WHEREFORE, Plaintiff prays that this Court grant its Motions for Temporary Restraining Order and Preliminary Injunction, and:
I. Issue a Declaratory Judgment that the actions complained of herein are unlawful, and;
II. Issue a Temporary Restraining Order, lasting in duration from the date of the Order until the earlier of either ten (10) days from the Order or until a hearing upon Plaintiff’s Motion for a Preliminary Injunction is held, that orders all Defendants, and any of their officers, agents, or employees, be prohibited from the acts listed in ¶ III below, and;
III. Issue a Preliminary Injunction, the same to be made permanent on final judgment, that orders all Defendants, and any of their officers, agents, or employees, be prohibited from the following acts:
1. From making, sending, or causing to be sent telephone calls to any of USAPA’s telephone numbers, including or any "Safety Hotline" telephone
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number, that are frivolous in quality or quantity, or that are knowingly false, or that needlessly contain indecent and profane language, and that are either intended to, or have the effect of, imposing burden and cost on the resources of said telephone lines or on USAPA;
2. From making, sending, or causing to be sent e-mails or other electronic transmissions to any USAPA or USAPA officer’s e-mail addresses that are frivolous in quality or quantity, or that are knowingly false, or that needlessly contain indecent and profane language, and that are either intended to, or have the effect of, imposing burden and cost on the resources of said USAPA or its officers;
3. From denying, conspiring to deny, or instigating denial of, access to "jump seats" on aircraft operated by any commercial carrier because of suspected membership in, or support of, USAPA, or status as an "East pilot," or because of any pretextual excuse to hide such anti-USAPA animus, or animus against East pilots;
4. From conveying or communicating personal threats of retaliation against the safety of individual pilot-employees of US Airways, or engaging in telephonic or other unlawful harassment, in order to prevent, deter or intimidate them from paying membership dues to USAPA or from paying non-membership agency fees required by law;
5. From making, sending, or causing to be sent e-mails using altered e-mail addresses falsely attributed to be, or appear nearly identical to, e-mail addresses employed by USAPA officers;
6. From causing or arranging USAPA officer’s e-mail addresses to be subscribed to internet web or e-mail subscriptions, whether of an adult nature or not, without their knowledge and permission;
7. From sending, or causing to be sent, injurious articles or other nonmailable matter to USAPA or USAPA’s officers through the U.S. Postal Service, or deceptive use of the U.S. Mail in order to impose, or which has the effect of imposing, unnecessary costs on USAPA, or from other unlawful abuse of the U.S. Postal Service designed to sabotage USAPA’s operations.
8. From taking, or conspiring to take, concerted action designed to tortiously interfere with US Airways’ contractual obligations to USAPA under Section 29 of the Collective Bargaining Agreement, provided that no party shall be enjoined from filing an appropriate grievance under the contractual grievance procedures
