In The Matter Of: 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, DC 

) 

FiECEIV 

MAY 1 8 2G'!1 

HEARING DC,_,i<c 

NORTHEASTERN AVIATION 

CORPORATION 

) DocketNo. FAA-2014-0812 

) 

) 

) Case No. 2011EA110028 

Respondent ) Assigned: Judge J.E. Sullivan 

RESPONDENT'S FIRST SET OF INTERROGATORIES AND FIRST 

REOUEST FOR PRODUCTION OF DOCUMENTS 

It is requested that the Complainant answer the following interrogatories and produce the 

documents hereinafter described within thirty (30) days. This request shall be deemed to be 

continuing as required by the Ru1es so as to require you to file supplemental responses. This 

request is intended to cover all documents in the Complainant's possession or subject to 

Complainant's custody and control and includes documents in the possession of each individual 

who acts as, or has acted at relevant times as, an employee, agent or representative of 

Complainant. 

DEFINITIONS 

A. When knowledge or information in possession of a party is requested, such 

request includes knowledge of the party's agents, representatives and, uu1ess privileged, the 

party's attorneys. 

B. The pronoun "you" and "yoms" refers to the party to whom these interrogatories 

are addressed. 

C. Unless otherwise indicated, these interrogatories refer to the time, place and 

circumstances of the occurrences mentioned or complained of in the pleadings. 
D. When used with respect to an individual, corporate, business or governmental 

entity, "identify" means state the name and present business or residence addresses of the 

individuals or entities and the employer, governmental or business affiliation and position of the 

individual. 

E. The terms "document' and "statement" mean without limitation, the following 

items, whether printed or recorded or reproduced by any other mechanical process or written or 

produced by hand: agreements, communications, correspondence, telegrams, memoranda, 

summaries or records of telephone conversations, summaries or records of personal 

conversations or interviews, diaries, reports, notebooks, note charts, plans, drawings, sketches, 

maps, summaries or reports of investigations, opinions or reports of consultants, photographs, 

motion picture films, tape recordings, computerized messages or data, brochures, pamphlets, 

advertisements, circulars, press releases, drafts, letters, any marginal comments appearing on any 

document, and all other writings, including electronic writings. 

F. When used with respect to a document, "identify" means furnish the document 

itself, or in lieu thereof, the name and ate of the document, the name and address of the person or 

persons originating the document, the name and address, if any, of the person or persons to 

whom the document is addressed, the names and addresses of all persons to whom copies of the 

documents were or have been sent, and the organization, firm or agency with which all such 

persons were connected as of the date of the document, and if not in possession of the original or 

a copy, furnish the name and address of the custodian of the original or a copy, or furnish the 

name and address of a person whom you believe is in possession of the original or a copy of such 

document. 

G. "Oral communication" means any oral exchange with words. 

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H. When used with respect to an oral communication, "identify" means state the date 

and place where such oral communication was made, the names of all individuals who 

participated in the communication, and their positions, employers, and employers' addresses, the 

names of all individuals who were present at the time the communication was made and their 

business affiliations and positions, the nature and substance of the communication, the nature 

and substance of each document recording or pertaining to such oral communication, and the 

name and present address of the present custodian of each such document. 

I. For all interrogatories to which the responding individual has an objection, state 

the factual and legal basis for the claimed privilege, or any other authority which provides the 

claimed basis for the objection. 

J. All documents requested as to which the responding individual claims privilege or 

any other objection as a ground for non-production shall be identified chronologically as follows: 

(a) date, 

(b) title, 

(c) type of document (e.g. memorandum, report, chart, etc.), 

(d) subject matter (without revealing the information as to which privilege or 

statutory authority is claimed), 

(e) factual and legal basis for the claimed privilege, or any other authority which 

provides the claimed ground for non-production. 

INTERROGATORIES 

1. Identify the names, titles, business or home addresses and telephone numbers of 

each person whom you (Complainant) intend to call as a witness at the hearing of this matter. 

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

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3. With respect to each expert witness you identify or intend to call at the hearing, 

please provide the following: 

(a) identifY the subject matter on which the expert is expected to testifY; 

(b) list the substance of the facts and opinions to which the expert is expected to 

testifY; 

(c) provide summary of the grounds for each opinion; 

(d) if you intend to introduce into evidence or otherwise rely upon a written 

curriculum vitae or other written document listing the expert's professional 

qualifications, identifY and attach copies of all such documents. 

4. Please provide the names of all individuals who have knowledge of, and/or 

investigated this matter. Include with your answer the substance of each individual's lmowledge 

and role in any investigation. 

5. Provide the specific factual basis upon which you rely for each violation cited and 

the individual who will provide testimony in support. 

6. Identify and produce copies of any and all documents or other tangible exhibits on 

which you anticipate relying, or will rely, in support of the case you will present at the hearing in 

this matter, including but not limited to documents or other tangible exhibits you intend to 

introduce into evidence. 

7. Please identify any documents that have been discarded or destroyed in 

connection with the investigation of this matter. 

RESPONDENT'S REQUEST FOR PRODUCTION OF DOCUMENTS 

1. Produce copies of all materials relied upon and/or consulted in responding to the 

Respondent's First Set oflnterrogatories. 

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2. Produce copies of any statements from any person whom Complainant or their 

representatives interviewed in connection with the instant matter. 

3. Produce copies of any notes and/or recordings from interviews of any person 

Complainant or their representatives interviewed in connection with the instant matter. 

4. Produce copies of all documents upon which Complainant intends to rely at the 

hearing on this matter. 

5. If Complainant intends to offer expert or opinion testimony from any witness in 

connection with this matter, produce all documents which reflect: 

a. The name and address of any such expert; 

b. Any such expert's occupation and field of specialization; 

c. Any such expert's qualifications as an expert; 

d. The number of years of experience that such expert has in his/her field of 

expertise; 

e. The remuneration, if any which has and/or will be paid to such expert in 

connection with the expert's rendering service of Complainant; 

f. Any publications or articles authored by any such expert; 

g. Any transcripts of testimony by any such expert in the last five years; 

h. Any report to Complainant, their agents, or attorneys, authored by any such 

expert; 

1. Any instructions provided to any such expert by Complainant, their agents, or 

attorneys. 

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6. If Complainant intends to introduce into evidence or otherwise rely upon a written 

curriculum vitae or other written document listing the expert's professional qualifications, 

identify and attach copies of all such documents. 

7. Produce copies of all documents, data compilations, and tangible things that are in 

the possession, custody or control of Complainant that they may use. 

8. Produce your entire investigative and penalty file including all e-mails, written 

notes, rules and regulations. 

Respectfully submitted, 

By: f.d...-A a . ~~ '!! 

Edward J. Longosz, II 

Evelyn D. Sahr 

Eckert Seamans Cherin & Mellott, LLC 

1717 Pennsylvania Avenue, NW, Suite 1200 

Washington, DC 20006 

Telephone: 202-659-6619 

Facsimile: 202-659-6699 

E-mail: elongosz@eckertsearnans.com 

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CERTIFICATE OF SERVICE 

I hereby certify that on this (SJ"' day of May, 2015, copies of the foregoing Respondent's 

First Set of Interrogatories and Request for Production of Documents was sent by e-mail 

and Federal Express as follows: 

Federal Aviation Administration 

600 Independence Avenue, S.W. 

Wilbur Wright Building- Suite 2Wl000 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Mr. Zachary M. Berman 

Complainant's Counsel 

Office of Regional Counsel, Eastern Region 

Federal Aviation Administration 

1 Aviation Plaza 

Jamaica, NY 11434 

Tel: 718-553-3273 

Fax: 718-995-5699 

Judge J.E. Sullivan 

US. Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE (Ell-310) 

Washington, DC 20590 

Tel: 202-366-6941 

Fax: 202-366-7537 

0J.;? . -:h-v ~ 

Edward J. Longosz, II~ 

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