UNITED STATES DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

IN THE MATTER OF 

MACH ONE AIR CHARTERS, INC. 

FAA DOCKET NO. [TO BE ASSIGNED] 

(Civil Penalty Proceedings) 

FDMS NO. FAA-2015-0643 

RECEIVED 

JUN 2 2 2015 

HEARING DOCKET 

COMPLAINANT'S FIRST SET OF REQUESTS FOR ADMISSION, 

INTERROGATORIES, AND REQUESTS FOR PRODUCTION OF DOCUMENTS 

To: MACH ONE AIR CHARTERS, INC. 

Through counsel 

Pursuant to 14 C.P.R.§ 13.220, the Complainant, by and through its Regional Counsel, 

requests that Mach One Air Charters Inc., (hereinafter "Mach One") by July 15, 2015, make the 

requested admissions, answer the following interrogatories under oath, and identify and produce 

the requested documents for inspection and copying at the Office of the Regional Counsel, 

Alaskan Region FAA, 222 W. 7"' Avenue, Box 14, Anchorage, Alaska 99513-7587. 

These requests are deemed continuing, and any information secured after answering 

and/or supplying the requested answers or documents/items is to be supplied by supplemental 

production pursuant to § 13 .220(i) of the Rules of Practice in FAA Civil Penalty Actions. 

BE ADVISED that 14 C.P.R.§ 13.220(1)(1) states, "A party's failure to respond to a 

request for admission, in writing and signed by the attorney or the party, not later than 30 days 

after service of the request, is deemed an admission of the truth of the statement or statements 

contained in the request for admission." 

DEFINITIONS 

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

manual, memorandum, record, report, statement, study, drawing, sketch, photograph, telegram, 

telex, or message, whether reported, transcribed, punched, taped, filmed or graphically 

represented in any manner, or material of any kind in the possession of, subject to the control of, 

or within the knowledge of, Respondent and/or his employees, agents, consultants, or experts. 

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

name, current or last known address, employer, and job description or title, and telephone 

number. 

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

document. 

4. As listed herein, singular pronouns also include the plural. 

5. "You," "your," and "Respondent" as used herein refer to Mach One, the Respondent in 

this matter. 

REQUESTS FOR ADMISSION 

Please admit the truth of each of the following statements: 

1. If the outside air temperature gauge on civil aircraft N881A was not functioning properly 

as alleged in paragraph 12 of Section II of the complaint at the time of the flights 

referenced in paragraphs 9 (as amended) and 1 0 of Section II of the complaint, then civil 

aircraft N881A would not have been in airworthy condition. 

2. If the left engine air intake anti-ice system on civil aircraft N881A was not functioning 

properly as alleged in paragraph 12 of Section II of the complaint at the time ofthe 

flights referenced in paragraphs 9 (as amended) and 10 of Section II of the complaint, 

then civil aircraft N881A would not have been in airworthy condition. 

3. At the time of the flights referenced in paragraphs 9 (as amended) and 10 of Section II of 

the complaint, there was no maintenance record entry in the maintenance records for civil 

aircraft N881A regarding any maintenance performed during the period May 10-12, 

2014, while the aircraft was in St. Paul, Minnesota. 

4. At the time of the flights referenced in paragraphs 9 (as amended) and 10 of Section II of 

the complaint, any maintenance that had been performed on civil aircraft N881A during 

the period May 10-12,2014, while the aircraft was in St. Paul, Minnesota, had not been 

approved for return to service. 

INTERROGATORIES AND REQUESTS FOR PRODUCTION 

1. For each of the above requests for admission that Mach One does not unequivocally 

admit, explain what specific facts or contentions in each statement Mach One believes are 

not true, state all facts that support its beliefs in this regard, and produce all documents 

that support these beliefs. 

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2. Identify each person whom Mach One intends to call as a witness at the hearing in this 

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

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. 

4. Does Mach One 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 a curriculum vitae for each expert witness. 

5. Does Mach One contend that it lacks the ability to pay the proposed civil penalty? If so, 

then state every fact upon which it intends to rely at the hearing in support of this 

contention, and produce a copy of each and every document it intends to introduce at the 

hearing in this matter in support of this contention. 

6. To the extent not encompassed in its response to any of the foregoing items, identify and 

produce all documents upon which Mach One expects to rely at the hearing or introduce 

as evidence in support of its position at the hearing in this matter. 

Served this 15th day of June 2015. 

HOWARD L. MARTIN, JR 

Regional Counsel 

By:~~Wl1~~ Glenn H. Brown 

Senior Attorney 

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CERTIFICATE OF SERVICE 

Re: Mach One Air Charters, Inc. 

FAA Case No. 2014WP210018 

DMS NO. FAA-2015-0643 

I hereby certify that on this date I served a copy of the COMPLAINANT'S FIRST SET OF . 

REQUESTS FOR ADMISSION, INTERROGATORIES, AND REQUESTS FOR 

PRODUCTION OF DOCUMENTS postage-prepaid, certified mail, return receipt requested, 

addressed as follows: 

H. Dan Hill, CEO 

Mach One Air Charters, Inc., Respondent 

7000 Merrill Avenue, #63 

Chino, CA 91710 

Steven L. Graff, Respondent's counsel 

Steven L. Graff, Inc. 

43399 Calle De Velardo 

Temecula, CA 92592 

I further certify that on this date I have served the original and a copy of the 

COMPLAINANT'S AMENDMENT OF COMPLAINT by postage-prepaid, certified mail, 

return receipt requested, addressed as follows: 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

ATTN: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2W1000 

Office of the Regional Counsel 

222 West 7th Avenue #14 

Anchorage, Alaska 99513-7587 

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