u.s. DEPARTMENT oF TRANSPORTAnolfl E C E IV ED 

SEP 2 9 2016 OFFICE OF HEARINGS 

WASHINGTON, D.C. 

HEARING DOCKFT ----In-the-Matter-of:--------------------------------------}------------------- ------------------- - ------------- -- -------------

) DocketNo: FAA-2015-3307 

FELTS FIELD AVIATION ) 

) Case No: 2015WP910090 

Respondent ) 

--------------~) Judge J.E. Sullivan 

COMPLAINANT'S RESPONSE TO RESPONDENT'S REQUESTS FOR ADMISSIONS 

The Complainant, by and through counsel, provides the following responses to Respondent's 

Requests for Admissions. Where an objection is noted, but a substantive response is provided, 

the s~?stantive response is provided without waiving the objection. 

REQUESTS FOR ADMISSIONS 

Request for Admission 1: Admit some colllillercial pilots are exempt from blood/alcohol testing: 

ANSWER: Objection - vague and ambiguous. This request seeks information regarding 

"blood/alcohol testing," but is vague and ambiguous regarding what type of testing to which it is 

referring. Subject to, and without waiving said objection, the Complainant(;armot admit or deny; 

therefore, deny. 

Request for Admission 1: Admit commercial pilots can operate under more than one Certificate 

Holder. 

ANSWER: Admit. 

Request for Admission 3: Admit Certificate Holders can contract with a third party administrator 

to monitor requirements under 14 CFR 120. 

ANSWER: Objection -Vague· mid overbroad. This request seeks information regarding "a third 

party administrator monitoringrequirements· imder 14 CFR 120," butis vague regarding what 

specific requirement under 14 CFR 120 to which it is referring. Additionally, this request is 

overbroad because it fails to specifY which of the numerous requirements under 14 CFR 120 it is 

referring to. Subject to, and without waiving said objection, the Complainant cannot admit or 

deny; therefore, deny. 

Request for Admission 4: Admit that third party administrators have contractual responsibilities 
to the Certificate Holder. 

ANSWER: Objection- calls for speculation. The Respondent seeks information that is within a 

_______________ C_ertifkat<!_HJ.!ld~r's_kn_o_w:Led~e,and_the_C_QIDJllaiuant~;;m_Qnly_spe_c_ula1~as_tQwhe_therthinLpill"t)' ____ _ 

administrators have contractual responsibilities to a Certificate Holder. Subject to, and without 

waiving said objection, the Agency cannot admit or deny; therefore, deny. 

Request for Admission 5: Admit the F.A.A. recognizes the contractual relationship between the 

certificate holder and the third party administrator. 

ANSWER: Objection - vague and ambiguous. This request seeks information regarding "the 

contractual relationship between the certificate holder and the third party administrator," but is 

vague and ambiguous regarding what contractual relationship to which it is referring. Subject to, 

and without waiving said objection, the Agency cannot admit or deny; therefore, deny. 

Request for Admission 6: Admit that First Advantage was approved and authorized to act as a 

third party administrator for the Respondent. 

ANSWER: Objection- calls for speculation. The Respondent seeks information that is within a 

Respondent's knowledge, and the Complainant can only speculate as to whether First Advantage 

was approved and authorized to act as a third party administrator for the Respondent. Subject to, 

and without waiving said objection, the Agency cannot admit or deny; therefore, deny. 

Respectfully submitted, 

Patricia A. MeN all 

Acting Assistant Chief Counsel for Enforcement 

jae~ Enforcement Division, Western Team 

P.O. Box 92007 

Los Angeles, CA 90009-2007 

Email: fatimah.stokley@faa.gov 

Telephone: (310) 725-7112 

Facsimile: (310) 725-6816 

Date: September 21,2016 

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Docket No. FAA-2015-3307 

Case No. 2015WP910090 

--------------------------------------------CERIIEICA'IE-OE..S.ER¥1CE-------------------- ---------

I hereby certifY that on this date I have sent by Facsimile and U.S. First Class Mail, the 

COMPLAINANT'S RESPONSE TO RESPONDENT'S REQUESTS FOR ADMISSION, 

addressed as follows: 

Judge J.E. Sullivan 

U.S. Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Ave, S.E. 

East Bldg., Room Ell-310 

Washington, D.C. 20590 

Also by Fax: 202-366-7536 

Federal Aviation Administration 

Hearing Docket Clerk, AGC-430 

Wilbur Wright Building, Suite 2Wl000 

800 Independence Ave., S.W. 

Washington, D.C. 20591 

Also by Fax: 202-267-1293 

Mark J. Conlin 

421 W. Riverside Ave., Suite 911 

Spokane, WA 99201 

Also by Fax: 509-623-1650 

Date: September 21,2016 

Antonia Garcia 

Paralegal Specialist 

Enforcement Division 

National Enforcement Program 

Western Team 

Federal Aviation Administration 

Lawndale, California 

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