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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

FORT WORTH DIVISION 

ROBERT (BOB) ROSS, § 

§ 

 Plaintiff/Counterclaim Defendant, § 

§ 

v. § Civil Action No. 4:22-cv-00034-Y 

§ 

ASSOCIATION OF PROFESSIONAL § 

FLIGHT ATTENDANTS § 

MCGAUGHEY, REBER AND § 

ASSOCIATES, INC, JULIE § 

HEDRICK, AND ERIK HARRIS, § 

§ 

 Defendants/Counterclaim Plaintiff. § 

DEFENDANT, MCGAUGHEY, REBER AND ASSOCIATES, INC. DISCLOSURES 

PURSUANT TO F.R.C.P. 26 (a) 

Defendant , McGaughey, Reber and Associates, Inc. submits these Initial Disclosures 

pursuant Rule 26(a)(1) of the Federal Rules of Civil Procedure (“F.R.C.P.”) to Plaintiff Robert 

(Bob) Ross (“Ross” or “Plaintiff”). 

These Initial Disclosure are based on the Defendant , McGaughey, Reber and Associates, 

Inc. current knowledge and upon a reasonable inquiry and review of information available to 

date. The Defendant , McGaughey, Reber and Associates, Inc. investigation concerning the facts 

and law of this case is ongoing, and the Defendant , McGaughey, Reber and Associates, Inc.

reserves the right to supplement, amend, correct, or otherwise modify these Initial Disclosures to 

the extent required by FRCP 26(e) if they obtain additional information. 

For any motion, hearing, or trial in this matter, the Defendant , McGaughey, Reber and 

Associates, Inc. reserves the right to rely on information obtained from any individual identified 

by Plaintiff Ross and the other Defendants in their Initial Disclosures under FRCP 26(a) and (e) 

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as to the subjects listed in those Initial Disclosures or otherwise disclosed over the course of this 

litigation. 

By providing these Initial Disclosures, the Defendant , McGaughey, Reber and 

Associates, Inc. do not waive the right to assert any and all objections as to the competency of a 

witness or the relevance, materiality, or admissibility of any evidence or subject matter. The 

Defendant , McGaughey, Reber and Associates, Inc. make these Initial Disclosures subject to, 

and without waiving, any and all applicable privileges, including the attorney-client privilege and 

the attorney work product doctrine. 

I. The name and, if known, the address and telephone number of each individual 

likely to have discoverable information—along with the subjects of that 

information—that the disclosing party may use to support its claims or defenses, 

unless the use would be solely for impeachment. 

A. Michael McGaughey. Michael McGaughey is an officer with McGaughey, Reber and 

Associates, Inc. and has information concerning the communication with the Defendant, 

APFA and its personnel. In particular he has information regarding the debt collection 

efforts of Defendant APFA and Diversified Credit’s efforts to collect the debt of Plaintiff, 

Ross. Mr. McGaughey also has information regarding the State and Federal Debt 

Collection Practices Acts and Defendant, McGaughey, Reber and Associates, Inc. 

following the legal procedure and processes to collect debts, including the Ross debt. He 

may be contacted through his Attorney of Record below.

B. Tom Reber. Tom Reber is an officer with McGaughey, Reber and Associates, Inc. and 

has information concerning the communication with the Defendant, APFA and its 

personnel. In particular he has information regarding the debt collection efforts of 

Defendant APFA and Diversified Credit’s efforts to collect the debt of Plaintiff, Ross. Mr. 

McGaughey also has information regarding the State and Federal Debt Collection Practices 

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Acts and Defendant, McGaughey, Reber and Associates, Inc. following the legal procedure

and processes to collect debts, including the Ross debt. He may be contacted through his 

Attorney of Record below.

C. Robert (Bob) Ross. Ross, the plaintiff in this action. Ross may be contacted through 

his counsel Kerri Phillips and Heather Abreu of K.D. Phillips Law Firm, PLLC. 

D. Eugenio Vargas. Vargas. Vargas may be contacted through his counsel Kerri Phillips 

and Heather Abreu of K.D. Phillips Law Firm, PLLC. 

E. Julie Hedrick. Hedrick, named as a defendant in this action, Hedrick may be 

contacted through her counsel of record, Sanford Denison, Baab and Denison.

F. Erik Harris. Harris, named as a defendant in this action, is the National Treasurer of 

APFA. Harris has discoverable information concerning the APFA Constitution and 

Policy Manual and the implementation of the Arbitrator’s Decision and Order. Harris 

may be contacted through his counsel of record, Sanford Denison, Baab and

Denison.

G. Josh Black. Black is the National Secretary of APFA. Black may be contacted 

through his counsel of record, Sanford Denison, Baab and Denison.

H. All other persons named by Plaintiff and other Defendants. Defendant, McGaughey, 

Reber and Associates, Inc. has no personal knowledge of what those persons named 

have knowledge of, but incorporates the statements of their counsel herein, for all 

purposes the same as if copied verbatim herein.

II. A copy—or a description by category and location—of all documents, electronically 

stored information, and tangible things that the disclosing party has in its 

possession, custody, or control and may use to support its claims or defenses, unless 

the use would be solely for impeachment. 

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The following documents are available at the offices of McGaughey, Reber and 

Associates, Inc. d/b/a Diversified Credit Systems principal place of business in 

Longview, Texas: 

III. A computation of each category of damages claimed by the disclosing party—who 

must also make available for inspection and copying as under Rule 34 the 

documents or other evidentiary material, unless privileged or protected from 

disclosure on which each computation is based, including materials bearing on the 

nature and extent of injuries suffered. 

Defendant, McGaughey, Reber and Associates, Inc. has no claim for damages pending at 

this time. Defendant reserves the right to supplement this answer, should a CounterClaim against Plaintiff be filed.

IV. For inspection and copying as under Rule 34, any insurance agreement under which 

an insurance business may be liable to satisfy all or part of a possible judgment in 

the action or to indemnify or reimburse for payments made to satisfy the judgment. 

There is no insurance coverage applicable to satisfy a possible judgement against 

the McGaughey, Reber and Associates, Inc., Defendant in this case. 

Date: August 5, 2022 

Respectfully Submitted,

/S/ Michael R. Rake

Michael R. Rake, Attorney at Law

SB # 16487600

P.O. Box 1556

Lake Dallas, TX 75065

Tel. & Fax: 940-498-2103

E-mail: mrake1@mrakeattorney.com

Counsel for Defendant McGaughey, Reber and 

Associates, Inc. d/b/a Diversified Credit Systems, 

Inc.

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CERTIFICATE OF SERVICE

I certify that on this 5th day of August 2022 a true and correct copy of the foregoing 

document was served on the below listed counsel of record for Plaintiff/Counterclaim Defendant 

Ross and all other parties of record by a means permitted by Rule 5(b)(2) of the Federal Rules of 

Civil Procedure (“F.R.C.P.”). 

/S/ Michael R. Rake

Michael R. Rake, Attorney at Law

KERRI PHILLIPS- Kerri@KDphillipslaw.com

HEATHER ABREU -Heather@KDphillipslaw.com

SANFORD R. DENISON-denison@baabdenison.com

Margot A. Nikitas- MNikitas@apfa.org

William W. Osborne-b.osborne@osbornelaw.com

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