7. Article XVIII, Section 1 of ALPA's Constitution and By-Laws (Exhibit 1 hereto) requires the prior approval of ALPA's President before any pilot group enters into contract negotiations. Article XVIII, Section 1 further provides that no collective bargaining contract or other agreement can become effective and binding "unless and until they bear the signature of the President."

8. The ALPA Administrative Manual provides governing policies to ALPA officials, members and staff on numerous matters as a supplement to the ALPA Constitution. Section 40 of ALPA's Administrative Manual is titled "Collective Bargaining" and sets forth the policies of the Association that relate to that subject and are applicable to all ALPA-represented pilot bargaining units. A copy of Section 40 is attached hereto as Exhibit 6.

9. Section 40, Part 3, y[ C.3 of the ALPA Administrative Manual provides that "[p]rior to Presidential signature... agreements... shall be reviewed by the Representation Department, which shall then make a recommendation regarding signing to the President based on compliance of the agreement(s) with
ALPA's stated goals and policies concerning collective bargaining." Section 40, Part 3,111[ C.4-5 provides that a pilot group that disputes a Presidential decision not to sign an agreement may appeal that decision to the ALPA Executive Council, composed of all of ALPA's nationally-elected officers, which has authority to override the President's decision.

10. Article 40, Part 6 of the Administrative Manual provides that a prerequisite to any concessionary agreement includes, among other things, the opening of a carrier's books by management for inspection and analysis by the union, a factual objective review of the company's financial condition and need for relief, the provision of a detailed economic recovery plan for the company, and appropriate quid pro quos for the pilots for any economic concessions that they may provide, including the provision for "snap-back" provisions to restore the concessions after a date certain or when they are no longer necessary.