UNITED STATES OF AMERICA 

U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. 

IN THE MATTER OF 

M.T.I. TRAVEL, INC. 

FAA DOCKET NO. FAA-2014-0110 

(Civil Penalty Action) 

FAA CASE NO. 2013S0950011 

RECEIVED 

APR 11 2014 

HEARING DOCKET 

COMPLAINANT'S REQUEST FOR DISCOVERY AND 

PRODUCTION OF DOCUMENTS 

Pursuant to the discovery guidelines set forth in section 13 .220 of the Rules of Practice in 

Federal Aviation Administration Civil Penalty Actions, 14 C.P.R. § 13.220, Complainant, the 

Federal Aviation Administration, hereby requests that Respondent, M.T.I. Travel, Inc. 

("M.T.I."), provide to counsel for Complainant all of the information requested in this discovery 

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request as provided below. 

The requested information should be sent to: Michael F. McKinley, Senior Attorney, 

Enforcement Division, AGC-300, Office of the Chief Counsel, Federal Aviation Administration, 

800 Independence Avenue, S.W., Washington, D.C. 20591, facsimile (202) 267-5106, no later 

than 28 days after service of this discovery request. 

All documents requested which the responding individual claims privilege or any other 

objection as a ground for non-production shall be identified chronologically as follows: 

(a) date; 

(b) title; 
(c) type of document (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 of the 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 of this matter. New 

evidence should be provided in accordance with section 13.220(i) of the Rules of Practice, 14 

C.F.R. § 13.220(i). 

DEFINITIONS 

1. Use of "you" and "your" refers to M. T .I.'s agents, M. T.I.' s attorneys, and any 

other person(s) acting or purporting to act for or on behalf ofM.T.I.. 

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 

construed without limitation. 

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, 

summaries or records of telephone conversations, summaries or records of personal 

conversations or interviews, diaries, graphs, reports, notebooks, note charts, plans, drawings, 

sketches, maps, summaries or reports of investigations, opinions or reports of consultants, 

photographs, motion picture films, brochures, pamphlets, advertisements, circulars, press 

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releases, drafts, letters, and marginal comments appearing on any document, and other data 

compilations from which information can be obtained or translated, if necessary, 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 by providing the person's name, occupation, and business address. 

2. For each and every witness identified in answer to Interrogatory No. 1, state the 

nature of the 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 which the 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 

which the witness will opine. 

4. List all exhibits you intend to use at the hearing in this case. 

5. For each of the 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 

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paragraph by number, for each that you deny in whole or part, and state the specific basis for 

your denial of that paragraph. Identify each and every fact that supports your denial. 

REQUESTS FOR PRODUCTION OF DOCUMENTS 

1. For each of the paragraphs in the Complaint you deny in whole or part, identify 

and provide any and all documents on which you rely in support of your 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 

interrogatory that it pertains to for which you referenced the document. 

3. For each and every witness identified as an expert m the preceding 

interrogatories, provide a copy of his or her current curriculum vitae. 

4. Provide copies of all documents that Respondent intends to introduce into 

evidence that have 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 set forth in the complaint. 

Date: April 8, 2014 

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Respectfully submitted, 

)jvtidr:U/4 

Michael F. McKinley 

Senior Attorney 

Enforcement Division 
CERTIFICATE OF SERVICE 

I hereby certify that I delivered by U.S. Certified Mail the original and one copy ofthe 

foregoing Request for Discovery and Production of Documents in In the Matter of M Tl, Inc, 

FAA Docket No. FAA-2014-0110, Case No. 2013S0950011, to: 

Federal Aviation Administration 

800 Independence Ave., S.W. 

Wilbur Wright Building-Suite 2Wl 000 

Washington, D.C. 20591 

ATTN: Hearing Docket Clerk, AGC-430 

In addition, I hereby certify that I served a copy of the same by U.S. Certified Mail, 

return receipt requested, addressed to the following: 

David P. Affinito, Esq. 

Dell'Italia, Affinito & Santola 

18 Tony Galento Plaza 

Orange, NJ 07050 

Hon. J.E. Sullivan 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

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

Washington, DC 20590 

Date: AprilS, 2014 

yMt.U/~ Michael F. McKinley 

Senior Attorney 

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