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.

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§ 

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§ 

§ 

§ 

§ 

§ 

§ 

§ 

Civil Action No. 4:22-cv-403-Y 

Judge Terry R. Means

PLAINTIFF’S BRIEF IN SUPPORT OF 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, 7.1, 7.2, 53.1, 56.3, 56.6 and files his Brief in Support of his Motion to Compel 

Defendants Production of Documents from ASSOCIATION OF PROFESSIONAL FLIGHT 

ATTENDANTS (hereinafter “APFA” or the “Union”), Julie Hedrick (“Hedrick”) and Erik Harris 

(“Harris”) (hereinafter collectively referred to as “Defendants”). Specifically, Defendants failed 

to provide responses to Plaintiff’s discovery requests served on July 29, 2022. Despite conferral 

with Defendants, as detailed below, Defendants failed to provide any documents responsive to 

Plaintiff’s requests for production under the improper objection(s) of “vague, ambiguous, overly 

broad, and not reasonably focused or tailored to lead to the discovery of information relevant to 

any claim or defense of the parties.” (See App. Pgs. 15-17). Plaintiff seeks information pertinent 

to the actions taken against the Ross Administration.

1 Plaintiff is entitled to the documentation 

1 “The Ross Administration” has previously been, and hereinafter will be, defined as the phrase is commonly known 

among the APFA membership: the four APFA members that served as National Officers from April 1, 2016 to June 

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requested in his First Amended First Requests For Production as the requested information is 

proportional to the needs of the case. Thus, Plaintiff seeks an order compelling Defendant to 

provide all documentation responsive to Plaintiff’s First Request for Production No. 1, 2, and 3. 

In support thereof, Plaintiff states the following:

1, 2018—which included Plaintiff, Eugenio Vargas as National Treasurer, Robert “Bob” Ross as National President, 

Nena Martin as National Vice-President, and Marcy Dunaway as National Secretary. Ms. Dunaway resigned from 

her position as American Airlines Flight Attendant, and therefore is no longer a member of APFA. 

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Contents

Table of Authorities....................................................................................................................3

Introduction and Rule 37(a) Certificate of Conference.................................................................5

Background .................................................................................................................................5

Argument and Authorities. ..........................................................................................................9

Defendant Failed to Answer Requests for Production and Has Otherwise Failed to Show How 

Plaintiff’s Request is Not Relevant or Otherwise Objectionable ............................................. 11

CONCLUSION......................................................................................................................... 14

Local Rule 7.1(b) Conferral and Certificate of Conference ..................................................... 15

Table of Authorities

Authorities

Dennis v. U.S., 3:16-cv-3148-G-BN (N.D. Tex. Oct. 23, 2017) 9 

McGowan v. SMU, 3:18-CV-141-N (N. D. Tex. May 6, 2020) 9, 10, 11, 13 

McLeod, Alexander, Powel & Apffel, P.C. v. Quarles, 894 F.2d 1482 (5th Cir. 1990) 9 

OrthoAccel Tech., Inc. v. Propel Orthodontics, LLC, 4:16-cv-00350-ALM (E.D. 9. 11. 12

 Tex. Apr. 4, 2017). 

Regulations & Statutes 

29 U.S.C. § 501 11 

Court Rules 

Fed. R. Civ. P. 34 1, 9, 10 

Fed. R. Civ. P. 34(a) 1, 9

Fed. R. Civ. P. 37 5, 9, 10

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Fed. R. Civ. P. 37(a)(3)(B) 1, 5

L.R. 5.2 1

L.R. 7.1 1

L.R. 7.2 1

L.R. 53.1 1

L.R. 56.3 1

L.R. 56.6 1

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Introduction and Rule 37(a) Certificate of Conference

The subject matter of this motion relates to a long-existing attempt by Plaintiff to obtain 

discovery from Defendant. These matters have already been brought to the Court’s attention 

through Plaintiff’s Response to Motion to Stay Discovery in the Ross v. APFA, et al case. (See 

Doc. Nos. 61, PAGEID 1661-62). This motion is expressly being brought pursuant to Rule 37 as 

well as the Court’s inherent powers. Notice of this motion is being served on Plaintiff’s counsel 

as noted below. The undersigned hereby certifies that he has conferred with counsel for

Defendants, most recently on September 1, 2023 in good faith and that every effort has been 

made to obtain the discovery that forms the basis of this motion without the need for court 

intervention. 

Background

In his Complaint, Plaintiff alleges claims of labor management violations, breach of the 

union constitution, and breach of fiduciary duty among others. Plaintiff was charged by his 

union and subjected to a disciplinary arbitration hearing that subsequently resulted in an award 

to the union for $30,963.03. During the review of the charges by the APFA Board of Directors, 

and the APFA Executive Committee documents pertinent to the allegations against him were 

withheld from the APFA leadership. During the disciplinary arbitration, Defendants 

intimidated witnesses and withheld exculpatory documents, including a confidential 

memorandum dated October 22, 2020 from an accounting firm—Woods, Stephens, & O’Neil, 

L.L.P.—that confirmed Plaintiff did not violate policy by overpaying Robert “Bob” Ross 

(“Confidential Memo”). The Confidential Memo stated “these payments appear appropriate 

and in compliance with the transition agreement.” (Doc. 1-2, PAGEID 52). Plaintiff asserts 

that this conduct was the result of his association and affiliation with the Ross Administration 

as National Treasurer from April 1, 2016 to June 1, 2018 [See Doc. 1, 76]. The Ross 

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Administration affiliates with a political group within the union in opposition to the political 

group currently in power. Plaintiff asserts that Defendants’ conduct resulted in an unlawful 

discipline designed to obstruct his free speech and association rights within the union. 

Furthermore, the conduct breached the APFA Constitution, and the Union and National 

Officers fiduciary duty owed to him as a member of the union in good standing. At issue in 

this Motion is Defendants’ inadequate production of documentation, or a proper objection(s), 

to Request for Production No. 1, 2 and 3 which seeks the following documents:

“1. All documents, including but not limited to policy documents, insurance 

contracts, addendums, exclusions, conditions, and declarations pages that afford 

liability insurance to either APFA, or any one of the current or former officers, 

board members, or any authorized agents, or employees acting on behalf of 

APFA 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, L.L.P. 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, L.L.P. concerning the Ross Administration.” (See 

App. Pgs. 8).

Plaintiff’s Request for Production No. 1, 2 and No. 3 requests information that is

proportional to the needs of his claims. More specifically, documents identifying other APFA 

leadership members who knew of the Confidential Memo or any other documentation that 

absolved Plaintiff of any wrong-doing. The requests seek documents and/or communications 

that expose those with any notice of any exculpatory documents concealed from the Plaintiff. 

It would also indicate Defendants’ intentions, feelings, and ultimate goals in relation to their 

actions toward the Ross Administration. 

On July 29, 2022, Plaintiff served his First Amended First Request for Production on 

Defendants. On August 26, 2022, Defendants’ Counsel, produced responses to Plaintiff’s First

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Amended First Request for Production and no documents. (See App. Pgs. 10-18). In their 

responses, Defendants raised claims of privilege and objections to each and every Requests for 

Production, however failed to provide a privilege log and improperly objected based on 

obscurity, relevancy, vagueness, and overly-broad requests being made. 

On August 14, 2023, Plaintiff’s Counsel conferred with Defendants’ Counsel via email 

regarding the discovery disputes. (See App. Pgs. 27-29). Defendants’ counsel responded on 

August 15, 2023 and stated that he would get back regarding this matter. (See App. Pgs. 26-

27). After no response was forthcoming, Plaintiff’s counsel emailed a second time on August 

17, 2023 and Defendants’ counsel requested a telephone call to discuss the requested 

documents. (See App. Pg. 24-25). 

Defendant’s counsel called Plaintiff’s counsel on August 23, 2023 to discuss the 

ongoing issues. The phone call on August 23, 2023 was documented in an email on August 25, 

2023 wherein all issues related to discovery were rectified, except for those documents related 

to the communications and documents between APFA and Woods, Stephens, and O’Neil as 

well as those responsive of Plaintiff’s requests for the internal distribution and discussion 

surrounding the Confidential Memorandum from Hal O’Neil. On August 25, 2023, Plaintiff’s 

counsel rectified all issues relating to discovery that Defendants’ counsel had raised and turned 

over every document in Counsel’s possession. 

As for Defendants’ counsel, however no documents were produced until September 1, 

2023 by Defendants’ counsel. (See App. Pgs. 21-23). In terms of the responsive documents, 

no documents responsive of Requests for Production 1, whilst very limited number of 

documents were produced in response to Requests for Production 2 and 3. Furthermore, only

99 pages of documents were produced, containing large blank sections within the email 

exchanges wherein portions of communications are either redacted without notation or simply 

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removed from the original documents. The documents were not in their original true and 

correct form. Notably missing from these communications are any emails from the National 

President, Julie Hedrick. Defendants failed to produce any privilege log asserting what 

documents and what communications have been redacted or removed based on privilege and 

which are not being produced based on privilege. Plaintiff seeks an order compelling all 

relevant insurance policies and riders covering the individual officers, documentation and 

communications between Woods, Stephens, and O’Neil and APFA in their original form, 

without any alterations, redactions, or deletions, since 2016 to current, as well as 

communications between APFA officials discussing the Ross Administration since 2020, again 

without any redactions, alterations, or deletions. These documents and communications are 

relevant, not privileged, and within the scope of discoverable information. 

While the parties were able to confer, no resolution has been reached as to Defendants’ 

lack of any adequate production of documents. In essence, Defendant contends that the 

requests for documentation are overly-board—however specificity was clarified during the 

conference call without appeasing Defendants’ counsel. Regarding Defendants’ concerns, 

Plaintiff produced all documents in Plaintiff’s counsel’s possession. Yet, Defendants have 

failed to produce insurance documents and communications that they agreed to produce. Those 

limited documents that were produced were heavily redacted or altered emails without notation 

for any redactions nor any privilege log provided. Plaintiff’s requests are proportional to the 

needs of this case and if not provided will leave him unable to adequately prepare for trial. 

Plaintiff will undoubtedly be prejudiced if Defendants are allowed to circumvent standard 

procedural requirements, production, and disclosure of documents—to maintain a flippant 

disregard of the procedural laws, and authority of this Court. 

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Argument and Authorities

The Federal Rules of Civil Procedure allow the parties to “obtain discovery regarding 

any nonprivileged matter that is relevant to any party’s claim or defense and proportional to the needs 

of the case.” Fed. R. Civ. P. 26(b)(1); McGowan v. SMU, 3:18-CV-141-N (N. D. Tex. May 6, 2020)

at *2. (See App. Pgs. 43-45). A litigant may request the production of documents falling "within 

the scope of Rule 26(b)" from another party if the documents are in that party's "possession, 

custody, or control." FED. R. CIV. P. 34(a). The Federal Rules of Civil Procedure further provide 

for a proportionality standard for discovery. Fed. R. Civ. P. 26(b)(1); Dennis v. U.S., 3:16-cv3148-G-BN (N.D. Tex. Oct. 23, 2017) (See App. Pgs. 32-42).; OrthoAccel Techn., Inc. v. Propel 

Orthodontics, LLC, 4:16-cv-00350-ALM (E.D. Tex. Apr. 4, 2017) at *5. (See App. Pgs. 46-49). 

The Fifth Circuit requires the party seeking to prevent discovery to specify why the discovery is 

not relevant or show that it fails the proportionality requirement. McLeod, Alexander, Powel & 

Apffel, P.C. v. Quarles, 894 F.2d 1482, 1485 (5th Cir. 1990). “A district court has wide discretion 

to supervise discovery and must limit discovery if it would be unreasonably cumulative, could be 

obtained more easily from a different source, or if the burden or expense of the proposed discovery 

outweighs its potential benefit.” See FED. R. CIV. P. 26(b)(2)(C). McGowan at 2. (See App. Pgs. 

43-45). 

Furthermore, the Federal Rule of Civil Procedure 37 provides in part:

(a) MOTION FOR AN ORDER COMPELLING DISCLOSURE

OR DISCOVERY.

(1) In General. On notice to other parties and all affected persons, 

a party may move for an order compelling disclosure or discovery. The 

motion must include a certification that the movant has in good faith

conferred or attempted to confer with the person or party failing to make 

disclosure or discovery in an effort to obtain it without court action.

... 

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(3) Specific Motions. 

(B) To Compel a Discovery Response. A party seeking discovery 

may move for an order compelling an answer, designation, production, or 

inspection. This motion may be made if:

... 

(iii) a party fails to produce documents or fails to respond that 

inspection will be permitted – or fails to permit inspection – as requested 

under Rule 34.

Federal Rule of Civil Procedure 37 provides an avenue for any party seeking disclosure 

of documents to compel that disclosure with an order. Fed. R. Civ. P. 37(a)(3)(B); McGowan

at *2. (See App. Pgs. 43-45). The Fifth Circuit provides that once a party, in the instant matter 

the Plaintiff, meets its burden to show the information sought is relevant or will lead to the 

discovery of admissible evidence the burden then shifts back to the opposing party to show why 

the requested information is irrelevant or show that it fails the proportionality requirement.

McGowan at *2. (See App. Pgs. 43-45). Courts interpret relevance broadly—meaning that the 

evidence and information sought does not need to prove or disprove a claim, moreover the 

evidence or information sought does not even need to have a strong probative force to be

relevant. Id. at 3. (See App. Pgs. 43-45). Finally, when ruling on discovery matters under Fed.

R. Civ. P. 37 the court should look to balance the need for Plaintiff’s request against the harm, 

prejudice, and burden to Defendant. Id. (See App. Pgs. 43-45).

Here, the information sought in Requests for Production No. 1, 2 and 3 are relevant and 

Plaintiff has met his burden of showing that the information sought meets this standard. The 

insurance documents covering theft or misappropriation of the National Officers in 2016-2018 

could lead to any possible claims made on the insurance policy and possible investigation into 

the matter by the insurance company—the lack of any such claim made would be just as 

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profound to note to the court considering the claims for breach of fiduciary duty under LMRDA 

§501 for misappropriation and theft. The communications with Hal O’Neil, the accountant the 

conducted the accounting review that gave rise to creating the Confidential Memo which led to 

the claims before this court would be highly relevant and not privileged. Finally, the discussion 

and dissemination of the Hal O’Neil correspondence would also be relevant to the evidence of 

any coordinated effort to subvert Plaintiff’s rights as a union member. The documents 

produced were altered, incomplete as to all responsive documents, and highly redacted without 

any indication of the redactions or legal basis for altering the original documents. No privilege 

log was produced claiming a legal basis to withhold documents nor those involved or included 

in the communication. Defendants has not and cannot meet their burden. When analyzing the 

balance between Plaintiff’s need for the information in response to Requests for Production No.

1, 2 and 3 and the possible harm, prejudice, or burden to Defendant, the scale tips dramatically 

and unequivocally in Plaintiff’s favor.

A. Defendants Failed to Show How Plaintiff’s Request is Not Relevant or 

Otherwise Objectionable

In Ortho-Accel, the plaintiff requested financial records to aid in its damages claim and 

calculations. The defendant objected asserting the requested information “contain sales 

information for other products in Propel’s [defendant] line that are not the subject of this

litigation.” The court was not convinced. It held that the plaintiff in this case should not be 

deprived of information because the defendant sold multiple products which were listed in its 

financials records. (OrthoAccel, at *7). Additionally, the court held in OrthoAccel plaintiff’s 

request were not unduly burdensome or duplicative. (Id. at 8, 9). 

In McGowan the court found that defendant’s request for access to plaintiff’s multiple 

accounts on social media accounts was appropriate. (McGowan at 4, and 5). The court however,

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clarified that the defendant’s access was not “unlimited” as unlimited accessis too broad. (Id. at 

5). 

In the matter before this Court, Request for Production No. 1, and 2 requests insurance 

documents, as well as documents and communications between the accounting firm Woods, 

Stephens & O’Neil, L.L.P. regarding the four national officers noted as the Ross 

Administration.2 and the transmittal of the Confidential Memo with parties inside and outside 

the union. (See App. Pgs. 8). Request for Production No. 3 seeks communications between 

APFA officials, and or counsel for APFA transmitting communications and documentation 

from Woods, Stephens & O’Neil, L.L.P. (See App. Pgs. 7-8). In its August 26, 2022 response 

to Plaintiff’s Requests for Production, Defendantsstated as follows: 

“The Union Defendants object on the basis of Fed.R.Civ.P., Rules 1 and 26(c), as set 

forth above and fully incorporated herein.

The Union Defendants further object to this request because it seeks documents

’concerning the Ross Administration.’ Such a request is vague, ambiguous, overly 

broad and not reasonably focused or tailored to lead to the discovery of information 

relevant to any claim or defense of the parties. The Union Defendants further object to 

this request to the extent it seeks discovery of documents protected by the attorneyclient privilege, trial preparation privilege, and/or work product doctrine.

The Union Defendants further object to this request as it seeks discovery of documents 

and materials which are not relevant to any claim or defense of the parties in that, and 

to the extent that, they relate to matters within the exclusive jurisdiction of the 

Arbitrator, to matters which go the merits of the Arbitrator’s Decision and Order, and 

to matters which are otherwise irrelevant to the enforcement of the Arbitrator’s 

Decision and Order and/or to any claim within the Court’s subject matter jurisdiction.”

Similar to Propel Orthodontics, here, Defendant should not be permitted to withhold 

information or documentation responsive of Request for Production No. 1, 2 or 3 simply 

because Defendants assert the term “concerning the Ross Administration” is overly broad, 

vague, or ambiguous. Any Defendants objections based on overly broad, unduly burdensome 

and not likely to lead to the discovery of relevant information.” (See App. Pgs. 15-17). Any 

2 Ross Administration defined with the Amended Requests as “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” 

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internal communication regarding the Ross Administration since the day Mr. Ross took office 

is within the scope of discoverable information. Not only is the objection improper as 

boilerplate, but also improper based on the proportional needs of Plaintiff’s access to evidence 

that is relevant and proportional to the needs of his case. Communications about the Ross 

Administration between and among AFPA officials, and internal and outside counsel is pertinent. 

Further, it is not privileged as Mr. Vargas and Mr. Ross are dues-paying members and any counsel 

working on behalf of APFA is being paid with their union dues, thus there is mutual representation

of the parties. Margot Nikitas participated in the arbitration at issue for the parties, therefore she 

cannot assert attorney-client privilege. Finally, the counsel hired by APFA were not hired for the 

purposes of pursuit of the Ross Administration and their alleged infractions, rather at the time Margot 

Nikitas represented flight attendants in arbitrations conducted under the collective bargaining 

agreement with American Airlines, Inc. on behalf of APFA3

. Despite this fact no privilege log has 

been produced. Counsel discussed potentially limiting this request to those communications 

with Woods, Stephens, and O’Neil only after March 1, 2018—the date after which Ross 

resigned as National President—however, narrowing the request as such prejudices Plaintiff as 

Defendant is counter-suing Plaintiff for breach of fiduciary duty based on charges and 

payments made. It deprives Plaintiff of the financial documents related to his defense of 

APFA’s breach of fiduciary duty claim. 

Additionally, and like McGowan here, Plaintiff is not requesting unlimited access to 

Defendant’s records, he is simply requesting Defendants produce all communications and 

documents about the Ross Administration under which he served the union—those who were 

ultimately charged and disciplined by the union for similar conduct. Plaintiff narrowed his 

3 Note: Arbitrations conducted under a Collective Bargaining Agreement (“CBA”) with American Airlines, Inc. 

pertained to infractions of an employee for specific conduct violations, as opposed to the arbitration/disciplinary 

hearing conducted by APFA against its membership. 

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request to a specific time frame, and well defined the subject-matter related, and the pertinent 

parties within APFA—this is hardly an unfettered or unlimited request. By limiting the request 

to those communications serving in the Ross Administration, it defines the scope as those 

documents and communications after April 1, 2016 to current, and those documents and 

communications discussing the Ross Administration. These documents would be discussing 

any matters related to only Robert “Bob” Ross, Eugenio Vargas, Nena Martin, and Marcy 

Dunaway. The scope and definition clearly limit the request in this manner. 

As discussed above, Plaintiff has met his burden to show how the requested documents 

are relevant and proportional. To date, Defendant failed to provide the requested documents or 

otherwise explain via specific objections how Request for Production No. 1, 2 and 3 are overly

broad, burdensome, or oppressive by submitting affidavits or offering evidence revealing the 

nature of the burden and how the requested information fails the proportionality calculation. 

Thus, Defendants should be compelled to respond and produce documents responsive to 

Request for Production No. 1, 2, and 3.

CONCLUSION

Plaintiff is entitled to a response as to Requests for Production No. 2 and 3. The 

responsive documents are both relevant and proportional. He will be prejudiced if Defendants 

documents are withheld. Specifically, the information requested in Request for Production No. 

1, 2, and 3 sought to prove Defendants’ pattern and practice of discriminatory behavior, 

specifically as it relates to the Ross Administration, to establish the causal elements of 

Plaintiff’s claims, and properly depose and potentially impeach witnesses. There are no other 

means for Plaintiff to obtain the information requested in Requests for Production No. 1, 2 and 

3 as that documentation is solely in Defendant’s possession, custody, and control. Despite 

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Plaintiff’s repeated attempts to resolve the discovery deficiency as to Requests for Production 

No. 1, 2 and 3, without Court intervention, those attempts have proven unsuccessful. Based on 

the foregoing, Plaintiff requests that this Honorable Court grant Plaintiff’s Motion to Compel 

Defendant to produce documentation responsive of Requests for Production No. 1, 2 and 3.

Respectfully submitted,

 

By: /s/ Kerri Phillips 

Kerri Phillips, Esq.

Texas Bar No. 24065906

Phone: (972) 327-5800

Email: kerri@kdphillipslaw.com

KD PHILLIPS LAW FIRM, PLLC

6010 West Spring Creek Parkway

Plano, Texas 75024

Fax: (940) 400-0089

For Service of Filings: 

notice@kdphillipslaw.com

 

ATTORNEY FOR PLAINTIFF

Local Rule 7.1(b) Conferral and Certificate of Conference

Pursuant to Local Rule 7.1(b) I hereby certify that counsel for the movant has conferred 

with Defendant in a good faith effort to resolve the issues raised herein. Plaintiff’s counsel 

conferred with Defendants’ counsel on via email on August 14, 2023, August 17, 2023, August 

18, 2023. A telephone call was held on August 23, 2023 wherein the concerns and objections 

were discuss, in particular Plaintiff offered to limit the time frame of the Requests for 

Production No. 1, 2 and 3 to overcome Defendants objections without success in appeasing 

him. Plaintiff’s further conferred with Defendants on via email on August 25, 2023, August 

26, 2023, and received a response on August 30, 2023 stating documents would be produced 

on August 31, 2023. As of the date of filing this Motion, Plaintiffs served extremely limited 

responses that were heavily redacted and no documents have been received from Woods, 

Stephens, and O’Neil. Counsel conferred on September 1, 2023 as to the relief requested in this 

instant Motion and Defendants’ counsel has replied they are opposed to the Motion. 

Date: September 5, 2023

By: /S/ Kerri Phillips 

 Kerri Phillips 

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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

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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