JOINT LIST OF EXHIBITS ADMITTED DURING THE PRELIMINARY INJUNCTION HEARING PAGE 1

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS

DAVID SAMBRANO, individually and on 

behalf of all others similarly situated, et al.,

Plaintiffs,

v. Civil Action No.: 4:21-01074-P

UNITED AIRLINES, INC., 

Defendant.

JOINT LIST OF EXHIBITS ADMITTED DURING 

THE PRELIMINARY INJUNCTION HEARING

Listed below are all exhibits Plaintiffs admitted during the Preliminary Injunction 

hearing held on October 13-14, 2021:

EXHIBIT NO. DESCRIPTION

1 Affidavit of David Eric Sambrano (ECF No. 7 at 1–5)

2 Affidavit of Kimberly Anne Hamilton (ECF No. 7 at 6–11)

3 Affidavit of Seth Adam Turnbough (ECF No. 7 at 12–16)

4 Affidavit of David Michael Castillo (ECF No. 7 at 17–21)

5 Affidavit of Debra Jennefer Thal Jonas (ECF No. 7 at 22–26)

6 Affidavit of Genise Gale Kincannon (ECF No. 7 at 27–31)

7 Affidavit of David Llen Lockwood (ECF No. 7 at 32–35)

8 Copy of text K. Hamilton submitted in support of RAP 

9 Coronavirus Q&A Updated September 7, 2021 from Flying 

Together 

10 September 19, 2021 email from Jodi Stringfellow to all DFW 

employees 

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JOINT LIST OF EXHIBITS ADMITTED DURING THE PRELIMINARY INJUNCTION HEARING PAGE 2

EXHIBIT NO. DESCRIPTION

11 August 4, 2021 letter from Dr. George Katsamakis 

12 May 20, 2021 page from Dr. George Katsamakis’ progress notes 

on exam of S. Turnbough 

13 September 21, 2021 email from United to S. Turnbough 

14 United HelpHub internet document “COVID-19 Vaccination: 

Medical Accommodations” as of September 29, 2021 

15 August 25, 2021 letter from D. Sambrano to United HR in 

support of RAP

16 September 14, 2021 COVID-19 Vaccine Medical Exemption 

form submitted to United by D.J. Jonas 

17 August 18, 2021 Screenshot of G. Kincannon’s explanation of 

need for RAP 

18 Declaration of Dr. Jayanta Bhattacharya

19 Curriculum Vitae of Dr. Jayanta Bhattacharya

20 Declaration of Fred Bates

21 Curriculum Vitae of Fred Bates

22 Hiam Chemaitelly et al., Waning of BNT162b2 vaccine protection 

against SARS-CoV-2 infection in Qatar, MEDRXIV, Aug. 27, 2021

(preprint), doi:10.1101/2021.08.25.21262584. (FN17)

23 Zachary J. Madewell et al., Household Transmission of SARS-CoV2: A Systematic Review and Meta-analysis, 3 JAMA NETW. OPEN 

e2031756 (2020). (FN35)

24 Sivan Gazit et al., Comparing SARS-CoV-2 natural immunity to 

vaccine-induced immunity: reinfections versus breakthrough 

infections, MEDRXIV, Aug. 25, 2021, 

https://doi.org/10.1101/2021.08.24.21262415. (FN46)

25 Richard K. Zimmerman, Helping patients with ethical concerns 

about COVID-19 vaccines in light of fetal cell lines used in some 

COVID-19 vaccines, 39 VACCINE 4242–4244 (2021). (FN58)

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EXHIBIT NO. DESCRIPTION

26 Supplemental Affidavit of Deba Jennefer Thal Jonas (ECF No. 38 

at 1-4)

27 September 9, 2021 Email from HelpHub to David Sambrano

28 United Airlines’ employee website as of October 5, 2021, labeled 

Covid-19 Vaccination: Religious Accommodation

29 Video Clip of Scott Kirby during United Town Hall

30 Kincannon – Email Link to United “COVID-19 Vaccination: 

Religious Accommodations” from United Website

31 Supplemental Declaration of Debra Jennefer Thal Jonas, attaching 

documents submitted during RAP

32 United: What to Expect When You Fly

Listed below are all exhibits Defendant admitted during the Preliminary Injunction hearing 

held on October 13-14, 2021:

EXHIBIT NO. DESCRIPTION

1 United’s COVID-19 Vaccination Policy dated Aug. 5, 2021

2 United’s COVID-19 Vaccination Policy dated Aug. 23, 2021

3 Face Covering / Mask Policy dated Aug. 18, 2021

4 Demonstrative Chart of Accommodation Requests

5 Spreadsheet of United Employees Who Received Remote Work

as Accommodation as of Oct. 1, 2021

6 Chart of United Costs Related to COVID-19 Insurance Claims

7 Email Sent to Employees Requesting a Reasonable

Accommodation dated Sept. 9, 2021

8 Explanation of Medical Accommodations, Available on Help Hub

9 Explanation of Religious Accommodations, Available on Help

Hub

10 Pilot Bulletin No. 21-273 Regarding “Face Mask Requirements

and Eye Protection Guidance” Effective Sept. 30 – Dec. 31, 2021

11 SRA Regarding Usage of Facemasks

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EXHIBIT NO. DESCRIPTION

12 Employee Vaccine Postcard dated Aug. 30, 2021

13 OSHA Complaint No. 1818391

14 Expert Report of Dr. Carlos Del Rio dated Oct. 5, 2021

15 CV of Professor Shane Crotty dated Oct. 2, 2021

16 Declaration of Shane Crotty1

17 Declaration of Kirk Limacher

18 Supplemental Declaration of Kirk Limacher

19 David Sambrano Flight Schedules, Jan. 1, 2018-present

20 Genise Kincannon Flight Schedules, Jan. 1, 2018-present

21 Seth Turnbough Flight Schedules, Jan 1, 2016-present

22 Seth Turnbough Sept. 2021 Pay Register

23 David Lockwood Vaccination Card dated Sept. 2, 2021

24 Letter to Employees on Leaves of Absence

25 Letter to Employees on Leaves of Absence FA&Pilot

26 Reasonable Accommodations Notifications Language as of Sept.

26, 2021

27 Reasonable Accommodations Vaccine Notifications

28 Basics of COVID-19, Centers for Disease Control and Prevention 

(May 24, 2021), https://www.cdc.gov/coronavirus/2019-

ncov/your-health/about-covid-19/basics-covid-19.html

29 Delta Variant: What We Know About the Science, Centers for 

DiseaseControl and Prevention (Aug. 26, 2021),

https://www.cdc.gov/coronavirus/2019-ncov/variants/deltavariant.html

30 Reduced Risk of Reinfection with SARS-CoV-2 After COVID-19

Vaccination— Kentucky, May–June 2021, Centers for Disease

Control and Prevention(Aug. 13, 2021), at

https://www.cdc.gov/mmwr/volumes/70/wr/mm7032e1.htm

31 SARS-CoV-2 Infections and Hospitalizations Among Persons

Aged ≥16Years, by Vaccination Status — Los Angeles County, 

California, May 1–July25, 2021, Centers for Disease Control and 

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JOINT LIST OF EXHIBITS ADMITTED DURING THE PRELIMINARY INJUNCTION HEARING PAGE 5

EXHIBIT NO. DESCRIPTION

Prevention (Aug. 27, 2021), at

https://www.cdc.gov/mmwr/volumes/70/wr/mm7034e5.htm

32 Transcript of March 27, 2020 Outreach Webinar, U.S. Equal

EmploymentOpportunity Commission (Mar. 27, 2020), at

https://www.eeoc.gov/transcript-march-27-2020-outreachwebinar#q1

October 18, 2021

Respectfully submitted,

/s/ Robert C. Wiegand

Robert C. Wiegand

Texas Bar No. 00791924

bob.wiegand@swolegal.com

Melissa J. Swindle

Texas Bar No. 24013600

Melissa.swindle@swolegal.com

Stewart Wiegand & Owens PC

325 N. St. Paul Street, Suite 3750

Dallas, TX 75201

Telephone: (469) 899-9800

Facsimile: (469) 899-9810 

Counsel for Plaintiffs and the 

Proposed Class

And

/s/ Russell D. Cawyer

Russell D. Cawyer

State Bar No. 00793482

Kelly Hart & Hallman LLP

201 Main St., Ste. 2500

Fort Worth, Texas 76102

Telephone: (817) 878-3562

Facsimile: (817) 335-2820

Email: russell.cawyer@kellyhart.com

Counsel for Defendant United 

Airlines, Inc.

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CERTIFICATE OF SERVICE

A true and correct copy of the foregoing has been served via the Court’s electronic filing 

system upon all counsel of record.

/s/ Robert C. Wiegand

Robert C. Wiegand

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