UNITEDSTATESOFAMERICA 

# OE·CEIVED U.S. DEPARTMENT OF TRANSPORTATIOrf""l
. . · ....

FEDERALAVIATIONADMINISTRATION 

## NOV 

## 292012 WASHINGTON, D.C.

## --------~-----I'H'i-tE~ARING 

## DOCKET IN THE MATTER OF MAGORIENHONING & HYDRAULICS

FAADOCKETNO. [TO BE ASSIGNED] (Civil PenaltyAction) FDMS NO. FAA-2012-0908 FAA CASENO. 2011WP910318

COMPLAINANT'S REQUEST FORDISCOVERYAND PRODUCTION OF DOCUMENTS Pursuant to the discovery guidelines setforth in section 13.220 ofthe Rules ofPractice in Federal Aviation Administration Civil Penalty Actions, 14 C.F.R. § 13.220, Complainant, the Federal Aviation Administration, hereby requests that Respondent, Magorien Honing & Hydraulics ("Magorien"), provide to counsel for Complainant all ofthe information requested in this discovery request as providedbelow. The requested information should be sent to: Michael F. McKinley, Senior Attorney, Enforcement Division, AGC-300, Office ofthe ChiefCounsel, Federal Aviation Administration, 800 Independence Avenue, S.W., Washington, D.C. 20591, facsimile (202) 267-5106, no later than 28 days after service ofthis discoveryrequest. All documents requested which the responding individual claims privilege or any other objection as a groundfor non-production shallbe identified chronologically as follows: (a) date;(b) title; (c) type ofdocument (e.g., memorandum, report, chart, etc.); (d) subject matter (without revealing the information as to which privilege or statutory authority is claimed); (e) factual or legal basis for the claimed privilege, or any other authority which provides the claimed ground for privilege. This discovery is a continuing request, through the date ofthe hearing in this matter, for Respondent to supplement or amend his answers and produce documents if new or different information or new or different documents are obtained during the pendency ofthis matter. New evidence should be provided in accordance with section 13.220(i) ofthe Rules ofPractice, 14 C.F.R. § 13.220(i). DEFINITIONS 

### 1. Use of"you" and "your" refers to Magorien's agents, Magorien's attorneys, and any otherperson(s) acting orpurporting to actfor or onbehalfofMagorien. 2. The words "and" and "or" shall be construed conjunctively and disjunctively as necessary to make the request inclusive rather than exclusive. The word "including" shall be construedwithoutlimitation. 3. The words "document" and "statement" mean, without limitation, the following items, whether printed or recorded or reproduced by any mechanical or electronic process or written or produced by hand: agreements, communications, correspondence, memoranda,
surnmanes or records of telephone conversations, sunnnaries or records of personal conversations or interviews, diaries, graphs, reports, notebooks, note charts, plans, drawings, sketches, maps, sunnnaries or reports of investigations, opinions or reports of consultants,

2photographs, motion picture films, brochures, pamphlets, advertisements, circulars, press releases, drafts, letters, and marginal comments appearing on any document, and other data compilations from which information can be obtained ortranslated, ifnecessary, into reasonably usable form. 4. The words "describe" and "state" mean to set forth each fact, consideration, circumstance, act, omission, event, transaction, occurrence or statement which supports, refutes, concerns, relates or refers to the matter(s) referenced or described in the interrogatory, and in addition, means to identify each oral communication and each document which concerns, refers
or relates to such fact, consideration, circumstance, act omission, event, transaction, occurrence
or statement. INTERROGATORIES 1. Identify each and every person Respondent intends to call as a witness in this proceeding byproviding the person's name, occupation, andbusiness address. 2. For each and every witness identified in answer to Interrogatory No. 1, state the nature ofthe witness's testimony (i.e. factual witness or expert witness); the subject matter upon which each intended witness is expected to testify; the facts and opinions to whichthe witness is expected to testify; and a narrative summary of the grounds for each opinion to which the witness will testify. 3. For each and every witness identified as an expert in answer to Interrogatory No. 2, state in detail the expertise possessed by each expert witness in the subject matter area on whichthe witness will opine. 4. List all exhibits youintend to use at the hearing inthis case.

35. For each ofthe paragraphs in the Complaint in this matter you deny in whole or part in your Answer, describe with particularity the basis for each denial. Identify the Complaint paragraph by number, for each that you deny in whole or part, and state the specific basis for your denial ofthatparagraph. Identify each and every fact that supports your denial.
REQUESTS FORPRODUCTION OF DOCUMENTS 

### 1. For each ofthe paragraphs in the Complaint you deny in whole or part, identify and provide any and all documents onwhich yourely in support ofyour denial(s). Your response to this Request should identify which denial(s) is/are addressed by each document provided in response to this request. 2. Provide copies of any document to which you referred to or relied upon in answering the immediately preceding interrogatories. For each document produced, identify the interrogatorythat itpertains to for which you referenced the document. 3. For each and every witness identified as an expert m the preceding interrogatories, provide a copy ofhis orher current curriculumvitae. 4. Provide copies of all documents that Respondent intends to introduce into evidence thathave not already been submitted to Complainant. 5. Provide copies of any statements made by witnesses identified 

### in the preceding interrogatories concerning, referring to, or involving the circumstances setforth in the complaint.

Date: November 26,2012
4 Respectfully submitted,

SeniorAttorney EnforcementDivisionCERTIFICATE OF SERVICE
I hereby certifythatI deliveredbyU.S. Certified Mail the original and one copy ofthe foregoing Request for Discovery andProduction ofDocuments inIn the Matter of Magorien Honing & Hydraulics, FAADocketNo. Unassigned, CaseNo. 2011WP910318, to: Federal AviationAdministration 600 Independence Ave., S.W. WilburWrightBuilding-Suite2W1000 Washington,D.C. 20591 ATTN: Hearing Docket Clerk, AGC-430 In addition, I hereby certifythat I served a copy ofthe same byU.S. Certified Mail, returnreceipt requested, addressedto the following: Doug Griffith, Esq. 633 W. 5th St., Ste. 2800 Los Angeles, CA 90071
Name: -+-u!<....::....::...fdJ::.:.___.c....t,--'-/....,

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