Oct.ll.2015 11:06 PM Conlin, Maloney & Miller 509 624 3020 

UNITED STATES OF AMERICA 

NATIONAL TRANSPORTATION SAFETY BOARD 

WASHINGTON, D.C. 

In the Matter of: 

Felts Field Aviation, 

Respondent 

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) ________________________) 

FAA Case # 20 15WP91 0090 

Judge Not Assigned 

COMBINED RESPONDENT'S FIRST SET OF INTERROGATORIES 

AND REQUEST FOR PRODUCTION OF DOCUMENTS 

TO: Complainant, through its attorney, Robert Spitzer. 

PAGE. 1/ 6 

The Respondent, by and through his Attorney requests that Complainant, 

within thirty (30) days after service, answer the following interrogatories under 

oath, produce the requested documents for inspection and copying to Mark J, 

Conlin's Office, 421 W. Riverside Avenue, Suite 911, Spokane, Washington, 

99201. 

These requests are deemed continuing, and any information secured after 

answering and/or supplying the requested answers or documents/items is to be 

supplied by supplemental production pursuant to Rule 26 (e) of the Federal 

Rules of Civil Procedures. 

COMBINED RESPONDENT'S FIRST SET OF 

INTERROGATORIES AND ReQUEST FO~ PRODUCTION OF DOCUMENTS Pogo ·1 
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DEFINITIONS 

1. "Documents", shall mean, regardless of origin or location, any 

handwriting, note, letter, manual, memorandum, record, report, statement, study, 

drawing, sketch, photograph, telegram, telex, or message, whether reported, 

transcribed, punched, taped, filmed or graphically represented in any manner or 

material of any kind in the possession of subject to the control of, or within the 

knowledge of, the Complainant's and/or his employees, agents, consultants or 

experts. 

2. "Identify" and/or "state the identity of" with reference to individuals' 

means state the name, current or last known address, employer and job 

description or title, and telephone number. 

3. "Identify" with reference to documents means state the date, the author 

unless apparent from the document. 

4. As listed herein, singular pronouns also include the plural. 

INTERROGATORIES 

INTERROGATORY NO. 1: Identify each person whom Complainant expects as 

witnesses at the hearing of this matter. 

ANSWER: 

COMBINED RESPONDENT'S FIRST SET OF 

INToRROGA'fORIES AND Ri;QUEST 

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INTERROGATORIES NO. 2: State the subject matter on which Complainant 

expects each person to testify, the substance of the facts and opinions, if any, 

and a summary of the grounds for each opinion. 

ANSWER: 

INTERROGARQRY NO. 3: For each expert Complainant 'Intends to call at the 

hearing, provide a curriculum vitae or other documents reflecting the expert's 

professional qualifications. 

ANSWER: 

INTERROGATORY NO.4: Identify and produce all documents in Complainant's 

possession, custody or control relating to all maintenance and inspections 

described in your Complaint. 

ANSWER: 

INTERROGATORY NO. 5: Identify and produce all correspondence between 

Complainant and each person Complainant intends to call as a witness in this 

matter, 

ANSWER: 

COM81N~D REi$PONDEiNT'S FIRS't SEiT OF 

INTERROGATORIES AND REQUEST 

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INTERROGATORY NO. 6: To the extent not encompassed in your response to 

any of the foregoing items, identify and produce all documents upon which you 

expect to rely at the hearing or introduce as evidence in support of Complainant's 

position at the hearing in this matter. 

ANSWER: 

REQUEST FOR PRODUCTION OF DOCUMENTS 

REQUEST FOR PRODUCTION NO. 1: Produce all photographs taken by the 

Federal Aviation Administration or in the possession of the Federal Aviation 

Administration of the subject Cessna 210 aircraft. 

ANSWER: 

· REQues·r FOR PRODUCTION NO. 2: Provide names, addresses and phone 

number of all those who have performed maintenance or conducted inspections 

or participated in any type of work on the Cessna 210 since the subject 

Inspection performed by the Respondent. 

ANSWER: 

COMBINED RESPONDENT'S FIRST SET OF 

INTeRROGATORIES AND REQUEST 

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DATED this ;.r~ day of October, 2015. 

I 

COMBINED RESPONDENT'S FIRST SET OF 

INTERROGATORIES AND REQUEST 

FOR PRODUCTION OF DOCUMENTS P•g•. 6 

Respectfully submitted, 

CONLIN, MALONEY & MILLER 

Counsel for Respondent 

421 W. Riverside Ave, Suite 911 

Spokane, WA 99201 

(509) 624-3020 
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CERTIFICATE OF SERVICE 

I hereby certify that the foregoing original of the Combined Respondent's 

First Set of Interrogatories and Request for Production of Documents was mailed 

and a copy faxed, postage prepaid, to: 

Federal Aviation Administration 

800 Independence Avenue SW 

ATTN: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building - Suite 2W1 000 

Washington DC 20591 

(202) 267-1293 

A copy of foregoing Combined Respondent's First Set of Interrogatories. 

and Request for Production of Documents was mailed and faxed to: 

Mr. Robert Spitzer, FAA Attorney 

Federal Aviation Administration 

Office of Regional Counsel- ANM-7 

Nortwest Mountain Region 

1601 Lind Avenue SW 

Renton, WA 98057 

Fax: (425) 227-1007 

Dated this 13th day of October, 2015 

COMBINED RESPONDENT'S FIRST SET OF 

INTERROGATORIES AND RSQUEST 

Cindy rt 

Assistant to Mark J. Conlin 

FOR PRODUCTION OF DOCUMENTS Poge • e