U.S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION 

# RECEIVED APR 09 2015 

## HEARING DOCKET In the Matter of:

Triumph Group Operations, Inc. d/b/a Triumph Accessory Services FAA Case No. 2014CE070023 FDMS No. FAA-2015-0636 Judge Not Assigned

RESPONDENT'S FIRST REQUEST FORPRODUCTION OF DOCUMENTS



### Pursuant to the discovery guidelines set forth in Section 220 ofthe Rules ofPractice in FAA Civil PenaltyActions, 14 C.F.R. § 

### 13.220, Triumph Group Operations, Inc. d/b/a Triumph Accessory Services ("Respondent") herebyrequests that Complainant Federal Aviation Administration (FAA) provide to Respondent's counsel the requested information described below 

### within thirty (30) days. Moreover, this is a continuing request for Complainant to provide all updates or new records orinformation, as itemized inthis document, through the date ofthe hearing. New evidence should be provided to the extent allowed by 14 C.F.R. §

### 13.220(i).
DEFINITIONS


### A. Unless otherwise indicated, this Request for Production ofDocuments refers to the time, place and circumstances ofthe occurrence referenced in the Complaint. B. Where knowledge, information or documents possessedby a party is requested, that request includes knowledge ofthe party's representatives, agents, and, unless privileged, attorneys. C. The pronoun "you" and "yours" refers to the party to whom or which this Request for Documents is addressed, and the persons mentioned in

### paragraph B, supra. D. Whenused with respect to a document, "identify" means to furnish the document itself, or in lieu thereof, the name and date ofthe document, the name and address, ifany, ofthe person 1orpersons to whom the document is addressed, the names and addresses ofall persons to whom copies ofthe document were orhave been sent, and the organization, firm or agency with which all suchpersons were connected as ofthe date ofthe document, and state whether you are inpossession ofthe original or copy, furnish the name and address ofa person whom youbelieveis in possession ofthe original or a copy ofsuch document. E. The term "identify", whenreferring to a person, means to identify the person byname, occupation(s ), and business address. F. The term "document" and "statement" mean without limitation, the following items, whether printed orrecorded or reproduced by any other mechanical process or written orproducedby hand: agreements, communications, correspondence, telegraphs, memoranda, electronic messages, court orlegal documents, summaries orrecordings oftelephone conversations, summaries orrecords ofpersonal conversations orinterviews, summaries orreposts of investigations, opinions orreports ofconsultants, diaries, graphs reports, notebooks, note charts, plans, drawing, sketches, maps, photographs, motionpicture films, brochures, pamphlets, advertisements, circulars, press releases, draft letters, and marginal comments appearing on any document, and all other tangible information capable ofbeingread, viewed orheard. G. All documents requested as to which the responding individual claims privilege or anyother objection as a ground for non-production shall be identified chronologically as follows: a. date, b. title, c. type ofdocument (e.g. memorandum, report, chart, etc.) d. subject matter (without revealing the information as to whichprivilege or statutory authorityis claimed; and e. factual orlegal basis for the claimedprivilege, or any other authoritythat provides the claimed ground for non-production.

2REQUEST FOR PRODUCTION OF DOCUMENTS Respondent respectfully requests copies ofthe releasable portions ofthe Federal Aviation Administration's Enforcement Investigative Report ("EIR") pertaining to the above-referenced matter.

Date: April 6, 2015 Respectfully submitted,

Marshall S. Filler Counsel for Triumph Group Operations, Inc. d/b/a Triumph Accessory Services Obadal, Filler, MacLeod & Klein, P.L.C. 117 North Henry Street Alexandria, VA 22314 Telephone: (703) 299-0784 Facsimile: (703) 299-0254 E-Mail: marshall.filler@potomac-law.com

3CERTIFICATE OF SERVICE I, EbonyEvans, hereby certify that I have onthis date sentbyU.S. Mail, postage prepaid, certified return-receipt requested, the original and one copy ofthe foregoing Respondent's First Request for Production ofDocuments, Federal Aviation Administration v. Triumph Group Operations, Inc. d/b/a Triumph Accessory Services, addressed to: Federal AviationAdministration 800 Independence Avenue, SW Washington, DC 20591 Attn: Hearing Docket Clerk, AGC-430 Wilbur WrightBuilding-Suite 2Wl000 In addition, I hereby certify that I have onthis date sentbyU.S. Mail, postageprepaid, certified return-receipt requested, one copy ofthe foregoing document to: Mark G. Camacho, Esq. Federal Aviation Administration Central Region, ACE-7 Room 506, DOT Building 901 Locust Kansas City, Missouri 64106-2641

/l '(;.-'! ,,·(.-'1 ( {)())

**~--}:<~\' ~-,;-,**  t' ,· -&e Ebony E.v'ans Administrative Coordinator Dated: April 6, 2015

4

# Obadal, Filler, MacLeod & 

# Klein, P.L.C. 

# RECEIVED

April 6, 2015 117 North Henry Street, Alexandria, VA 22314-2903 Telephone 703,299.0784 Fax 703,299.0254 vrww_,potomac-law.com


### Original Delivered by: Certified Mail 

## APR 09 2015 

## HEARING DOCKET

Return Receipt Requested Return Receipt Number: 7011 0110 0001 3259 4812 Federal Aviation Administration 800 Independence Avenue, S.W. Washington, DC 20591 Attn: Hearing Docket Clerk, AGC-430 Wilbur Wright Building-Suite 2W1 000 RE: In the Matter ofTriumph Group Operations, Inc. d/b/a Triumph Accessory Services, FAA Case No. 2014CE070023 To Whom It May Concern: Please find enclosed the original and one copy of a request for production of documents in connection with the above referenced proceeding. A copy ofthe request has also been sent to Mark G. Camacho, Federal Aviation Administration, Central Region, ACE-7, Room 506, DOT Building, 901 Locust, Kansas City, MO 64106-2641. Sincerely,

Marshall S. Filler Counsel for Triumph Group Operations, Inc. d/b/a Triumph Accessory Services

cc: Mark G. Camacho, Esq. 

### ' 

# A o r"1 

## L lo , ,)C\t) April 6, 2015