UNITED STATES OF AMERICA U.S. DEPARTMENT OF TRANSPORTATION

FEDERALAVIATION ADMINISTRATION WASHINGTON, D.C.
IN THE MATTEROF M.T.I. TRAVEL, INC. FAADOCKET NO. FAA-2014-0110 (Civil Penalty Action) FAA CASE NO. 2013S0950011 

# RECEIVED APR 

## 11 2014 HEARING DOCKET

COMPLAINANT'S REQUEST FORDISCOVERYAND PRODUCTION OF DOCUMENTS Pursuant to the discovery guidelines set forth in section 13.220 ofthe Rules ofPractice 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 ofthe information requested inthis 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 than28 days after service ofthis 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 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 ornew 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 M.T.I.'s agents, M.T.I.'s attorneys, and any other person(s) acting or purporting to act for or onbehalfofM.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

2releases, drafts, letters, and marginal comments appearing on any document, and other data compilations from which information can be obtained or translated, 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 proceedingbyprovidingthe 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 eachintended 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 whichthe witness will opine. 4. List all exhibits you intendto use atthe hearing in this case. 5. For each ofthe paragraphs in the Complaint in this matter you deny in whole or part in your Answer, describe with particularitythe basis for each denial. Identify the Complaint

3paragraph 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 andprovide any and all documents on whichyourely 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 itpertainsto for whichyoureferencedthe 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 alreadybeen submittedto Complainant. 5. Provide copies of any statements made by witnesses identified in the preceding interrogatories concerning, referring to, or involvingthe circumstances set forth inthe complaint.

Date: April 8, 2014

4 Respectfully submitted, 

# )jvtidr:U/4 Michael F. McKinley SeniorAttorney EnforcementDivisionCERTIFICATE OF SERVICE
I hereby certifythatI deliveredbyU.S. CertifiedMail the original and one copy ofthe foregoing Request for Discovery andProduction ofDocuments in

### In the Matter of M Tl, Inc, FAADocketNo. FAA-2014-0110, CaseNo. 2013S0950011,to: Federal AviationAdministration 800 Independence Ave., S.W. Wilbur WrightBuilding-Suite 2Wl000 Washington, D.C. 20591 ATTN: HearingDocket Clerk, AGC-430 In addition, I hereby certifythat I served a copy ofthe samebyU.S. Certified Mail, returnreceipt requested, addressedto the following: DavidP. Affinito, Esq. Dell'Italia, Affinito & Santola 18 Tony Galento Plaza Orange, NJ 07050 Hon. J.E. Sullivan Administrative Law Judge Office ofHearings, M-20 U.S. Department ofTransportation 1200 NewJersey Avenue, S.E. (Ell-310) Washington, DC 20590

Date: AprilS, 2014

# yMt.U/~ Michael F. McKinley SeniorAttorney

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