EXHIBIT A

Case 1:22-cv-23519-KMM Document 31-1 Entered on FLSD Docket 02/06/2023 Page 1 of 8
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

ESTATE OF LANE CAVINESS, et al.,

Plaintiffs,

v.

ATLAS AIR, INC., et al.,

Defendants. 

Case No. 1:22-cv-23519-KMM-LFL

DECLARATION OF CARLEEN A. YBARRA ON BEHALF OF DEFENDANTS 

ATLAS AIR, INC., JOHN W. DIETRICH, PATRICIA GOODWIN-PETERS, 

AND JEFFREY CARLSON

I, Carleen A. Ybarra, declare as follows:

1. I currently serve as Director Employee Relations & Workforce Solutions for 

Atlas Air, Inc. (“Atlas”). I have held this position since July 19, 2021. I have personal 

knowledge of the information herein. 

2. Atlas is a Delaware corporation. Its principal place of business and corporate 

headquarters are located at 2000 Westchester Avenue, Purchase, New York, and its senior 

leadership team manages Atlas’s worldwide operations from there. Atlas employs 

approximately 4,354 domestic active employees located in airports across the country, Atlas’s 

corporate headquarters, and all of its offices. 

3. Atlas’s wholly owned parent company, Atlas Air Worldwide Holdings, Inc. 

(“AAWW”), is also a Delaware corporation with its principal place of business in Purchase, 

New York.

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4. Atlas’s policies concerning the COVID-19 vaccine—including its reasonable 

accommodations policy—were developed and executed primarily by employees based in 

New York and, during pandemic conditions, working from other states in the Northeast.

5. Atlas maintains operational centers at the following airports throughout the 

continental United States: Anchorage, Chicago-O’Hare, Cincinnati, John F. Kennedy, Los 

Angeles, and Miami. This means that just one of Atlas’s operation centers is located in Florida. 

6. Only 14.5% of Atlas’s U.S. workforce has a Florida duty station—634 out of a 

domestic workforce of 4,354. From January 2021 through October 2022 (when this litigation 

commenced), take offs and landings in Florida never represented more than 9% of total monthly 

flights.

7. Atlas maintains a training center in Miami, Florida and conducts a small 

percentage of its operations in the state. Flight Crew training takes place at the Miami training 

center, and certain specialized ground employees based in Miami also receive the training 

specific to their position in Miami. 

8. In their Complaint (¶ 130), Plaintiffs allege that Atlas’s Miami training center 

contains “30,000 square feet of administrative and instructional space.” Yet, Atlas maintains far 

greater space elsewhere—including over 150,000 square feet of space in Kentucky, over 100,000 

square feet in California, and over 65,000 square feet of space in New York—as well as 

significant physical plants at locations across the country (and internationally, including over 

22,007 square feet in Hong Kong, 4,800 square feet in Shanghai, and 4,300 square feet in South 

Korea).

9. Atlas’s workforce outside of Florida far outnumbers its workforce inside of 

Florida. In Kentucky alone, Atlas has 1,365 employees—more than double the number of 

Case 1:22-cv-23519-KMM Document 31-1 Entered on FLSD Docket 02/06/2023 Page 3 of 8
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employees who work in Florida. Atlas also has 537 employees in Alaska, 538 employees in 

California, 731 in New York, 206 in Illinois, 163 in Texas, and other employees based in 14 

other states and various foreign countries. 

10. Atlas’s Ground Operations Support and Facilities, Accounting, Finance, Financial 

Planning and Analysis, Safety, Administration, Systems Operations, Defense & Government 

Programs, Sales & Marketing, Communications, Legal, and Human Resources functions all are 

based in New York. Atlas’s Flight Operations (including Scheduling and Planning) are based in 

New York and Kentucky. Some of these Atlas functions maintain staff in other offices, but are 

still led from New York. 

11. Atlas’s principal executive offices are also located in New York. 

12. Atlas’s board meetings typically take place in New York or in Washington, D.C. 

The most recent board meeting took place in New York. 

13. Atlas services its wholly owned parent company’s stock (AAWW) in New York. 

That stock currently trades on the NASDAQ, in New York. Atlas’s parent company has entered 

into a definitive agreement to be acquired by an investor group. Upon completion of the 

transaction, Atlas’s parent will become a privately held company and shares of AAWW stock 

will no longer be listed on the NASDAQ.

14. In my capacity as Director Employee Relations & Workforce Solutions, I am 

familiar with Atlas’s process of maintaining employment records. It is the regular practice of 

Atlas for its employees to create and update a record for each Atlas employee that includes 

(among other things) the location where the employee works (i.e., has his/her base of operation) 

and where the employee resides. Atlas keeps these employee records in the course of its 

regularly conducted business activities. Based on a review of Atlas’s regularly maintained 

Case 1:22-cv-23519-KMM Document 31-1 Entered on FLSD Docket 02/06/2023 Page 4 of 8
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employment records, the Plaintiffs include current and former pilots and ground operations 

personnel.1

 As set forth in the below table, 62 of the 98 Plaintiffs currently or formerly 

employed by Atlas in this action have no tie to Florida, while another 15 do not work in Florida, 

but only live there.

Last Name First Name Employee 

Type

Work 

Location

(State)

Home 

Location 

(State)

Akerlund Patrick Pilot AK AK

Alzati Michael Pilot TN FL

Anderson Eric Pilot KY KY

Ballard Jr. Michael Pilot KY KY

Bearce Jr. Larry Pilot FL IA

Bellman Robert Pilot FL FL

Bendiburg Benjamin Pilot TX NH

Berry Gregory Pilot AK GA

Berry* Douglas Pilot AK GA

Bohnert Douglas Pilot IL CO

Botha Lynette Pilot CA SD

Buehrer* Caleb Pilot IL TX

Bullock Richard Pilot FL FL

Carroll Jon Pilot KY NC

Caskey Vergil Pilot AK OK

Castor James Pilot CA CO

Chapman Brett Pilot AK AK

Charboneau Nathan Pilot KY MI

Churchel Shawn Pilot CA FL

Colon Joel Pilot KY FL

Connor Mark Pilot TX TN

Cronauer Matthew Pilot CA VA

Cunningham* Fred Pilot CO CO

Danza Royal Pilot CA AZ

De Sousa Elliot Pilot IL CO

Desandro Eric Pilot FL FL

Dixon Steve Pilot KY TN

Erickson James Pilot CA ID

Esquivia Luis Pilot CA FL

 

1 Individuals noted with an asterisk (*) next to their last name in the table are no longer 

employed with Atlas.

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Last Name First Name Employee 

Type

Work 

Location

(State)

Home 

Location 

(State)

Estate of Lane Caviness2 Pilot (Lane 

Caviness)

FL (Lane 

Caviness)

TX (Lane Caviness)

Estes Lee Pilot KY AL

Fratti Robert Pilot CA ID

Frisbie Jason Pilot CA AK

Frye Timothy Ground 

Operations

FL FL

Fussle Jonathan Pilot NY IN

Gamboa Tony Pilot FL FL

Gebhard Dennis Pilot FL FL

Ghods Reza Pilot CA FL

Gilman Mark Pilot OR AR

Giudice Robert Pilot CA UT

Gordon Eric Pilot IL PA

Gordon Greg Pilot NY OK

Greer* Daniel Pilot CA CA

Heivilin Rexford Pilot FL GA

Henning Jason Pilot KY KS

Hewson David Pilot KY FL

Hontz Todd Pilot FL FL

Hudson Daniel Pilot CA TX

Justice Roger Pilot KY IN

Kassandji Venancio Pilot FL FL

Kearins John Pilot FL NH

Keen David Pilot KY GA

Kinder Ricky Pilot KY IA

Kirby Beth Pilot KY SC

Koustas Andreas Pilot FL NH

Kravetz Chad Pilot FL FL

Lee Daniel Pilot AK AK

Lindberg Carl Pilot CA AZ

Loschiavo Joseph Pilot KY AL

Lutz Andrew Pilot KY FL

Lutz Blythe Pilot KY FL

Macario Rafael Pilot KY FL

Mayo Jr. Douglas Ground 

Operations

FL FL

 

2 Plaintiffs’ Complaint is silent as to the residency or place of employment as to 

Lane Caviness (deceased) or for the representatives of his Estate: Plaintiff Landon Caviness and 

Plaintiff Morgan Caviness are not Atlas employees. 

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Last Name First Name Employee 

Type

Work 

Location

(State)

Home 

Location 

(State)

McMillan Montague Pilot KY ID

McQuillen April Pilot KY FL

McQuillen Christopher Pilot KY FL

Meissner* Steven Pilot AK FL

Michonski Jeffrey Pilot OR VA

Mickler Andrew Pilot AK AK

Morris Corey Pilot FL FL

Muratore Steven Pilot FL FL

Myers Gregory Pilot CA CA

Napora Peter Pilot CA AZ

Pardo Joel Ground 

Operations

FL KY

Phillips Patrick Pilot TN TX

Phillips* Lance Ground 

Operations

FL CO

Pittet* Siegfried Pilot AK TX

Pronk Glen Pilot KY KY

Randall Charles Pilot IL PA

Raymond Peter Pilot KY TX

Roberts Joshua Pilot KY OH

Rogers Jason Pilot CA CA

Samson Gregory Pilot AK ID

Schreck Kimberly Ground 

Operations KY KY

Serritella* William Pilot NY FL

Shelton Gentry Pilot TX TX

Snaza Todd Pilot FL SD

Sorrentino Donald Pilot NY NH

South Mark Pilot KY KY

Stark Michael Pilot CA TX

Staton Austin Pilot AK AK

Stowells Forrest Pilot OR WA

Swift John Pilot CA CA

Taylor Nick Pilot AK AZ

Thompson William Pilot FL FL

Thoroughman Brandon Ground 

Operations KY IN

Verdes Gustavo Pilot FL AZ

Villella James Pilot KY FL

Zarrabian Farshad Pilot CA FL

Case 1:22-cv-23519-KMM Document 31-1 Entered on FLSD Docket 02/06/2023 Page 7 of 8
Pursuant to 28 U .S.C. § 1746, 1 declare under penalty of perjury that the foregoing is true 

and correct. 

Executed on February 2. 2023. 

Carleen A. a,,Y, 

Director Ef Joye Re ations & Workforce Solutions

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