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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-403-Y 

Judge Terry R. Means

PLAINTIFF’S MOTION TO COMPEL DEFENDANTS’ 

PRODUCTION OF DOCUMENTS 

Now comes the Plaintiff, EUGENIO VARGAS (hereinafter “Plaintiff” or “Vargas”), by 

and through undersigned counsel, pursuant to Federal Rules of Civil Procedure 34, 37, and Local 

Rules 5.2 and 7.1 and files his Motion to Compel Defendants ASSOCIATION OF 

PROFESSIONAL FLIGHT ATTENDANTS (hereinafter “APFA”), Julie Hedrick and Erik Harris 

(collectively referred to as “Defendants”) Production of Documents and withdraw objections to 

Plaintiff’s requests for production and produce whatever documents may be in Defendants’

possession or subject to its control that are responsive to Plaintiff’s First Amended First Request 

for Production served upon Defendant in this cause and in support thereof would respectfully show 

as follows: 

 

II. FACTS 

Plaintiff served Defendants with PLAINTIFF/COUNTERCLAIM DEFENDANT 

FIRST AMENDED FIRST REQUEST FOR PRODUCTION TO 

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DEFENDANTS/COUNTERCLAIM PLAINTIFF on July 29, 2022. Defendants

responded to Plaintiff’s First Amended First Request for Production, via email on 

August 26, 2022.

Defendants’ Responses to Plaintiff’s Requests for Production are attached 

hereto in Plaintiff’s Appendix to Motion to Compel and are incorporated herein by 

this reference for all purposes. (See App. Pgs. 1-30). Defendants objected to Plaintiff’s

Requests for Production No.’s 1, 2, and 3. All of the requests by Plaintiff in the 

Requests for Production are necessary to enable Plaintiff to prepare for trial in this 

cause. Defendants’ objections have no merit. Plaintiff is seeking an order from this 

Court ruling the objections should be withdrawn and the Requests properly answered 

by Defendants.

Without the documents requested, Plaintiff will not be able to effectively prove 

his claims at trial.

WHEREFORE, PREMISES CONSIDERED, Plaintiff prays as follows:

1. That Defendants be ordered to withdraw their objections to Plaintiff’s

First Amended First Amended First Request for Production and to 

produce all of the requested documents in Defendants’ possession or 

subject to their control that are responsive to Plaintiff’s First Amended

First Request for Production.

2. Movant be awarded such other and further relief, legal or equitable, 

which Movant may show itself justly entitled to receive.

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Respectfully submitted,

K.D. 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 on September 5, 2023, a true and correct copy of the above was served on 

Defendants’ attorneys, via the e-filing manager. 

/S/ Kerri Phillips

Kerri Phillips

Jeffrey Bartos

Guerrieri, Bartos, & Roma, P.C. 

1900 M Street, NW, Suite 700

Washington, DC 20036

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

Email: jbartos@geclaw.com

Charlette Matts

In-House Counsel for APFA

1004 West Euless Blvd

Euless, TX 76040

Tel: (682) 301-8454 

Cmatts@apfa.org

Case 4:22-cv-00430-Y Document 110 Filed 09/05/23 Page 3 of 4 PageID 3726
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James Sanford

4803 Gaston Avenue

Dallas, TX 75249-1020 

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

0001 

Email jim@gillespiesanford.com

Email: joe@gillespiesanford.com

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