Gregoiy G. Skordas (#3865) 

SKORDAS, CASTON & HYDE, LLC 

341 So. Main Street, Suite 303 

Salt Lake City, UT84i n 

Telephone: (801)531-7444 

Facsimile: (801)531-8885 

Attorney for Defeiidant 

APR - 6 20)2 

HEARING DOCKET 

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UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

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C ' J 

- • C -•'mm. •~1 -

In the Matter of: 

Joseph Moesscr 

RESPONDENTS RESPONSE TO 

INITIAL DISCOVERY 

REQUESTS 

FAA Case No. 2010NM72000] 

DMSNo. FAA-2011-1286 

Jiidue Richard C. Goodwin 

The Respondent, Joseph Moesser, by and through his attoniey, Gregory G. Skordas, 

hereby responds to the Goveniment's Initial Discovery Requests. 

RESPQNDBNT'S RESPONSE TO INITIAL DISCOVERY REOUESl' 

"-^JnterrocatoriesH 

Interrogatory No. 1: All witnesses with personal knowledge of the matters alleged in the 

Complaint are identified in rcpotis already in Complainant's possession. 

liitciTOgatory No. 2: None 

InteiTOgatoiy No. 3: None 

hitciTogatory No. 4: None. 
InteiTogatory No. .5: None 

IntciTogatory No. 6: None 

Inten-ogatoi7 No. 7: The facts that Respondent anticipates presenting pertaining to mitigation of 

the requested sanction are as follows: (1) The financial infoniiatioii already provided to 

complainant; (2) Respondent's successful completion of probation; and (3) his public service 

statements to other muzzle loader hunters raising awareness of the issues suiTounding his 

prosecution as required by the Government as a condition ot his probation. 

hiterrogatory No. S: None 

InteiTogator>' No. 9: Responses to requests for admissions were given after due diligence , based 

upon information and belief and in good faith. 

Interrogatory No. 10: The basic facts have all been admitted in Respondent's Answer, fhe 

aftlnnative defenses raised are legal issues. 

Request for Production: 

We are unable to provide materials in accordance with your request for production as Mr. 

Moesser does not have documentation responsive to requests 1 through 5. 

Request for Adjnissions: 

#1. Admit 

#2. Admit 

^-=#3.—--Admit—^-

U4. Admit 

US. Admit 

U6: Admit 

n-7. Admit 
#S. Admit 

#9. Admit 

#10 Admit 

#11 Admit 

#12. Admit, though Respondent carried small arms ammunition (for muz/de loaders) 

for personal use in a box or package specifically designed to carry small amounts 

oflTinsuuu'sUdn:-""^ ' "=• ••^-^•°'^ — -^ ^-v.—•—^ • ~^— •--—-, 

#13. Admit 

#14. Adnnt 

#15. Admit 

#16 Admit 

#17 Deny. Hodgdon Triple Seven Pellets can be used in a variety of rifles and pistols. 

#18 Deny 

t^\9 Admit, but the Hodgdon Triple Seven Pellets were ammunition for a for a muzzle 

loader. 

#20. Admit, but the Hodgdon Triple Seven Pellets were amnumilioii for a muzzle 

loader. 

#21. Admit, but the Hodgdon Triple Seven Pellets were annnuniiion fora muzzle 

loader. 
#22. 

U23. 

Admit. The final destination was Pemba Mozambique 

Admit. Tiie amniutiition fora muzzle loader consists of the materials respondent 

ciieckcd with his baggage. 

#24. Admit, The TiS sbotshclls were filled with ammunition for a muzzle loader. 

#25. Admit. The 2 shotsheils were filled with ammunition for a muzzle loader 

#26. DaiyT"Thl:McflIied*siiotshc[ljr\\^e'iVot'iiTt'cnde^^^ 

#27. Deny; The refilled shotsheils were not intended as concealment 

DATED this,-^/ day of March, 2012. 

SKORDA-S,-eA-STQN & HYDE, LLC 

GregoiyG. Skordas 

4 
CERTIFICATE OF SERVICE 

I hereby eeilify that on ihqii^C- ^ day oi'March, 2012, I served a true and coirect copy of 

the foregoing RESPONDENT'S RESPONSE TO INITIAL DISCOVERY REQUESTS, via 

facsimile and by United States first class mail, postage pre-paid, to the following: 

Federal Aviation Administration (Original & one copy) 

SOU Independence"AVcrSW-^^"^*^—'-^^ • 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building - Suite 2W1000 

Facsimile 202.493.5142 

Jeffrey M Harper 

FAA Office of Regional Counsel 

1601 Lind Ave.,SW 

Renton, WA 9S057 

Facsimile: 425.227.1007 

The Honorable Richard C. Goodwin 

Office of Hearings, M-20 

U.S. Dept. of Transportation 

1200 New Jersey Avenue. S.E. 

Washington, DC 20590 

Facsimile 202.366.7536 

Skordas, Caslon & Hyde, LLC