Joint Report Of Court-Ordered Mediation - Page 1 3430909.1 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

FORT WORTH DIVISION 

DAVID SAMBRANO, individually, and 

on behalf of all others similarly situated, 

Plaintiffs, 

v. 

UNITED AIRLINES, INC., 

Defendant. 

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Civil Action No. 

4:21-CV-01074-P 

JOINT MEDIATION REPORT

 Plaintiffs and Defendant submit this Joint Mediation Report pursuant to the Court’s 

October 20, 2021, Order, which directs the parties to “detail[] the settlement negotiations, 

including a statement on the parties’ progress towards settlement and on lingering issues before 

the Court in this case, if any.” ECF No. 81 (“Order”). 

1. Since the Order was issued, the parties have been working with the mediators 

appointed by the Court, including the Honorable Kent Hance, Chancellor-Emeritus, as Lead 

Mediator and Honorable Royal Furgeson (Ret.), Dean-Emeritus, as Local Mediator. Counsel for 

both sides spoke separately with the mediators on several occasions beginning on Friday, 

October 21, 2021. 

2. On Monday, October 25, 2021, the mediators met with counsel for both sides at 

the Omni Hotel in Fort Worth from 7 p.m. until approximately 9 p.m. Plaintiffs were 

represented by Gene Schaerr and John Sullivan. United was represented by Don Munro and 

Russell Cawyer. 

 2. The parties conducted a day-long, in-person mediation on Tuesday, October 26, 

2021, from 9:00 a.m. to approximately 6:00 p.m., at the Omni Hotel in Fort Worth, Texas. The 

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plaintiffs in attendance were David Sambrano, David Castillo, Kimberly Hamilton, Genise 

Kincannon, and Seth Turnbough. Debra Jennifer Thal Jonas is ill and so was unable to attend in 

person. Plaintiffs’ counsel Gene Schaerr and John Sullivan were also present. United was 

represented by Vania Wit, deputy general counsel, Sheila Frederick, associate general counsel, 

Mary O’Neil, senior managing counsel, and Kirk Limacher, Vice President, Human Resources. 

United’s counsel Don Munro and Russell Cawyer were also present. 

 3. Each side had multiple meetings with the mediators throughout the day, and 

thoroughly discussed the various issues. The parties also exchanged settlement proposals 

through the mediators. 

 4. Since then, the parties have continued to discuss this matter with the mediators in 

phone conferences. 

 5. Despite these efforts, the parties have not, as of the deadline for this Report, been 

able to reach agreement on any of the issues pending before the Court. The parties, however, are 

still discussing a possible settlement with respect to a subset of the putative class, and will report 

the results of that discussion to the Court on or before Tuesday, November 2 

 6. Neither party has any objection if the Court wishes to conduct private 

conversations with the mediators regarding their impressions of the case, the prospects for 

settlement, or any related issues. 

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Respectfully submitted, 

 /s/ John C. Sullivan 

John C. Sullivan 

Texas Bar No. 24083920 

john.sullivan@the-sl-lawfirm.com 

S|L LAW PLLC 

610 Uptown Boulevard, Suite 2000 

Cedar Hill, TX 75104 

Telephone: (469) 523-1351 

Facsimile: (469) 613-0891 

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 

Mark R. Paoletta (Pro Hac Vice)

D.C. Bar No. 422746 

mpaoletta@schaerr-jaffe.com 

Gene C. Schaerr (Pro Hac Vice)

D.C. Bar No. 416368 

Brian J. Field (Pro Hac Vice)

D.C. Bar No. 985577 

Kenneth A. Klukowski (Pro Hac Vice)

D.C. Bar No. 1046093 

Annika M. Boone (Pro Hac Vice)

Utah Bar No. 17176 

SCHAERR | JAFFE LLP 

1717 K Street NW, Suite 900 

Washington, DC 20006 

Telephone: (202) 787-1060 

Facsimile: (202) 776-0136 

COUNSEL FOR PLAINTIFFS 

AND THE PROPOSED CLASS

/s/ Donald J. Munro 

Donald J. Munro 

D.C. Bar No. 453600 

JONES DAY

51 Louisiana Avenue, NW 

Washington, DC 20001 

Telephone: (202) 879-3939 

Facsimile: (202) 626-1700 

Email:dmunro@jonesday.com 

Russell D. Cawyer 

State Bar No. 00793482 

KELLY HART & HALLMAN LLP 

201 Main St., Ste. 2500 

Fort Worth, Texas 76102 

(817) 878-3562 (telephone) 

(817) 335-2820 (facsimile) 

russell.cawyer@kellyhart.com 

Jordan M. Matthews (Pro Hac Vice) 

IL Bar No. 6300503 

Jones Day 

77 W. Wacker Drive, Suite 3500 

Chicago, Illinois 60601 

Telephone: (312) 782-3939 

Facsimile: (312) 782-8585 

Email: jmatthews@jonesday.com 

Alexander V. Maugeri (Pro Hac Vice) 

NY Bar No. 5062666 

Jones Day 

250 Vesey Street 

New York, NY 10281-1047 

Telephone: (212) 326-3880 

Facsimile: (212) 755-7306 

Email: amaugeri@jonesday.com 

ATTORNEYS FOR DEFENDANT 

UNITED AIRLINES, INC. 

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CERTIFICATE OF SERVICE 

On October 29, 2021, I electronically submitted the foregoing document with the clerk of 

court for the U.S. District Court, Northern District of Texas, using the electronic case filing 

system of the court. I hereby certify that I have served all counsel and/or pro se parties of record 

electronically or by another manner authorized by Federal Rule of Civil Procedure 5(b)(2). 

 /s/ Russell D. Cawyer 

 Russell D. Cawyer

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