CJ'( r . r QYYcJ~t0C D W 

Before the U.S. Department ofTransportation 

In the matter of 

TRANS TIME EXPRESS 

Z "It Federal Aviation Administration , •. 

) 

) 

) 

) 

) 

) 

Docket No. TBA 

FAA Case No. 20 I 1 S W700220 

Judge Ronnie A. Yoder 

1: 51 
RESPONDANT'S RESPOND TO COMPLAINANT'S INTERROGATORIES, 

REQUEST FOR PRODUCTION OF DOCUMENTS, AND REQUEST FOR ADMISSIONS 

Pursuant to Rule 220 ofthe Rules ofPractice in FAA Civil Penalty Actions, 14 

C.F.R. § 13.220, the Respondant, Trans Time Express.(TTE), hereby provides its 

responses to the Complianant, as foll ows: 

INTERROGATORIES UNDER 14 C.F.R. § 13.220(k) 

1. Identify each and every person you intend to call as a witness in this proceeding. 

by providing the person's name, occupation. busi ness address. and phone number 

(including land lines and cell phones). 

ANSWER: Ali Sharafeddin, President, Trans Time Express, 

1730 Lynn st. Arlington. VA 22209 

tel: (703)0525-4666 

Bahman Mehdyoun. manager. Trans Time Express 

1730 Lynn st. Arlington, VA 22209 

tel: (202)528-2200 

2. For each witness identified in response to Interrogatory l, identify the nature of 

the testimony to be provided (i.e., factual witness or expert witness) and 

summarize the substance ofthe testimony to be provided. 

ANSWER: Both witness will testifY about the nature and procedures oftheir 

business. and how it functions. and the services they provide. 

3. For each person identified as an expert in Interrogatory No.2. provide a statement 

of the substance of the facts and opinions to which the witness is expected to 

testifY: a narrative summary ofthe grounds for each opinion to which the witness 

will testifY: and detail the expertise possessed by each expert witness in the 
subject matter area on which the witness will opine. 

ANSWER: VI A. 

4. List all exhibits you intend to use at the hearing in this case. 

ANSWER: Respondant's Exhibit #I: Copy of the shipping label used to ship the 

material to Bandas Law firm 

5. Identify any and a ll documents in your possession that concern. refer to. or 

involve the circumstances set forth in the Complaint in this proceeding. 

ANSWER: No other documents. except for Respondant's exhibit # I. at this 

time. 

6. Describe with particularity each and every fact on which you rely to support each 

and every denial contained in your Answer to the Complaint in this case. 

ANSWER: The testimony of our witnesses will show that we were not at fault. 

7. Describe with particularity the reasons why you cannot admit or deny a llegations 

contained in the Complaint as reflected in your Answer to the Complaint in this 
case with the statements that 'ITE is without sufficient knowledge or information 

to admit or deny the allegation." 

ANSWER: The driver who handled this transaction, and another employee who 

may have had more particular knowledge about this event are no longer with the 

company. 

8. Describe with particularity each and every fact on which you rely to support each 

and eve!)· affirmative defense contained in your Answer to the Complaint in this 

case. 

ANSWER: The answers were given based on experience about the day-to-day 

operations, and what must have happened. 

9. Identify the person listed in FedEx U.S. Airbill 8668 4774 3122 as "Ben" in the 

Sender's Name box by providing the person's name. occupation. business 

address, and phone number (including land lines and cell phones). See 

Attachment I. 

ANSWER: Bahman Mehdyoun, manager. Trans Time Express 

1730 Lynn st. Arlington, VA 22209 

tel: (202)528-2200 

I 0. Identify ail employees involved in picking up. classifYing, describing. packaging. 

marking, and labeling the shipment assigned FedEx Airbill number 8668 4774 

3122 for transportation in commerce by air by providing each person's name. 

occupation. business address. and phone number (including land lines and cell 

phones). 

ANSWER: Bahman Mehdyoun, manager. Trans Time Express 
1730 Lynn st. Arlington. VA 22209 

tel: (202)528-2200 

REQUESTS FOR PRODUCTION OF DOCUMENTS UNDER 

14 C.F.R § J3.llO(b) 

I. Copies of each and every document that you intend to introduce as evidence in 

this case. 

2. Copies of any statements made by witnesses identified in the preceding 

Interrogatories concerning, referring to. or involving the circumstances set forth in 

the Complaint. 

3. A current copy ofthe curriculum vitae for each expert identified in response to the 

preceding Interrogatories. 
4 . Copies of all documents that support each and every denial. if any. contained in 

your Answer to the Complaint in this case. 

5. Copies of all documents that support each and every affinnative defense. if any. 

contained in your Answer to the Complaint in this case. 

6. Copies of all correspondence between you and Bandas Law Finn. 

REQUESTS FOR ADMISSION UNDER 14 C.F.R. § 13.220(1) 

Please provide responses to the following admissions. For all denials. please 

provide with particularity each and every fact on which you rely to support each and 

every denial. If you are unable to admit or deny the truth of the matter. please provide 

evidence that a reasonable inquiry into the matter or that the information known to, or 

readily obtainable by, you is insufficient to enable you to admit or deny the matter. 

L You were contracted by Bandas Law Firm to provide transportation for certain 

items. 

Admit _:;i__ Deny __ 

2. The items you picked up for Bandas Law Finn were ten twenty-two tluid ounce 

plastic bottles otMasterjack Drain Opener. 

Admit --2._ Deny __ 

3. You packaged the items that you picked up for Bandas Law Finn. 

Admit~ Deny __ 

4. Prior to July 28, 20 I I. you did not provide hazardous materials training to your 

employees in accordance with 49 C.F.R. § 173.l(b). 

Admit~ Deny _21._ 

A'{, 1 hrv :-~d rn, 1, nv i J,. ~j" 
5. Prior to July 28. 20 II. you did not provide hazardous materials training to your 

employees in accordance with 49 C.F.R. § 172.702(a). 

Admit __ Deny __ 

6. Prior to July 28, 20 II , you did not provide hazardous materials training to your 

employees with regard to any Department of Transportation Hazardous Materials 

Regulations. 

Admit Deny __ AfdA,_, ~ """",LJ 

7. The shipment you made on behalf offiandas Law Firm that is the subject ofthis 

matter was not have accompanied by shipping papers identifying the hazardous nature of 

the contents contained therein. 

Admit __:L Deny __ 

8. The shipment you made on behalf offiandas Law Firm that is the subject of this 

matter did not have accompanying shipping papers identifYing the hazardous nature of 

the contents contained therein. 

Admit -.J_ Deny __ 

9. The shipment you made on behalf of Bandas Law Firm that is the subject of this 

matter did not have accompanying shipping papers containing the certifications required 

under the Department of Transportation Hazardous Materials Regulations. 

Admit .:::L_ Deny __ 

10. The shipment you made on behalfofBandas Law Firm that is the subject of this 

matter did not have accompanying shipping papers that included the identification 

number as shown in Column (4)ofthe49.C.F.R. section 172.101 table. 

Admit ~ Deny __ 
II. The shipment you made on behalf offiandas Law Firm that is the subject of this 

matter did not have accompanying shipping papers that included the prope r shipping 

name as shown in Column (2) of the 49. C.F.R. section 172. \0 I table. 

Admit~ Deny __ 

12. The shipment you made on behalf offiandas Law Firm that is the subject of this 

matter did not have accompanying shipping papers that included the hazard class or 

division number as shown in Column (3) of the 49. C.F.R. section I 72.101 table. 

Admit~ Deny __ 

I 3. The shipment you made on behalf offiandas Law Firm that is the subject of this 

matter did not have accompanying shipping papers that included the packaging group as 

shown in Column (5) of the 49. C.F.R. section I 72.10 I table . 

Admit~ Deny __ 

14. The shipment you made on behalfoffiandas Law Firm that is the subject of this 

matter did not have accompanying shipping papers that included the total net mass of the 

material per package. 

Admit --.:4:- Deny __ 

15. The shipment you made on behalf offiandas Law Firm that is the subject of this 

matter did not have accompanying shipping papers tbat included the number and type of 

packages by description. 

Admit -4\- Deny __ 
16. The shipment you made on behalf ofBandas Law Firm that is the subject of this 

matter was not marked in accordance with the Department of Transportation Hazardous 

Materials Regulations. 

Admit ~ Deny __ 

17. The shipment you made on behalf ofBandas Law Finn that is the subject of this 

matter was not marked with the shipping name and identification number ofthe 

hazardous materials contained therein. 

Admit~ Deny __ 

18. The shipment you made on behalf ofBandas Law Finn that is the subject oft.his 

matter was not marked with orientation markings. 

Admit~ Deny __ 

19. The shipment you made on behalf ofBandas Law Firm that is the subject of this 

matter was not labeled in accordance with the Department of Transportation Hazardous 

Materials Regulations. 

Admit~ Deny __ 

20. The shipment you made on behalf offiandas Law Firm that is the subject of this 

matter did not have accompany ing emergency response information in accordance with 

the Department ofTransportation Hazardous Materials Regulations. 

Admit ~ Deny __ 

21 . The shipment you made on behalf offiandas Law Firm that is the subject of this 

matter was not shipped in a package that met the requirements of the Department of 

Transportation Hazardous Materials Regulations. 

Admit _L_ Deny __ 
I affirm that the above representation is true and correct to the best of my 

information, knowledge ,and belief. 

., ;) 

!) . .I )0 - ::y-:"::"\ ,.. Bahlnan Mehdymm .......... 

Manager-Trans Time Express 

• ,1_ \__ Respectfully submitted, " / · / 

'-~ ."'V\.-~ 

Cameron Niakan 

Attorney for Respondant 

I 0 I 0 I grosvenor Pl. #620 

Rockville, MD 20852 

(202)276-4 726 

CN@NiakanLaw.com 

Dated: May 22, 20 14 
Certificate of Service 

I hereby certifY that on this date I have placed in the U.S. mail, postage prepaid, certified 

return-receipt, a copy ofthe RESPONDANT'S RESPOND TO COMPLAINANT'S 

INTERROGATORIES, REQUEST FOR PRODUCTION OF DOCUMENTS, AND 

REQUEST FOR ADMISSIONS 

in thecase of In the Matter of Trans Time Express, FAA Case no. 20 ll SW700220. 

addressed to: 

Charles Raley, Attoreny 

Enforcement Devision, AGC-300 

Office ofthe Chief Counsel 

FAA 

800 Independence Ave. S.W. 

Washington. DC 20591 

Dated: May 22. 2014 

_., ' I \ 

~ 

N. (L k~ ,;1 
E:l " 

I n 

~ ::= .n ~ 

..t::l I ~ 

~\ • 

~~ 

,. _j l • 

• 
Exp. Date: 04/ 13 

Billing address is same as office. 

Thank you so much for your help. Let me know if you need any other information. 

Amber M . Pederson 

Legal Secretary 

Bandas Law Finn 

500 N Shoreline Blvd., Suite 1020 

Corpus Christi, Texas 78401 

Ph: 361-698-5200 

Fx: 361-698-5222 
Our office needs you to pick up 1 0 (22oz.) bottles of Masterjack Drain Opener from 

Fischer Hardware 

6129 Backlick Road 

Springfield, VA 22150 

Ph: 703-451-3700 

They are about $15.00 per bottle. I have attached a picture of the bottle for you to review. 

Once they are picked up, please take them to a Fed Ex location and have them use our account 

#328983125.lfthey need to use multiple boxes that is fine Have them use a billing reference of 

Amy Fields and then ship them to: 

Bandas Law Firm 

500 N. Shoreline Blvd., Suite 1020 

Corpus Christi, Texas 78401 

Once shipped please send me an invoice for your services rendered and we will remit payment. 

As a show of good faith I am leaving our credit card info to leave on file until the invoice is paid. 

AMEX 

Robert J. Sigler 

Bandas Law Firm, P.C. 

Card #: 3 715 51561 7 02054 

4 digit code: 6315 

s 
Makmg business How 

****************************************************************************** 

****************************************************************************** 

******************Privileged and/or confidential information may be contained in this 

message. If you are not the addressee indicated in this message (or are not responsible for 

delivery ofthis message to that person) , you may not copy or deliver this message to anyone. In 

such case, you should destroy this message and notify the sender by reply e-mail. If you or your 

employer do not consent to Internet e-mail for messages of this kind, please advise the sender. 

Trans Time Express, inc. does not provide or endorse any opinions, conclusions or other 

information in this message that do not relate to the official business ofthe company or its 

subsidiaries. 

****************************************************************************** 

****************************************************************************** 

****************** 

----- Original Message -----

From: 

BLF Desk <BLFDesk@bandasJawfirm.com> 

To: 

"bent'@.transtimeexpress.com" <ben(a)transtimeexpress.com> 

Cc: 

Sent: 

Tue, 26 Jul 2011 20:36:18 +0000 

Subject: 

Services needed 

Ben, 
I really appreciate it Ben. 

Amber M. Pederson 

Legal Secretary 

Bandas Law Firm 

500 N Shoreline Blvd., Suite 1 020 

Corpus Christi, Texas 78401 

Ph: 361-698-5200 

Fx: 361-698-5222 

From: 'Ben Diyoun' [mailto:ben@transtimeexpress.com] 

Sent: Tuesday, July 26, 2011 3:58PM 

To: BLF Desk 

Subject: Re: Services needed 

Amber, 

I have scheduled a pickup in the morning, I will keep you posted as things progress .. 

Ben Diyoun 

TTE/Operations Supervisor 

703-525-4666 

7 
As far as i know FEDEX picked up your box for shipment around 4pm for delivery by noon 

tomorow. I have inclosed in pdf format Inviced charges, recipts and the conformation recipts for 

the charge on your American Express for the amount of$323.40. Please let me know ifthats all 

you needed and if theres is any thing els i can do for you. 

Kind Regards, 

Ben Oiyoun 

TTE/Operations Supervisor 

703-525-4666 

Making business flow 

****************************************************************************** 

****************************************************************************** 

******************Privileged and/or confidential information may be contained in this 

message. If you are not the addressee indicated in this message (or are not responsible for 

delivery of this message to that person) , you may not copy or deliver this message to anyone. In 

such case, you should destroy this message and notify the sender by reply e-mail. If you or your 

employer do not consent to Internet e-mail for messages of this kind, please advise the sender. 

Trans Time Express, inc. does not provide or endorse any opinions, conclusions or other 

information in this message that do not relate to the official business of the company or its 

subsidiaries. 

****************************************************************************** 

****************************************************************************** 

****************** 

----- Original Message -----

From: 

BLF Desk 

To: 

"Ben Diyoun" 

Cc: 

Sent: 

Tue, 26 Jul 2011 21:06:45 +0000 

Subject: 

RE: Services needed 
Replv, Reply All or Fon.vard I More 

'Ben Diyoun' 

ToMe 

Jan 20,2012 

Ben Diyoun 

TTE/Operations Supervisor 

703-525-4666 

Making busmess flow 

****************************************************************************** 

****************************************************************************** 

****************** Privileged and/or confidential information may be contained in this 

message. If you are not the addressee indicated in this message (or are not responsible for 

delivery of this message to that person), you may not copy or deliver this message to anyone. In 

such case, you should destroy this message and notify the sender by reply e-maiL If you or your 

employer do not consent to Internet e-mail for messages of this kind, please advise the sender. 

Trans Time Express, inc. does not provide or endorse any opinions, conclusions or other 

information in this message that do not relate to the official business of the company or its 

subsidiaries. 

****************************************************************************** 

****************************************************************************** 

****************** 

----- Original Message -----

From: 

"Ben Diyoun" <ben@transtimeexpress.com> 

To: 

"BLF Desk" <BLFDesk@bandaslawfirm.com> 

Cc: 

Sent: 

Wed, 27 Jul 2011 17:31:35 -0500 

Subject: 

RE: Services needed 

Hi Amber, 
500 N. Shoreline Blvd., Suite 1020 

Corpus Christi, Texas 7840 I 

Once shipped please send me an invoice for your services rendered and we will remit payment. 

As a show of good faith I am leaving our credit card info to leave on file until the invoice is paid. 

AMEX 

Robert J. Sigler 

Bandas Law Firm, P.C. 

Card#: 3715 515617 02054 

4 digit code: 6315 

Exp. Date: 04/ 13 

Billing address is same as office. 

Thank you so much for your help. Let me know if you need any other information. 

Amber M. Pederson 

Legal Secretary 

Bandas Law Firm 

500 N. Shoreline Blvd., Suite l 020 

Corpus Christi, Texas 78401 

Ph: 361-698-5200 

Fx: 361-698-5222 
----- Original Message -----

From: 

BLF Desk 

To: 

"ben@transtimeexpress.com" 

Cc: 

Sent: 

Tue, 26 Jul 2011 20:36:18 +0000 

Subject: 

Services needed 

Ben, 

Our office needs you to pick up 10 (22oz.) bottles of Masterjack Drain Opener from 

Fischer Hardware 

6129 Backlick Road 

Springfield, VA 22 150 

Ph: 703-451-3700 

They are about $ 15.00 per bottle. r have attached a picture of the bottle for you to review. 

Once they are picked up, please take them to a Fed Ex location and have them use our account 

#328983125. If they need to use multiple boxes that is fine. Have them use a billing reference of 

Amy Fields and then ship them to: 

Bandas Law Firm 
----- Original Message -----

From: 

"Ben Diyoun" <ben@transtimeexpress.com> 

To: 

"BLF Desk" <BLFDesk@bandaslawtirm.com> 

Cc: 

Sent: 

Tue, 26 Jul2011 15:58:22 -0500 

Subject: 

Re: Services needed 

Amber, 

I have scheduled a pickup in the morning, 1 will keep you posted as things progress .. 

Regards, 

Ben Diyoun 

TTE/Operations Supervisor 

703-525-4666 

Making business flow 

****************************************************************************** 

****************************************************************************** 

****************** Privileged and/or confidential information may be contained in this 

message. If you are not the addressee indicated in this message (or are not responsible for 

delivery of this message to that person), you may not copy or deliver this message to anyone. In 

such case, you should destroy this message and notify the sender by reply e-mail. If you or your 

employer do not consent to Internet e-mail for messages of this kind, please advise the sender. 

Trans Time Express, inc. does not provide or endorse any opinions, conclusions or other 

information in this message that do not relate to the official business of the company or its 

subsidiaries. 

****************************************************************************** 

****************************************************************************** 

****************** 
Exp. Date: 04/13 

Billing address is same as office. 

Thank you so much for your help. Let me know if you need any other information. 

Amber M . Pederson 

Legal Secretary 

Bandas Law Firm 

500 N Shoreline Blvd., Suite I 020 

Corpus Christi, Texas 78401 

Ph: 36 1-698-5200 

Fx: 361-698-5222 
Our office needs you to pick up 10 (22oz.) bottles of Masterjack Drain Opener from 

Fischer Hardware 

6129 Backlick Road 

Springfield, VA 22150 

Ph: 703-451-3 700 

They are about $15.00 per bottle. I have attached a picture ofthe bottle for you to review. 

Once they are picked up, please take them to a Fed Ex location and have them use our account 

#328983 125. If they need to use multiple boxes that is fine Have them use a billing reference of 

Amy Fields and then ship them to: 

Bandas Law Firm 

500 N. Shoreline Blvd., Suite 1020 

Corpus Christi, Texas 78401 

Once shipped please send me an invoice for your services rendered and we will remit payment. 

As a show of good faith I am leaving our credit card info to leave on file until the invoice is paid. 

AMEX 

Robert J. Sigler 

Bandas Law Firm, P.C. 

Card #: 3715 515617 02054 

4 digit code: 63 15 
Making business flow 

****************************************************************************** 

****************************************************************************** 

****************** Privileged and/or confidential infonnation may be contained in this 

message. If you are not the addressee indicated in this message (or are not responsible for 

delivery of this message to that person) , you may not copy or deliver this message to anyone. In 

such case, you should destroy this message and notify the sender by reply e-mail. If you or your 

employer do not consent to Internet e-mail for messages of this kind, please advise the sender. 

Trans Time Express, inc. does not provide or endorse any opinions, conclusions or other 

information in this message that do not relate to the official business of the company or its 

subsidiaries. 

****************************************************************************** 

****************************************************************************** 

****************** 

----- Original Message -----

From: 

BLF Desk <BLFDesk@.bandaslawiinn. com> 

To: 

"ben!wtranstimeexpress.com" <ben\mtranstimeexpress. com> 

Cc: 

Sent: 

Tue, 26 Jul 2011 20:36:18 +0000 

Subject: 

Services needed 

Ben, 
I really appreciate it Ben. 

Amber M. Pederson 

Legal Secretary 

Bandas Law Firm 

500 N Shoreline Blvd., Suite 1020 

Corpus Christi, Texas 78401 

Ph: 361-698-5200 

Fx: 361-698-5222 

From: 'Ben Diyoun' [mailto:ben@transtimeexpress.com] 

Sent: Tuesday, July 26, 201 1 3:58PM 

To: BLF Desk 

Subject: Re: Services needed 

Amber, 

I have scheduled a pickup in the morning, I will keep you posted as things progress .. 

Regards. 

Ben Diyoun 

TIE/Operations Supervisor 

703-525-4666 
'Ben Diyoun' 

ToMe 

Jan 20, 2012 

Ben Diyoun 

TIE/Operations Supervisor 

703-525-4666 

Making business flow 

****************************************************************************** 

****************************************************************************** 

******************Privileged and/or confidential information may be contained in this 

message. If you are not the addressee indicated in this message (or are not responsible for 

delivery of this message to that person), you may not copy or deliver this message to anyone. In 

such case, you should destroy this message and notify the sender by reply e-mail. If you or your 

employer do not consent to Internet e-mail for messages of this kind, please advise the sender. 

Trans Time Express, inc. does not provide or endorse any opinions, conclusions or other 

information in this message that do not relate to the official business of the company or its 

subsidiaries. 

****************************************************************************** 

****************************************************************************** 

****************** 

----- Original Message -----

From: 

"Ben Diyoun" <ben@transtimeexpress.com> 

To: 

"BLF Desk" <BLFDesk@bandaslawftrm.com> 

Cc: 

Sent: 

Wed, 27 Jul 2011 17:31 :35 -0500 

Subject: 

RE: Services needed 

Hi Amber, 

\( 
As far as i know FEDEX picked up your box for shipment around 4pm for delivery by noon 

tomorow. I have inclosed in pdf format lnviced charges, recipts and the conformation recipts for 

the charge on your American Express for the amount of$323.40. Please let me know ifthats all 

you needed and if theres is any thing els i can do for you. 

Kind Regards, 

Ben Diyoun 

TIE/Operations Supervisor 

703-525-4666 

Making busrness flow 

****************************************************************************** 

****************************************************************************** 

****************** Privileged and/or confidential information may be contained in this 

message. If you are not the addressee indicated in this message (or are not responsible for 

delivery of this message to that person) , you may not copy or deliver this message to anyone. In 

such case, you should destroy this message and notify the sender by reply e-mail. If you or your 

employer do not consent to Internet e-mail for messages of this kind, please advise the sender. 

Trans Time Express, inc. does not provide or endorse any opinions, conclusions or other 

information in this message that do not relate to the official business of the company or its 

subsidiaries. 

****************************************************************************** 

****************************************************************************** 

****************** 

----- Original Message -----

From: 

BLF Desk 

To: 

"Ben Oiyoun" 

Cc: 

Sent: 

Tue, 26 Jul 2011 21 :06:45 +0000 

Subject: 

RE: Services needed