Ridnour et al v. Delta Air Lines, Inc. et al

1
Caitlin Wain
From: 	Alex Speakar <aspeakar@bairdholm.com>
Sent: 	Thursday, January 8, 2026 3:27 PM
To: 	Andrew M. Ferguson; carson@ned.uscourts.gov
Cc: 	Joleen Baker; Victoria Harder; Jennifer Tricker; kirschman@Whitfieldlaw.com; Clete W. Blakeman;
Kayla Hathcote
Subject: 	RE: 8:24CV442 Wanda Ridnour and Bruce Ridnour vs. Delta Air Lines, Inc., Skywest Airlines, Inc., Unifi
Aviation, LLC, and John Doe 1-6 Discovery Dispute Conference Delta Position Statement
Attachments: 	Delta_Ridnour - Delta's RFPDS to Unifi Aviation (Sent 9.22.2025)(6864305.1).pdf; Delta_Ridnour -
Delta's ROGS to Unifi Aviation (Sent 9.22.2025)(6864304.1).pdf; RE: Ridnour v. Delta, et al - Delta's
Discovery requests to UNIFI Aviations
CAUTION - EXTERNAL:
Dear Judge Carson,
This firm serves as counsel for Delta Air Lines, Inc. in the above-referenced lawsuit. Defendant Unifi Aviation LLC never
provided any responses to Delta’s written discovery requests issued on September 22, 2025. I attach Delta’s requests
hereto for the Court’s reference.
On September 22, 2025, Delta issued its First Set of Interrogatories and Requests for the Production of Documents to
Unifi. On October 28, 2025, Delta emailed Unifi’s counsel regarding the outstanding September discovery requests. On
October 29, 2025, Unifi’s counsel promised to check on the status of the responses. Delta again sought Unifi’s responses
on November 6, 2025, and at a November 6 th deposition, for an unrelated case both counsel attended, Unifi’s counsel
responded that the discovery responses would be forthcoming as counsel was just awaiting Unifi’s signature. Again, Unifi
did not provide any responses and on November 14, 2025, Delta informed Unifi that without responses Delta would have
to take action to compel the same. Delta’s counsel followed up with a phone call to Unifi’s counsel on December 23, 2025,
in a last effort to secure Unifi’s responses. I attached the parties’ email correspondence hereto for the Court’s reference.
Despite Delta’s numerous attempts to secure Unifi’s responses, to date, Delta has not received any response from Unifi to
the September 22, 2025, discovery requests Delta issued. Delta now seeks this Court’s intervention to secure Unifi’s
discovery responses.
Thank you.
Alex M. Speakar
Baird Holm LLP
1700 Farnam Street
Suite 1500
Omaha, NE 68102-2068
www.bairdholm.com
402.636.8264 Direct Dial Phone
402.344.0588 Fax
aspeakar@bairdholm.com
To help protect you r priv acy, Microsoft Office prevented automatic download of this picture from the Internet.
	Baird Holm LLP
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 1 of 40 - Page ID #
<pageID>

2
This communication, along with any attachments, is covered by federal and state law governing electronic
communications and may contain confidential and legally privileged information. If the reader of this message is not the
intended recipient, you are hereby notified that any dissemination, distribution, use or copying of this message is strictly
prohibited. If you have received this in error, please reply immediately to the sender and delete this message. Thank you.
From: Kayla Hathcote <Kayla_Hathcote@ned.uscourts.gov>
Sent: Tuesday, January 6, 2026 2:18 PM
To: Alex Speakar <aspeakar@bairdholm.com>; Andrew M. Ferguson <aferguson@hennessyroach.com>
Cc: Joleen Baker <jbaker@bairdholm.com>; Victoria Harder <vharder@bairdholm.com>; Jennifer Tricker
<jtricker@bairdholm.com>; kirschman@Whitfieldlaw.com; Clete W. Blakeman <clete@carlsonblakeman.com>;
carson@ned.uscourts.gov
Subject: RE: 8:24CV442 Wanda Ridnour and Bruce Ridnour vs. Delta Air Lines, Inc., Skywest Airlines, Inc., Unifi Aviation,
LLC, and John Doe 1-6 Discovery Dispute Conference Request
Counsel,
The court understands there is a discovery dispute between the parties. To ensure that the matter is
addressed efficiently and fairly, the following procedures apply:
Both parties are to submit to the court by email to carson@ned.uscourts.gov, and to each other, a
concise statement (no more than three paragraphs) summarizing their respective position by noon on
Friday, January 9, 2026. Please include copies of any disputed requests. If the other defendants take no
position on the dispute, please let us know.
The parties must thereafter meet and confer (either in person or at a minimum by phone) to discuss in
good faith the particular issues as raised in the submissions. This discussion will be required regardless
of prior efforts to confer.
If a discovery dispute call with the court remains necessary after doing so, please jointly review Judge
Carson's calendar at https://www.ned.uscourts.gov/court-calendar, and note that the 1:30-2:30 p.m.
hour is generally reserved for criminal hearings. The parties should then email chambers to confirm that
they have conferred as instructed and propose two or more mutually agreeable dates and times. The
court will select one of the proposed dates and set the hearing, which will be recorded.
Please see the following General Order No. 2025-04 regarding the storage, management, and access to
restricted and sealed documents on CM/ECF, as the court’s procedures have recently changed.
Materials submitted prior to the hearing and the audio recording of the hearing will be uploaded to the
public docket unless there is a request for restriction.
Thank you,
Kayla N. Hathcote
Law Clerk to U.S. Magistrate Judge Ryan C. Carson
U.S. District Court for the District of Nebraska
Kayla_Hathcote@ned.uscourts.gov
Telephone: (402) 661-7343
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 2 of 40 - Page ID #
<pageID>

3
From: Alex Speakar <aspeakar@bairdholm.com>
Sent: Monday, January 5, 2026 2:36 PM
To: Kayla Hathcote <Kayla_Hathcote@ned.uscourts.gov>; Andrew M. Ferguson <aferguson@hennessyroach.com>
Cc: Joleen Baker <jbaker@bairdholm.com>; Victoria Harder <vharder@bairdholm.com>; Jennifer Tricker
<jtricker@bairdholm.com>; kirschman@Whitfieldlaw.com; Clete W. Blakeman <clete@carlsonblakeman.com>;
carson@ned.uscourts.gov
Subject: Wanda Ridnour and Bruce Ridnour vs. Delta Air Lines, Inc., Skywest Airlines, Inc., Unifi Aviation, LLC, and John
Doe 1-6 8:24CV442 Discovery Dispute Conference Request
CAUTION - EXTERNAL:
Dear Judge Carson and Ms. Hathcote,
This firm serves as counsel for Delta Air Lines, Inc. in the above-referenced lawsuit. We write to request a discovery
conference with the Court regarding Defendant Unifi Aviation LLC’s total failure to respond to Delta’s written discovery
requests.
Pursuant to the June 24, 2025, Progression Order entered for this matter, no party may file a Motion to Compel without
first contacting chambers to set a discovery conference to discuss the parties’ dispute. On September 22, 2025, Delta
issued its First Set of Interrogatories and Requests for the Production of Documents to Unifi. Since that time Delta has
continued to follow up with counsel for Unifi via email, in person conversations, and phone calls to secure Unifi’s
responses. Despite Delta’s numerous attempts to secure Unifi’s responses, to date, Delta has not received any response
from Unifi to the September 22, 2025, discovery requests Delta issued.
Because Delta’s previous efforts to secure the responses were ultimately unsuccessful, we now seek this Court’s
intervention to secure Unifi’s responses to the outstanding discovery without objection before proceeding in filing any
Motion to Compel.
We request the Court schedule a conference to address the dispute and Unifi’s failure to provide discovery responses
and, if necessary, grant Delta leave to file a Motion to Compel said responses.
Thank you for your attention to this matter.
Best,
Alex M. Speakar
Baird Holm LLP
1700 Farnam Street
Suite 1500
Omaha, NE 68102-2068
www.bairdholm.com
402.636.8264 Direct Dial Phone
402.344.0588 Fax
aspeakar@bairdholm.com
To help protect you r priv acy, Microsoft Office prevented automatic download of this picture from the Internet.
	Baird Holm LLP
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 3 of 40 - Page ID #
<pageID>

4
This communication, along with any attachments, is covered by federal and state law governing electronic
communications and may contain confidential and legally privileged information. If the reader of this message is not the
intended recipient, you are hereby notified that any dissemination, distribution, use or copying of this message is strictly
prohibited. If you have received this in error, please reply immediately to the sender and delete this message. Thank you.
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening
attachments or clicking on links.
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening
attachments or clicking on links.
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 4 of 40 - Page ID #
<pageID>

From: 	Andrew M. Ferguson
To: 	Caitlin Wain; Alex Speakar; carson@ned.uscourts.gov
Cc: 	Joleen Baker; Victoria Harder; Jennifer Tricker; kirschman@Whitfieldlaw.com; Clete W. Blakeman; Kayla Hathcote; Lauren L. Meyer
Subject: 	RE: 8:24CV442 Wanda Ridnour and Bruce Ridnour vs. Delta Air Lines, Inc., Skywest Airlines, Inc., Unifi Aviation, LLC, and John Doe
1-6 Discovery Dispute Conference Delta Position Statement
Date: 	Friday, January 9, 2026 8:44:11 AM
CAUTION - EXTERNAL:
Judge Carson,
This office represents UniFi Aviation, LLC in regard to the above matter. Unfortunately, I
am only in a position to concur with Ms. Speakar’s recitation of events as they pertain to
her timeline regarding discovery. I also, again unfortunately, concur that she and I have
discussed this issue on several occasions without reaching a resolution.
I spoke with UniFi yesterday, January 8, 2026. It is my understanding that I will have
responses (verified Answers to Interrogatories and Responses to Requests for Production of
Documents) to Deltas discovery requests today. They will be filed as soon as I receive
them.
Ms. Speakar have conferred and are planning to speak on Monday or Tuesday (a time has
not yet been finalized) to discuss any issues raised in what I will submit. Thank you.
Andy Ferguson
Andrew M. Ferguson
Hennessy & Roach, P.C.
14301 FNB Pkwy., Ste. 111, Omaha, NE 68154
Direct 402.933.0952
Office 402.933.8851
aferguson@hennessyroach.com
From: Caitlin Wain <Caitlin_Wain@ned.uscourts.gov>
Sent: Thursday, January 8, 2026 4:27 PM
To: Alex Speakar <aspeakar@bairdholm.com>; Andrew M. Ferguson <aferguson@hennessyroach.com>;
carson@ned.uscourts.gov
Cc: Joleen Baker <jbaker@bairdholm.com>; Victoria Harder <vharder@bairdholm.com>; Jennifer Tricker
<jtricker@bairdholm.com>; kirschman@Whitfieldlaw.com; Clete W. Blakeman <clete@carlsonblakeman.com>;
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 5 of 40 - Page ID #
<pageID>

Kayla Hathcote <Kayla_Hathcote@ned.uscourts.gov>
Subject: RE: 8:24CV442 Wanda Ridnour and Bruce Ridnour vs. Delta Air Lines, Inc., Skywest Airlines, Inc., Unifi
Aviation, LLC, and John Doe 1-6 Discovery Dispute Conference Delta Position Statement
Received by Judge Carson’s chambers. Thank you,
Caitlin E. Wain
Law Clerk to United States Magistrate Judge Ryan C. Carson
U.S. District Court for the District of Nebraska
caitlin_wain@ned.uscourts.gov
Telephone: (402) 661-7342
From: Alex Speakar <aspeakar@bairdholm.com>
Sent: Thursday, January 8, 2026 3:27 PM
To: Andrew M. Ferguson <aferguson@hennessyroach.com>; carson@ned.uscourts.gov
Cc: Joleen Baker <jbaker@bairdholm.com>; Victoria Harder <vharder@bairdholm.com>; Jennifer Tricker
<jtricker@bairdholm.com>; kirschman@Whitfieldlaw.com; Clete W. Blakeman <clete@carlsonblakeman.com>;
Kayla Hathcote <Kayla_Hathcote@ned.uscourts.gov>
Subject: RE: 8:24CV442 Wanda Ridnour and Bruce Ridnour vs. Delta Air Lines, Inc., Skywest Airlines, Inc., Unifi
Aviation, LLC, and John Doe 1-6 Discovery Dispute Conference Delta Position Statement
CAUTION - EXTERNAL:
Dear Judge Carson,
This firm serves as counsel for Delta Air Lines, Inc. in the above-referenced lawsuit. Defendant Unifi Aviation LLC never
provided any responses to Delta’s written discovery requests issued on September 22, 2025. I attach Delta’s requests
hereto for the Court’s reference.
On September 22, 2025, Delta issued its First Set of Interrogatories and Requests for the Production of Documents to
Unifi. On October 28, 2025, Delta emailed Unifi’s counsel regarding the outstanding September discovery requests. On
October 29, 2025, Unifi’s counsel promised to check on the status of the responses. Delta again sought Unifi’s responses
on November 6, 2025, and at a November 6 th deposition, for an unrelated case both counsel attended, Unifi’s counsel
responded that the discovery responses would be forthcoming as counsel was just awaiting Unifi’s signature. Again, Unifi
did not provide any responses and on November 14, 2025, Delta informed Unifi that without responses Delta would have
to take action to compel the same. Delta’s counsel followed up with a phone call to Unifi’s counsel on December 23,
2025, in a last effort to secure Unifi’s responses. I attached the parties’ email correspondence hereto for the Court’s
reference.
Despite Delta’s numerous attempts to secure Unifi’s responses, to date, Delta has not received any response from Unifi
to the September 22, 2025, discovery requests Delta issued. Delta now seeks this Court’s intervention to secure Unifi’s
discovery responses.
Thank you.
Alex M. Speakar
Baird Holm LLP
1700 Farnam Street
Suite 1500
Omaha, NE 68102-2068
www.bairdholm.com
402.636.8264 Direct Dial Phone
402.344.0588 Fax
aspeakar@bairdholm.com
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 6 of 40 - Page ID #
<pageID>

Baird Holm LLP
This communication, along with any attachments, is covered by federal and state law governing electronic communications
and may contain confidential and legally privileged information. If the reader of this message is not the intended recipient,
you are hereby notified that any dissemination, distribution, use or copying of this message is strictly prohibited. If you
have received this in error, please reply immediately to the sender and delete this message. Thank you.
From: Kayla Hathcote <Kayla_Hathcote@ned.uscourts.gov>
Sent: Tuesday, January 6, 2026 2:18 PM
To: Alex Speakar <aspeakar@bairdholm.com>; Andrew M. Ferguson <aferguson@hennessyroach.com>
Cc: Joleen Baker <jbaker@bairdholm.com>; Victoria Harder <vharder@bairdholm.com>; Jennifer Tricker
<jtricker@bairdholm.com>; kirschman@Whitfieldlaw.com; Clete W. Blakeman <clete@carlsonblakeman.com>;
carson@ned.uscourts.gov
Subject: RE: 8:24CV442 Wanda Ridnour and Bruce Ridnour vs. Delta Air Lines, Inc., Skywest Airlines, Inc., Unifi
Aviation, LLC, and John Doe 1-6 Discovery Dispute Conference Request
Counsel,
The court understands there is a discovery dispute between the parties. To ensure that the matter is
addressed efficiently and fairly, the following procedures apply:
Both parties are to submit to the court by email to carson@ned.uscourts.gov, and to each other, a
concise statement (no more than three paragraphs) summarizing their respective position by noon on
Friday, January 9, 2026. Please include copies of any disputed requests. If the other defendants take no
position on the dispute, please let us know.
The parties must thereafter meet and confer (either in person or at a minimum by phone) to discuss in
good faith the particular issues as raised in the submissions. This discussion will be required regardless
of prior efforts to confer.
If a discovery dispute call with the court remains necessary after doing so, please jointly review Judge
Carson's calendar at https://www.ned.uscourts.gov/court-calendar, and note that the 1:30-2:30 p.m.
hour is generally reserved for criminal hearings. The parties should then email chambers to confirm that
they have conferred as instructed and propose two or more mutually agreeable dates and times. The
court will select one of the proposed dates and set the hearing, which will be recorded.
Please see the following General Order No. 2025-04 regarding the storage, management, and access to
restricted and sealed documents on CM/ECF, as the court’s procedures have recently changed.
Materials submitted prior to the hearing and the audio recording of the hearing will be uploaded to the
public docket unless there is a request for restriction.
Thank you,
Kayla N. Hathcote
Law Clerk to U.S. Magistrate Judge Ryan C. Carson
U.S. District Court for the District of Nebraska
Kayla_Hathcote@ned.uscourts.gov
Telephone: (402) 661-7343
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 7 of 40 - Page ID #
<pageID>

From: Alex Speakar <aspeakar@bairdholm.com>
Sent: Monday, January 5, 2026 2:36 PM
To: Kayla Hathcote <Kayla_Hathcote@ned.uscourts.gov>; Andrew M. Ferguson <aferguson@hennessyroach.com>
Cc: Joleen Baker <jbaker@bairdholm.com>; Victoria Harder <vharder@bairdholm.com>; Jennifer Tricker
<jtricker@bairdholm.com>; kirschman@Whitfieldlaw.com; Clete W. Blakeman <clete@carlsonblakeman.com>;
carson@ned.uscourts.gov
Subject: Wanda Ridnour and Bruce Ridnour vs. Delta Air Lines, Inc., Skywest Airlines, Inc., Unifi Aviation, LLC, and
John Doe 1-6 8:24CV442 Discovery Dispute Conference Request
CAUTION - EXTERNAL:
Dear Judge Carson and Ms. Hathcote,
This firm serves as counsel for Delta Air Lines, Inc. in the above-referenced lawsuit. We write to request a discovery
conference with the Court regarding Defendant Unifi Aviation LLC’s total failure to respond to Delta’s written discovery
requests.
Pursuant to the June 24, 2025, Progression Order entered for this matter, no party may file a Motion to Compel without
first contacting chambers to set a discovery conference to discuss the parties’ dispute. On September 22, 2025, Delta
issued its First Set of Interrogatories and Requests for the Production of Documents to Unifi. Since that time Delta has
continued to follow up with counsel for Unifi via email, in person conversations, and phone calls to secure Unifi’s
responses. Despite Delta’s numerous attempts to secure Unifi’s responses, to date, Delta has not received any response
from Unifi to the September 22, 2025, discovery requests Delta issued.
Because Delta’s previous efforts to secure the responses were ultimately unsuccessful, we now seek this Court’s
intervention to secure Unifi’s responses to the outstanding discovery without objection before proceeding in filing any
Motion to Compel.
We request the Court schedule a conference to address the dispute and Unifi’s failure to provide discovery responses
and, if necessary, grant Delta leave to file a Motion to Compel said responses.
Thank you for your attention to this matter.
Best,
Alex M. Speakar
Baird Holm LLP
1700 Farnam Street
Suite 1500
Omaha, NE 68102-2068
www.bairdholm.com
402.636.8264 Direct Dial Phone
402.344.0588 Fax
aspeakar@bairdholm.com
Baird Holm LLP
This communication, along with any attachments, is covered by federal and state law governing electronic communications
and may contain confidential and legally privileged information. If the reader of this message is not the intended recipient,
you are hereby notified that any dissemination, distribution, use or copying of this message is strictly prohibited. If you
have received this in error, please reply immediately to the sender and delete this message. Thank you.
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 8 of 40 - Page ID #
<pageID>

CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening
attachments or clicking on links.
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening
attachments or clicking on links.
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening
attachments or clicking on links.
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 9 of 40 - Page ID #
<pageID>

From: 	Alex Speakar
To: 	Andrew M. Ferguson
Cc: 	Lauren L. Meyer; Victoria Harder
Subject: 	RE: Ridnour v. Delta, et al - Delta"s Discovery requests to UNIFI Aviations
Date: 	Thursday, January 8, 2026 4:28:48 PM
Attachments: 	image001.jpg
image002.jpg
Hi Andy-
Following up again on Unifi’s responses and our conversation last week. We would certainly prefer not to file a Motion to
Compel, but the responses have been outstanding since September, and we need to move forward.
If we don’t receive the responses in the next week will have to move forward with a Motion.
Thank you.
Alex M. Speakar
Baird Holm LLP
1700 Farnam Street
Suite 1500
Omaha, NE 68102-2068
www.bairdholm.com
402.636.8264 Direct Dial Phone
402.344.0588 Fax
aspeakar@bairdholm.com
Baird Holm LLP
This communication, along with any attachments, is covered by federal and state law governing electronic communications
and may contain confidential and legally privileged information. If the reader of this message is not the intended recipient,
you are hereby notified that any dissemination, distribution, use or copying of this message is strictly prohibited. If you have
received this in error, please reply immediately to the sender and delete this message. Thank you.
From: Alex Speakar
Sent: Thursday, November 6, 2025 7:24 AM
To: Andrew M. Ferguson <aferguson@hennessyroach.com>
Cc: Lauren L. Meyer <lmeyer@hennessyroach.com>
Subject: RE: Ridnour v. Delta, et al - Delta's Discovery requests to UNIFI Aviations
Andy-
Any update on Unifi’s discovery responses?
Thanks.
Alex M. Speakar
Baird Holm LLP
1700 Farnam Street
Suite 1500
Omaha, NE 68102-2068
www.bairdholm.com
402.636.8264 Direct Dial Phone
402.344.0588 Fax
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 10 of 40 - Page ID #
<pageID>

aspeakar@bairdholm.com
Baird Holm LLP
This communication, along with any attachments, is covered by federal and state law governing electronic communications
and may contain confidential and legally privileged information. If the reader of this message is not the intended recipient,
you are hereby notified that any dissemination, distribution, use or copying of this message is strictly prohibited. If you have
received this in error, please reply immediately to the sender and delete this message. Thank you.
From: Andrew M. Ferguson <aferguson@hennessyroach.com>
Sent: Wednesday, October 29, 2025 8:25 AM
To: Alex Speakar <aspeakar@bairdholm.com>
Cc: Lauren L. Meyer <lmeyer@hennessyroach.com>
Subject: RE: Ridnour v. Delta, et al - Delta's Discovery requests to UNIFI Aviations
Alex, I will check on the status today and let you know. Thanks. Andy Andrew M. Ferguson Hennessy & Roach, P.C. 14301 FNB Pkwy., Ste. 111, Omaha, NE 68154 Direct 402.933.0952 Office 402.933.8851 aferguson@hennessyroach.com From: Alex Speakar <aspeakar@bairdholm.com>
CGBANNERINDICATOR
Alex,
I will check on the status today and let you know. Thanks.
Andy
Andrew M. Ferguson
Hennessy & Roach, P.C.
14301 FNB Pkwy., Ste. 111, Omaha, NE 68154
Direct 402.933.0952
Office 402.933.8851
aferguson@hennessyroach.com
Hennessy & Roach, P.C.
From: Alex Speakar <aspeakar@bairdholm.com>
Sent: Tuesday, October 28, 2025 2:22 PM
To: Andrew M. Ferguson <aferguson@hennessyroach.com>
Cc: Victoria Harder <vharder@bairdholm.com>; Joleen Baker <jbaker@bairdholm.com>; Jennifer Tricker
<jtricker@bairdholm.com>; Lauren L. Meyer <lmeyer@hennessyroach.com>
Subject: RE: Ridnour v. Delta, et al - Delta's Discovery requests to UNIFI Aviations
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 11 of 40 - Page ID #
<pageID>

Andy-
When can we expect to receive Unifi’s responses to Delta’s discovery requests sent September 22 nd ?
Best,
Alex M. Speakar
Baird Holm LLP
1700 Farnam Street
Suite 1500
Omaha, NE 68102-2068
www.bairdholm.com
402.636.8264 Direct Dial Phone
402.344.0588 Fax
aspeakar@bairdholm.com
Image removed by sender. Baird Holm LLP
This communication, along with any attachments, is covered by federal and state law governing electronic communications
and may contain confidential and legally privileged information. If the reader of this message is not the intended recipient,
you are hereby notified that any dissemination, distribution, use or copying of this message is strictly prohibited. If you have
received this in error, please reply immediately to the sender and delete this message. Thank you.
From: Joleen Baker <jbaker@bairdholm.com>
Sent: Monday, September 22, 2025 2:19 PM
To: Andrew M. Ferguson <aferguson@hennessyroach.com>
Cc: andrea@carlsonblakeman.com; clete@carlsonblakeman.com; kirschman@whitfiledlaw.com; Jennifer Tricker
<jtricker@bairdholm.com>; Alex Speakar <aspeakar@bairdholm.com>; Victoria Harder <vharder@bairdholm.com>;
Paula Gloe <pgloe@bairdholm.com>
Subject: Ridnour v. Delta, et al - Delta's Discovery requests to UNIFI Aviations
Counsel,
Attached please find Defendant Delta Air Lines, Inc.’s Interrogatories and Requests for Production of Documents to UNIFI
Aviations LLC in the above-referenced matter, We have included the word versions for you as a courtesy and a notice of
service will be filed today, Should you have any questions, comments or concerns, contact Jennifer Tricker or Alexandra
Speakar.
Joleen M. Baker
Legal Assistant
Baird Holm LLP
1700 Farnam Street
Suite 1500
Omaha, NE 68102-2068
www.bairdholm.com
402.231.8569 Direct Dial Phone
402.344.0588 Fax
jbaker@bairdholm.com
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 12 of 40 - Page ID #
<pageID>

Image removed by sender. Baird Holm LLP
This communication, along with any attachments, is covered by federal and state law governing electronic communications
and may contain confidential and legally privileged information. If the reader of this message is not the intended recipient,
you are hereby notified that any dissemination, distribution, use or copying of this message is strictly prohibited. If you have
received this in error, please reply immediately to the sender and delete this message. Thank you.
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 13 of 40 - Page ID #
<pageID>

6820119.1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEBRASKA
WANDA RIDNOUR & BRUCE RIDNOUR,
Husband and Wife,
Plaintiffs,
v.
DELTA AIR LINES, INC., SKYWEST
AIRLINES, INC., UNIFI AVIATIONS, LLC
f/k/a DAL GLOBAL SERVICES, LLC, &
JOHN DOE, individual and entity 1 – 6,
Defendants.
Case No. 8:24-cv-00442
DELTA AIR LINES, INC. FIRST SET OF
INTERROGATORIES TO DEFENDANT
UNIFI AVIATIONS, LLC f/k/a DAL
GLOBAL SERVICES, LLC
TO: Defendant, UNIFI AVIATIONS, LLC f/k/a DAL GLOBAL SERVICES, LLC (“Unifi”)
through their attorneys of record Andrew M. Ferguson of Hennessy Roach Law Firm.
The following Interrogatories must be answered separately, in writing and under oath,
within thirty (30) days of the date of service, pursuant to Rule 33 of the Federal Rules of Discovery.
Answers to these Interrogatories shall contain your complete knowledge, including that which is
available to you personally or through your agents or attorney.
These Interrogatories shall be deemed continuing, and should you or your agents discover
any additional information as to the matters into which these Interrogatories inquire between the
time Answers are made and the time of trial that require supplementation of these Answers
pursuant to Rule 33 of the Federal Rules of Civil Procedure, supplemental or amended Answers
should be served, advising the attorneys for Defendant Delta Airlines, Inc. (“Delta”) of the newly
discovered information as far in advance of trial as possible.
If, in response to any of the Interrogatories below, you object in lieu of an answer, please
state with specificity your reasons for the objection, including the legal or factual grounds upon
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 14 of 40 - Page ID #
<pageID>

6820119.1
which the objection is based. If you have objected on the ground of privilege, please specify the
privilege claimed and produce a privilege log.
INTERROGATORIES
INTERROGATORY NO. 1: 	If you or any one acting on Unifi’s behalf, including
your employees, agents, and representatives, has ever taken or received any verbal, written, or
otherwise recorded statement from any person relating to the November 16, 2023, incident
referenced in ¶¶ 17 – 37 of the Amended Complaint (the “Incident”) and/or any claims or defenses
raised by any party to this case, please describe each statement, which includes describing who
made the statement, who took and/or was present for the statement, the date and place of the
statement, and the contents of the statement. For all information upon which you claim privilege,
please provide the information required at Fed.R.Civ.Pro. 26(b)(5).
ANSWER:
INTERROGATORY NO. 2: 	List every individual of whom you are aware who
has any information or knowledge with respect to any of the allegations made in Plaintiffs’
Amended Complaint, whether or not you intend to call such person at the trial of this matter. Please
include each person's name, phone number, and a description of the information or knowledge you
believe s/he has.
ANSWER:
INTERROGATORY NO. 3: 	State the names and addresses of the persons from
whom you, anyone on your behalf or any other person of whom you are aware, has taken written
or mechanically recorded statements or reports, concerning or in any manner relating to this
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 15 of 40 - Page ID #
<pageID>

6820119.1
lawsuit, and the name and address of the person or persons presently having custody of such
statements or reports.
ANSWER:
INTERROGATORY NO. 4: 	State the name and address of any persons who
witnessed, are reported to have witnessed, or who were in any way involved in the Incident or the
events leading up to it and describe with particularity your understanding of what the person or
persons witnessed at the time of the Incident.
ANSWER:
INTERROGATORY NO. 5: 	Identify 	by 	name 	and 	phone 	number 	all 	Unifi
employees/contractors scheduled to work or who worked Flight No. 3963 which arrived in Omaha
on November 16, 2023, carrying Plaintiffs, including those who assisted with and witnessed the
Incident and describing with particularity the role, job duties, and involvement in the Incident for
each identified individual, including, all those individuals identified in Unifi’s Rule 26(a)
disclosures.
ANSWER:
INTERROGATORY NO. 6: 	If you claim that any other party or non-party caused
or contributed to the cause of the damages alleged in this case, please describe in detail the facts
you believe support your claim for each such person or entity.
ANSWER:
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 16 of 40 - Page ID #
<pageID>

6820119.1
INTERROGATORY NO. 7: 	If you contend any party to this litigation and/or such
party’s employee, agent, or representative made an admission or statement against interest
(whether verbal or written, formal or informal, and to you or to someone else), please describe
each admission or statement against interest, including the speaker, to whom the speaker made the
admission/statement, when and where the admission/statement was made, any witnesses to the
admission/statement, and what was said.
ANSWER:
INTERROGATORY NO. 8: 	State whether you had any communication, including
writings or oral conversation, with any agent or representative of any of the other parties or with
Plaintiffs relating to the Incident and/or the injuries allegedly sustained, and if so, please state the
contents of the communication or conversation and the statements, if any, that were made.
ANSWER:
INTERROGATORY NO. 9: 	Describe the actions Unifi took, by and through its
employees, 	agents, 	and/or 	representatives, 	in 	responding 	to 	the 	Incident 	including 	how
employees/contractors 	assisted 	the 	Plaintiffs’ 	in 	deplaning, 	if 	and 	how 	it 	contacted
medical/emergency services, and any subsequent investigation or inspection pertaining to the
Incident.
ANSWER:
INTERROGATORY NO. 10: 	State 	with 	particularity 	all 	accommodations,
requests, assistance, medical conditions, any physical limitations, and any other correspondence
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 17 of 40 - Page ID #
<pageID>

6820119.1
or communication from or between Plaintiffs and Unifi regarding boarding and traveling on the
date of the Incident.
ANSWER:
INTERROGATORY NO. 11: 	Set forth the name and last known address of all
persons who have made any inspections or investigations of any matter pertaining to Plaintiffs’
claims and the Incident setting forth the nature of the investigation or inspection made, and the
date of any such inspection or investigation.
ANSWER:
DATED this 22 nd day of September, 2025.
DELTA AIR LINES, INC., DEFENDANT,
By: 	/s/ Alexandra M. Speakar
Jennifer D. Tricker, 23022
Alexandra M. Speakar, 27937
of 	BAIRD HOLM LLP
1700 Farnam Street, Suite 1500
Omaha, NE 68102-2068
Phone: 402-344-0500
jtricker@bairdholm.com
aspeakar@bairdholm.com
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 18 of 40 - Page ID #
<pageID>

6820119.1
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on the 22nd day of September, 2025, the foregoing,
Delta Airlines Inc.’s First Set of Interrogatories to Defendant Unifi Aviation, LLC, were served
upon all counsel of record via electronic mail to the following:
Andrea A. Klinetobe
Cletus W. Blakeman
Carlson, Blakeman Law Firm
2002 Douglas Street
Omaha, NE 68102
andrea@carlsonblakeman.com
clete@carlsonblakeman.com
Attorneys for Plaintiffs
Richard J. Kirschman
Whitfield, Eddy Law Firm
699 Walnut Street, Ste. 2000
Des Moines, IA 50309
kirschman@whitfiledlaw.com
Attorney for SkyWest Airlines, Inc.
Andrew M. Ferguson
Hennessy Roach Law Firm
14301 FNB Parkway, Ste. 308
Omaha, NE 68154
aferguson@hennessyroach.com
Attorney for Unifi Aviation, LLC
f/k/a DAL Global Services, LLC
/s/ Alexandra M. Speakar
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 19 of 40 - Page ID #
<pageID>

6820119.1
VERIFICATION
I, 	, declare under penalty of perjury under the laws of
the United States of America that I have read the foregoing answers to Defendant Delta Airlines
Inc.’s First Set of Interrogatories to UNIFI Aviations, LLC f/k/a DAL Global Services LLC. and
that the answers are true and correct to the best of my knowledge, information, and belief.
Executed on this ___ day of _________, 2025.
UNIFI AVIATIONS, LLC f/k/a DAL
GLOBAL SERVICES, LLC,
DEFENDANT,
___________________________
NAME
____________________________
DATE
___________________________
SIGNATURE
___________________________
TITLE
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 20 of 40 - Page ID #
<pageID>

6820121.1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEBRASKA
WANDA RIDNOUR & BRUCE RIDNOUR,
Husband and Wife,
Plaintiffs,
v.
DELTA AIR LINES, INC., SKYWEST
AIRLINES, INC., UNIFI AVIATIONS, LLC
f/k/a DAL GLOBAL SERVICES, LLC, &
JOHN DOE, individual and entity 1 – 6,
Defendants.
Case No. 8:24-cv-00442
DELTA AIR LINES, INC. FIRST SET OF
REQUESTS FOR PRODUCTION OF
DOCUMENTS TO DEFENDANT UNIFI
AVIATION, LLC f/k/a DAL GLOBAL
SERVICES, LLC
TO: 	Defendant, UNIFI AVIATION, LLC f/k/a DAL GLOBAL SERVICES, LLC, (“Unifi”)
through their attorneys of record Andrew M. Ferguson of Hennessy Roach Law Firm.
Pursuant to Rule 34 of the Federal Rules of Civil Procedure please respond to the following
requests for production of documents and produce the requested documents to the undersigned
attorneys for Delta Air Lines, Inc. (“Delta”) within thirty (30) days from the date of service. These
requests are continuing in nature and require supplementary production of any and all documents
falling within the scope of the request that may come into your custody, control, or possession
subsequent to your responses hereto.
If, in response to any of the Request for Production of Documents below, you object in lieu
of an answer, please state with specificity your reasons for the objection, including the legal or
factual grounds upon which the objection is based. If you have objected on the ground of privilege,
please specify the privilege claimed and produce a privilege log.
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 21 of 40 - Page ID #
<pageID>

6820121.1
REQUEST FOR PRODUCTION OF DOCUMENTS
REQUEST NO. 1: 	With respect to your expert witnesses, please provide:
1. 	a complete statement of all opinions your expert witnesses will express and the
basis and reasons for them;
2. 	the facts or data considered by the witnesses in forming them;
3. 	any exhibits that will be used to summarized or support the expert opinions;
4. 	the witnesses’ qualifications, including a list of all publications authored in the
previous 10 years;
5. 	a list of all other cases in which, during the previous 4 years, the witnesses have
testified as an expert at trial or by deposition; and
6. 	a statement of the compensation to be paid for the study and testimony in the
case.
RESPONSE:
REQUEST NO. 2: 	Provide information related to the compensation your experts will
or has charged you for their study or testimony.
RESPONSE:
REQUEST NO. 3: 	Documents and correspondence reflecting all facts or data that your
attorney provided and that your experts considered in forming their opinions to be expressed.
RESPONSE:
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 22 of 40 - Page ID #
<pageID>

6820121.1
REQUEST NO. 4: 	Documents and correspondence reflecting assumptions that your
attorney provided and your experts relied on in forming the opinions to be expressed.
RESPONSE:
REQUEST NO. 5: 	All documents identified, referred to, or relied upon in your answers
to Delta’s Interrogatories.
RESPONSE:
REQUEST NO. 6: 	Provide a copy of each exhibit, piece of evidence, and demonstrative
you expect to offer or otherwise use at the trial of this case.
RESPONSE:
REQUEST NO. 7: 	All photographs, videos, or other visual depictions of the November
16, 2023 – November 17, 2023, incident (“the Incident”), as described in ¶¶ 17-37 in Plaintiffs’
Amended Complaint.
RESPONSE:
REQUEST NO. 8: 	Provide any diagram, chart, drawing, and/or sketch relating to the
scene of the Incident, the people and/or vehicles involved in the Incident, and/or any damage
resulting from the Incident.
RESPONSE:
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 23 of 40 - Page ID #
<pageID>

6820121.1
REQUEST NO. 9: 	All photographs, videos, or other visual depictions and documents
regarding the flight to Omaha, NE on November 16, 2023, or the Incident.
RESPONSE:
REQUEST NO. 10: 	Provide copies of and/or documents that reflect any statement from
any person relating to the Incident and/or any claims or defenses raised by any party to this case.
RESPONSE:
REQUEST NO. 11: 	Provide 	all 	documents 	and 	correspondence 	relating 	to 	any
admission(s) and/or statement(s) against interest that you alleged Plaintiffs’ by and through any of
its employees, agents, or representatives, has made regarding the Incident and/or any claim or
defense raised by any party in the above-captioned case.
RESPONSE:
REQUEST NO. 12: 	All 	reports, 	documents, 	and 	correspondence 	relating 	to 	each
inspection and investigation of any event, condition, or issue relating to Incident, whether prepared
by you or on your behalf or by another investigative entity, including, but not limited to, law
enforcement reports, EMS or other first responder reports, insurance investigative summaries,
and/or private investigator reports.
RESPONSE:
REQUEST NO. 13: 	All communications between you and any third party regarding the
Incident, including but not limited to emails, text messages, and social media messages. For all
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 24 of 40 - Page ID #
<pageID>

6820121.1
information upon which you claim privilege, please provide the information required at
Fed.R.Civ.Pro. 26(b)(5).
RESPONSE:
REQUEST NO. 14: 	All documents and correspondence that reflect those actions you
took, by and through your employees, agents, and/or representatives, following the Incident in
response to or as a result of Incident.
RESPONSE:
REQUEST NO. 15: 	All documents and/or communications provided to or received from
any governmental agency in connection with the Incident.
RESPONSE:
REQUEST NO. 16: 	Provide 	all 	documentation, 	records, 	and 	communications
evidencing complaints or reports made to Unifi, your employees, or affiliates regarding the flight
involved in the Incident, Flight No. 3963, on November 16, 2023.
RESPONSE:
REQUEST NO. 17: 	Provide 	all 	documentation, 	records, 	and 	communications
evidencing complaints or reports made to Unifi from Plaintiffs.
RESPONSE:
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 25 of 40 - Page ID #
<pageID>

6820121.1
REQUEST NO. 18: 	All documents and/or communications reflecting any statements
made by witnesses regarding the Incident.
RESPONSE:
REQUEST NO. 19: 	All documents and/or communications reflecting any statements
made by any person relating to the Incident and/or any claims or defenses raised by any party to
this case.
RESPONSE:
REQUEST NO. 20: 	All documents and/or communications sent to or received from any
other party to this litigation related to the Incident.
RESPONSE:
REQUEST NO. 21: 	All documents and correspondence you have sent, obtained or
otherwise received as the result of a subpoena, a records authorization, FOIA, and/or other records
request (whether formally served or informally submitted) to any third-party regarding the Incident
and this lawsuit.
RESPONSE:
REQUEST NO. 22: 	Provide 	the 	documents 	and 	correspondence 	evidencing 	the
employees/contractors scheduled to work Flight No. 3963 which arrived in Omaha on November
16, 2023.
RESPONSE:
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 26 of 40 - Page ID #
<pageID>

6820121.1
REQUEST NO. 23: 	Provide all documents and agreements between SkyWest, Unifi,
and/or Delta regarding the scope of the parties’ relationship in coordinating and staffing flights
like Flight No. 3963.
RESPONSE:
REQUEST NO. 24: 	Provide a copy of any and all insurance policies which may be
responsible to pay, in part or in whole, the damages in this case.
RESPONSE:
REQUEST NO. 25: 	Provide all documentation and correspondence evidencing the
physical condition of the Plaintiffs prior to the Incident and after.
RESPONSE:
REQUEST NO. 26: 	Provide the policies, agreements, and procedures governing
the training, education, and operation of Unifi staff including documentation evidencing training
of in-flight staff and ground crew in responding to flight issues such as the Incident. This includes
how staff are instructed regarding in-flight or boarding or disembarking the plane emergencies, as
well as how staff should assist passengers who are unable to board or disembark the plane without
assistance.
RESPONSE:
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 27 of 40 - Page ID #
<pageID>

6820121.1
REQUEST NO. 27: 	Provide the policies, agreements, and procedures governing when
staff can and should decline to allow a passenger to board the plane.
RESPONSE:
REQUEST NO. 28: 	Provide the policies, agreements, and procedures governing the
training, education, and operation of Unifi staff in boarding and deplaning flights in place at the
time of the Incident.
RESPONSE:
REQUEST NO. 29: 	Provide 	documentation 	and 	correspondence 	regarding 	all
accommodations, requests, assistance, medical conditions, any physical limitations, and any other
correspondence or communication from Plaintiffs’, SkyWest, or Unifi regarding Plaintiffs’ travel
on Flight No. 3963 on November 16, 2023.
RESPONSE:
REQUEST NO. 30: 	Please provide a copy of all discovery you provided to any other
party in this lawsuit.
RESPONSE:
REQUEST NO. 31: 	Please provide a copy of all documents referenced in your Rule
26(a) Initial Disclosures.
RESPONSE:
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 28 of 40 - Page ID #
<pageID>

6820121.1
DATED this 22 nd day of September, 2025.
DELTA AIR LINES, INC., DEFENDANT,
By: 	/s/ Alexandra M. Speakar
Jennifer D. Tricker, 23022
Alexandra M. Speakar, 27937
of 	BAIRD HOLM LLP
1700 Farnam Street, Suite 1500
Omaha, NE 68102-2068
Phone: 402-344-0500
jtricker@bairdholm.com
aspeakar@bairdholm.com
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 29 of 40 - Page ID #
<pageID>

6820121.1
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on the 22nd day of September, 2025, the foregoing,
Delta Airlines Inc.’s First Set of Request for Production of Documents to Defendant Unifi Aviation,
LLC, f/k/a DAL Global Services, LLC were served upon all counsel of record via electronic mail to
the following:
Andrea A. Klinetobe
Cletus W. Blakeman
Carlson, Blakeman Law Firm
2002 Douglas Street
Omaha, NE 68102
andrea@carlsonblakeman.com
clete@carlsonblakeman.com
Attorneys for Plaintiffs
Richard J. Kirschman
Whitfield, Eddy Law Firm
699 Walnut Street, Ste. 2000
Des Moines, IA 50309
kirschman@whitfiledlaw.com
Attorney for SkyWest Airlines, Inc.
Andrew M. Ferguson
Hennessy Roach Law Firm
14301 FNB Parkway, Ste. 308
Omaha, NE 68154
aferguson@hennessyroach.com
Attorney for Unifi Aviation, LLC
f/k/a DAL Global Services, LLC
/s/ Alexandra M. Speakar
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 30 of 40 - Page ID #
<pageID>

From: 	Alex Speakar
To: 	Caitlin Wain; carson@ned.uscourts.gov
Cc: 	Briza Menjivar; Victoria Harder; Jennifer Tricker; kirschman@Whitfieldlaw.com; Clete W. Blakeman; Kayla Hathcote; Lauren L. Meyer;
Andrew M. Ferguson
Subject: 	RE: 8:24CV442 Wanda Ridnour and Bruce Ridnour vs. Delta Air Lines, Inc., Skywest Airlines, Inc., Unifi Aviation, LLC, and John Doe
1-6 Discovery Dispute Conference Delta Position Statement
Date: 	Tuesday, February 17, 2026 8:02:07 AM
Attachments: 	image002.png
Unifi_Delta Meet and Confer Letter to Unifi(7065512.1).pdf
2026.02.09 Unifi"s Supplement RRFP to Delta(7064062.1).pdf
2026.01.14 - Unifi"s Answer to Delta"s ROGs (Delta_Ridnour)(7048641.1).pdf
2026.01.14 - Unifi"s Responses to Delta"s RFPs (Delta_Ridnour)(7048642.1).pdf
CAUTION - EXTERNAL:
Dear Judge Carson,
The remaining discovery issues are as follows: (1) Unifi only provided two documents in response to Delta’s requests for
production through their singular supplemental responses to Request No. 26; (2) Unifi copy and pasted the same
boilerplate objections for 26/30 requests for production with no specificity as to the basis for the objection (Requests Nos.
6 - 30); (3) Unifi cannot provide any accounting of where certain documentation is or what efforts it took to locate the
same. Delta requests that the Court require Unifi to supplement its responses to Delta’s requests for production and
remove the boilerplate objections for Requests Nos. 2, 3, 6, 7, 8, 11, 12, 13, 14, 15, 16, 17, 18, 19, 21, 22, 23, 24, 25, 26,
27, 28, 29, and 30. A short timeline of the party’s correspondence since January 9 th, is below.
January 9, 2026: Unifi provides its responses to Delta’s First Set of Interrogatories and Requests for Production.
January 14, 2026: Meet and confer call between Delta and Unifi counsel. Delta’s counsel requests production of
responsive documents as the written responses did not produce even a single document in response to the discovery
requests.
January 26, 2026: Delta issues its Meet and Confer Letter detailing the improper objections and responses Unifi
provided.
January 29, 2026: Unifi confirmed receipt of the meet and confer and requests until February 6, 2026, to respond.
February 9, 2026: Unifi provides one supplemental RFP response to Delta.
February 10, 2026: Meet and confer call between Delta and Unifi counsel. Delta seeks supplemental responses as set
forth in Meet and Confer by February 12 th.
Since the parties last contacted the Court on January 9, Unifi provided Delta with their written discovery responses
(attached), Delta issued a meet and confer letter (attached), and the parties engaged in at least two meet and confer
phone calls. The specific deficiencies with Unifi’s discovery responses are set forth in the attached meet and confer letter,
namely that Delta provided zero documentation with these initial responses and asserted the same boilerplate objection
to 26/30 requests for production. Following the Meet and Confer Letter, Unifi only provided one supplemental request for
production response (attached) and produced only two documents, which Unifi claimed were responsive solely to
Request for Production No. 26 concerning agreements, training, operation, and staff procedure documents. The
produced agreement outlines the type of service Unifi provides to the subject airport but provides none of the other
information requested in Request No. 26 regarding how Unifi staff are trained, educated, or otherwise operate to respond
to flight issues. This is despite Unifi counsel confirming during the meet and confer calls that Unifi trains its airport staff.
Considering the four-month delay in receiving Unifi’s written discovery responses, it is not clear what efforts Unifi took
over that course of time to locate responsive information.
Unifi did not provide any written response to Delta’s meet and confer letter or issue any additional supplemental
responses after the parties’ February 10 th meet and confer call. While Unifi eventually provided a few piecemeal
documents such as an employee schedule and the insurance policy as Delta’s counsel requested, Unifi did not
supplement its responses to requests for production as Delta requested to reflect the same. See Auer v. City of Minot,
2016 WL 11477247, at *1 (D.N.D., 2016) (explaining “parties are required to formally supplement any answers to written
discovery so that, if there is a dispute later, there is something the court can look to without having to wade through,”
piecemeal information). For example, Request No. 30 seeks the documents cited in Unifi’s Initial Disclosures (such as the
insurance policy for this dispute). While Unifi eventually provided this document, Unifi did not supplement its discovery
responses to reflect the same. Instead, Unifi maintained the same boilerplate objection to this request:
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 31 of 40 - Page ID #
<pageID>

This repeated boilerplate objection in no way
explains any undue burden in providing this information which is clearly relevant to the claims as it is citied in Unifi’s Initial
Disclosures. Simmons v. JP Morgan Chase Bank, N.A., 2010 WL 4273177, at *3 (D.Neb., Oct. 21, 2010) (granting Motion
to Compel when Defendant could not demonstrate any support for its bare objections for relevancy and overly
burdensome). Thus, the issues raised in the attached meet and confer letter continue to form the basis for this discovery
dispute. We would ask that Unifi supplement its responses and remove the improper, boilerplate objections, for Requests
Nos. 2, 3, 6, 7, 8, 11, 12, 13, 14, 15, 16, 17, 18, 19, 21, 22, 23, 24, 25, 26, 27, 28, 29, and 30.
Best,
Alex M. Speakar
Baird Holm LLP
1700 Farnam Street
Suite 1500
Omaha, NE 68102-2068
www.bairdholm.com
402.636.8264 Direct Dial Phone
402.344.0588 Fax
aspeakar@bairdholm.com
Baird Holm LLP
This communication, along with any attachments, is covered by federal and state law governing electronic communications
and may contain confidential and legally privileged information. If the reader of this message is not the intended recipient,
you are hereby notified that any dissemination, distribution, use or copying of this message is strictly prohibited. If you have
received this in error, please reply immediately to the sender and delete this message. Thank you.
From: Caitlin Wain <Caitlin_Wain@ned.uscourts.gov>
Sent: Friday, February 13, 2026 5:09 PM
To: Alex Speakar <aspeakar@bairdholm.com>
Cc: Briza Menjivar <bmenjivar@bairdholm.com>; Victoria Harder <vharder@bairdholm.com>; Jennifer Tricker
<jtricker@bairdholm.com>; kirschman@Whitfieldlaw.com; Clete W. Blakeman <clete@carlsonblakeman.com>;
Kayla Hathcote <Kayla_Hathcote@ned.uscourts.gov>; Lauren L. Meyer <lmeyer@hennessyroach.com>; Andrew M.
Ferguson <aferguson@hennessyroach.com>; carson@ned.uscourts.gov
Subject: RE: 8:24CV442 Wanda Ridnour and Bruce Ridnour vs. Delta Air Lines, Inc., Skywest Airlines, Inc., Unifi
Aviation, LLC, and John Doe 1-6 Discovery Dispute Conference Delta Position Statement
Counsel,
The case conference instructions entered in this case are not easily accessible at the moment, due to a change
in the court’s procedures related to restricted and sealed documents. I will ask the Clerk to replace the case
conference instructions at Filing No. 41 with an unrestricted copy. However, due to the federal holiday on
Monday it may not get done until Tuesday, so I have copied the dial-in information copied below. Thank
you,
Caitlin
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 32 of 40 - Page ID #
<pageID>

Dial 1-855-244-8681
Enter the access code: 2310 555 0906, then hit the # key
From: Caitlin Wain <Caitlin_Wain@ned.uscourts.gov>
Sent: Friday, February 13, 2026 4:39 PM
To: Alex Speakar <aspeakar@bairdholm.com>
Cc: Briza Menjivar <bmenjivar@bairdholm.com>; Victoria Harder <vharder@bairdholm.com>; Jennifer Tricker
<jtricker@bairdholm.com>; kirschman@Whitfieldlaw.com; Clete W. Blakeman <clete@carlsonblakeman.com>;
Kayla Hathcote <Kayla_Hathcote@ned.uscourts.gov>; Lauren L. Meyer <lmeyer@hennessyroach.com>; Andrew M.
Ferguson <aferguson@hennessyroach.com>; carson@ned.uscourts.gov
Subject: RE: 8:24CV442 Wanda Ridnour and Bruce Ridnour vs. Delta Air Lines, Inc., Skywest Airlines, Inc., Unifi
Aviation, LLC, and John Doe 1-6 Discovery Dispute Conference Delta Position Statement
Counsel,
A text order will be entered shortly setting a discovery dispute conference for February 17, 2026 at 1:00 p.m.
Please provide a brief email summary to carson@ned.uscourts.gov of any progress made since the
summaries were exchanged in January and the parties current positions by 9:00 a.m. on February 17. Thank
you,
Caitlin E. Wain
Law Clerk to United States Magistrate Judge Ryan C. Carson
U.S. District Court for the District of Nebraska
caitlin_wain@ned.uscourts.gov
Telephone: (402) 661-7342
From: Alex Speakar <aspeakar@bairdholm.com>
Sent: Friday, February 13, 2026 4:11 PM
To: Caitlin Wain <Caitlin_Wain@ned.uscourts.gov>
Cc: Briza Menjivar <bmenjivar@bairdholm.com>; Victoria Harder <vharder@bairdholm.com>; Jennifer Tricker
<jtricker@bairdholm.com>; kirschman@Whitfieldlaw.com; Clete W. Blakeman <clete@carlsonblakeman.com>;
Kayla Hathcote <Kayla_Hathcote@ned.uscourts.gov>; Lauren L. Meyer <lmeyer@hennessyroach.com>; Andrew M.
Ferguson <aferguson@hennessyroach.com>; carson@ned.uscourts.gov
Subject: RE: 8:24CV442 Wanda Ridnour and Bruce Ridnour vs. Delta Air Lines, Inc., Skywest Airlines, Inc., Unifi
Aviation, LLC, and John Doe 1-6 Discovery Dispute Conference Delta Position Statement
CAUTION - EXTERNAL:
Ms. Wain,
Unifi served its initial discovery responses on January 9 th. The parties have had at least two meet and confer calls since
then and have been unable to resolve the outstanding discovery issues with Unifi’s responses.
Per the Court’s earlier instructions, counsel for Delta and Unifi reviewed the Judge’s calendar and both parties are
available for a discovery conference Tuesday (2/17) at 1pm, or 2pm.
Please let us know if you need anything further to get this conference scheduled.
Best,
Alex M. Speakar
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 33 of 40 - Page ID #
<pageID>

Baird Holm LLP
1700 Farnam Street
Suite 1500
Omaha, NE 68102-2068
www.bairdholm.com
402.636.8264 Direct Dial Phone
402.344.0588 Fax
aspeakar@bairdholm.com
Baird Holm LLP
This communication, along with any attachments, is covered by federal and state law governing electronic communications
and may contain confidential and legally privileged information. If the reader of this message is not the intended recipient,
you are hereby notified that any dissemination, distribution, use or copying of this message is strictly prohibited. If you have
received this in error, please reply immediately to the sender and delete this message. Thank you.
From: Caitlin Wain <Caitlin_Wain@ned.uscourts.gov>
Sent: Friday, January 9, 2026 8:56 AM
To: Andrew M. Ferguson <aferguson@hennessyroach.com>; Alex Speakar <aspeakar@bairdholm.com>;
carson@ned.uscourts.gov
Cc: Joleen Baker <jbaker@bairdholm.com>; Victoria Harder <vharder@bairdholm.com>; Jennifer Tricker
<jtricker@bairdholm.com>; kirschman@Whitfieldlaw.com; Clete W. Blakeman <clete@carlsonblakeman.com>;
Kayla Hathcote <Kayla_Hathcote@ned.uscourts.gov>; Lauren L. Meyer <lmeyer@hennessyroach.com>
Subject: RE: 8:24CV442 Wanda Ridnour and Bruce Ridnour vs. Delta Air Lines, Inc., Skywest Airlines, Inc., Unifi
Aviation, LLC, and John Doe 1-6 Discovery Dispute Conference Delta Position Statement
Counsel,
Judge Carson has received summaries from Delta Air Lines and UniFi Aviation. In light of the ongoing
efforts to complete the discovery requested the court will wait to set a telephone conference. Please continue
to confer to see if these issues can be resolved without court intervention. Thank you,
Caitlin E. Wain
Law Clerk to United States Magistrate Judge Ryan C. Carson
U.S. District Court for the District of Nebraska
caitlin_wain@ned.uscourts.gov
Telephone: (402) 661-7342
From: Andrew M. Ferguson <aferguson@hennessyroach.com>
Sent: Friday, January 9, 2026 8:44 AM
To: Caitlin Wain <Caitlin_Wain@ned.uscourts.gov>; Alex Speakar <aspeakar@bairdholm.com>;
carson@ned.uscourts.gov
Cc: Joleen Baker <jbaker@bairdholm.com>; Victoria Harder <vharder@bairdholm.com>; Jennifer Tricker
<jtricker@bairdholm.com>; kirschman@Whitfieldlaw.com; Clete W. Blakeman <clete@carlsonblakeman.com>;
Kayla Hathcote <Kayla_Hathcote@ned.uscourts.gov>; Lauren L. Meyer <lmeyer@hennessyroach.com>
Subject: RE: 8:24CV442 Wanda Ridnour and Bruce Ridnour vs. Delta Air Lines, Inc., Skywest Airlines, Inc., Unifi
Aviation, LLC, and John Doe 1-6 Discovery Dispute Conference Delta Position Statement
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 34 of 40 - Page ID #
<pageID>

CAUTION - EXTERNAL:
Ms. Wain,
This office represents UniFi Aviation, LLC in regard to the above matter. Unfortunately, I
am only in a position to concur with Ms. Speakar’s recitation of events as they pertain to
her timeline regarding discovery. I also, again unfortunately, concur that she and I have
discussed this issue on several occasions without reaching a resolution.
I spoke with UniFi yesterday, January 8, 2026. It is my understanding that I will have
responses (verified Answers to Interrogatories and Responses to Requests for Production of
Documents) to Deltas discovery requests today. They will be filed as soon as I receive
them.
Ms. Speakar have conferred and are planning to speak on Monday or Tuesday (a time has
not yet been finalized) to discuss any issues raised in what I will submit. Thank you.
Andy Ferguson
Andrew M. Ferguson
Hennessy & Roach, P.C.
14301 FNB Pkwy., Ste. 111, Omaha, NE 68154
Direct 402.933.0952
Office 402.933.8851
aferguson@hennessyroach.com
From: Caitlin Wain <Caitlin_Wain@ned.uscourts.gov>
Sent: Thursday, January 8, 2026 4:27 PM
To: Alex Speakar <aspeakar@bairdholm.com>; Andrew M. Ferguson <aferguson@hennessyroach.com>;
carson@ned.uscourts.gov
Cc: Joleen Baker <jbaker@bairdholm.com>; Victoria Harder <vharder@bairdholm.com>; Jennifer Tricker
<jtricker@bairdholm.com>; kirschman@Whitfieldlaw.com; Clete W. Blakeman <clete@carlsonblakeman.com>;
Kayla Hathcote <Kayla_Hathcote@ned.uscourts.gov>
Subject: RE: 8:24CV442 Wanda Ridnour and Bruce Ridnour vs. Delta Air Lines, Inc., Skywest Airlines, Inc., Unifi
Aviation, LLC, and John Doe 1-6 Discovery Dispute Conference Delta Position Statement
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 35 of 40 - Page ID #
<pageID>

Received by Judge Carson’s chambers. Thank you,
Caitlin E. Wain
Law Clerk to United States Magistrate Judge Ryan C. Carson
U.S. District Court for the District of Nebraska
caitlin_wain@ned.uscourts.gov
Telephone: (402) 661-7342
From: Alex Speakar <aspeakar@bairdholm.com>
Sent: Thursday, January 8, 2026 3:27 PM
To: Andrew M. Ferguson <aferguson@hennessyroach.com>; carson@ned.uscourts.gov
Cc: Joleen Baker <jbaker@bairdholm.com>; Victoria Harder <vharder@bairdholm.com>; Jennifer Tricker
<jtricker@bairdholm.com>; kirschman@Whitfieldlaw.com; Clete W. Blakeman <clete@carlsonblakeman.com>;
Kayla Hathcote <Kayla_Hathcote@ned.uscourts.gov>
Subject: RE: 8:24CV442 Wanda Ridnour and Bruce Ridnour vs. Delta Air Lines, Inc., Skywest Airlines, Inc., Unifi
Aviation, LLC, and John Doe 1-6 Discovery Dispute Conference Delta Position Statement
CAUTION - EXTERNAL:
Dear Judge Carson,
This firm serves as counsel for Delta Air Lines, Inc. in the above-referenced lawsuit. Defendant Unifi Aviation LLC never
provided any responses to Delta’s written discovery requests issued on September 22, 2025. I attach Delta’s requests
hereto for the Court’s reference.
On September 22, 2025, Delta issued its First Set of Interrogatories and Requests for the Production of Documents to
Unifi. On October 28, 2025, Delta emailed Unifi’s counsel regarding the outstanding September discovery requests. On
October 29, 2025, Unifi’s counsel promised to check on the status of the responses. Delta again sought Unifi’s responses
on November 6, 2025, and at a November 6 th deposition, for an unrelated case both counsel attended, Unifi’s counsel
responded that the discovery responses would be forthcoming as counsel was just awaiting Unifi’s signature. Again, Unifi
did not provide any responses and on November 14, 2025, Delta informed Unifi that without responses Delta would have
to take action to compel the same. Delta’s counsel followed up with a phone call to Unifi’s counsel on December 23,
2025, in a last effort to secure Unifi’s responses. I attached the parties’ email correspondence hereto for the Court’s
reference.
Despite Delta’s numerous attempts to secure Unifi’s responses, to date, Delta has not received any response from Unifi
to the September 22, 2025, discovery requests Delta issued. Delta now seeks this Court’s intervention to secure Unifi’s
discovery responses.
Thank you.
Alex M. Speakar
Baird Holm LLP
1700 Farnam Street
Suite 1500
Omaha, NE 68102-2068
www.bairdholm.com
402.636.8264 Direct Dial Phone
402.344.0588 Fax
aspeakar@bairdholm.com
Baird Holm LLP
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 36 of 40 - Page ID #
<pageID>

This communication, along with any attachments, is covered by federal and state law governing electronic communications
and may contain confidential and legally privileged information. If the reader of this message is not the intended recipient,
you are hereby notified that any dissemination, distribution, use or copying of this message is strictly prohibited. If you have
received this in error, please reply immediately to the sender and delete this message. Thank you.
From: Kayla Hathcote <Kayla_Hathcote@ned.uscourts.gov>
Sent: Tuesday, January 6, 2026 2:18 PM
To: Alex Speakar <aspeakar@bairdholm.com>; Andrew M. Ferguson <aferguson@hennessyroach.com>
Cc: Joleen Baker <jbaker@bairdholm.com>; Victoria Harder <vharder@bairdholm.com>; Jennifer Tricker
<jtricker@bairdholm.com>; kirschman@Whitfieldlaw.com; Clete W. Blakeman <clete@carlsonblakeman.com>;
carson@ned.uscourts.gov
Subject: RE: 8:24CV442 Wanda Ridnour and Bruce Ridnour vs. Delta Air Lines, Inc., Skywest Airlines, Inc., Unifi
Aviation, LLC, and John Doe 1-6 Discovery Dispute Conference Request
Counsel,
The court understands there is a discovery dispute between the parties. To ensure that the matter is
addressed efficiently and fairly, the following procedures apply:
Both parties are to submit to the court by email to carson@ned.uscourts.gov, and to each other, a
concise statement (no more than three paragraphs) summarizing their respective position by noon on
Friday, January 9, 2026. Please include copies of any disputed requests. If the other defendants take no
position on the dispute, please let us know.
The parties must thereafter meet and confer (either in person or at a minimum by phone) to discuss in
good faith the particular issues as raised in the submissions. This discussion will be required regardless
of prior efforts to confer.
If a discovery dispute call with the court remains necessary after doing so, please jointly review Judge
Carson's calendar at https://www.ned.uscourts.gov/court-calendar, and note that the 1:30-2:30 p.m.
hour is generally reserved for criminal hearings. The parties should then email chambers to confirm that
they have conferred as instructed and propose two or more mutually agreeable dates and times. The
court will select one of the proposed dates and set the hearing, which will be recorded.
Please see the following General Order No. 2025-04 regarding the storage, management, and access to
restricted and sealed documents on CM/ECF, as the court’s procedures have recently changed.
Materials submitted prior to the hearing and the audio recording of the hearing will be uploaded to the
public docket unless there is a request for restriction.
Thank you,
Kayla N. Hathcote
Law Clerk to U.S. Magistrate Judge Ryan C. Carson
U.S. District Court for the District of Nebraska
Kayla_Hathcote@ned.uscourts.gov
Telephone: (402) 661-7343
From: Alex Speakar <aspeakar@bairdholm.com>
Sent: Monday, January 5, 2026 2:36 PM
To: Kayla Hathcote <Kayla_Hathcote@ned.uscourts.gov>; Andrew M. Ferguson <aferguson@hennessyroach.com>
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 37 of 40 - Page ID #
<pageID>

Cc: Joleen Baker <jbaker@bairdholm.com>; Victoria Harder <vharder@bairdholm.com>; Jennifer Tricker
<jtricker@bairdholm.com>; kirschman@Whitfieldlaw.com; Clete W. Blakeman <clete@carlsonblakeman.com>;
carson@ned.uscourts.gov
Subject: Wanda Ridnour and Bruce Ridnour vs. Delta Air Lines, Inc., Skywest Airlines, Inc., Unifi Aviation, LLC, and
John Doe 1-6 8:24CV442 Discovery Dispute Conference Request
CAUTION - EXTERNAL:
Dear Judge Carson and Ms. Hathcote,
This firm serves as counsel for Delta Air Lines, Inc. in the above-referenced lawsuit. We write to request a discovery
conference with the Court regarding Defendant Unifi Aviation LLC’s total failure to respond to Delta’s written discovery
requests.
Pursuant to the June 24, 2025, Progression Order entered for this matter, no party may file a Motion to Compel without
first contacting chambers to set a discovery conference to discuss the parties’ dispute. On September 22, 2025, Delta
issued its First Set of Interrogatories and Requests for the Production of Documents to Unifi. Since that time Delta has
continued to follow up with counsel for Unifi via email, in person conversations, and phone calls to secure Unifi’s
responses. Despite Delta’s numerous attempts to secure Unifi’s responses, to date, Delta has not received any response
from Unifi to the September 22, 2025, discovery requests Delta issued.
Because Delta’s previous efforts to secure the responses were ultimately unsuccessful, we now seek this Court’s
intervention to secure Unifi’s responses to the outstanding discovery without objection before proceeding in filing any
Motion to Compel.
We request the Court schedule a conference to address the dispute and Unifi’s failure to provide discovery responses
and, if necessary, grant Delta leave to file a Motion to Compel said responses.
Thank you for your attention to this matter.
Best,
Alex M. Speakar
Baird Holm LLP
1700 Farnam Street
Suite 1500
Omaha, NE 68102-2068
www.bairdholm.com
402.636.8264 Direct Dial Phone
402.344.0588 Fax
aspeakar@bairdholm.com
Baird Holm LLP
This communication, along with any attachments, is covered by federal and state law governing electronic communications
and may contain confidential and legally privileged information. If the reader of this message is not the intended recipient,
you are hereby notified that any dissemination, distribution, use or copying of this message is strictly prohibited. If you have
received this in error, please reply immediately to the sender and delete this message. Thank you.
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening
attachments or clicking on links.
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 38 of 40 - Page ID #
<pageID>

CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening
attachments or clicking on links.
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening
attachments or clicking on links.
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening
attachments or clicking on links.
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening
attachments or clicking on links.
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 39 of 40 - Page ID #
<pageID>

From: 	Andrew M. Ferguson
To: 	carson@ned.uscourts.gov
Cc: 	Lauren L. Meyer
Subject: 	RE: 8:24CV442 Wanda Ridnour and Bruce Ridnour vs. Delta Air Lines, Inc., Skywest Airlines, Inc., Unifi Aviation,
LLC, and John Doe 1-6 Discovery Dispute Conference Delta Position Statement
Date: 	Monday, February 16, 2026 5:44:18 PM
CAUTION - EXTERNAL:
Judge Carson,
Please consider this email the position statement of UniFi Aviation,
LLC. It is the position of UniFi that progress has been made in regard to
this discovery dispute. Initially, when UniFi responded to Delta’s
discovery requests, specifically the request for production of
documents, UniFi informed Delta that UniFi was not in possession of
any documents responsive to the requests. After discussion with
opposing counsel some clarifications were made regarding particular
requests and UniFi has provided those documents. While UniFi
understand that Delta is entitled to all relevant documents and
information it is UniFi’s position and that all documents in its
possession have been provided. Thank you.
Andrew M. Ferguson
Andrew M. Ferguson
Hennessy & Roach, P.C.
14301 FNB Pkwy., Ste. 111, Omaha, NE 68154
Direct 402.933.0952
Office 402.933.8851
aferguson@hennessyroach.com
8:24-cv-00442-JFB-RCC Doc # 72 Filed: 02/17/26 Page 40 of 40 - Page ID #
<pageID>