 The Local Union represents the Southwest Airlines Flight Attendants. Local 556  of the Air Transport Division of the TWU was chartered as a Local on October 13, 1981, in the  city of Dallas.    Plaintiff Jackson began the process of obtaining signatures on recall petitions in  August of 2015. The effort was made in response to actual violations of the Constitution and By- Laws committed by certain Executive Board members. At all times the recall effort was  conducted in accordance with the union Constitution and By-Laws.    On December 15, 2016, valid recall petitions signed by 7,592 TWU members in  good standing were presented to the Local for verification as required by the By-Laws. The  recall petitions alleged violations of the Local By-Laws Objectives Article II (b) and the TWU  International Constitution Article XIX Section 5. The petitions met or exceeded the form  requirements described in the By-Laws.    The recall petitions sought the recall of Local 556 President Audrey Stone, 1st  Vice President Todd Gage, 2nd Vice President Brett Nevarez, Recording Secretary Cuyler  Thompson, Financial Secretary/Treasurer John Parrott, Board Member at Large Sam Wilkins,  Board Member at Large Crystal Reven, DEBM1 Andrea Garnett, DEBM Stacey Vavakas,  DEBM David Jackson, DEBM Pamila Forte, DEBM Rachel Brownfield, DEBM Jimmy West,  and DEBM Matt Hettich.    An appeal was filed with TWU International on January 17, 2017 at the request of  union leadership. As of the date of filing, TWU International has refused to verify the recall  petitions and comply with the Constitution and By-Laws.    Multiple attempts were made, both by plaintiff Jackson and her counsel, to confer  with legal counsel for International to assist and cooperate in the recall petition validation.  Attempts to communicate and assist were ignored completely.    In continuing to ignore the recall petitions of more than 50% of the eligible  membership, both Local and International are depriving the members of rights as conferred in  the Act and the governing documents of International and Local.  IV.   Each of the foregoing paragraphs are incorporated and re-alleged.    “The Labor–Management Reporting and Disclosure Act of 1959 was the product  of congressional concern with widespread abuses of power by union leadership.” Finnegan v.  Leu, 456 U.S. 431, 435 (1982). Although the LMRDA as originally enacted focused on  disclosure requirements and regulating union elections, over time various amendments have  shifted the focus toward “protection for members of unions paralleling certain rights guaranteed  by the Federal Constitution[.]” Id. To state a claim under § 412, plaintiffs must show (1) that  they are members of a labor organization and (2) that the organization infringed a right secured  by § 411, 412, 413, 414, or 415. See Martinez v. Am. Fed'n of Gov't Emps., 980 F.2d 1039,  1041–42 (5th Cir. 1993).    In repeatedly ignoring the valid recall petitions of plaintiffs, both Local and  International have denied plaintiffs the equal rights provided for in the Act.    Specifically, the Act recognizes that a member’s exercise of their equal rights are  “subject to reasonable rules and regulations in such organization’s constitution and bylaws.”  Here, plaintiffs are attempting to participate and engage in the rights described in the Act in  conformity with the by-laws and constitution, but are improperly being blocked from doing so.    In repeatedly ignoring the valid recall petitions of plaintiffs, the defendants have  in effect deprived the plaintiffs of their freedom of speech and assembly, barring plaintiffs from  having a voice in the conduct of the union’s business.    Thus, the defendants violated§ 411(a)(1) and (2) and deprived Plaintiffs and other  Local 556 members in good standing of their right to participate in the deliberations and voting  upon the business and elections of the union.    Local 556 has adopted By-Laws that provide for the proper procedures and  methods for the recall of an Officer of the Local.    Said By-Laws apply to Local 556 members in good standing.    The By-Laws are a contract between the Local 556 and its members.    Local 556 Executive Board violated the By-Laws when it rejected Plaintiffs’  recall petitions and refused to verify signatures as required by the Constitution and By-Laws.     As of the date of filing, Local and TWU International have refused to verify the  recall petitions and comply with the Constitution and By-Laws.   In their recall petitions, Plaintiffs allege violations of the Constitutions and By- Laws that severely and materially affect the members of the union on a daily basis. A recall  election is a method by which the members can remove from power those who negatively impact  their rights, do not work in their best interests, and violate the governing documents and  principles of the union.    “A preliminary injunction is an extraordinary equitable remedy that may be  granted only if the plaintiff establishes four elements: (1) a substantial likelihood of success on  the merits; (2) a substantial threat that the movant will suffer irreparable injury if the injunction  is denied; (3) that the threatened injury outweighs any damage that the injunction might cause  the defendant; and (4) that the injunction will not disserve the public interest.” Hoover v.  Morales, 164 F.3d 221, 224 (5th Cir. 1998).    Unless Defendants are restrained, Plaintiffs will be irreparably injured, and suffer  loss and damage by Defendants' wrongful conduct described above. Specifically, the conduct  complained of in the recall petitions will continue, and the plaintiffs will continue to be harmed.    Unless this Court issues a preliminary injunction, the Board will continue to block  a democratically held election for new Executive Board members.     Further, unless Defendant is immediately enjoined, Plaintiffs will have no  adequate remedy at law.    An injunction would not disserve the public interest. On the contrary, an  injunction blocking the defendants’ attempts to violate the rights conferred to plaintiffs under the  Act would serve the public interest and fulfill the purpose of the Act as envisioned by Congress.    Plaintiffs seek a preliminary injunction enjoining defendants from any and all  such conduct that serves to block or prevent the recall election as provided in Article X of the  By-Laws.    Preliminary injunction is also sought pursuant to 29 U.S.C. § 412.   Plaintiffs seek a declaration from the Court concerning the rights and legal  relations as authorized by 28 U.S.C. § 2201.    Plaintiffs seek a declaration that they have complied with the requirements of the  Constitution and By-Laws of the Local and International and are thus entitled to a recall election.    Plaintiffs seek class certification under Rule 23 of the Federal Rules of Civil  Procedure.    The putative class members are defined as: all Local 556 members in good  standing who affixed their signature, employee number, and the date to a recall petition as set  forth in Article X of the By-Laws of the Local.    Numerosity: The class consists of approximately 8,000 members (additional recall  petitions are received daily). The class is therefore so numerous that joinder of all members is  impractical.    Commonality: There are questions of law and fact that are common to the class.  Because each class member affixed their signature to the same recall petition, the violations  alleged herein apply to each class member equally.    Typicality: The claims of the representative Jeanna Jackson are typical of the  class members as each have sought recall of Officers of the Local pursuant to Article X of the  By-Laws.    Adequacy of Representation: As a member in good standing of the Local, plaintiff  Jackson’s claims are so identical to those putative class members that her claim and efforts to  enforce the provisions of the By-Laws show prima facie evidence of adequacy of representation.  Plaintiff Jackson was the party initiating the recall effort on behalf of the putative class.    The Transport Workers Union of America is affiliated with the AFL-CIO and the  World Wide International Transport Workers Federation.    All TWU Members belong to Locals formed on the basis of interest and  geographic location. The Members elect their own Local Officers who handle most of their  issues and business. The International coordinates the activities of the Divisions and the Locals  and assists in negotiations, organizing drives and legislative campaigns. It provides professional  legal, education, research and public relations services to the Locals and Divisions.  