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based upon age and to promote employment of persons within said group."
In the instant case involving Respondent, since Complainant is a resident of New York and Respondent, Eastern Airline, is New York based, this is the proper forum in which to bring suit, and obviously New York law should apply. Kilberg vs. Northeast Airlines 9 N.Y. 2d 34.

WHEREFORE, complaint Micheal A. Gitt prays this tribunal issue an order pursuant to Section 297 of the New York State Human Rights Law requiring respondents to cease and desist from all such unlawful discriminatory practices as previously described herein including but not limited to the following:
(1) The refusal of respondents to re-hire and re-employ complainant in the capacity of aviation flight instructor, supervisory pilot, test pilot, check pilot, or ferry pilot;
(2) The enforcement of each and every provision of the collective bargaining agreement (respondent exhibit "L") between respondent and the Airline Pilots Association which result in the discriminatory deprivation of the right of employment of complainant, including but not limited to the following provisions:
(a) Section 25 on page 25 - paragraph (a) which states in substance that a pilot who cannot maintain a valid airline pilot competency certificate is taken off the seniority list;

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