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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

§

§ 

§ 

§ 

§ 

§

Defendants/Counterclaim Plaintiff. §

§

PLAINTIFF’S SETTLEMENT CONFERENCE STATEMENT

COME NOW, Plaintiff Robert “Bob” Ross (“Plaintiff”), by and through his undersigned 

counsel, and submits this Plaintiff’s Settlement Conference Statement: 

The parties attended a settlement conference for Robert “Bob” Ross v. APFA, et al on 

March 27, 2023. In attendance were: 

Robert “Bob” Ross, Plaintiff 

Kerri Phillips, Plaintiff’s Counsel 

Sanford Denison, Defendants’ Counsel 

Julie Hedrick, Association of Professional Flight Attendants (hereinafter “APFA”) 

National President

Erik Harris, APFA National Treasurer 

Charlette Matts, In-House counsel for APFA, 

An Agent on behalf of McGaughey Reber and Associates, Inc. DBA Diversified Credit 

Michael Rake, McGaughey Reber and Associates, Inc. DBA Diversified Credit’s counsel 

of record. 

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Defendant, Diversified Credit, and Plaintiff have discussed settlement. Plaintiff made an 

offer that is currently being discussed to resolve the pending claims. The likelihood for settlement 

is optimistic regarding the claims pending against Diversified Credit. 

However, regarding Defendants, APFA and its individual officers, unfortunately

settlement is not likely at this point. Plaintiff put forth multiple offers for settlement to Defendants, 

APFA, Erik Harris and Julie Hedrick, which would allow Plaintiff to continue employment with 

the employer, American Airlines, Inc., without continuing to endure the abuse suffered from the 

Union and its officers’ conduct. As of the filing of this pleading, all offers for settlement made by 

the Plaintiff have been rejected by Defendants. 

Currently, Defendants are unable or unwilling to settle due to their concerns about

additional liability and/or additional lawsuits resulting from the charging parties against Plaintiff 

in the Arbitration/Union Disciplinary action—Melissa Chinery-Burns and Sandra Lee. 

Defendants’ Counsel made clear that Defendant, APFA, is contractually liable if settlement occurs 

on its counterclaims. Defendant, APFA, must first have a final judicial resolution to its Motion to 

Enforce the Arbitration Award and Breach of Fiduciary Duty claimsto consider settlement without 

accepting risks of liability from others. As of the date of this filing, Defendant, APFA, is unable 

to negotiate settlement or mediate in good faith as it is contractually required to enforce an 

arbitration award acquired by its membership on its behalf and refuses to acknowledge the 

fraudulent means used to acquire it. As of the date of this filing, settlement is not likely based on 

the pending counterclaims by APFA and its perceived liability. 

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Respectfully submitted,

KD PHILLIPS LAW FIRM, PLLC

 

By: /s/ Kerri Phillips______________ 

Kerri Phillips, Esq.

Texas Bar No. 24065906

Phone: (972) 327-5800

Email: kerri@KDphillipslaw.com

6010 W. Spring Creek Parkway

Plano, Texas 75024

Fax: (940) 400-0089

For Service of Filings: 

notice@KDphillipslaw.com

ATTORNEY FOR 

PLAINTIFF/COUNTERCLAIM 

DEFENDANT 

 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 3rd day of April 2023 a true and correct copy of 

the foregoing instrument was served upon Defendants’ attorneys via the e-filing manager 

and email to at denison@baabdenison.com, b.osborne@osbornelaw.com and

mrake1@mrakeattorney.com respectively. 

/s/ Kerri Phillips ________ 

Kerri Phillips, Esq.

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