U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of Endless Mountains Air, Inc. 

Docket No. FAA-2013-0848 

Case No. 2012EA050008 

Judge Sullivan 

RECEIVED 

JUN 1 7 2014 

HEARING DOCKET 

AGENCY'S FIRST SET OF INTERROGATORIES AND REQUEST FOR 

PRODUCTION OF DOCUMENTS 

COMES NOW the Agency, by and through its designated representative, the 

Regional Counsel for the Eastern Region and his duly designated agents, and 

requests that Respondent, Endless Mountains Air, Inc., respond to the following 

discovery within thirty (30) days: 

INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS 

I. IdentifY the names, titles, business or home addresses and telephone numbers of 

each person whom the Respondent intends to call as a witness at the hearing of this 

matter. 

2. Provide the substance of the testimony to be offered by each of said witnesses. 

3. With respect to each expert witness identified in response to request Nos. I and 2 

above: 

(a) identify the subject matter on which the expert is expected to 

testifY; 
(b) list the substance of the facts and opinions to which the expert 

is expected to testifY; 

(c) provide a summary of the grounds for each opinion; 

(d) if the Respondent intends to introduce into evidence or otherwise rely 

upon a written curriculum vitae or other written document listing the 

expert's professional qualifications, identity and attach copies of all 

such documents. 

4. Identity and produce copies of any and all documents or other tangible 

exhibits on which the Respondent anticipates relying, or will rely, in support 

of the case it will present at the hearing in this matter, including but not 

limited to documents or other tangible exhibits it intends to introduce into 

evidence. 

5. State all facts to support the contention of Respondent that smce the 

beginning of the 12th calendar month before the flights referenced in 

paragraph II of section I of the Complaint in this matter, Randy Palmer had 

passed a flight check in a Cirrus SR-20 aircraft. 

6. Produce copies of all documents that support the contention of Respondent 

that since the beginning of the 12th calendar month before the flights 

referenced in paragraph II of section I of the Complaint in this matter, Randy 
Palmer had passed a flight check in a Cirrus SR-20 aircraft. 

Respectfully submitted, 

Alfred R. Johnson, Jr. 

Regional Counsel 

Ry Zachary Man 

i#~ Attorney 

Federal Aviation Administration 

1 Aviation Plaza 

Jamaica, NY 11434 

718 553-3258 

718 995-5699 

Date: June 11,2014 
CERTIFICATE OF SERVICE 

I hereby certifY that the foregoing Agency's First Set of Interrogatories and Request 

for Production of Documents have been seen via first class mail and facsimile to the 

following: 

Mr. Willima J. Dobitsch, Jr. 

Endless Mountains Air, Inc. 

Seamans Airport 

727 Windsock Lane 

Factoryville, P A 18419 

FAX: 570-945-5953 

I 

hereby certifY that the foregoing Agency's First Set of Interrogatories and Request 

for Production of Documents have been seen via first class mail to the following: 

Federal Aviation Administration (Original and one copy) 

800 Independence Avenue, S.W. 

Washington, D.C. 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbnr Wright Building- Room 2014 

JUN 11 Z014 

Date: ------- ~~~ Paralegal Specialist 

Federal Aviation Administration 

Office of Regional Counsel 

1 Aviation Plaza 

Jamaica, NY 11434