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February 4, 2008

From:   Ellen C. Ham

            Ford & Harrison, Law Offices

To:      Robert Eberle

           Jubelier, Pass & Intrieri, P.C.

Re:     PSA/IBT Gr. Nos. 087-04 (J. Snively/Break Issue) & 161-06 (R. Young/OT)

Dear Bob,

       As you know, this firm will represent PSA Airlines in the arbitration hearings for the above-referenced grievances.  This letter is in response to your correspondence dated January 7, 2008 requesting payroll information and other documents in order to determine potential monetary liability should one or both grievances be sustained in arbitration.  We find no such justification for producing such information under the Railway Labor Act, the existing PSA/IBT collective bargaining agreement, or pursuant to any past practice between the parties.  Therefore, your request is denied.  We understand, however, your concern over the preservation of certain information given the recent cessation of passenger/fleet service duties performed by the PSA agents.  I can assure you that PSA has retained (as it is required under federal law) the payroll information for the relevant time period.

       Also, we feel your request for this information is premature.  The union must first prove that PSA violated the collective bargaining agreement.  Only upon such a finding by the System Board, would the parties take on the task of determining monetary liability.  To the extent that the Union may have failed to collect sufficient documentation from its members since the filing of both grievances in order to prove its case, PSA has no legal or contractual obligation to do the Union's work.  Finally, if you still feel (as you stated in your letter) that there is room for further discussion as to a resolution in one or both cases, please contact me directly.  If not we should proceed with scheduling hearings in both matters.

                            Sincerely,

                                   Ellen C. Ham

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March 10. 2008

From:  Robert Eberle

           Jubelier, Pass & Intrieri, P.C.

To:      Ellen C. Ham

           Ford & Harrison, Law Offices

Re:      PSA/IBT Gr. Nos. 087-04 (J. Snively/Break Issue) & 161-06 (R. Young/OT)

Dear Ellen,

       This letter is in response to your letter dated February 4, 2008, regarding the above-referenced grievances.

       The Union disagrees with the Company's response to the information requests.  However, at this point the most practical way to address these issues is to move forward with the arbitrations.  My files reflect that we previously selected Lawrence T. Holden, Jr. as the neutral arbitrator for Gr. No. 087-04.  I will send out a separate letter requesting Arbitrator Holden to provide us with available dates for a hearing.  My files also reflect that we have selected Dr. John W. Boyer for a different grievance involving these same parties.  I suggest that we inquire with Arbitrator Boyer about utilizing that date for this arbitration.  Please let me know your thoughts on this.

                            Very truly yours,

                                          Robert A. Eberle

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March 10, 2008

To:      Lawrence T. Holden, Jr., Esquire

Re:     PSA/IBT Gr. Nos. 087-04 (J. Snively/Break Issue) & 161-06 (R. Young/OT)

From:  Robert Eberle

           Jubelier, Pass & Intrieri, P.C.

Dear Arbitrator Holden:

       The parties to the above-referenced cases previously notified you of your selection as arbitrator.  At the present time, the parties request hearing dates when you would be available to hear this case.  Would you kindly provide the parties with available dates?  Ellen C. Ham represents the Employer, the undersigned represents the Union.

       The parties thank you in advance for your attention to this matter.

                            Very truly yours,

                                          Robert A. Eberle