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II:' the Matter or: 

U.S. DEPARTMENT OJ< TRANSPORTATJON 

OFFICE OF HEARINGS 

W ASHJNGTON, D.C. 

Docket No: f/c/\-2( · '\-3307 

FI::L'CS FIET:J XI'!ATION 

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R eSllOildcnt 

Case No: 201.S\JiP9 i :1090 

Judge j .Ji Stili.ivaE 

COMPLAINANT'S FIRST SET OF 

DISCOVERY REQUESTS TO RESPONDENT 

Complainant, by and through cmmsel, requests that Respondent res1J011C: ·,,.:ithin :.· 

reasonable ::i,ne. but no iater than Augus~ 21, 20l6. to the following Reone,)TS f'n:· 

Admissions. interrogatories, and Requests fi)r Production of Docvmen:t:s. separate!:·· anc' 

fuily under oalic 

These discovery requests are intended to be continuing in :lilllJre and ai' 

in'i't>rmation th:Jt m.ay be discovered by you subsequent to the service ancc filinv ,,. your 

answers must be brought to the attention of the Complainant's attomev i.immgh 

sunrlcmentai ,,,n,swers when it becomes available to you, and in a reasona.ble <:imc ·xi or :_o 

the hearing;,; this matter. Ifthere are any additions, deletions or changc5 11:: ::he answers 

or informatioDIJrOvided at any time prior to the hearing. yml are specifieai!v ,-eGLlCstccl tc 

immediately infom1 tmd fctrnish such information to Complainant's attomey. :··such 

informatioP 's not furnished, the attorney for Complainant, at the time oi'lhc >caring, 

may move to exclude from evidence such information requested and not !'hmishcc. 

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DEFINITIONS 

"Documents" means, regardless of origin or location, any handwriting, note, 

letter, manual, memorandum, record, report, statement, study, drawing, sketch, 

photograph, 1:elegram, telex, or message, whether reported, transcribed, nunchc<i, taped, 

filmed or granhically represented in any manner, or material of any kind i!' the ocssession 

of subject tc the control of, or wi.thin the knowledge of, Respondent anci/cy his 

employees, agents, partners, consultants, or experts. 

2. "Tdenlify" and/or "state the identity of' with reference to individuals means 

state !he nan1e, cu1Tent or last known address, employer, and job descriptioE or :Iitle. and 

telephone numbeL 

3. "Identify all documents" means state the date and author lmless apparent from 

the document 

4. As i.isted herein, singular pronouns also include the plural. 

5. "You," "your," and "Respondent," as used herein refers to Felts :>'ield ·'··'·'iation, 

Inc. (Felts fieid). 

BE ADVISED that Rule 36 of the federal Rules of Civil Procedure s~ates, "rr 

matter is admitted unless, within 30 days after being served, the party to whon'- the 

reQuest is directed serves on the requesting party a written answer or objection ae~dresscd 

to the matter and signed by the party or its attorney." 

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REQUESTS FOR ADMISSIONS 

Complainant requests that the Respondent make the to !lowing admissions: 

Admit that Richard Webber was not added to Felts Field's random c>·ug ana 

alcohol testing pool until on or about April6, 2015. 

2. Admit that Richard Webber was not included in the random selection noo: :iLtring 

sele<,tions made in July of2013. 

3 _ Admit that Richard Webber was not included in the random selecti_on poe: :luring 

selections made in October of2013. 

4. Admit that Richard Webber was not included in the random selection po(•: -lttring 

selections made in January of2014. 

5. Admit that Richard Webber was not included in the random selection uoc•. juring 

selections made in April of2014. 

6. Admit that Richard Webber was not included in the random selection poe-: during 

selections made in July of2014. 

7. Admit that Richard Webber was not iacluded in the random selection noc,! during 

selections made in October of2014. 

8. Admit that Richard Webber was not induded in the random selection noc-~ :luring 

selections made in January of2015. 

INTERROGATORIES 

Identify b'' name, address, and telephone number all persons whom ;'llU Know to 

have nersonal knowledge of the matters alleged in the Complaint. 

2. Identify by title, date, author, present custodian, and content, al! docc.ments, 

including correspondence, obtained by you or in your possession, relatin~' :0 the 

assertions in the Complaint, your request for a hearing, your answer, a:.1<o an)' 

affirmative defenses which you anticipate raising in this matter. See Reouest l[)r 

Production No. l, 

3. Identify by name, address, and teleph<)ne number, all persons whom you intend to 

have testify as a factual or expert witness in your defense at the heari.ng '.n this 

matter. and for factual wimesses, provide a detailed summary of each ·oerson's 

anticipated testimony. 

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4. ldentify by title, date, author, present custodian, and contenL all documerts which 

you anticipate offering into evidence or using at the hearing in this mallE:r. See 

Request for Production No. 2. 

5 _ With respect to each expert witness identified in response to Interrogato ·:.- No. _,. 

specifY their specit1c area of expertise and provide a synopsis of their cr,:dcntiaJs. 

background. training, and experience. 

6. With respect to each expert you expe~t to call as a witness, state the subject. matteT 

on whi.ch the expert is expected to testify, th<; substance of the facts and Doinions 

to which the expert is expected to testify, and provide a summary of the grounds 

for each such opinion. 

/_ Describe with specificity all of the :facts which you anticipate presenting during 

the course of the hearing in this matter pertaining to the ~voidance or ~nitigatio1' 

ofthc sanction sought by the FAA in this case. 

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8:. For each allegation in the Complaint that is denied-whether outrigk J!" as a 

result of !1aving insufficient information Or knowledge from which > t<)rm a 

belief as to the truth of the allegation, in whole, or in part-state with suecificity 

the facts that are the basis for that denial as well as the inquiries :aken tc 

dctern1ine that the allegation in the complaint is not correct. See Reouest for 

Production No. 3. 

9 _ For any Requests for Admissions that are denied-whether outright or i'.S a resuh 

of having insufficient information or knowledge from which to form a bdicf as to 

the truth of the allegation, in whole, or in part-state with specificit;1 the facts and 

evidence which are the basis for that denial as well o.s the inquiries taken to 

determine that the !acts in the request for admission are not correct Sc: Request 

for Production No. 4. 

; 0. Describe with specificity all facts and evidence you intend to rely upou -, support 

of any aflirmative defenses raised in any Answer to the Complaint. See Request 

for Production No. 5 _ 

REQUESTS FOR PRODUCTION 

Request for Production No. 1: Provide a copy of all documents referred lO in y,·,u::-

answer w Interrogatory No. 2. 

Request for Production No. 2: Provide a copy of all docum<;nts referred w in ;1ou:· 

answer to lnten-ogatory No.4. 

Regqest for Production No. 3: Provide a CC•PY of all documents that support yo•.tr answer 

w Interrogatory No. 8. 

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Request 'for Production No. 4: Provide "-copy of all documents that ~upport yow answer 

to InteTTogatory No. 9. 

Request for Production No. 5: Provide a copy of all documents that suppott yotF an~wer 

to Interrogatory No. 10. 

Request for Production No.6: Provide a copy of all exhibits that you intend to d'fer or 

will use during the hearing in this matter. 

Respectfully submitted, 

Patricia A. McNall 

Acting Assistant Chief Counsel for Enforcement 

c--.. r--' 

By ~'X-z_~ 

Fatimah Stokley,~~ Enforcement Division, Western Team 

Emaii: fatimah.stokley@faa.gov 

Telephone: (310) 725-7112 

Facsimile: (310) 725-6816 

DateC:: July 2;, 2016 

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CERTIFICATE OF SERVICE 

Docket No. c

0AA-2015-3307 

Case No. 20l5WP910090 

l hereby certify that on this date l have faxed and placed in the United States :naL 

nostage prel)aicL the COMPLAINANT'S FIRST SET OF DTSCOV'c'<":' ~~. 

RESPONDE!'r::. addressed as follows' 

Dilted July 2:. 2016 

Judge J.E. Sullivan 

U.S. Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department ofTrarrsportatio11 

1200 New Jersey Ave, S.E. 

East Bldg., Room Ell-310 

Washington, D.C 20590 

Facsimile: 202-366-7536 

Federal Aviation AdministTation 

Hesdng Docket Clerk, AGC-430 

Wilbur Wright Building, Suite 2Wl 000 

800 Independence Avil., S.W. 

Washington, D.C. 20591 

Facsimile: 202-267-1293 

Mark J. Conlin, Esq. 

(Respondent's Cmmsel) 

Conlin, Maloney & Miller 

4 21 W, Riverside Ave., Suite 911 

Spokane, WA 9920 l 

Facsimile: 509-623-1650 

Antonia Garcia. ·Paralegal Spe"2i"i!HSt 

Orrice of the Regional Counsel 

Federal Aviation Administration 

Lawndale, California 

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To: Judge J.E Sullivan, U.S. AU 

Comoany: ':JOT- Office of Hearings, M-20 

Phone: 

From: ~atimah Stokley, Attorney 

11tle: Attorney, FAA Enforcement Division-Western 

Team 

Date: 7/2112016 

Pages w/oover: ' 

cc: Mark J. ConiinJ!sq., Fax (509) 623-1650 

F/\_1\ Hearing Docket Clerk, Fax 202-267-129] 

141001/007 

Federal .Aviation 

Administration 

::nfon::ern~nt Division- W~rr. To:! !;1m 

? 0. Be: 92007 

~os Angeles, C." 90009-2007 

T 310-7~25-7~ ·:2 

:= 3"10-!15-6816 

:: Fatim~h Stol\lev@faa.gov 

Document: In the Matter of 

l

0 elts Fi.,ld Aviation 

Com~1a1nant's First Set c·:-

Jiscove~· Requests 1c 

Respon:Jenc 

0 LJ.S. 0<?[/;.".r~menl cfTrar;::porl;;tlion