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| 12 MONTH FMLA PERIOD |
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| America West Airlines told employees in a handbook that they could take 12 weeks within any 12 month period. The Airline argued it was a rolling 12 month period. An employee needed a 12 month calendar period. The Ninth Circuit ruled that the handbook was not clear, so whatever method of calculating the 12 month period that helps the employee will be used. |
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| (Bachelder v. America West Airlines) |
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