OG/22/2010 15:07 FAX 2024935142 FAA •> QM S gjOOI/OOS 

•'^SEi]/f 

Scon-R. MORRIS 

FAA OFFlCn OF RlXWONAL COUNSEL 

1601 I.rNDAvE., SW 

RENTON, WASHnslGTON 9S057 

TlvlJiPnONE: 425.227.1417 

FACSIMIU': 425.227.1007 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

"r^i 

In the Matter ol": 

Sky West Airlines, Inc. 

FAA DOCKRT CPI0NM0002 

FAA Case No. 2009NM060048 

DMS No. FAA-2010-0312 

Judge Goodwin 

COMPLAINANT'S INITIAL DISCOVERY REQUEST 

To: Respondent 

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

please respond to the following Interrogatories, Requests for Production of Documents, and 

Request for Admissions, separately and fully under oath by June 27, 2010. 

rhc.<;e discovery requests are intended to discover information and/or documents not only 

within your personal knowledge or obtainable by you, but also infonnation 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 arc continuing in nature and any infomiation which may be 

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

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 arc any additions, deletions or changes 

in the answers or iniomiation provided at any lime prior lo hearing the Respondent is specifically 

requested lo so immediately inform the agency attorney. If such information is not furnished, the 

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

requested and not furnished. 

The agency attorney further requests tiiat the Respondent produce tJie documents idcntilied 

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

570, 1601 Lind Avenue, SW, Rcnton, Washington 98057, by July 7, 2010. 

PRIVILEGE 

If, in responding lo, or failing to respond to these inlerrogatorie.s, requests for admission and 

requests for production you invoke or rely upon any privilege of any kind, stale specifically the 

nature of the privilege; tlie basis upon which you invoke, rely upon or claim it, including any 
OG/22/2010 15:07 FAX 2024935142 FAA DMS 002/006 

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foX?an^Lommr.^i'''''"v\'" ^ i^f ^ "[' documents or other information, including contacts and communications which you believe to be embraced by the privilege invoked 

DATHD this 7th/day of June 2010. 

FAA Attomey 

Complainant's Initiiil l^i-sLOvciy Requesi 

SkyWcsl Airline.s • C;i> l()NM()002 

I'aj;.* 2 of 6 

Sl.XVIT R. MOKKI.s, FA A A'ITORNC Y 

ILL: 425.227.1417, I-AX: '125.227.1007 
06/22/2010 15:07 FAX 2024935142 FAA + DMS 12003/006 

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INTERROGArORJES AND RFQUESTS FOR PRODUCTION 

Intcirogatorv No. 1: Identity by name, address and telephone number all persons whom vou know 

to have personal knowledge of the matters alleged in the Complaint. 

interrogatory No, 2: Identify by title, date, author, present cu.'Jtodian, and content, all documents 

mcliiding correspondence, obtained by you or in your possession, relating lo the assertions in the 

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

this matter. ^ 

R.EQUEST FOR PRODUCTION NOM: Provide a copy of all documents referred to in your 

answer to the preceding interrogatory. 

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

to have testily as a factual or expert witness in your defense at the hearing in these matter, cmd for 

factual 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 witness 

or witnesses. 

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

answer to the preceding interrogatory. 

Integogatory No^5: With respect to each expert witness identified in response lo Inten-ogatory No 

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

background, training and experience. 

IntcnrogatorY No. 6: With respect to each expert you expect to call as a witness, state the subject 

matter on which the expen is expected to testify, and .state tiie substance of the facts and opinions to 

which tlic expert is expected to testily, and a summary of the grounds for each .such opinion. 

Inierronatorv No. 7: State by name, address, telephone number, dale of conversation, and substance 

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

matters alleged in the complaint. 

Interrogatory No. 8: Describe with specificity all of the facts which you anticipate presenting in the 

course ot the hearing ui this matter pertaining to the avoidance or mitigation of the sanction 5;o>jghi 

by the FAA in this case. 

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

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

sanction sought by the FAA in this case. 

RRpUHST FOR PRODUCTION NO. 3: Provide a copy of all Exhibits that yc^u will present 

during the hearing in this matter. 

Interrogatory No. 10: Describe with specificity what facts or evidence SkyWcst relies upon in 

support of any affirmative defenses raised in its Answer to ihe Amended Cornplaini. 

Complainant's Initial Discovery Request 

SkyWcst AirliiiM • CP10NM0002 

Page 3 of 6 

'svxvrj R, MORRIS. FAA A moRNKY 

•[•EL; 425,227.1417; FAX: 42.5.227.1007 
06/22/2010 15:07 FAX 2024935142 FAA + DMS 21004/006 

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REOUHSr FOR PRODUCTION NO, 4: Provide a copy of all documents that support your 

response to interrogatory 10. 

Tnterrogatoi^ No. 11: In its answer to Complaint, section II, paragraph 17, SkyWest "avers that in 

lieu of the hydraulic hand pump, SkyWest availed itself of other procedures, including its Standard 

Practices and GMM consistent with the EMB-120 Maintenance Manual and Sky West's G^4M." 

State with specificity what "other procedures", Standard Practices, or other GMM references it is 

referring to. 

RROUEST FOR PRODUCTION NO. 5: 

response to interrogatory 11. 

Provide a copy of all documents that support your 

REQUEST FOR PRODUCTION NO. 6: Provide a copy of any SkyWest approved or accepted 

document that allows it to pcrfonn tlie maintenance described in Paragraph 17 of the Complaint 

wi thout the use of a hydraulic hand pump. 

Interrogatory No. 12: Describe with specificity all facts you intend to assert and who are you 

offering as witnesses in support of the first affirmative defense raised in its answer? Provide the 

name, address, and telephone number of said witnesses. 

E£_QUEST FOR PRODUCTION NO. 7: Provide a copy of all dociunents that support your 

response to interrogatory 12. 

iBteripgatoi^ No. 13-. Describe with specificity all facts you intend to assert and who are you 

offering as witnesses in support o/the third affirmative defense raised in its answer? Provide the 

name, address, and telephone number of said witnesses. 

REQUEST FOR PRODUCTION NO. 7: Provide a copy of all documents that support your 

response to interrogator)' 13. 

Interrogatory No. 14: Describe with specificity ail facts vou intend to assert and who are you 

offering as witnesses in support of the fiAh affirmative detbnse raised in its answer? Provide the 

name, address, and telephone number of said witnesses. 

Interrogatory No. 15: Describe with specificity all facts that that SkyWest believes .support its 

assertion that the Agency use any ASAP report to "initiate and prosecufion" the enforcement action 

that is the basis of the Complain in this case. 

REQUEST FOR PRODUCTION NO. 8: Provide a copy of all documents thai suppo:l vour 

re.sponse to interrogaiories 14 and 15. 

Complainant's Initial Discovciy Request 

Sky West Airlines - CPIONM0002 

l'a|i!e4of6 

SCOTT R. M<5Rni.v, 1'AA A TTORNICY 

ILL: 425.227,1417; TAX:/125.227.1007 
06/22/2010 15:07 FAX 2024935142 FAA + OMS 0005/006 

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REQUEST FOR ADMISSIONS 

Under 14 C.F.R. 13.220(b) and Rule 36 ofihe Federal Rules of Civil Procedure, you are requested 

to admit the truth of the following matters. A matter is admitted unless responded to in a 

reasonable time. 'I"he Rules of Practice in F/VA Civil Penalty Actions, 14 C.F.R. 13.220(d), defines 

a reasonable time to be 30 days. The agency requests that an answer is served upon the agency 

attomey either admitting the matter, .specifically denying the matter, stating why the matter cannot 

be admitted or denied, or objecting to the raiuest, with reasons for the objection stated within 30 

days of the date of service upon you, to wii: July 7, 2010. 

REQUEST FOR ADMISSION NO 1: Admit that in Fiscal Year 2009 SkyWest Airiines had 

operating revenues in excess of $100,000,000. 

REOUFSI FOR ADMISSION NO 2: Admit that in Fiscal Year 2008 SkyWest Airlines had 

operating revenues in excess of $100,000,000. 

REQUEST FOR ADMISSION NO. 3: Admit that SkyWest Airlines employs more than 1500 

employees. 

REQUEST FOR ADMISSION NO. 4: Admit that SkyWest Airlines has the financial ability to pay 

the $ 182,500 requested civil penalty. 

CoiTipl<iinnni':; Initial Discovery Request 

SkyWcKf Airline.'; - CPIONMOOO? 

Puy:c 5 of 6 

.Sc.-OTT R, M0RR1.<;. FA A A1T0RNJ-y 

ILL: 425.227.1417; FAX ; 425.227.1007 
06/22/2010 15:08 FAX 2024935142 FAA DMS 0006/006 

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CERTIFICATE OF SERVICE 

I hereby certify that the foregoing Complainant's Initial Discovery Request has been served 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, Rm El 2-320 

Washington, D.C. 20590 

TEL: 202.366.2139 

FAX: 202.366.7536 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, D.C. 20591 

Atm: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2W1000 

FAX: 202.493.5020 

Michael L. Dworkin 

465 California Street, Suite 210 

San Francisco, CA 94104-1808 

TEL: 405.421.2500 

FAX: 405.954.4676 

Dated this 7th day of .lune, 2010. 

_>_ M01F7\IR CHIN 

Office of Regional Counsel (ANM-7 ) 

Federal Aviation Administration 

1601 Lind Ave. SW 

Renton, WA 98057 

425.227.2160 

Complainant'.'! Initial DLiicovery Reque,<;t 

SkyWest Airlines - CPIOMM0002 

l^agc 6 of 6 

SCOTT K. MORRIS, FAA AT rORNnV 

ILL: 425.227.1417; FAX: 425.227.1007 

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