And the -- particularly where there are
allegations of irreparable harm?
And, of course, the Rules of Evidence don't really apply
other than the facts that are presented have to be
reliable. So that makes it a lot easier for this Court to give
all reasonable inferences in favor of the plaintiff.
But as I said, that's for another day. And as I also
mentioned, and I want to hear from Mr. Siegel on this, is
whether or not things have changed in terms of ripeness because
that made a big difference to me. I have been trying at
length, as I think everybody knows, to try to figure out why
the Ninth Circuit did what it did on ripeness but understanding
full well this process of negotiations for Collective
Bargaining Agreement. So I accepted that -- wait a minute.
I accepted that and then I read the MOU. It's quite
clear to me that the corporation is standing back and they are
saying just tell us what to do. Just solve this seniority
issue. And I had mentioned I think before that this whole
process of seniority could be resolved because the companies
may say, look, we're going to give everybody a huge raise so
let's just go with date of hire and everybody accepts that.
Well, that's not what they are saying.
They are saying -- they are saying you resolve it so
here we are. As far as I'm concerned, at some point, the new
allegation that occurred subsequent has created ripeness. So
we're -- and you have not persuaded me otherwise.