RECEIVED 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

MAR 3 1 2014 

HEARING DOCKET 

In the Matter of Lincoln Park Aviation, Respondent 

Docket No. FAA-2013-0719 

Case No. 2011EA250037 

Administrative Law Judge J.E. Sullivan 

AGENCY'S FIRST SET OF INTERROGATORIES AND REQUEST FOR 

PRODUCTION OF DOCUMENTS AND REQUEST FOR ADMISSIONS 

The Complainant, the Agency, by its undersigned counsel, hereby requests that Lincoln 

Park Aviation (Respondent) provide responses to the following discovery requests within thirty 

(30) days of service. This request shall be deemed to be continuing to the extent permitted by Rule 

26( e) of the Federal Ru1es 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 as, or has acted at relevant times as, an employee, agent or representative of Respondent. 

DEFINITIONS 

A. When knowledge or information in possession of a party is requested, such request 

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

attomeys. 

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" 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, 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 messages or 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 furnish 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 

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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, 

or furnish 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. 

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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-production. 

INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS 

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 ofthis 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; 

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(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, identity and attach copies of all such documents. 

4. Identity and produce copies of any and all documents or other tangible exhibits 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 or other 

tangible exhibits it intends to introduce into evidence. 

Respectfully submitted, 

Alfred R. Johnson, Jr. 

Regional Counsel 

ny Zachary M.Bea¥ ~~ Attorney 

Federal Aviation Administration 

I Aviation Plaza 

Jamaica, NY 11434 

TEL:718 553-3258 

FAX: 718 995-5699 

Date: March 25, 2014 

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CERTIFICATE OF SERVICE 

I hereby certify that the foregoing AGENCY'S FIRST SET OF INTERROGATORIES 

AND REQUEST FOR PRODUCTION OF DOCUMENTS have been sent via Federal 

Express to the following: 

Frank R. Galella 

Lincoln Park Aviation 

425 Beaverbrook Road 

Lincoln Park, NY 07035 

Judge J.E. Sullivan 

U.S. Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. (El1-310) 

Washington, DC 20590 

FAX: (202)366-7536 

I hereby certify that the foregoing AGENCY'S FIRST SET OF INTERROGATORIES 

AND REQUEST FOR PRODUCTION OF DOCUMENTS have been sent via first class 

mail to the following: 

Federal Aviation Administration (Original and one copy via first class mail) 

800 Independence Avenue, S.W. 

Washington, D.C. 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Room 2014 

MAR 2 5 2014 

Date: -------

L}vJI~ t7~ks Paralegal Specialist 

Federal Aviation Administration 

Office of Regional Counsel 

1 Aviation Plaza 

Jamaica, NY 11434 

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