Jeffrey M. Harper 

~,,,. IFD 

I 'f t:. 

FAA Office of Regional Counsel 

1601 Lind Avenue Southwest 

Renton, Washington 98057 

T (425) 227-2161 

AUG ! 7 2015 

HEAFliNG DOCKET 

F (425) 227-1007 

In the Matter of: 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARING'"Sc---------

WASHINGTON, D.C. 

FAA Case No. 2015WP910067 

DMS No. FAA-2015-2436 

Solid Edge Aviation, L.L.C. 

Honorable Richard C. Goodwin 

Complainant's Initial Discovery Request 

To Respondent: 

In accordance with 14 C.P.R. § 13.220 and the Federal Rules of Civil Procedure, please 

respond to the following Interrogatories, Requests for Production of Documents, and 

Request for Admissions, separately and fully under oath by September 9, 2015. 

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

within your personal knowledge or obtainable by you, but also information in the possession 

of or obtainable by your attorneys, investigators, representatives, employees, agents, or 

anyone acting on your behalf or on their behalf. 

These discovery requests are continuing in nature ,and any information which may be 

discovered by you subsequent to the service and filing of your answers must be brought to 

the attention of the agency attorney through supplemental answers when it becomes 

available to you, at a reasonable time prior to the hearing in this matter. If there are any 

additions, deletions or changes in the answers or information provided at any time prior to 

the hearing Respondent is specifically requested to so inunediately inform the agency 

attorney. If such information is not furnished, the agency attorney at the time of the hearing 

will move to exclude from evidence such information requested and not furnished. 

The agency attorney further requests that the Respondent produce the documents identified 

and designated herein for inspection and copying at the Federal Aviation Administration 
(FAA) Office ofRegional Counsel, Suite 570, 1601 Lind Avenue, Southwest, Renton, 

Washington 98057, by September 9, 2015. 

Privilege 

If, in responding to, or failing to respond to these Interrogatories, Requests for Admission 

and Requests for Production you invoke or rely upon any privilege of any kind, state 

specifically the nature of the privilege; the basis upon which you invoke, rely upon, or claim 

u- .u uu ____ ----------It,-mcllllimg anystaffitory or aeci:swnalreiereJl:ce}f app!Ical5Je; and Identify all document'"s"or.----

other information, including contacts and communications, which you believe to be 

embraced by the privilege invoked. 

Definitions 

"Documettf' means and refers to any e-mail, text message, instant message, calendar, letter, 

book, pamphlet, periodical, report, memorandum, notation, message, social media post, blog 

post, study, working paper, schedule, chart, graph, photograph, index, minutes, lease, 

invoice, purchase order, record of purchase or sale, correspondence, proposal, written 

contract, addendum, transmittal, calculation sheet, accounting records, tax returns worksheet, 

drawing, sketch, blueprint, diary, transcription or taping of telephone or personal 

conversations or conference, or all other written, printed, typed, taped, fihned, or graphic 

matter however produced or reproduced, whether in physical or electronic form. 

"You," "your," "Solid Edge Aviation, L.L.C." or "Solid Edge" refers to the respondent in this 

matter, Solid Edge Aviation, L.L.C., its past and present officers, employees, and agents, or 

anyofthem. 

Respectfully submitted this lOth day of August, 2015. 

Digitally signed by JEFFREY M 

~~ _, _ ,:1:/ HARPER { 4~:. /;&~--J~~---~~ DN: c=US, o=U.S. Government, 

'l_- M H -----ott=ANM;-ou=ANM, cn=JEFFREY 

;: · · arper M HARPER 

FAA Attorney Date•2D15.DB.lD 1 H7•54-D7'DD' 

Complainant's Initial Discovery Request 

In the Matter of Solid Edge Aviation, L.L.C. 

FAA Case No. 2015WP910067, DMS No. FAA-2015-2436 

Page 2 of 7 

Jeffrey M. Harper, FAA Attorney 

T (425) 227-2161 

F (425) 227-1007 
Interrogatories 

Interrogatory No. 1: IdentifY by name, address, and telephone number all persons whom you 

know to have personal knowledge of the matters alleged in the Complaint 

Interrogatory No. 2: Identify by title, date, author, present custodian, and content, all 

documents, including correspondence, obtained by you or in your possession, relating to the 

assertions in the Complaint, your appeal, your answer, and any affirmative defenses which 

-------------- --- -----------you antiCipate rrusffig~ee Requesrfor ProCluction No.1. 

Interrogatory No. 3: Identify by name, address, and telephone number, all persons whom you 

intend to have testify as a factual or expert witness in your defense at the hearing in this 

matter, and for factual witnesses, provide a detailed summary of each person's anticipated 

testimony. 

Interrogatory No.4: Identify by title, date, author, present custodian, and content, all 

documents which you anticipate offering into evidence or using at the hearing in this matter, 

and through which witness or witnesses the document will be offered. See Request for 

Production No.2. 

Interrogatory No. 5: With respect to each expert witness identified in response to 

Interrogatory No. 3, specifY their specific area of expertise and provide a synopsis of their 

credentials, background, training, and experience. 

Interrogatory No. 6: With respect to each expert you expect to call as a witness, state the 

subject matter on which the expert is expected to testifY, the substance of the facts and 

opinions to which the expert is expected to testify, and provide a summary of the grounds for 

each such opinion. 

Interrogatory No. 7: Describe with specificity all facts and evidence you intend to rely upon 

in support of any affirmative defenses raised in any Answer to the Complaint See Request 

for Production No. 3. 

Interrogatory No.8: Describe with specificity all of the facts which you anticipate presenting 

in the course of the hearing in this matter pertaining to the avoidance or mitigation of the 

sanction sought by the FAA in this case. See Request for Production No.4. 

Interrogatory No. 9: For each allegation in the Complaint that is denied-whether outright or 

as a result of having insufficient information or knowledge from which to form a belief as to 

the truth of the allegation, in whole, or in part-state with specificity the facts that are the 

Complainant's Initial Discovery Request 

In the Matter of Solid Edge Aviation, LL.C. 

FM Case No. 2015WP910067, DMS No. FAA-2015·2436 

Page 3 of7 

Jeffrey M. Harper, FAA Attorney 

T (425) 227·2161 

F (425) 227·1007 
basis for that denial as well as the inquiries taken to determine that the allegation in the 

Complaint is not correct. See Request for Production No. 5. 

Interrogatory No. 10: For any Requests for Admissions that are denied-whether outright or 

as a result of having insufficient information or knowledge from which to form a belief as to 

the truth of the allegation, in whole, or in part--state with specificity the facts and evidence 

which are the basis for that denial as well as the inquiries taken to determine that the facts in 

the request for admission are not correct. See Request for Production No. 6. ---

Interrogatory No. 11: Provide a list of all dates on which Mr. Brunner performed safetysensitive functions for Solid Edge. See Request for Production No. 8. 

Requests for Production 

Reguest for Production No. 1: Provide a copy of all documents referred to in your answer to 

Interrogatory No.2 

Reguest for Production No.2: Provide a copy of all documents referred to in your answer to 

Interrogatory No.4. 

Reguest for Production No. 3: Provide a copy of all documents that support your answer to 

Interrogatory No. 7. 

Reguest for Production No.4: Provide a copy of all documents that support your answer to 

Interrogatory No. 8. 

Reguest for Production No. 5: Provide a copy of all documents that support your answer to 

Interrogatory No. 9. 

Reguest for Production No. 6: Provide a copy of all documents that support your answer to 

Interrogatory No. 10. 

Reguest for Production No. 7: Provide a copy of all exhibits that Solid Edge Aviation, L.L.C. 

intends to offer as evidence or will use during any hearing in this matter. 

Request for Production No. 8: Provide a copy of all documents that support your answer to 

Interrogatory No. 11. 

Reguest for Production No. 9: Provide a copy of all documents evidencing the efforts taken 

by Solid Edge Aviation, L.L.C. to obtain the information listed in 49 C.P.R. Section 40.25(b) 

from Era Helicopters for Mr. Robert Grenga 

Complainant's Initial Discovery Request 

In the Matter of Solid Edge Aviation, L.LC. 

FAA Case No. 2015WP910067, DMS No. FAA-2015·2436 

Page 4 of 7 

Jeffrey M. Harper, FAA Attorney 

T (425) 227-2161 

F (425) 227-1007 
Request for ProductionNo. 10: Provide a copy of all documents evidencing the efforts taken 

by Solid Edge Aviation, L.L.C. to obtain the infonnation listed in 49 C.P.R. Section 40.25(b) 

from Tri State Care Flight for Mr. Henry Kowalski. 

Request for Production No. 11: Provide a certified copy of the death certificate for Mr. Larry 

Brunner. 

Request for Production No. 12: Provide a copy of Solid Edge Aviation, L.L.C.'s current 

-balance-slreer(smtement ofimancial posifionf. 

Request for Production No. 13: Provide a copy of Solid Edge Aviation, L.L.C.'s income 

statement (statement of operations I operating statement). 

Request for Production No. 14: Provide copies of Solid Edge's Federal income tax retums 

for 20 n to present, including all schedules and attachments. 

Request for Production No. 15: Provide a copy of all statements for all loans and credit cards 

for which Solid Edge Aviation, L.L.C. is the debtor or to which it has access to credit, for the 

period 2011 to present. 

Request for Production No. 16: Provide a copy of all statements for all checking and savings 

accounts held in Solid Edge Aviation, L.L.C. 's name or to which it has access for the period 

2011 to present 

Request for Production No. 17: Provide a copy of all statements for any other account held in 

Solid Edge Aviation, L.L.C. 's name or to which it has access (including, but not limited to, 

brokerage and money market accounts), for the period 2011 to present. 

Reauests for Admission 

Under 14 C.F.R. § 13.220(b) and Rule 36 of the Federal Rules of Civil Procedure, you are 

requested to admit the truth of the following matters. A matter is admitted unless responded 

to in a reasonable time. The Rules of Practice in FAA Civil Penalty Actions, 14 C.F R. 

§ 13.220(d), defines a reasonable time to be 30 days. The agency requests that an answer be 

served upon the agency attorney either admitting the matter, specifically denying the matter, 

stating why the matter cannot be admitted or denied, or objecting to the request, with reasons 

for the objection stated within 30 days of the date of service upon you, that is, September 9, 

2015. 

Request for Admission No. 1: Admit Eric Brunner has been the manager of Solid Edge 

Aviation, L.L.C. since July 14, 2010, as reflected in the corporate records for Solid Edge 

Aviation, L.L.CC., maintained by the Arizona Corporation Commission. 

Complainant's Initial Discovery Request 

In the Matter of Solid Edge Aviation, LL.C. 

FAA Gase No. 2015WP910067, DMS No. FM-2015·2436 

Page 5 of 7 

Jeffrey M. Harper, FM Attorney 

T (425) 227·2161 

F (425) 227-1007 
Request for Admission No. 2: Admit that, at all times relevant herein, Eric Brunner has been 

the manager of Solid Edge, as reflected in the corporate records for Solid Edge Aviation, 

L.L.C., maintained by the Arizona Corporation Commission. 

Complainant's Initial Discovery Request 

In the Matter of Solid Edge Aviation, L.L.C. 

FAA Case No. 2015WP910067, OMS No. FAA-2015-2436 

Page 6 of 7 

Jeffrey M. Harper, FAA Attorney 

T (425) 227-2161 

F (425) 227-1007 
CERTIFICATE OF SERVICE 

I hereby certify that the foregoing Complainant's Initial Discovery Request has been 

served via facsimile and Certified Mail- Return Receipt Requested this date, to the 

following: 

The Honorable Richard C. Goodwin 

Office of Hearings, M-20 

1200 New Jersey Avenue, S.E. (Ell-310) 

.... -Washington,DC-20!590-

Fax: (202) 366-7536 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2Wl 000 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, DC 20591 

Fax: (202) 267-1293 

Mr. Daryl M. Williams, Esq. 

Bair, Williamsth and Greer, LLP 

6225 North 24 Street, Suite 125 

Phoenix, AZ 85016 

T (602) 445-7714 

F (602) 271-9308 

darylwilliams@bwglaw.net 

Dated this lOth day of August, 2015. 

dana.l.stephenson@faa.g 

ov 

Dana L. Stephenson 

Digitally signed by dana.l.stephenson@faa.gov 

ON: cn=dana.l.stephenson@faa.gov 

Date: 2015.08.10 1 1:03:45 -07'00' 

Office of Regional Counsel (ANM-7) 

Federal Aviation Administration 

1601 Lind Ave. SW 

Renton, W A 98057 

(425) 227-2164 

Complainant's Initial Discovery Request 

In the Matter of Solid Edge Aviation, LL.C. 

FAA Case No. 2015WP910067. DMS No. FAA-2015-2436 

Page 7 of 7 

Jeffrey M. Harper, FM Attorney 

T (425) 227-2161 

F (425) 227-1007