.
AMERICAN AIRLINES, INC.,
Defendant.

Civil Action No. 3:06-CV-0072-M ECF Judge Barbara M.G. Lynn

JOINT MOTION FOR CONDITIONAL CERTIFICATION OF THE SETTLEMENT CLASS, PRELIMINARY APPROVAL OF THE SETTLEMENT
AGREEMENT, AND APPROVAL OF THE FORMS OF CLASS NOTICE Plaintiffs Mark Woodall, Michael P. McMahon, and Paul J. Madson (“Plaintiffs”), on behalf of themselves and the members of the putative class, along with Defendant American Airlines, Inc. (“Defendant”), by and through the undersigned attorneys, hereby jointly move the Court for an Order: 1. Conditionally certifying, for settlement purposes only, the Settlement Class and Settlement Sub-Classes pursuant to Rules 23(a) and 23(b)(2) of the Federal Rules of Civil Procedure; 2. Provisionally designating Plaintiffs Woodall, McMahon, and Madson as representatives of the Settlement Class;

Case 3:06-cv-00072-M Document 44 Filed 04/17/08 Page 2 of 4 PageID 1792 3. Provisionally designating Plaintiffs Woodall and McMahon as representatives of
the Vacation Accrual Sub-Class; 4. Provisionally designating Plaintiff Woodall as the representative for the Sick
Leave Accrual Sub-Class; 5. Provisionally designating counsel for the representative Plaintiffs, Esther G.
Lander, John P. Cunningham, and Andrew Braniff, Civil Rights Division of the U.S. Department of Justice, as counsel for the Settlement Class;
6. Preliminarily approving the Settlement Agreement; 7. Approving the Notice and Public Notice, and ordering the mailing and/or publication to Settlement Class Members in accordance with the Settlement Agreement; and 8. Scheduling a Fairness Hearing for purposes of determining whether, among other things, to finally certify the Settlement Class and Settlement Sub-Classes and finally approve the Settlement Agreement. Plaintiffs’ memorandum in support of this motion, as well as a proposed Order, are attached. Defendant will file a separate memorandum in support of this motion.
2

Case 3:06-cv-00072-M Document 44 Filed 04/17/08 Page 3 of 4 PageID 1793

Dated: April 17, 2008

Respectfully submitted,
For Plaintiffs: GRACE CHUNG BECKER Acting Assistant Attorney General Civil Rights Division
John M. Gadzichowski (WI Bar No. 1014294) Acting Chief
/s/ Esther G. Lander Esther G. Lander (DC Bar No. 461316) Esther.Tamburo@usdoj.gov Acting Deputy Chief
John P. Cunningham (VA Bar No. 43973) John.Cunningham4@usdoj.gov Andrew Braniff (IN Bar No. 23430-71) Andrew.Braniff@usdoj.gov Trial Attorneys U.S. Department of Justice Civil Rights Division Employment Litigation Section 950 Pennsylvania Avenue, N.W. Patrick Henry Building, 4th Floor Washington, D.C. 20530 Telephone: (202) 514-3831 Facsimile: (202) 514-1005
For Defendant:
/s/ Margaret H. Allen Ralph I. Miller (TX Bar No. 14105800) Ralph.Miller@weil.com Michelle Hartmann (TX Bar No. 24032402) Michelle.HartmannMurawski@weil.com Margaret H. Allen (TX Bar No. 24045397) Margaret.Allen@weil.com Weil, Gotshal & Manges LLP 200 Crescent Court, Suite 300 Dallas, TX 75201-6950 Telephone: (214) 746-7700 Facsimile: (214) 746-7777
3

Case 3:06-cv-00072-M Document 44 Filed 04/17/08 Page 4 of 4 PageID 1794
CERTIFICATE OF SERVICE I hereby certify that on this 17th day of April 2008, I electronically submitted the foregoing Joint Motion for Conditional Certification of the Settlement Class, Preliminary Approval of the Settlement Agreement, and Approval of the Forms of Class Notice, along with a Memorandum in Support, and an attached Settlement Agreement with Exhibits with the clerk of court for the U.S. District Court, Northern District of Texas, using the electronic case files system of the court. The electronic case files system sent a “Notice of Electronic Filing” to the following individuals, who have consented in writing to accept this Notice as service of this document by electronic means:
Ralph I. Miller Michelle Hartmann Margaret H. Allen Weil, Gotshal & Manges LLP 200 Crescent Court, Suite 300 Dallas, TX 75201-6950 Telephone: (214) 746-7700 Facsimile: (214) 746-7777 Attorneys for Defendant
/s/ John P. Cunningham John P. Cunningham Attorney for Plaintiffs
4

 
 Case 3:06-cv-00072-M Document 74 Filed 08/01/08 Page 1 of 10 PageID 2841

IN THE UNITED STATES DISTRICT CO FOR THE NORTHERN DISTRICT OF TE
DALLAS DIVISION

MARK WOODALL,

§

MICHAEL P. MCMAHON,

§

PAULJ. MADSON,

§

Individually and on behalf of a class

§

of all similarly situated persons,

§

Civil Action No. 3:06-CV-0072-M

§

ECF

Plaintiffs,

§

Judge Barbara M.G. Lynn

§

v.

§

§

AMERICAN AIRLINES, INC.,

§

§

Defendant.

§

(~@8PfB FROfOSI£D] FINAL ORDER APPROVING SETTLEMENT, CERTIFYING CLASS, AND DIRECTING DISMISSAL

The Settlement Agreement, dated April 16, 2008, and First Amendment thereto,
dated July '2.\ , 2008 (collectively, the "Agreement"), which has been executed by counsel on
behalf of the Parties1 to this action, provides for the settlement of this Litigation on behalf of the

Representative Plaintiffs and the Settlement Class Members, subject to final approval by this

Court of its terms and to the entry ofthis Final Order.

Pursuant to the Preliminary Order dated May 13, 2008, conditionally certifying

the Settlement Class, preliminarily approving of the Agreement, approving the Notice and Public

Notice, and scheduling the Fairness Hearing, the Court directed that the approved Notice be

delivered to Members of the Settlement Class individually and the approved Public Notice be

published on https://www.aapilots.com.

American denies any wrongdoing, fault, violation oflaw, or liability for damages

1 All capitalized terms used in this Final Order shall have the same meaning as defined in the Agreement on file in this Litigation.

DAI :\517488\05\B3@_05!.DOC\14013.0111

Case 3:06-cv-00072-M Document 74 Filed 08/01/08 Page 2 of 10 PageID 2842

or injunctive relief of any sort. American objected, and continues to object, to the certification of any class except certification of the Settlement Class for settlement purposes only.
The Parties have applied to the Court for final approval of the Agreement, and the Parties have submitted this Final Order for entry. A Fairness Hearing was held before this Court
~3&/,~y of~ .1.~8'~ on July 24, 2008,1o consider, among other things, whether the Agreement should be finally approved by this Court as fair, reasonable, and adequate, and whether the Settlement Class and Settlement Sub-Classes should be finally certified pursuant to Rules 23(a) and 23(b)(2) of the Federal Rules ofCivil Procedure.
After considering (i) the memoranda submitted on behalf of the Representative Plaintiffs; (ii) the Agreement and all exhibits thereto; (iii) the record of this proceeding, including the evidence presented at the Fairness Hearing; (iv) the representations and arguments of counsel for the respective Parties; and (v) the relevant law based upon the findings of fact and law identified below and implicit in this Final Order:
It is hereby ORDERED, ADJUDGED, AND DECREED that: 1. The Agreement is the product of good faith, arms' length negotiations by the Parties, each of whom was represented by experienced counsel. A. Certification of the Settlement Class 2. The Court, solely for purposes of this settlement, finds as follows:
(a) the members ofthe Settlement Class, the Sick Leave Accrual SubClass, and the Vacation Accrual Sub-Class are all so numerous that joinder of all members would be impracticable;
(b) the Litigation and proposed settlement raise questions of law and fact common to the claims of the members of the Settlement Class and Settlement Sub-Classes;

DAI :1517488\05\B3@_05LDOC\14013.011 I

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Case 3:06-cv-00072-M Document 74 Filed 08/01/08 Page 3 of 10 PageID 2843
(c) the claims and defenses of the Representative Plaintiffs are typical of the claims of the Settlement Class and Settlement Sub-Classes;
(d) in prosecuting the Litigation and negotiating and entering into the settlement, the Representative Plaintiffs have fairly and adequately protected the interests ofthe Settlement Class and Settlement Sub-Classes, and have fairly and adequately represented the Settlement Class and Settlement Sub-Classes;
(e) in prosecuting the Litigation and negotiating and entering into the Agreement, Settlement Class Counsel are adequate, qualified, experienced and competent to protect the interests of the Settlement Class, and in fact have fairly and adequately represented the interests of the Settlement Class; and
(f) American allegedly has acted or refused to act on grounds that apply generally to the class, so that final injunctive relief is appropriate respecting the Settlement Class as a whole, and the monetary damages to be provided pursuant to the Agreement to the members of the Vacation Accrual Sub-Class and the Sick Leave Accrual Sub-Class are incidental to the injunctive relief. 3. Accordingly, this Court finds that the Settlement Class and Settlement Sub-Classes as proposed in the Agreement meet all of the requirements for certification of a class under Rules 23(a) and 23(b)(2) of the Federal Rules of Civil Procedure. Accordingly, the Court finally certifies a Settlement Class composed of: All persons (including the Representative Plaintiffs) who are or were employed by American as pilots for any length of time from January 1, 2001 through February 29, 2008, inclusive, who have taken, were eligible to take, or may take a military leave of absence due to service in the United States Uniformed Services.

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Case 3:06-cv-00072-M Document 74 Filed 08/01/08 Page 4 of 10 PageID 2844

4. Further, the Court finally certifies a Sick Leave Accrual Sub-Class composed of all Settlement Class Members who did not obtain sick leave benefits during a month in which he or she took a Qualified Leave.
5. Further, the Court finally certifies a Vacation Accrual Sub-Class composed of all Settlement Class Members who did not obtain vacation benefits during a month in which he or she took a Qualified Leave.
6. The Court approves the designation of the Esther G. Lander, John P. Cunningham, and Andrew Braniff, of the U.S. Department of Justice, Civil Rights Division, Employment Litigation Section, as Settlement Class Counsel.
B. Notice to the Settlement Class Members 7. In accordance with the Agreement and the Preliminary Order, Notice was
published to the Members of the Settlement Class and Settlement Sub-Classes who are reasonably identifiable from American's databases by first class mail; a Public Notice was issued by publication on https://www.aapilots.com; and the Settlement Class Counsel established a specific electronic mail inquiry address for the purpose of enabling Settlement Class Members to obtain copies ofthe Notice and to make inquiries with respect to the Agreement. This notification was in full compliance with the notice requirements of due process, federal law, the Constitution of the United States, and any other applicable law.
C. Notice Pursuant to Class Action Fairness Act 8. The Court has previously found, in its order dated May 13, 2008, that
American fully complied with the notice provisions pursuant to the Class Action Fairness Act of 2005, 28 U.S.C. § 1715.
D. Approval of the Agreement 9. The Court finally approves the Agreement and all terms set forth therein

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Case 3:06-cv-00072-M Document 74 Filed 08/01/08 Page 5 of 10 PageID 2845

and finds that the Agreement is, in all respects, fair, reasonable and adequate and in the best interest of all Settlement Class Members, and the Parties are directed to consummate and perform its terms.
10. The injunctive relief to be provided to the Settlement Class and the incidental monetary relief to be provided to the Settlement Sub-Classes contained in the Agreement are hereby approved as fair, reasonable and adequate.
E. Injunctive Relief 11. Accordingly, pursuant to the terms of the Agreement, American is hereby
enjoined as follows: (a) If and when this Final Order becomes Final, without reversal, to
three years thereafter, American shall comply with the provisions ofUSERRA. (b) If and when this Final Order becomes Final, without reversal, to
three years thereafter, American shall provide all currently employed pilots who are in the Uniformed Services and who take a Qualified Leave all vacation and sick leave benefits that would be afforded such pilots if they were not absent for such Qualified Leave.
(c) If and when this Final Order becomes Final, without reversal, to three years thereafter, American shall make the Agreement available to all pilots and flight management personnel on the Internet at https://www.aapilots.com.
(d) If and when this Final Order becomes Final, without reversal, to three years thereafter, American shall, if necessary, modify any agreement, practice, order, or policy currently in place to ensure that all currently employed pilots who are in the Uniformed Services and who take a Qualified Leave are provided all vacation and sick leave benefits that would be afforded them if they

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Case 3:06-cv-00072-M Document 74 Filed 08/01/08 Page 6 of 10 PageID 2846

were not absent for such Qualified Leave. Further, if and when this Final Order becomes Final, without reversal, to three years thereafter, American shall not establish or adopt any agreement, practice, order, or policy unless it ensures that all pilots who are in the Uniformed Services and who take a Qualified Leave are provided all vacation and sick leave benefits that would be afforded such pilots if they were not absent for such Qualified Leave.
(e) If and when this Final Order becomes Final, without reversal, to three years thereafter, and although no such allegations have been raised in this Litigation, American shall continue to not take any action against any future, current, or former employee because he or she has opposed discrimination on the basis of membership in the Uniformed Services, filed a charge of a violation of USERRA, testified, furnished information or participated in any manner in any investigation, proceeding or hearing in connection with any charge or complaint of a violation ofUSERRA, or participated in any manner in connection with the monitoring or implementation of the Agreement, or sought and/or received any monetary and!or non-monetary relief pursuant to the Agreement. 12. Upon American's implementation of all the remedial relief to Representative Plaintiffs and Settlement Class Members in accordance with paragraphs 4.2, 10.1, and the First Amended exhibits of the Agreement (i.e., non-monetary and monetary awards), American shall file with the Court, and serve upon Settlement Class Counsel a final written certification signifying that all remedial relief to Representative Plaintiffs and Settlement Class Members has been implemented. Such final written certification shall set forth and include: the identity, by redacted employee identification number, of each Representative Plaintiff or

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Case 3:06-cv-00072-M Document 74 Filed 08/01/08 Page 7 of 10 PageID 2847

Settlement Class Member who received remedial relief under the Agreement, as well as a description of the monetary and/or non-monetary relief received; the identity, by redacted employee identification number, of each Representative Plaintiff or Settlement Class Member who rejected remedial relief under the Agreement, as well as a description of the monetary and/or non-monetary relief rejected; the amount of monetary relief, if any, that went undistributed and the reasons therefor; and any supporting documents, records and information relating to the implementation of the remedial relief to Representative Plaintiffs or Settlement Class Members under the Agreement that American deems necessary.
13. After the Effective Date and for nine months thereafter, Settlement Class Counsel may make up to three (3) written inquiries upon American regarding the status of distributing the monetary awards and providing the other remedial relief set forth in paragraph 4.2 of the Agreement. Settlement Class Counsel may make such inquiry upon American no more than once every thirty (30) days. Settlement Class Counsel may also make written inquiry upon American during the Injunctive Period regarding the status of the prospective injunctive benefits set forth in paragraph 4.1 of the Agreement. Settlement Class Counsel may make the latter inquiry upon American no more than once every ninety (90) days and no more than three (3) times per year. American shall respond within thirty (30) days to any such written inquiry.
F. Trip Bidding Claim 14. Plaintiff Madson's claim in the Second Amended Complaint concerning
the Trip Bidding Claim has not been certified, and is mooted by a separate settlement agreement between plaintiff Madson and American, and is hereby dismissed with prejudice as to plaintiff Madson refiling same.

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----------------------
Case 3:06-cv-00072-M Document 74 Filed 08/01/08 Page 8 of 10 PageID 2848
G. Objections to the Proposed Settlement 15. Any and all objections to the Agreement have been considered and are
hereby found to be without merit and overruled. H. Release and Dismissal 16. All Settlement Class Members shall be deemed to have released all of
their Released Claims, and shall be forever barred from prosecuting any action against the Released Persons based on or arising out of the Released Claims.
17. American and the Related Parties are hereby released and discharged from the Released Claims.
I. Dismissal 18. The Court hereby dismisses all claims as against American in the
Litigation without prejudice, with the exception ofplaintiffMadson's Trip Bidding Claim, which is dismissed with prejudice as to plaintiff Madson refiling same.
J. Appeal 19. This Final Order is a final decision and is appealable pursuant to 28 U.S.C.
§ 1291. K. Continuing Jurisdiction 20. The Court hereby reserves jurisdiction over all matters relating to the
modification, interpretation, implementation, effectuation, enforcement, and administration of the settlement as set forth in the Agreement, which is hereby incorporated herein by reference, and the Final Order, which jurisdiction may be called upon by filing a motion to enforce for alleged failure to comply with their terms.

DAI:\517488\05\B3@_05!.00C\14013.0111

Page 8

Case 3:06-cv-00072-M Document 74 Filed 08/01/08 Page 9 of 10 PageID 2849
L. Attorneys' Fees, Costs 21. Each party shall bear its own attorneys' fees and costs.
M. Material Modification 22. In the event that the terms of the Agreement or this Final Order are
materially modified upon any appeal, either Party may seek to set aside this Final Order upon application to this Court within twenty (20) days of such material modification. SO ORDERED. DATED:
-------/

DAI :\517488\05\B3@_05!.00C\14013.0111

Page9

Case 3:06-cv-00072-M Document 74 Filed 08/01/08 Page 10 of 10 PageID 2850
CASE CLOSED
CASE NUMBER: 3~.06-ev- 67.b ~
DATE: _ _--'-"O~o-r-:=-/o~/;_D_?_
X TRIAL: YES _ _ NO •

 
 Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 1 of 22 WEIL, GOTSHAL & MANGES LL P
200 CRESCENT COURT SUITE 300
DALLAS . TEXAS 7520 1 (214) 746 .7700
FAX : (214) 746-777 7

WRITER'S DIRECT LINE
(214) 746-7847 m ichelle .harcmaon@well .co m

February 25, 200 9

PageID 2980
AUSTIN BOSTON BUDAPEST FRANKFURT HONG KON G HOUSTON LONDON
MIAMI MUNICH NEW YORK
PARI S PRAGUE PROVIDENCE SHANGHA I SILICON VALLEY WARSAW WASHINGTON, D.C .

BY FCF
The Honorable Barbara M .G. Lynn United States District Court 1100 Commerce Street, Room 1572 Dallas, Texas 7524 2
Re : Final Certification : Mark Woodall, et aI v. American Airlines, Inc. ("American'), Case No . 3-06CV-0072M .
Dear Judge Lynn :
Pursuant to Paragraph 12 of the Final Order entered by this Court on August 1, 2008, American hereby files this final certification (the "Final Certification") signifying that the remedial relief to the Settlement Class Members has been distributed . (See Final Order at 1112.)
A. American Has Implemented All Required Injunctive Relief.
The injunctive relief required by the Final Order has been fully implemented . American was not required by the Agreement or the Final Order to implement any injunctive relief until after the Final Order became final without reversal or modification in any material respect, which date was on September 1, 2008 . (See Final Order ¶ 1 1 ; see also Agmt. T 2 .6, 2 .9, 4.1, 8 .2 .) On its own, effective as of March 1, 2008, American nevertheless began providing all currently employed pilots who are in the Uniformed Services and who take a Qualified Leave after that date all vacation an d
1 Unless otherwise defined, all capitalized terms used herein have the same meaning as defined in the Settlement Agreement, dated April 16, 2008, and First Amendment thereto, dated July 21, 2008 (collectively, the "Agreement") on file with the Court .

Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 2 of 22 PageID 2981
WEIL, GOTSHAL & MANGES LL P
The Honorable Barbara M.G. Lynn February 25, 200 9 Page 2
sick leave benefits afforded to Settlement Class Members under the Agreement and Final Order .
B. American Has Distributed the Remedial Relief.
In accordance with Paragraph 12 of the Final Order, attached hereto and incorporated herein as Exhibits A and B are tables showing the identity, by redacted employee identification number, of each Settlement Class Member who received remedial relief under the Agreement and Final Order, as well as the description of the monetary and/or non-monetary relief received . Exhibit A details the non-monetary relief provided, and Exhibit B details the monetary relief provided .
By October 6, 2008 (which was within sixty days of the Final Order becoming Final without reversal or modification), non-monetary relief (i .e., credited sick leave) was distributed to each relevant Settlement Class Member pursuant to Paragraph 4.2 of the Agreement and Paragraph 9 of the Final Order . (See Ex. A. )
Also by October 6, 2008 (which is within 60 days of the Final Order becoming Final without reversal or modification), $347,905 .98, constituting the monetary relief provided under the Agreement and Final Order, was distributed to each relevant Settlement Class Member pursuant to Paragraphs 4 .2 and 10 .1 of the Agreement and Paragraph 9 of the Final Order . (See Ex. B. )
No Settlement Class Member rejected the monetary relief provided to him or her pursuant to the Agreement and the Final Order . However, if any monetary relief is returned at a later date, American will notify the Court and donate such sums to Snowball Express, as provided by the Agreement and the Final Order .
As demonstrated above, the swiftness and care with which American has implemented the relief required by the Agreement and Final Order underscores its dedication to its pilots and respect for members in the Uniformed Services .
Respectfully submitted ,
Enclosure

Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 3 of 22 PageID 2982 WEIL, GOTSHAL& MAN GES LLP
The Honorable Barbara M.G. Lynn February 25, 2009 Page 3
cc : Esther Lander, Esq . (by email and w/ enclosures) Andrew Braniff, Esq . (by email and w/ enclosures) Ralph 1 . Miller, Esq . (w/ enclosures) Margaret H. Allen, Esq . (w/ enclosures)

Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 4 of 22 PageID 2983
EXHIBIT A

Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 5 of 22 PageID 2984

Non-Monetary Compensation . Credited Sick Leav e

Redacted Pilot Identification Number
X931 X3659 X7152 X7300 X7445 X0303 X8127 X2164 X2338 X2396 X2514 X7823 X3416 XX7446 XX7467 XX7528 XX7656 XX8243 XX3461 XX8310 XX8325 XX8375 XX8494 XX8525 XX8540 XX8607 XX3526 XX3570 XX3586 XX3659 XX8814 XX8866 XX8944 XX9076 XX9132 XX9161 XX9197 XX8697

Hours of Sick Leav e Credite d
11 . 7 5 6.7 5 5 6.7 6.7 5 5 6.7 5 5 5 10 6. 7 5 5 6. 7 10 6. 7 6.7 10
11 . 7 5 6.7 5 5 6.7 15 6.7 5
13 . 4 6.7 55 11 . 7 6 .7 6 .7 5

Page 1

Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 6 of 22 PageID 2985

Non-Monetary Compensation : Credited Sick Leav e

Redacted Pilot Identification Number
XX8901 XX8908
XX8970 XX9056 XX9062 XX9099 XX2402 XX2420 XX2543 XX2551 XX2619 XX2626 XX2748
XX2780 XX2853 XX2938 XX2946 XX2954 XX2956 XX2962 XX3005 XX3042
XX1730 XX4451 XX4456 XX4524 XX4543 XX4865 XX4631 XX4664 XX4678 XX4705 XX4764 XX4766
XX4774 XX4787 XX4835 XX4957

Hours of Sick Leave Credite d
6.7 5 5 5 5 5 6.7 5 6. 7 25 . 1 6. 7 5 6.7
5 6.7 5
5 10 5 11 . 7 5 5
5 6. 7
5 6, 7 6. 7 11, 7 5 10 6, 7 18 . 4 5 36 . 7
5 5 6.7 6 .7

Page 2

Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 7 of 22 PageID 2986

Non-Monetary Compensation : Credited Sick Leav e

Redacted Pilot Identification Number
XX4720 . XX4748 XX4761 XX4819 XX4830 XX4865 XX4917 XX4956 XX4997 XX3658 XX6853 XX1992 XX2003 XX2053 XX2066 XX2067 XX 1872 XX2229 XX7984 XX7992 XX7998 XX8001 XX8010 XX8015 XX8020 XX8058 XX8079 XX8097 XX8107 XX8108 XX8136 XX8171 XX8177 XX8206 XX8220 XX8221 XX8226 XX8227

Hours of Sick Leave Credited
5 5 15 20 16 . 7 28 .4 5 5 6 .7 11, 7 6 .7 5 11 . 7 11 . 7 6. 7 11 . 7 6. 7 11 . 7 5 5 6. 7 5 13 . 4 5 5 5 5 6.7 5 5 15 15 5 15 5 6.7 20 5

Page 3

Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 8 of 22 PageID 2987

Non-Monetary Compensation : Credited Sick Leav e

Redacted Pilot Identification Number
XX8238 XX8264 XX8270 XX8289 XX8298 XX8319 XX8320 XX8327 XX8340 XX8347 XX8352
XX8353 XX8355 XX8367 XX8373 XX8381 XX8382 XX8385 XX8424 XX8431 XX8432 XX8439 XX8450 XX8457 XX8461 XX8465 XX8487 XX3419 XX3441 XX2362 XX2366 XX2722 XX5174 XX5212 XX5231 XX5232 XX5238 XX5247

Hours of Sick Leav e Credite d
6.7 10 15 6. 7 5 20 5 6.7 20 10 5
15 6 .7 10 5 5 5 5 6, 7 21 . 7 5 6, 7 10 31 . 7 10 6 .7 20 5 5 5 10
6.7 5 16 . 7 5 11 . 7 6 .7 6 .7

Page 4

Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 9 of 22 PageID 2988

Non-Monetary Compensation : Credited Sick Leave

Redacted Pilot Identification Number
XX5252 XX5260 XX5261 XX5267 XX5276 XX5278 XX5280 XX5301 XX5303 XX5305 XX5309 XX5311 XX5323 XX5327 XX5328 XX5347 XX5349 XX5364 XX5365 XX5375 XX5376 XX5389 XX5400 XX5403 XX5404 XX5415 XX5434 XX5443
XX5465 XX5471 XX5476 XX5480 XX5482 XX5506
XX5513 XX5524 XX5525 XX5526

Hours of Sick Leave Credited
5 13 . 4
5 6.7 11 . 7 5 16 . 7 6 .7 10 5 5 6.7 5 18 . 4 6. 7 5 5 5 23 . 4 11 . 7 5 16 . 7 5 6 .7 6 .7 6 .7 6, 7 5
5 5 6. 7 5 5 5 5 15
6.7 11 .7

Page 5

Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 10 of 22 PageID 2989

Non-Monetary Compensation : Credited Sick Leav e

Redacted Pilot Identification Number
XX5528 XX5529 XX5532 XX5538 XX5545 XX5551 XX5558 XX5567 XX5569 XX5570 XX5581 XX5601 XX5612 XX5631 XX5632 XX5636 XX5642 XX5657 XX5663 XX5670 XX5676 XX5677 XX5679 XX5686 XX5687 XX5693 XX5695 XX5715 XX5723 XX5727 XX5731 XX5733 XX5813 XX5822 XX5851 XX5857 XX5867 XX5878

Mows of Sick Leave Credite d
6 .7 5
5 5 5 5 5 6.7 6, 7 21 . 7 20 5 5 10 5 5 5 6.7 5
10 5
10 20 10 25 6 .7 15 5 15 11, 7 5 5 10 11, 7 5 5 5 5

Page 6

Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 11 of 22 PageID 2990

Non-Monetary Compensation ; Credited Sick Leave

Redacted Pilot Identification Number
XX5879 XX5880 XX5906 XX5930 XX5942 XX5960 XX5961 XX5962 XX5964 XX5994
XX5995 XX5997 XX6004
XX6010 XX6015 XX6022 XX6040 XX6058 XX6125 XX6139 XX6142 XX6156 XX6169 XX6171 XX6185 XX0632 XX4101 XX4111 XX4123 XX4152 XX4158 XX4186 XX4187 XX4207 XX4214
XX4221 XX4223 XX4231

Hours of Sick Leave Credited
11 . 7 5 6.7 6.7 5
11 . 7 6 .7 6 .7 5 6.7
5 6.7 6.7
5 13 . 4 11 . 7 13 . 4 6. 7 6.7 11 . 7
5 6.7 5 6.7 5 5 16 . 7 10 6.7 6. 7 6. 7 5 13 . 4 6. 7 6. 7
5 6. 7 6 .7

Page 7

Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 12 of 22 PageID 2991

Non-Monetary Compensation : Credited Sick Leave

Redacted Pilot Identification Number
XX4233 XX4235 XX4255 XX4271 XX4310 XX4363 XX4370 XX4386 XX4402 XX4415 XX4417 XX4432 XX4508 XX4533 XX4546 XX4660 XX4669 XX0403 XX0556 XX0576 XX0794 XX1808
TOTAL

Hours of Sick Leave Credited
6.7 6.7 11 . 7 20 . 1 6 .7 13 .4 5 6 .7 13 .4 6 .7 6 .7 5 6.7 11 . 7 6.7 6.7 6.7 5 5 15 6.7 10
2436 .6

Page 8

Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 13 of 22 PageID 2992
EXHIBIT B

Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 14 of 22 PageID 2993

Moneta ry Compensation Provided to Members of the Sub-Classe s

Redacted Pilot Identificatio n
Number
X931 X3659 X7152 X7300 X7445 X0303 X2077 X8127 X2164 X2396 XX7446 XX7467 XX7528 XX7656 XX8310 XX8325 XX8375 XX8494 XX8525 XX8573 XX8607 XX3526 XX3586 XX8814 XX8866 XX8944 XX9076 XX9132 XX9197 XX8697 XX8901 XX8970 XX9056 XX9062 XX9099 XX2402 XX2420 XX2543 XX2551 XX2619 XX2626 XX2724 XX2748

Total Moneta ry Copensatio n Provided
$3,843 .58 $1,214 .05 $1,633 .06 $1,049 .40 $1,277 .64 $1,776 .13 $1,135.31 $1,368 .30 $1,073 .98 $1,415 .87 $1,188 .36 $2,614 .50 $1,200 .87 $1,172,25 $1,362 .93 $3,038 .18 $4,417 .82 $2,626 .51 $897 .06 $1,76418 $1,127 .92 $1,006 .13 $1,066 .47 $882 .79 $1,376,53 $1,733 .60 $8,946 .38 $3,046 .72 $1,785 .11 $1,056 .79 $1,238 .26 $1,020 .23 $810.89 $888.68 $881 .41 $1,234 .14 $794.40 $2,231 .88 $6,507 .49 $1,941 .88 $922 .45 $435.44 $868 . 36

Moneta ry Compensatio n Provided for Vacatio n Accrual Sub-Class
$3,843 .5 8 $1,214 .0 5 $1,63106 $1,049 .40 $1,277 .64 $1,776 .1 3 $1,135 .3 1 $1,368 .30 $1,073 .98 $1,415 .87 $1,188 .36 $2,614 .50 $1,200 .8 7 $1,172 .2 5 $1,362,9 3 $3,038 .1 8 $3,803 .38 $2,626 .5 1 $897 .06 $1,162 .85 $1,127 .9 2 $1,006 .1 3 $1,066 .4 7 $882 .7 9 $1,376 .5 3 $1,733 .6 0 $8,946 .3 8 $3,046 .7 2 $1,785,1 1 $1,056 .79 $1,238 .2 6 $1,020 .2 3 $810 .8 9 $888 .68 $881 .4 1 $1,234 .1 4 $794 .40 $2,231 .8 8 $6,507 .4 9 $1,941 .8 8 $922 .45
$868 .36

Moneta ry Compensation Provided for Sick Leave
Accrual Sub-Clas s
$614 .44 $591 .33
$435 .44

Page 1

Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 15 of 22 PageID 2994

Monetary Compensation Provided to Members of the Sub-Classes

Redacted Pilot Identification
Number
XX2938 XX2954 XX2956 XX2962 XX3005 XX3042 W730 XX4451 XX4456 XX4524 XX4543 XX4565 XX4631 XX4664 XX4705 XX4764 XX4766 XX4774 XX4787 XX4835 XX4897 XX4957 XX4720 XX4748 XX4761 XX4819 XX4830 XX4865 XX4956 XX4997 XX3658 XX6853 XX 1992 XX2003 XX 1872 XX2229 XX7979 XX7984 XX7992 XX7998 XX8001 XX8010 XX8015

Total Moneta ry Copensation Provided
$942 .19 $1,691 .65 $942 .19 $1,891 .36 $863 .15 $937 .85 $751 .09 $2,128 .75 $87970 $927 .81 $1,158 .02 $912 .85 $83439 $1,77337 $4,339 .06 $873 .65 $6,628 .27 $735 .36 $860,08 $1,309 .87 $3,936 .82 $1,933 .93
$775 .14 $748 .42 $2,355 .17 $3,705 .69 $2,848 .46 $5,842,35 $788 .91 $1,900 .19 $378,51 $444.76 $862.18 $538 .85 $430.96 $1,013 .45 $978.67 $793.39 $847.34 $954.98 $420.32 $929.20 $426.11

Moneta ry Compensation Provided for Vacation Accrual Sub-Class
$942,1 9 $1,691 .6 5 $942 .1 9 $1,891 .3 6 $863 .1 5 $937 .8 5 $751 .0 9 $2,128 .7 5 $879 .7 0 $927 .8 1 $1,158 .0 2 $912,8 5 $834 .3 9 $1,773 .3 7 $4,339,0 6 $873 .6 5 $6,628 .2 7 $735 .3 6 $860 .0 8 $1,309 .8 7 $2,635 .20 $1,933 .9 3 $775 .1 4 $748,42 $2,355 .1 7 $3,705,6 9 $2,848 .4 6 $5,842,3 5 $788 .9 1 $1,9001 9 $378 .5 1 $444 .76 $862 .1 8 $538 .8 5 $430 .96 $1,013 .4 5 $978 .6 7 $793 .3 9 $847 .3 4 $954 .9 8 $420 .3 2 $929 .2 0 $426 .11

Moneta ry Compensation Provided for Sick Leave
Accrual Sub-Clas s
$1,3€}1 .6 2

Wage 2

Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 16 of 22 PageID 2995

Monetary Compensation Provided to Members of the Sub-Classe s

Redacted Pilot Identification
Number
XX8020 XX8058 XX8079 XX8097 XX8107 XX8108 XX8111 XX8136 XX8171 XX8179 XX8195 XX8206 XX8220 XX8221 XX8226 XX8227 XX8238 XX8241 XX8264 XX8270 XX8289 XX8298 XX8319 XX8320 XX8321 XX8325 XX8340 XX8347 XX8352 XX8353 XX8355 XX8358 XX8367 XX8373 XX8377 XX8381 XX8385 XX8424 XX8431 XX8439 XX8450 XX8457 XX8461

Total Moneta ry Copensation Provided
$372 .49 $714.23 $803.46 $35231 $430.64 $379.86 $375.11 $1,459 .79 $1,819 .46 $2,107,08 $833.23 $1,227 .97 $562.74 $841 .65 $1,856B3 $800.16 $412.62 $1,853 .73 $1,160 .03 $1,759 .77 $405.51 $377.76 $1,476,36 $37610 $6,594 .35 $782.98 $2,432 .26 $1,367 .67 $822 .84 $1,503 .96 $856.50 $841 .65 $1,105 .54 $380.10 $1,265 .43 $298 .30 $370.10 $506 .79 $1,112,42 $340 .45 $369 .82 $2,748 .57 $838 .78

Moneta ry Compensation Provided for Vacation Accrual Sub-Class
$372 .49 $714 .23 $803,46 $352 .3 1 $430 .64 $379 .86 $375 .1 1 $1,459 .7 9 $1,819 .4 6 $1,246 .60 $469 .75 $1,227 .9 7 $562 .74 $841 .65 $1,856 .6 3 $800 .1 6 $412 .62 $1,853 .7 3 $1,160 .0 3 $1,759 .7 7 $405 .5 1 $377 .7 6 $1,476 .3 6 $376 .1 0 $4,116 .74 $782 .98 $2,432 .26 $1,367 .6 7 $822 .8 4 $1,503 .96 $856 .5 0 $841 .6 5 $1,105.54 $380 .1 0 $850 .61 $298 .3 0 $370.1 0 $506 .7 9 $1,112 .42 $340 .4 5 $369 .8 2 $2,748 .57 $838 .78

Moneta ry Compensatio n Provided for Sick Leav e
Accrual Sub-Clas s
$860 .4 8 $363 .4 8
$2,477 .6 1
$414 .8 2

Page 3

Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 17 of 22 PageID 2996

Monetary Compensation Provided to Members of the Sub-Classes

Redacted Pilot Identification
Dumber
XX8487 XX8492 XX3074 XX3441 XX2362 XX2721 XX2722 XX2726 XX2730 XX5174 XX5212 XX5231 XX5232 XX5238 XX5247 XX5252 XX5260 XX5261 XX5267 XX5276 XX5278 XX5280 XX5301 XX5303 XX5305 XX5311 XX5327 XX5347 XX5348 XX5349 XX5365 XX5366 XX5375 XX5376 XX5377 XX5389 XX5400 XX5404 XX5415 XX5434 XX5443 XX5464 XX5476

Total Monetary Copensation Provided
$2,271 .96 $1,452 .99 $1,119 .25 $380 .10 $681 .37 $342 .46 $468 .19 $341 .67 $360 .00 $369 .82 $1,740 .32 $720 .80 $1,097,44 $831 .45 $747 .56 $714 .93 $795 .67 $745 .67 $373 .99 $1,649 .69 $416 .01 $2,083 .59 $371 .57 $368 .03 $361 .65 $399 .54 $964 .64 $366.72 $917.71 $36624 $2,179 .75 $2,087-04 $928 .81 $365.93 $852 .10 $1,403 .99 $411 .42 $474 .29 $833 .04 $836 .02 $703 .19 $418 .99 $455,79

Monetary Compensation Provided for Vacation Accrual Sub-Class
$2,271 .9 6 $746 .64 $1,119 .2 5 $380 .1 0 $681 .3 7
$4681 9 $341,6 7 $360.0 0 $369 .8 2 $1,740 .3 2 $720 .8 0 $1,097 .44 $831 .4 5 $747 .56 $714 .9 3 $795,6 7 $745 .6 7 $373,99 $1,649 .6 9 $416 .0 1 $2,0815 9 $371 .57 $368 .03 $361 .65 $399 .54 $964 .6 4 $366 .7 2 $506 .79 $366 .2 4 $2,179 .7 5 $1,30162 $928 .8 1 $365 .9 3 $388 .53 $1,403 .99 $411 .4 2 $474 .2 9 $833 .04 $836 .0 2 $703 .1 9 $418 .99 $455 .79

Moneta ry Compensatio n Provided for Sick Leave
Accrual Sub-Clas s $706 .35 $342 .4 6
$410 .92 $783 .42 $463 .5 7

Page 4

Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 18 of 22 PageID 2997

Monetary Compensation Provided to Members of the Sub-Classes

Redacted Pilot Identification
Dumber
XX5480 XX5482 XX5506 XX5512 XX5524 XX5525 XX5526 XX5528 XX5529 XX5532 XX5534 XX5545 XX5551 XX5558 XX5567 XX5569 XX5570 XX5581 XX5601 XX5631 XX5632 XX5642 XX5653 XX5657 XX5663 XX5670 XX5671 XX5676 XX5677 XX5679 XX5686 XX5687 XX5693 XX5695 XX5699 XX5723 XX5727 XX5728 XX5731 XX5733 XX5741 XX5747 XX5751

Total Moneta ry Copensation Provided
$364 .20 $688 .62 $360 .40 $438 .95 $1,049 .54 $793 .74 $397 .02 $375 .48 $350 .84 $356 .61 $843 .21 $390 .22 $693 .47 $691 .08 $449 .49 $444 .76 $1,799 .83 $781 .49 $368 .51 $389 .70 $774 .24 $418 .72 $345 .47 $40109 $359 .85 $677 .49 $386 .42 $691 .05 $1,215 .76 $1,176 .61 $349 .00 $1,08410 $455 .79 $385 .84 $1,553 .06 $774 .26 $832 .29 $1,342 .40 $394 .63 $370 .20 $342 .79 $932 .59 $958 .95

Monetary Compensation Provided for Vacation Accrual Sub-Class
$364 .20 $688 .62 $360 .40 $438 .95 $1,049 .54 $793 .74 $397 .02 $375 .48 $350 .84 $356 .6 1 $843 .2 1 $39022 $693 .47 $691 .08 $449 .49 $444,7 6 $1,799,8 3 $781 .49 $368 .5 1 $389 .7 0 $774 .2 4 $418 .7 2 $345 .4 7 $403 .09 $359 .8 5 $677 .4 9 $386 .4 2 $691 .0 5 $1,215 .7 6 $1,176 .6 1 $349 .0 0 $1,084.1 0 $455 .7 9 $385 .8 4 $1,553 .0 6 $774 .2 6 $832 .2 9 $342 .79 $394 .6 3 $370 .2 0 $342 .7 9 $932 .5 9 $958 .95

Moneta ry Compensatio n Provided for Sick Leav e
Accrual Sub-Glass
$999 .6 1

Page 5

Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 19 of 22 PageID 2998

Monetary Compensation Provided to Members of the Sub -Classe s

Redacted Pilot Identification
Number
XX5762 XX5776 XX5779 XX5800 XX5805 XX5813 XX5814 XX5818 XX5821 XX5822 XX5840 XX5851 XX5857 XX5867 XX5873 XX5878 XX5879 XX5880 XX5891 XX5905 XX5906 XX5930 XX6942 XX5961 XX5962 XX5964 XX5994 XX5995 XX6004 XX6010 XX6015 XX6021 XX6023 XX6028 XX6038 XX6040 XX6073 XX6118 XX6132 XX6133 XX6139 XX6142 XX6144

Total Monetary Co pen sa ti on Provi ded
$912 .47 $347 .49 $755 .35 $843 .86 $503 .20 $1,397,46 $340 .52 $50619 $2,768 .27 $715 .58 $345 .03 $448 .28 $345,47 $446 .73 $1,855 .56 $683 .78 $715 .70 $351 .84 $394 .64 $785 .60 $432,50 $489 .40 $356 .54 $444 .76 $438.61 $362.35 $328.87 $353.05 $37532 $352 .82 $853.60 $1,869 .63 $398 .95 $403 .19 $369 .99 $388 .15 $650 .78 $313 .07 $802 .17 $2,36145 $313,07 $347 .33 $1,623 .32

Monetary Compensation Provided for Vacation Accrual Sub-Class
$501 .47
$755 .35 $8418 6 $503 .2 0 $1,397 .4 6 $340 .5 2 $506 .7 9 $2,768 .2 7 $715 .5 8 $345 .0 3 $448 .2 8 $345 .4 7 $446.7 3 $1,855 .56 $683 .7 8 $715 .7 0 $351 .84
$785 .60 $432 .50 $489 .40 $356 .54 $444 .76 $438 .6 1 $362 .35 $328 .8 7 $353 .05 $375 .3 2 $352 .8 2 $853 .6 0 $1,869 .6 3 $398 .9 5 $4031 9 $369 .9 9 $388 .1 5 $650 .7 8 $313 .0 7 $802 .1 7 $2,363 .45 $313 .0 7 $347 .3 3 $738 .83

Monetary Compensatio n Provided for Sick Leave
Accrual Sub-Clas s $411, 0 0 $347 .4 9
$394 .6 4
$884 .49

Page 6

Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 20 of 22 PageID 2999

Monetary Compensation Provided to Members of the Sub -Classes

Redacted Pilot Identification
Number
XX6169 XX6171 XX6174 XX6177 XX6185 XX6187 XX0632 XX4101 XX4111 XX4114 XX4117 XX4121 XX4122 XX4126 XX4140 XX4145 XX4150 XX4152 XX4154 XX4158 XX4159 XX4186 XX4187 XX4191 XX4195 XX4198 XX4207 XX4214 XX4216 XX4221 XX4223 XX4225 XX4231 XX4232 XX4241 XX4243 XX4255 XX4264 XX4271 XX4272 XX4277 XX4280 XX4320

Total Monetary Copensation Provided
$462 .57 $444 .76 $403 .28 $827,79 $339 .50 $679 .23 $388 .83 $1,268 .41 $313 .07 $438 .61 $699 .81 $497 .91 $506 .75 $1,090 .98 $435 .55 $368 .12 $494 .42 $492 .85 $834 .97 $44519 $1,352,05 $398 .95 $801 .64 $442 .67 $883 .36 $497,30 $434 .00 $434 .00 $400 .46 $368 .12 $340 .58 $2,071 .68 $479 .15 $78624 $413 .19 $408 .84 $438.6 1 $490.97 $1,010 .21 $470.73 $783.68 $3,342 .90 $310.25

Moneta ry Compensation Provided for Vacation Accrual Sub-Class
$462 .5 7 $444 .76 $403 .28 $416 .07 $339 .50 $342 .88 $388 .83 $1,268,4 1 $313 .07 $438 .6 1 $699 .8 1 $497 .9 1 $506 .7 5 $1,090 .9 8 $435 .5 5 $368 .1 2 $4944 2 $492 .8 5 $834 .9 7 $4457 9 $1,352 .0 5 $398 .9 5 $801 .6 4 $442 .6 7 $8813 6 $4973 0 $434 .0 0 $434,00 $400 .46 $368,1 2 $340 .58 $1,092 .17 $479 .1 5 $786 .2 4 $413 .1 9 $408,8 4 $438 .6 1 $490 .9 7 $1,010 .2 1 $470 .7 3 $78 1 6 8 $3,342 .90 $310 .25

Monetary Compensatio n Provided for Sick Leav e
Accrual Sub-Class $411 .7 2 $336 .3 5
$979 .5 1

Page 7

Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 21 of 22 PageID 3000

Monetary Compensation Provided to Members of the Sub-Classes

Redacted Pilot Identification
Number
XX4330 XX4343 XX4346 XX4357 XX4363 XX4366 XX4370 XX4383 XX4386 XX4391 XX4398 XX4415 XX4417 XX4419 XX4420 XX4432 XX4435 XX4440 XX4447 XX4476 XX4499 XX4502 XX4508 XX4516 XX4517 XX4527 XX4533 XX4536 XX4546 XX4550 XX4575 XX4588 XX4629 XX4660 XX4713 XX4714 XX4723 XX4727 XX4744 XX4749 XX4781 XX4782 XX48.15

Total Moneta ry Copensation Provided
$406 .16 $320 .78 $860 .43 $926 .75 $352 .51 $799 .31 $396 .16 $404 .00 $352 .51 $328 .98 $309 .70 $432 .50 $454 .56 $408 .84 $1,155 .69 $456 .12 $406 .03 $399 .08 $638.26 $2,257 .83 $314.07 $37628 $362 .59 $307.56 $148 .65 $381 .11 $372 .03 $1,031 .53 $327 .81 $362 .59 $339 .18 $148 .65 $437 .10 $360 .05 $147 .09 $147 .09 $147 .61 $147 .09 $147,09 $147 .09 $147 .09 $147,09 $147 .09

Moneta ry Compensation Provided for Vacation Accrual Sub-Class
$406 .1 6 $320 .7 8 $860 .4 3 $9267 5 $352 .5 1 $799 .3 1 $396 .1 6 $404 .00 $352 .5 1 $328 .98 $309,70 $432 .5 0 $454 .5 6 $408 .8 4 $1,155 .6 9 $456 .1 2 $406 .0 3 $399 .0 8 $492 .72 $1,197 .05 $314 .0 7 $376,28 $362 .59
$148,65 $381 .1 1 $372 .03 $1,031 .5 3 $327 .8 1 $362 .5 9 $339 .1 8 $148 .6 5 $437 .1 0 $360 .0 5 $147 .09 $147 .09 $147 .6 1 $147 .0 9 $147,0 9 $147 .0 9 $147 .0 9 $147 .0 9 $147 .09

Moneta ry Compensation Provided for Sick Leave
Accrual Sub-Clas s
$145,54 $1,060,7 8 $307 .56

Page 8

Case 3:06-cv-00072-M Document 78 Filed 02/25/09 Page 22 of 22 PageID 3001

Moneta ry Compensation Provided to Members of the Sub-Classe s

Redacted Pilot Identification
Number
XX5177 XX0259 XX0372 XX0403 XX0556 XX0576 XX 1808 XX 1860 W940 XX4730
TOTAL

Total Monetary Copensation Provided
$1,898 .00 $3,958 .25 $897 .088 $1,697 .92 $1,209,19 $3,879 .61 $1,072 .02 $447 .03 $450 .13 $430 .96
$347,905 .98

Monetary Compensation Provided for Vacation Accrual Sub -Class
$1,898 .00 $3,958 .25 $897 .08 $1,697 .92 $1,209 .1 9 $3,879 .6 1 $1,072 .0 2 $447 .03 $450 .1 3 $430 .9 6
$331,861 .35

Monetary Compensatio n Provided for Sick Leav e
Accrual Sub-Class
$16,044 .63

Page 9

 
 Case: 3:06­cv­72 As of: 10/16/2012 01:21 AM CDT 1 of 10
CLOSED,ECF,JURY
U.S. District Court Northern District of Texas (Dallas) CIVIL DOCKET FOR CASE #: 3:06−cv−00072−M

Woodall et al v. American Airlines Inc Assigned to: Judge Barbara M.G. Lynn Cause: Right to re−employment of inducted persons
Plaintiff

Date Filed: 01/12/2006 Date Terminated: 08/01/2008 Jury Demand: Both Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: U.S. Government Plaintiff

Mark Woodall

represented by David J Palmer US Department of Justice Civil Rights Division 950 Pennsylvania Ave NW Room 4036 Washington, DC 20530 202/514−3831 Fax: 202/514−1005 LEAD ATTORNEY ATTORNEY TO BE NOTICED Bar Status: Government Attorney

Andrew Braniff US Department of Justice Civil Rights Division 950 Pennsylvania Ave NW Room 4036 Washington, DC 20530 202/514−9229 Fax: 202/514−1005 Email: andrew.braniff@usdoj.gov ATTORNEY TO BE NOTICED Bar Status: Government Attorney

Christine M Roth US Department of Justice Employment Litigation Section − PHB 950 Pennsylvania Ave NW Washington, DC 20530 202/514−2375 Fax: 202/514−1005 Email: christine.roth@usdoj.gov TERMINATED: 07/30/2007 Bar Status: Government Attorney

Esther G Tamburo US Department of Justice − Civil Rights Division Employment Litigation Section − PHB 950 Pennsylvania Ave NW Room 4036 Washington, DC 20530 202/616−1578 Fax: 202/514−1005 Email: esther.tamburo@usdoj.gov ATTORNEY TO BE NOTICED Bar Status: Government Attorney

John Cunningham US Department of Justice Employment Litigation Section − PHB 950 Pennsylvania Ave NW Washington, DC 20530 202/305−4195

Case: 3:06­cv­72 As of: 10/16/2012 01:21 AM CDT 2 of 10

Fax: 202/514−1005 Email: john.cunningham4@usdoj.gov ATTORNEY TO BE NOTICED Bar Status: Government Attorney

John M Gadzichowski US Attorney's Office − Civil Rights Div/Emp Lit Section PO Box 65968 Washington, DC 20035−5968 202/353−1929 Bar Status: Government Attorney

Wan J Kim US Department of Justice Civil Rights Division 950 Pennsylvania Ave NW Room 4036 Washington, DC 20530 202/514−3831 Fax: 202/514−1005 Bar Status: Government Attorney

Plaintiff Michael P McMahon

represented by David J Palmer (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED Bar Status: Government Attorney

Andrew Braniff (See above for address) ATTORNEY TO BE NOTICED Bar Status: Government Attorney

Christine M Roth (See above for address) TERMINATED: 07/30/2007 Bar Status: Government Attorney

Esther G Tamburo (See above for address) ATTORNEY TO BE NOTICED Bar Status: Government Attorney

John Cunningham (See above for address) ATTORNEY TO BE NOTICED Bar Status: Government Attorney

John M Gadzichowski (See above for address) Bar Status: Government Attorney

Wan J Kim (See above for address) Bar Status: Government Attorney

Plaintiff
Paul J Madson Individually and on behalf of a class of all similarly situated persons

represented by David J Palmer (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED Bar Status: Government Attorney

Case: 3:06­cv­72 As of: 10/16/2012 01:21 AM CDT 3 of 10
Andrew Braniff (See above for address) ATTORNEY TO BE NOTICED Bar Status: Government Attorney
Christine M Roth (See above for address) TERMINATED: 07/30/2007 Bar Status: Government Attorney
Esther G Tamburo (See above for address) ATTORNEY TO BE NOTICED Bar Status: Government Attorney
John Cunningham (See above for address) ATTORNEY TO BE NOTICED Bar Status: Government Attorney
John M Gadzichowski (See above for address) Bar Status: Government Attorney
Wan J Kim (See above for address) Bar Status: Government Attorney

V. Defendant American Airlines Inc

represented by Ralph I Miller Weil Gotshal &Manges 200 Crescent Court Suite 300 Dallas, TX 75201 214/746−7756 Fax: 214/746−7700 FAX Email: ralph.miller@weil.com LEAD ATTORNEY ATTORNEY TO BE NOTICED Bar Status: Admitted/In Good Standing
Erin Eckols Weil Gotshal &Manges 200 Crescent Court Suite 300 Dallas, TX 75201 214/746−7734 Fax: 214/746−7777 Bar Status: Admitted/In Good Standing
Margaret Hope Allen Weil Gotshal &Manges 200 Crescent Court Suite 300 Dallas, TX 75201 214/746−8137 Fax: 214/746−7777 Email: margaret.allen@weil.com ATTORNEY TO BE NOTICED Bar Status: Admitted/In Good Standing
Michelle LeGrand Hartmann

Case: 3:06­cv­72 As of: 10/16/2012 01:21 AM CDT 4 of 10
Weil Gotshal &Manges 200 Crescent Court Suite 300 Dallas, TX 75201 214/746−7700 Email: michelle.hartmann@weil.com ATTORNEY TO BE NOTICED Bar Status: Admitted/In Good Standing
Nicholas J Pappas Weil Gotshal &Manges LLP 767 Fifth Ave 29th Floor New York, NY 10153 212/310−8669 Fax: 212/310−8007 Email: nicholas.pappas@weil.com Bar Status: Not Admitted

Date Filed 01/12/2006 01/12/2006 01/12/2006 03/08/2006 03/09/2006 03/14/2006
03/14/2006 04/12/2006 04/12/2006 04/12/2006
06/12/2006 06/27/2006

# Docket Text
1 COMPLAINT against American Airlines Inc filed by Mark Woodall, Michael P McMahon, Paul J Madson. (govt, no fee) (cxb, ) (Entered: 01/13/2006)
***Magistrate Judge Irma C. Ramirez chosen by random selection to handle matters that may be referred in this case. (nap, ) (Entered: 01/13/2006)
2 CERTIFICATE OF INTERESTED PERSONS/DISCLOSURE STATEMENT by Mark Woodall, Michael P McMahon, Paul J Madson. (nap, ) (Entered: 01/13/2006)
3 Unopposed Motion for Extension of Time to File Answer by American Airlines Inc (nap, ) (Entered: 03/09/2006)
4 UNOPPOSED MOTION to Extend Time to Move for Class Certification Pursuant to Local Rule 23.2 by Mark Woodall, Michael P McMahon, Paul J Madson (nap, ) (Entered: 03/13/2006)
5 ORDER granting 4 UNOPPOSED MOTION to Extend Time to Move for Class Certification Pursuant to Local Rule 23.2. Plts' motion for class certification shall be filed upon such date to be determined by this Court upon its review of the parties' proposed scheduling order. (Signed by Judge Barbara M. G. Lynn on 3/14/06) (nap, ) (Entered: 03/15/2006)
6 ORDER granting 3 Unopposed Motion for Extension of Time to File Answer re 1 Complaint. American Airlines Inc answer due 4/12/2006. See order for specifics. (Signed by Judge Barbara M. G. Lynn on 3/14/06) (nap, ) (Entered: 03/15/2006)
7 MOTION to Dismiss 1 Complaint, and, alternatively, MOTION to Strike by American Airlines Inc.. (mfw, ) (Entered: 04/12/2006)
8 Brief in Support re 7 MOTION to Dismiss 1 Complaint, and, alternatively, MOTION to Strike filed by American Airlines Inc.. (mfw, ) (Entered: 04/12/2006)
9 Appendix in Support re 7 MOTION to Dismiss 1 Complaint, and, alternatively, MOTION to Strike and Brief in Support Thereof filed by American Airlines Inc. (mfw, ) Additional attachment(s) added on 4/13/2006 (mfw, ). (Entered: 04/13/2006)
10 RESPONSE in Opposition filed by Mark Woodall, Michael P McMahon, Paul J Madson re 7 MOTION for Dismissal of Plaintiffs' Complaint, and, Alternatively, MOTION to Strike 1 Complaint (jyg, ) (Entered: 06/13/2006)
11 REPLY Brief in Support filed by American Airlines Inc re 7 MOTION for Dismissal of Plaintiffs' Complaint, and, Alternatively, MOTION to Strike 1 Complaint (jyg, ) (Entered: 06/27/2006)

Case: 3:06­cv­72 As of: 10/16/2012 01:21 AM CDT 5 of 10

07/03/2006 07/03/2006 07/05/2006 07/10/2006 07/12/2006 09/01/2006 10/06/2006
10/30/2006 10/31/2006 11/01/2006 12/04/2006 12/04/2006 12/04/2006
01/16/2007 01/16/2007

12 Unopposed MOTION for Leave to File A Correction Page by Mark Woodall, Michael P McMahon, Paul J Madson (jyg, ) (Entered: 07/03/2006)
13 Application and Order for Admission Pro Hac Vice by Nicholas J Pappas for American Airlines Inc (Signed by Judge Barbara M. G. Lynn on 7/3/06) (nap, ) (Entered: 07/05/2006)
14 Minute Entry for proceedings held before Judge Barbara M. G. Lynn : Telephone Conference. The Court held a telephone conf. to advise the parties of a potential conflict of interest. The parties are directed to advise the Court within 5 business days whether such a conflict exists. (nap, ) (Entered: 07/10/2006)
15 ORDER granting 12 Unopposed MOTION for Leave to File A Correction Page. See order for specifics. (Signed by Judge Barbara M. G. Lynn on 7/10/06) (nap, ) (Entered: 07/10/2006)
16 NOTICE by American Airlines Inc regarding potential conflict of interest (nap, ) (Entered: 07/13/2006)
17 Order Designating Case for ECF − see order for specifics. (Signed by Judge Barbara M. G. Lynn on 09/01/06) (axm, ) (Entered: 09/01/2006)
18 Memorandum Opinion and Order denying 7 Motion to Dismiss and, Alternatively, to Strike filed by American Airlines Inc. Plaintiffs are granted leave to amend their Complaint concerning trip bidding so as to bring them in compliance with the pleading requirements of FRCvP 8(a)(2). Plaintiffs have until 10/30/06 to amend their Trip Bidding Claim, properly to state a claim for injunctive relief, or to seek monetary damages via an avenue that does not require that Plaintiffs' claim for monetary relief be incidental to a claim for injunctive relief, as is required by Rule 23(b)(2). Failure to amend will result in the dismissal of Plaintiff's Trip Bidding Claim. All other relief not expressly granted herein is denied. (Signed by Judge Barbara M. G. Lynn on 10/6/2006) (kdc, ) Additional attachment(s) added on 10/18/2006 (kdc, ). (Entered: 10/06/2006)
19 AMENDED COMPLAINT against American Airlines Inc filed by Mark Woodall, Michael P McMahon, Paul J Madson.(Cunningham, John) (Entered: 10/30/2006)
20 Unopposed Motion for Extension of Time to File Answer , Move or Otherwise Respond to Plaintiffs' First Amended Complaint by American Airlines Inc (Attachments: # 1 Proposed Order)(Hartmann, Michelle) (Entered: 10/31/2006)
21 ORDER granting 20 Motion for Extension of Time to File Answer American Airlines Inc answer due 12/4/2006. (Signed by Judge Barbara M. G. Lynn on 11/1/06) (jrb, ) (Entered: 11/02/2006)
22 MOTION for Partial Dismissal of 19 Amended Complaint by American Airlines Inc (Hartmann, Michelle) Modified on 12/5/2006 (jrb, ). (Entered: 12/04/2006)
23 Brief/Memorandum in Support filed by American Airlines Inc re 22 MOTION for Partial Dismiss re 19 Amended Complaint (Hartmann, Michelle) (Entered: 12/04/2006)
24 Appendix in Support filed by American Airlines Inc re 22 MOTION for Partial Dismiss re 19 Amended Complaint (Attachments: # 1 App. 1 − 40# 2 App. 41 − 80# 3 App. 81 − 119# 4 App. 120 − 158# 5 App. 159 − 198# 6 App. 199 − 239# 7 App. 240 − 277# 8 App. 278 − 308# 9 App. 309 − 352# 10 App. 353 − 388# 11 App. 389 − 435# 12 App. 436 − 483# 13 App. 484 − 521# 14 App. 522 − 563# 15 App. 564 − 595# 16 App. 596 − 636# 17 App. 637 − 679# 18 App. 680 − 703# 19 App. 704 − 733) (Hartmann, Michelle) (Entered: 12/04/2006)
25 AMENDED COMPLAINT SECOND against American Airlines Inc filed by Mark Woodall, Michael P McMahon, Paul J Madson. (Cunningham, John) (Entered: 01/16/2007)
26 RESPONSE in Opposition filed by Mark Woodall, Michael P McMahon, Paul J Madson re 22 MOTION for Partial Dismiss re 19 Amended Complaint (Cunningham, John) (Entered: 01/16/2007)

Case: 3:06­cv­72 As of: 10/16/2012 01:21 AM CDT 6 of 10

01/16/2007 01/31/2007 02/01/2007 02/15/2007 05/08/2007 06/19/2007 06/27/2007 07/27/2007 07/30/2007
08/20/2007
11/28/2007 11/30/2007 01/09/2008 02/26/2008

DEMAND for Trial by Jury by Mark Woodall, Michael P McMahon, Paul J Madson. See Second Amended Complaint. (jyg) (Entered: 07/30/2007)
27 (LETTER) REPLY filed by American Airlines Inc re 22 MOTION for Partial Dismiss re 19 Amended Complaint (Miller, Ralph) Modified on 2/1/2007 (jb). (Entered: 01/31/2007)
28 ORDER denying as moot 22 Motion for Partial Dismissal of Plaintiffs' Amended Complaint and Plaintiffs' Opposition thereto. Ordered that Defendant shall have 10 days from the date of this Order to answer Plaintiffs' Second Amended Complaint. (Signed by Judge Barbara M. G. Lynn on 2/1/07) (jrb) (Entered: 02/02/2007)
29 ANSWER to Amended Complaint / Answer and Affirmative Defenses to Plaintiffs' Second Amended Purported Class Action Complaint by American Airlines Inc (Hartmann, Michelle) (Entered: 02/15/2007)
30 ORDER REQUIRING SCHEDULING CONFERENCE AND REPORT FOR CONTENTS OF SCHEDULING ORDER.Proposed Scheduling Order due by 6/19/2007. (Signed by Judge Barbara M. G. Lynn on 5/8/07) (Attachments: # 1 consent letter # 2consent form) (jrb) (Entered: 05/08/2007)
31 Proposal for contents of scheduling and discovery order / Joint Report Regarding Contents of Scheduling Order by Mark Woodall, Michael P McMahon, Paul J Madson, American Airlines Inc. (Hartmann, Michelle) (Entered: 06/19/2007)
32 NOTICE by Mark Woodall, Michael P McMahon, Paul J Madson, American Airlines Inc re 31 Proposed Scheduling and Discovery Order (Allen, Margaret) (Entered: 06/27/2007)
33 Unopposed MOTION to Withdraw as Attorney Christine M. Roth by Mark Woodall, Michael P McMahon, Paul J Madson (Cunningham, John) (Entered: 07/27/2007)
34 ORDER granting 33 Plaintiffs' Unopposed Motion for Withdrawal of Appearance Pursuant to Local Rule 83.12. The Clerk of the Court may remove Mrs. Roth's name from the docket and take any other appropriate action in accordance with this Order. (Signed by Judge Barbara M. G. Lynn on 7/3/07) (klm) (Entered: 07/30/2007)
35 SCHEDULING ORDER:Discovery due by 4/30/2008. Pretrial Conference set for 2/2/2010 09:00 AM before Judge Barbara M. G. Lynn. Jury Trial set on the Court's three−week docket for 2/10/2010 09:00 AM before Judge Barbara M. G. Lynn. Proposed Pretrial Order due by 1/20/2010. Pretrial Materials due by 1/20/2010. Settlement Status Report due by 5/30/2009. Joinder of Parties: No later than thirty (30) days following the Court's ruling on the Motion for Class Certification. Amendment of Pleadings: No later than thirty (30) days following the Court's ruling on the Motion for Class Certification. Dispositive Motions: All motions that would dispose of all or any part of this case, including motions for summary judgment, shall be filed no later than thirty (30) days after the close of merits−based discovery. (see order for specifics) (Signed by Judge Barbara M. G. Lynn on 08/20/07) (lmp) Modified on 8/22/2007 (lmp). (Entered: 08/20/2007)
36 Agreed Joint MOTION to Extend Time Deadlines in the Court's Scheduling Order by Mark Woodall, Michael P McMahon, Paul J Madson (Attachments: # 1 Exhibit Proposed Amended Scheduling Order) (Cunningham, John) Modified on 11/29/2007 (lmp) (Entered: 11/28/2007)
37 ORDER granting 36 Agreed Joint Motion to Extend Deadlines in the Court's Scheduling Order. (see order for specifics) (Signed by Judge Barbara M. G. Lynn on 11/30/07) (klm) (Entered: 12/03/2007)
38 STATUS REPORT Regarding Settlement Negotiations by Mark Woodall, Michael P McMahon, Paul J Madson, American Airlines Inc. (Cunningham, John) (Entered: 01/09/2008)
39 STIPULATION by Mark Woodall, Michael P McMahon, Paul J Madson to Extend Expert Designation Deadlines in Court's Scheduling Order. (Cunningham, John) (Entered: 02/26/2008)

Case: 3:06­cv­72 As of: 10/16/2012 01:21 AM CDT 7 of 10

03/31/2008 04/03/2008 04/04/2008 04/16/2008 04/17/2008 04/17/2008 04/17/2008
04/17/2008 04/21/2008 05/08/2008 05/08/2008
05/13/2008
05/13/2008 05/16/2008

40 Second STIPULATION by Mark Woodall, Michael P McMahon, Paul J Madson, American Airlines Inc to Extend Expert Designation Deadlines in Court's Scheduling Order. (Cunningham, John) Modified on 4/1/2008 (klm). (Entered: 03/31/2008)
41 Joint MOTION to Stay the Litigation and All Deadlines in the Court's Scheduling Order by Mark Woodall, Michael P McMahon, Paul J Madson, American Airlines Inc. (Cunningham, John) Modified on 4/3/2008 (tln). (Entered: 04/03/2008)
42 ORDER granting 41 Agreed Joint Motion to Stay the Litigation and All Deadlines in the Court's Scheduling Order. (See Order for specifics) (Signed by Judge Barbara M. G. Lynn on 4/4/08) (skt) (Entered: 04/04/2008)
43 STATUS REPORT Letter re: Plaintiff Paul Madson's Settlement Agreement by Mark Woodall, Michael P McMahon, Paul J Madson. (Cunningham, John) (Entered: 04/16/2008)
44 Joint MOTION to Certify Class , Preliminarily Approve Settlement Agreement, and Approve Forms of Class Notice by Mark Woodall, Michael P McMahon, Paul J Madson with Brief/Memorandum in Support. (Cunningham, John) (Entered: 04/17/2008)
45 Brief/Memorandum in Support filed by Mark Woodall, Michael P McMahon, Paul J Madson re 44 Joint MOTION to Certify Class , Preliminarily Approve Settlement Agreement, and Approve Forms of Class Notice (Cunningham, John) (Entered: 04/17/2008)
46 Appendix in Support/Proposed Settlement Agreement filed by Mark Woodall, Michael P McMahon, Paul J Madson re 44 Joint MOTION to Certify Class , Preliminarily Approve Settlement Agreement, and Approve Forms of Class Notice, 45 Brief/Memorandum in Support of Motion Including Settlement Agreement and Exhibits (Cunningham, John) Modified on 4/18/2008 (npk). (Entered: 04/17/2008)
47 Brief/Memorandum in Support filed by American Airlines Inc re 44 Joint MOTION to Certify Class , Preliminarily Approve Settlement Agreement, and Approve Forms of Class Notice (Miller, Ralph) (Entered: 04/17/2008)
48 ORDER SETTING HEARING. A hearing on the 44 preliminary approval of a settlement agreement is hereby SET in this case for Tuesday, May 13, 2008, at 2:00 p.m. before Judge Barbara M. G. Lynn. (Signed by Judge Barbara M. G. Lynn on 4/21/08) (tln) (Entered: 04/21/2008)
49 SUPPLEMENTAL Memorandum of Law filed by American Airlines Inc re 44 Joint MOTION to Certify Class , Preliminarily Approve Settlement Agreement, and Approve Forms of Class Notice | (Allen, Margaret) Modified on 5/9/2008 (svc). (Entered: 05/08/2008)
50 Appendix in Support filed by American Airlines Inc re 49 Brief/Memorandum in Support of Motion (Attachments: # 1 App. 1−40, # 2 App. 41−79, # 3 App. 80−110, # 4 App. 111−149, # 5 App. 150−185, # 6 App. 186−195, # 7 App. 196−234, # 8 App. 235−269, # 9 App. 270−295, # 10 App. 296−322, # 11 App. 323−343) (Allen, Margaret) (Entered: 05/08/2008)
51 ORDER CONDITIONALLY CERTIFYING THE SETTLEMENT CLASS, PRELIMINARY APPROVING THE AGREEMENT, APPROVING FORMS OF CLASS NOTICE AND SCHEDULING A FAIRNESS HEARING: The Fairness hearing will be held on 7/24/08 at 9:00 AM. (See Order for specifics) (Signed by Judge Barbara M. G. Lynn on 5/13/08) (skt) (Entered: 05/15/2008)
Set/Reset Hearings: Fairness Hearing set for 7/24/2008 09:00 AM before Judge Barbara M. G. Lynn. (skt) (Entered: 05/15/2008)
52 Minute Entry for proceedings held before Judge Barbara M. G. Lynn: Settlement Hearing held on 5/13/08. Attorney Appearances: Plaintiff − Counsel of record; Defense − Counsel of record. (Court Reporter Sue Engledow.) Time in Court: 1 hr 20 min. (npk) (Entered: 05/16/2008)

Case: 3:06­cv­72 As of: 10/16/2012 01:21 AM CDT 8 of 10

05/21/2008 05/22/2008 05/22/2008
07/17/2008 07/17/2008 07/17/2008 07/17/2008 07/17/2008 07/17/2008 07/17/2008 07/24/2008
07/28/2008 07/29/2008 07/29/2008

53 Joint MOTION to Seal Document − File Paul J. Madson's Individual Confidential Settlement Agreement Under Seal filed by Mark Woodall, Michael P McMahon, Paul J Madson, American Airlines Inc (Attachments: # 1 Text of Proposed Order) (Allen, Margaret) (Entered: 05/21/2008)
54 ORDER granting 53 Joint Motion to File Paul J. Madson's Individual Confidential Settlement Agreement Under Seal. (Signed by Judge Barbara M. G. Lynn on 5/22/08) (skt) (Entered: 05/22/2008)
55 TRANSCRIPT of Preliminary Settlement Hearing Proceedings held on May 13, 2008 before Judge Barbara M.G. Lynn. Court Reporter/Transcriber P. Sue Engledow, Telephone number 214.753.2325. Parties are notified of their duty to review the transcript. A copy may be purchased from the court reporter or viewed at the clerk's office public terminal. If redaction is necessary, a Redaction Request − Transcript must be filed within 21 days. If no such Request is filed, the transcript will be made available via PACER without redaction after 90 calendar days. The clerk will mail a copy of this notice to parties not electronically noticed. Redaction Request due 6/12/2008. Redacted Transcript Deadline set for 6/23/2008. Release of Transcript Restriction set for 8/20/2008. (pse) (Entered: 05/22/2008)
57 Joint MOTION Final Approval of the Settlement Agreement filed by Mark Woodall, Michael P McMahon, Paul J Madson (Cunningham, John) (Entered: 07/17/2008)
58 Brief/Memorandum in Support filed by Mark Woodall, Michael P McMahon, Paul J Madson re 57 Joint MOTION Final Approval of the Settlement Agreement (Cunningham, John) (Entered: 07/17/2008)
59 Appendix in Support filed by Mark Woodall, Michael P McMahon, Paul J Madson re 58 Brief/Memorandum in Support of Motion, 57 Joint MOTION Final Approval of the Settlement Agreement (Cunningham, John) (Entered: 07/17/2008)
60 Brief/Memorandum in Support filed by American Airlines Inc re 57 Joint MOTION Final Approval of the Settlement Agreement and Response to Objections (Attachments: # 1 Text of Proposed Order) (Hartmann, Michelle) (Entered: 07/17/2008)
61 Appendix in Support filed by American Airlines Inc re 60 Brief/Memorandum in Support of Motion (Joint) for Final Approval of Settlement and Response to Objections (Hartmann, Michelle) (Entered: 07/17/2008)
62 SUPPLEMENTAL MEMORANDUM in Further Support filed by American Airlines Inc re 57 Joint MOTION Final Approval of the Settlement Agreement (Supplemental Memorandum in Further Support) (Hartmann, Michelle) Modified on 7/21/2008/Modified title (cxb). (Entered: 07/17/2008)
63 Appendix in Support filed by American Airlines Inc re 62 Brief/Memorandum in Support of Motion (Supplemental) Memorandum in Further Support of Joint Motion for Final Approval of Settlement and Response to Objections (Hartmann, Michelle) (Entered: 07/17/2008)
65 Minute Entry for proceedings held before Judge Barbara M. G. Lynn: Motion Hearing held on 7/24/08 re 57 Motion for Approval of Settlement Agreement filed by Michael P McMahon, Mark Woodall, Paul J Madson. Attorney Appearances: Plaintiff − Esther Tamburo−Lander/Andrew Braniff; Defense − Ralph Miller/Erin Echols/Michelle Hartmann−Murawski/Margaret Allen. (Court Reporter Sue Engledow) Time in Court: 55 mins. (tln) (Entered: 07/24/2008)
66 ORDER SETTING HEARING: A continuation of the hearing on the final approval of a settlement agreement will be held 7/30/2008 at 9:00 a.m. (Signed by Judge Barbara M. G. Lynn on 7/28/08) (klm) (Entered: 07/28/2008)
67 Unopposed MOTION to Seal Document re Notice of Filing Objections at Dkt No. 56 filed by Mark Woodall, Michael P McMahon, Paul J Madson (Attachments: # 1 Exhibit Tab 1 to Unopposed Motion) (Cunningham, John) (Entered: 07/29/2008)
68 NOTICE of Filing Supplemental Objection filed by Mark Woodall, Michael P McMahon, Paul J Madson (Cunningham, John) (Entered: 07/29/2008)

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07/29/2008 07/30/2008 07/31/2008
08/01/2008 08/01/2008 08/01/2008 08/01/2008 08/08/2008
08/08/2008
09/02/2008

MOTION for Leave to File Redacted Version of the Notice filed by Mark Woodall, Michael P McMahon, Paul J Madson. (see doc. 67 for image) (klm) (Entered: 07/30/2008)
69 Minute Entry for proceedings held before Judge Barbara M. G. Lynn: Motion Hearing held on 07/30/08 re 57 Joint MOTION Final Approval of the Settlement Agreement filed by Michael P McMahon, Mark Woodall, Paul J Madson. Attorney Appearances: Plaintiff − Esteher Tamburo−Lander, Andrew Braniff; Defense − Ralph Miller/Erin Echols/Michelle Hartmann−Murawski/Margaret Allen. (Court Reporter Sue Engledow.) Time in Court: 1hr 45min. (lmp) (Entered: 07/31/2008)
70 TRANSCRIPT of Settlement Proceedings held on July 24, 2008 before Judge Barbara M.G. Lynn. Court Reporter/Transcriber P. Sue Engledow, Telephone number 214.753.2325. Parties are notified of their duty to review the transcript. A copy may be purchased from the court reporter or viewed at the clerk's office public terminal. If redaction is necessary, a Redaction Request − Transcript must be filed within 21 days. If no such Request is filed, the transcript will be made available via PACER without redaction after 90 calendar days. The clerk will mail a copy of this notice to parties not electronically noticed. Redaction Request due 8/21/2008. Redacted Transcript Deadline set for 9/2/2008. Release of Transcript Restriction set for 10/29/2008. (pse) (Entered: 07/31/2008)
71 Minute Entry for proceedings held before Judge Barbara M. G. Lynn: Telephone Conference on the Joint Motion for Final Approval of the Settlement. Attorney Appearances: Plaintiff − Esther Tamburo−Lander; Andrew Braniff; Defense − Ralph Miller, Erin Eckols, Michelle Hartmann−Murawski, Jennifer Brandeis. (Court Reporter Sue Engledow.) Time in Court: /15. (klm) (Entered: 08/01/2008)
72 ORDER granting 67 Unopposed MOTION to Permanently Seal Notice of Filing Objections at Dkt No. 56. and Request for Leave to File Redacted Version of the Notice. (see order) (Signed by Judge Barbara M. G. Lynn on 08/01/08) (lmp) (Entered: 08/04/2008)
73 NOTICE of Filing Objections to Settlement Agreement (Redacted) filed by Mark Woodall, Michael P McMahon, Paul J Madson. (lmp) (Entered: 08/04/2008)
74 Final Order Approving Settlement, Certifying Class, and Directing Dismissal. (see order) (Signed by Judge Barbara M. G. Lynn on 08/01/08) (lmp) (Entered: 08/04/2008)
75 TRANSCRIPT of Settlement Proceedings held on July 24, 2008 before Judge Barbara M.G. Lynn. Court Reporter/Transcriber P. Sue Engledow, Telephone number 214.753.2325. Parties are notified of their duty to review the transcript. A copy may be purchased from the court reporter or viewed at the clerk's office public terminal. If redaction is necessary, a Redaction Request − Transcript must be filed within 21 days. If no such Request is filed, the transcript will be made available via PACER without redaction after 90 calendar days. The clerk will mail a copy of this notice to parties not electronically noticed. Redaction Request due 8/29/2008. Redacted Transcript Deadline set for 9/8/2008. Release of Transcript Restriction set for 11/6/2008. (pse) (Entered: 08/08/2008)
76 TRANSCRIPT of Settlement (Cont'd) Proceedings held on July 30 &August 1, 2008 before Judge Barbara M.G. Lynn. Court Reporter/Transcriber P. Sue Engledow, Telephone number 214.753.2325. Parties are notified of their duty to review the transcript. A copy may be purchased from the court reporter or viewed at the clerk's office public terminal. If redaction is necessary, a Redaction Request − Transcript must be filed within 21 days. If no such Request is filed, the transcript will be made available via PACER without redaction after 90 calendar days. The clerk will mail a copy of this notice to parties not electronically noticed. Redaction Request due 8/29/2008. Redacted Transcript Deadline set for 9/8/2008. Release of Transcript Restriction set for 11/6/2008. (pse) (Entered: 08/08/2008)
77 Supplemental Document by American Airlines Inc Letter notifying Court, in accordance with Court's Minute Order of 8/1/08, American Airlines has posed notificiation of all Settlement Class Members on its website. (Hartmann, Michelle) (Entered: 09/02/2008)

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02/25/2009

78 NOTICE of Final Certification filed by American Airlines Inc (Hartmann, Michelle) (Entered: 02/25/2009)