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1 STATE OF TEXAS )

2 COUNTY OF DALLAS )

3 THIS IS TO CERTIFY THAT I, MELISSA J. CARSON,

4 a Certified Shorthand Reporter in and for the State of

5 Texas, reported in shorthand the proceedings had at the

6 time and place set forth in the caption hereof, and

7 that the above and foregoing 265 pages contain a full,

8 true, and correct transcript of the said proceedings to

9 the best of my ability.

10 Certified to on this the 28th day of October,

11 2021.

12

13

14 ____________________________

 MELISSA J. CARSON, Certified

15 Shorthand Reporter in and for

 The State of Texas

16

17

18 Certification No. 1737

19 CRCB Firm Registration #489

20 Expires August 31, 2022

21 CARSON REPORTING & ASSOCIATES

22 Post Office Box 551628

23 Dallas, Texas 75355-1628

24 Telephone 214.346.3434

25

APPENDIX 262

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1 IN THE MATTER OF THE HEARING

2 MELISSA CHINERY, Member )

 and )

3 SANDRA LEE, Member )

 )BEFORE ARTICLE VII

4 AND ) ARBITRATOR

 )HON. RUBEN B. ARMENDARIZ

5 )

ROBERT ROSS, Member )

6

7

8

 **************************************

9 NOVEMBER 17, 2021

10 VOLUME 2

 **************************************

11

12

13

14 BE IT REMEMBERED that on the 17th day of

15 November, 2021, the above cause came on for hearing

16 before HON. RUBEN R. ARMENDARIZ at the WESTIN IRVING

17 CONVENTION CENTER AT LAS COLINAS, 400 West Las Colinas

18 Boulevard, located in the City of Irving, County of

19 Dallas, State of Texas, whereupon the following

20 proceedings were had.

21

22

23

24

25

APPENDIX 263

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1 A P P E A R A N C E S:

2 HON. RUBEN R. ARMENDARIZ

 LABOR MANAGEMENT ARBITRATOR

3 29010 Pfeiffers Gate

 Fair Oaks Ranch, Texas 78015

4 PHONE: 210.379.0860

 EMAIL: arbruben@gmailcom

5

 APPEARING AS THE ARBITRATOR

6

 MS. MELISSA CHINERY

7 EMAIL: Melchinery@aol.com

 AND

8 MS. SANDRA LEE

 EMAIL: SEL27995@gmail.com

9

 APPEARING FOR THE CHARGING PARTY

10

 MR. ROBERT ROSS

11 EMAIL: 1RROSS@COMCAST.NET

 AND

12 MS. GINA GUIDRY

13 APPEARING FOR THE CHARGED PARTY

14

15 * * * *

16

17

18

19

20

21

22

23

24

25

APPENDIX 264

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1 WITNESS INDEX

2

CATHY LUKENSMEYER PAGE

3 Direct Examination by Ms. Chinery................ 54

Cross-Examination by Ms. Guidry.................. 74

4 Redirect Examination by Ms. Chinery.............. 84

Recross-Examination by Mr. Ross.................. 90

5

ERIK HARRIS

6 Direct Examination by Ms. Lee.................... 99

Cross-Examination by Mr. Ross.................... 132

7 Redirect Examination by Ms. Lee.................. 221

Recross-Examination by Mr. Ross.................. 231

8

MICHAEL TRAPP

9 Direct Examination by Ms. Chinery................ 249

Cross-Examination by Mr. Ross.................... 259

10

JOHN NIKIDES

11 Direct Examination by Ms. Chinery................ 272

Cross-Examination by Ms. Guidry.................. 297

12 Redirect Examination by Ms. Lee.................. 321

13

REPORTER'S NOTE:

14 Due to the horrible acoustics in the hearing room and

without the use of microphones, there will be noted

15 (unintelligible) several times throughout the

transcript. I apologize for this; however, if I cannot

16 hear it, I cannot write it.

17 Additionally there are several notations of

simultaneous speaking or simultaneous discussions

18 throughout the transcript. When several people talk at

the same time, there is no way to possibly discern who

19 is speaking.

20

21

22

23

24

25

APPENDIX 265

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1 That is yet to be discovered.

2 The first charge that they have are

3 credit cards. There will be no proven willful act of

4 any credit card usage. I've been frugal. I've been

5 honest. I've saved the membership tens of thousands of

6 dollars by my actions and by actions of my family, the

7 move, and otherwise. We will prove that we have not

8 willfully violated any policy.

9 Were there mistakes? Possibly. Could we

10 have found errors in accounting? Possibly. I don't

11 think so. Could there be a receipt that's unexplained?

12 Possibly. But I don't think that there's anybody that

13 can go through life and never make a mistake, but the

14 question is were they willful.

15 We have a question of rental cars, charge

16 number two, violation, rental car. We have records

17 that show that this should have never been in these

18 charges and the entire charges should have been

19 dismissed for untimely. We will show documentation

20 that they've known about any questions on rental cars

21 all the way back to 2019. For them to include that in

22 these charges right here should have been investigated

23 and discovered prior to arbitration. The process of

24 the Executive Committee did not allow myself to attend

25 that Executive Committee in a timely manner or to

APPENDIX 266

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1 defend myself or any investigative process whatsoever

2 that would have shown that that was untimely. And if

3 that of -- that charge is untimely within it, the

4 entire charge should have been thrown out for

5 timeliness.

6 Reimbursement. They'll show that under

7 policy manual 5G 1B, ground transportation they claim

8 at residence. I have no idea what they're talking

9 about on this, but I'm positive that through my actions

10 there was no violation of any reimbursement to myself

11 and I look forward to proving that today.

12 Number four, MEA and SAF expense. There

13 have been resolutions passed that have cleared up any

14 confusion that was in the policy manual at the time.

15 In clearing up those confusions, the 2021 policy manual

16 is updated to actually include how the Ross

17 administration handled certain MEA and SAF meal

18 expenses to include how we actually did it. That will

19 also be investigated while we're here today and you

20 will see that there were no MEA and SAF meal expense

21 and certainly no willful intent of any violation.

22 Number five, charge, payout of vacation,

23 changed the formula. This is a good topic that should

24 have been investigated and should still be investigated

25 because the terms of Ross' Transition Agreement, though

APPENDIX 267

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1 Treasurer.

2 ERIK HARRIS,

3 having been first duly sworn, testified as follows:

4 DIRECT EXAMINATION

5 BY MS. LEE:

6 Q. Hi, Erik.

7 A. Hello.

8 Q. Thank you for coming today. We know it's been

9 quite the week, so we appreciate it.

10 A. Thank you.

11 Q. So again, what is your name?

12 A. Erik Harris.

13 Q. Where are you employed?

14 A. American Airlines and APFA.

15 Q. Okay. What is your position at APFA?

16 A. I'm the National Treasurer.

17 Q. How long have you been employed at American

18 Airlines?

19 A. About eight years.

20 Q. Okay. Besides National Treasurer, have you

21 held any other positions -- positions at APFA during

22 your career?

23 A. Yes, various positions. Most recently --

24 well, prior to this position, I was a contract chair.

25 I served on the budget committee pretty much my entire

APPENDIX 268

Treasurer.

2 ERIK HARRIS,

having been first duly sworn, testified as follows:

. 

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1 career.

2 Q. And in your role as National Treasurer, have

3 you been responsible for responding to requests to see

4 financial information?

5 A. Yes.

6 Q. Did you receive requests from Melissa and

7 myself to come down and see financial records?

8 A. Yes.

9 Q. And did you set up times for us to see the

10 information?

11 A. Yes.

12 Q. Approximately how many times have we come down

13 to review information?

14 A. About five to 10.

15 Q. So have you been present with myself and

16 Melissa when we came down?

17 A. Yes.

18 Q. If you were not present, who was present?

19 A. I believe there was only one time and my

20 assistant, Robert, was there and Margot has been there

21 and there were a couple occasions where all four

22 Officers were there.

23 Q. So we were never alone -- alone with these

24 financial documents?

25 A. That's right.

APPENDIX 269

Approximately how many times have we come down

13 to review information?

14 A. About five to 10.

Q. So have you been present with myself and

16 Melissa when we came down?

A. Yes.

18 Q. If you were not present, who was present?

19 A. I believe there was only one time and my

20 assistant, Robert, was there and Margot has been there

21 and there were a couple occasions where all four and there were a couple 

22 Officers were there.

23 Q. So we were never alone -- alone with these

24 financial documents?

25 A. That's right.

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1 Q. Who was the Treasurer before you took office?

2 A. Craig Gunter.

3 Q. And before him?

4 A. Eugenio Vargas.

5 Q. How would you describe the state of the Union

6 financial records when you took office?

7 A. They were -- it was pretty bad, in bad shape.

8 Q. Who has the responsibility under APFA

9 Constitution to maintain the financial records?

10 A. The National Treasurer does.

11 Q. Did you receive a subpoena from Melissa and

12 myself, the charging parties, for financial documents

13 related to this hearing?

14 A. Yes.

15 Q. And did you oversee the efforts to locate and

16 provide those documents?

17 A. Yes.

18 Q. Can you explain the steps taken to ensure

19 which documents you had? Oh, okay. I'll tell you

20 what, I want you to look at Exhibits 8 through 46 in

21 the big book.

22 A. Okay.

23 MS. LEE: Oh, we need -- that too.

24 THE ARBITRATOR: Which one, the blue

25 one?

APPENDIX 270

How would you describe the state of the Union

6 financial records when you took office?

7 A. They were -- it was pretty bad, in bad shape.

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1 MS. LEE: Yeah.

2 MS. CHINERY: Hold on. I'm coming.

3 MS. LEE: We'll give you yours.

4 THE ARBITRATOR: Oh, okay. I guess we...

5 MS. LEE: I'm going to move to submit

6 Exhibits 8 through 46 into evidence, which are

7 financial documents.

8 THE ARBITRATOR: You got to prove them

9 up first.

10 MS. LEE: Okay.

11 Q. (BY MS. LEE) Are there any items you were

12 unable to locate from the subpoena?

13 A. Yes.

14 Q. Okay. I want you to take a look at those

15 documents, 8 through 46.

16 A. Okay.

17 MR. ROSS: 8 through 46?

18 MS. LEE: 8 through 46. Take your time.

19 MR. ROSS: I have 27 here.

20 MS. LEE: I think it's 46.

21 MR. ROSS: 8 through 46?

22 MS. LEE: 8 through 46.

23 MR. ROSS: So --

24 (Simultaneous speaking.)

25 MS. LEE: She's going to give them to

APPENDIX 271

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1 A list of hotels for Bob Ross. All paperwork for

2 rental cars. Any equipment purchase. Correspondence

3 with the collection agency regarding Ross' failure to

4 provide information. Emails from -- between Debbie

5 Hoover and Eugenio regarding repayment. Receipts for

6 hotel stays, U-Hauls, and a list of vacation days.

7 Accounting of vacation payout and Bob Ross' exit -- Bob

8 Ross' exit package and documents from outside Counsel,

9 Mike (sic) Richards.

10 Q. Okay. Can you explain the steps that we took

11 to -- that you took to give us these documents besides

12 the subpoena? Had we -- had we gone over these

13 documents?

14 A. Yes. So for these documents, are you

15 saying -- what was the question?

16 Q. Those financial documents.

17 A. But what was the question?

18 Q. Okay. So the documents that you have in front

19 of you are the documents that we subpoenaed?

20 A. Yes. Yes.

21 MS. LEE: Okay. So these are Exhibits 8

22 through 46, which I'd have like -- like to have

23 admitted into evidence, which are financial documents.

24 THE ARBITRATOR: Any objection?

25 MR. ROSS: I think we've already

APPENDIX 272

Any objection?

MR. ROSS: I think we've already

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 11 of 46 PageID 6950
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APPENDIX 273

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1 MS. CHINERY: Objection, we -- we --

2 MR. ROSS: -- I'm still speaking -- if

3 some of this stuff could be entered into the record and

4 we get into it and find out it's not correct, not true,

5 now it's been entered into the record -- record. So I

6 am not familiar enough with protocol to make sure

7 that --

8 MS. CHINERY: You've had these documents

9 for months.

10 THE ARBITRATOR: Well look, let's --

11 let's get something -- off the record.

12 (Discussion off the record.)

13 THE ARBITRATOR: I hear -- I hear your

14 concern, but all we're -- we're -- we're accepting this

15 for the reason that he -- he complied with the subpoena

16 and that's what these documents are, nothing else.

17 We're not saying that they're true, correct or

18 whatever, we're just submitting it in based upon the

19 duces tecum. Okay? Okay. It's -- do you still have

20 an objection?

21 MR. ROSS: No.

22 THE ARBITRATOR: Okay. Hearing no

23 objection, charging party CP Exhibit 8 through 46 -- is

24 it 8 --

25 MS. CHINERY: Yes.

APPENDIX 274

THE ARBITRATOR: Well look, let's --

11 let's get something -- off the record.

(Discussion off the record.)

THE ARBITRATOR: I hear -- I hear your

14 concern, but all we're -- we're -- we're accepting this

15 for the reason that he -- he complied with the subpoena

16 and that's what these documents are, nothing else.

17 We're not saying that they're true, correct or

18 whatever, we're just submitting it in based upon the

19 duces tecum. Okay? Okay. It's -- do you still have

20 an objection?

MR. ROSS: No.

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1 MS. CHINERY: This is --

2 MR. ROSS: Okay. All kind of assumptions

3 have been made based on a false or altered

4 (unintelligible) altered agreement and which gives the

5 assumption that Ross was under -- overpaid. It's in

6 collections right now and I think we just established

7 the fact that there are --

8 MS. CHINERY: Objection --

9 MR. ROSS: 12 --

10 MS. CHINERY: -- you didn't establish

11 anything --

12 THE ARBITRATOR: Yeah.

13 MR. ROSS: -- 12 days of vacation --

14 THE ARBITRATOR: Why don't you ask him a

15 question.

16 Q. (BY MR. ROSS) Are there -- based on the

17 information that I showed you, does it appear that

18 there are 12 days of sick --

19 MS. CHINERY: Objection, leading.

20 THE ARBITRATOR: No, I'm going to --

21 MR. ROSS: Here's the question --

22 THE ARBITRATOR: -- allow it.

23 Q. (BY MR. ROSS) Does it appear that there are

24 12 days of sick still unpaid?

25 A. Yes.

APPENDIX 275

MR. ROSS: Okay. All kind of assumptions

3 have been made based on a false or altered

4 (unintelligible) altered agreement and which gives the

5 assumption that Ross was under -- overpaid. It's in

6 collections right now and I think we just established

7 the fact that there are --

8 MS. CHINERY: Objection --

9 MR. ROSS: 12 --

10 MS. CHINERY: -- you didn't establish

11 anything --

12 THE ARBITRATOR: Yeah.

13 MR. ROSS: -- 12 days of vacation --

14 THE ARBITRATOR: Why don't you ask him a

15 question.

16 Q. (BY MR. ROSS) Are there -- based on the

17 information that I showed you, does it appear that

18 there are 12 days of sick --

19 MS. CHINERY: Objection, leading.

20 THE ARBITRATOR: No, I'm going to --

21 MR. ROSS: Here's the question --

22 THE ARBITRATOR: -- allow it.

23 Q. (BY MR. ROSS) Does it appear that there are

24 12 days of sick still unpaid?

25 A. Yes.

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1 Q. Okay. Going back to Section 16, the color

2 chart, one page behind it says part two, you accept

3 that --

4 A. Yes.

5 Q. -- (unintelligible) and the very next page

6 back should be a chart. This chart was provided by

7 APFA?

8 A. Oh, yes.

9 Q. Okay.

10 A. It's my chart, yeah.

11 Q. And as you thumb through it, you'll get to a

12 page that has got an A on it on the top. This is --

13 these numbers in here represent how much for each one

14 of the sick and vacation days, the day rate that was

15 paid for each one of those, what it was paid for,

16 correct? And on that particular one it shows Bob Ross

17 and it says overpayment calculation.

18 A. Yes.

19 Q. All right. Overpayment calculation and it's

20 based on, if you look down at vacation pay 2017, if you

21 look on the right-hand side -- or left-hand side --

22 A. Yes.

23 Q. -- okay? And if you skim across and it says

24 eligible days to pay, 14?

25 A. Yes.

APPENDIX 276

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1 Q. That's per policy, correct?

2 A. Yes.

3 Q. But it's not necessarily per Transition

4 Agreement because the Transition Agreement says all

5 accrued and unused?

6 A. Yes.

7 Q. That doesn't specify per policy, it specifies

8 outside of policy, right, in --

9 A. Yes.

10 Q. -- the Transition Agreement, okay?

11 A. Yes.

12 Q. And then sick pay for 2017, if you skim

13 across, has 12 eligible days?

14 A. Yes.

15 Q. Okay. So there were more days accrued than 14

16 and there were more days accrued than 12 for those

17 two --

18 A. Yes.

19 Q. -- right? And that's what Ross was to be paid

20 out above and beyond policy per Transition Agreement?

21 MS. LEE: Objection, he -- he's asking a

22 question and then he's answering it.

23 THE ARBITRATOR: Yeah. Why don't you

24 ask a question.

25 Q. (BY MR. ROSS) Based on the policy agreement,

APPENDIX 277

But it's not necessarily per Transition

4 Agreement because the Transition Agreement says all

5 accrued and unused?

6 A. Yes.

7 Q. That doesn't specify per policy, it specifies

8 outside of policy, right, in --

9 A. Yes.

10 Q. -- the Transition Agreement, okay?

11 A. Yes.

12 Q. And then sick pay for 2017, if you skim

13 across, has 12 eligible days?

14 A.

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1 would you ascertain that Ross was to be paid out above

2 policy, based on the wording of the Transition

3 Agreement?

4 A. Yes. Yeah.

5 Q. So that transition was proved and signed by

6 the Board?

7 A. Yes.

8 Q. So they knew it. They knew that there was a

9 certain amount of monies, right?

10 A. I believe so. I --

11 Q. And --

12 (Simultaneous speaking.)

13 A. -- wasn't there --

14 Q. Okay. So -- but if Ross was really only paid

15 12, that's per policy, per se --

16 A. Yes.

17 Q. -- and 14 for vacation per policy and that's

18 all he was paid, then he would be underpaid, correct?

19 MS. LEE: Objection, it's leading.

20 THE ARBITRATOR: No, he's asked the

21 question.

22 MS. LEE: Okay.

23 THE ARBITRATOR: He asked the question --

24 MS. LEE: I'm waiting for him to ask --

25 THE ARBITRATOR: -- would he be

APPENDIX 278

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1 underpaid.

2 MS. LEE: Okay. Yes.

3 A. Yes.

4 Q. (BY MR. ROSS) Okay. So if a wrong

5 calculation was used, right, the daily rate --

6 A. Oh, the formula --

7 Q. -- to --

8 (Simultaneous speaking.)

9 A. -- yes.

10 Q. (BY MR. ROSS) -- see the -- say the formula --

11 say the formula coming up for how much he got paid for

12 each one of those days was incorrect, all right?

13 A. Uh-huh.

14 Q. Because it had numbers that should or should

15 not have -- we don't know because nobody was at the

16 actual negotiations of that tentative agreement or that

17 Transition Agreement except the parties who were there,

18 right? Would that be -- you wouldn't -- you didn't

19 have any paper that says what I was supposed to be

20 paid?

21 A. No, I didn't.

22 Q. And Eugenio Vargas, the Treasurer at the time,

23 he wasn't a part -- he wasn't a Board member, so he

24 wasn't a part, he didn't sign it. So you could only

25 really -- would you -- would you agree that you could

APPENDIX 279

Because it had numbers that should or should

15 not have -- we don't know because nobody was at the

16 actual negotiations of that tentative agreement or that

17 Transition Agreement except the parties who were there,

18 right? Would that be -- you wouldn't -- you didn't

19 have any paper that says what I was supposed to be

20 paid?

21 A. No, I didn't.

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 18 of 46 PageID 6957
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Page 214

1 THE ARBITRATOR: Well --

2 MR. ROSS: I have -- I have.

3 (Simultaneous speaking.)

4 THE ARBITRATOR: Look --

5 MR. ROSS: The reason -- the reason I'm

6 trying to bring it up --

7 THE ARBITRATOR: You can argue this in

8 brief, okay?

9 MR. ROSS: Okay.

10 THE ARBITRATOR: Let's go on to

11 something else.

12 Q. (BY MR. ROSS) The documentation that you sent

13 when you responded is the same documentation; is

14 that --

15 A. Yes.

16 Q. They're a duplicate --

17 A. Yes.

18 Q. -- right? So when Diversified came and got

19 all the documents that Ross himself prior didn't

20 understand and couldn't figure out and asked questions

21 about, when -- when Ross received this, and can you

22 look at it and can you see that it's the same documents

23 that went to Diversified that you had sent Mr. Ross?

24 A. Yes.

25 Q. Okay. So instead of Ross understanding what

APPENDIX 280

MR. ROSS: The reason -- the reason I'm

6 trying to bring it up --

7 THE ARBITRATOR: You can argue this in

8 brief, okay?

THE ARBITRATOR: Let's go on to

11 something else.

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 19 of 46 PageID 6958
Robert Ross 11/17/2021

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Page 215

1 it was and still didn't understand what it was,

2 Diversified Credit just simply got all the exact same

3 documents, right?

4 A. Right.

5 Q. Okay. Look at the very front page and -- on

6 Diversified where the number one is checked.

7 A. Yes.

8 Q. Can you read that?

9 A. We have determined that the information in our

10 file regarding the account is accurate. Attached

11 hereto is validation of the account information in our

12 file.

13 Q. Okay. Are they accountants? Do they know the

14 inner workings? Have they ever seen Ross' Transition

15 Agreement? That's three questions, but --

16 MS. CHINERY: Objection, your

17 transition, what does that have to do with --

18 THE ARBITRATOR: Yeah, they're not --

19 MR. ROSS: Since Ross was paid for his

20 Transition Agreement --

21 THE ARBITRATOR: Okay. Mr. Ross --

22 MR. ROSS: Alls I did was just --

23 THE ARBITRATOR: Mr. Ross, this -- this

24 outfit, Diversified, they're not aware of the

25 Transition Agreement.

APPENDIX 281

THE ARBITRATOR: Mr. Ross, this -- this

24 outfit, Diversified, they're not aware of the

25 Transition Agreement.

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 20 of 46 PageID 6959
Robert Ross 11/17/2021

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Page 216

1 MR. ROSS: Right.

2 THE ARBITRATOR: Okay. And so --

3 MR. ROSS: How could they still -- how

4 can they attest --

5 THE ARBITRATOR: Well, you're making an

6 assumption that they looked at your Transition

7 Agreement. Let's, you know --

8 MR. ROSS: No, I'm sorry --

9 THE ARBITRATOR: -- you --

10 MR. ROSS: -- that's not the right

11 assumption as --

12 THE ARBITRATOR: Okay.

13 THE WITNESS: It's also a part of -- did

14 say it's also a part of pending litigation. So we --

15 we -- she doesn't want us to discuss much of the

16 collections in -- in that as well, so --

17 THE ARBITRATOR: Okay.

18 Q. (BY MR. ROSS) Has Ross ever -- has Ross

19 ever --

20 THE ARBITRATOR: Is that -- is that

21 true --

22 MR. ROSS: That's not --

23 THE ARBITRATOR: -- that they --

24 MR. ROSS: -- true.

25 THE ARBITRATOR: -- say pending

APPENDIX 282

THE ARBITRATOR: Well, you're making an

6 assumption that they looked at your Transition

7 Agreement. Let's, you know --

MR. ROSS: -- that's not the right

11 assumption as --

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 21 of 46 PageID 6960
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1 litigation.

2 MR. ROSS: No, they claim it is that I

3 received no -- no litigation, I've received zero --

4 THE ARBITRATOR: Notice.

5 MR. ROSS: -- no, they've -- they've

6 called, I've talked to them. I finally had to tell

7 them that -- Diversified that I'm not going to have a

8 conversation with them because they report and --

9 THE ARBITRATOR: That's okay --

10 (Simultaneous speaking.)

11 MS. CHINERY: Objection --

12 THE REPORTER: I can't --

13 THE ARBITRATOR: So let me -- let me say

14 this, Mr. Ross. We've gone through this a lot --

15 MR. ROSS: Right.

16 THE ARBITRATOR: -- today. You can argue

17 this in a brief. You can show the formulas, you can do

18 whatever, but you can argue it in the brief and let's

19 get on with this. Let's ask what other questions you

20 have of Mr. Harris.

21 MR. ROSS: That was a -- that was a major

22 part of it, because that statement right there --

23 THE ARBITRATOR: No, what --

24 MR. ROSS: (Unintelligible.)

25 THE ARBITRATOR: -- did I say? Let's go

APPENDIX 283

THE ARBITRATOR: -- today. You can argue

17 this in a brief. You can show the formulas, you can do

18 whatever, but you can argue it in the brief and let's

19 get on with this. Let's ask what other questions you

20 have of Mr. Harris.

THE ARBITRATOR: -- did I say? Let's go

MR. ROSS: That was a -- that was a major

22 part of it, because that statement right there --

23 THE ARBITRATOR: No, what --

24 MR. ROSS: (Unintelligible.)

1 litigation.

2 MR. ROSS: No, they claim it is that I

3 received no -- no litigation, I've received zero --

4 THE ARBITRATOR: Notice.

5 MR. ROSS: -- no, they've -- they've

6 called, I've talked to them. I finally had to tell

7 them that -- Diversified that I'm not going to have a

8 conversation with them because they report and --

9 THE ARBITRATOR: That's okay --

10 (Simultaneous speaking.)

11 MS. CHINERY: Objection --

12 THE REPORTER: I can't --

13 THE ARBITRATOR: So let me -- let me say

14 this, Mr. Ross. We've gone through this a lot --

15 MR. ROSS: Right.

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1 on. Let's move on.

2 MR. ROSS: We'll deal with this in brief.

3 Q. (BY MR. ROSS) When Ross was put into

4 collections, was he put into collections by will of the

5 Board or did he -- at that point had he violated any --

6 MS. CHINERY: Objection, he didn't pay

7 his bill.

8 THE REPORTER: I didn't understand that.

9 THE ARBITRATOR: Well, you know, he's

10 asking a question and I told you, let's go to something

11 else, okay?

12 MR. ROSS: Want to get completely off of

13 that. Okay.

14 MS. BRUNS: Move from collections to

15 something else.

16 MR. ROSS: (Sotto voce.) Yeah, can we

17 take a -- take a break here?

18 THE ARBITRATOR: No, let's -- let's

19 finish with this witness, okay?

20 Q. (BY MR. ROSS) Do you recall an email between

21 an update on the former National Officers which were

22 paid out on November 10th, 2019?

23 A. August 10th, 2019?

24 Q. Yes.

25 A. No.

APPENDIX 284

Robert Ross 11/17/2021

Page 218

1 on. Let's move on.

Carson Reporting & Associates 214.346.3434

MR. ROSS: We'll deal with this in brief.

3 Q. (BY MR. ROSS) When Ross was put into

4 collections, was he put into collections by will of the

5 Board or did he -- at that point had he violated any --

6 MS. CHINERY: Objection, he didn't pay

7 his bill.

8 THE REPORTER: I didn't understand that.

9 THE ARBITRATOR: Well, you know, he's

10 asking a question and I told you, let's go to something

11 else, okay?

12 MR. ROSS: Want to get completely off of

13 that. Okay.

14

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 23 of 46 PageID 6962
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Page 325

1 STATE OF TEXAS )

2 COUNTY OF DALLAS )

3 THIS IS TO CERTIFY THAT I, MELISSA J. CARSON,

4 a Certified Shorthand Reporter in and for the State of

5 Texas, reported in shorthand the proceedings had at the

6 time and place set forth in the caption hereof, and

7 that the above and foregoing 302 pages contain a full,

8 true, and correct transcript of the said proceedings.

9 Certified to on this the 13th day of December,

10 2021.

11

12

13 ____________________________

 MELISSA J. CARSON, Certified

14 Shorthand Reporter in and for

 The State of Texas

15

16

17 Certification No. 1737

18 CRCB Firm Registration #489

19 Expires August 31, 2022

20 CARSON REPORTING & ASSOCIATES

21 Post Office Box 551628

22 Dallas, Texas 75355-1628

23 Telephone 214.346.3434

24

25

APPENDIX 285

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 24 of 46 PageID 6963
AFFIDAVIT OF EUGENIO VARGAS – Page 1 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

 FT. WORTH DIVISION 

ROBERT “BOB” ROSS §

Plaintiff/Counterclaim Defendant § 

§ Case No. 4:22-CV-00343-Y 

§

 § 

ASSOCIATION OF 

PROFESSIONAL FLIGHT 

ATTENDANTS, MCGAUGHEY, 

REBER AND ASSOCIATES, INC., 

JULIE HEDRICK, ERIK HARRIS, 

LARRY SALAS, JOSH BLACK 

§ 

§ 

§ 

§ 

§ 

§ 

Defendants/Counterclaim Plaintiff. § 

§ 

EUGENIO VARGAS §

Plaintiff/Counterclaim Defendant § 

§ Case No. 4:22-CV-00430-Y 

§

 § 

ASSOCIATION OF 

PROFESSIONAL FLIGHT 

ATTENDANTS, JULIE HEDRICK, 

ERIK HARRIS, LARRY SALAS, 

JOSH BLACK 

§ 

§ 

§ 

§ 

§ 

Defendants/Counterclaim Plaintiff. § 

§ 

AFFIDAVIT OF EUGENIO VARGAS IN SUPPORT OF MOTION FOR SUMMARY 

JUDGMENT 

BEFORE ME, the undersigned authority, on this day personally appeared EUGENIO 

VARGAS, who being by me first duly sworn, did state: 

1. “I have been employed as a flight attendant working with American Airlines, Inc.

since November 1995. I am also a member of the Association of Professional Flight

Attendants (“APFA”). I have personal knowledge of the facts contained herein, I

am 21 years or older and of sound mind to make these statements.

APPENDIX 286

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 25 of 46 PageID 6964
AFFIDAVIT OF EUGENIO VARGAS – Page 2 

2. I have read the foregoing Plaintiff’s Motion for Partial Summary Judgment and 

every factual contention for which I have personal knowledge is true and correct. 

3. I am a current member of APFA in good standing. I met with an investigator with 

the United States Department of Labor in 2021 investigating the end-of-term 

payments I made while National Treasurer to myself, Marcy Dunaway, Nena 

Martin, and Robert “Bob” Ross. I have never been charged with or convicted of a 

crime. 

4. On April 1, 2016 I was voted into office as the APFA National Treasurer. While 

serving in office, I made public statements with regard to union-related matters in 

opposition of a merger between the Association of Flight Attendants-CWA’s 

(“AFA”) or affiliation of any kind, with the APFA. After multiple attempts were 

made by AFA to effectuate a merger or a “raid” of APFA during 2016, I assisted in 

drafting a letter to AFA’s International President requesting that all attempts to 

merge or ‘raid’ our union cease immediately. I authorized my signature to be used 

on the letter dated July 4, 2017. A true and correct copy of a draft of the July 4, 

2017 letter sent by the Ross Administration to the AFA during my term in office as 

National Treasurer is attached hereto and incorporated herein. Additionally, this 

letter was read aloud at a labor coalition meeting by Ross in which AFA’s 

International President was in attendance on behalf of the entire Ross 

Administration. The original copy of the letter was left in the APFA archives. 

5. I have also held other positions within the APFA prior to being voted to the National 

Treasurer’s position with the Ross Administration, including a position sitting on 

the APFA Board of Directors for two different terms. I have vocally opposed any 

APPENDIX 287

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 26 of 46 PageID 6965
AFFIDAVIT OF EUGENIO VARGAS – Page 3 

merger or affiliation between APFA and AFA while in these positions. I continue 

to support the American Airlines Flight Attendants union as an individual and 

independent labor union and continue to oppose any affiliation with AFA in the 

future. 

6. On March 2, 2018, I learned that Robert “Bob” Ross (“Ross”) had negotiated and 

signed a Transition Agreement for his resignation from Mark Richards, Counsel for 

APFA at the time. Mark Richards showed me and APFA’s in-house Senior 

Accountant Rene Berthelot sections 3, 4, and 5 of the Transition Agreement that 

addressed Ross’s compensation on one occasion. In consultation with APFA Senior 

Accountant, Rene Berthelot, I calculated the payments made to Ross under his 

Transition Agreement. The payment calculations were approved by other APFA 

National Officers then forwarded to payroll and accounting staff for payment. I did 

not discuss nor consult with Ross about how to calculate these payments; Ross had 

no input on the calculations and payments made to him. I calculated the daily rate 

of pay using this total taxable annual income including the Meal Expense 

Allowance and the Special Assignment Fee guaranteed stipends and then dividing 

the amount by 365. This was in consultation with Rene Bartholet, APFA’s Senior 

Accountant. It was similar to the per diem calculation used to calculate payments 

made under Laura Glading’s, the prior APFA National President, Transition 

Agreement. 

7. In 2019, I was contacted by APFA and told that I owed an overpayment made based 

on a miscalculation of the daily rate used to calculate and pay out my sick and 

vacation end-of-term payout. After several months of requesting a meeting, I met 

APPENDIX 288

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 27 of 46 PageID 6966
AFFIDAVIT OF EUGENIO VARGAS – Page 4 

with Hal O’Neil, APFA’s outside accountant, Nena Martin and Marcy Dunaway, 

and Craig Gunter, APFA National Treasurer at the time, to review and discuss the 

miscalculation and alleged overpayment owed. At this meeting, I informed Craig 

Gunter that the same method of calculation for the end-of-term payouts were used 

for myself, Nena Martin, and Marcy Dunaway as were used for Robert “Bob” Ross. 

APFA Board of Directors and APFA Legal Counsel met with me via telephone 

conference, wherein I was told APFA would file a lawsuit for my actions while in 

office based on this miscalculation. APFA agreed not sue me if I would repay the 

overpayment of the end-of-term payout. I agreed to repay APFA the amount of 

$4,143.57 and signed a promissory note in that amount. I have made all payments 

thereunder. 

8. APFA Policy provided that calculations for payments were made in conjunction 

with staff accountants, reviewed and approved by two APFA officers for 

compliance with policy, and approved by two additional APFA accounting 

personnel for accuracy of calculation, budgeting purposes, and issuance of 

payment. If anything did not meet my approval, I escalated all matters to APFA 

Board of Directors for approval. I always followed procedures and policies while 

in office. 

9. On September 14, 2021, Chinery v. Vargas Arbitration Hearing was held which I 

attended and was represented by Heidi Morgan and Nena Martin. During the 

Arbitration Hearing, I subpoenaed all four national officers to testify. Erik Harris 

testified regarding the overpayment damages and declared Ross was overpaid as a 

result of the change in the per diem formula used to pay out sick and vacation days 

APPENDIX 289

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 28 of 46 PageID 6967
AFFIDAVIT OF EUGENIO VARGAS – Page 5 

under his Transition Agreement. Additionally, I never received the Confidential 

Memo prior to or during the Arbitration Hearing. Erik Harris never informed the 

Arbitrator of the Confidential Memo. 

10. All evidence and testimony regarding the Ross Transition Agreement was limited 

by the Arbitrator during my Arbitration Hearing. I was unable to fully question 

witnesses or present evidence about the interpretation of terms, the calculation of 

payments, or the determination of an overpayment. 

11. I objected to witnesses that were intimidated and harassed to alter their testimony 

or prevent them from testifying for me. I was not provided with the chance to admit 

this evidence or address this issue at my Arbitration Hearing by the Arbitrator. 

Attached is a true and correct copy of an affidavit that I was denied admission on 

record by the Arbitrator. 

12. To my personal knowledge, APFA has never banned an APFA member from 

holding office for life, until myself and Robert “Bob” Ross received Article VII 

Arbitration Awards. 

13. To my personal knowledge, APFA has never publicly announced an Article VII 

Award in a Presidential Hotline Email to the APFA membership, until myself and 

Robert “Bob” Ross received Article VII Arbitration Awards. A true and correct 

copy of the Presidential Hotlines emailed to the APFA membership are attached 

hereto and incorporated herein. 

14. Attached hereto and incorporated herein is a true and correct copy of the Article 

VII Arbitration Award issued against me on February 17, 2022. 

15. Attached hereto and incorporated herein is a true and correct copy of the 

APPENDIX 290

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 29 of 46 PageID 6968
AFFIDAVIT OF EUGENIO VARGAS – Page 6 

Supplemental Arbitration Award increasing the fines against me to $30,963.03 

based on an audit conducted by APFA. 

16. I was not given notice of the manner in which the audit was conducted, nor ever 

given a copy of the documents used to create the audit. I was never given the 

opportunity to attend or witness the audit. No one ever contacted me or my 

representatives to inquire as to expenses or charges and the circumstances 

surrounding those charges. 

17. Attached hereto and incorporated herein are the receipts for all costs and expenses 

incurred because of my Article VII Disciplinary Arbitration as well as the final day 

of the Arbitration which was unpaid. The daily pay rate is $341.25. The costs of 

the hotel stay for the witnesses, plus costs all other additional costs totaled 

$1,842.05. The total amount of actual damages from Article VII Arbitration 

Hearing are $2,183.30. 

18. I have publicly opposed any possible merger between AFA and APFA. The Article 

VII Arbitration Award, the ban against my ability to hold office and the public 

statements made against me have intimidated me and stifled my dissent, as I fear 

that I will suffer retaliation by my labor union for my position against APFA. 

19. Attached hereto and incorporated herein is a true and correct copy of a letter from 

Erik Harris to all parties in my Arbitration related to documents that could not be 

located. This was an exhibit used in my Arbitration Hearing to question Erik Harris 

about missing documentation and whether the documents were well maintained.” 

 

FURTHER AFFIANT SAYETH NOT. 

APPENDIX 291

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 30 of 46 PageID 6969
AFFIDAVIT OF EUGENIO VARGAS – Page 7 

 ____________________________________ 

 Eugenio Vargas 

SWORN AND SUBSCRIBED TO before me on this _____day of _____________ 2024. 

____________________________________

Notary Public 

25th April 

County of Rockwall, State of Texas. Signer(s): Eugenio 

Vargas, appeared with Texas DL, as identification along with 

multi-factor KBA authentication, during this audio/video 

recorded remote online notarization. 

___________________

t P bli Sonia Platz 

__________________________

APPENDIX 292

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 31 of 46 PageID 6970
July 4, 2017 

Sara Nelson, President DRAFT 

Association of Flight Attendants 

1275 K Street NW 5th Floor 

Washington, D.C. 20006 

Dear Sara: 

As AFA’s President, you have sent many messages, both publicly and through AFA’s 

mobilization efforts to get the public and APFA members to rally behind your effort to get APFA 

to affiliate with AFA. Despite your attempt to characterize AFA’s conduct as a friendly overture 

rather than a hostile raid, you did not even have the courtesy to send the message to any of the 

APFA National Officers or Board of Directors. 

You have, however, gone to the extent of sending AFA letters, Bag Tags and AFA pins to APFA 

members, as well as forcefully stating at the recent Coalition of Labor Unions meeting on May 

11, 2017 “APFA stole 6000 of our AFA members and we are not going to stop until we have 

every one of them back”. 

You have also requested that APFA, along with our legal advisors, schedule a meeting with 

AFA, however you have refused our premeeting requirement to sign a no-raid agreement and 

also agree that any meeting between us would not include a discussion about a possible merger 

between AFA and APFA. 

As APFA’s National Officers, we once again wish to make it absolutely clear to you and any 

other AFA leaders who may support you in this matter that APFA is not interested in a 

discussing any affiliation with AFA. Moreover, any AFA effort to infiltrate the APFA Board of 

Directors will not work. 

It is APFA’s firm belief that a union’s efforts to organize is best utilized in organizing 

“unorganized” workers. Therefore, we not only ask, but we demand that you leave APFA and its 

membership alone, and direct your energies and resources elsewhere. 

On behalf of the APFA and the more than 26,000 Flight Attendants we represent, 

Bob Ross Nena Martin 

President Vice-President 

Marcy Dunaway Eugenio Vargus 

Secretary Treasurer 

APPENDIX 293

Bob Ross Nena Martin 

President Vice-President

Marcy Dunaway y Eugenio Vargus

Secretary 

g

Treasurer

As APFA’s National Officers, g we once again wish to make it absolutely clear to you and any y y

other AFA leaders who may pp y su ort you in this matter that APFA is not interested in a

discussing any affiliation with AF g y A. Moreover, any AFA effort to infiltrate the APFA Board of

Directors will not work.

It is APFA’s firm belief that a union’s efforts to organizeis best utilized in org g anizing

“unorganized” workers. Therefore, y, we not only ask, but we demand that you leave APFA and its

membership alone, and direct your energies and resources elsewhere. 

members, yg as well as forcefully stating at the recent Coalition of Labor Unions meeting on May g

11, 2017 “APFA stole 6000 of our AFA members and , we are not going to stop until we have 

every one of them back”.

You have, ,g however, gone to the extent of sending AFA letters, Bag Tags and AFA pins to APFA g ,gg p

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 32 of 46 PageID 6971
APPENDIX 294

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 33 of 46 PageID 6972
APPENDIX 295

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 34 of 46 PageID 6973



	


	 	

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APPENDIX 296

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 35 of 46 PageID 6974
8/1/22, 11:03 PM 3.24.22 – APFA Receives Article VII Arbitration Awards – APFA

https://www.apfa.org/2022/03/24/3-24-22-apfa-receives-article-vii-arbitration-awards/ 1/7

Search here...

3.24.22 – APFA Receives Article VII Arbitration Awards



APPENDIX 297

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 36 of 46 PageID 6975
8/1/22, 11:03 PM 3.24.22 – APFA Receives Article VII Arbitration Awards – APFA

https://www.apfa.org/2022/03/24/3-24-22-apfa-receives-article-vii-arbitration-awards/ 2/7



APPENDIX 298

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 37 of 46 PageID 6976
8/1/22, 11:03 PM 3.24.22 – APFA Receives Article VII Arbitration Awards – APFA

https://www.apfa.org/2022/03/24/3-24-22-apfa-receives-article-vii-arbitration-awards/ 3/7

	

		

		


 		

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APPENDIX 299

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 38 of 46 PageID 6977
8/1/22, 11:03 PM 3.24.22 – APFA Receives Article VII Arbitration Awards – APFA

https://www.apfa.org/2022/03/24/3-24-22-apfa-receives-article-vii-arbitration-awards/ 4/7

	










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APPENDIX 300

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 39 of 46 PageID 6978
8/1/22, 11:03 PM 3.24.22 – APFA Receives Article VII Arbitration Awards – APFA

https://www.apfa.org/2022/03/24/3-24-22-apfa-receives-article-vii-arbitration-awards/ 5/7

	
	




				
	

	
		


 		
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APFA Events

2022 Fall Board of Directors Meeting

(https://www.apfa.org/event/2022-fall-board-ofdirectors-meeting/)



APPENDIX 301

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 40 of 46 PageID 6979
8/9/22, 5:36 PM Lawsuits Filed Against APFA

https://mailchi.mp/apfa.org/lawsuits-filed-against-apfa?e=cb0c5b0668 1/3

Monday, June 6, 2022

Lawsuits Filed Against APFA

One of the first steps we took upon taking office a little over two years ago was reasserting

APFA’s adherence to financial accountability and transparency. Our administration and your

Board of Directors implemented financial reform in many sections throughout our Policy

Manual, but there is still more to accomplish. 

 

Both the law and the APFA Constitution are clear- APFA members have a right to review

the union’s financial records to see how our dues dollars are spent. Previous allegations of

financial impropriety were swept under the rug in the name of unity or protecting the

institution. 

 

After an in-depth review of APFA’s financial records, members brought forward charges

under Article VII of the APFA Constitution against former APFA National President Bob Ross

and former APFA National Treasurer Eugenio Vargas for financial malfeasance and

mismanagement. The problem is clear: APFA’s structure lacks a higher level of financial

oversight above the National Officer level. Our National Officers are expected to do the right

thing concerning financial accountability. Under our imperfect system of checks and

balances, APFA members are tasked with attempting to ensure financial accountability at

APFA. 

The aforementioned charges were heard by one of the most respected arbitrators in the

country who had no prior involvement with APFA, Arbitrator Ruben Armendariz, a board

member of the prestigious National Academy of Arbitrators. After days of hearing and

reviewing lengthy briefs, Arbitrator Armendariz issued decisions in each case in February

and March of this year and took the extraordinary step of banning both former officers from

holding any position for life in APFA. Both were fined and ordered to repay certain costs

related to the arbitration. In addition, Arbitrator Armendariz ordered an independent audit

of meal expenses, car rentals, furniture purchases, and personal vacation expenses paid for

by APFA, which is ongoing. 

In the Vargas award, after a three-day hearing and full exchange of evidence, Arbitrator

Armendariz determined: “It is this arbitrators Opinion, Vargas attempted to benefit

monetarily and thus failed in his fiduciary duty as National Treasurer by willfully changing

the formula for the payouts for Bob Ross, Nena Martin, and Marcy Dunaway as well as

himself.” Arbitrator Armendariz also found Vargas failed in his duty to properly inventory

furniture and ordered an audit of meal expenses. 

In the Ross award, Arbitrator Armendariz determined that “Defendant Ross has

overwhelmingly violated the APFA Policy Manual and APFA Constitution.” Arbitrator

APPENDIX 302

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 41 of 46 PageID 6980
8/9/22, 5:36 PM Lawsuits Filed Against APFA

https://mailchi.mp/apfa.org/lawsuits-filed-against-apfa?e=cb0c5b0668 2/3

Armendariz further stated: "The arbitrator finds that throughout this proceeding, Defendant

Ross intentionally and willfully ignored the provisions of the APFA Policy Manual and thus,

has violated and abused his fiduciary duty entrusted to him by the APFA membership.

Ross’s testimony was inconsistent and not forthright. Because Ross abused his position of

trust as well as his fiduciary duty to the membership of the APFA, he can no longer hold a

position of trust with the APFA."

The arbitrator took the rare step of ordering Mr. Ross to pay the full cost of the hearing and

repay APFA for certain infractions. Ross was banned from holding any position with APFA for

life and told to resign as SFO Base President.

To be clear, what was uncovered in these hearings was nothing short of shocking. The union

credit card was used to the tune of tens of thousands of dollars on furniture and meals for

officers with insufficient documentation or adherence to proper procedure. Much of

this furniture is still unaccounted for. Key financial records are missing, and the meal policy

was often not adhered to.

This should have been the end of the matter, and APFA should be able to focus on defending

and negotiating our contract with American Airlines.

In the aftermath of the arbitration awards, rather than accepting the rulings, the Ross and

Vargas teams have chosen to go to Federal Court to attempt to overturn the arbitration

awards. In complaints filled with conspiracy theories and dubious legal theories, they argue

everyone is to blame but themselves.

Click here to read the Ross v APFA complaint.

Click here to read APFA's response to the Ross v APFA complaint.

Click here to read the Vargas v APFA complaint.

(Because the Vargas complaint was filed after the Ross complaint, APFA's

response to the Vargas v APFA complaint has not yet been filed with the court.)

The law and the APFA Constitution are very clear that arbitration awards are final and

binding. By suing APFA to overturn the awards, the charged parties will cost the APFA

membership a great deal of dues money in the form of legal fees (unless the charged

parties are required to pay costs). These lawsuits serve no purpose but to divert attention

from the workplace issues that matter to our Flight Attendants.

Another concern is the corruption that existed within APFA by limiting members' access to

union financials out of fear that others would uncover potential impropriety. In the past,

APFA Leaders were advised by their outside legal counsel to limit financial transparency and

“protect the institution.” The lack of financial oversight of APFA National Officers has created

these problems. As a result, we are forced to hire an outside arbitrator to oversee Article

VII charges, which is a costly procedure. Article VII, Section 6.H of the APFA Constitution

provides that the decision of the Article VII Arbitrator shall be final and binding on the

accuser and the accused. When we receive an arbitration award and the accused parties

refuse to accept the results, they make a mockery of the APFA Constitution, and we must

spend our dues dollars on defending our union and our leadership, instead of using those

finances to improve the work lives of the membership. APFA cannot continue to operate this

way in the long term.

We don't believe it was always this way at APFA. The founders of our union broke free from

APPENDIX 303

To be clear, what was uncovered in these hearings was nothing short of shocking. The union

credit card was used to the tune of tens of thousands of dollars on furniture and meals for

officers with insufficient documentation or adherence to proper procedure. Much of

this furniture is still unaccounted for. Key financial records are missing, and the meal policy

was often not adhered to

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 42 of 46 PageID 6981
8/9/22, 5:36 PM Lawsuits Filed Against APFA

https://mailchi.mp/apfa.org/lawsuits-filed-against-apfa?e=cb0c5b0668 3/3

the male-dominated Transport Workers Union (TWU) and formed a union focused on Flight

Attendants. By all accounts, they ran a clean union, and we have many accomplishments

over the years. But things change, and good intentions are not enough. Over the last

decade, this union has lurched from one internal crisis to another. 

 

APFA members work hard for our dues money every day. We believe in the work conducted

at APFA and all the Leaders and Flight Attendants who make up our union. 

 

We deserve to know our dues are being spent for their intended purpose. We will maintain

financial transparency, vigorously defend this union, and keep you apprised of the status of

these lawsuits. 

In Solidarity, 

About APFA:

The Association of Professional Flight Attendants (APFA) represents the 24,000+ Flight

Attendants of American Airlines, an airline that consists of aviation professionals with a

diverse history brought together from multiple airlines. From APFA’s inception in 1977, the

Union has fiercely advocated for the Flight Attendant profession. Our Union has been at the

forefront of the fight for workplace equality, legislative affairs, and worker’s rights.

APFA Headquarters:

(817) 540-0108 | www.apfa.org | 1004 W. Euless Blvd, Euless, TX 76040

Unsubscribe nenarott@aol.com from this list | Forward to a friend | Update your profile 

Copyright (C) 2022 APFA All rights reserved.

APPENDIX 304

Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 43 of 46 PageID 6982
	
 


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Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 44 of 46 PageID 6983
	
 


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Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 45 of 46 PageID 6984
	
 


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Case 4:22-cv-00343-Y Document 239-6 Filed 04/26/24 Page 46 of 46 PageID 6985