U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

RECEIVED 

APR 0 9 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 FOR PRODUCTION OF DOCUMENTS 

Pursuant to the discovery guidelines set forth in Section 220 of the Rules of Practice in 

FAA Civil Penalty Actions, 14 C.F.R. § 13.220, Triumph Group Operations, Inc. d/b/a Triumph 

Accessory Services ("Respondent") hereby requests 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 or information, as itemized in this document, through the date of the 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 of Documents refers to the time, 

place and circumstances of the occurrence referenced in the Complaint. 

B. Where knowledge, information or documents possessed by a party is requested, that request 

includes knowledge of the 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. When used with respect to a document, "identify" means to furnish the document itself, or in 

lieu thereof, the name and date of the document, the name and address, if any, of the person 

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or persons to whom the document is addressed, the names and addresses of all persons to 

whom copies of the document were or have been sent, and the organization, firm or agency 

with which all such persons were connected as of the date of the document, and state whether 

you are in possession of the original or copy, furnish the name and address of a person whom 

you believe is in possession of the original or a copy of such document. 

E. The term "identify", when referring to a person, means to identify the person by name, 

occupation( s ), and business address. 

F. The term "document" and "statement" mean without limitation, the following items, whether 

printed or recorded or reproduced by any other mechanical process or written or produced by 

hand: agreements, communications, correspondence, telegraphs, memoranda, electronic 

messages, court or legal documents, summaries or recordings of telephone conversations, 

summaries or records of personal conversations or interviews, summaries or reposts of 

investigations, opinions or reports of consultants, diaries, graphs reports, notebooks, note 

charts, plans, drawing, sketches, maps, photographs, motion picture films, brochures, 

pamphlets, advertisements, circulars, press releases, draft letters, and marginal comments 

appearing on any document, and all other tangible information capable of being read, viewed 

or heard. 

G. All documents requested as to which the responding individual claims privilege or any other 

objection as a ground for non-production shall be identified chronologically as follows: 

a. date, 

b. title, 

c. type of document (e.g. memorandum, report, chart, etc.) 

d. subject matter (without revealing the information as to which privilege or statutory 

authority is claimed; and 

e. factual or legal basis for the claimed privilege, or any other authority that provides the 

claimed ground for non-production. 

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REQUEST FOR PRODUCTION OF DOCUMENTS 

Respondent respectfully requests copies of the releasable portions of the 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 

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CERTIFICATE OF SERVICE 

I, Ebony Evans, hereby certify that I have on this date sent by U.S. Mail, postage prepaid, 

certified return-receipt requested, the original and one copy of the foregoing Respondent's First 

Request for Production of Documents, Federal Aviation Administration v. Triumph Group 

Operations, Inc. d/b/a Triumph Accessory Services, addressed to: 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building-Suite 2Wl 000 

In addition, I hereby certify that I have on this date sent by U.S. Mail, postage prepaid, 

certified return-receipt requested, one copy of the 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 

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'(;.-'! ,,·(.-'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 0 9 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 of Triumph 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 of the 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