Singapore Airlines, LTD vs. Mr. ***** (USA)
Guest
Posts: n/a
Q: Under general conditions of service, paragraph 1.7, this was a paragraph that concerened you; is that correct?
A: Inasmuch as I had to have two guarantors, yes.
Q: What about the seven period?
A: That as well. That wasn't mentioned in the interview process. because it's noy only seven years, as it reads and as you know, it's seven years from the completion of training, which can take anywhere from a year to a year ans a half, so the total term can be up to eight and a half, nine years.
Q: And under paragraph 2.3, this is also concerned you, did it not? Take a minute and review it.
A: Yes it concerened me greatly.
Let's take a look at paragraph 6 and 6.1 under Scope of employment where it says: "You are required to serve SIA in any part of the world and on any of the routes served by SIA, including the operation of special chartered flights, passenger or freighter aircraft," do you see that?
A: Yes.
Q: Did you ever ask LM or anyone else about that paragraph being in contradiction to his statement that he didn't see any reason why you wouldn't be flying a 747?
A: So much as we've read, no, not at all. The 747 encompasses all those things.
Q: But you understood it was up to Singapore Airlines as to in what part of the world you would be in and what routes you would fly and what planes you would fly?
A: Yes. And as I stated before, all the statements that would give me the reason to believe that it was up to my performance to earn that assignment.
Q: But it was also based on availability, correct?
A: True, and there was plenty of that as well.
Q: We also see in paragraph 25 a statement that the applicable law for the purpose of your contract of employment will be the laws of Singapore, correct?
A: Yes.
Q: Did you at any time, prior to the institution of this litigation, undertake to determine what the laws of Singapore were in regards to the bonding agreement?
(Defendant's attorney): I'll object to that question to the extent it calls for materials which may be privileged under the attorney-client priviledge and caution you not to waive that privilege.
Q: I don't want to hear any conversations that you might have had, even prior to this litigation, with your attorneys at Bogle. But other than conversations with any attorneys that you might have had, did you undertake to learn about the singapore law meant in regard to your contract of employment?
A: Up to the time that I signed this document, the answer would be no.
Q: What about prior to the time you left Singapore airlines?
A: Yes.
Q: What did you inquire about?
(Defendant's attorney): I'm going to ask that I have a conference with my client at this point to explain to him the attorney-client privilege in more detail, as I have a feeling he doesn't quite appreciate it at this point.
Q: Let me ask a predicate question first.
Q: Any of these conversations about the application of law in Singapore prior to the time you left Singapore airlines, did they involve money?
A: Yes.
Q: Let me ask the question again. Did you have any conversations with anybody regarding the appliof Singapore law prior to the time you left Singapore airlines?
(Defendant's attorney): Same objection.
Q: That's just a yes or no question.
A: Yes.
Q: Did any of those conversations involve nonlawyers?
A: Yes.
Q: Tell me about the conversations that involved nonlawyers?
A: Particular other individuals who had tried to take action to relieve themselves of the bond. A group of 11, if I remember right, 11 Australians, tried to, through legal action, relieve the responsibility ot the bonding agreement. In the process, while they were told they would win -
Q: Pardon? While they were told what?
A: They were told by their lawyer they would win - this is the story, is what they would end up winning may be what they - not something they may not like. In other words, the retribution for having won would be something that wouldn't prolong their career in the airline. With that information they went to the Singapore ALPA, Airline Pilot's Association, and asked them for their assistance in the matter. They didn't end up getting any assistance. Instead what they were planning to do was divulge to management, and the response from management was to try and attempt for them to sign an agreement that they would not sue singapore airlines over the bond. I don't know that any of them signed it, but those individuals then were passed over for promotion.
Q: Did they end up leaving Singapore Airlines?
A: Some did yes.
Q: Did you know if they left prior to the time their bond had expired?
A: Yes.
Q: Was their litigation involving their bond?
A: I presume so.
Q: So your testimony is they went to the union, the Airline Pilot's Association, and the airline Pilot's Association then turned their names over to the company?
A: Yes. There is -
Q: Who told you this story?
A: Colleagues.
Q: Do you remember who, specifically?
A: It was frequent - one problem I have with specifically mentioning names is that they still work there, and this getting back to Singapore Airlines would result in admonishment that I don't want them to receive. The other thing was it was a common story amongst the foreign pilots, so any number of them know it.
Q: I'm entitled to know that information. It's part of discovery, and i do want the name.
(Defendant's attorney): Would like to take a brief recess?
The Witness: I think it's time for a break.
Q: We're between a question and answer. there is no question of privilege. Breaks are impermissible between a question and answer under rules, unless there is a qof privilege.
(Defendant's attornry): I understand that, and I would be happy to explain the situation and the ramifications of not answering this question to my client.
The Witness: That's my question at this point, if I don't answer the question, what are the ramifications?
Q: I will allow a break.
(Defendant's attorney): That's all I'm going to do.
Q: I want to go on the record to say that i think it is impermissible under the rules, but in the spirit of accommodation -
Q: I'll allow you to go ahead and ask him. Go ahead and talk to him.
(Brief recess)
Q: Who told you that informayion?
A: In addition to what I was saying about quite a common story amongst the pilots, and they would discuss it often, an individual, his name is GS, we discussed that information. Any other people that I discussed - numerous people discussed it with - the actual source of the story I honestly do not recall. There is - it's an Australian. he may not even be working with the company anymore, but I don't recall.
Q: But you recall that you discussed this with GS?
A: Yes.
Q: And that he told you about that information?
A: Yes.
Q: When did you learn about these 11 Australians and the bonding agreement?
A: Somewhere near the summer of 95.
Q: Prior to the time you signed the bonding agreement, and based on your discussion with the Boeing lawyer, you were concerned, I take it, that the bonding agreement was a form of indentured servitude, in your mind; is that correct?
A: Yes.
Q: And you knew that you were undertaking some risk when you signed it?
A: Yes.
Q: Did you have any other conversations with anyone at Singapore Airlines, other than LM, and the technical conversations you had with Mr.L, about the bonding agreement prior to the time you signed the acceptance of employment letter on Oct 20, 93?
A: Can I hear the question again, because it's the first part I don't remember.
(The record was read.)
A: Don't believe so.
Q: When did you then go to singapore?
A: Let's see, tha date of service was Nov 9th, so I arrived there, I believe, on the 8th.
Q: Did you find housing at that point?
A: No. We were given 10 days in the Paramount hotel on the company prior to having to have a place of our own.
Q: When did you find housing, approximately?
A: The last day of that.
Q: Around the middle of Nov?
A: Right, that's correct, which wasn't easy.
Q: It wasn't easy to find?
A: Those days were packed with other things to0 do for the company. it's also at that point when I - to do this I engaged a Realtor, basically, to help me locate a place based on what i anticipated for earnings, and that's when i found out that HDBs are not available, the governmensubsidized apartments, are not available for rent by non-singaporeans in whole. In other words, you could rent a room, in other words, boarder, but you could not rent the entire apartment, and what some Singaporeans do is lock up a room, but that doesn't meet the requirements of the law, and if that were to be discovered, I could be - and, of course, my wife could be evicted, not a very good thing to happen when you're not at home.
Q: Did you eventually find a place then?
A: yes.
Q: Was it in an HDB?
A: No.
Q: Where was it you found a place?
A: First I had a private apartment in - the name of it, it was called Phoenix - Phoenix something. I don't recall.
A: Inasmuch as I had to have two guarantors, yes.
Q: What about the seven period?
A: That as well. That wasn't mentioned in the interview process. because it's noy only seven years, as it reads and as you know, it's seven years from the completion of training, which can take anywhere from a year to a year ans a half, so the total term can be up to eight and a half, nine years.
Q: And under paragraph 2.3, this is also concerned you, did it not? Take a minute and review it.
A: Yes it concerened me greatly.
Let's take a look at paragraph 6 and 6.1 under Scope of employment where it says: "You are required to serve SIA in any part of the world and on any of the routes served by SIA, including the operation of special chartered flights, passenger or freighter aircraft," do you see that?
A: Yes.
Q: Did you ever ask LM or anyone else about that paragraph being in contradiction to his statement that he didn't see any reason why you wouldn't be flying a 747?
A: So much as we've read, no, not at all. The 747 encompasses all those things.
Q: But you understood it was up to Singapore Airlines as to in what part of the world you would be in and what routes you would fly and what planes you would fly?
A: Yes. And as I stated before, all the statements that would give me the reason to believe that it was up to my performance to earn that assignment.
Q: But it was also based on availability, correct?
A: True, and there was plenty of that as well.
Q: We also see in paragraph 25 a statement that the applicable law for the purpose of your contract of employment will be the laws of Singapore, correct?
A: Yes.
Q: Did you at any time, prior to the institution of this litigation, undertake to determine what the laws of Singapore were in regards to the bonding agreement?
(Defendant's attorney): I'll object to that question to the extent it calls for materials which may be privileged under the attorney-client priviledge and caution you not to waive that privilege.
Q: I don't want to hear any conversations that you might have had, even prior to this litigation, with your attorneys at Bogle. But other than conversations with any attorneys that you might have had, did you undertake to learn about the singapore law meant in regard to your contract of employment?
A: Up to the time that I signed this document, the answer would be no.
Q: What about prior to the time you left Singapore airlines?
A: Yes.
Q: What did you inquire about?
(Defendant's attorney): I'm going to ask that I have a conference with my client at this point to explain to him the attorney-client privilege in more detail, as I have a feeling he doesn't quite appreciate it at this point.
Q: Let me ask a predicate question first.
Q: Any of these conversations about the application of law in Singapore prior to the time you left Singapore airlines, did they involve money?
A: Yes.
Q: Let me ask the question again. Did you have any conversations with anybody regarding the appliof Singapore law prior to the time you left Singapore airlines?
(Defendant's attorney): Same objection.
Q: That's just a yes or no question.
A: Yes.
Q: Did any of those conversations involve nonlawyers?
A: Yes.
Q: Tell me about the conversations that involved nonlawyers?
A: Particular other individuals who had tried to take action to relieve themselves of the bond. A group of 11, if I remember right, 11 Australians, tried to, through legal action, relieve the responsibility ot the bonding agreement. In the process, while they were told they would win -
Q: Pardon? While they were told what?
A: They were told by their lawyer they would win - this is the story, is what they would end up winning may be what they - not something they may not like. In other words, the retribution for having won would be something that wouldn't prolong their career in the airline. With that information they went to the Singapore ALPA, Airline Pilot's Association, and asked them for their assistance in the matter. They didn't end up getting any assistance. Instead what they were planning to do was divulge to management, and the response from management was to try and attempt for them to sign an agreement that they would not sue singapore airlines over the bond. I don't know that any of them signed it, but those individuals then were passed over for promotion.
Q: Did they end up leaving Singapore Airlines?
A: Some did yes.
Q: Did you know if they left prior to the time their bond had expired?
A: Yes.
Q: Was their litigation involving their bond?
A: I presume so.
Q: So your testimony is they went to the union, the Airline Pilot's Association, and the airline Pilot's Association then turned their names over to the company?
A: Yes. There is -
Q: Who told you this story?
A: Colleagues.
Q: Do you remember who, specifically?
A: It was frequent - one problem I have with specifically mentioning names is that they still work there, and this getting back to Singapore Airlines would result in admonishment that I don't want them to receive. The other thing was it was a common story amongst the foreign pilots, so any number of them know it.
Q: I'm entitled to know that information. It's part of discovery, and i do want the name.
(Defendant's attorney): Would like to take a brief recess?
The Witness: I think it's time for a break.
Q: We're between a question and answer. there is no question of privilege. Breaks are impermissible between a question and answer under rules, unless there is a qof privilege.
(Defendant's attornry): I understand that, and I would be happy to explain the situation and the ramifications of not answering this question to my client.
The Witness: That's my question at this point, if I don't answer the question, what are the ramifications?
Q: I will allow a break.
(Defendant's attorney): That's all I'm going to do.
Q: I want to go on the record to say that i think it is impermissible under the rules, but in the spirit of accommodation -
Q: I'll allow you to go ahead and ask him. Go ahead and talk to him.
(Brief recess)
Q: Who told you that informayion?
A: In addition to what I was saying about quite a common story amongst the pilots, and they would discuss it often, an individual, his name is GS, we discussed that information. Any other people that I discussed - numerous people discussed it with - the actual source of the story I honestly do not recall. There is - it's an Australian. he may not even be working with the company anymore, but I don't recall.
Q: But you recall that you discussed this with GS?
A: Yes.
Q: And that he told you about that information?
A: Yes.
Q: When did you learn about these 11 Australians and the bonding agreement?
A: Somewhere near the summer of 95.
Q: Prior to the time you signed the bonding agreement, and based on your discussion with the Boeing lawyer, you were concerned, I take it, that the bonding agreement was a form of indentured servitude, in your mind; is that correct?
A: Yes.
Q: And you knew that you were undertaking some risk when you signed it?
A: Yes.
Q: Did you have any other conversations with anyone at Singapore Airlines, other than LM, and the technical conversations you had with Mr.L, about the bonding agreement prior to the time you signed the acceptance of employment letter on Oct 20, 93?
A: Can I hear the question again, because it's the first part I don't remember.
(The record was read.)
A: Don't believe so.
Q: When did you then go to singapore?
A: Let's see, tha date of service was Nov 9th, so I arrived there, I believe, on the 8th.
Q: Did you find housing at that point?
A: No. We were given 10 days in the Paramount hotel on the company prior to having to have a place of our own.
Q: When did you find housing, approximately?
A: The last day of that.
Q: Around the middle of Nov?
A: Right, that's correct, which wasn't easy.
Q: It wasn't easy to find?
A: Those days were packed with other things to0 do for the company. it's also at that point when I - to do this I engaged a Realtor, basically, to help me locate a place based on what i anticipated for earnings, and that's when i found out that HDBs are not available, the governmensubsidized apartments, are not available for rent by non-singaporeans in whole. In other words, you could rent a room, in other words, boarder, but you could not rent the entire apartment, and what some Singaporeans do is lock up a room, but that doesn't meet the requirements of the law, and if that were to be discovered, I could be - and, of course, my wife could be evicted, not a very good thing to happen when you're not at home.
Q: Did you eventually find a place then?
A: yes.
Q: Was it in an HDB?
A: No.
Q: Where was it you found a place?
A: First I had a private apartment in - the name of it, it was called Phoenix - Phoenix something. I don't recall.
Guest
Posts: n/a
Gladiator,
I (and other PPRuNer's that I've spoken to), find this quite interesting. Is this being published as-it-happens, or has the case been completed.
One favor to ask. Could you please start a Part 2 to this thread. I don't wish for this thread to be locked...maybe the last entry could forward it to part 2...it's just starting to take a LONG time to load each time. Thanks.
I (and other PPRuNer's that I've spoken to), find this quite interesting. Is this being published as-it-happens, or has the case been completed.
One favor to ask. Could you please start a Part 2 to this thread. I don't wish for this thread to be locked...maybe the last entry could forward it to part 2...it's just starting to take a LONG time to load each time. Thanks.
Guest
Posts: n/a
Q: How long did you live in that apartment?
A: Two months. It turned out that that would be unsuitable for my wife if she were to move there. She would not be at all happy with it, so I went looking for someplace else.
Q: Did your wife come over in Nov with you?
A: March, it wasn't until the following March.
Q: Why did you decide your wife wouldn't like the Phoenix?
A: General condition. Again, the water heater was only available for shower itself, not for the cooking and cleaning - I mean for the cleaning in the kitchen. Another surprise is they have garbage chutes. they don't have dumpsters that you take garbage to down below. the garbage chute was notorious for smell, odor, and pests, cockroaches.
Q: So you had a lot of cockroaches in the apartment?
A: Not the German kind either, the Florida kind (indicating).
Q: Indicating huge?
A: In other words, not the small, the big. It came with a washer, but there was no dryer. To dry the clothes you had to put them onna stick that hung out the building, which would make your clothes prone to flying off into the breeze. All those sort of things, I had to find something different.
Q: How much did that apartment cost?
A: I believe that one was 2,000 Singapore dollars a month.
Q: So significantly more than you had been told?
A: Exactly.
Q: When did you find another apartment?
A: Approximately two, three weeks. Located -
Q: Are we talking then about December?
A: Yes. The lease, I think, was Dec 15th. I'm not sure.
Q: Where was this apartment?
A: This was located on east Coast Road. the address was xxx, and the name of it, Merlin Mansion, which it wasn't, a mansion, that is, four-story walk-up. We lived on the second floor, 900 sq feet, three bedroom. What we would call a living room actually one large, open hall or area, which would be your dinning room and living area and a kitchen. Only the bedrooms were air-conditioned at the time, with a washer. Again you've got to hang your clothes, but at least you didn't have to hang them out of the building. They were on a rack within the washer area. the rent for that was 2,600 a month.
Q: Was it clean?
A: Yes it was clean. At the time it was fine.
Q: Did it have hot water?
A: That was the other attractive feature, it had a five-gallon hot water tank that supplied hot water to all the spigots.
Q: Cockroaches?
A: No. Luckily we only found dead ones. Did have lizards though. We call them chameleons, they call them geckos.
Q: Were you concerend in December about the price of the housing and whether you would be able to make ends meet?
A: Yes.
Q: Did you ever talk to Ms. DY or LM about the fact that you couldn't get a place for 1100 as they told you?
A: Yes. They felt that I should be looking into the HDBs, but when I told them my concerns, they didn't think that that was something to worry about.
Q: Your concerns that people lock up apartments?
A: No, the concern that you end up thrown out, evicted if discivered.
Q: They felt that wasn't anything to worry about?
A: Yes.
Q: In the first couple of months did you experience any discrimination against Westerners?
A: The onlt discrimination - not from the airline. The discrimination experienced early on was purely a matter of pricing. With this apartment that I rented at 2600 a month, one of their claims was they were doing me a favor, because from a Japanese flight attendant they would get over 3,000 a month. In other words, their pricing was dependant on who it was they were renting to. Pricing for food at groceries, other than the formal chains, in other words, if you were buying groceries from a vendor, depended on whether you were Caucasian, a maid, or a local. pricing at shops were - pricing was a matter of barter, which included jewelry shops, clothing, et cetera. It was again, a matter of who you were and what you earned by virtue of race.
Q: And you experienced in those first couple of months that it would cost you more than a Singaporean to live in Singapore?
A: Yes.
Q: What about the air quality in the first couple of months, did you come to see that the air quality was ppor?
A: After I moved into the apartment on East Coast Road, yes, keeping - in other words, in just daily upkeeping, discovered the grime.
Q: What about the rats that you would see in public, did you discover that in the first few months you were there?
A: The first time I saw a rat actually was coming out of the garbage can at the apartment at East Coast Road complex's garbage bin. they lived on the other side of the wall in an underground nest.
Q: That was when?
A: It was in probably Jan of 94?
Q: And these unsafe transportation conditions, pedestrians being hit, when did you first observe that?
A: I think that was Feb where I almost got hit - where I was hit.
Q: Feb of 94?
A: Yes.
Q: Do you remember when in Feb?
A: Like I say, it's approximate. It was early on. My wife, hadn't yet arrived.
Q: So early in Feb?
A: First quarter, first quarter of the year anyhow.
Q: First quarter of the year, not first quarter of Feb?
A: No. First quarter of the year, sometime before she showed up in March.
Q: When did you realize that the pipes were seeping?
A: Pipe seepage didn't occur until afetr my wife moved in and our first vacation back, so it would be the latter of 94.
Q: In the first few months did you become concerned about being able to make ends meet in Singapore?
A: In the first few months I still had the expectation of getting assignment to the 44, becausee I had no reason to think otherwise. so I suspected that with thr income that came from that it would not be a problem, even witht the increase, from expectations.
Q: What about living conditions, in the first few months did you observe that living conditions were different than you thought they were going to be?
A: Yes.
Q: Showing you what has been marked exhibit 3, this is a 1992 agreement between singapore Airlines and the airline Pilot's Association; is that correct?
A: Yes.
Q: When did you receive a copy of this agreement?
A: I received a copy of this agreement back in Oct of 88 - no, Oct of 93 when I was - when I received my offer letter, i received a copy of this as well.
Rest to follow.
A: Two months. It turned out that that would be unsuitable for my wife if she were to move there. She would not be at all happy with it, so I went looking for someplace else.
Q: Did your wife come over in Nov with you?
A: March, it wasn't until the following March.
Q: Why did you decide your wife wouldn't like the Phoenix?
A: General condition. Again, the water heater was only available for shower itself, not for the cooking and cleaning - I mean for the cleaning in the kitchen. Another surprise is they have garbage chutes. they don't have dumpsters that you take garbage to down below. the garbage chute was notorious for smell, odor, and pests, cockroaches.
Q: So you had a lot of cockroaches in the apartment?
A: Not the German kind either, the Florida kind (indicating).
Q: Indicating huge?
A: In other words, not the small, the big. It came with a washer, but there was no dryer. To dry the clothes you had to put them onna stick that hung out the building, which would make your clothes prone to flying off into the breeze. All those sort of things, I had to find something different.
Q: How much did that apartment cost?
A: I believe that one was 2,000 Singapore dollars a month.
Q: So significantly more than you had been told?
A: Exactly.
Q: When did you find another apartment?
A: Approximately two, three weeks. Located -
Q: Are we talking then about December?
A: Yes. The lease, I think, was Dec 15th. I'm not sure.
Q: Where was this apartment?
A: This was located on east Coast Road. the address was xxx, and the name of it, Merlin Mansion, which it wasn't, a mansion, that is, four-story walk-up. We lived on the second floor, 900 sq feet, three bedroom. What we would call a living room actually one large, open hall or area, which would be your dinning room and living area and a kitchen. Only the bedrooms were air-conditioned at the time, with a washer. Again you've got to hang your clothes, but at least you didn't have to hang them out of the building. They were on a rack within the washer area. the rent for that was 2,600 a month.
Q: Was it clean?
A: Yes it was clean. At the time it was fine.
Q: Did it have hot water?
A: That was the other attractive feature, it had a five-gallon hot water tank that supplied hot water to all the spigots.
Q: Cockroaches?
A: No. Luckily we only found dead ones. Did have lizards though. We call them chameleons, they call them geckos.
Q: Were you concerend in December about the price of the housing and whether you would be able to make ends meet?
A: Yes.
Q: Did you ever talk to Ms. DY or LM about the fact that you couldn't get a place for 1100 as they told you?
A: Yes. They felt that I should be looking into the HDBs, but when I told them my concerns, they didn't think that that was something to worry about.
Q: Your concerns that people lock up apartments?
A: No, the concern that you end up thrown out, evicted if discivered.
Q: They felt that wasn't anything to worry about?
A: Yes.
Q: In the first couple of months did you experience any discrimination against Westerners?
A: The onlt discrimination - not from the airline. The discrimination experienced early on was purely a matter of pricing. With this apartment that I rented at 2600 a month, one of their claims was they were doing me a favor, because from a Japanese flight attendant they would get over 3,000 a month. In other words, their pricing was dependant on who it was they were renting to. Pricing for food at groceries, other than the formal chains, in other words, if you were buying groceries from a vendor, depended on whether you were Caucasian, a maid, or a local. pricing at shops were - pricing was a matter of barter, which included jewelry shops, clothing, et cetera. It was again, a matter of who you were and what you earned by virtue of race.
Q: And you experienced in those first couple of months that it would cost you more than a Singaporean to live in Singapore?
A: Yes.
Q: What about the air quality in the first couple of months, did you come to see that the air quality was ppor?
A: After I moved into the apartment on East Coast Road, yes, keeping - in other words, in just daily upkeeping, discovered the grime.
Q: What about the rats that you would see in public, did you discover that in the first few months you were there?
A: The first time I saw a rat actually was coming out of the garbage can at the apartment at East Coast Road complex's garbage bin. they lived on the other side of the wall in an underground nest.
Q: That was when?
A: It was in probably Jan of 94?
Q: And these unsafe transportation conditions, pedestrians being hit, when did you first observe that?
A: I think that was Feb where I almost got hit - where I was hit.
Q: Feb of 94?
A: Yes.
Q: Do you remember when in Feb?
A: Like I say, it's approximate. It was early on. My wife, hadn't yet arrived.
Q: So early in Feb?
A: First quarter, first quarter of the year anyhow.
Q: First quarter of the year, not first quarter of Feb?
A: No. First quarter of the year, sometime before she showed up in March.
Q: When did you realize that the pipes were seeping?
A: Pipe seepage didn't occur until afetr my wife moved in and our first vacation back, so it would be the latter of 94.
Q: In the first few months did you become concerned about being able to make ends meet in Singapore?
A: In the first few months I still had the expectation of getting assignment to the 44, becausee I had no reason to think otherwise. so I suspected that with thr income that came from that it would not be a problem, even witht the increase, from expectations.
Q: What about living conditions, in the first few months did you observe that living conditions were different than you thought they were going to be?
A: Yes.
Q: Showing you what has been marked exhibit 3, this is a 1992 agreement between singapore Airlines and the airline Pilot's Association; is that correct?
A: Yes.
Q: When did you receive a copy of this agreement?
A: I received a copy of this agreement back in Oct of 88 - no, Oct of 93 when I was - when I received my offer letter, i received a copy of this as well.
Rest to follow.
