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^ 

U.S, Deportment 

of Transportation 

Federal Aviation 

Administration 

New England Region 

Office of the Regional Counsel 

12 New England Executive Park 

Burlington. MA 01803-5299 

Telephone: (781)238-7045 

FAX. (781)236-7055 

February 12, 2plO 

FEDERAL EXPRESS AND FACSIMILE (202) 366-7536 '' ' 

The Honorable Isaac D. Benkjn 

Administrative Law Judge IV!...,. -. 

Office of Hearings, M-20 

U.S. Deparimcni of Transportation 

1200 New Jersey Ave., S.E. 

Washington,DC. 20590 

RE: Federal Aviation Administration V. City of Bridgepon. Connecticut 

Docket No. CP09NE0001 

,j.>'n'i. ''|i'- n*^ 

Dear Judge Benkin: 

Enclosed, please find a copy of ihc Complainani's First Set of InteiTogatories and 

Request for Production in the above-captioned Civil Penally Action, whicii were served 

on the City of Bridgeport on February 12, 2010. 

Sincerely, 

HN R. DONNELLY 

Senior Attorney 

cc: Richard Kascak, Jr., Esquire 

Hearing Docket 
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UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

J. RANDOLPH BABBIT, Administrator, 

Federal Aviation Administration, 

Complainant, 

V. 

CITY OF BRIDGEPORT, CONNECTICUT, 

Respondent. 

Docket No. CP09NE0001 

Administrative Law Judge 

Isaac D. Benkin 

Date: February 12,2010 

COMPLAINANT'S FIRST SET OF INTERROGATORIES 

AND REOUEST FOR PRODUCTION OF DOCUMENTS 

Pursuant to 14 C.F.R. Pait 13.220 of the Rules of Practice for FAA Civil Penalty Actions, the 

Complainant requests that the Respondent, within 15 days of service, answer the following 

inteiTOgatories and produce copies of the requested documents. 

INTERROGATORJES AND REQUESTS FOR PRODUCTION 

(1) Identify each person an.swering or assisting in the preparation of answers to these 

inteiTOgatories. 

(2) Identify each person Respondent intends to call as a witness concerning the complaint in this 

matter. 
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(3) Provide a .summary of the facts and opinions to which each intended witness is 

expected to testify. 

(4) Provide copies of all statements made by each of Respondent's intended 

witnesses relative to the allegations at issue in this proceeding. 

(5) Provide copies of all documents, pl:iotographs or other evidence which Responcfeui 

intend.") to introduce at hearing. 

(6) Please provide a brief summary of all proposed affirmative defenses and the faci^ia! and 

legal basis for each. 
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(7) Identify each expert Respondent intends to call as a witness to this proceeding. 

(8) For each expert Respondent intend.^ to call at the hearing, provide a cuniculum vitae or 

other document reflecting the expert's professional qualifications, 

(9) Please specify the evidentiary and factual basis for Respondent'.s full or pariial denial to 

the following paragraphs in the Administrator's Complaint: 

a) Paragraph 5. 

b) Paragraph 6. 

c) Paragraph 7. 

d) Paragraph 8. 

c) Paragraph 10. 

f) Paragraph 11. 

g) Paragraph 13. 

h) Paragraph 16. 

i) Paragraph 18, 

j) Paragraph 20, 

k) Paragraph 22. 
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I) Paragraph 23. 

m) Paragraph 24. 

n) Paragraph 25. 

o) Paragraph 26. 

p) Paragraph 27. 

q) Paragraph 28. 

(10^ Please provide a detailed summary of and copies of all peninent documents regarding 

Respondent's "ability to pay" a civil penalty if imposed. 

(11) Please provide written documentation of any air carrier service that has operated from 

Sikorsky Memorial Airport (BDR), Stratford, Connecticut from 1991 to present. Please 

include dates said air carrier service began and ended, and fully describe the name and 

type of air carrier service, total number of passengers enplaned, etc. 

(12) Please state exactly why the City of Bridgepon needs a Pan 139 Airpon 

Operating Certificate. 

(13) Please provide any written evidence Respondent has that air carrier service will begin at 

BDR in the next five years. 
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(14) Please identify any and all coiTecdve actions Respondent took to address the Part 

139 discrepancies identified by the FAA's airport certification and safety 

inspection of BDR conducted on March 29 and 30, 2007, and state the date those 

con-ections were made. 

Respectftilly Submitted. 

R, DONNELLY, Senior Att^ 

F^<leral Aviation Administration 

)fficc of Regional Counsel 

12 New England Executive Park 

Burlington, MA 01803-5299 

Tel: 781-238-7045 

Fax:781-238-7055 

Email: .lohn.l)onneHv(aitaa.ttov 

February 12,2010 
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CERTIFICATE OF SERVICE 

I hereby certify that today, February 12, 2010,1 have sent via Federal Express and 

Facsimile an original of the Complainant's First Set of InteiTOgatories and Request for 

Production of Documents in the matter of FAA v. City of Bridgeport. Connecticut, FAA Docket 

No. CP09NE0001 addressed to the following: 

The Honorable Isaac D. Benkin 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Ave., S.E. 

Washington, D.C. 20590 

Fax: (202) 366-7536 

Mr. Richard G. Kascak, Jr. 

Associate City Attorney 

Office of the City Attorney 

999 Broad Stieet, 2"'^ Floor 

Bridgeport, Connecticut 06604-4328 

Fax: (203) 576-8252 \ 

I also certify that today, Febi\iary 12, 2010,1 have .sent via Certified Mail-Return Receipt 

Requested and U.S. First Class Mail, a copy of said document addressed to the following: [ 

Hearing Docket Cleric AGC-430 [ 

Federal Aviation Administration 1 

Wilbur Wright Building-Suite 2W1000 | 

800 Independence Avenue, SW j 

Washington, DC 20591 i 

C-f-tO(' K 

DONNA SORENSEN Dated: February 12, 2010 

Program Analyst