12/B5/2B15 B9:45 4252271007 

DAvroF, SHAYNE 

FAA 0FFJCE OF REGION At COUNSEL 

160! LIND AVE., SW 

RENTON, WASHINGTON 98057 

TELEPHONE: ( 425) 227-2165 

FACSIMILE: (425) 227-1007 

ANM7 

UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORT A TlON 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the M~tter of: 

William A. Curtright 

Docket No. FAA-2015-!319 

FAA Case No. 2014NM090046 

Judge J. E. Sullivan 

COMPLAINANT'S RESPONSES TO RESPONDENT'S REQUEST FOR 

INTERROGATORIES AND PRODUCTJON OF DOCUMENTS 

PAGE 02/10 

Complainant hereby responds to the Respondent's Request for Interrogatories and Production 

of Documents, in the above-captioned matter as follows; 

INTERROGATORIES 

INTERROGATORY No. 1: Describe with specificity aU of the facts and arguments which 

you anticipate presenting in the course of the Department of Transportation (DOT) 

hearing in this matter pertaining to the civil penalty arnollilt that the FAA seeks in this 

case of action. 

Answer; Complainant's allegations are set forth in the Complaint filed in this 

matter aod the disclosures previously provided. 

FAA v. William A Curtright 

Docket No, FAA-2015-1319 

PAA C<loo No, 2014NM090046 

Page 1 of9 

DAVID F. SHAYNE. FAA ATTORNlW 

TEL: (425) 227-2165; FIIX: (425) 227·1007 
12/05/2015 09:45 4252271007 ANM7 PAGE 03/10 

INTERROGATORY No.2: De8cribe with specificity all of the facts and arguments which 

you anticipate presenting in the course of the Department of Transportation (DOT) hearing in 

this matter pertaining to the civil penalty amount sought by the FAA in the case of action. 

Answer: See Answer to lnter.-ogatory 1. 

INTERROGATORY No.3: Describe with specificity all of the facts and arguments which 

you anticipate presenting in the course of the Department of Transportation (DOT) hearing 

in this matter identifYing the grounds that will show a genuine issue of material fact. 

Answe.-: See Answer to Interrogatory 1. 

INTERROGATORY No. 4: Describe with specifi.city all of the facts and arguments 

which you anticipate presenting in the course of the Department of Transportation (DOT) 

hearing in this matter identifYing why the FAA believes a civil pena.Jty of $11,000.00 as 

being appropriate for the alleged violation of Section 14. C.F.R. 91.417(c). 

Answer: Ob,jection, calls for legal opinion, not for information likely to lead to 

admissible evidence. Notwithstanding and while not waiving ob.iection, See FAA 

Order 2150.3B Appendix B page 8. 

INTERROGATORY No. 5: Describe with specificity all of the facts and arguments which you 

anticipate presenting .in the course of the Department of Transportation (DOT) hearing the 

FAA's explanation of why they arc proposing an $11,000.00 fine as the civil penalty, and what 

forms the basis for the maximum amotmtallowed. 

Answer: See Answer to Interrogatory 4. 

INTERROGATORY No. 6: Describe with specificity all ofthe facts and arguments which 

you anticipate presenting in the course of the Department of Transportation (DOT) hearing 

in this matter identifYing why the FAA had offered a settlement of $5,000.00. 

Answer; 

evidence. 

ObJection, irrelevant, not for information likely to lead to admissi.ble 

INTERROGATORY No. 7: Describe with specificity all of the facts and arguments which 

you anticipate presenting i.n the course of the Dcpartm~nt of Transportation (DOT) hearing in 

this matter identifying why the FAA had offered a settlement of $3,500.00 for full settlement 

ofthis case. 

FAA v, William A. Cttrtl·lghi 

Docket No. FAA-2015-1319 

FAA Case No. 2014NM090046 

Page 2 of9 

01\VIl) P, SHAYNE. fAA ATTORNBY 

TEL: (425) 227·2165; FAX: (425)227-1007 
Answer: 

evidence. 

4252271007 ANM7 

Objection, irrelevant, not for inform.~ti.on likely to lead to admissible 

PAGE 04/10 

JNTERROGATORY No. 8: Identify by name, address and telephone ntm1ber, all persons 

whom you discussed at your agency regarding tl1e FAA offered settlement of$5,000.00. 

Answer: 

evidence. 

Objection, irrelevant, not for information likely to lead to admi~siblc 

INTERROGATORY No. 9: IdentifY by name, address and telephone number, all persons 

whom you discussed at your agency regarding ilie FAA offered settlement of$3,5000.00. 

Answer: 

evidence. 

Objection, irrelevant, not for iuformation likely to lead to admissible 

INTERROGATORY No 10: IdentifY by name, address and telephone number all persons 

whom you !mow to have personal knowledge of the matters alleged in the Complaint. 

Answer: FAA investigators Marty Conroy, William McKibbon and Curt Cowley. 

INTERROGATORY No. ll: IdentifY by title, date, author, present custodian, and 

content, all documents, including correspondence, obtained by you or in your 

possession, relating to ilie assertions in the Complaint, and evidence that Respondent did 

not provide tbe documentation that was requested of him under Section 14 C.F.R. 

91.417(c). 

Answer: All of the documents responsive to this request were previously 

identified and provided in initial disclosures. 

INTERROGATORY No. 12: Identify by name, address and telephone number, all 

persons whom you intend to hllve testifY as a factual or expert witness in support of your 

complaint at the hearing in this matter, and for factual witnesses, provide a detailed 

summary of each persons anticipated testimony. 

Answer: Previously provided in initial disclosures. 

FAA v, William A Curtright 

Docket No. PAA-20 !5-1319 

FAA Case No. 2014NM09004& 

Pogc3 or9 

DAVID F. SJ.lA YNTI. F'AA ATTQ'RN'T?,Y 

TEL: (425) 227"2165; F J\X: (425) 227·1007 
12/05/2015 09:45 4252271007 AN~I7 

INTERROGATORY No. 13: Identify by title, date, author, present custodian, and content, 

aU documents which you anticipate offering into evidence at the hearing in this matter, and 

through which witness or witnesses. 

Answer: Sec Answer to Interrogatory 11. 

INTERROGATORY No. 14: With respect to each expert witness identified in response 

to Interrogatory No.l2, above, specify their specific area of expertise, and provide a 

synopsis of their credentials, background, training and experience. 

Answer: Complainant does not anticipate calling expert witness, notwithstanding 

the foregoing, Marty Conroy would qualify as an expert in general aviation-aircraft 

operations by virtue of his t.-aining and experience as a professional pilot and FAA 

Inspector. 

INTERROGATORY No. 15: With respect to each expert you expect to call as a witness, 

state the subject matter on which the expert is expected to testify, and state the substance of 

the facts and opinions to which the expert is expected to testify, an.d a summary of the 

grounds for each such opinion. 

Answer: See Answer to Interrogatory 14. 

INTERROGATORY No. 16: State by name, address, telephone number, date of 

conversation, and substance of conversation, all persons with whom you have discussed 

the matters alleged in the Complaint. 

Answer: See Answers to Interrogatory lO and ll. 

INTERROGATORY No. 17: If you deny any or all of Requests for Admissions, 

please explain in detail the specifi.c reason for each and every fact denied. 

Answer: Not applicable. 

INTERROGATORY No. 18: If you deny any or all of Request for Admissions please 

explain in detail the specific reason for each and every fact denied and sate specifically 

whether you had a conversation with ASI Comoy and, if so, wba.t is your recollection of 

the conversation. 

PAGE 05/10 

PAA v, William A. Curtrlght 

DockelNo. PAA-2015-1319 

fAA Case No. 2014NM090046 

Page 4 of9 

DAVID f. SHAYNE, FAA ATTORNEY 

TEL: (425) 227-2165: FAX: (425) 227·1007 
12/05/2015 09:45 4252271007 ANM7 

Answer: Not applicable. 

INTERROGATORY No. 19: With respect to FAA attomey David F. Shayne, please describe if you are a pen:oanent employee of the FAA or a contracted attorney with the FIV\. 

Answer: 

evidence. 

Objection, irrelevant, not for infol'mation likely to lead to admissible 

INTERROGATORY No. 20: With respect to FAA attorney David F. Shayne, please 

describe if you are a contracted attorney with the F M if you receive a percentage payment 

based on the amount of civil penalties are collected by you or the FAA. 

Answer: 

evidence. 

Objection, irrelevant, not for information likely to lead to admissible 

REQUEST FOR PRODUCTION 

REQUEST FOR PRODUCTION NO. 1: Provide a copy of all documents referred to 

in your answer to the preceding interrogatories No. 1 through No. 20. 

Answer: See Answer to Interrogatory U. 

REQUEST FOR ADMISSIONS 

PAGE 05/10 

REQUEST FOR ADMISSION No I. Admit that Attachment l is a true and correct copy 

of an electronic mail message (email) you sent to Wm. Ames Curtright, DBA on October 

14, 2015 and an electronic mail message (email) Wm. Ames Curtright, DBA sent to you, 

David F. Shayne on October 14, 2015. 

Answel': Admit. 

FAA v. William A. Curtright 

Docket No. FAA-2015-1319 

FAA Cn.« No. 20 14NM090046 

Page 5 of9 

DAVID F. SHAYNF., fAA ATTORNJ?:Y 

TEL: (425) 227-2165: FAX: (425) 227·1007 
12/05/2015 09:45 4252271007 ANM7 

REQUEST FOR ADMISSION No 2. Admit that Attachment 2 is a true and correct 

copy of a speed merna that was attached to the October 14,2015 electronic mail message 

(email) (document request for admission No. l) from the FAA in Hillsboro, Oregon to 

Marty G. Conroy cc: Bill McKibbon regarding INSPECTOR STATEI\.1ENT. 

Answer: Admit. 

REQUEST FOR ADMISSION No 3. AdmitthatAttachment 3 is a true and correct 

copy ofthe Compla.int that the FAA fikd with the United States Of America 

Department of Transportation Office of Hearings Washington, D.C. by FAA 

attorney David F. Shayne against William A. Curtright with case no. FAA 

Case No. 2014NM090046. 

Answer: Admit. 

REQUEST FOR ADMISSION No 4. Admit that Attachment 4 is a true and correct 

copy of a A SECTION B Statement of Case and Factors Affecting Sanction produced 

by the FAA in their initial disclosure statement in C~.se No. 201 4NM090046. 

Answer: Admit. 

REQUEST FOR ADMISSION No 5. Admit that Attachment 5 is a true and correct 

copyofa letter to Mm:tin. G. Conroy from Dr. W. Ames Curtright, dated 

September 9, 2014 re: EIR Number 2014NM090046 with attachments of 

Oregon Aircraft Registration Certificate; Memorandum from Ben W. Davidson 

to William Ames Curtright dated August 26, 2014;medical Certificate Third 

Class; electronic maiJ message (emaH) from William Arnes Curtright to 

Marty Conroy dated July 7, 2014 with subject N949JP Information, The 

Standard Pilot Log book. 

Answer: Admit. 

REQUEST FOR ADMISSION No 6. Admit that Attachment 6 is a true and correct 

copy of a electron.ic mail message (email) from William Ames Curtright to 

Marty Conroy dated August 2 8, 20 !4 s~1bject N949JP Information, 

Answer: Admit. 

PAGE 07/10 

REQUEST FOR ADMISSION No 7. Admit that Attachment 7 is a true and correct copy 

of a Decision and Order in the matter of Premier Jets, Inc. with FAA Order No. 99-

7 Served August 31, J 999, with Docket No. CP97NM0005 that was sent to FAA 

attorney David F. Shayne with ~espondent's additional disclosures pursuant to 

FRCP 269l(a) on September 20", 23016. 

PAA v. Wi!Iifl.rn A Curtri,ght 

Docket No. FAA"201S"il 19 

PAA c,c No, 2014NM090046 

rage 6 of9 

DAV!D F', SHAYNE, .F 1\1\ J\.TTORNBY 

TEL; (425) 227-2165: FAX: (425) 227-1007 
12/05/2015 09:45 4252271007 ANM7 

Answer: Complainant is unfamiliar with this document, and lacks information on its authenticity therefore denies. 

REQUEST FOR ADMISSION No 8. Admit that AttachmentS is a true and correct 

copy of a photo's ofN949JP log book 1, 2 and 2 produced to FAA attorney 

David F. Shayne with Respondent Initial Disclosures Pursuant to the ALJ' S Order of August 10, 2016 and FRCP 269(a) on September 9, 2016 by Respondent. 

Answer: Admit. 

REQUEST FOR ADMISSION :No.9. Admit that Attachment 9 is a true and correct 

copy of a email fTom Scott Myers of FAA to Patty Abel dated July 30, 

2015 regarding that they a.re in receipt of Mr. Curtright's email dated July 

27, 2015. 

Answer: Admit. 

REQUEST FOR ADMISSION No !0. AdmitthatAttachmcnt 10 is a true and 

correct copy of a electronic mail message (email) from Dr. William A. Curtright, 

DBA to Judge Richard Goodwin cc: Patricia Matthew and David F. Shayne 

dated August II, . 2015 re: Reply . to FAA's Motion; with electronic mail 

message (email) from patty Abel to Bill McKibbon and Scott Myers of 

FAA dated July 30, 2015 regarding if they had received the documents sent 

on July 27, 2015. 

Answer: Admit. 

REQUEST FOR ADMISSION No. II. Admit that Attachment 11 is a true and 

correct copy of a electronic mail message (email) from Dr. W.illiam A. Curtdght, 

DBA to David Shayne dated July 23, 2015 regarding flight logs, weight and 

balance with attachments of FAA Approved Airplane flight manual 

supplement 2 with a total of 4 pages; Supplemental Type Certificate dated 

March I, 2011. 

Answer: Admit. 

PAGE 08/10 

FAA. v, Willi;;~rn A Curtright 

OockeJ:No. FAA-20.15-!3.19 

fAA Ca,oNo. 2014NM090046 

Page 7 of9 

DAV!D F, S!-!AYNE~ FA/\ ATtORNEY 

TEL: (1·25) 227-2165: FAX: (425) 227-1007 
12/05/2015 09:45 4252271007 ANM7 

REQUEST FOR ADMISSION No. 12. Admit that Attachment 12 is a true 

and correct copy of a letter dated July 22, 2015 from Dr. Wm. Ames 

Curtright, DBA to Bill McKibbon and Scott Myers of Flight Standards Dist. 

Office rc: EIR number 20!4NM0900046. 

Answer: Admit. 

REQUEST FOR ADMISSION No. 13. Admit that Attachment 13 is a true 

and correct copy of a letter d~ted May 11, 2015, from Dr. Wm. Ames 

Curtright, DBA to Martin Conroy Aviation Safety Inspector re: Case No. 

20 14NM090046. 

Answer: Admit. 

REQUEST FOR ADMISSION No. 14. Admit that Attachment 14 is a true 

and correct copy of a letter dated May 11,2015 from Dr. Wm. Ames 

Curtright, DBA to Scott Myers re: FAA Case No. 2014NM090046. 

Answer: Admit. 

~i\A v. William A. Ctlrtfight 

Docket No. F AA-20 I S-13 I .9 

FAA Cn~oNo. 2014NM090046 

Page 8 of9 

0AVfr) F, SHAYNP .• FAA A'T1'0RNP.Y 

TEL; (425) 227·2165; FAX: (425) 227·1007 
12/05/2015 09:45 4252271007 ANM7 

CERTIFICATE OF SERVICE 

l hereby certizy that the foregoing Complainant's Responses to Respondent's Request for 

Interrogatories and Production of Documents has been served this date, to the following: 

Judge J .E. Sullivan (Facsimile and First Class Mail) 

U.S. Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Ave., S.E. (Ell-310) 

Washington, D.C. 20590 

Fax.: (202) 366-7536 

Federal Aviation Administration (Facsimile and First Class Mail) 

800 Independence Avenue SW 

Washington, D.C. 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2Wl000 

Fax: (202) 267-1293 

William A Curtright (First Class Mail and Certified Mail- Return 

Receipt Requested) 

P.O. Box 1350 

Jefferson, OR 97352 

Dated this 61

h day of December 20 16. 

JeffKamb , Legal Tech 

Office of Regional Counsel (A .. -7) 

Federal Aviation Administrat'on 

1601 Lind Ave. SW 

Renton, WA 98057 

PAGE 10/10 

FAA v. Wil1ilu'l1 A, ('.I,J1'1',rig:ht 

OcokctNo. FAA-2015-1319 

FAA Ca.;o No. 2014NM090046 

Page 9 of9 

DAVID f.', SHAYNE, J7;\l\ ATTORNEY 

TEL: (425) 227,2165; FAX: (425) 227-1007 
12/05/2015 09:45 4252271007 ANM7 PAGE 01/10 

Federal Aviation 

Administration 

Hearing Docket Clerk, AGC-430, and Judge Office of the Regionol Counsel, ANM-7 

1601 Lind Ave., S,W, To: J.E. Sullivan. 

Phone: 

Fax: j202) 267-1293, 202-366-7536, 

From: David Shayne 

Title: FAA Attorney, ANM-7 

December6, 2016 

Date: 

10 

Pages w/cover: 

D Per your Request 

D For Coordination 

NOTES/COMMENTS: 

Renton, WA 98057 

Telephone: (425) 227-1165 

Facsimile: (425) 227-1007 

Email: 

Facsimile 

Description of item being transmitted: 

Complainant's Responses to Respondent's 

Request for Interrogatories and Production 

for Documents 

D For Review D Please Comment 

J( Hard Copy to Follow via U.S, Mail 

RE: William A Curtright, Docket No. FAA-2015-1319 

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