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JEFFREY M. }L\K>F.R 

FAA OFFICE OF RiXGIONAL COUNSEL 

1601 LrKD AVENUE SOUTHWEST 

R£NTON, WASHrNGl ON 9S057 

•1BLHPH^^^^:: (425)227-2161 

FACSIMILE; (425) 227-1007 

OFFARTMENT OF 

I'lANSPORTATIOM 

••'C'CKETOPhRATiONS 

ZOii Si? - n p 3: qc; 

UMTE D STATE S O F AMERIC A 

DEPARTMEN T O F TRANSPORTATIO N 

OFFIC E O F HEARING S 

WASHINGTON , D. C 

FAA Case No. 20] 1NM070021 

DMS No. F/\A-2011-0484 

In the Matter of: 

Cornerstone Aviation, Inc. 

F.AA Case No. 2011MM070022 

DMS No. F.AA-2011-0481 

F.AA Case Ko. 2011NM070042 

DMSNo. FAA-20I1-0489 

Judge Richard C. Goodwin 

COMPLAINANT^S INITIALDISCQVKRYREOUES'I 

To: Re^-pondcnt 

In acc-ordancc v-ith 14C.f_R. § 13.220 and the Federal Rules of Civil Procedure, please respond to 

tlie following Inrerrogatorics, Rcquesrts for Production of Documents, and Request for Admissions, 

separately and fuUy under oaih by August 2^, 2011. 

These discovery requests are intended to discover information and/or documents not only within 

your personal knowledge or obtainable by you, but also mfonnation in the possession of or 

obtainable by your attorneys, invesrigaiors, reprcsentaTrves, employees, agents, or anyone acting on 

your behalf or on their behalf. 

ihese discovery requests arc continuing in nature and any information which may be discL>vered by 

you subsequent to the service and filing of your ans^vers must be brought to the attention of the 

agency attorney through supplemental answers u'hen it becomes available to you, at a reasonable 

time prior to tht hearing in this matter. If there are any additions, delerion.s or changes jn the 

answers or infortnatioa provided at any time prior to hearing Ihc Responden.1 is specifically 

requested to so immediately infomi the agency attorney. If sucb information is not furnishcdi the 

agency attorney at the time of the beariDg will move to exclude frum ciidence such 

information requested and not furnished. 

Complainani;: IiiiUil Discovery Rcqiicu 

Comcraonc AviuLioiv Inc. - 201 l>fMfJ7U021, 

20llNMn?O022, iOI 1NM070O42 

Page 1 of 6 

VRL: (425> 221-1]Or, TAX: (425) ;::7-l007 

g'd i^SlZ'SS^lOQ uoiiiErtv ©uoisjaujOQ d9L:cO il eode s 
09/09/2011 14:24 FAX 2024935142 FAA - QMS ©002/005 

SepOS 1 1 02.16p Cornsrstong Availion 801-355-2754 p.4 

FAA Correspondence Complainant's tn'rtial Discovery Request Cornerstone Aviation 

Bernard Connelly - FV^A FSDO 

1020 N. Flyer Way 

Salt Lake City, LTT84316 

(301)257-5054 

William Hughes - FAA 

1020 N. Flyer Way 

Salt Lake City, UT 84116 

(SOI) 257-5045 

George David Cawthra - FAA- FSDO Manager 

1020 N. Flyer Way 

Salt Lake City. LIT 84116 

(SOI) 257-S046 

Page 4 of 4 
09/09/2011 14 24 FAX 2024935142 FAA ^ DMS 0003/00 5 

SepOS 11 02:l5p CornerstonQ Avaition 801-355-2754 p.3 

FAA Correspondence Complairwnf s Initial Discovery Request Cornerstone Aviation 

ATTACHMENT 

Cameron Howell-CFIl for Michael Stann 

IZSl North MurdotV; Drwe 

Plensant Grove, UT 84052 

(«01) 523-2858 

Kris Khe - CFII for Haley Wilson 

8791 South Terra Point Way 

West Jordan, UT S4088 

(801) B54-4d21 

Michael Stann - student of Cameron Howelt 

2115 S. Richard St. 

Salt Lake Cilv,UTS4115 

(801) 244-1404 

Fiona Silcox-Assistant chief instructor for CSA at SLCC campus 

250 W. 3900 So. 

Salt Lake atY,UT&4107 

(801) 949-3194 

Brian Vandenvel - Chief instructor for CSA 

1015 N. 1010 W. 

f'leas^snt Grove, UT 84062 

(801) 836-7112 

Richard Marshall -forme r chief instructor for CSA - Private Pilot Certjfkatjon program 

7SB^ South Grant Street 

Midvale, UT 84047 

(801) 671-3302 

Tom Kuhlman —retired FAA, current Designated Pilot Examiner fDPE) 

9508 South Kilmuir Circle \ 

So. Jordan, UT84095 

(801)633-6386 \ 

Jack Garzella - Computer Software specialist 

1871 Longbranch Drive 

Draper, UT8402O 

(801)523-8243 

Page 3 of a 
09/09/2011 14.24 FAX 2024935U2 FAA ^ OMS @]004/005 

Sep 08 11 02:15p Cornerstone Avaltion 601-355-2754 p.2 

FAA Correspondence Coniplainanr's initial Discovery flequest Cornerstone Aviation 

S. Adrriit - she only qualifies to receive partial credit urvder her part 61 tramin^VKhtch acnounta to 

25% of the course requiremfint*;. V> she COLIIH only count 7.S hours tov^ards her instrument 

ground instruction. During the course of instrument training her instructor logged 18.8 hours of 

briefing time with her on a one-on-one basis. That equates to 26.3 hours out of the required 30 

hours. 

S. Admit 

7. Admit- they used to he 141 but at the time of Wilson's training they were Part 61 . 

8. Admit 

9. Admit 

10. Admit 

11. Admit 

12. Admit 

13. Admit 

14. Admit 

15. Admit 

16. Admit 

37. No - When CSA ddministration <jiscovered tJ^at Cameron H&well, his instructor, and Michael 

Stann began the flight training prior to his passing his private pilot certification check ride, CSA 

repaid Mr. Stann for his training up until that paint (several thousand dollars) and told him that 

we could not count any of that training and would re-start his instrument program. CSA selfdtsciosed that Information t o iVie fSDO in SLC. CSA told his CFl to begin a new training record 

and destroy the old record as it could not be used. Additionally, students have access to online 

scheduling program to schedule flights. Michael Stann scheduled ahead to start instrument 

training 

Pace 2 of 4 
09/09/2011 14.25 FAX 2024935142 FAA - Of.lS [2005/005 

Sep 0811 02:15p Cornerstone Avaition 301 -355-2754 p. 1 

FAA Correspond fin re ("omplainants Initial Discovery Request Cornerstone Aviation 

LNTERROGATORIES 

Since complaints are consalidated into one letter, the responses have also been consolidated. Please 

refer to initial letter to CSA for details of item numbers. 

L IMomes, Addresses and Telephone Numbers (see attachment) 

2. All correspondence from FAA is in the possession of 3usan Horstman, Including all copies of 

documents sent to her by Jeffrey Harper. 

3. Names, Addresses and Telephone Numbers of persons whom CSA intends to have testify as a 

factual or expert wrtness in CSA's defense at the hearing of this rnatter. (see attachment) 

4. The documenb> CSA arriicipatbi. offtntri^ Inio evidt;nce ^L the he^iing or (his matter are the same 

CSA offered to the FAA FSDO, all of which were sent to Jeffrey Harper, The matters concerning 

SLCC records wrill be addressed by either Susan Horstman or Fiona Silcox. 

5. All expert witnesses are involved in flight training in one aspect or arwther, either as instructors, 

check pilots, assistant or chief instructors or FAA DP examiners, (see attachment) 

6. All expert witnesses are involved in flight training in ore aspect or another, erther as instructors, 

check pilots, assistant or chief instructors or FAA DP examiners. The subject matter is my FAA 

Part 141 TCO. One witness is a computer software specialist designing our new program. 

7. Please clariTy :his r^iquest as 1 do not know wlio Mr. Michdelby ii . 

8. Since this has t>een ongoing for several months ft is impossible t o recall exact dates of 

conversations and with whom I have discussed the matters alleged in the ComplainL It is most 

likely limited t o persons affiliated with the flight sci^ool as they have received instruction so the 

occurrences will not happen again. 

9. CSA's Part 141 TCO.and training documents 

REQUESTS FOR PRODUCTTON 

l - ^ The FAA already has copies of the documents —do you need me to make addititHial copies 

of the materials you sent TO me? The software designer of new flight school training 

program has computer protulype ready. TJtfs will have to be shown in person to FAA. 

REQUE&T FOR ADMISSIONS 

1. Admit 

2, Admit - did at the time; with FAA consent have now changed method of record keeping 

3- Admit 

4. Admit - She was a transfer student from Utah Valley University where she completed her 

private pilot ground school course. 

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