In deposition testimony dated May 15, 1998, Jack Strandell, MIA Ramp Manager, testified that it is UAL's policy to retaliate against employees who file EEO complaints against the Company. Mr. Strandell's deposition regarded a copy of United's Series 15 "Harassment and Discrimination" policy, dated January 11, 1996, which he had handed out to a UAL employee.

This Series 15 policy to which Mr. Strandell testified, was submitted as an evidentiary document in another recent federal lawsuit against United Air Lines. In response, Jennifer Ansbro Hale, Senior Counsel, United Air Lines, Inc., submitted a "Declaration," alleging that this Series 15 policy "was never drafted, implemented, or published" by United. Although Ms. Hale claims that this is a false document, United has never submitted the actual policy that did exist on January 11, 1996. United has only submitted policies that were published after this date.

If the policy Mr. Strandell gave a United employee is a fraudulent document as alleged by Ms. Hale, then Mr. Strandell must have committed perjury when he testified under oath that this was United's corporate policy. If Mr. Strandell did commit perjury, then one would expect his employment to be terminated, as he has violated numerous corporate policies and federal laws.

However, when Mr. Strandell was deposed a second time only a few months ago, he was still employed as the MIA Ramp Manager, and it appeared that no disciplinary actions have been taken against him. Perhaps he was telling the truth during his deposition? United's consistent retaliatory actions towards their employees who file EEO complaints further seems to support Strandell's testimony.

Specifically, the Harassment and Discrimination Policy states:

" United Airlines prohibits Employees to bring any complaints to the attention of the Equal Employment Opportunity Commission (EEOC). " and,

" Any attempt to resolve alleged incidents of Harassment or Discrimination outside 'The Network' could result in further disciplinary action, up to and including discharge from the company. "

The following are excerpts from Mr. Strandell's deposition testimony:

ATTORNEY: Let's have this marked Exhibit No. 9 for Identification. Look at Plaintiff's Exhibit No. 9, and tell me if you recognize that document.

Let me ask you first, is that your handwriting on there?

STRANDELL: Yes.

ATTORNEY: Do you recall writing that on that document?

STRANDELL: No, I don't.

ATTORNEY: Do you recall that document at all, the content of that document? Because it mentions something about company procedures, regulations regarding The Network. Would that be that document?

STRANDELL: Maybe that's talking The Network document. I just don't --

ATTORNEY: Is that what you were referring to when you said there was a company rule or regulation on that?

STRANDELL: Yes.

ATTORNEY: And according to the statement that's on this document that in your handwriting it says: "Jeff, these are the items Joyce [Sechler] said she would give you. Thanks, Jack."

Do you recall Joyce giving you those documents, any kind of documents to give to Jeff? Does that refresh your recollection?

STRANDELL: Not at all.

ATTORNEY: Do you agree with the policy and procedure that's in there?

STRANDELL: Yes.

ATTORNEY: Specifically, my question was, did you receive any training from United Airlines with regard to the issue of employment discrimination?

STRANDELL: Well, we have videos that we go through that outline the course, but you do not retaliate against employees if they bring complaints to you. If that's what you mean, sure.

ATTORNEY: It would be improper to your knowledge any way to retaliate against an employee for bringing a sex discrimination complaint?

STRANDELL: Oh, absolutely.

ATTORNEY: That's improper?

STRANDELL: Sure.

ATTORNEY: And it would be improper to discourage an employee from going outside United Airlines to file a charge of discrimination with the Equal Employment Opportunity Commission?

STRANDELL: No.

ATTORNEY: It wouldn't be improper for the company to prevent them from doing that, from discouraging them from doing that?

STRANDELL: No.

ATTORNEY: Would it be improper for someone such as yourself in management to discipline an employee who had filed a charge of discrimination with a federal agency such as the Equal Employment Opportunity Commission?

STRANDELL: No, not unless it was found to be untrue.

ATTORNEY: I'm just talking about the fact that they filed a charge of discrimination. Whether its true or not --

STRANDELL: No.

ATTORNEY: You couldn't do that?

STRANDELL: No. What I'm saying is you wouldn't discipline an employee because he's gone and filed, as you say, a discrimination suit or whatever like that. I wouldn't discipline an employee for that.

But once it's investigated and it's found that there was no cause for discrimination, then yes, there is a chance.

ATTORNEY: Referring now back to Plaintiff's Exhibit No. 9, which you identified as rules and regulations pertaining to the use of The Network at United Airlines.

Do you think that rule and regulation in any way discourage employees from going outside The Network and pursuing their claims through an outside agency, such as the Equal Employment Opportunity Commission?

STRANDELL: Well it states you should go to your management first.

ATTORNEY: Doesn't it also say that United Airlines prohibits employees to bring any complaints to the attention of the Equal Employment Opportunity Commission? Does it say that?

STRANDELL: Yes.

ATTORNEY: And you agree with that policy?

STRANDELL: That it says that, yes.

ATTORNEY: You agree that that was United Airlines' policy?

STRANDELL: Yes. Can we take a quick break?

ATTORNEY: For what reason?

STRANDELL: I need to go to the bathroom.