U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

OFFICE OF HEARINGS 

WASHINGTON, DC 

R'E,CE,VED 

MAY t ~ 2013 

HEARING DOCKET 

In the Matter of: FAA DOCKET No. FAA-2013-0040 

Martinaire Aviation LLC 

Respondent 

JUDGE GOODWIN 

FAA Case No.2011SW700189 

(Civil Penalty Action) 

FDMS No. FAA-2013-0040 

COMPLAINANT'S FIRST SET OF INTERROGATORIES 

NOW COMES the Federal Aviation Administration (hereinafter 

"FAA") pursuant Rule 209 of the Rules of Practice in FAA Civil 

Penalty Actions, 14 C.F.R. § 13.209, and Complainant hereby 

requests Martinaire Aviation LLC, to answer the following 

interrogatories fully and separately in writing under oath 

within thirty days of service. 

DEFINITIONS 

1. ''You" and ''your" refer to Martinaire Aviation LLC, 

(hereinafter "Martinaire") and each of its affiliates, attorney, 

accountants, divisions, subdivisions, predecessors, directors, 

officers, employees, agents, representatives and all persons 

acting or purporting to act on its behalf. 

2. "Document" means any writing or recording as defined in Rule 

1001 of the Federal Rules of Evidence, including any drafts, 

revisions and computer-readable material. If a document has 

been prepared in several copies which are not identical, or if 

the original identical copies are no longer identical by reason 

of subsequent notation or other modification of any kind 

whatsoever, including, but not limited to, notations on the 

backs of pages thereto, each non-identical copy is a separate 

document. "Document" shall also include any data compilation 

from which information can be obtained or translated if 

necessary by you through detection devices into reasonably 

usable form. 
3. "Personff includes, without limitation, any natural person, 

proprietorship, corporation, partnership, trust, joint venture, 

association, organization, business entity or governmental 

agency. 

4. "Relating toff and "relates toff mean, without limitation, 

relating to, constituting, concerning mentioning, referring to, 

describing, summarizing, evidencing listing, relevant to, 

demonstrating, or tending to prove, disprove, or explain. 

5. "Andff and "orff shall be construed either disjunctively or 

conjunctively as necessary to bring within the scope of the 

discovery request all responses that might otherwise be 

construed to be outside its scope. 

6. The use of the singular includes the plural, and vice versa. 

7. The use of one gender includes all others, appropriate in 

the context. 

8. "Identifyff means and requires you to state: 

(a) With respect to a person, his or her name, address, 

telephone number, employer and job title. 

(b) With respect to a document, the name and address of its 

author or maker, the names and addresses of all persons who were 

addresses, the date on which it was created or made, the nature 

of the document and the substance of the information or 

communication set forth in the document. 

(c) With respect to a tangible or demonstrative thing, 

a sufficiently graphic description to distinguish it from other 

tangible or demonstrative things of the same class or type. 

(d) With respect to conversations and written or oral 

communications: 

(i) The date on which each conversation or communication 

occurred. 

(ii) The persons making such conversation or communication. 

(iii) The substance of the conversation or communication. 

(iv) The names and addresses of every person present when 

the conversation or communication occurred. 

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(v) The place where the conversation occurred. 

INSTRUCTIONS 

1. If you discover new information, you are obligated to 

supplement your responses to these interrogatories no later than 

thirty days after the discovery of the further information and 

in no event later than fifteen days before the first day of 

trial. 

2. If you object to furnishing any information requested by 

these interrogatories on the grounds of privilege, work product 

or otherwise, your response should state the existence of the 

information, document or communication, identify the specific 

grounds on which your objection is based, and identify the 

information objected to by furnishing its date, participants 

(e.g., names of speakers, authors, addressees) and a general 

description of the nature, rather that the substance, of the 

purportedly privileged information. If the information objected 

to contains relevant non-objectionable matter, you should 

disclose it. 

3. The relevant time period of these interrogatories is from 

January 1, 2009 to date and shall include all information, which 

relates or refers to this period unless another time or period 

is specifically referred to in an interrogatory. 

4. If you cannot furnish exact data, such as dates, periods or 

amounts, supply estimated data to the extent possible and 

indicate that the data is estimated. 

INTERROGATORIES 

Interrogatory # 1: Identify the name, address, telephone 

number, and position of each person answering or assisting in 

answering these interrogatories. 

Interrogatory# 2: Identify the name, address, and telephone 

number of each person, other than expert witnesses, that you 

will or may call as witnesses at trial and summarize the 

expected testimony. 

Interrogatory # 3: Identify by name, address and telephone 

number all persons who have personal knowledge of the 

Notification of pilot-in-command documents alleged in 

Complainant's Complaint. 

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Interrogatory # 4: Identify 

numbers all persons who have 

affirmative defenses alleged 

by name address and telephone 

personal knowledge of your 

in your Answer. 

Interrogatory # 5: Identify by title, date, author, present 

custodian and content all documents obtained by you or in your 

possession relating to the assertions in Martinaire's Answer, 

including affirmative defenses. 

Interrogatory # 6: Identify the name, address, telephone, 

number, and specialty of each person you expect to call as an 

expert witness at trial, and for each expert identified, state 

the subject matter of his or her testimony and the substance of 

the facts and opinions to which the expert is expected to 

testify. 

Interrogatory# 7: Identify the amount of net income Martinaire 

earned during 2010, 2011, 2012 and 2013. 

Interrogatory # 8: Explain the factual basis for each denial in 

Martinaire's Answer to Complainant's complaint. 

Interrogatory # 9: Identify the employees in the Martinaire, 

Texas who received the following training: 

(a) General awareness/familiarization training;, 

(b) Function-specific training; 

(c) Safety Training; 

(d) Security awareness training; 

(e) In-depth security training. 

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Respectfully submitted this 13ili day of May 2013. 

ERIC E. ANDERSON 

Regional Counsel 

Southwest Region 

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CERTIFICATE OF SERVICE 

Re: Martinaire Aviation, LLC, FAA Case No. 2011SW700189 

I hereby certify that on this date, I have sent via Federal 

Express and fax a true copy of the Complainant's First Set of 

Interrogatories and Request to Produce addressed as follows to: 

Mr. Michael L. Dworkin and Associates 

Law Offices 

465 California Street, Suite 210 

San Francisco, California 94104-1808 

(FAX and Federal Express) 

Federal Aviation Administration 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building~Suite 2W1000 

800 Independence Avenue SW 

Washington, DC 20591 

(Original plus one copy) 

(Federal Express) 

The Honorable Richard C. Goodwin 

Administrative Law Judge 

Office of Hearings, M-20 

Department of Transportation 

1200 New Jersey Avenue, S.W. 

Washington, DC 20590 

FAX: 1-202-366-7536 

(FAX and Federal Express) 

ERIC E. ANDERSON 

Regional Counsel 

Southwest Region 

Archier, Agency 

(817) 222-5074 

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Dated: May 13, 2013