U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

FEDERAL AVIATION ADMINISTRATION, 

Complainant, 

RECEIVED 

JAN 1 2 2015 

HEARING DOCKET 

vs. 

Docket No. FAA-2013-0291 

FAA Case No. 2011S0290032 

AIRBORNE MAINTENANCE AND 

ENGINEERING SERVICES, 

Respondent. 

Judge Sullivan 

REPLY IN SUPPORT OF MOTION TO COMPEL AND EXCLUDE 

December 19, 2014, the FAA filed a motion to compel and exclude relating to 

Respondent's failure to comply with its discovery obligations. On January 6, 2015, Respondent 

responded to this motion. To the extent necessary, the FAA requests leave 1 to file, and does file, 

this reply in support.2 The Response, while colorful, provides no legitimate explanation for why 

Respondent failed to comply with its discovery obligations, and the Motion should be granted. 

Respondent's Failure To Respond To Interrogatory #133 

With regards to Interrogatory #13, Respondent argues that the FAA's Motion has not 

merit because (1) the litigation schedule does not call for witness lists to be exchanged until 

April 9, 2015 and (2) the obligation to update discovery responses is continuing in nature. See 

Response at 7-11. Respondent's argues is that it did nothing wrong because it was not required to 

answer the interrogatory in question - indeed, Respondent asserts that it may simply continue to 

1 Part 13 references only Motions and Responses, but is silent as to the status of Replies in Support. 2 The Response also spends several pages presenting Respondent's view on the merits of the case, see Response at 

13-15. As these observations bear no relation to the Motion at hand, they will not be addressed here. 3 The Motion also referenced Interrogatory #14. Respondent has subsequently complied with tbat request. 

1 
"discover" new witnesses in the coming months, see Response at 11. This argument is without 

foundation. 

Respondent is correct that final witness lists are not due until April2015. However, that 

the parties are required to make prehearing submissions, including witness lists, in April 2015 

does not relieve Respondent of its obligation to answer discovery requests about potential 

witnesses. 4 Respondent's obligation to answer interrogatories is a distinct one from Respondent's 

obligation to make a prehearing submission. 

Respondent is also correct that the obligation to supplement discovery responses is 

continuing in nature. However, that the Respondent's obligation to supplement continues after 

discovery does not mean that this obligation did not exist during discovery. Respondent was 

served with the Agency's First Discovery Requests, including Interrogatory #13, in January 

2014. Respondent's answers were due 30 days later. Respondent asserts that "New or updated 

[discovery] responses can be hatched and submitted seasonably," rather than "immediately," 

after each "new piece of information" is discovered. See Response at 10-11. However, the 

circumstances of this case do not involve Respondent discovering new pieces of information. 

Nor do they involve Respondent seasonably providing information. Respondent's disclosure of 

six potential witnesses in December 2014 would only be "seasonable" and appropriate if these 

witnesses and their potential testimony had only recently come to Respondent's attention. 

However, Respondent's December 23, 2014 discovery supplement discloses no "new piece of 

information" that Respondent has only now discovered. Rather, it discloses four witnesses who 

are either management officials at Respondent, or who were management officials at 

Respondent's sister corporation (Capital Cargo International Airlines, which is represented by 

4 Respondent itself filed discovery requests about the FAA's potential witnesses, aud made no objection to the 

FAA's discovery requests about potential witnesses. 

2 
opposing counsel in a companion case to this one), and who are to be testifYing primarily about 

conversations that took place several years ago. Respondent does not assert that it was unaware 

of these witnesses or this potential testimony. 5 Rather, Respondent asserts, without explanation, 

that it did not need to disclose it until after discovery had closed. 

These circumstances s·.1pport the FAA's request ·~iet tnese newly-disclosed witnesses be 

excluded. In its Response/Reply, R<Jspondent repeat~:dly compares its conduct with that of the 

FAA, arguing that the FAA "flagrantly" violated the scheduling order by making its initial 

disclosures 12 days late. Such a comparison reflects poorly on Respondent. The FAA's 

disclosure was less than two weeks late because the undersigned was out of the office for a 

family medical emergency and, ultimately, a funeral. The FAA submitted its disclosure the same 

day that the undersigned was able to return to work. Respondent's answer to the FAA's 

interrogatory about potential witnesses, on the other hand, was over nine months late because 

Respondent chose to withhold information that it could have, and was required to, disclose. 

Parties ask questions like these, about potential witnesses, not only so that they can 

receive the information at some time before hearing, but also so that they can have the 

opportunity to explore the potential testimony as appropriate through additional discovery. 

Respondent here denied the FAA any opportunity to engage in this sort of follow-up 6 A party 

5 Indeed, most of the testimony identified in the December 23,2014 disclosure appears to relate solely to 

Respondent's allegation that Inspector Lipinski is biased, a charge that Respondent has made the centerpiece of its 

defense in this case. 6 In an effort to rebut this notion, the Respondent points out that it identified various individuals in response to other 

discovery obligations. See Response at 11-13. And it is true that Respondent identified quite a few individuals- 39 

in its initial disclosures, and 70 in response to different interrogatory. See Response Exhibit 5 Attachment I, Exhibit 

6 Attachment I. These responses were insufficient to provide the information required in response to Interrogatory 

13. In these attachments, Respondent identifies scores of individuals, almost all of whom are identified as 

performing a handful of specific maintenance items or who are identified only as having "general knowledge of the 

situation." These responses are unhelpful in directing further discovery- the information provided for each 

individual is insufficient to inform the opposing party what the individual knows, and the number of individuals 

involved is too great for individual follow-up as to each. For example, other discovery responses indicated that the 

category of persons with "general knowledge of the situation" might simply be individuals who had discussed, but 

had no personal knowledge of the situation. As Respondent notes, the FAA ultimately took only one deposition out 

3 
should not be permitted to knowingly withhold information throughout the course of discovery, 

and then still take advantage of that information later in litigations. 

Respondent's Failure to Make Timely Initial Expert Disclosures 

Respondent also prcvides no suitable explanation for why it did not include Becker and 

Savastano in its initial expert disclosures. See Response at 12-13. Respondent presents no 

argument that their identified testimony was truly rebuttal testimony, rather than something that 

should have been in initial expert disclosures. Rather, Respondent asserts that the timing of this 

disclosure was "based on th.e lateness of Complainant's disclosure" and that "it was entitled to 

react to the unexcused and late disclosure of Complainant's experts by proposing to use expert 

rebuttal witnesses." Response at 12-13. 

The timing of the FAA's disclosure has no bearing on Respondent's right to identity 

rebuttal experts (or initial experts)- either the testimony for Becker and Savastano is rebuttal 

testimony, or it is not. The FAA's untimely initial expert disclosure might have justified a failure 

to timely submit an expert rebuttal, because Respondent might have needed more time to prepare 

the rebuttal testimony. But it does not transform non-rebuttal testimony into rebuttal testimony, 

or justify untimely filing of initial expert disclosures. 

of those- that of management official Jeffrey Becker, who was present at the time the aircraft were inspected by the 

FAA and who responded to the Letter of Investigation in this case. Mr. Becker was noticed for a personal deposition 

and was also identified by Respondent as its representative for a Corporate deposition, resulting in only a single 

deposition, rather than two. Notably, Mr. Becker's testified that no one at AMES and none of the mechanics who 

had worked on the aircraft had any present personal knowledge of the condition of the aircraft at the pertinent time 

in this case, except that they could identify what records they had made at the time, see, e.g., Attachment Hat 39-46, 

75-76, 78-81, further demonstrating the insufficiency of the information provided by Respondent to addressing the 

important matter of who might testify at hearing, what they might testify about, and whether any follow-up might be 

needed. 

As Mr. Becker's deposition was ultimately delayed until late October due to Mr. Becker's medical problems in the 

spring, the unavailability of opposing couusel in July 2014 and the undersigned in August 2014 and the subsequent 

deposition scheduling issues between the parties, taking further depositions to follow up on Mr. Becker's would 

have required leave of court to extend the deposition period beyond November 7, 2014. 

4 
While the timing at issue here is not so severe as the timing with regards to Respondent's 

answer to Interrogatory # 13 (over three weeks late compared to over nine months late), the 

commonality is that Respondent simply chose not to comply with its discovery obligation. 

Respondent could have, but chose not to, disclose B:;cker and Savastano in its initial expert 

disclosures. Respondent now argues that the untimeline~s of the FAA's initial expert disclosure 

(as a result of a death in the undersigned's family) provides it with carte blanche to make its own 

untimely initial expert disclosures. But an unavoidable, good cause delay in one party's 

discovery responses does not authorize the opposing party to disregard its own obligations. 

Conclusion 

WHEREFORE, the FAA respectfully requests that the Judge grant the FAA's motion to 

compel and exclude testimony with regards to Respondent's refusal to comply with its discovery 

obligations with regards to witness identification, including the exclusion of Becker and 

Savastano as expert witnesses, the exclusion of the witnesses disclosed on December 23, 2014, 

the exclusion of any other witnesses Respondent may later identify, and that Respondent 

complete its disclosure with regards to Hancher. 

b.-

Respectfully submitted this l day of January, 2015. 

CHRISTOPHER STEVENSON 

Attorney 

Office of the Regional Counsel 

5 
CERTIFICATE OF SERVICE 

I hereby certify that the foregoing Reply in Support of Motion to Compel and Exclude was sent: 

original and one copy via certified mail to: 

Federal Aviation Administntion 

800 Independence Avenue, S.W. 

Washington, D.C. 20591 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2W1000 

one copy via certified mail and facsimile to: 

The Honorable J.E. Sullivan 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE (Ell-310) 

Washington, DC 20590 

facsimile: (202) 366-7536 

Robert P. Silverberg, Esq. 

1101 30th Street, NW, Suite 120 

Washington, D.C. 20007 

Facsimile: (202) 944-3306 

Legal 

~=N~ Assistant 

Office of the Regional Counsel 

JAN 7 2015 

Dated 

6 
In The Matter Of: 

Airborne Maintenance and Engineering Services 

Jeffrey Becker 

October 29, 2014 

Legal Realtime Reporting 

622 E. Central Blvd. 

Orlando, FL 32801 

Original File 102914 Becker final. txt 

Min-U-Script® with Word Index 
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39 

discovery, so that we don't show up at a hearing or 

a judgment motion, and all of a sudden, there are 

three affidavits from mechanics saying, well 

actually, I observed this, that and the other detail 

and I do happen to remember. 

So if you, Mr. Silverberg, as the attorney for 

AMES and you, Mr. Becker, as the corporate 

representative for AMES, are willing -- let me 

confirm. You are saying that none of these 

individuals who worked on the aircraft in August of 

2009, October 2009, March of 2010, have any personal 

recollection of -- we can go plane by plane if you 

like. 

MR. SILVERBERG: You didn't -- this calls out 

a date in May of 2010. That's what this calls out. 

These gentlemen worked on the airplane much earlier 

than May, as you know. 

MR. STEVENSON: So, okay. 

MR. SILVERBERG: That's --

MR. STEVENSON: As of -- okay. Let's just 

take it back to an individual plane. We've been 

talking about November 899. 

MR. SILVERBERG: This is your 30(b)6 question. 

You're asking Mr. Becker to testify what inspectors 

did in connection with the main landing gear change 
1 

2 

3 

or the "C" Check at an earlier date or are you 

asking what they 

MR. STEVENSON: At this time right now, I am 

4 asking about the original reinstallation. 

5 MR. SILVERBERG: That's not the 30(b)6 

6 question and you know that. 

7 BY MR. STEVENSON: 

8 Q. Okay. That's -- as to each of the three 

9 aircraft, the identity of any individuals currently or 

10 formerly employed by AMES who have personal knowledge of 

11 the original reinstallation of the MLG and flying doors 

12 by AMES. 

13 

14 

15 

MR. SILVERBERG: Asked and answered. 

MR. STEVENSON: Okay. So --

MR. SILVERBERG: We've been through that. 

16 BY MR. STEVENSON: 

17 Q. So you don't. These people have no personal 

18 knowledge. They are or the extent of their personal 

19 knowledge to be able to say, well, I signed that off. 

20 This is the process that I followed. 

40 

21 MR. SILVERBERG: That's your question. That's 

22 the form of your question. Go ahead. Continue. 

23 A. I can go ahead and answer by stating that we 

24 performed an investigation when this first came to our 

25 attention. Any technicians and inspectors that had taken 
1 part in any of these installations -- and I don't 

2 remember specifically, but I do recall that the answers 

3 were exactly as Bob referenced. They reviewed the 

4 maintenance manual, they reviewed the nonroutine sign 

5 offs and there was no additional information they 

6 provided other than that at the time we did the 

7 investigations. 

8 BY MR. STEVENSON: 

9 Q. Okay. And is that still true today that they 

10 would not be able to provide any additional information? 

11 I don't know why it would've changed, but I have to ask. 

12 A. We have not talked to them since the initial 

13 investigation. 

14 

15 

Q. Okay. And is that -- just for clarity of the 

record, I had been asking you about just 899AA. Is this 

16 also true of the original reinstallation, sorry, of the 

17 main landing gear replacement on N898AA, in or about 

18 October of 2009? 

41 

• 19 

20 

21 

22 

23 

24 

25 

A. Yeah. My recollection is that we, like I said, 

we initiated an investigation. I don't recall if it was 

tail number specific. I know it was specifically about 

the subject of the rigging of the doors because that's 

what the issue was at hand, yes. But without looking at 

our discrepancy notice files or the corrective action 

report files, I can't answer specific tail numbers or 
42 

1 specific individuals. 

2 Q. But my understanding from what you just said is 

3 that at the time that AMES was internally investigating 

4 this, you interviewed these people and they could not 

5 provide any information other than 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

A. 

Q. 

Correct. 

This is what the records are? 

A. Correct. 

Q. Okay. And again, same question. With regards 

to N287SC and the main landing gear replacement performed 

in March of 2010, is that the same situation, those 

individuals cannot provide additional information beyond 

identifying the records? 

A. Correct. 

Q. Okay. Now, there have been references in your 

discovery responses to a, if I understand correctly, a 

tire replacement on N287SC that occurred after AMES 

replaced the main landing gear but before the vibration 

19 incident on April 10 of 2010. Do I understand that 

20 correctly? 

21 

22 

A. 

Q. 

23 changed? 

Right. 

Okay. And how do you know that the tire was 

24 A. I was provided, from Capital Cargo, a print out 

25 of the maintenance performed on that aircraft over a time 
43 

1 period -- I believe it was from the time it left our 

2 facility on or about the middle of March to the time that 

3 it left Cincinnati after the vibration work. 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

Q. Okay. And do you have a copy of that print 

out? 

MR. SILVERBERG: It's in our materials. 

A. I believe it is part of the omnibus. I mean 

the discovery materials. 

MR. SILVERBERG: I have a copy of it. 

MR. STEVENSON: Okay. 

MR. SILVERBERG: You should have a copy of it. 

MR. STEVENSON: Can you identify what number 

that was? 

14 MR. SILVERBERG: 111. While you're rooting 

15 through your files, let's go off the record. I'm 

16 going to take a quick bathroom break. 

17 {Proceedings recessed at 9:43 a.m.) 

18 {Proceedings resumed at 9:53 a.m.) 

19 BY MR. STEVENSON: 

20 Q. All right. So I understand correctly, the tire 

21 change took place on March 25th, 2010, which would've 

22 been three days after the landing gear was approved for 

23 return to service by AMES? 

24 

25 

A. 

Q. 

Correct. 

And do you know what physically is involved in 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

44 

changing the tire on a 727? 

A. Yes. Based on the procedures both published by 

Capital Cargo and that are in the AMM, yes. 

Q. And can you summarize those? 

A. Well, again, I'd like to have the documents 

because I can point specifically to it. It's easier for 

me to communicate the steps and make sure I don't miss 

any key items. 

Q. I understand. 

in detail. But I mean, 

I'm not asking you to go into it 

you said you knew what the 

procedures were. I'm just asking you in general terms 

12 what the procedure is. We can look at the documents at 

13 some later time if we want, but right now I'm just asking 

14 you --

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

MR. SILVERBERG: Do you have the document that 

you're referring to? 

MR. STEVENSON: I'm guessing no, unless you 

provided it to me, since this document was not 

identified in your discovery response such that I 

realized what it was. 

MR. SILVERBERG: So you're just asking this 

witness to summarize his understanding of the 

document? We don't have the document in front of 

us? 

MR. STEVENSON: We're not -- I'm not handing 
1 

2 

3 

him a document. 

MR. SILVERBERG: Okay. 

MR. STEVENSON: I'm asking him to summarize 

4 his understanding of what is involved in changing 

5 the tire on one of the main landing gear on a 727. 

6 A. As it applies to the flying door, one of the 

7 steps -- and this is for the outboard tires only -- the 

8 flying door is in the way of removing the tire. And 

45 

9 there is a banana link or what's called an actuating rod, 

10 I believe, in the maintenance manual, and there's some 

11 steps in order to move the door out of the way in order 

12 to get access to the wheel. 

13 BY MR. STEVENSON: 

14 Q. Okay. And how do you know -- okay. Let me --

15 you said that that was for an outboard tire? 

16 

17 

18 

19 

20 

21 

22 

23 

24 

A. Mm-hmm. 

Q. Do you know if this was an inboard or outboard 

tire that was replaced on March 25, 2010? 

A. On March 25th, it was an outboard. It was a 

number four, based on my memory. 

Q. Okay. And are those -- how are the tires 

numbered for the 

A. Left to right, it's 1, 2, 3, 4. 

Q. And just for the clarity of the record, as is 

25 usual with aviation, I presume that left to right is from 
1 Q. Okay. And do you have any reason to believe 

2 that he would write something down in a statement for an 

3 EIR that he did not believe to be accurate? 

75 

4 MR. SILVERBERG: Objection. You're asking him 

5 to speculate about Mr. Gasche's state of mind. 

6 A. Yeah. I was going to say, again, I've never 

7 met Mr. Gasche. That letter is the extent of any, any 

8 sort of knowledge I have of him. 

9 BY MR. STEVENSON: 

10 

11 

12 

13 

Q. Sure. 

A. But I repeat that he somehow put that together 

three months later. 

Q. Now, we have been talking about the time that 

14 you were in Toledo. Did you ever personally examine 

15 these aircraft after they were back in Wilmington? 

16 A. Oh, after they ferried from Toledo to -- and 

17 Bradley to Wilmington? 

18 

19 

Q. 

A. 

Yes. 

Yes. I went down and at least on a daily 

20 basis, walked around the aircraft and talked to Charles 

21 Working, who was the director of maintenance that was 

22 there for Capital Cargo prepping the airplanes and 

23 talking to my inspectors. 

24 Q. Okay. Did you have the opportunity to 

25 personally examine the other aircraft like you had with 
1 287SC? 

2 

3 

A. 

Q. 

Yes. 

Okay. And what, if anything, do you remember 

4 observing about the condition of those aircraft? 

5 A. Yeah, I mean, we were under direction -- we 

6 were under direction from Charles Working. We were -- I 

7 recall that our marching orders from the operator, which 

8 is completely understandable in the case, was we need to 

9 make this like new. We want this -- we want these 

76 

10 landing gear or these flying doors immaculate. We don't 

11 want any opportunity for Frank or any other FAA inspector 

12 

13 

14 

15 

16 

to inspect any of 

any more problems. 

So I do 

inspect the flying 

comb. They wanted 

these 

recall 

doors 

us to 

airplanes after the fact and find 

that my inspectors were asked to 

and the areas with a fine tooth 

write up every nick, every minor 

17 flaw -- which is not normal, by the way, in a "C" Check 

18 environment or anything else. Unless there's a specific 

19 job card that drives you to a specific area. 

20 Q. Sure. Do you have any personal recollection of 

21 what, if any, nicks or flaws were on these aircraft? 

22 A. Urn, no. I mean, most of my dialogue -- I mean, 

23 I knew that there was nonroutines. Written, many 

24 nonroutines. I remember talking to Dan Boggs about it 

25 and saying, yeah, there's a lot of nicks and bumps and 
78 

1 mean, I, on different occasions, I've asked my QC 

2 manager, my QC supervisors, do you recall; I'll show them 

3 a piece of paper. But nothing, from what you're asking, 

4 nothing has come up. 

5 BY MR. STEVENSON: 

6 

7 

Q. Sure. You mentioned earlier that in order to 

know if the gears sorry. If the flying doors were out 

8 of rig, you would have to perform a gear swing. Do you 

9 know, did AMES perform a gear swing at some point while 

10 these aircraft were in your facility? 

11 A. Oh, yeah, absolutely. 

12 MR. SILVERBERG: Are we talking about --

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

A. Each one of them. 

MR. SILVERBERG: -- after they were returned 

to Wilmington or are we talking about the original 

work? 

MR. STEVENSON: We're talking about them when 

they were in Wilmington starting at the end of May 

2010? 

MR. SILVERBERG: Okay. 

A. Yes. 

question was. 

frame. 

Yes. And that's what I understood the 

And we're talking about the May time 

BY MR. STEVENSON: 

Q. Yes. Do you know when those gear swings were 
1 performed? 

2 A. The dates and times are listed on the 

3 nonroutine and partial worksheets for each of the 

4 airplanes. 

5 Q. Okay. Would these gear swings have been 

6 something that was performed immediately when the 

79 

7 aircraft was brought in or would this have been something 

8 that was performed after other maintenance was done to 

9 make sure that everything was good to go at that point? 

10 A. My recollection is that we didn't perform any 

11 gear swings when the airplanes first got there. We only 

12 performed them as a function of after we replaced all the 

13 hardware and inspected the areas. 

14 

15 

16 

17 

Q. Sure. 

A. Again, that's my recollection on it. 

recall anything otherwise. 

Q. Okay. I want to ask you some specific 

I don't 

18 questions on -- these are essentially more specific 

19 versions of something I already asked, but I just want to 

20 confirm. 

21 Other than looking at the maintenance write 

22 ups, do you personally or collectively as AMES, have any 

23 knowledge of whether at the time these aircraft were 

24 brought into Wilmington at the end of May, 2010, there 

25 was any missing mounting hardware in the landing gear 
1 assemblies or the flying doors? 

2 A. No. 

3 

4 

5 

6 

7 

8 

9 

10 

11 

Q. Okay. Do you --

MR. SILVERBERG: Wait a minute. I'm sorry. 

The answer no is -- you're asking about his 

recollection? 

MR. STEVENSON: I asked him if he has any 

knowledge of that beyond what's in the maintenance 

documents. 

A. Right. My answer is no. 

MR. SILVERBERG: Okay. 

12 BY MR. STEVENSON: 

80 

13 Q. Okay. Again, and all these questions I'm going 

14 to refer to the same time frame and the same aircraft. 

15 Let me know if I've asked too many and it's gotten 

16 confusing. 

17 Do you have any knowledge as to whether or not 

18 there were improperly installed spacing shims in the 

19 hinges? 

20 No. 

21 

A. 

Q. Do you have any knowledge of whether or not 

22 there was damage to flap track fairing mating surfaces? 

23 A. No. And again, this is outside of what's 

24 

25 

already -- what's documented. 

Q. Absolutely correct. I understand that there 
1 

2 

3 

4 

are the documents, and the documents, we'll talk about 

those in a little bit. I just wanted to --

A. Okay. 

Q. -- I just wanted to distinguish for the point 

81 

5 of -- sake of clarity. Do you know, other than from what 

6 the documents say, whether or not there was damage to any 

7 of the door structures that were adjacent to the attached 

8 fittings? 

9 A. No. 

10 Q. Okay. Do you know if there was any damage to 

11 the hinge fairing fittings? 

12 A. Hinge fairing fittings. Is this the cover, the 

13 hinge covers or is that something different? 

14 Q. Well, unfortunately, this is one of those 

15 problems for me with Inspector Lipinski not being here is 

16 I do not have a technical adviser. So if that 

17 phraseology does not make any sense to you, then I can't 

18 really clarify. 

19 A. Okay. I mean, to clarify, the hinge covers 

20 specifically in regards to the piano hinges. 

21 Q. Okay. 

22 

23 

24 

25 

A. 

Q. 

A. 

Q. 

Yes. I remember looking at those --

Okay. 

-- myself. 

And what did you see when you looked at them?