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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

FORT WORTH DIVISION 

ROBERT (BOB) ROSS, 

Plaintiff/Counterclaim 

Defendant, 

v. 

ASSOCIATION OF PROFESSIONAL 

FLIGHT ATTENDANTS, et al., 

Defendants/Counterclaim 

Plaintiff.

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Civil Action No. 4:22-cv-343-Y 

Judge Terry R. Means 

MOTION TO COMPEL PRODUCTION OF DOCUMENTS IN 

RESPONSE TO SUBPOENA ISSUED TO WOODS, 

STEPHENS AND O’NEIL, L.L.P. 

COME NOW, Plaintiff, Robert “Bob” Ross (“Ross”), and file this, his Motion to Compel 

Response to Subpoena Issued to Woods, Stephens, and O’Neil, L.L.P. (“Woods, Stephens, and 

O’Neil”) and in support thereof, would respectfully show this Court as follows: 

1. Woods, Stephens, and O’Neil objected to the Subpoena served on October 20, 

2022, within the time period for compliance, and should be compelled to serve documents and 

all objections overruled. 

2. Counsel for Defendants served objections on behalf of Woods Stephens, and 

O’Neil to Plaintiff’s Counsel on November 3, 2022. Original Counsel for Defendants have 

subsequently withdrawn from this case and been replaced with new counsel. No confirmation 

has been asserted that new Counsel does, in fact, represent Woods, Stephens, and O’Neil to date. 

3. It has been ten (10) months since Woods, Stephens, and O’Neil was served with 

the Subpoena, and yet Woods, Stephens, and O’Neil will not withdraw objections, and refuses 

to produced any documents responsive of Plaintiff’s Subpoena. 
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 Therefore, for the reasons set forth more fully in the incorporated Brief in 

Support, Ross asks that this Court grant his Motion and overrule Defendants’ and Woods, 

Stephens, and O’Neil’s objections to the Subpoena and further issue an order compelling Woods, 

Stephens, and O’Neil to produce all documents responsive to Plaintiff’s Subpoena. 

WHEREFORE, PREMISES CONSIDERED, Plaintiff request that this Court grant his 

Motion to Compel Production of Documents in Response to Subpoena to Woods, Stephens, and 

O’Neil L.L.P. and for such other relief as the Court deems proper. 

THIS, the 5th day of September, 2023. 

Respectfully submitted, 

 

 

By: /s/ Kerri Phillips s 

Kerri Phillips, Esq. 

Texas Bar No. 24065906 

Phone: (972) 327-5800 

Email: kerri@kdphillipslaw.com

KD PHILLIPS LAW FIRM, PLLC 

6010 West Spring Creek Parkway 

Plano, Texas 75024 

Fax: (940) 400-0089 

For Service of Filings: 

notice@kdphillipslaw.com 

 

 

ATTORNEY FOR PLAINTIFF
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CERTIFICATE OF CONFERENCE 

Pursuant to Local Rule 7.1(b) I hereby certify that counsel for the movant has conferred 

with Defendant in a good faith effort to resolve the issues raised herein. Plaintiff’s counsel 

conferred with Defendants’ counsel on via email on August 14, 2023, August 17, 2023, August 

18, 2023. A telephone call was held on August 23, 2023 wherein the concerns and objections 

were discuss, in particular Plaintiff offered to limit the time frame of the Requests for Production 

No. 1, 2 and 3 to overcome Defendants objections without success in appeasing him. Plaintiff’s 

further conferred with Defendants on via email on August 25, 2023, August 26, 2023, and 

received a response on August 30, 2023 stating documents would be produced on August 31, 

2023. As of the date of filing this Motion, Plaintiffs served extremely limited responses that were 

heavily redacted and only responsive to Request for Production 2, and no documents have been 

received from Woods, Stephens, and O’Neil. Counsel conferred on September 1, 2023 as to the 

relief requested in this instant Motion and Defendants’ counsel has replied they are opposed to 

the Motion. Counsel for Diversified is unopposed. 

THIS, the 5th day of September 2023. 

By: /s/ Kerri Phillips 

Kerri Phillips, Esq. 

CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing BRIEF IN SUPPORT OF 

MOTION TO COMPEL PRODUCTION OF DOCUMENTS IN RESPONSE TO 

SUBPOENA ISSUED TO WOODS, STEPHENS, O’NEIL, L.L.P. has been served in accordance 

with the Federal Rules of Civil Procedure to all counsel of record identified below on this 5th day of 

September, 2023. 

 

By: /s/ Kerri Phillips s 

Kerri Phillips, Esq.

Jeffrey Bartos 

Guerrieri, Bartos, & Roma, P.C. 

1900 M Street, NW, Suite 700 

Washington, DC 20036 

Tel: (202) 624-7400; Fax: (202) 624-7420 

Email: jbartos@geclaw.com

Charlette Matts 

In-House Counsel for APFA 

1004 West Euless Blvd 

Euless, TX 76040 

Tel: (682) 301-8454 

Cmatts@apfa.org
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James Sanford 

4803 Gaston Avenue 

Dallas, TX 75249-1020 

Tel: (214) 800-5111; Fax: (214) 838-

0001 

Email jim@gillespiesanford.com

Email: joe@gillespiesanford.com

Michael Rake 

PO Box 1556 

Lake Dallas, TX 75065-1556 

Tel: (940) 498-2103 Fax: (940) 498-2103 

Email: mrake1@mrakeattorney.com