01/15/2013 14:02 8472947498 FAA GLRC 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

IN THE MATTER OF 

FAA v. Vincent R. Brown 

FAA DOCKET NO. (not assigned) 

FDMS NO: FAA-2012~0906 

FAA CASE NO. 2008-GL-13-0048 

COMPLAINANT'S REQUEST FOR DISCOVERY 

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COMES NOW the Administrator, acting by and through hi.s counsel, and submits the following 

Request for Discovery. The Administrator further requests that Respondent provide the 

following information in response to this request for. discovery by or before Friday, January 31, 

2013. INTERROGATORIES 

1. Provide the name, occupation, and business address for any and all persons that have 

knowledge of what occurred on May 10, 2008, on Frontier Flight #371, enroute from 

Milwaukee, Wisconsin (MKE) to Denver, CO. 

2. Provide the substance and basis of the testimony to be offered by each of witnesses 

identified in response to Interrogatory 1 above. 

3. State the name, occupation, business address and. telephone number for each expert 

witness Respondent intends to call as a witness in this proceeding. 

4. State the qualifications, experience, and training of each person identified .in response to 

Interrogatory 3 above. 

5. Provide the substance and basis of the testimony to be offered by each of the witnesses 

identified in response to Interrogatory 3 above. 
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PAGE 05/07 

IN THE MATTER OF: Vincent R --FAA FDMS NO: FAA-2012-.0906 

CERTIFICATE OF SERVICE 

I hereby certify that I have this date sent the Complainant's Request for Discovery, via the 

methods listed. below, to: 

Vincent R. Brown 

5637 Glen Oaks Drive 

Rocklin, CA 957765 

Dated this 15th. day of January 2013. 

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6. State the name, occupation, business address and telephone number of any other person 

or persons known by the Respondent to have relevant knowledge of and/or infom1.ation 

about the matter in this pr~ceeding. 

7. Provide a summary of the substance and basjs of the knowledge of each person identified 

in response to Interrogatory 3 above. 

8. Describe each exhibit, other than a document, Respondent intends to introduce into 

evidence in this proceeding. 

9. Provide any and aU case law or statuto:ry law that Respondent intends to introduce at trial. 

REQUEST TO PRODUCE DOCUMENTS 

1. Produce copies of all documents Respondent intends to introduce into evidence in this 

proceeding, to include, but not limited to reports, letters, memoranda, writings, 

photographs, drawings~ sketches, computer data, audio recordings and transcripts, and 

video recordings. 

2. Produ.ce a copy of all prior written statements made by any person identified in 

lnterrogatories 1, 3 and 6 above which relates in any manner or .has any bearing on the 

incident at issue in this proceeding. 

3. Provide a description of any non-document exhibit, not otherwise capable of being copied 

or reproduced, Respondent intends to introduce into evidence in this proceeding. 

Dated this 15th day of January 2013. 

By; 

Respectfully Submitted, 

Jeffrey A. Klang 

Kate 

l~V Barber 

Attorney 

Federal Aviation Administration 

2300 East Devon 

Des Plaines, IL 60018 

(847) 294-7862; Fax (847) 294-7498 

ATTORNEY FOR COMPLAINANT 

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.... 

01/15/2013 14:02 8472947498 FAA GLRC 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

OFFICE OF HEARINGS 

WASHINGTON, DC 

1N THE MATTER OF: 

erved: January 15, 2013 

VINCENT R. BROWN, 

DMS NO; FAA-2012-0906 

Respondent. udge: Richard C. Goodwin 

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1\ c. ") 3 J-\· ~ .. ..J 

COMPLAINANT'S MOTION TO DEEM ALLEGATIONS ADMITTED AND FOR 

JUDGMENT ON THE PLEADINGS OR FOR HEARING ON SANCTION ONLY 

NOW COMES the Complainant. by counsel, and pursuant to the Rules of Practice set 

forth in 14 C.P.R. Part 13. Subpart G, of the Federal Aviation Regulatlons, and for the reasons 

set forth below, moves the Judge for an order deeming the allegations set forth iti the Complaint 

admitted thereby limiting the hearing in this matter to sanction alone. 

1, On July 12~ 2012. the Agency. through counsel, issued a Final Notice of Proposed Civil 

Penal.ty to the Respondent proposing to assess a Civil Penalty in the instant case. 

2. On July 22, 2012, the Respondent requested a formal hearing in accordance with 14 C.F. 

R. §13.16 of the Federal Aviation Regulations. 

3. On June 24, 2011, the Complainant filed the Federal Aviaiton Administration's 

Complaint. 

4. Pursuant to 14 C.F.R 13.209(a), the Respondent is required to file a written answer, not 

later. than 30 days after service of the complaint. 

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S. To date~ the Respondent has failed to file an answer to the Agency's Complaint. 

6. Pursuant to 14 C.F.R 13.209(£), the failure to file an. answer without good cause shall be 

deemed an. admission of the truth of each allegation contained in the complaint. 

WHEREFORE, the Complainant hereby respectfully requests 

(a) the issuance of an Order granting the Complainants's motion deeming the admission 

by the Respondent of the truth of the allegations contained in the complaint; 

(b) judgment on the pleadings be entered or, in the alternative, the Complainant requests 

that any hearing in this matter be limited to the issue of sanction only. 

Attorney 

Federal Aviation Administration 

Great Lakes Region, Office ofRegional Counsel 

2300 E. Devon. 

Des Plaines, IL 60018 

Phone:847-294-7862 

Fax: 847-294-7498 

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01/15/2013 14:02 8472947498 FAA GLRC 

CERTIFICATE OF SERVICE 

I hereby certify that I have, this date, served the foregoing Motion to the folloWing 

addresses: 

One Copy (via regular mail and facsimile): 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, D.C. 20591 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2Wl000 

One Copy (via .-egular mail and facsimile): 

The Honorable Richard C. Goodwin, Administrative Law Judge· 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

W ashin.gton, DC 20590 

Fax: 202-366-7536 

One Copy (via Certified & Regular Mail): 

Mr. Vincent R. Brown 

5637 Glen Oaks Dr. 

Rocklin, CA 95765 

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