1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

ROBERT (BOB) ROSS, §

§

 Plaintiff/Counterclaim Defendant, §

§

v. § Civil Action No. 4:22-cv-00034-Y

§

ASSOCIATION OF PROFESSIONAL §

FLIGHT ATTENDANTS §

MCGAUGHEY, REBER AND §

ASSOCIATES, INC, JULIE §

HEDRICK, AND ERIK HARRIS, §

§

 Defendants/Counterclaim Plaintiff. §

PLAINTIFF’S DISCLOSURES PURSUANT TO F.R.C.P. 26 (a)

Pursuant to this Court’s Order of June 13, 2022 (Dkt. No. 13), counsel for 

Plaintiff/Counterclaim Defendant Robert (Bob) Ross submits these disclosures required by 

Federal Rule of Civil Procedure 26(a)(1) as follows:

(i) the name and, if known, the address and telephone number of each individual 

likely to have discoverable information—along with the subjects of that 

information—that the disclosing party may use to support its claims or defenses, 

unless the use would be solely for impeachment;

1. Any and all former and current members of the Board of Directors of the Association 

of Professional Flight Attendants and its affiliates from January 1, 2015 to current 

whose current national headquarters location includes but is not limited to 1004 West 

Euless Boulevard, Euless, Texas 76040. (817) 540-0208. Information and testimony 

regarding claims for violations of Breach of Fiduciary Duty, Breach of Union 

Constitution, Violation of Member’s Bill of Rights under Labor Management 

Reporting and Disclosure Act. 

Case 4:22-cv-00343-Y Document 29 Filed 08/04/22 Page 1 of 5 PageID 217
2

2. Any and all former and current national officers of the Association of Professional 

Flight Attendants and its affiliates from January 1, 2015 to current whose current 

national headquarters location includes but is not limited to 1004 West Euless 

Boulevard, Euless, Texas 76040. (817) 540-0208. Information and testimony 

regarding claims for violations of Breach of Fiduciary Duty, Breach of Union 

Constitution, Violation of Member’s Bill of Rights under Labor Management 

Reporting and Disclosure Act. 

3. Any and all staff current and former members of the Association of Professional 

Flight Attendants and its affiliates from January 1, 2015 to current whose current 

national headquarters location includes but is not limited to 1004 West Euless 

Boulevard, Euless, Texas 76040. (817) 540-0208. Information, testimony, 

correspondence, and documentation regarding claims for violations of Breach of 

Fiduciary Duty, Breach of Union Constitution, Violation of Member’s Bill of Rights 

under Labor Management Reporting and Disclosure Act. 

4. Any and all current and former members of the executive committee of the 

Association of Professional Flight Attendants and its affiliates from January 1, 2015 

to current whose current national headquarters location includes but is not limited to 

1004 West Euless Boulevard, Euless, Texas 76040. (817) 540-0208. Information and 

testimony regarding claims for violations of Breach of Fiduciary Duty, Breach of 

Union Constitution, Violation of Member’s Bill of Rights under Labor Management 

Reporting and Disclosure Act. 

5. Any and all current and former members of the in-house and outside legal team of 

the Association of Professional Flight Attendants and its affiliates from January 1, 

2015 to current whose current national headquarters location includes but is not 

limited to 1004 West Euless Boulevard, Euless, Texas 76040. (817) 540-0208. 

Information and testimony regarding claims for violations of Breach of Fiduciary 

Duty and Violation of Member’s Bill of Rights under Labor Management Reporting 

and Disclosure Act. 

Case 4:22-cv-00343-Y Document 29 Filed 08/04/22 Page 2 of 5 PageID 218
3

6. Any and all current and former officers, employees, staff members, debt collection

agents, contractors, associates Diversified Credit Systems a/k/a McGaughey, Reber 

and Associates, Inc whose address includes but is not limited to 706 Glencrest Ln 

Unit A, Tyler, TX 75701 (903) 297-0600. Information and testimony including but 

limited to claims for violations of Fair Debt Collection Practices Act and Federal Fair 

Credit Reporting Act. 

7. Any and all certified public accountants, accountants, partners, associates, staff 

members and affiliates of Wood, Stephens & O’Neil, L.L.P., its predecessors, 

affiliates and assigns whose current address includes but is not limited to 6300 

Ridglea Place, Suite 318, Fort Worth, Texas 76116. (817) 377-1700. Information and 

testimony regarding claims for violations of Breach of Fiduciary Duty, Breach of 

Union Constitution, Violation of Member’s Bill of Rights under Labor Management 

Reporting and Disclosure Act. 

8. Any and all staff current and former employees of the Association of Professional 

Flight Attendants and its affiliates from January 1, 2015 to current whose current 

national headquarters location includes but is not limited to 1004 West Euless 

Boulevard, Euless, Texas 76040. (817) 540-0208. Information, testimony, 

correspondence, and documentation regarding claims for violations of Breach of 

Fiduciary Duty, Breach of Union Constitution, Violation of Member’s Bill of Rights 

under Labor Management Reporting and Disclosure Act. 

9. Any and all staff current and former employees of the American Airlines, Inc. and its 

affiliates from January 1, 2015 to current whose current national headquarters 

location includes but is not limited to 4333 Amon Carter Blvd, Fort Worth, Texas 

76155, (817) 963-1234. Information, testimony, correspondence, and documentation 

regarding claims for violations of Breach of Fiduciary Duty, Breach of Union 

Constitution, Violation of Member’s Bill of Rights under Labor Management 

Reporting and Disclosure Act. 

10. Bob Ross, c/o KD Phillips Law, 5700 Tennyson Parkway, Suite 300, Plano Texas 

75024; Topic: Union Practices, Fact Witness

Case 4:22-cv-00343-Y Document 29 Filed 08/04/22 Page 3 of 5 PageID 219
4

11. Eugenio Vargas, c/o KD Phillips Law, 5700 Tennyson Parkway, Suite 300, Plano 

Texas 75024; Topic: Union Practices, Fact Witness

12. Nena Martin: 1404 Grizzly Hollow, Wentzville, MO 63385; Topic: Union Practices, 

Fact Witness

13. Ruben R. Armendariz, Arbitrator, 8610 Cheviot Heights, San Antonio, Texas 78254 

(210) 370860; Topic: Union Practices, Fact Witness

14. Dr. Kamalpreet Dulai, McClellan Park Air Force Base, Veterans Administration; 150 

Muir Road, Martinez, CA 94553 (925) 372-2000; Topic: Damages

15. Gene Ackerman, Answer Home Loans – 916-835-8684; 6085 Douglas Blvd, Suite 

500, Granite Bay, CA 95746 Topic: Damages.

(ii) a copy—or a description by category and location—of all documents, 

electronically stored information, and tangible things that the disclosing party has 

in its possession, custody, or control and may use to support its claims or defenses, 

unless the use would be solely for impeachment;

1. Copy of Arbitration Decision

2. Transcripts from Arbitration Hearing

3. Email correspondence between the parties regarding the arbitration

4. Copy of Transition Agreement

5. Correspondence from APFA to Plaintiff regarding wages

6. Social Media Posts

7. Agreement between APFA and Laura Glading

8. APFA Constitution and Policies

9. Affidavits from witnesses 

(iii) a computation of each category of damages claimed by the disclosing party—who 

must also make available for inspection and copying as under Rule 34 the 

documents or other evidentiary material, unless privileged or protected from 

disclosure, on which each computation is based, including materials bearing on the 

nature and extent of injuries suffered; and

(1) Legal Fees to Date: est. $61,345.90

(2) Arbitration and Costs Assessed in Arbitration Fees: est. $27,631.60 + Additional 

Costs

(3) Lost Income: est. $23,420.60

(4) Costs incurred in Arbitration: est. $8,610.72

(5) Damages for FCRA violations: est. $691,637

Case 4:22-cv-00343-Y Document 29 Filed 08/04/22 Page 4 of 5 PageID 220
5

(6) Medical Costs: unknown

(7) Reputational Harm: unknown

(8) Pain and Emotion Suffering: unknown

(9) Lost Employment Opportunities: unknown

(10) Loss Future Income: unknown

(11) Punitive Damages: unknown

(iv) for inspection and copying as under Rule 34, any insurance agreement under 

which an insurance business may be liable to satisfy all or part of a possible 

judgment in the action or to indemnify or reimburse for payments made to satisfy 

the judgment.

(1) Robert (Bob was insured per Federal Law mandates; however, all policy documents 

were left in possession of the Association of Professional Flight Attendants upon his 

departure in 2018, and no copies were retained, per Union Policy. He has not been 

provided this information to date, therefore is unable to provide the Defendants with 

this information. 

Date: August 3, 2022 Respectfully Submitted

 /s/ Kerri Phillips

KERRI PHILLIPS

Texas Bar No. 24065906 

HEATHER ABREU

Texas Bar No. 24122577

K.D. Phillips Law Firm, PLLC 

5700 Tennyson Parkway, Suite 300

Plano, Texas 75024

Phone: (972) 327-5800

Fax: (940) 400-0089

Email: Kerri@KDphillipslaw.com

Email: Heather@KDphillipslaw.com

Counsel for Plaintiff Robert “Bob” Ross

CERTIFICATE OF SERVICE

I certify that on this 4th day of August 2022, I served a true and correct copy of the foregoing to the below 

persons through electronic filing and email.

SANFORD R. DENISON denison@baabdenison.com

MARGOT A. NIKITAS MNikitas@apfa.org

WILLIAM W. OSBORNE b.osborne@osbornelaw.com

/s/ Kerri Phillips

Kerri Phillips

Case 4:22-cv-00343-Y Document 29 Filed 08/04/22 Page 5 of 5 PageID 221