SERVED JUNE 26,2013 

u.s. DEPARTMENT oF TRANSPORTATioR E C E I VE 0 

OFFICE OF HEARINGS JUN 2 ? 2013 WASHINGTON, D.C. 

IN THE MATTER OF 

TRANS NORTH AVIATION, LTD 

FAA DOCKET NO. (2012-GL-03-0012) 

(Civil Penalty Action) 

FDMS No. FAA-2013-0046 

APPLICATION FOR SUBPOENA 

HEARING DOCKET 

Trans North Aviation, LTD, Respondent, by its undersigned counsel, requests the 

issuance of a subpoena duces tecum to American Medical Response Ambulance for the 

information as set forth below and in support ofthis application states as follows: 

1. On the date of the flight which is the focus of this appeal, the Respondent was to 

pick up a patient at a Florida airport. 

2. There was a delay resulting in the patient arriving at the aircraft later than 

planned. 

3. The resultant delay caused or contributed to the extension of the planned crew 

duty day. 

4. The Patient Care Report in the custody of American Medical Response 

Ambulance may contain information as to reason for and the length of the delay. 

5. The documents sought by Trans North Aviation are not only specifically relevant 
to the matters before this Court, but the documents sought are reasonable in their 

scope. 

6. The specific entity that Trans North Aviation, LTD requests subpoena duces 

tecum issue to is: 

American Medical Response Ambulance 

530 S. Main Street, Suite I 041 

Akron, OH 44311 

7. The specific documents Trans North Aviation, LTD requests are contained in the 

attached rider. 

8. All documents produced in compliance with the requested subpoena will be 

produced to counsel for the Administrator. 

WHEREFORE, the Respondent, Trans North Aviation, LTD prays for an order 

from this Court granting this Application for the Issuance of Subpoena Duces Tecum to 

the entity referenced above, for the materials as referenced above, together with such 

other relief as this court deems just and appropriate. 

Dated: June 26,2013 

Respectfully submitted, 

BARNETT & BORTH, LLC 
~ Counsel for Respondent 

Barnett & Borth, LLC 

800Waukegan Road 

Suite 200 

Glenview, IL 60025 

Tel. (847) 724-5520 

Fax (815) 356-7042 
RIDER TO SUBPOENA DUCES TECUM 

TRANS NORTH AVIATION, LTD. 

FAA DOCKET NO. (2012-GL-03-0012) 

FDMS No. FAA-2013-0046 

A. Any and all handwritten or typed or printed documents of any type, including, 

but not linrited to: notes of telephone conversations, telephone logs, file notes, 

work papers, business records, calendars, charts, computer printouts, 

computer tapes, correspondence, diary entries or notations, displays, drafts, 

exhibits, files, fihns, summaries of investigations, invoices, journals, 

laboratory reports, letters, memos, notes, preliminary notes, packaging 

materials, photographic slides, photographs, proof of mailing, receipts, 

recordings, records, shipping documents, statements, study notes, summaries, 

work papers, records, documents, notations, attachments, exhibits, test results, 

contracts and written agreements pertaining to, relating to, or involved with, 

either directly or indirectly, American Medical Response Ambulance Patient 

Care Report 9011438220000 concerning patient JOHN BIALEK with a 

November 28, 2011 date of call. 

B. Any and all documents in your possession identifying the names and 

addresses and employer of individuals involved American Medical Response 

Ambulance Patient Care Report 9011438220000 concerning patient JOHN 

BIALEK with a November 28, 2011 date of call. 
CERTIFICATE OF SERVICE 

The undersigned certifies that the foregoing Application for Subpoena was served 

via facsimile and FedEx overnight deliver as follows: 

ORIGINAL AND ONE COPY 

Federal Aviation Administration 

600 Independence Avenue, S.W. 

Wilbur Wright Building-Suite 2Wl000 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

FAX: 202-493-5142 

ONE COPY 

Jeanette Daubaras, Complainant's Counsel 

Great Lakes Region, AGL-7M 

Federal Aviation Administration 

2300 East Devon Avenue 

Des Plaines, IL 60018-4696 

TEL: 847-294-7713 

FAX: 847-294-7498 

The Honorable Richard C. Goodwin, Administrative Law Judge 

Office of Hearings, M-20 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor 

Room E12-320 

Washington, DC 20590 

TEL: 202-366-2139 Attorney-Advisor 

202-366-5121 Legal Assistant 

FAX: 202-366-7536 

Dated this 26'h day of June, 2013. 

Attorney 

~/ for Respondent