Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, Plaintiff Northwest Airlines, Inc. ("Northwest") propounds this First Request for the Production of Communications Equipment for Inspection and Copying to Kevin Griffin. The communications equipment requested for production include computers; computer hard drives; floppy disks; hard disks; removable media; backup tapes; servers; CD-ROMs; zip disks; other electronic, magnetic, or optical storage devices; other computer equipment; voice-mail and answering machine tapes; or other electronic storage media, used for purposes described herein (collectively referred to as "Equipment"). The Equipment is to be produced within fifteen days of service hereof at the offices of Ernst & Young, 2400 Pauahi Tower, 1001 Bishop Street, Honolulu, HI 96813, or at

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such other reasonable time and place as may be mutually agreed upon by counsel for Defendants and Northwest

1. These requests for production are continuing in nature. You must supplement or amend your responses to these requests pursuant to Rule 26(e) of the Federal Rules of Civil Procedure.

2. If any of the following requests cannot be responded to in full after exercising due diligence to secure the information, so state and respond to the extent possible, specifying your inability to respond to the remainder, stating whatever information you have concerning the unanswered portions.

3. If your response to any of these requests is qualified in any particular manner, set forth the details of such qualification.

4. In responding to these requests, produce all Equipment that is available to you including not only Equipment immediately available to your counsel, but also that is available to or in the "possession, custody or control" of you or any agent of yours. Equipment is deemed to be within your "possession, custody or control" if you have the right to acquire the Equipment from another person or public or private entity having possession of the Equipment.

5. Unless otherwise specified or required by the context of the request, references to the singular include the plural, references to the plural include the singular, references to one

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gender include the other gender, references to the past tense include the present, and references to the present tense include the past.

6. Pursuant to the Federal Rules of Civil Procedure, if any Equipment responsive to this request is withheld under a claim of privilege, in order that the Court and the parties may determine the validity of the claim of privilege, you must set forth in your response to this request a schedule which specifically provides for each item of Equipment withheld:

a. a specific description of the item of Equipment withheld, the type of information contained on the item of Equipment withheld, the volume of information contained on the item of Equipment withheld, and any other information necessary to sufficiently identify the Equipment withheld and to permit evaluation of the claim of privilege;

b. a specific statement of the basis upon which privilege is claimed; and

c. whether any non-privileged or non-protected matter is included in the Equipment.

7. If you object to part of a request and refuse to respond to that part, you must produce all Equipment called for which are not subject to that objection. Similarly, wherever Equipment is not produced in full, please state with particularity the reason or reasons it is not being produced in full, and describe, to the best of your knowledge, information and belief, and with as much particularity as possible, those portions of the Equipment which are not produced. If you object to a request's scope or time period, state your objection and respond to the request for the scope or time period you believe is appropriate.

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8. Unless otherwise specified, the time period covered by these requests is from January 1, 1999, to the date of trial in this matter.

9. The following Requests do not seek any Equipment relating solely to the negotiating positions or collective bargaining strategies of Local 2000, except insofar as they relate to or discuss HAVOC, or Work To Rule, or Work To Contract, of Fly The Contract, or Sick-Out, or Slowdown or any other suggestion or statement regarding methods, means, or tactics which might be employed by one or more flight attendants to express displeasure with the collective bargaining positions or to bring pressure upon Northwest to change collective bargaining positions.

10. Wherever it is reasonably practicable, please produce Equipment in such a manner as will facilitate its identification with the particular request or category of requests to which it is responsive. In accordance with Rule 34(b) of the Federal Rules of Civil Procedure, the Equipment shall be labeled to correspond with the following requests by number.

1. "Date" means the exact day, month, and year, if ascertainable, or, if not, the best approximation (including relationship to other events).

2. "Northwest" means Northwest Airlines, Inc., and/or any employees, agents, persons or entities acting on its behalf, whether individually or collectively.

3. "You" or "Your" means Kevin Griffin, and/or any persons or entities acting on the behalf of Kevin Griffin, including but not limited to any and all agents, employees,

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representatives, or attorneys. These requests seek all Equipment available to You and Your agents or representatives, including all Equipment available to your attorneys or anyone else acting on your behalf.

4. "Defendant" (and the plural thereof) means the International Brotherhood of Teamsters, AFL-CIO; IBT Local 2000; Billie Davenport; Al Habib; Danny Campbell; Anne Toombs; Lovey Offerle; Joan Prince Crandall; Shadlea Bennett-Williams; Andrew Damis; Local 2000's Contract Action Team; Local 2000's HAVOC Committee; the Rank and File Action Team; Jose Ibarra; Kristi Valenzuela; Bierne Des ilets; Scott Vanspeybroeck; Carl Badynee; Dorothy Hutchinson; Ashley McNeely; Kaki Androsiuk; Gary Helton; Bob Boehm; Lou Rudy; Kevin Griffin; and Ted W. Reeve; and/or any persons or entities acting on any of their behal{including but not limited to any and all of their agents, employees, representatives, or attorneys.

5. "Local 2000" means International Brotherhood of the Teamsters, AFL-CIO, Local 2000.

6. "HAVOC" means any program, plan, campaign, or other effort to exert pressure on Northwest Airlines in flight attendant collective bargaining; HAVOC is sometimes refeffed to as "Having A Voice in Our Contract" and/or "Have A Vacation Over Christmas."

7. "Work to rule, " "work to contract" and "fly the contract" mean any program, plan, campaign or other effort to change the normal manner or method by which Northwest flight attendants have generally performed their duties as flight attendants for Northwest.

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8. "Sick-out" means any program, plan, campaign or other effort to encourage increased use of sick time by flight attendants.

9. "Slowdown" means any program, plan, campaign or other effort to change the normal manner, method, duration or frequency by which Northwest flight attendants have generally performed their duties as flight attendants for Northwest.

10. "Equipment" means computers; computer hard drives; floppy disks; hard disks; removable media; backup tapes; servers; CD-ROMs; zip disks; other electronic, magnetic, or optical storage devices; other computer equipment; voice-mail and answering machine tapes; or other electronic storage media.

11. "Concerning" means in any way describing, reflecting, embodying, contained in, referring to, relating to, connected with or pertaining to, in whole or in part.

12. "Person" means an individual, firm, partnership, corporation, proprietorship, association, governmental body or agency, or any other organization or entity unless specifically stated otherwise.

13. "Statement" or "statements" mean any and all conversations, comments and other written, verbal or electronic communications.

14. "Communicates" and "communication" mean every matter or means of disclosure or exchange of information, whether orally, by document or otherwise, and whether face-to-face, in a meeting, by telephone, voice-mail, mail, e-mail, personal delivery or otherwise.

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15. "And" and "or" shall be individually interpreted in every instance as meaning "and/or" and shall not be interpreted conjunctively or disjunctively to exclude any information otherwise within the scope of any request.

16. "Each" means each and every, and "every" means every and each.

17. "Any" means any and all, and "all" means all and any.

18. "Job Action" means "work to rule," "work to contract," "fly the contract," "sick-out," and "slowdown," as those terms are defined above, plus any other action taken by a Northwest flight attendant to alter the manner, duration, frequency or method by which Northwest flight attendants perform their duties as flight attendants for Northwest.

Request No.1.

All Equipment owned, leased, operated or otherwise used by You to draft, prepare, read, record, review, or store any message, document or communication concerning:

a. HAVOC, or Work To Rule, or Work To Contract, of Fly The Contract, or Sick-Out, Slowdown, Job Action ; or

b. any other suggestion or statement regarding methods, means, or tactics which might be employed by one or more flight attendants to express displeasure with Northwest's or Local 2000's collective bargaining positions or to bring pressure upon Northwest to change collective bargaining positions.

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By:

Timothy R.Thomton (109630)

Scott G. Knudson (141987)

BRIGGS & MORGAN

2400 IDS Center

80 South Eighth Street

Minneapolis, MN 55402

(612) 334-8400

John J. Gallagher

Margaret H. Spurlin

Glenn Merten

PAUL, HASTINGS, JANOF SKY & WALKER LLP

~299 Pennsylvania Avenue, N.W.

Washington, D.C. 20004

(202) 508-9500

Attorneys for Plaintiff

Northwest Airlines, Inc.

I hereby certify that copies of the foregoing First Request for the Production of Communications Equipment for Inspection and Copying to Kevin Griffin were served via Overnight Express Mail (Federal Express) this 7th day of January, 2000, upon:

Michael B. Bloom

Miller O'Brien Bloom, P.L.L.P.

1208 Plymouth Building

12 South Sixth Street

Minneapolis, MN 55402

Attorney for Local 2000 and Billie Davenport

Roland Wilder

Baptiste & Wilder

Suite 500

1150 Connecticut Avenue NW

Washington, DC 20036

Attorney for International Brotherhood of Teamsters

and by overnight delivery upon:

Kevin Griffin

2333 Kapiolani Boulevard

Honolulu, HI 96826