>^C|^^;(I^EPARTMENT OF TRANSPORTATION ^ 

FEDERAL AVIATION ADMINISTRATION f"*^ p( ^ 

OFFICE OF HEARINGS ^ ^ *^ I |/1^:/ ^ 

WASHINGTON, D.C. ,.., *^i j 

In the Matter of Maria Taveras i ;• , r ^""'vucnr'^r--^ 

2008SW210198 

CP10SW0005 o/MT^-ClJIio 

The Honorable Isaac D. Benkin 

^bit)-

COMPLAINANT'S FIRST SET OF INTERROGATORIES, REOUESTS FOR PRODUCTION 

OF DOCUMENTS. AND REOUESTS FOR ADMISSION 

Pursuant to 14 C.F.R. 13.220 and Rules 33 and 34 of the Federal Rules of Civil Procedure, 

Complainant requests that the Respondent provide the following discovery within thirty (30) days. 

It is requested that the Respondent answer the following interrogatories and produce the 

documents hereinafter described. This request shall be deemed to be continuing to the extent 

permitted by Rule 26(e) of the Federal Rules of Civil Procedure so as to require you to file 

supplemental responses. This request is intended to cover all documents in the Respondent's 

possession or subject to Respondent's custody and control and includes documents in the possession 

of each individual who acts, or has acted at relevant times, as an employee, agent or representative 

of Respondent. 

DEFINITIONS 

A. When knowledge or information in possessiwi of a party is requested,' such request includes 

knowledge of the party's agents, representatives and, unless privileged, the party's attorneys. 

B. The pronoun "you" and "yours" refers to the party to whom these interrogatories are addressed. 

C. Unless otherwise indicated, these interrogatories refer to the time, place and circumstances of the 
occurrences mentioned or complained of in the pleadings. 

D. When used with respect to an individual, corporate, business or governmental entity, "identify" 

means state the name and present business or residence addresses of the individuals or entities and 

the employer, governmental or business affiliation and position of the individual. 

E. The terms "document" and "statement" niean without limitation, the following items, whether 

printed or recorded or reproduced by any other me^h^ical process or written or produced by hand: 

agreements, communications, correspondence, telegrams, memoranda, summaries or records of 

telephone conversations, summaries or records of personal conversations or interviews, diaries, 

reports, notebooks, note charts, plans, drawings, sketches, maps, summaries or reports of 

investigations, opinions or reports of consultants, photographs, motion picture films, tape 

recordings, computerized data, brochures, pamphlets, advertisements, circulars, press releases, 

drafts, letters, any marginal comments appearing on any document, and all other writings, including 

electronic writings. 

F. When used with respect to a document, "identify" means ftimish the document itself, or in lieu 

thereof, the name and date of the document, the name and address of the person or persons 

originating the document, the name and address, if any, of the person or persons to whom the 

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

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 if not in possession of the original or a copy, furnish; 

the name and address of the custodian of the original or a copy, pr. ftimish the name and address of a 
person whom you believe is in possession of the original or a copy of such document. 

G. "Oral communication" means any oral exchange with words. 

H. When used with respect to an oral communication, "identify" means state the date and place 

where such oral communication was made, the names of all individuals who participated in the 

communication,'"and their positions, employers, and employers' addresses, the names of all 

individuals who were present at the time the communication was made and their business 

affiliations and positions, the nature and substance of the communication, the nature and substance 

of each document recording or pertaining to such oral communication, and the name and present 

address of the present custodian of each such document. 

I. For all interrogatories to which the responding individual has an objection, state the factual and 

legal basis for the claimed privilege, or any other authority which provides the claimed basis for the 

objection. 

J. 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). 

(e) factual and legal basis for the claimed privilege, or any other authority which 
provides the claimed ground for non-productivity 

INTERROGATORIES 

1. 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. 1 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, identify and attach copies of all such documents. 

4. To the extent not encompassed in your response to request Nos. 1, 2 and 3 above, identify and 

produce statements of all individuals who spoke to, or were interviewed by, the Respondent 

regarding this matter. 

5. Identify and produce copies of any and all documents 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 you intend to introduce into evidence. 

6. In your answer you stated that Respondent is limited financial means. Please have the enclosed 

Financial Statement of Debtor form filled out in order to make a determination as to Respondent's 

ability to pay the proposed civil penalty. 

REOUESTS FOR PRODUCTION OF DOCUMENTS 

1. To the extent not encompassed in your response to request Nos. 1, 2 and 3 above, identify and 

produce statements of all individuals who spoke to, or were interviewed by, the Respondent 

regarding this matter. 

2. Identify and produce copies of any and all documents 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 you intend to introduce into evidence. 

3. Provide signed copies of Respondent's 2006 through 2009 personal tax return forms. 

REOUESTS FOR ADMISSIONS 

1. During a departure delay of the above flight, left your seat and followed a flight attendant to the 

first class to request water. 

2. During Flight 423, you told flight attendants that you were an attorney and knew important 

people in government and at American Airlines, and could have flight attendants fired. 

3. During the deplaning stage of the above flight, you told flight attendant Ms. Julia Sasson that she 

is stupid. 

4. During the deplaning stage of the above flight, you told flight attendant Ms. Julia Sasson that 

American Airlines has poor quality employees like herself, and hence, experiences financial 
problems. 

4. You then proceeded to push the flight attendant backwards, knocking her to the floor of the 

aircraft. 

5. As a result, you physically assaulted the flight attendant as she was conducting her flight duties. 

6. As a result of this incident, you were questioned and detained until the following day. 

Respectftilly submitted, 

Alfi-ed R. Johnson, Jr. 

Regional Counsel 

By: UQ\Jix4. limnMu. Date: _MIMM/I- ' 

Leonid Talisman 

Attorney 

Federal Aviation Administration 

1 Aviation Plaza 

Jamaica, NY 11434 

Telephone: 718 553-3403 

Facsimile: 718 995-5699 
U.S. Department of Justice 

Financial Statement of Debtor 

{Submitted for Government Action on 

Claims Due the United States) 

NOTE: Use additional sheets where space on this form 

is insufficient or continue on back of last page. 

FINANCIAL STATEMENT OF DEBTOR 

Authority tor the solicitation of the requested information is one or more of the following; 5 U.S.C. 301, 901 (see Note, lixccutive Order 6166, June 10, 1933); 

2XIJ.S.C 50l.(;M<;(jf.;31 U.S.C. 951, eMf?.; 44 U.S.C. 3101; 4 CFR 101, f< see?.; 28 CFR 0.160, 0.171 and Appendix to Subpart Y. Fed.R.Civ.P. 33(a), 28 

use . 1651,3201 etseq. 

The principal purpose for gathering this information is to evaluate your ability to pay the Government's claim or judgment against you. Routine 

uses of the information are established in the following U.S. Department of Justice Case File Systems published in Vol. 42 of the Federal Register: 

Justice/CIV-001 at page 5332; Justice/TAX-OOl at page 15347; Justice/USA-005 at pages 53406-53407; Justice/USA-007 at pages 53408-53410; 

Justice/CRIM-016 at page 12274. Disclosure of the information is voluntary. If the requested information is not tiimished, the U.S. Department of Justice has 

the right to such disclosure of the information by legal methods. 

Section 1 

Personal 

Information 

1. Full Name(s) 

Street Address 

City State 

County of Residence 

How long at this residence? 

.?.ip_ 

1 a. Home Telephone: ( ) 

Best Time to Call a.m. 

) 

p.m. 

lb. Cellular Number: (_ 

2. Marital Status: 

n Married D Separated 

DUnmarried (single, divorced, widowed) 

3. Your Social Security No. (SSN) 

4. Spouse's Social Security No. 

3a. Your Date of Birth (mm/dd/yy) 

4a. Spouse's Date of Birth (mm/dd/yy)_ 

5, D Own 1 lome DRent DOther (specify, i.e. share rent, live with relative)_ 

6. List the dependants you can claim on your tax return: (Attach sheet if more space is needed) 

First Name Relationship .Age Does this person First Name Relationship Age Does this person 

live with you'' live with you? 

DNO DVes DNO OVes 

• N O nVes ONO DVes 

Section 2 7. Are you or your spouse self-employed or operate a business? (Check "Yes" if either applies) 

Your DN o D Yes If yes, provide the following information: 

Business 7a. Name of Business 7c. Employer Identification No: 

Information 7b. Street Address _ 

City State .Zip_ 

7d. Do you have employees? • No D Yes 

7e. Do you have accounts receivable? D No • Yes 

If yes, please complete section 8 on page 5. 

.ATTACHMENTS REQl'IRED: Please provide proof of self-employment income for the prior J months 

(e.g. invoices, commissions, sales records, income statement). 

Section 3 

Employment 

Information 

8. Your employer 

Street Address 

City State 

Work telephone no. ( ) 

May we contact you at work? • No 

8a. How long with this employer? 

8b. Occupation 

Zip 

a Yes 

9. Spouse's Emplayer 

Street Address 

Citv State Zip 

Work telephone no. ( ) 

May we contact you at work? • No 

9a. How long with this employer? 

9b. Occupation 

DYes 

^"^ ATT.VCHMENTS REQUIRED: Please provide proof of gross earnings and deductions for the pHst 3 months from each employer (e g 

pay stubs, earnings statements). If year-to-date inlbmiation is available, send only I such statement as long as a minimum of 3 months is 

represented. 
Name SSN Page 2 

Section 4 

Other 

Income 

Information 

10. Do you receive income from sources other than your own business or your employer? (Check all that apply.) 

D Pension D Social Security D Other (specify, e.g. child support, alimony, rental) 

^ ^ ATTACHMENTS REQUIRED; Please provide proof of pension/social security/other income for the pa.st 3 months from each payor, 

including any statements showing deductions. If year-to-date information is available, send only 1 stateinent as long as 3 monttis is represented. 

Section 5 11. CHECKING ACCOUNTS. List all checking accounts. (If you need additional space, attach a separate sheet.) 

Banking, Type of 

111 vestment. Account 

Cash, Credit 11 a. Checking 

and Life 

Insurance Information 

lib. Checking 

FuH name of Bank, Credit 

Union or Institution • 

"Name 

Address 

City/State/Zip 

Name 

Address 

Bank Account No. 

Current Account 

Balance 

City/State/Zip_ 

I Ic. Total Checking Accounts Balances 

12. OTHER ACCOUNTS. List all accounts, including brokerage, savings and money market, not listed in 11. 

12a. 

12b. 

12c. 

Type of 

Account 

Full name of Bank, Credit 

Union or Institution 

Name 

Address 

City/State/Zip 

Name 

Address 

City/State/Zip 

Total Other Account Balances 

Bank Account No. 

Current Account 

Balance 

ATT.\CHMENTS REQUIRED; Please include your current bank statements (checking, savings, money market and brokerage accounts) 

for the past 3 months for all accounts. 

13. INVESTMENTS. List all investment assets below. Include stocks, bonds, mutual funds, stock options, 

certificates of deposits and retirement assets such as IRAs, Keogh and 401(k) plans. 

Name of Company 

Number of 

Shares/Units 

13a. 

13b. 

13c. 

13d. Total Investments $ 

Current 

Value 

$ 

$ 

$ 

Loan Used as collateral 

Amount (if any) on loan? 

$ n No n Yes 

$ D No D Yes 

$ D No D Yes 

14. CASH ON HAND. Include any money that you have that is not in the bank. 

14a. Total Cash on Hand $ 
Name SSN Page 3 

Section 5 15. .AVAILABLE CREDIT. List all lines of credit, including credit cards. (If you need additional space, attach a 

continued separate sheet.) 

Full Name of Minimum 

Credit Institution Credit Limit Amount Owed Payment 

15a. Name $ 

Address 

City/State/Zip_ 

15b. Name 

Address 

City/State/Zip_ 

15c. Total Minimurii Payments $_ 

16. LIFE INSURANCE. Do you have life insurance with a cash value? 

(Term Life Insurance does not have a cash value.) 

16a. Name of Insurance Company 

16b. Policy Number(s) 

16c. Owner of Policy 

D No D Yes 

16d. Current Cash Value $ I6e. Outstanding Loan Balance $_ 

Subtract "Outstanding Loan Balance: line 16e from "Current Cash Value" line t6d = I6f $_ 

^ ^ ^ ATTACHMENTS REQUIRED Please include a statement from the life insurance companies that includes type and cash/loan 

value amounts. If currently borrowed against, include loan amount and date of loan. 

Section 6 17. OTHER INFORMATION. Respond to the following questions related to your financial condition: 

Other (Attach a separate sheet if you need more space. )lnformation 

17a. Do you have a safe deposit box? D No D Yes 

If yes, please include the name and address of location of box, the box number and the contents below: 

17b. Do you have a will? D No D Yes; if yes, where is it kept? 

17c. Are there any garnishments against your wages? D No D Yes 

If yes, who is the creditor? Date of Judgment_ Amount of debt $ 

17d. Are there any judgments against you? D No 

If yes, who is the creditor?_ 

17e. Are you a party to a lawsuit? D No 

If yes, amount of suit $ 

Subject matter of suit 

n Yes 

Date of Judgment_ Amount of debt $ 

n Yes 

Possible completion date_ Court 

17f Did you ever file bankruptcy? D No 

If yes, date filed 

DYe s 

Date discharged 

17g. In the past 10 years did you transfer any assets out of your name for less than their actual value? 

D No D Yes 

If ves. what asset? Value of asset at time of transfer $ 

When was it transferred? To whom was it transferred? 

17h. Do you anticipate any increase in household income in the next 2 years? D No D Yes 

If yes, why will the income increase? (Attach sheet if you need more space.) 

How much will it increase? 

17i. Are you a beneficiary of a trust or an estate? D No 

If yes. name of the trust or estate 

DYe s 

Anticipated amount to be received $^ 

When will the amount be received? 

17j. Are you a participant in a profit sharing plan? D No 

If yes, name of plan 

DYe s 

Value in plan $ 
Name SSN Page 4 

Section 7 

Assets and 

Liabilities 

•Current 

Value is 

the amount 

you could 

sell the 

asset for today 

18. PURCHASED AUTOMOBILES, TRUCKS AND OTHER LICENSED ASSETS. Include boats, RV's, 

motorcycles, trailers, etc. (If you need additional space, attach a separate sheet.) 

Current 

•Current Loan Name of Purchase Monthly 

Value Balance Lender Date Payment 

18a. $ $ $ 

Description 

(year, make, model) 

18b. 

LEASED AUTOMOBILES, TRUCKS AND OTHER LICENSED ASSETS. Include boats, RV's, 

motorcycles, trailers, etc. (If you need additional space, attach a separate sheet.) 

Description Lease 

(year, make, model) Balance 

Name and 

Address of 

Lessor 

Lease 

Date 

Monthly 

Payment 

18c. 

18d. 

.VTT.XCH.MEINTS REQUIRED; Please include your current statement from lender with monthly car payment and current 

balance of the loan for each vehicle purchased or leased. 

20. REAL ESTATE. List all real estate you own. (If you need additional space, attach a separate sheet.) 

Street Address, City 

State, Zip, County Date Purchase •Current Loan Monthly 

Lender/Lien Holder Purchased Price Value Balance Pvmt 

20a. 

20b. 

2 1 . PERSONAL ASSETS. List all personal assets below. (If you need additional space, attach a separate sheet) 

Fiiiniliire'Personal effects includes the totnl current market value of your household such as furniture and appliances 

Other Personal Assets includes all artwork, jewelry, collections, antiques or other assets 

Description 

2Ia. 

21b. 

21c. 

21d. 

2le. 

Furniture/Personal Effects $ 

Other: (List below) 

Artwork 

.lewclry 

Current 

Value 

$ 

$ 

$ 

$ 

$ 

Loan 

Balance 

$ 

$ 

$ 

$ 

$ 

Lender 

Monthly 

Payment 

$ 

$ 

$ 

$ 

% 

Date of 

Final Pvmt 
U Name SSN Page 5 

'•A 

;| Section 7 

:,) continued 22. BUSINESS ASSETS. List all business assets and encumbrances below, include Uniform Commercial Code filings. (If you need 

: 3 additional space, attach a separate sheet.) Tools used in Trade or Business includes the basic tools or books used to conduct your business, 

^j excluding automobiles Other Business Assets includes machinery, equipment, inventory or other assets. 

Current Loan Monthly Date of 

Description Value Balance Lender Payment Final Pvmt 

22a. 

22b. 

22c. 

22d. 

22e. 

Tools used in Trade/ 

Business 

Other; (List below) , 

Machinery 

Equipment 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

Section 8 23. ACCOUNTS/NOTES RECEIVABLE. List all accounts separately, including contracts awarded, but not 

Accounts/ started. (If you need additional space, attach a separate sheet.) 

Notes 

Receivable Description Amount Due Date Due Age of Account 

I \e only if 23a. Name $ • 0-30 days 

needed Address • 30-60 days 

City/State/Zip O 60-90 days 

D 90+ days 

23b. Name $ • 0-30 days 

Address • 30-60 days 

City/State/Zip • 60-90 days 

• 90+ days 

23c. Name $ • 0-30 days 

Address .-. • 30-60 days 

City/State/Zip • 60-90 days 

Q 90+ days 

23d. Name $ • 0-30 days 

Address • 30-60 days 

City/State/Zip • 60-90 days 

D 90+ days 

23e. Name $ • 0-30 days 

Address • 30-60 days 

City/State/Zip • 60-90 days 

a 90+ days 

23f Name ~ $ " a 0-30 days 

Address • 30-60 days 

City/State/Zip • 60-90 days 

D 90+ days 

Add "Amount Due" from lines 23a through 23f = 23g $_ 
Name SSN Page 6 

Section 9 

Monthly 

Income and 

Expense 

Analysis 

If only one 

spouse has 

a debt, but 

both have 

income, list 

the total 

household 

income and 

expenses. 

Total Income 

Source 

24. Wages (yourself) $. 

25. Wages (spouse) 

26. Interest - Dividends 

27. Net Business Income 

28. Net Rental Income 

29. Pension/Social Security . 

30. Pension/Social Security . 

(Spouse) 

31. Child Support 

32. Alimony 

33. Other 

34. Total Income $. 

Gross monthly 

Total Living Expenses 

Expense Items' 

35. Rent/Mortgage 

36. Electric 

37. Natural Gas 

38. Cable TV 

39. Telephone 

40. Water 

41. Food 

42. Car Payment 

43. Gasoline 

44. Car Insurance 

45. Cell Phone/Pager 

46. Other Utilities 

47. Clothing & Misc. 

48. Health Care 

49. Court Ordered Payments 

50. Child/Dependant Care 

51. Life Insurance 

52. Other secured debt 

53. Other expenses 

54. Education Expenses 

55. Total Living Expenses 

Actual MffffthlY 

$ 

**^ATTACHMENT S REQlilRED: Please include; 

A copy of your last Fomi 1040 with all Schedules 

Proof of all current expenses that you paid for the last 3 months, including utilities, rent, insurance, property taxes, etc. 

Proof of all non-business transportation expenses (e g car payments, lease payments, fuel, oil, insurance, parking, registration) 

Proof of payments for health care, including health insurance premiums, co-payments and other out-of-pocket e.\penses 

Copies of any court order requiring payment and proof of such payments for the past 3 months 

CERTIFICATION 

I declare that I have examined the information given in this statement and, to the best of my knowledge and belief, it is true, correct, 

and complete, and I further declare that I have no assets, owned either directly or indirectly, or income of any nature other that as 

shown in this statement, including any attachment. 

Signature Social Security No. Date 

WARNING 

False statements are punishable up to five years imprisonment, a fine of $250,000, or both pursuant to 18 U.S.C. §1001. 

Expenses generally not allowed: We generally do not allow you to claim tuition for private schools, public 

or private college expenses, charitable donations, voluntaiy retirement contributions, payments on unsecured debts 

such as credit card bills and other similar expenses. However, we may allow these expenses, if you can prove that 

they are necessary for the health and welfare of you or your family. 
CERTIFICATE OF SERVICE 

I hereby certify that on this day copies of the foregoing complainant's first set of interrogatories, 

requests for production of documents, and requests for admission were sent via Federal Express 

addressed as follows: 

The Honorable Isaac D. Benkin 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor 

Room El2-320 

Washington, D.C. 20590 

Federal Aviation Administration (Original and one copy) 

600 Independence Avenue, SW 

Wilbur Wright Building - Room 2W1000 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Alexei Schacht 

Nalven & Schacht, Attorneys at Law 

350 Fifth Avenue, Suite 4022 

New York, NY 10118 

Date: i:i^?//' 

)an Maher 

'Management and Program Analyst 

Office of Regional Counsel 

1 Aviation Plaza 

Jamaica, NY 11434