William A. Curtright 

Respondent 

PO Box 1350 

Jefferson, OR 97352 

Telephone: (503) 209-7388 

Fax: (503) 485-0812 

RECEI\lED 

JAN 2 3 2017 

HEARING DOCK~i 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In The Matter Of: 

Docket No. FAA-2015-1319 

WILLIAM A. CURTRIGHT, DBA 

CaseNo.2014NM090046 

Respondent 

Judge J.E. Sullivan 

RESPONDENTS AMENDED MOTION TO COMPEL 

COMES NOW Respondent, William A. Curtright, DBA respectfully files and submits 

this Amended Motion to Compel pursuant to local rules 14 CRF 13.21 and Federal Rules of 

Civil Procedure 37(a)(1) and (2)(a)(b) Respondent hereby moves the Court be compelled to have 

Complainant respond to Discovery based on the following facts: 

1. Respondent reincorporates fact numbers 1 and 2 From Respondents First Motion to 

Compel filed on December 6, 2016 herein with the Court and served on Complainant. 

2. Complainant refused to respond in a timely manner, to Respondents Discovery of 

Interrogatories and Request for Admissions. 

3. Complainant refused to respond to Respondent's Interrogatories for Interrogatories No. 4, 

5, 6,7,8,9,18,19,20 and Request for Admission No. 7 the Respondent moves the court to 

compel the Complainant to respond to the Discovery requests or pursuant to 

RESPONDENT'S AMENDED MOTION TO COMPEL 

Docket No. FAA·2015-1319 

Case No. 2014NM0046 

Page 1 

William A. Curtright,DBA 

Respondent 

Telephone: (503) 209-7388 

Fax (503)485·0812 
Federal Rules of Civil Procedure 37-3(A)(ii)(iii)(v)(vi) moves this court to strike all 

pleadings in whole and dismissing the action in whole with prejudice. (Herein attached 

as Exhibit A is Complainant's Responses to Respondents's Request for Interrogatories 

and Production of Documents) 

Dated this 6 day of January 2017 

Respectfully submitted, 

Dr. Wm. Ames Curtright, DBA 

Docket No. FAA-2015-1319 

(Civil Penalty Action) 

SERVICE LIST- BY U.S. MAIL 

ORIGINAL & ONE COPY 

Federal Aviation Administration (Fax and Certified First Class Mail) 

Attn: Hearing Docket Clerk, AGC-430 

800 Independence Avenue SW 

Washington, DC 20591 

Wilbur Wright Building, Suite 2WIOOO 

Fax: (202) 267-1293 

ONE COPY 

Judge J.E. Sullivan (Fax, Email, and Certified First Class Mail) 

U.S. Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE (El1-310) 

RESPONDENT'S AMENDED MDTION TO COMPEL 

Docket No. FAA-2015-1319 

Case No. 2014NM0046 

Page 2 

William A. Curtright,DBA 

Respondent 

Telephone: (503) 209-7388 

Fax (503)485-0812 
Washington, DC 20590 

TEL: 202-366-6941 

FAX: 202-366-7536 

David F. Shayne, FAA Attorney (Fax, Email, and Certified First Class Mail) 

Complainant's Counsel 

Northwest Mountain Region, ANM-7 

Federal Aviation Administration 

1601 Lind Ave. SW 

Renton, W A 98057 

TEL: 425-227-1847 

RESPONDENT'S AMENDED MOTION TO COMPEL 

Docket No. FAA-2015-1319 

Case No. 2014NM0046 

Page 3 

William A. Curtright, DBA 

Respondent 

Telephone: (503) 209-7388 

Fax (503)485-0812 
DAVID F. SHAYNE 

FAA OFFICE OF REGIONAL COUNSEL 

1601 LIND AVE., SW 

RENTON, WASHINGTON 98057 

TELEPHONE: (425) 227-2165 

FACSIMILE: (425)227-1007 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of: 

William A. Curtright 

Docket No. F AA-2015-1319 

FAA Case No. 2014NM090046 

Judge J. E. Sullivan 

COMPLAINANT'S RESPONSES TO RESPONDENT'S REQUEST FOR 

INTERROGATORIES AND PRODUCTION OF DOCUMENTS 

Complainant hereby responds to the Respondent's Request for Interrogatories and Production 

of Documents, in the above-captioned matter as follows: 

INTERROGATORIES 

INTERROGATORY No. I: Describe with specificity all of the facts and arguments which 

you anticipate presenting in the course of the Department of Transportation (DOT) 

hearing in this matter pertaining to the civil penalty amount that the FAA seeks in this 

case of action. 

Answer: Complainant's allegations are set forth in the Complaint filed in this 

matter and the disclosures previously provided. 

FAA v. William A. Curtright 

Docket No. FAA-20I5-1319 

FAA Case No. 20I4NM090046 

Page I of9 

DAVID F. SHAYNE, FAA ATTORNEY 

TEL: (425) 227-2165; FAX: (425) 227-1007 
INTERROGATORY No.2: Describe with specificity all of the facts and arguments which 

you anticipate presenting in the course of the Department ofTransportation(DOT) hearing in 

this matter pertaining to the civil penalty amount sought by the FAA in the case of action. 

Answer: See Answer to Interrogatory 1. 

INTERROGATORY No.3: Describe with specificity all of the facts and arguments which 

you anticipate presenting in the course of the Department of Transportation (DOT) hearing 

in this matter identifYing the grounds that will show a genuine issue of material fact. 

Answer: See Answer to Interrogatory 1. 

INTERROGATORY No. 4: Describe with specificity all of the facts and arguments 

which you anticipate presenting in the course of the Department of Transportation (DOT) 

hearing in this matter identifying why the FAA believes a civil penalty of $11,000.00 as 

being appropriate for the alleged violation of Section 14. C.F.R. 91.417(c). 

Answer: Objection, calls for legal opinion, not for information likely to lead to 

admissible evidence. Notwithstanding and while not waiving objection, See FAA 

Order 2150.3B Appendix B page 8. 

INTERROGATORY No.5: Describe with specificity all of the facts and arguments which you 

anticipate presenting in the course of the Department of Transportation (DOT) hearing the 

FAA's explanation of why they are proposing an $11,000.00 fine as the civil penalty, and what 

forms the basis for the maximum amount allowed. 

Answer: See Answer to Interrogatory 4. 

INTERROGATORY No.6: Describe with specificity all of the facts and arguments which 

you anticipate presenting in the course of the Department of Transportation (DOT) hearing 

in this matter identifying why the FAA had offered a settlement of $5,000.00. 

Answer: 

evidence. 

Objection, irrelevant, not for information likely to lead to admissible 

INTERROGATORY No.7: Describe with specificity all of the facts and arguments which 

you anticipate presenting in the course of the Department of Transportation (DOT) hearing in 

this matter identifying why the FAA had offered a settlement of $3,500.00 for full settlement 

of this case. 

FAA v. William A. Curtright 

Docket No. FAA-2015-1319 

FAA Case No. 2014NM090046 

Page 2 of9 

DAVID F. SHAYNE, FAA ATTORNEY 

TEL: (425) 227-2165; FAX: (425) 227-1007 
Answer: 

evidence. 

Objection, irrelevant, not for information likely to lead to admissible 

INTERROGATORY No. 8: Identify by name, address and telephone number, all persons 

whom you discussed at your agency regarding the FAA offered settlement of$5,000.00. 

Answer: 

evidence. 

Objection, irrelevant, not for information likely to lead to admissible 

INTERROGATORY No. 9: Identify by name, address and telephone number, all persons 

whom you discussed at your agency regarding the FAA offered settlement of $3,5000.00. 

Answer: 

evidence. 

Objection, irrelevant, not for information likely to lead to admissible 

INTERROGATORY No 10: Identify by name, address and telephone number all persons 

whom you know to have personal knowledge of the matters alleged in the Complaint. 

Answer: FAA investigators Marty Conroy, William McKibbon and Curt Cowley. 

INTERROGATORY No. 11: Identify by title, date, author, present custodian, and 

content, all documents, including correspondence, obtained by you or in your 

possession, relating to the assertions in the Complaint, and evidence that Respondent did 

not provide the documentation that was requested of him under Section 14 C .F .R. 

91.417(c). 

Answer: All of the documents responsive to this request were previously 

identified and provided in initial disclosures. 

INTERROGATORY No. 12: Identify by name, address and telephone number, all 

persons whom you intend to have testify as a factual or expert witness in support of your 

complaint at the hearing in this matter, and for factual witnesses, provide a detailed 

summary of each persons anticipated testimony. 

Answer: Previously provided in initial disclosures. 

FAA v. William A. Curtright 

Docket No. F AA-20 15-1319 

FAA Case No. 2014NM090046 

Page 3 of9 

DAVID F. SHAYNE, FAA ATTORNEY 

TEL: (425) 227-2165; FAX: (425) 227-1007 
INTERROGATORY No. 13: Identify by title, date, author, present custodian, and content, 

all documents which you anticipate offering into evidence at the hearing in this matter, and 

through which witoess or witoesses. 

Answer: See Answer to Interrogatory 11. 

INTERROGATORY No. 14: With respect to each expert witoess identified in response 

to Interrogatory No.l2, above, specify their specific area of expertise, and provide a 

synopsis of their credentials, background, training and experience. 

Answer: Complainant does not anticipate calling expert witness, notwithstanding 

the foregoing, Marty Conroy would qualify as an expert in general aviation-aircraft 

operations by virtue of his training and experience as a professional pilot and FAA 

Inspector. 

INTERROGATORY No. 15: With respect to each expert you expect to call as a witness, 

state the subject matter on which the expert is expected to testify, and state the substance of 

the facts and opinions to which the expert is expected to testifY, and a summary of the 

grounds for each such opinion. 

Answer: See Answer to Interrogatory 14. 

INTERROGATORY No. 16: State by name, address, telephone number, date of 

conversation, and substance of conversation, all persons with whom you have discussed 

the matters alleged in the Complaint. 

Answer: See Answers to Interrogatory 10 and 11. 

INTERROGATORY No. 17: If you deny any or all of Requests for Admissions, 

please explain in detail the specific reason for each and every fact denied. 

Answer: Not applicable. 

INTERROGATORY No. 18: If you deny any or all of Request for Admissions please 

explain in detail the specific reason for each and every fact denied and sate specifically 

whether you had a conversation with ASI Comoy and, if so, what is your recollection of 

the conversation. 

FAA v. William A. Curtright 

Docket No. FAA-2015-1319 

FAA Case No. 2014NM090046 

Page 4 of9 

DAVID F. SHAYNE, FAA ATTORNEY 

TEL: (425) 227-2165; FAX: (425) 227-1007 
Answer: Not applicable. 

INTERROGATORY No. 19: With respect to FAA attorney David F. Shayne, please 

describe if you are a permanent employee of the FAA or a contracted attorney with the 

FAA. 

Answer: Objection, irrelevant, not for information likely to lead to admissible 

evidence. 

INTERROGATORY No. 20: With respect to FAA attorney David F. Shayne, please 

describe if you are a contracted attorney with the FAA if you receive a percentage payment 

based on the amount of civil penalties are collected by you or the FAA. 

Answer: Objection, irrelevant, not for information likely to lead to admissible 

evidence. 

REQUEST FOR PRODUCTION 

REQUEST FOR PRODUCTION NO. I: Provide a copy of all documents referred to 

in your answer to the preceding interrogatories No. I through No. 20. 

Answer: See Answer to Interrogatory 11. 

REQUEST FOR ADMISSIONS 

REQUEST FOR ADMISSION No I. Admit that Attachment 1 is a true and correct copy 

of an electronic mail message (email) you sent to Wm. Ames Curtright, DBA on October 

14, 2015 and an electronic mail message (email) Wm. Ames Curtright, DBA sent to you, 

David F. Shayne on October 14, 2015. 

Answer: Admit. 

FAA v. William A. Curtright 

Docket No. FAA-2015-1319 

FAA Case No. 2014NM090046 

Page 5 of9 

DAVID F. SHAYNE,FAAATTORNEY 

TEL: (425) 227-2165; FAX: (425) 227-1007 
REQUEST FOR ADMISSION No 2. Admit that Attachment 2 is a true and correct 

copy of a speed memo that was attached to the October 14,2015 electronic mail message 

(email) (document request for admission No. 1) from the FAA in Hillsboro, Oregon to 

Marty G. Comoy cc: Bill McKibbon regarding INSPECTOR STATEMENT. 

Answer: Admit. 

REQUEST FOR ADMISSION No 3. AdmitthatAttachment3is a true and correct 

copy of the Complaint that the FAA filed with the United States Of America 

Department of Transportation Office of Hearings Washington, D.C. by FAA 

attorney David F. Shayne against William A. Curtright with case no. FAA 

Case No. 2014NM090046. 

Answer: Admit. 

REQUEST FOR ADMISSION No 4. Admit that Attachment 4 is a true and correct 

copy of a A SECTION B Statement of Case and Factors Affecting Sanction produced 

by the FAA in their initial disclosure statement in Case No. 2014NM090046. 

Answer: Admit. 

REQUEST FOR ADMISSION No 5. AdmitthatAttachment5is a true and correct 

copy of a letter to Martin G. Conroy from Dr. W. Ames Curtright, dated 

September 9, 2014 re: EIR Number 2014NM090046 with attachments of 

Oregon Aircraft Registration Certificate; Memorandum from Ben W. Davidson 

to William Ames Curtright dated August 26, 2014;medical Certificate Third 

Class; electronic mail message (email) from William Ames Curtright to 

Marty Conroy dated July 7, 2014 with subject N949JP Information, The 

Standard Pilot Log book. 

Answer: Admit. 

REQUEST FOR ADMISSION No 6. Admit that Attachment 6 is a true and correct 

copy of a electronic mail message (email) from William Ames Curtright to 

Marty Conroy dated August 28, 2014 subject N949JP Information. 

Answer: Admit. 

REQUEST FOR ADMISSION No 7. Admit that Attachment 7 is a true and correct copy 

of a Decision and Order in the matter of Premier Jets, Inc. with FAA Order No. 99-

7 Served August 31, 1999, with Docket No. CP97NM0005 that was sent to FAA 

attorney David F. Shayne with Respondent's additional disclosures pursuant to 

FRCP 2691 (a) on September 20th, 23016. 

FAA v. William A. Curtright 

Docket No. FAA·2015-1319 

FAA Case No. 2014NM090046 

Page 6 of9 

DAVID F. SHAYNE, FAA ATTORNEY 

TEL: (425) 227·2165; FAX: (425) 227-1007 
I

( Answer: Complainant is unfamiliar with this document, and lacks information on 

\ its authenticity therefore denies. 

REQUEST FOR ADMISSION No 8. AdmitthatAttachment8 is a true and correct 

copy of a photo's ofN949JP log book 1, 2 and 2 produced to FAA attorney 

David F. Shayne with Respondent Initial Disclosures Pursuant to the ALJ' S 

Order of August 10, 2016 and FRCP 269(a) on September 9, 2016 by 

Respondent. 

Answer: Admit. 

REQUEST FOR ADMISSION No.9. Admit that Attachment 9 is a true and correct 

copy of a email from Scott Myers of FAA to Patty Abel dated July 30, 

2015 regarding that they are in receipt of Mr. Curtright's email dated July 

27, 2015. 

Answer: Admit. 

REQUEST FOR ADMISSION No 10. AdmitthatAttachment 10 is a true and 

correct copy of a electronic mail message (email) from Dr. William A. Curtright, 

DBA to Judge Richard Goodwin cc: Patricia M<;!!hew -and David F. Shayne 

dated August 11,2015 re: Reply to FAA's M_91ion; with electronic mail 

message (email) from patty Abel to Bill _McKibbon and Scott Myers of 

FAA dated July 30, 2015 regarding if"they had received the documents sent 

on July 27, 2015. 

/ 

Answer: Admit. 

REQUEST FOR ADMISSION No. 11. Admit that Attachment 11 is a true and 

correct copy of a electronic mail message (email) from Dr. William A. Curtright, 

DBA to David Shayne dated July 23,2015 regarding flight logs, weight and 

balance with attachments of FAA Approved Airplane flight manual 

supplement 2 with a total of 4 pages; Supplemental Iype Certificate dated 

March 1, 2011. 

Answer: Admit. 

FAA v_ William A Curtright 

Docket No. FAA-2015-1319 

FAA Case No_ 2014NM090046 

Page 7 of9 

DAVIDF_ SHAYNE, FAA ATTORNEY 

TEL: (425) 227-2165; FAX: (425) 227-1007 
REQUEST FOR ADMISSION No. 12. Admit that Attachment 12 is a true 

and correct copy of a letter dated July 22, 2015 from Dr. Wm. Ames 

Curtright, DBA to Bill McKibbon and Scott Myers of Flight Standards Dist. 

Office re: EIR number 2014NM0900046. 

Answer: Admit. 

REQUEST FOR ADMISSION No. 13. Admit that Attachment 13 is a true 

and correct copy of a letter dated May II, 2015, from Dr. Wm. Ames 

Curtright, DBA to Martin Conroy Aviation Safety Inspector re: Case No. 

20 14NM 090046. 

Answer: Admit. 

REQUEST FOR ADMISSION No. 14. Admit that Attachment 14 is a true 

and correct copy of a letter dated May 11, 2015 from Dr. Wm. Ames 

Curtright, DBA to Scott Myers re: FAA Case No. 2014NM090046. 

Answer: Admit. 

Resp tfttll:x submitted this 61

h day of December 2016. 

D .SHAYNE 

FAA Attorney 

FAA v. William A. Curtright 

Docket No. FAA-2015-1319 

FAA Case No. 2014NM090046 

Page 8 of9 

DAVID F. SHAYNE,FAAATTORNEY 

TEL: (425) 227-2165; FAX: (425) 227-1007 
CERTIFICATE OF SERVICE 

I hereby certifY that the foregoing Complainant's Responses to Respondent's Request for 

Interrogatories and Production of Documents has been served this date, to the following: 

Judge J.E. Sullivan (Facsimile and First Class Mail) 

U.S. Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200New JerseyAve., S.E. (Ell-310) 

Washington, D.C. 20590 

Fax: (202) 366-7536 

Federal Aviation Administration (Facsimile and First Class Mail) 

800 Independence Avenue SW 

Washington, D.C. 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2W1 000 

Fax: (202) 267-1293 

William A. Curtright (First Class Mail and Certified Mail- Return 

Receipt Requested) 

P.O. Box 1350 

Jefferson, OR 97352 

FAA v. William A. Curtright 

Docket No. F AA-20 15-1319 

FAA Case No. 2014NM090046 

Page 9 of9 

Dated this 6th day of December 2016. 

JeffKamb ij, Legal Tech 

Office of Regional Counsel ( -7) 

Federal Aviation Administrat" on 

1601 Lind Ave. SW 

Renton, WA 98057 

DAVID F. SHAYNE, FAA ATTORNEY 

TEL: (425) 227-2165; FAX: (425) 227-1007