^ DMS 21002/005 

07/30/2010 n:1 0 FAX 2024935U2 FAft 12,002/005 

07/28/2010 14:14 FAX 425 227 1007 ANM-7 

..,'1 I..." ' " r";/Mi;\liOi" l 

SCOTT R. MORRIS 

FAA Of KICP. OF RflGIONAL COUNSEL 

1601 LINDAVE. , SW 

RfiNTON, WASHINOTOM 98057 

TRLEPHONK: 425.227.1417 

FACSIMri.F.: ^25.227.1007 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In ihe Matter of: 

Synagro West, Inc. 

FAA DOCKET CPIONMOOOS 

FAA Case No. 2009NM7002C)3" 

DMS No. FAA-2010-0622 

Judge Goodwin 

COMPLA^NA^fT'S INI riAL DISCOVERY RKQUEST 

To: Respondent 

In accordance with 14 CFR Sections 13.220 and the Federal Rules of Civil Procedure, 

please respond to the following rnterrogatories. Requests for Production of Documents, tind 

Request for Admissions, separately and fully under oath by August 28, 2010. 

These discovery rixjuests arc intended lo discover information and/or documents not only 

within your personal knowledge or obtainahle by you, but also inibrmation in the possession of or 

obtainable by your attorneys, investigators, representatives, employees, agents, or anyone acting on 

your behalf or on their behalf. 

These discovery requests are continuing in nature and any information vvhich may be 

discovered by you subsequent to the service and filing of your answers must be brought to tlie 

attention of the agency attorney through supplemental answers when it becomes available to you, at 

a reasonable time prior to the hearing in this matter. If there are any additions, deletions or changes 

in the answers or information provided at any time prior to hearing the Respondent is specifically 

requested to so iirunediatcly inform the agei\cy attorney. If such information is not fiamishcd, the 

agency attorney at the time of the hearing will move to exclude from evidence such information 

requested and not tumished. 

The agency attorney further requests that the Respondent produce the documents identified 

and designated herein for inspection and copying at the FAA Office of Regional Counsel, Suite 

570.1601 l.ind Avenue, SW, Rcnton, Washington 98057, by Augu^st 28, 2010. 

PRIVILEGE 

If, in responding to, or failing to respond to these inlerrogaiorics, requests for admission and 

requests for production you invoke or rely upon any privilege of any kind, state .•specifically the 

nature oi' (he privilege; the basis upon which you invoke, rely upon or claim it, including any 
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staiulory or decisional reference; and identic: all documents or other infomiation, including 

comacis and communications which you believe to be embraced by the privilege invoked. 

DATED this 27th day of July 2010. 

R. Ml 

^AA Attorney 

Coiriplalnant's Illlxial Discovery Requesi 

iSynagro West. Inc. -CT']0WMOOO5 

Page 2 of 4 

icOTT K. MORRIS, FAA ATTORNEV 

TEL-. 425,227 1417; FAX: i:>5,227.l0O7 
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INl-ERROGATORIES AND REQUESTS FOR PRODUCTION 

Inlerrogatorv No, 1: Identify by name, address and telephone number all persons whoni you know 

u> have personal knowledge of the matters alleged in the Complaint. 

Interrogatory No. 2: Identify by title, date, author, present custodian, and content, all documents, 

including correspondence, obtained by you or in your possession, relating to the assertions in the 

Complaint, your appeal, your answer, and any affinnativc defenses which you anticipate raising in 

this mattei-. 

REQUEST FOR PRODUCTION NO. 1: 

answer to the preceding interrogatory. 

Provide a copy of all documents referred lo in your 

Interrogatory No. 3: Idendfy by name, address and telephone number, all persons whom you intend 

to have testify as a factual or expert witness in your defense at the hearing in ihcsc matter, and for 

facmal witnesses, provide a detailed summary of each persons anticipated testimony. 

Interrogatory No. 4: Identify by title, date, author, present custodian, and content, all documents 

which you anticipate offering into evidence at the hearing in this matter, and through which wimess 

or witnesses. 

REQUEST FOR PRODUCTION NO. 2: Provide a copy of all documents referred to in your 

answei- to the preceding interrogatory. 

InterroKatorv No. 5: With respect to each expert vvitness identified in response to Interrogatory No. 

3, above, specify their specific area of expertise, and provide a synopsis of their credentials, 

background, training and experience. 

Interro^atorv No. 6: With respect to each expert you expect to call as a witness, state thie subject 

matter on which the expert is expected to testify, and state the substance of the facts and opinions to 

which the expert is expected to testify, and a summaiy of the grounds for each such opinion. 

Interrogatory No. 7: State by name, address, telephone number, date of conversation, and substance 

of conversation, all persons [other than legal counsel or spouse] with whom you have discussed the 

mailers alleged in the complaint. 

Inten'ogatorv No. .8; Describe with specificity all of the fiicts which you anticipate presenting in the 

course of the hearing in this matter pertaining to iho avoidance or mitigation of the sanction soughl 

by the FAA in this case. 

Intcrrogatoiv No. 9: Describe with specificity all of the documents you anticipate presenting in the 

course of the hearing in this matter to substantiate any financial inability to pay the proposed 

sanction sought by the FAA in this case. 

REQUEST FOR PRODUCTION NO. 3: Provide a copy of all Exhibits that you will present 

during the hearing in this matter. 

Interrogatory No. 10: Describe with specificity what facts or evidence you rely upon in support of 

any affirmative defenses raised in any Answer to the Complainl. 

Complainant's Initial Discovery Request 

Synagro West, Inc. -CP10NMC005 

Paijjc 3 o f d 

SCOTT R. MORRIS, FA A ATTORNEY 

TEL: 425.227.1417; FAX : 42:5.227.1007 
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CERTIFICATE OF SERVICE 

I hereby certify that the foregoing Complainant's Initial Discovery Request has been sep'cd via 

facsimile and certified mail - Return Receipt Requested this date, to the following; 

The Honorable Richard C- Goodwin 

Office of hearings, M-20 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor, Rin E12-320 

Washington, DC. 20590 

TEL: 202.366.2139 

FAX; 202.366.7536 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, D.C. 20591 

Arm: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building - Suite 2WI00O 

FAX: 202.493.5020 

Kenneth A. Scott 

Blair Hilty, Attorneys at Law 

14711 Pebble Bend Drive 

Houston, TX 77068-2923 

TEL: 713.862.5599 

FAX: 713.868.9444 

Dated this 28th day of July. 2010. 

MOIFAIR CHIN 

Office of Regional Counsel (ANM-7) 

Federal Aviation Administration 

1601 LindAve. SW 

Renton, WA 98057 

425.227.2160 

Coiiijjl.'jinant's Initiul t>iscovcry Request 

Synagro West. Inc. ~ CPIONMOOOS 

Page 4 of 4 

SCOTT R, MOIVRIS, FAA AITOHNEV 

TEL: 425.227,1417; FAX: 425.:227.I007