465 California Street 

Suite 210 

• 

San Francisco 

California 94104 

• 

(415) 421-2500 

Fax (415) 421-2560 

www.avialex.com 

law@avialex.com 

Michael L. Dworkin and Associates 

Law Offices 

FED EX: 

Federal Aviation Administration 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building -Suite 2W1000 

800 Independence Avenue SW 

Washington, DC 20591 

RE: Belt Makers, Inc. 

FAA Case No. 2011WP910400 

FDMS: FAA-2013-0049 

Dear Hearing Docket Clerk: 

RECEIVED 

June 5, 2013 

JUN -7 2013 

HEARING DOCKET 

1.· ·• 

Enclosed herewith for filing is the following document: 

Belt Makers, Inc's Objections and Responses to Complainant's 

Discovery Request. 

cc: The Honorable Richard C. Goodwin 

Administrative Law Judge 

Lisa Toscano, Esq. 

FAA,AWP-7 ·:..._--

Very truly yours, 

a'/1~ 

Caitlin M. Miller 

Legal Assistant 
MICHAEL L. DWORKIN #64047 

MICHAEL L. DWORKIN and ASSOCIATES 

465 California Street, Suite 210 

San Francisco, California 94104 

Telephone: (415) 421-02500 

Facsimile: (415) 421-2560 

Email: law@avialex.com 

Attorneys for BELT MAKERS, INC. 

RECEIVED 

JUN ~ 7 2013 

HEARING DOCKET 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of: 

BELT MAKERS, INC. 

FAA CASE NO. 2011WP910400 

FDMS: FAA-2013-0049 

BELT MAKERS, INC.'S OBJECTIONS 

AND RESPONSES TO 

COMPLAINANT'S DISCOVERY 

REQUEST 

Judge: The Honorable Richard C. Goodwin 

BELT MAKERS, INC. (hereinafter referred to as "BELT MAKERS" or 

"Respondent"), by and through its undersigned counsel, objects and responds to Complainant's 

First Request for Discovery, dated May 24, 2013 and received May 28, 2013. 

INTRODUCTION AND GENERAL OBJECTIONS 

This matter arises out of a September 16, 2011 inspection at BELT MAKER's facilities 

of its Antidrug Alcohol Misuse Prevention Program ("AAMPP:") by representatives of the 

FAA's Drug Abatement Division. 
FAA's Drug Abatement Division. 

Complainant alleges that the inspection revealed that BELT MAKERS had employed 

three persons in safety-sensitive functions when they were not in the random pool for drug and 

alcohol testing between the dates they were hired (May 16, 2011 for Maria Sanchez; May 23, 

201 for Samantha Villalobos; and February 2, 2011for Ernesto Mendoza) and September 20, 

2011, when they were eventually placed in the random pool. Complainant further determined 

that BELT MAKERS failed to retain documentation i) of training on drug use, and ii) that it had 

provided educational materials explaining alcohol testing requirements and its policies and 

procedures with respect to meeting those requirements for these three employees. 

With the exception of the allegations concerning retention of documentation, BELT 

MAKERS does not refute these allegations and freely admitted its mistake during Complainant's 

initial investigation almost two years ago. During the pendency of this action, BELT MAKERS 

has continued to fully admit and take full responsibility for them. That being the case, what 

other information could Complainant possibly need that would require its propounding this 

overly broad and unduly burdensome discovery? 

Inasmuch as the seminal issue in this case is sanction, Complainant's discovery is 

excessive, compound, complex, overly broad and unduly burdensome, transcending the 

boundaries of reasonable discovery and seeking information that is already within Complainant's 

possession, knowledge, care, custody and control. 

Complainant's discovery appears to have been motivated less by a genuine need for 

relevant and probative information, and more to drive up the costs and burdens of BELT 

FDMS: F AA-2013-0049 

BELT MAKERS's Objections and Responses to Complainant's Discovery 

Page 2 
MAKERS' defense of this action to bludgeon and badger BELT MAKERS into settlement. 

As for the contested factual allegations of the Complaint, specifically that BELT 

MAKERS failed to provide documentation of training given to supervisor Leonard Byrd, 

specifically, i) EAP initial training on reasonable cause, and ii) training for the purpose of 

qualifying him to make a determination concerning the need for alcohol testing based on 

reasonable suspicion, and AAMPP training to the employees Sanchez, Villalobos and Mendoza, 

Complainant's allegations are not supported by its own evidentiary file which clearly shows that 

training was given to these persons and that they signed for it. 

During the September 16, 2011 inspection, Complainant's Special Agents performed 

what they considered to be a comprehensive review of BELT MAKERS' AAMPP. They asked 

for no assistance from BELT MAKERS other than showing the FAA where the records were 

kept. Complainant did not ask for assistance in finding training records, nor did they advise that 

could not find them until several months later. When Complainant eventually advised BELT 

MAKERS that could not find the records during the September 16, 2011 inspection, BELT 

MAKERS immediately, and without any difficulty, found the records and furnished them. 

What makes these allegations even more outlandish is the existence of the exact 

documents Complainant alleges were unavailable are contained in in Complainant's 

Enforcement Investigative Report (See lOP# 3). 

Complainant's allegations as to training records are without merit and are based on 

Complainant's own deficient inspection and its ignoring information that is contained in its EIR 

and in no way indicative of BELT MAKER's record retention policy or procedures. All such 

FDMS: FAA-2013-0049 

BELT MAKERS's Objections and Responses to Complainant's Discovery 

Page 3 
records were were available on September 16, 2011. 

BELT MAKERS's investigation is ongoing and continuing and BELT MAKERS reserves 

the right to supplement or amend these Responses as its investigation proceeds up through the 

time of hearing. Accordingly, these Responses should be considered tentative at best. 

Finally, BELT MAKERS, in its Answer and Affirmative Defenses ("Answer"), has 

asserted numerous affirmative defenses and reserves the right to assert additionally affirmative 

defenses as they arise. Notwithstanding any response or admission contained herein, BELT 

MAKERS reasserts each and every affirmative defense contained in its Answer, which BELT 

MAKERS incorporates herein by this reference as if fully set forth herein. 

RESPONSES TO REQUESTS FOR ADMISSIONS 

The objections set forth above are hereby incorporated herein in their entirety as if fully 

set forth herein. Notwithstanding these objections, BELT MAKERS, based on its information 

and belief, responds to the Requests for Admissions as follows: 

RESPONSE TO REQUESTS FOR ADMISSIONS NOS. 1, 2, 3, 4, and 5: 

BELT MAKERS does not refute these allegations and freely admitted so during the 

Complainant's initial investigation almost two years ago and again in its Answer to Complaint 

filed on April 19, 2013. BEL TMAKERS has taken total responsibility for them and has initiated 

appropriate corrective actions. What else could Complainant possibly need? 

Inasmuch as the seminal issue is sanction, Complainant's discovery is excessive, 

FDMS: FAA-2013-0049 

BELT MAKERS's Objections and Responses to Complainant's Discovery 

Page4 
compound, complex, overly broad and unduly burdensome, transcending the boundaries of 

reasonable discovery and seeking information that is already within Complainant's possession, 

knowledge, care, custody and control. 

Complainant's discovery appears to have been motivated less by a genuine need for 

relevant and probative information, and more to drive up the costs and burdens of BELT 

MAKER's defense of this action to bludgeon BELT MAKER into settlement. 

BELT MAKERS objects to all discovery requests pertaining to the above as unduly 

burdensome, unneeded and unwarranted, and propounded for the sole purpose of badgering 

BEL TMAKERS into settling or withdrawing its appeal. 

REQUEST FOR ADMISSION NO.6: 

At all times relevant to the Complaint (the Final Notice of Proposed Civil Penalty), 

during the September 16, 2011, inspection referenced in Paragraph No.5 of the 

Complaint, Respondent was unable to provide documentation of EAP initial training on 

reasonable cause given to Leonard Byrd, a supervisor. 

RESPONSE: 

Denied. 

During the September 16, 2011 inspection, Complainant performed a comprehensive 

review of BELT MAKER's AAMPP. Complainant did not ask for assistance in finding the 

records for Mr. Byrd, nor did they advise that could not find the records for Mr. Byrd until 

several months later. 

FDMS: F AA-2013-0049 

BELT MAKERS's Objections and Responses to Complainant's Discovery 

Page 5 
When Complainant eventually advised BELT MAKERS that it did not find the records 

on the September 16,2011, BELT MAKERS immediately, and without any difficulty, found 

said records and furnished them to the FAA. 

What makes these allegations even more outlandish is the existence of the exact 

documents Complainant alleges were unavailable, in Complainant's Enforcement Investigative 

Report lOP# 3. 

Complainant's allegations as to Mr. Byrd are without merit and are based on 

Complainant's own deficient inspection and in no way indicative ofBELT MAKER's record 

retention policy or procedures. Mr. Byrd's records were available on September 16, 2011. 

REQUEST FOR ADMISSION NO. 7: 

At all times relevant to the Complaint (the Final Notice of Proposed Civil Penalty), 

during the September 16, 2011, inspection referenced in Paragraph No.5 of the 

Complaint, Respondent was unable to provide documentation of training provided to 

Leonard Byrd, a supervisor, for the purpose of qualifying him to make a determination 

concerning the need for alcohol testing based on reasonable suspicion. 

RESPONSE: 

Denied. 

During the September 16, 2011 inspection, Complainant performed a comprehensive 

review of BELT MAKER's AAMPP. Complainant did not ask for assistance in finding the 

records for Mr. Byrd, nor did they advise that could not find the records for Mr. Byrd until 

FDMS: FAA-2013-0049 

BELT MAKERS's Objections and Responses to Complainant's Discovery 

Page 6 
several months later. 

When Complainant eventually advised BELT MAKERS that it did not find the records 

on the September 16,2011, BELT MAKERS immediately, and without any difficulty, found 

said records and furnished them to the FAA. 

What makes these allegations even more outlandish is the existence of the exact 

documents Complainant alleges were unavailable, in Complainant's Enforcement Investigative 

Report lOP# 3. 

Complainant's allegations as to Mr. Byrd are without merit and are based on 

Complainant's own deficient inspection and in no way indicative ofBELT MAKER's record 

retention policy or procedures. Mr. Byrd's records were available on September 16, 2011. 

REQUEST FOR ADMISSION NO. 7: 

At all times relevant to the Complaint (the Final Notice of Proposed Civil Penalty), 

during the September 16, 2011, inspection referenced in Paragraph No.5 of the 

Complaint, Respondent was unable to provide documentation that it had provided the 

educational materials referenced in paragraph no. 29 of the Complaint to Maria 

Sanchez ... , Samantha Villalobos ... and Emesto Mendoza .... 

RESPONSE: 

Denied. 

During the September 16, 2011 inspection, Complainant performed a comprehensive 

review of BELT MAKER's AAMPP. Complainant did not ask for assistance in finding the 

FDMS: FAA-2013-0049 

BELT MAKERS's Objections and Responses to Complainant's Discovery 

Page 7 
records for these employees, nor did they advise that could not find the records until several 

months later. 

When Complainant eventually advised BELT MAKERS that it did not find the records 

on the September 16, 2011, BELT MAKERS immediately, and without any difficulty, found 

said records and furnished them to the FAA. 

What makes these allegations even more outlandish is the existence of the exact 

documents Complainant alleges were unavailable, in Complainant's Enforcement Investigative 

Report lOP# 3. 

Complainant's allegations as to the training given to these three employees are without 

merit and are based on Complainant's own deficient inspection and in no way indicative of 

BELT MAKER's record retention policy or procedures. These records were available on 

September 16, 2011. 

RESPONSES TO INTERROGATORIES 

The objections set forth above are hereby incorporated herein in their entirety as if fully 

set forth herein. Notwithstanding these objections, BELT MAKERS, based on its information 

and belief, responds to the Interrogatories as follows: 

INTERROGATORY NO. 1: 

For each of the above requests for admission that you do not admit, explain what specific 

facts or contentions in each statement you believe are not true, state all facts that support 

FDMS: F AA-2013-0049 

BELT MAKERS's Objections and Responses to Complainant's Discovery 

Page 8 
your beliefs in this regard, and produce all documents that support these beliefs. 

RESPONSE TO INTERROGATORY NO.1: 

Regarding Request For Admissions Nos. 6, 7 and 8, during the September 16, 2011 

inspection, Complainant performed a comprehensive review of BELT MAKER's Antidrug 

AAMPP. Complainant did not ask for assistance in finding records, nor did they advise that 

could not find the records until several months later 

When Complainant eventually advised BELT MAKERS that they did not find the records 

on the September 16, 2011, BELT MAKERS immediately, and without any difficulty, found 

said records. 

What makes these allegations even more outlandish is the existence of the exact 

documents Complainant alleges were unavailable, in Complainant's Enforcement Investigative 

Report lOP# 3. 

Complainant's allegations as to Mr. Byrd and the three named employees are without 

merit and are based on Complainant's own deficient inspection and in no way indicative of 

BELT MAKER's record retention policy or procedures. These records records were available on 

September 16, 2011. 

INTERROGATORY NO.2: 

Identify each person whom you intend to call as a witness at the hearing in this matter 

and for each such witness, provide a summary of the expected testimony. 

FDMS: FAA-2013-0049 

BELT MAKERS's Objections and Responses to Complainant's Discovery 

Page 9 
RESPONSE TO INTERROGATORY NO.2 

BELT MAKERS has not yet decided who will be called to testify and discovery is currently 

ongoing. Without waiving said objections, Respondent currently intends to call the following 

persons to testify at hearing: 

1) Tim Dunlop, President ofBELTMAKERS; 

2) Leonard Byrd; 

3) Maria Sanchez; 

4) Samantha Villalobos; and 

5) Ernesto Mendoza. 

BELT MAKERS further reserves the right to call as its witnesses any persons identified 

in Complainant's Enforcement Investigative Report (EIR), any persons now or hereinafter 

identified by Complainant as its witnesses and any persons who may be called to testify by 

Complainant at deposition or at hearing in this matter. 

The substance of the testimony of Mr. Dunlop should be readily apparent to Complainant 

who has already provided written responses to all of Complainant's communications regarding 

alleged compliance issues. BELT MAKERS incorporates and adopts as if fully set forth herein 

the previous communications. This testimony will include, but not be limited to the purpose and 

preparation BELT MAKERS's AAMPP; the FAA base inspection during which the alleged 

discrepancies were discovered; BELT MAKERS's response to the FAA findings; BELT 

MAKERS's immediate and comprehensive corrective actions, including but not limited to 

revision of it personnel and hiring practices, the AAMPP, its Antidrug Alcohol Misuse 

FDMS: FAA-2013-0049 

BELT MAKERS's Objections and Responses to Complainant's Discovery 

Page 10 
Prevention Training Program, and additional training for all personnel involved. Mr. Byrd, Ms. 

Sanchez, Ms. Villalobos and Mr. Mendoza will testify as to the AAMPP training that they were 

furnished by BELT MAKERS and the documentation of their training. 

BELT MAKERS may also utilize personnel from the TAG/ AMS Consortium, which has 

developed the AAMPP, the training program and the documentation for such training. 

Investigation and discovery are ongoing and continuing, and BELT MAKERS reserves 

the right to amend and/or supplement these responses up through the date of hearing. 

BELT MAKERS further reserves the right to utilize other witnesses, not identified 

herein, for impeachment purposes. 

INTERROGATORY NO.3: 

For each person identified in response to Interrogatory No.2, produce a copy of each and 

every statement made by that person in which the facts and circumstances of matters at 

issue in this case are referenced or discussed. 

RESPONSE TO INTERROGATORY NO.3: 

BELT MAKERS objects to this Request to the extent that it seeks documents covered by 

the attorney-client privilege, protected by the work-product doctrine or which are already in 

Complainant's possession, care, custody or control, and/or which have been heretofore produced 

by BELT MAKERS and provided to Complainant. 

To the extent that it has not already done so, BELT MAKERS will provide copies of all 

documents, including statements, it intends to submit at hearing. Investigation and discovery are 

FDMS: FAA-2013-0049 

BELT MAKERS's Objections and Responses to Complainant's Discovery 

Page 11 
ongoing and continuing, and BELT MAKERS reserves the right to amend and/or supplement 

these responses up through the date of hearing. 

Finally, BELT MAKERS reserves the right to utilize at hearing any document not 

identified in these Objections and Responses to Request for Production which may be utilized by 

Complainant and/or for purposes of impeachment. 

INTERROGATORY NO.4: 

Do you intend to present any expert witness testimony at the hearing of this matter? If so, 

then provide a synopsis of each expert witness' testimony, state the grounds for each 

expert opinion, and produce curriculum vitae for each expert witness. 

RESPONSE TO INTERROGATORY NO. 4: 

BELT MAKERS has not retained any experts in this case and does not, at this time, 

intend to call any expert witnesses. 

Notwithstanding the foregoing, BELT MAKERS reserves the right to seek expert 

testimony from any persons identified in Complainant's EIR, any persons now or hereinafter 

identified by Complainant as its witnesses and/or experts and any persons who may be called to 

testify by Complainant in this matter and/or any person who may offer expert testimony on 

Complainant's behalf. 

Investigation and discovery are ongoing and continuing, and BELT MAKERS reserves 

the right to amend and/or supplement these responses up through the date of hearing. 

FDMS: F AA-2013-0049 

BELT MAKERS's Objections and Responses to Complainant's Discovery 

Page 12 
INTERROGATORY NO. 5: 

Do you contend that Belt Makers, lacks the ability to pay the proposed civil penalty If so, 

then state every fact upon which you intend to rely at the hearing in support of this 

contention, and produce a copy of each and every document you intend to introduce at 

the hearing in this matter in support of this contention. 

RESPONSE TO INTERROGATORY NO. 5: 

BELT MAKERS is reviewing its financials and intends to amend this answer at a later 

time. However, until such time as an appropriate protective order is issued precluding the public 

availability, release or dissemination of any such information, BELT MAKERS objects to this 

request. 

INTERROGATORY NO.6: 

To the extent not encompassed in your response to any of the foregoing items, identify 

and produce all documents upon which you expect to rely at the hearing or introduce as 

evidence in support of your position at the hearing in this matter. 

RESPONSE TO INTERROGATORY NO.6: 

BELT MAKERS's provided Complainant with documentation evidencing and 

substantiating BELT MAKERS' corrective and responsive actions. BELT MAKERS intends to 

utilize all such documents as exhibits at hearing. In the interests of economy, they are not being 

reduplicated as they are already in Complainant's possession, care, custody or control. 

FDMS: F AA-2013-0049 

BELT MAKERS's Objections and Responses to Complainant's Discovery 

Page 13 
BELT MAKERS reserves the right to utilize additional documents that may not exist as 

of the date of these responses but as they may be developed in the future to evidence 

BEL TMAKERS' ongoing corrective actions. 

At this moment, BELT MAKERS does not anticipate introducing any exhibits other than 

those documents that are already in Complainant's possession, care, custody or control or have 

already been provided by BELT MAKERS to Complainant during or incident to the 

investigation or which have been identified above. However, BELT MAKERS reserves the right 

to introduce any document referenced in the EIR, the AAMPP, Training Manuals, Personnel 

Manuals and other then-current Company policies and procedures and any subsequently 

discovered exhibits. BELT MAKERS also reserves the right to utilize any documents that have 

been or will be produced by Complainant or which may be utilized by Complainant at hearing. 

BELT MAKERS reserves the right to amend and/or supplement these responses up through the 

date of hearing and further reserves the right to utilize other documents, not previously 

identified, for impeachment purposes. 

INTERROGATORY NO.7: 

Describe with specificity and in detail any and all affirmative defenses you intend to 

assert at the DOT administrative hearing in this matter. 

RESPONSE TO INTERROGATORY NO.7: 

BELT MAKERS objects to Interrogatory No.7, as each ofthe Denials and Affirmative 

Defenses contained in BELT MAKERS's Answer clearly speak for themselves. 

FDMS: FAA-2013-0049 

BELT MAKERS's Objections and Responses to Complainant's Discovery 

Page 14 
Additionally, BELT MAKERS reserves the right to assert additional affirmative defenses 

as they arise. Notwithstanding any response or admission contained herein, BELT MAKERS 

reasserts each and every affirmative defense contained in its Answer, which BELT MAKERS 

incorporates herein by this reference as if fully set forth herein. 

INTERROGATORY NO. 8: 

Describe with specificity and in detail all of the facts and arguments which Respondent 

anticipates presenting in the course of the hearing in this matter pertaining to mitigation 

of the sanction sought by Complainant in this case. 

RESPONSE TO INTERROGATORY NO.8: 

BELT MAKERS objects to Interrogatory No.8, as each ofthe Denials and Affirmative 

Defenses contained in BELT MAKERS's Answer clearly speak for themselves. See 

Complainant's own Sanction Guidance Table contained in Order 2150.3B, under which the 

penalty sought by Complainant in this case is clearly excessive and unreasonable, particularly for 

a small business concern such as BELT MAKERS. 

Additionally, BELT MAKERS reserves the right to assert additional affirmative defenses 

as they arise. Notwithstanding any response or admission contained herein, BELT MAKERS 

reasserts each and every affirmative defense contained in its Answer, which BELT MAKERS 

incorporates herein by this reference as if fully set forth herein. 

FDMS: FAA-2013-0049 

BELT MAKERS's Objections and Responses to Complainant's Discovery 

Page 15 
INTERROGATORY NO. 9: 

State all facts upon which you base the contention asserted in your First Affirmative 

Defense of your Answer. 

RESPONSE TO INTERROGATORY NO. 9: 

BELT MAKERS objects to Interrogatory No. 9, as the First Affirmative Defense clearly 

speaks for itself. 

INTERROGATORY NO. 10: 

State all facts upon which you base the contention asserted in your Second Affirmative 

Defense ofyour Answer. 

RESPONSE TO INTERROGATORY NO. 10: 

BELT MAKERS objects to Interrogatory No. 10, as the Second Affirmative Defense 

clearly speaks for itself. 

INTERROGATORY NO. 11: 

State all facts upon which you base the contention asserted in your Third Affirmative 

Defense of your Answer. 

RESPONSE TO INTERROGATORY NO. 11: 

BELT MAKERS objects to Interrogatory No. 11, as the Third Affirmative Defense 

clearly speaks for itself. 

FDMS: FAA-2013-0049 

BELT MAKERS's Objections and Responses to Complainant's Discovery 

Page 16 
INTERROGATORY NO. 12: 

State all facts upon which you base the contention asserted in your Fourth Affirmative 

Defense ofyour Answer. 

RESPONSE TO INTERROGATORY NO. 12: 

BELT MAKERS objects to Interrogatory No. 12, as the Fourth Affirmative Defense 

clearly speaks for itself. 

INTERROGATORY NO. 13: 

State all facts upon which you base the contention asserted in your Fifth Affirmative 

Defense ofyour Answer. 

RESPONSE TO INTERROGATORY NO. 13: 

BELT MAKERS objects to Interrogatory No. 13, as the Fifth Affirmative Defense clearly 

speaks for itself. 

INTERROGATORY NO. 14: 

State all facts upon which you base the contention asserted in your Sixth Affirmative 

Defense ofyour Answer. 

RESPONSE TO INTERROGATORY NO. 14: 

BELT MAKERS objects to Interrogatory No. 14, as the Sixth Affirmative Defense 

clearly speaks for itself. See Order 2150.3B. 

FDMS: FAA-2013-0049 

BELT MAKERS's Objections and Responses to Complainant's Discovery 

Page 17 
INTERROGATORY NO. 15: 

State all facts upon which you base the contention asserted in your Seventh Affirmative 

Defense ofyour Answer. 

RESPONSE TO INTERROGATORY NO. 15: 

BELT MAKERS objects to Interrogatory No. 15, as the Seventh Affirmative Defense 

clearly speaks for itself. 

INTERROGATORY NO. 16: 

State all facts upon which you base the contention asserted in your Eighth Affirmative 

Defense ofyour Answer. 

RESPONSE TO INTERROGATORY NO. 16: 

BELT MAKERS objects to Interrogatory No. 16, as the Eight Affirmative Defense 

clearly speaks for itself. Additionally, at least one FAA Special Agent contacted 

BEL TMAKERS' customers and end users, not in connection with any legitimate investigative 

function, but for the purpose of harming business relationships and causing BEL TMAKERS 

substantial loss ofbusiness and causing hardship for BELTMAKERS and its owner, 

management and employees. 

DATED this u 

~ day of June, 2013. 

FDMS: FAA-2013-0049 

BELT MAKERS's Objections and Responses to Complainant's Discovery 

Page 18 
... ·~ 

CERTIFICATE OF SERVICE 

The undersigned hereby certifies that on this fi!!aay of June, 2013, a true and correct 

copy ofthe foregoing BELT MAKERS, INC.'S OBJECTIONS AND RESPONSES TO 

COMPLAINANT'S DISCOVERY was served as follows: 

The Honorable Richard C. Goodwin 

Administrative Law Judge 

Office ofHearings, M-20 

Department of Transportation 

1200 New Jersey Avenue, S.W. 

Washington, DC 20590 

FAX: 1-202-366-7536 

{FAX and FED EX} 

Federal Aviation Administration 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2W1 000 

800 Independence A venue SW 

Washington, DC 20591 

{FEDEX) 

Lisa Toscano, Esq. 

Federal Aviation Administration 

Office of the Regional Counsel 

Western-Pacific Region, AWP- 7 

15000 Aviation Boulevard 

Lawndale, CA 90261 

FAX: 1-310-725-6816 

{FAX and FED EX} 

Caitlin Miller 

FDMS: FAA-2013-0049 

BELT MAKERS's Objections and Responses to Complainant's Discovery 

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