BY MR. SILVERMAN:
Q. Mr. Scherff, my question was simply, were you aware of the
methodology of going to the membership and bypassing the BPR to
amend the constitution prior to our conversation today?
A. At some point, yes, sir.
Q. Okay.
By the way, in terms of the numbers, does the West --
does the Phoenix-based pilots comprise 25 percent of the USAPA
membership in good standing?
A. I'm not sure how many. I wouldn't be the person to ask
that.
Q. Okay.
MR. SILVERMAN: Can we bring up Plaintiffs' 24,
please.
BY MR. SILVERMAN:
Q. Bear with me, please, Mr. Scherff.
Directing your attention to paragraph 10H of MOU II,
is it your testimony, Mr. Scherff, that you have no idea what
this provision means? 02

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United States District Court
JOHN SCHERFF - Cross
A. No, sir. I believe that that paragraph says that it's
stats quo and I stated that I believe the status quo is the
Nicolau.
Q. Okay. So to unpack this a little bit, this provision
says, the words, US Airways agrees that neither this memorandum
nor the JCBA shall provide a basis for changing the seniority
lists currently in effect at US Airways other than through the
process set forth in this Paragraph 10.
Do you agree?
A. Yes.