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-430-Y

 Judge Terry R. Means

(Relates to Motion Referred to 

Magistrate Judge Cureton)

DEFENDANTS’ RESPONSE IN OPPOSITION

TO AMENDED MOTION TO COMPEL

RESPONSES TO FIRST REQUESTS FOR PRODUCTION

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TABLE OF CONTENTS

FACTUAL AND PROCEDURAL BACKGROUND ....................................................................1

ARGUMENT: THE MOTION TO COMPEL SHOULD BE DENIED .........................................6

I. APFA COMPLIED WITH REQUEST 1. ...........................................................................7

II. REQUESTS 2 AND 3 ARE OVERLY BROAD AND UNDULY 

BURDENSOME..................................................................................................................7

III. THE APFA DEFENDANTS PROPERLY RESPONDED TO THE 

NARROWED SCOPE OF REQUESTS 2 AND 3 AGREED TO BY 

PLAINTIFF. ......................................................................................................................10

CONCLUSION..............................................................................................................................12

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TABLE OF AUTHORITIES

Cases Page(s)

Lopez v. Don Herring Ltd.,

327 F.R.D. 567 (N.D. Tex. 2018)..........................................................................................8, 9

MC Trilogy Texas, LLC v. City of Heath, Texas,

No. 3:22-CV-2154-D, 2023 WL 5918925 (N.D. Tex. Sept. 11, 2023).....................................9

MetroPCS v. Thomas,

327 F.R.D. 600 (N.D. Tex. 2018)..............................................................................................8

Ross v. APFA,

No. 4:22-cv-343-Y.....................................................................................................................5

Statutes

UNITED STATES CODE

29 U.S.C. § 401 et seq................................................................................................................2

Case 4:22-cv-00430-Y Document 148 Filed 11/13/23 Page 3 of 17 PageID 4541
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

(Relates to Motion Referred to 

Magistrate Judge Cureton)

DEFENDANTS’ RESPONSE IN OPPOSITION

TO AMENDED MOTION TO COMPEL

RESPONSES TO FIRST REQUESTS FOR PRODUCTION

Defendants the Association of Professional Flight Attendants (“APFA”), its President 

Julie Hedrick, and its Treasurer Erik Harris, hereby oppose Plaintiff’s Amended Motion to 

Compel their responses to Plaintiffs First Requests for Production of Documents, Doc. 134. As 

shown below, Defendants have complied with the Requests as narrowed by counsel during the 

conferral process, and Plaintiff’s effort to reassert a broader set of Requests fails because the

original Requests are overly broad and unduly burdensome. The motion should be denied.

FACTUAL AND PROCEDURAL BACKGROUND

This case arises out of an internal union arbitration, which addressed charges of financial 

misconduct by Plaintiff Eugenio Vargas during his term as Treasurer of APFA. Pursuant to the 

APFA Constitution, two rank-and-file union members filed internal charges against Mr. Vargas 

alleging a range of financial misconduct while in office. A nationally respected arbitrator, Ruben 

R. Armendariz, served as the impartial arbitrator in the hearing on these charges and, after an 

extensive hearing, concluded that Mr. Vargas had, among other things, “attempted to benefit 

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

formula” for calculation of certain benefits paid to himself and three other former National 

Officers. Doc. 1-1 at 35, 37. In a supplemental ruling based on an independent financial review 

ordered by the Arbitrator, Arbitrator Armendariz determined that Mr. Vargas had made over 

$13,000 in “Inappropriate credit card charges related to meals.” Supp. Decision, Doc. 39-1 at 2; 

see also Order, Doc. 46 at 1 (taking judicial notice of the supplemental arbitral decision). Mr. 

Vargas was ordered to repay that amount, the cost of the independent financial review, and half 

of the Arbitrator’s fee and was “prohibited from serving in any APFA National Officer position 

or Regional Officer position for life.” Doc. 39-1 at 2.

While Mr. Vargas did agree to repay the APFA for some of his improper expenditures, 

Doc. 1-1 at 37 (noting that Mr. Vargas had “entered into a payment agreement to repay the 

overage debt” in one regard), he did not comply with the obligation to repay the union for other 

improper expenditures or other costs. Instead, he has sued the APFA and its National President 

and Treasurer claiming in the operative First Amended Complaint, Doc. 133, that the arbitration 

violated the Labor Management Reporting and Disclosure Act, 29 U.S.C. § 401 et seq.; and also 

that the APFA Defendants breached the APFA Constitution, breached their fiduciary duty, and 

engaged in fraud in connection with the arbitration. Doc. 133 ¶¶ 28-54. Plaintiff seeks $50,000 in 

compensatory damages, plus punitive damages. Doc. 133 at 11.

In addition, the APFA has filed a counterclaim against Mr. Vargas for breach of his 

federal fiduciary duty, based on the final and binding determination of the Arbitrator that Mr. 

Vargas had expended and received union funds in violation of the APFA Constitution and Policy 

Manual. Doc. 132 at ECF pp. 6-11.

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In July 2022, Plaintiff served the APFA Defendants with three Requests for Production of 

Documents. Pl.’s Appx. 3-8, Doc. 136 at ECF pp. 6-11. Plaintiff requested:

1. “All documents ... that afford liability insurance to either APFA, or 

any of the current or former officer, board members, or any authorized agents or 

employees ... for purposes of protection in compliance with Labor Management 

Reporting and Disclosure Act 502(a)”

2. “All documents, correspondence and communications between the 

accounting firm of Wood, Stephens & O’Neil, LLP and any APFA official, whether 

current or former, elected or appointed; or any APFA counsel, whether in-house or 

outside counsel, concerning the Ross Administration.”

3. “All communications between any APFA officials, whether current 

or former, elected or appointed; or any APFA counsel, whether in-house or outside 

counsel, which disseminated any communications or documentation from Wood, 

Stephens & O’Neil, LLP concerning the Ross Administration.” 

Pl.’s Appx. 8 (emphasis added). For purpose of these Requests, Plaintiff defined “the Ross 

Administration” to “mean[] any person supporting Robert ‘Bob’ Ross’s elected position as 

National President or Base President, including but not limited to Eugenio Vargas and Nena 

Martin.” Pl.’s Appx. 6 (emphasis added).1

The firm Wood, Stephens, & O’Neil, LLP (“WSO”) is an accounting firm based in Fort 

Worth, Texas. The firm, through Hal O’Neil, CPA, one of its owners, has provided accounting 

services to the APFA since 2004. The firm conducts an annual audit of the APFA, works on tax 

returns, and performs audits relating to certain requirements of the Railway Labor Act, 45 U.S.C. 

§ 151, et seq., regarding union dues. It also responds to requests for additional analysis on an asneeded basis. Declaration of Hal O’Neil, Appx. 3, ¶ 3.

1 Mr. Ross served as APFA National President from 2016 to 2018, and as San Fransisco Base 

President in 2021-2022. While Plaintiff in his motion asserts a different definition of “Ross 

Administration,” see Doc. 135 at 1 n.1, the quoted language above is from the Requests for 

Production he seeks to enforce.

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In 2019 and 2020, Mr. O’Neil reviewed certain payments that had been made to certain 

former officers of the APFA, including Mr. Vargas. In connection with those requests, Mr. 

O’Neil prepared and produced to the APFA worksheets showing overpayment calculations the 

firm had made along with a memorandum. Declaration of Hal O’Neil, Appx. 3, ¶ 4. Plaintiff has 

referred to this memorandum as the “Confidential Memorandum” and it plays, according to 

Plaintiff, a central role in his lawsuit. See Doc. 135 at 5-6.

2

The Defendants timely served objections to these Requests including, among other 

things, objections based on overbreadth and ambiguity. The Defendants further objected that in 

light of their then-pending Motion to Dismiss for lack of subject matter jurisdiction, Doc. 24, 

discovery on any of these issues was improper or at minimum posed an undue burden until the 

issue of subject matter jurisdiction was decided. Pl.’s Appx. 10-18, Doc. 136 at ECF pp. 13-21.3

On August 14, 2023, over a year after Defendants had responded to the Requests for 

Production and less than three months before discovery closed, Plaintiff’s counsel emailed 

defense counsel with a “Request for Discovery and Withdraw of Objections ... Conference 

Requirement.” Pl.’s Appx. 27-28, Doc. 136 at ECF pp. 30-31. Focusing on the “insurance 

documents, and the communications about the Confidential Memo and any communication

transmitting it to other union members, please advise whether your clients plan to produce any

documents.” Pl.’s Appx. 28-29, Doc. 136 at ECF pp. 31-32. After discussion among counsel, 

2 While not dispositive in the context of the present motion, Defendants note that Plaintiff vastly 

overstates the significance of the Confidential Memorandum. Among other things, it did not 

clear Mr. Vargas or anyone of wrongdoing, and, indeed, the Arbitrator held that Mr. Vargas had 

acknowledged his own error in authorizing and receiving payments discussed in that memo and 

had himself agreed to repay the amounts he improperly received. See Defs.’ Appx. 7-10

(Arbitration decision excerpt, filed by Plaintiff as Doc. 1-1 herein).

3 The Court granted the motion to dismiss, Doc. 52, but on reconsideration allowed Plaintiff to 

file an amended complaint, Doc. 72.

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Plaintiff’s counsel “offered to restrict [the request concerning communications] to only those 

documents and communications relating to the Ross Administration since 2018 – after the Ross 

Administration left office.” Pl.’s Appx. 22-23, Doc. 136 at ECF 25-26. The APFA Defendants 

then agreed to produce APFA’s documents related to the O’Neil firm’s evaluation of 

overpayments made to Mr. Vargas and other union officers, as well as an audit report created by 

the O’Neil firm covering the year in which Mr. Vargas and Mr. Ross left office. Pl.’s Appx. 19, 

Doc. 136 at ECF p. 22.

To comply with this agreement, APFA searched electronic and physical files of the APFA 

representatives who would have communicated with the O’Neil firm or would have received

communications between the APFA and the O’Neil firm. Responsive documents were compiled 

and initially produced as separate communications, and then again – after a request by Plaintiff’s 

counsel – as complete email chains. See Pl.’s Appx 1 (email J. Bartos to K. Phillips, 9/1/23); 

Defs.’ Appx. 2, 11 (Declaration of C. Matts, ¶ 4; email J. Bartos to K. Phillips, 10/20/23).4 In 

addition to the APFA Defendants’ production, Plaintiff’s counsel – who represents former APFA 

President Robert Ross in a related case, Ross v. APFA, No. 4:22-cv-343-Y – subpoenaed the 

O’Neil firm for its corresponding set of documents and received responsive documents. (That 

production is also subject to a pending motion to compel.)

With regard to the requested insurance policy documents, Plaintiff had earlier subpoenaed 

the APFA’s long-standing insurance broker, IMA Financial, which produced a complete set of 

APFA policies. Defs.’ Appx. 17 (IMA Production Email, 6/1/23). Rather than re-producing 

4 Plaintiffs’ Appendix includes some, but not all, of the APFA Defendants’ initial production 

(Pls.’ Appx. 73-154) but does not include the supplemental production of complete email chains, 

which were numbered APFA 100-176, see Defs.’ Appx. 11 (email J. Bartos to K. Phillips, 

10/20/23).

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these documents, APFA referred Plaintiffs’ counsel to those documents which Plaintiff already 

had in his possession. Pl.'s’ Appx. 1.

Despite the APFA’s production, Plaintiff filed his Amended Motion to Compel on 

October 20, 2023. Doc. 134. Plaintiff accuses Defendants’ counsel of “never turning over any 

meaningful discovery” and speculates that Defendants have “with[e]ld many relevant 

documents” and failed to “take any meaningful discovery measures to find ... and produce 

discovery in this case.” Doc. 134 at 3. While acknowledging, on the one hand, that he 

“narrowed his request to a specific time frame and well defined the subject matter” of the 

requests, Doc. 135 at 17, Plaintiff describes the sweep of his request as now including “all 

communications and documents about the Ross Administration,” from “April 2016, to current”, 

ibid., and now including all “communications between APFA officials discussing the Ross 

Administration since 2020,” id. at 18. Plaintiff argues that his Requests are “proportional to the 

needs of his claim,” not overly broad, and are relevant. Id. at 7, 15-18.

ARGUMENT

THE MOTION TO COMPEL SHOULD BE DENIED

Plaintiff’s motion should be denied. With respect to the request for insurance policy 

documents, APFA has formally advised Plaintiff that he has the complete set of responsive 

documents from APFA’s insurance broker. There is no meaningful dispute with respect to that 

issue. With respect to communications with the accounting firm, Wood, Stephens & O’Neil, 

LLP (“WSO”), and follow on transmittals of information from that firm among APFA 

representatives, the Requests as written are on their face overly broad, ambiguous, and unduly 

burdensome. Plaintiff agreed to narrow his requests to communications regarding WSO’s 

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analysis of overpayments, and APFA searched for provided responsive documents. Plaintiff 

impugns that production as inadequate, but his critique is speculative and unfounded. 

I. APFA COMPLIED WITH REQUEST 1.

Plaintiffs first request sought insurance policies held by APFA. On June 1, 2023, these 

policies, totaling over 1400 pages, were produced in full to Plaintiff by IMA Financial the 

APFA’s insurance broker. Defs.’ Appx. 17 (IMA Production Email) Subsequently, APFA 

confirmed in writing that the IMA production was also responsive to the request to APFA. See

Pl.’s Appx. 1. Plaintiff insists on APFA producing these same documents to him again, a demand 

which is utterly unnecessary and the reasoning for which he has never explained. Rule 26 

contemplates that “the court must limit ... discovery ... if it determines that: (i) the discovery 

sought is unreasonably cumulative or duplicative, or can be obtained by some other source that is 

more convenient ... [or] (ii) the party seeking discovery has had ample opportunity to obtain the 

information.” Rule 26(b)(2)(C), Fed. R. Civ. P. Plaintiff already has the documents he seeks, 

APFA has confirmed exactly which documents those are, and there is no basis to compel APFA 

to simply send him the same documents which are within his possession. The motion should be 

denied with respect to Request 1.

II. REQUESTS 2 AND 3 ARE OVERLY BROAD AND UNDULY BURDENSOME.

Plaintiff’s requests regarding communications with the accounting firm WSO, or further 

transmission of such communications, are not reasonably particular, but are overly broad and 

unduly burdensome on their face.

Federal Rule of Civil Procedure 34(b) provides that a request for production ... 

must describe with reasonable particularity each item or category of items to be 

inspected or produced. The test for reasonable particularity is whether the request 

places the party upon ‘reasonable notice of what is called for and what is not. 

Therefore, the party requesting the production of documents must provide 

‘sufficient information to enable [the party to whom the request is directed] to 

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identify responsive documents. The goal is that the description be sufficient to 

apprise a man of ordinary intelligence which documents are required.

Lopez v. Don Herring Ltd., 327 F.R.D. 567, 575–76 (N.D. Tex. 2018) (citations and internal

quotations marks omitted).

Requests 2 and 3 fail this basic test. As noted above, after defining the term “the Ross 

Administration” to “mean[] any person supporting Robert ‘Bob’ Ross’s elected position as 

National President or Base President, including but not limited to Eugenio Vargas and Nena 

Martin,” Pl.’s Appx. 6 (emphasis added), Plaintiff goes on to request

2. “All documents, correspondence and communications between the 

accounting firm of Wood, Stephens & O’Neil, LLP and any APFA official, whether 

current or former, elected or appointed; or any APFA counsel, whether in-house or 

outside counsel, concerning the Ross Administration.”

3. “All communications between any APFA officials, whether current 

or former, elected or appointed; or any APFA counsel, whether in-house or outside 

counsel, which disseminated any communications or documentation from Wood, 

Stephens & O’Neil, LLP concerning the Ross Administration.” 

Pl.’s Appx. 8 (emphasis added). By their terms, these requests call for the APFA Defendants to 

determine who are people “supporting” Mr. Ross during the two periods he held office (first as 

National President, and then as SFO Base President) and then to search for all communications

with the union’s long-standing outside accounting firm for any past audit or other 

communications regarding any such unspecified person and also any transmittal of any such 

communications. These requests would thus require APFA to search through all communications 

between any current or former APFA representative and anyone at Wood Stephens & O’Neil 

going back to at least 2016 regardless of the particular subject matter. Such requests are facially 

improper. See MetroPCS v. Thomas, 327 F.R.D. 600, 610 (N.D. Tex. 2018) (discovery requests 

are “facially overbroad where [they] ... seek all documents concerning the parties to [the 

underlying]] action, regardless of whether those documents relate to that action and regardless of 

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date; [t]he requests are not particularized; and [t]he period covered by the requests is 

unlimited.”); Lopez, 327 F.R.D. at 576.

The overbreadth of these requests is underscored by the fact that Mr. Vargas made no 

effort to limit them to communications or documents relating to himself or his claims and 

counter-defenses. He seeks all information regarding all unnamed “supporter[s]” of the Ross 

Administration, and at minimum regarding named individuals who are not party to this action. 

Such information is not likely to lead to the discovery of admissible evidence.

Plaintiff defends these Requests by asserting that he “is not requesting unlimited access 

to Defendant’s records,” Doc. 135 at 17, but quickly concedes just how overly broad his requests 

are: claiming that he “is simply requesting Defendants produce all communications and 

documents about the Ross Administration,” id. at 17 (emphasis added). These “[allencompassing demands” fail to meet the requirement of reasonable particularity and are overly 

board. Lopez v. Don Herring Ltd., 327 F.R.D. at 575.

These requests would also unduly impinge on legitimate privacy interests of individual 

APFA representatives during the past seven years, whose financial information may have been 

reviewed or discussed as part of any work by WSO. Plaintiff’s counsel adamantly refused to 

discuss a protective order and communicated Mr. Vargas’s disavowal of any interest in 

maintaining confidentiality of such information. Defs.’ Appx. 13-15 (emails regarding

confidentiality). In light of Mr. Vargas’s failure to show any need for this information, these 

privacy concerns are compelling reasons to deny the motion. See MC Trilogy Texas, LLC v. City 

of Heath, Texas, No. 3:22-CV-2154-D, 2023 WL 5918925, at *8 (N.D. Tex. Sept. 11, 2023), 

Appx. 25 (finding burden, including privacy intrusion, “imposed on the non-party ... is too great 

when compared to the negligible discoverable information that [plaintiff] may obtain.”).

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Finally, compliance with the broad requests now pursued by Mr. Vargas would impose a 

substantial and undue burden on APFA. APFA would be required to search physical and 

electronic files going back over seven years for all communications with WSO regarding any 

member (or, potentially, any “supporter”) of the Ross Administration on any topic whatsoever, as 

well as all documents exchanged which related to any transactions involving such people. APFA 

would also have to search physical and electronic files for any internal communications among

or between any “current or former”, “elected or appointed” APFA officials. APFA has at any 

given time approximately 33 elected representatives at the national level, and approximately 32

appointed representatives. Plaintiff’s unlimited request for seven years of such documents would 

multiply that number significantly. Defs.’ Appx. 2 (Matts Decl.), ¶ 5. Compliance with the 

Requests as now pressed by Plaintiff would consume substantial amounts of APFA staff 

resources and funds, with little to no corresponding benefit to Plaintiff or the ultimate resolution

of this case. 

III. THE APFA DEFENDANTS PROPERLY RESPONDED TO THE NARROWED 

SCOPE OF REQUESTS 2 AND 3 AGREED TO BY PLAINTIFF.

In the course of discussion regarding the scope of Plaintiff’s requests, Plaintiff agreed to a 

narrower scope for production, to which the APFA Defendants then properly responded. As 

discussed above, given Plaintiff’s focus on what he calls the “Confidential Memo” produced by 

WSO, which was written in 2020, and given the APFA’s concerns over the broad sweep of the 

requests, the parties agreed to limit the scope of requests to documents surrounding the 

production and dissemination of the Confidential Memo, and communications with WSO 

regarding Ross after he had left office. APFA thereafter searched its files for responsive 

documents and produced them to Plaintiff, including WSO’s audit covering Plaintiff’s final year 

in union office. See Defs.’ Appx. 1-2 (Matts Decl. ¶¶ 3-4). When Plaintiff initially questioned 

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the format of the original production, APFA responded with an additional production showing all 

email chains. Defs.’ Appx. 11.

Plaintiff impugns that production as inadequate, but his critique is speculative and 

unfounded. Plaintiff speculates—offering no evidence—that more documents must exist. Doc. 

135 at 8 (assuming communications from APFA President); 11 (“the most compelling evidence 

that the other side is withholding evidence, is the lack of evidence itself”); 11 (assuming there

would be emails showing a “set up for the services ... [and] agreement on what needs to be 

done”); 14 (assuming that the Confidential Memo “would have been heavily discussed [in 

writing] before Hal O’Neil drafted this letter”). The argument is as evidence-free as it is circular. 

Plaintiff also critiques the format of the APFA’s initial production, which had separated 

out email communications, id. at 10, but that issue was resolved by the APFA’s production of the 

complete email chains in its supplemental production.5 And while Plaintiff asserts that various 

“worksheets” attached to emails were not produced, his own Appendix includes the worksheets

associated with the Confidential Memorandum regarding the overpayments made to himself, Mr. 

Ross, and the others from the Ross Administration. See Pls.’ Appx. 100-01 (email referencing 

“the workpapers we discussed” and listing attachments) and Pls’ Appx. 102-131 (the workpapers 

as referenced in the email); see also Pl.’s Appx. 141 (email referencing Memorandum and “the 

attached schedules”) and Pl’s Appx. 142-154 (the referenced Memorandum and schedules).6

5 For example, the “gaps” between emails Plaintiff complains of, Doc. 135 at 10, were simply a 

byproduct of the initial production style; the subsequent production of email chains has no such 

“gaps.”

6 During the course of supplementing discovery and reviewing Plaintiff’s briefing, APFA 

determined that attachments to two emails from the year prior to the Confidential Memorandum 

had not been included in the prior production and has supplemented its production to include 

these attachments. These pertain to the emails shown at Pl.’s Appx. 3-4.

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With respect to Requests 2 and 3, Plaintiff seeks in his Proposed Order a mandate that 

APFA produce all responsive documents “in .PST format”. No such demand was made in the 

Requests for Production, however, and the APFA should not be made to produce the same 

documents in more than one format. See Fed. R. Civ. P. 34(b)(2)(E)(iii) (“A party need not 

produce the same electronically stored information in more than one form.”).

At bottom, APFA searched for and produced responsive documents. Plaintiff’s ipse dixit 

belief that there must be more is not grounds for any relief under the Federal Rules.

CONCLUSION

For the foregoing reasons, Defendants respectfully submit that Plaintiff’s Amended 

Motion to Compel should be denied.

Dated: November, 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

abird@geclaw.com

Counsel for Defendant and Counterclaim Plaintiff 

Association of Professional Flight Attendants, and 

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13

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

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CERTIFICATE OF SERVICE

I certify that on November 13, 2023, I electronically submitted this document to the clerk 

of the court for the U.S. District for the Northern District of Texas using the court’s electronic 

case filing system. The electronic case filing system sent a “Notice of Electronic Filing” to the 

following individuals, who have consented to accept this Notices as service of this document by 

electronic means: 

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

notice@KDphillipslaw.com

/s/ James D. Sanford

JAMES D. SANFORD

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