1 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

FORT WORTH DIVISION 

ROBERT (BOB) ROSS, § 

§ 

Plaintiff/Counterclaim Defendant, § 

§ 

v. § 

§ 

ASSOCIATION OF PROFESSIONAL § Civil Action No. 4:22-cv-00343-Y 

FLIGHT ATTENDANTS, § 

MCGAUGHEY, REBER AND § 

ASSOCIATES, INC., JULIE § 

HEDRICK, AND ERIK HARRIS, § 

§ 

Defendants/Counterclaim Plaintiff. § 

UNION DEFENDANTS’ REPORT TO THE COURT REGARDING 

THE PARTIES’ SETTLEMENT CONFERENCE 

In accordance with the Court’s Initial Scheduling Order (Doc. 77) the parties participated 

in a formal settlement conference at which the parties and their counsel appeared in person to 

discuss settlement of this case. Defendant Counterclaim Plaintiff Association of Professional 

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

Defendants”) file this written report in accordance therewith: 

(a) The date on which the settlement conference was held: 

The conference was held on March 27, 2023 in conference rooms reserved at the offices 

of Caddo Office Reimagined, 2201 Spinks Rd., Flower Mound, Texas 75022. The conference 

lasted for approximately two hours and thirty minutes. 

(b) The persons present at the conference: 

On behalf of Plaintiff Counterclaim Defendant Robert (“Bob”) Ross: 

1. Robert (“Bob”) Ross; 

2. Kerri Phillips, K.D. Phillips Law Firm, PLLC, participated as counsel for 

Robert (“Bob”) Ross. 

Case 4:22-cv-00343-Y Document 83 Filed 04/03/23 Page 1 of 4 PageID 1837
2 

On behalf of the Union Defendants: 

1. Julie Hedrick, APFA National President; 

2. Erik Harris, APFA National Treasurer; 

3. APFA participated through APFA Staff Attorney Charlette Matts, APFA 

National President Julie Hedrick and APFA National Treasurer Erik Harris, who 

each had authority to bargain in good faith on behalf of Defendant APFA; and 

4. Sanford R. Denison, Baab & Denison, LLP, participated as counsel for the 

Union Defendants. 

On behalf of Defendant McGaughey, Reber and Associates, Inc., d/b/a Diversified Credit 

Systems: 

1. McGaughey, Reber and Associates, Inc. participated through Michael 

McGaughey, its president; and 

2. Michael R Rake, Michael R. Rake, Attorney at Law, participated as counsel 

for McGaughey, Reber and Associates, Inc. 

(c) A statement regarding whether meaningful progress toward settlement was made: 

During the conference the parties and their counsel discussed various options which might 

serve as a framework within which to craft a resolution of this case as between Plaintiff and 

APFA; however ; however, despite the individual defendants’ improper joinder as parties, no 

separate proposal for their dismissal apart from APFA was received from Plaintiff 

Despite the parties’ efforts to explore different settlement alternatives, the parties remain far 

apart with respect to settlement terms which would be acceptable to all parties and, from the 

Union Defendants’ perspective, feasible as not requiring actions which violate APFA’s 

Constitution, applicable law or the rights of APFA’s other members. 

While the parties and counsel were able to engage in a constructive discussion of their 

respective positions and views as to the terms of an acceptable and feasible resolution of this 

case, the parties were not able to make meaningful progress towards a settlement. 

Case 4:22-cv-00343-Y Document 83 Filed 04/03/23 Page 2 of 4 PageID 1838
3 

(d) A statement regarding the prospects of settlement before trial. 

The Union Defendants have been and remain open to continuing to explore with Ross 

options for an agreed resolution of this case which is consistent with and does not run afoul of 

applicable law, the APFA’s Constitution or the rights of its other members. However, as of this 

date, because the parties remain far apart with respect to settlement terms which are acceptable to 

all parties and which are feasible as consistent with APFA’s obligations under law and its 

Constitution, the Union Defendants do not believe that the prospects for settlement prior to trial 

are good. 

Date: April 3, 2023 Respectfully Submitted, 

 /s/ Sanford R. Denison 

SANFORD R. DENISON 

Tex. Bar No. 05655560 

Baab & Denison, LLP 

6301 Gaston Ave., Suite 1403 

Dallas, TX 75214 

Tel.: (214) 637-0750; Fax.: (214) 637-0730 

Email: denison@baabdenison.com 

WILLIAM W. OSBORNE* 

D.C. Bar No. 912089 

Osborne Law Offices P.C. 

5335 Wisconsin Avenue N.W., Suite 440 

Washington, D.C. 20015 

Tel.: (202) 243-3200;Fax: (202) 686-2977 

Email: b.osborne@osbornelaw.com 

Counsel for Defendant Counterclaim Plaintiff 

Association of Professional Flight Attendants, and 

Defendants Julie Hedrick and Erik Harris 

*Admitted Pro Hac Vice 

Case 4:22-cv-00343-Y Document 83 Filed 04/03/23 Page 3 of 4 PageID 1839
4 

CERTIFICATE OF SERVICE 

I certify that on this 3rd day of April 2023 a true and correct copy of the foregoing 

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

Ross by a means permitted by Rule 5(b)(2) of the Federal Rules of Civil Procedure (“F.R.C.P.”). 

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/ Sanford R. Denison 

SANFORD R. DENISON 

Case 4:22-cv-00343-Y Document 83 Filed 04/03/23 Page 4 of 4 PageID 1840