IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

EUGENIO VARGAS,

 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

APPENDIX IN SUPPORT OF THE APFA DEFENDANTS’ RESPONSE IN OPPOSITION TO 

MOTION TO QUASH AND FOR PROTECTIVE ORDER

Pursuant to Local Rule 7.1(i) and Section II.C of this Court’s Case Management 

Requirements, the Association of Professional Flight Attendants (“APFA”) submits this appendix 

of materials cited in its Response in Opposition to Motion to Quash and for Protective Order:

Description Appendix Pages

Joshua Black’s Declaration Appx 1-4

Exhibit A – 2024 APFA National Officer Elections Appx. 5-10

Exhibit B – Special Board of Directors Teleconference Appx. 11-14

Exhibit C – Annual Board of Directors Convention Appx. 15-16

Exhibit D – Letter re: Ross Willingness-to-Serve nomination Appx. 17-18

Exhibit E – Letter re: Vargas Willingness-to-Serve nomination Appx. 19-20

Exhibit F – 2024 National Officer Elections: Candidate 

Announcement Appx. 21-25

Plaintiff’s Responses and Objections to APFA Defendants’ First Set of 

Interrogatories to Eugenio Vargas

Appx. 26-28

Plaintiff’s Responses and Objections to APFA Defendants’ 

Second Set of Requests for Production to Eugenio Vargas Appx. 29-31

(Relates to Motion Referred to

Magistrate Judge Cureton)

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 1 of 34 PageID 4920
2

Dated: December 13, 2023 Respectfully submitted,

 /s/ James D. Sanford

JAMES D. SANFORD 

Tex. Bar No. 24051289

Gillespie Sanford LLP 

4803 Gaston Ave.

Dallas, TX 75246

Tel.: (214) 800-5111; Fax.: (214) 838-0001

Email: jim@gillespiesanford.com

JEFFREY A. BARTOS (pro hac vice)

D.C. Bar No. 435832

Guerrieri, Bartos & Roma, PC

1900 M Street, N.W. Suite 700

Washington, DC 20036

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

Email: jbartos@geclaw.com

Counsel for Defendant and Counterclaim Plaintiff 

Association of Professional Flight Attendants, and 

Defendants Julie Hedrick and Erik Harris

CHARLETTE L. MATTS (pro hac vice) 

Tex. Bar No. 24133870

Association of Professional Flight Attendants 

1004 W. Euless Blvd.

Euless, TX 76040

Tel.: (682) 301-8454

Email: Cmatts@apfa.org

Counsel for Defendant and Counterclaim Plaintiff 

Association of Professional Flight Attendants

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 2 of 34 PageID 4921
3

CERTIFICATE OF SERVICE

I certify that on December 13, 2023, a true and correct copy of the foregoing Appendix of 

Materials Cited In APFA Defendants’ Response in Opposition to Motion to Quash and for 

Protective Order was served upon all persons who have requested notice and service of pleadings 

in this case via the Court’s ECF system. 

KERRI PHILLIPS

K.D. Phillips Law Firm, PLLC

6010 W. Spring Creek Parkway

Plano, TX 75024

Phone: (972) 327-5800

Fax: (940) 400-0089

Email: kerri@KDphillipslaw.com

MICHAEL R RAKE

Michael R. Rake, Attorney at Law PO Box 1556 

Lake Dallas, TX 75065 

Tel.: (940) 498-2103

Fax: (940) 498-2103

Email: mrake1@mrakeattorney.com

/s/ James D. Sanford

JAMES D. SANFORD

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 3 of 34 PageID 4922
DECLARATION OF JOSHUA BLACK

Joshua Black hereby declares as follows:

1. I am an adult resident of the State of Texas and make this Declaration based on 

my personal knowledge.

2. I am the National Secretary for the Association of Professional Flight Attendants

(“APFA”). Pursuant to Article III, Section 6.D.6 of the APFA Constitution and Section 14.D.5 of 

the APFA Policy Manual, the National Secretary provides oversight and administrative 

assistance to the National Ballot Committee (“NBC”), which has the responsibility to carry out 

all aspects of APFA elections. However, the National Secretary is not a member of the NBC and 

has no decision-making authority within the NBC. 

3. Article VI of the APFA Constitution sets out the timeline for candidate 

nominations, balloting, and election contests for office. 

4. On November 2, 2023, the NBC issued the 2024 APFA National Officer 

Elections Hotline, which outlines the 2024 National Officer elections timeline and provides

information about the virtual candidate forum, the voting method, candidate booklets, candidate 

eligibility, and voting eligibility and instructions to the membership about how to update their 

addresses with APFA. (Exhibit A). From November 7, 2023, at 10:00 a.m. Central Standard 

Time, until December 7, 2023, at 10:00 a.m. Central Standard Time, active members in good 

standing were able to nominate themselves or another active member in good standing for a 

National Officer position by submitting Willingness-to-Serve (“WTS”) notifications on apfa.org.

5. In accordance with Section 14. H of the APFA Policy Manual, after the close of 

the WTS on December 7, 2023, two members of the NBC retrieved the WTS notifications from 

the election submission site. The NBC members examined the WTS notifications to determine

the nominated persons and their references’ eligibility. 

APPENDIX 1

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2

6. Plaintiffs Ross and Vargas did not submit any WTS notifications nominating 

themselves for National Officer positions. Five WTS notifications were submitted by non-party 

APFA members nominating Bob Ross for the APFA National President position and one nonparty member submitted a WTS notification nominating Eugenio Vargas for the APFA National 

Treasurer position.

7. The NBC members withdrew those WTS notifications in accordance with binding

Opinion and Awards issued by Article VII Arbitrator Ruben Armendariz, prohibiting Ross and 

Vargas from serving in any APFA National Officer positions. In accordance with those 

Arbitration Awards, the APFA Board of Directors had passed two resolutions implementing the 

Awards and directing the NBC to remove any WTS notifications nominating Plaintiffs Ross and 

Vargas from consideration for officer positions. (Exhibits B and C).

8. The NBC Chairperson sent email correspondences to the individuals who had 

submitted WTS notifications nominating Plaintiffs Ross and Vargas for National Officer position 

informing them that Plaintiffs Ross and Vargas are not eligible to hold National Officer 

positions. (Exhibits D and E). 

9. Also, December 7, 2023, the NBC issued the 2024 National Officer Elections: 

Candidate Announcement Hotline announcing the candidates for the National Officer position. 

(Exhibit F). Neither Heidi Morgan, Melissa Chinery-Burns or Sandra Lee are candidates for any 

National Officer position. 

10. On December 27, 2023, the National Officer election will open and the ballot 

packages will be mailed. (Exhibit A). On January 26, 2024, the National Officer election will 

close and the ballot count will take place at the APFA Headquarters. (Exhibit A). In the event no 

candidate for a given position secures a majority vote on the first ballot, a run-off election will be 

APPENDIX 2

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3

held for each such position. In the event of a run-off, on January 31, 2024, the National Officers 

run-off debate is scheduled to occur at the APFA Headquarters. (Exhibit A). On February 5, 

2024, run-off elections will open and the ballot packages will be mailed. (Exhibit A). On March 

6, 2024, run-off elections will close and the ballot count will take place at the APFA 

Headquarters. (Exhibit A).

I declare under penalty of perjury that the foregoing is true and correct. Executed this 11th

day of December, 2023.

___________________________________

Joshua Black

APPENDIX 3

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INTENTIONALLY LEFT BLANK

APPENDIX 4

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 7 of 34 PageID 4926
11.02.23 - 2024 APFA National Officer Elections - APFA

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11.02.23 – 2024 APFA National Officer Elections

2024 APFA National Officer Elections

Thursday, November 2, 2023

Log In

APPENDIX 5

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11.02.23 - 2024 APFA National Officer Elections - APFA

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Click the image above for the 2024 National Officer Elections video update.

The APFA National Ballot Committee has continued our focus over the last few years on making

several key improvements to the balloting processes and continuing to modernize behind the

scenes. We are pleased to be able to make some positive changes in both the Willingness-to-Serve

form as well as some of the election processes for the upcoming 2024 National Officer Elections.

The National Ballot Committee policies and procedures are guided by the APFA Constitution ,

Policy Manual, and the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA)

guidelines set forth by the Department of Labor. Every change and update are carefully reviewed by

APFA’s Legal Department with frequent consultation with our local representative at the Department

of Labor.

2024 National Officer Elections Timeline

APPENDIX 6

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11.02.23 - 2024 APFA National Officer Elections - APFA

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Virtual Candidate Forum

On December 8, 2023, at 1:00pm (CT), the National Ballot Committee will hold a virtual candidate

forum. All candidates are strongly encouraged to attend to learn more about the election process

and ask questions. Candidates will be sent instructions on how to join after the Willingness-to-Serve

closes.

Voting Method: Paper Ballots vs. Electronic Voting

APPENDIX 7

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For the upcoming election, we will be using the traditional method of Paper/Mail Balloting. Despite

the progress we have made in transitioning back to electronic voting for representative elections,

both through our vendor and the internal policy updates that addressed concerns raised in the

previous election with DOL (Department of Labor) involvement, there remain significant ambiguities

and lack of guidance from the DOL regarding electronic voting for primary and run-off elections for

representatives at this point in time.

However, we remain fully committed to utilizing electronic voting for all non-representative elections

whenever feasible.

Please ensure that your Paper Ballot reaches the designated P.O. Box by January 26th, 2024, at

10:00am (CT). Duplicate Ballot Package requests will be handled through the Help Desk at

YesElections or via the APFA website.

Candidate Booklets

Candidate booklets will be available to all members on the Union Electionspage of the APFA

website on December 27, 2023, the day the ballot packages are mailed. On the voter information

page included with your ballot, a QR code will also be printed that you can scan, which will take you

directly to the candidate booklets. Candidate information will be available to you throughout the

balloting period. You may print the information from the website.

Candidate Eligibility

Candidates who submit a Willingness-to-Serve for a National Officer position, must be a member in

good standing per APFA Constitution Article II, Section 4.A-C – Article VI, Section 4.B & 4.D by

the close of that process on December 7, 2023, at 10:00am (CT).

Voter Eligibility

To be eligible to vote, each APFA member must be a member in good standing no later than five (5)

days prior to the date the votes are counted (“balloting date”). The primary balloting date is January

26, 2024; therefore, you must be in good standing by January 22, 2024. The Dues Department

endeavors to run the monthly billing on the 15th of every month. Members’ eligibility will update after

the monthly billing date; therefore, it is strongly advised you check your membership status and

dues by logging into APFA.org on or after that date to confirm your eligibility.

A member will also be eligible to vote if on an official APFA payment plan that was executed at least

thirty (30) days prior to the balloting date which is December 27, 2023, and at least one payment

APPENDIX 8

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has been made. You can set up an official APFA payment plan by contacting the dues department

at [email protected] or by calling (817) 540-0108.

If there is the need for a run-off election, the balloting date is March 6, 2024, and you must be dues

current by March 1, 2024, or on an official APFA payment plan that was executed by February 5,

2024, for any run-off election, per APFA Policy Manual, Section 2.G.7.f.

Update Your Address With APFA

The National Ballot Committee reminds every member to make sure that APFA has their correct

mailing address to receive a ballot package. Even though you may have updated your address with

the Company, American Airlines does not share that information with APFA. This is especially

important for members who moved or relocated recently.

Update your mailing or contact information by clicking here. If you need assistance with logging in

to update your information, please email [email protected].

If you have issues logging into the APFA website, please visit the support page by clicking here.

You may also contact the Membership Department at 817-540-0108.

Keep an eye out for the Union Elections section on the APFA website throughout the 2024 National

Officer Elections for more information and updates.

In Solidarity,

Adam Brooks

APFA National Ballot Committee Chair

[email protected]

Posted in Hotlines - 2023 and tagged National Ballot Committee, National Officer Elections, NBC,

November 2023, Union Elections

APFA Headquarters

1004 West Euless Boulevard

Euless, Texas 76040

M-F: 9:00AM - 5:00PM (CT)

Phone: (817) 540-0108

APPENDIX 9

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11.02.23 - 2024 APFA National Officer Elections - APFA

https://www.apfa.org/2023/11/02/11-02-23-2024-apfa-national-officer-elections/[12/8/2023 6:08:08 PM]

 Call APFA

Contract & Scheduling

Desk

M-F: 7:00AM - 7:00PM (CT)

Phone: (817) 540-0108

    

 Chat APFA

After-Hours Live Chat

M-F: 3:00PM - 11:00 PM

(CT)

Sat-Sun: 9:00AM - 5:00PM

(CT)

 APFA Events

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events...

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APPENDIX 10

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 13 of 34 PageID 4932
Res. #2 March 23, 2022 Page 1 of 4 

APFA 

SPECIAL BOARD OF DIRECTORS TELECONFERENCE

March 24, 2022

 

Resolution #: 2 

BOS Milenkovic CLT Hazlewood

DCA PennelDFW De RoxtraLAX NikidesLGA SantanaMIA TrautmanORD WroblePHL KaswinkelPHX AgeeSFO Schwartz

Pres Hedrick

Resolution Information

Resolution Name: Chinery-Lee v Ross 

Arbitration Remedy 

Status: Pass 

Maker: Hedrick

Second: Nikides YES

Date: 3/23/2022 NO

Time: 4:08 p.m. ABS

Affects PM: N/A

Comments: Yes: 10 No: 0 Abstain: 1 Absent: 0 Show of Hands: 

WHEREAS, APFA Constitution, Article VII provides APFA members a mechanism to hold their 

representatives accountable through internal hearing procedures facilitated by a neutral third-party 

arbitrator; and 

WHEREAS, two such members, Melissa Chinery & Sandra Lee, filed Article VII Charges against 

previous APFA National President, Bob Ross, on November 18, 2020; and 

WHEREAS, these Article VII charges were referred to the designated Article VII Arbitrator, Ruben 

Armendariz, in accordance with APFA Constitution Article VII, Section 3; and 

WHEREAS, the Chinery-Lee v. Ross charges were heard on June 16, 2021, and continued on 

November 17 & 18, 2021, in Irving, Texas; and 

WHEREAS, Arbitrator Armendariz rendered a decision in the matter of Chinery-Lee v. Ross on 

March 19, 2022; and 

WHEREAS, the remedy states: 

“1. The APFA will hire an Independent Forensic Auditor to audit Robert Ross’ weekly reports, 

monthly reports and APFA credit card charges from April 1, 2016 through July, 2018 and 

perform the following tasks: 

Specifically: 

a. The Auditor shall inspect the receipts for the Ross family vacation taken in the Grand 

Canyon in August 2016. Ross claimed all of hotel stays, meals and mileage charges 

as relocation moving expenses when some are for a personal vacation. Please 

determine what costs should not have been claimed as relocation moving expenses. 

APPENDIX 11

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 14 of 34 PageID 4933
APFA 

BOARD OF DIRECTORS MEETING

Res. #2 March 23, 2022 Page 2 of 4 

Ross is liable for the excess cost and is hereby Ordered to repay APFA for all 

inappropriate charges! 

b. The Auditor shall inspect Ross’ APFA credit card usage for personal and group meals 

and purchases for personal items such as tools, toiletries, bath towels, and candy from 

April 1, 2016 through July 2018 and determine the cost of all inappropriate charges. 

If no documentation was provided to support each purchase was a union related 

business cost, then Ross is liable for all inappropriate charges and is hereby Ordered 

to repay the APFA for all inappropriate charges! 

c. The Auditor shall inspect all of Ross’ rental car usage from April 1, 2016 through 

October 16, 2016 and determine if these rentals were for union related business. APFA 

paid for the rental cars but there should be documentation to show if it was for union 

related business. If not, Ross is to be assessed the cost of the rental cars during the 

above period and is hereby Ordered to repay APFA for inappropriate rental car usage! 

d. The Auditor shall inspect all of Ross’ claimed mileage from the Sacramento Airport 

to his residence (42 miles) and return (42 miles) as well as all monthly parking of his 

personal car. He claimed $105.00 per month from April 1, 2016 through July 2016 to 

park his car at the Sacramento airport. Ross is to be assessed the mileage and monthly 

parking he claimed and Ross is hereby Ordered to repay APFA for all of these 

inappropriate charges! 

2. Ross is hereby Ordered to immediately repay the APFA $5,436.47 per the finding of the APFA 

Board of Directors. An independent accounting firm determined the formula used to determine 

the daily rate assessed for sick and vacation payout was incorrect. 

3. Ross is hereby Ordered to repay the APFA $8,106.13 for leasing an apartment at the Bear Creek 

Complex where he had no intention of occupying. 

4. Ross is hereby fined and Ordered to repay the APFA for all of the Arbitrator’s Fee for this 

arbitration. 

5. Ross is hereby ordered to repay the APFA the full cost of hiring the Independent Forensic 

Auditor. 

6. Ross is hereby Ordered to repay $3,637.00 to the APFA for all of the furniture he had purchased 

and delivered to his residence located in South Lake, Texas. 

7. Ross is prohibited from serving in any official position within the APFA organization that is set 

forth and included in the APFA Constitution and Policy Manual that is covered or identified. If 

Ross currently holds any official position presently, he is to resign said position. This is to bar 

Ross from any official position for life other than that of member. 

8. The APFA if it hasn’t done so, must create a separate body of trained forensic accountants to 

oversee the annual audit and to create procedures and recommendations to preclude fraud for 

the BOD’s review and action to be included within the Policy Manual. National Officers or 

Officers who have the authority to extend APFA to credit or use of an APFA credit card must 

be held economically responsible. The language created must be very clear and unambiguous. 

Training over the LMRDA must be a requirement for all National Officers or any person who 

can extend APFA to credit and whom is given an APFA credit card. These individuals must 

sign a document declaring and attesting that they have read and understand their responsibilities 

in using an APFA credit card or extending credit to the APFA for rental cars, apartments, etc., 

and that negligence will not be tolerated and will be dealt with severe penalties. 

9. The arbitrator shall retain jurisdiction over any issue involving this remedy only. Moreover, if 

the Independent Auditor determines any monies are due from Ross, that will be the amount to 

be assessed or due for repayment to the APFA. The APFA shall either Order said repayment 

APPENDIX 12

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APFA 

BOARD OF DIRECTORS MEETING

Res. #2 March 23, 2022 Page 3 of 4 

from Ross or submit the Independent Auditors findings to have this arbitrator issue a 

Supplemental Decision and Remedy.” 

; and 

WHEREAS, Bob Ross resigned from his position as APFA SFO Base President; and 

WHEREAS, APFA Constitution Article VII, Section 6.H states that “[t]he decision of the Article 

VII Arbitrator shall be final and binding upon the accused and the accuser;” and 

WHEREAS, the APFA Board of Directors is authorized and empowered to take any and all lawful 

action consistent with the Constitution to safeguard and protect the APFA and the rights, privileges, 

duties, and responsibilities of the officers, representatives, and members of the APFA. 

BE IT THEREFORE RESOLVED, the APFA affirms the APFA Article VII Arbitrator’s decision 

and remedy and hereby sanctions the following actions: 

1. The APFA National Treasurer shall retain an independent forensic auditor to effectuate item 

1.a-d of the Arbitrator’s remedy. Within 30 days of completion, the results of this investigation 

shall be remitted to the Board of Directors for review. After this review, the APFA shall order 

Bob Ross to repay APFA for any monies deemed owed by the independent forensic auditor. 

2. APFA hereby orders Bob Ross to repay $5,436.47 to the APFA for the overpayment for the 

incorrectly calculated daily rate for sick and vacation payout. 

3. APFA hereby orders Bob Ross to repay $8,106.13 for leasing an apartment at the Bear Creek 

Complex for which he had no intention of occupying. 

4. APFA hereby orders Bob Ross to repay $10,452 for all of the Arbitrator’s fees for this 

arbitration including the arbitrator’s hotel expenses. 

5. Once the forensic audit is completed, APFA will remit for payment the full cost of the 

Independent Forensic Audit to Bob Ross. 

6. APFA hereby orders Bob Ross to repay $3,637.00 for all the furniture purchased and delivered 

to his personal residence located in South Lake, Texas. 

7. APFA hereby orders the NBC to maintain a record of the Chinery-Lee v. Ross Article VII 

award to ensure any Willingness-to-Serve Bob Ross may submit for any election APFA holds 

during his lifetime is removed from consideration. 

8. APFA hereby orders the National Secretary's Office to maintain a record of the Chinery-Lee v. 

Ross Article VII award to ensure any resume Bob Ross may submit during his lifetime for any 

positions covered by the APFA Constitution and Policy Manual is removed from consideration. 

9. APFA hereby orders the National Treasurer to immediately take steps to effectuate item 8 of the 

Arbitrator’s remedy including: 

 Hiring an independent body of trained forensic accountants to oversee the annual audit. 

APPENDIX 13

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APFA 

BOARD OF DIRECTORS MEETING

Res. #2 March 23, 2022 Page 4 of 4 

 Reviewing Section 5 of the Policy Manual in order to clarify all financial policies 

ambiguous in nature and reviewing and implementing additional revisions as they relate 

to the decision of the Article VII Arbitrator. 

 Developing and delivering training for those who may extend credit of the APFA. This 

training shall include proper use of member’s dues, the LMRDA and other applicable 

laws and regulations, and APFA policies. 

 Reviewing the APFA credit card policy and ensuring compliance with the LMRDA and 

other applicable laws and regulations. Any ambiguities to the APFA credit card policy 

shall be clarified. Representatives shall be required to sign a statement declaring and 

attesting that they have read and understood their responsibilities in using an APFA 

credit card or extending credit to the APFA for rental cars, apartments, etc. 

10. Should any further fees be incurred by the Article VII Arbitrator related to the issuance and 

implementation of the remedy, one hundred percent (100%) of such fees shall be remitted to 

Bob Ross for repayment. 

; and 

BE IT FURTHER RESOLVED, should Bob Ross fail to remit payment to the APFA pursuant to 

the Chinery-Lee v. Ross Article VII award, the provisions of Section 7.J of the APFA Policy Manual 

shall not apply. The APFA shall retain jurisdiction over the debt owed by Bob Ross as it relates to 

the Chinery-Lee v Ross Article VII Remedy. APFA will take any and all actions consistent with 

local, state, and federal laws to recoup these monetary damages including legal action, if necessary; 

and 

BE IT FINALLY RESOLVED, the APFA Leadership hereby condemns the actions Bob Ross took 

to defraud the members of APFA during his term as APFA National President. 

APPENDIX 14

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 17 of 34 PageID 4936
Res. # 10 March 8-10, 2022 Page 1 of 2 

APFA 

ANNUAL BOARD OF DIRECTORS CONVENTION

March 8-10, 2022

Westin Irving Convention Center at Las Colinas 

 

Resolution #: 10 

BOS Milenkovic CLT Hazlewood

DCA PennelDFW De RoxtraLAX NikidesLGA SantanaMIA TrautmanORD WroblePHL KaswinkelPHX AgeeSFO RossPres Hedrick

Resolution Information

Resolution Name: Chinery-Lee v Vargas 

Arbitration Remedy 

Status: Pass 

Maker: Hedrick

Second: Nikides YES

Date: 03/10/2022 NO

Time: 2:55 p.m. ABS

Affects PM: N/A

Comments: Yes: 10 No: 1 Abstain: 0 Absent: 0 Show of Hands: 

WHEREAS, APFA Constitution, Article VII provides APFA members a mechanism to hold 

their representatives accountable through internal hearing procedures facilitated by a neutral 

third-party arbitrator; and 

WHEREAS, two such members, Melissa Chinery & Sandra Lee, filed Article VII Charges 

against previous APFA National Treasurer, Eugenio Vargas, on November 24, 2020; and 

WHEREAS, these Article VII charges were referred to the designated Article VII Arbitrator, 

Ruben Armendariz, in accordance with APFA Constitution Article VII, Section 3; and 

WHEREAS, the Chinery-Lee v Vargas charges were heard on September 14-16, 2021 in Irving, 

Texas; and 

WHEREAS, Arbitrator Armendariz rendered a decision in the matter of Chinery-Lee v Vargas 

on February 18, 2022; and 

WHEREAS, the remedy states: 

“Vargas is to repay APFA for the following: 

1. If after the Independent Auditors audit is completed and he/she determines that 

Vargas had used the APFA credit card for his own personal use on meals during his 

APPENDIX 15

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APFA 

BOARD OF DIRECTORS MEETING

Res. # 10 March 8-10, 2022 Page 2 of 2 

tenure as National Treasurer, Vargas is hereby Ordered to repay APFA for all meals 

he charged to the APFA credit card. 

2. Vargas is prohibited from serving in any APFA National Officer position or Regional 

Officer position for life. 

3. Vargas is hereby fined and ordered to repay the APFA for half of the Arbitrator’s Fee 

for this arbitration. 

4. The arbitrator shall retain jurisdiction for 90-days over any issue involving this 

remedy only. Moreover, if the Independent Auditor determines any monies are due 

from Vargas, that will be the amount to be assessed or due and the BOD or EC shall 

Order said repayment from Vargas.” 

; and 

WHEREAS, the APFA Board of Directors is authorized and empowered to take any and all 

lawful action consistent with the Constitution to safeguard and protect the APFA, and the rights, 

privileges, duties and responsibilities of the officers, representatives and members of the APFA. 

BE IT THEREFORE RESOLVED, the APFA affirms the APFA Article VII Arbitrator’s 

decision and remedy and hereby sanctions the following actions: 

1. The APFA Board of Directors hereby orders APFA National Treasurer, Erik Harris, to 

retain an independent auditor to investigate if Vargas had used the APFA credit card for 

his own personal use on meals during his tenure as National Treasurer. Within 30 days of 

completion, the results of this investigation shall be remitted to the Board of Directors for 

review. After this review, the APFA Board of Directors shall order Eugenio Vargas to 

repay APFA for any monies deemed owed by the independent auditor. 

2. The APFA Board of Directors hereby orders the NBC to maintain a record of the 

Chinery-Lee v Vargas Article VII award to ensure Eugenio Vargas name is removed 

from any Willingness-to-Serve that he may submit for life. 

3. The APFA Board of Directors hereby orders Eugenio Vargas to repay APFA $8,623.17 

for the Article VII Arbitrator’s fees. The National Treasurer shall be charged with 

collecting from Vargas consistent with the APFA Constitution, Policy Manual, and any 

applicable Federal, State, and local laws. 

4. Notwithstanding, should any further fees be incurred by the Article VII Arbitrator as it 

relates to the issuance and implementation of the remedy, fifty percent (50%) of such fees 

shall be remitted to Eugenio Vargas for repayment.

APPENDIX 16

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 19 of 34 PageID 4938
From: Ballot Committee

Subject: Willingness-to-Serve: Nomination Ineligible

Date: Thursday, December 7, 2023 12:54:55 PM

Attachments: image002.png

Importance: High

December 7, 2023

Hello,

The National Ballot Committee (NBC) has received your Willingness-to-Serve form nominating Robert

“Bob” Ross as a candidate for an APFA National Officer position. This is to advise you that Mr. Ross is

not eligible to hold such office.

On March 19, 2022, Arbitrator Ruben Armendariz issued a binding Opinion and Award under Article VII

of the APFA Constitution prohibiting Bob Ross from “serving in any official position within the APFA

organization that is set forth and included in the APFA Constitution and Policy Manual that is covered or

identified.” In accordance with that decision, on May 23, 2022, the APFA Board of Directors adopted the

Chinery-Lee v Ross Arbitration Remedy Resolution, which, among other things, directed the NBC to

“maintain a record of the Chinery-Lee v. Ross Article VII award to ensure any Willingness-to-Serve Bob

Ross may submit for any election APFA holds during his lifetime is removed from consideration.”

In accordance with the Article VII ruling and the Board of Directors’ implementing resolution, the

National Ballot Committee (NBC) has therefore removed from consideration all Willingness-to-Serves

nominating Bob Ross as a candidate for any APFA elected position.

Accordingly, the NBC will take no further action related to the self-nomination or nomination of Bob Ross

for any position within the APFA for which he is prohibited from being a candidate. The NBC has also

concluded that Art. VI, Section 6 of the APFA Constitution is not applicable to this action.

In Solidarity,

Adam Brooks Pronouns: he, him, they, them

National Ballot Committee Chair

Association of Professional Flight Attendants

Office: 817.540.0108 | Email: ballot@apfa.org

#WeAreReady #27kStrong #SolidaridtySeason #Strike #ContractNow

APPENDIX 17

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 20 of 34 PageID 4939
The content of this email is intended solely for the recipient(s). It is not to be shared, forwarded or posted without

the authors written consent.

APPENDIX 18

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 21 of 34 PageID 4940
From: Ballot Committee

Subject: Willingness-to-Serve: Nomination Ineligible

Date: Thursday, December 7, 2023 12:55:32 PM

Attachments: image001.png

Importance: High

December 7, 2023

Hello,

The National Ballot Committee (NBC) has received your Willingness-to-Serve form nominating Eugenio

Vargas as a candidate for an APFA National Officer position. This is to advise you that Mr. Vargas is not

eligible to hold such office.

On February 18, 2022, Arbitrator Ruben Armendariz issued a binding Opinion and Award under Article

VII of the APFA Constitution prohibiting Eugenio Vargas from “serving in any APFA National Officer

position or Regional Officer position for life.” In accordance with that decision, on March 10, 2022, the

APFA Board of Directors adopted the Chinery-Lee v. Vargas Arbitrator Remedy Resolution, which,

among other things, directed the NBC to “maintain a record of the Chinery-Lee v. Vargas Article VII

award to ensure Eugenio Vargas’ name is removed from any Willingness-to-Serve that he may submit for

life.”

In accordance with the Article VII ruling and the Board of Directors’ implementing resolution, the NBC

has therefore removed from consideration all Willingness-to-Serves nominating Eugenio Vargas as a

candidate for any APFA elected position.

Accordingly, the NBC will take no further action related to the self-nomination or nomination of Eugenio

Vargas for any position within the APFA for which he is prohibited from being a candidate. The NBC has

also concluded that Art. VI, Section 6 of the APFA Constitution is not applicable to this action.

In Solidarity,

Adam Brooks Pronouns: he, him, they, them

National Ballot Committee Chair

Association of Professional Flight Attendants

Office: 817.540.0108 | Email: ballot@apfa.org

#WeAreReady #27kStrong #SolidaridtySeason #Strike #ContractNow

The content of this email is intended solely for the recipient(s). It is not to be shared, forwarded or posted without the authors written consent.

APPENDIX 19

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 22 of 34 PageID 4941
APPENDIX 20

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 23 of 34 PageID 4942
12.07.23 - 2024 National Officer Elections: Candidate Announcement - APFA

https://www.apfa.org/2023/12/07/12-07-23-2024-national-officer-elections-candidate-announcement/[12/8/2023 8:02:32 PM]

12.07.23 – 2024 National Officer Elections: Candidate

Announcement

2024 National Officer Elections:

Candidate Announcement

Thursday, December 7, 2023

Today, the APFA National Ballot Committee (NBC) retrieved the Willingness-To-Serves (WTS) for

the positions of National President, National Vice President, National Secretary and National

Treasurer. The NBC would like to thank all members who submitted a Willingness-to-Serve for

these positions.

The following candidates will be on the ballot:

National President

Log In

APPENDIX 21

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 24 of 34 PageID 4943
12.07.23 - 2024 National Officer Elections: Candidate Announcement - APFA

https://www.apfa.org/2023/12/07/12-07-23-2024-national-officer-elections-candidate-announcement/[12/8/2023 8:02:32 PM]

Herman Gardner

Cheryl Gaymon

Karina Hargrove

Julie Hedrick

A. Marie Plevritis

Lisa Villa

Kenneth Virzi

National Vice President

John Binford

Jesse Boyd

Francisco Cuadros

Jason Gillespie

Nena Martin

Jennifer McCauley

Miguel Mejias

Samuel Morales

Larry Salas

Leslie Van Anne

National Secretary

Josh Black

Nicole Hudiburg

Leanne Pruett*

Rene Rose

Katy Singh

Brian Yan

National Treasurer

Erik Harris

Tommy Hsia Yang

Claudia Keife*

Rock Salomon*

*Denotes a candidate that has been nominated but has yet to accept or decline the nomination

National Officers Term

The newly elected National Officers will assume office on April 1, 2024, for a four-year term of office

APPENDIX 22

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 25 of 34 PageID 4944
12.07.23 - 2024 National Officer Elections: Candidate Announcement - APFA

https://www.apfa.org/2023/12/07/12-07-23-2024-national-officer-elections-candidate-announcement/[12/8/2023 8:02:32 PM]

ending on March 31, 2028.

Ballots

The ballots for the APFA National Officer Elections will be mailed to the address you have on file

with APFA on December 27, 2023. Please ensure that your Paper Ballot reaches the designated

P.O. Box by January 26th, 2024, at 10:00am (CT). Duplicate Ballot Package requests will be

handled directly through the Help Desk at YesElections or via APFA.org.

If no candidate receives a majority (50% plus one) of the valid ballots received for a National Officer

position, the National Ballot Committee will mail a run-off ballot to all members on February 5,

2024. Ballots for the run-off election must be received by March 6, 2024, at 10:00am (CT).

Candidate Booklets

Candidate booklets will be available to all members on the Union Electionspage of APFA.org on

December 27, 2023, the day the ballot packages are mailed. On the voter information page

included with your ballot, a QR code will also be printed that you can scan, which will take you

directly to the candidate booklets. Candidate information will be available to you throughout the

balloting period. You may print the information from the website.

Voter Information

To be able to vote, each APFA member must be a member in good standing no later than five (5)

days prior to the date the votes are counted (“balloting date”). The balloting date is January 26,

2024; therefore, you must be in good standing by January 22, 2024. The Dues Department

endeavors to run the monthly billing on the 15th of every month. Members’ eligibility will be updated

after monthly billing; therefore, it is strongly advised you check your membership status and dues by

logging into APFA.org on or after that date to confirm your eligibility. A member will also be eligible

to vote if on an official APFA payment plan that was executed at least thirty (30) days prior to the

balloting date and at least one payment has been made. Which means you must be on the official

plan by December 27, 2023, for the primary election. You can set up an official APFA payment plan

by contacting the Dues Department at [email protected] or by calling 817-540-0108.

Update Your Address With APFA

The National Ballot Committee reminds every member to make sure that APFA has their correct

mailing address to receive a ballot package. Even though you may have updated your address with

the Company, American Airlines does not share that information with APFA. This is especially

important for members who moved or relocated recently. Update your mailing or contact information

APPENDIX 23

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 26 of 34 PageID 4945
12.07.23 - 2024 National Officer Elections: Candidate Announcement - APFA

https://www.apfa.org/2023/12/07/12-07-23-2024-national-officer-elections-candidate-announcement/[12/8/2023 8:02:32 PM]

by clicking here, logging in, and clicking “My Account”. If you need assistance logging into the

APFA website, please visit the support page by clicking here. You may also contact the

Membership Department at 817-540-0108.

In Solidarity,

Adam Brooks

APFA National Ballot Committee Chair

[email protected]

Posted in Hotlines - 2023 and tagged December 2023, National Ballot Committee, National Officer

Elections, NBC, Union Elections

APFA Headquarters

1004 West Euless Boulevard

Euless, Texas 76040

M-F: 9:00AM - 5:00PM (CT)

Phone: (817) 540-0108

 Call APFA

Contract & Scheduling

Desk

M-F: 7:00AM - 7:00PM (CT)

Phone: (817) 540-0108

    

 Chat APFA

After-Hours Live Chat

M-F: 3:00PM - 11:00 PM

(CT)

Sat-Sun: 9:00AM - 5:00PM

(CT)

 APFA Events

Currently, no scheduled

events...

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Airline Ambassadors

APA

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TWU-556

AFA-CWA

APPENDIX 24

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 27 of 34 PageID 4946
12.07.23 - 2024 National Officer Elections: Candidate Announcement - APFA

https://www.apfa.org/2023/12/07/12-07-23-2024-national-officer-elections-candidate-announcement/[12/8/2023 8:02:32 PM]

UNICEF/Change for Good CWA-IBT

APPENDIX 25

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 28 of 34 PageID 4947
1 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

FORT WORTH DIVISION 

EUGENIO VARGAS, 

Plaintiff/Counterclaim 

Defendant, 

v. 

ASSOCIATION OF PROFESSIONAL 

FLIGHT ATTENDANTS, et al., 

Defendants/Counterclaim 

Plaintiff. 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

Civil Action No. 4:22-cv-430-Y 

Judge Terry R. Means 

PLAINTIFF’S RESPONSES AND OBJECTIONS TO APFA 

DEFENDANTS’ FIRST SET OF INTERROGATORIES TO 

EUGENIO VARGAS 

1. For each statement described in paragraph 49 of your First Amended Complaint 

(doc. 55-1), 

a. Quote the exact language of the statement. 

b. State when and to whom the statement was made. 

c. Identify all documents in which the statement was made. 

RESPONSE: Plaintiff objects to this interrogatory because it references an Amended Complaint 

that Plaintiff was denied leave to amend. Plaintiff objects to this request as it is vague and 

ambiguous as to the term “First Amended Complaint” in its entirety. Plaintiff also objects as 

Defendants seek information in the possession of, known to, or otherwise equally available to the 

plaintiff. Plaintiff further objects to this request as it is oppressive and unduly burdensome. 

Plaintiff objects to this request as the information requested is equally available to Defendant. 

Plaintiff objects to this request as Plaintiff already has any responsive information in its possession. 

2. For each statement described in paragraph 50 of your First Amended Complaint 

(doc. 55-1), 

a. Quote the exact language of the statement. 

b. State when and to whom the statement was made. 

c. Identify all documents in which the statement was made. 

APPENDIX 26

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 29 of 34 PageID 4948
2 

RESPONSE: Plaintiff objects to this interrogatory because it references an Amended Complaint 

that Plaintiff was denied leave to amend. Plaintiff objects to this request as it is vague and 

ambiguous as to the term “First Amended Complaint” in its entirety. Plaintiff also objects as 

Defendants seek information in the possession of, known to, or otherwise equally available to the 

plaintiff. Plaintiff further objects to this request as it is oppressive and unduly burdensome. 

Plaintiff objects to this request as the information requested is equally available to Defendant. 

Plaintiff objects to this request as Plaintiff already has any responsive information in its possession. 

3. For each statement described in paragraph 51 of your First Amended Complaint 

(doc. 55-1). 

a. Quote the exact language of the statement. 

b. State when and to whom the statement was made. 

c. Identify all documents in which the statement was made. 

RESPONSE: Plaintiff objects to this interrogatory because it references an Amended Complaint 

that Plaintiff was denied leave to amend. Plaintiff objects to this request as it is vague and 

ambiguous as to the term “First Amended Complaint” in its entirety. Plaintiff also objects as 

Defendants seek information in the possession of, known to, or otherwise equally available to the 

plaintiff. Plaintiff further objects to this request as it is oppressive and unduly burdensome. 

Plaintiff objects to this request as the information requested is equally available to Defendant. 

Plaintiff objects to this request as Plaintiff already has any responsive information in its 

possession. 

4. Identify all persons who have provided you or your attorney with any financial 

support or payments in connection with this litigation. 

RESPONSE: Plaintiff objects to this interrogatory because this interrogatory seeks attorney-client 

privilege information. Furthermore, Plaintiff objects to this interrogatory as it is vague, 

ambiguous unduly burdensome and irrelevant. Plaintiff further objects to this request as it calls 

for information that is not relevant, nor reasonably calculated to lead to the discovery of relevant 

or admissible evidence. 

Respectfully submitted, 

KD PHILLIPS LAW FIRM, PLLC 

 

APPENDIX 27

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 30 of 34 PageID 4949
3 

 

By: /s/ Kerri Phillips 

Kerri Phillips 

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

 

CERTIFICATE OF SERVICE 

I certify that true and correct copy of this document was sent to all counsel of 

record, hereunder listed via ECF filing on this the 28th day of September 2023. 

Jeff Bartos 

 James Sanford 

 Charlette Matts 

 /s/ Kerri Phillips 

Kerri Phillips 

APPENDIX 28

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 31 of 34 PageID 4950
IN THE UNITED STATES DISTRICT 

COURT FOR THE NORTHERN DISTRICT 

OF TEXAS FORT WORTH DIVISION 

EUGENIO VARGAS, 

Plaintiff/Counterclaim 

Defendant, 

v. 

ASSOCIATION OF PROFESSIONAL 

FLIGHT ATTENDANTS, et al., 

Defendants/Counterclaim 

Plaintiff. 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

Civil Action No. 4:22-cv-430-Y 

Judge Terry R. Means 

PLAINTIFF’S RESPONSES AND OBJECTIONS TO APFA DEFENDANTS’ 

SECOND SET OF REQUESTS FOR PRODUCTION 

TO EUGENIO VARGAS 

Pursuant to Federal Rule of Civil Procedure 34, Defendants Association of Professional 

Flight Attendants, Julie Hedrick, and Erik Harris (collectively, “APFA Defendants”) by and 

through counsel, hereby make the following Requests that Plaintiff Eugenio Vargas make 

available to Defendants’ counsel for inspection and copying the following documents that are in 

your possession, custody, or control wherever located within thirty (30) days of the service upon 

you at the offices of Gillespie Sanford LLP, 4803 Gaston Ave., Dallas, TX 75246, or such other 

place as may be mutually agreed upon by the parties. 

The Instructions and Definitions from the APFA Defendants First Set of Requests for 

Production are adopted as if restated herein. 

Please produce the following: 

1. All documents identified or described in your answers to any 

Interrogatories served upon you in this matter. 

APPENDIX 29

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 32 of 34 PageID 4951
RESPONSE: Plaintiff objects to this Request because it references an Amended Complaint that 

Plaintiff was denied leave to amend. Plaintiff objects to this request as it is vague and 

ambiguous as to the term “First Amended Complaint” in its entirety. Plaintiff also objects as 

Defendants seek information in the possession of, known to, or otherwise equally available to 

the plaintiff. Plaintiff further objects to this request as it is oppressive and unduly burdensome. 

Plaintiff objects to this request as the information requested is equally available to Defendant. 

Plaintiff objects to this request as Plaintiff already has any responsive information in its 

possession. 

Plaintiff reserves the right to supplement its response in accordance with FRCP 26(e). 

2.. All documents containing the statements described in paragraph 49 of your 

First Amended Complaint (doc. 55-1). 

RESPONSE: Plaintiff objects to this Request because it references an Amended Complaint that 

Plaintiff was denied leave to amend. Plaintiff objects to this request as it is vague and 

ambiguous as to the term “First Amended Complaint” in its entirety. Plaintiff also objects as 

Defendants seek information in the possession of, known to, or otherwise equally available to 

the plaintiff. Plaintiff further objects to this request as it is oppressive and unduly burdensome. 

Plaintiff objects to this request as the information requested is equally available to Defendant. 

Plaintiff objects to this request as Plaintiff already has any responsive information in its 

possession. 

Plaintiff reserves the right to supplement its response in accordance with FRCP 26(e). 

3. All documents containing the statements described in paragraph 50 of your 

First Amended Complaint (doc. 55-1). 

RESPONSE: Plaintiff objects to this Request because it references an Amended Complaint that 

Plaintiff was denied leave to amend. Plaintiff objects to this request as it is vague and 

ambiguous as to the term “First Amended Complaint” in its entirety. Plaintiff also objects as 

Defendants seek information in the possession of, known to, or otherwise equally available to the 

plaintiff. Plaintiff further objects to this request as it is oppressive and unduly burdensome. 

Plaintiff objects to this request as the information requested is equally available to Defendant. 

Plaintiff objects to this request as Plaintiff already has any responsive information in its 

possession. 

Plaintiff reserves the right to supplement its response in accordance with FRCP 26(e). 

4. All documents containing the statements described in paragraph 51 of your 

First Amended Complaint (doc. 55-1). 

RESPONSE: Plaintiff objects to this Request because it references an Amended Complaint that 

Plaintiff was denied leave to amend. Plaintiff objects to this request as it is vague and 

ambiguous as to the term “First Amended Complaint” in its entirety. Plaintiff also objects as 

APPENDIX 30

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 33 of 34 PageID 4952
Defendants seek information in the possession of, known to, or otherwise equally available to the 

plaintiff. Plaintiff further objects to this request as it is oppressive and unduly burdensome. 

Plaintiff objects to this request as the information requested is equally available to Defendant. 

Plaintiff objects to this request as Plaintiff already has any responsive information in its 

possession. 

Plaintiff reserves the right to supplement its response in accordance with FRCP 26(e). 

Respectfully submitted, 

KD PHILLIPS LAW FIRM, PLLC 

 

 

By: /s/ Kerri Phillips 

Kerri Phillips 

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 

 

CERTIFICATE OF SERVICE 

I certify that true and correct copy of this document was sent to all counsel of record, 

hereunder listed via ECF filing on this the 28th day of September 2023. 

Jeff Bartos 

 James Sanford 

 Charlette Matts 

 /s/ Kerri Phillips 

Kerri Phillips 

 

APPENDIX 31

Case 4:22-cv-00430-Y Document 175 Filed 12/13/23 Page 34 of 34 PageID 4953