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UNITED STATES DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION •!!n"pl 3 p |: 38 

* FAA Docket No.CP 1 OSW0006 - -' >^ ^-H V'v'^l ^ 

In the Matter of: * 

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* DMS No. FAA-2010-0532 

AMERICAN AIRLINES, INC. * J 0OCK2 T 

* Hon. Richard C. Goodwin (ALJ) 

* 

COMPLAINANT'S AMENDED RESPONSE TO RESPONDENT'S FIRST SET OF 

INTERROGATORIES TO COMPLAINANT 

Interrogatory 3. 

3. Please identify all FAA rules, regulations, orders, policies and/or other reference documents, 

whether formal or informal, that evidence, refer or relate to a Flight Fault Review ("FFR"), as 

alleged in Paragraphs II (7)-(8) in the FAA's Complaint. 

RESPONSE: 

Objection is made to this response as it is overly broad and burdensome. All documents in 

Complainant's EIR or which are intended to be used at trial have been provided to 

Respondent or are included herewith. Further, Flight Fault Review (FFR) is not related to 

the FAA, but rather is an option on aircraft operated by American Airlines. American 

Airlines has custody and control of any such documents which may exist. 

4. Please identify all FAA rules, regulations, orders, policies and/or other reference documents, 

whether formal or informal, that evidence, refer or relate to the interpretation of Respondent's DC9 MEL Item 22-2(b). 

RESPONSE: 

Objection is made to this response as it is overly broad and burdensome. All documents in 

Complainant's EIR and expected to be used at the time of trial have been provided to Respondent 

or are included herewith. 

5. Please identify each and every fact that supports your contention in Paragraph II (17) of the 

Complaint that "the proper deferral option would have been to placard the duplex rudder servo in 

accordance with MEL 22-16." 
RESPONSE: 

The Flight Fault Review revealed the autopilot duplex rudder servo had failed. There is only one 

autopilot duplex rudder servo on the aircraft. That servo was bad. A fully functioning autopilot 

duplex rudder servo is required for the autopilot coupled (ILS) operations, category 2 operations 

and automatic go around. The only deferral option would have been to comply with MEL item 

22-16. (The Complaint will be amended). 

7. Please identify each and every document that refers or relates to your contention in Paragraph 

11 (17) of the Complaint that "the proper deferral option would have been to placard the duplex 

rudder servo in accordance with MEL 22-16." 

RESPONSE: 

Op Specs , page D-085-10 (lOP 3) 

Log pages form E-6 logbook for aircraft 454 (lOP 4) 

Computers print out from American Airlines computer (lOP 5) 

Copy of American Airlines MD-80 maintenance manual (lOP 6) 

Copy of Page 22-2 of American Airiines MD-80 MEL (lOP 7) 

Copy of page 22-12 of American Airiines MD-80 MEL (lOP 8) 

Copy of page 22-12 of American Airiine MD-80 MEL (lOP 9) 

Copy of repair report from Honeywell Inc (lOP 15) 

Documents included herewith. 

REQUESTS FOR PRODUCTION 

3. All Documents related to any side or personal file(s) kept or maintained by FAA personnel 

regarding FAA Case No. 2008SW210058, specifically including FAA Inspectors Andrew Blosser, 

C.J. Di Cesare and William T. Satterfield. 

RESPONSE: 

Any documents responsive to this request are enclosed. 

10. All Documents related to a Flight Fault Review, specifically including its intended use and/or 

limitations. 

RESPONSE: 

Flight Fault Review is not an related to FAA but rather is an option on aircraft operated by 

American Airlines. American Airlines has custody and control of any such documents which 

may exist. All documents in Complainant's EIR and expected to be used at time of trial have 

been provided to Respondent or are enclosed herewith. 

11. All Documents related to other FAA enforcement proceedings in which FAA has alleged that a 
Part 121 air carrier improperly relied on DC-9 MEL System 22 (Autoflight) to defer maintenance. 

RESPONSE: 

Objection is made to this Request for Production in that the information sought is not relevant to 

the facts of this case nor calculated to lead to any relevant information. Objection is made to this 

Request for Production in that it is overly broad and burdensome. All documents in 

Complainant's EIR and expected to be used at time of trial have been provided to 

Respondent or are enclosed herewith. 

15. All Communications between FAA Inspector Andrew Blosser and anyone else regarding 

American's compliance with Federal Aviation Regulations. 

RESPONSE: 

Complainant objects to this Request for Production as it is that it is overly broad and burdensome. 

Objection is made to Request for Production No. 15 as it is vague and ambiguous. 

18. All Documents related to Your contention that "[a] fully functioning autopilot duplex rudder 

servo is required for the autopilot to function properly," as alleged in Paragraph II (11) of the 

Complaint. 

RESPONSE: 

Objection is made to Request for Production No. 18 as it is vague and ambiguous. All documents 

in Complainant's EIR have been provided to Respondent. All documents in Complainant's EIR 

and expected to be used at time of trial have been provided to Respondent or are enclosed 

herewith. 

19. All Documents related to Your contention that "[djeferral using MEL, Item 22-2b was 

improper," as alleged in Paragraph II (14) of the Complaint. 

RESPONSE: 

Objection is made to Request for Production No. 19 as it is vague and ambiguous. All documents 

in Complainant's EIR and expected to be used at time of trial have been provided to Respondent 

or are enclosed herewith. 

20. All Documents related to Your contention that "[t]he proper deferral option would have been 

to placard the duplex rudder servo in accordance with MEL 22-16," as alleged in Paragraph II (17) 

of the Complaint. 

RESPONSE: 

Objection is made to Request for Production No. 20 as it is vague and ambiguous. All documents 

in Complainant's EIR and expected to be used at time of trial have been provided to Respondent 

or are enclosed herewith. 
Respectfully submitted, 

LYNETTE WORD 

Regional Counsel 

Southwest Region 

Yolanda Ayal 

Attorney 

Safety Enforcement Branch 

Phone: (817)222-5070 

FAX: (817) 222-5945 or 5092 
CERTIFICATE OF SERVICE 

I hereby certify that on September 7, 2010, an original and one copy of 

COMPLAINANT'S AMENDED RESPONSE TO RESPONDENT'S INTERROGATORIES 

AND REQUEST FOR PRODUCTION OF DOCUMENTS was sent by Federal Express Mail to: 

Federal Aviation Administration 

600 Independence Avenue, S.W. 

Wilbur Wright Building - Room 2W1000 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

I hereby certify that on September 7, 2010, a copy of COMPLAINANT'S AMENDED 

RESPONSE TO RESPONDENT'S INTERROGATORES AND REQUESTS FOR 

PRODUCTION OF DOCUMENTS was sent by Federal Express Mail to: 

The Honorable Richard C. Goodwin 

US Department of Transportation, Office of Hearings, M-20 

1200 New New Jersey Avenue, S.E. 

East Building Ground Floor, Room El2-320 

Washington, DC 20590 

Evan P. Singer, 

Jones Day 

2727 North Harwood St. 

Dallas, TX 75201-1515 

(:. ^^i ^ 

Sylvia C. Twa, Paralegal 

Office of Regional Counsel 

Federal Aviation Administration 

Fort Worth, TX 76137 

Date; September 7, 2010