Q. So I want to make sure I understand the way you did the calculation.
[SIZE=11pt]So for Mr. Connell, his date of hire by US Airways was May 19, 1986. [/SIZE]
And you would do his length of service calculation from that date,
[SIZE=11pt]May 19, 1986, to the snapshot date. [/SIZE]Is that right?
[SIZE=11pt]A. That's what we do for every pilot on the [/SIZE]
[SIZE=11pt]list, yeah.[/SIZE]
Q. And so for him that would give him 10,066 days of length of service.
A. yeah. That's 30 years, so, yeah.
[SIZE=11pt]Q. Okay. And then on the US Airways list, as you describe in Slides 10 and 11, [/SIZE][SIZE=10pt]you have a West pilot, Mr. Braid, who is a member of [/SIZE][SIZE=11pt]your committee.[/SIZE]
[SIZE=11pt]Is that right? [/SIZE]
A. Yes, he is.
Q. And his date of hire by America West was November 16, 1998.
[SIZE=11pt]You calculate his length of service as[/SIZE] 5,502 days, for Mr. Braid
[SIZE=11pt]A. That's correct. [/SIZE]
Q. Okay. Now, under this US Airways list, you put Mr. Braid senior to Mr. Connell.
A. I didn't do that. Arbitrator Nicolau did that.
[SIZE=11pt]Q. Well, you constructed the list; right? [/SIZE]
[SIZE=11pt]A. Arbitrator Nicolau constructed the list. I updated it. [/SIZE]
Q. All right. Mr. Connell is a Group 2 Captain.
[SIZE=11pt]A. If you say so.
Q. And so that would take Mr. Braid as a [/SIZE]
[SIZE=11pt]Group 2 First Officer, put him in a seniority position with Group 2 Captains. [/SIZE]
[SIZE=11pt]A. Yes. [/SIZE]
[SIZE=11pt]Q. Okay. And in the East system, that's the [/SIZE][SIZE=10pt]intervening positions of Group 3 FO and Group 4 FO. [/SIZE]
[SIZE=11pt]So that's effectively three category and status promotions. [/SIZE]
[SIZE=11pt]A. I wouldn't characterize it that way. [/SIZE]
Q. So the effect of that list is to place Mr. Braid ahead of a pilot with 4,500 more days length of service, or 12 and a half years prior.
A. And that was the case when Arbitrator Nicolau put the list together, yes.
[SIZE=11pt]...[/SIZE]
Q. Or a difference between FO Ferguson and Capt. Thompson of 5,943 days, which is over 16 years length of service.
[SIZE=11pt]Is that right?
A. Yep. The math is correct.[/SIZE]
[SIZE=11pt]...[/SIZE]
Q..But nonetheless, that difference for Mr. Ziegler of being put junior to a pilot with 21 and a half less years of service is the effect of the list you used in this system; right?
A. That is the effect of the Nicolau list, yes.