UNITED STATES OF AMERICA U.S. DEPARTMENT OF TRANSPORTATION

FEDERALAVIATIONADMINISTRATION WASHINGTON, D.C.
IN THEMATTER OF AVIATION REPAIRSOLUTIONS,INC. FAADOCKETNO. [TO BEASSIGNED] (Civil PenaltyAction) FDMS NO. FAA-2012-0474 FAA CASENO. 2011WP910331 

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COMPLAINANT'S REQUEST FORDISCOVERYAND PRODUCTION OF DOCUMENTS Pursuantto the discovery guidelines set forth in section 13.220 ofthe Rules ofPractice in Federal Aviation Administration Civil Penalty Actions, 14 C.F.R. § 13.220, Complainant, the Federal Aviation Administration, hereby requests that Respondent, Aviation Repair Solutions, Inc. ("Aviation Repair"), provide to counsel for Complainant all ofthe informationrequested in this discovery request as providedbelow. The requested information should be sent to: Michael F. McKinley, Senior Attorney, Enforcement Division, AGC-300, Office ofthe ChiefCounsel, Federal Aviation Administration, 800 Independence Avenue, S.W., Washington, D.C. 20591, facsimile (202) 267-5106, no later than 28 days after service ofthis discovery request. All documents requested 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 ofdocument (e.g., memorandum, report, chart, etc.); (d) subject matter (without revealing the information as to which privilege or statutory authority is claimed); (e) factual or legal basis for the claimed privilege, or any other authority which provides the claimed ground for privilege. This discovery is a continuing request, through the date ofthe hearing in this matter, for Respondent to supplement or amend his answers and produce documents if new or different information or new or different documents are obtained during the pendency ofthis matter. New evidence should be provided in accordance with section 13.220(i) ofthe Rules ofPractice, 14 C.P.R. 

### § 13.220(i). DEFINITIONS 1. Use of "you" and "your" refers to Aviation Repair's agents, Aviation Repair's attorneys, and any other person(s) acting or purportingto act for or onbehalfofAviationRepair. 2. The words "and" and "or" shall be construed conjunctively and disjunctively as necessary to make the request inclusive rather than exclusive. The word "including" shall be construedwithout limitation. 3. The words "document" and "statement" mean, without limitation, the following items, whether printed or recorded or reproduced by any mechanical or electronic process or written or produced by hand: agreements, communications, correspondence, memoranda,
summanes or records of telephone conversations, summaries or records of personal conversations or interviews, diaries, graphs, reports, notebooks, note charts, plans, drawings, sketches, maps, summaries or reports of investigations, opinions or reports of consultants,

2photographs, motion picture films, brochures, pamphlets, advertisements, circulars, press releases, drafts, letters, and marginal comments appearmg on any document, and other data compilations from which information can be obtained or translated, ifnecessary, into reasonably usable form. 4. The words "describe" and "state" mean to set forth each fact, consideration, circumstance, act, omission, event, transaction, occurrence or statement which supports, refutes, concerns, relates or refers to the matter(s) referenced or described in the interrogatory, and in addition, means to identify each oral communication and each document which concerns, refers
or relates to such fact, consideration, circumstance, act omission, event, transaction, occurrence
or statement. INTERROGATORIES l. Identify each and every person Respondent intends to call as a witness in this proceedingbyproviding theperson's name, occupation, andbusiness address. 2. For each and every witness identified in answer to Interrogatory No. l, state the nature ofthe witness's testimony (i.e. factual witness or expert witness); the subject matter upon which eachintended witness is expected to testify; the facts and opinions to whichthe witness is expected to testify; and a narrative sunnnary of the grounds for each opinion to which the witness will testify. 3. For each and every witness identified as an expert in answer to Interrogatory No.2, state in detail the expertise possessed by each expert witness in the subject matter area on which the witness will opine. 4. List all exhibits you intend to use atthe hearing inthis case.



### 35. For each ofthe paragraphs in the Complaint inthis matter you deny in whole or part inyour Answer, describe withparticularity the basis for each denial. Identify the Complaint paragraph by number, for each that you deny in whole or part, and state the specific basis for your denial ofthatparagraph. Identify each and every fact that supports your denial.
REQUESTS FORPRODUCTION OF DOCUMENTS 1. For each ofthe paragraphs in the Complaint you deny in whole or part, identify andprovide any and all documents onwhichyou rely in support ofyour denial(s). Yourresponse to this Request should identify which denial(s) is/are addressed by each document provided in response to this request. 2. Provide copies of any document to which you referred to or relied upon in answering the immediately preceding interrogatories. For each document produced, identify the interrogatory that itpertains to for whichyoureferencedthe document. 3. For each and every witness identified as an expert m the preceding interrogatories,provide a copy ofhis orher current curriculum vitae. 4. Provide copies of all documents that Respondent intends to introduce into evidence thathave not already been submittedto Complainant. 5. Provide copies of any statements made by witnesses identified in the preceding interrogatories concerning, referring to, or involving the circumstances set forth in the complaint.

Date: July 31,2012 4 Respectfully submitted,

# ~t1v¥_~ M chael F. McKinley Senior Attorney Enforcement DivisionCERTIFICATE OF SERVICE
I hereby certify that I deliveredbyU.S. Certified Mail the original and one copy ofthe foregoing Requestfor Discovery and Production ofDocuments inIn the Matter of Aviation Repair Solutions, Inc, FAADocketNo. Unassigned, CaseNo. 2011WP91033l, to: Federal Aviation Administration 600 Independence Ave., S.W. Wilbur WrightBuilding-Suite2Wl000 Washington, D.C. 20591 ATTN: Hearing DocketClerk, AGC-430 In addition, I hereby certify that I served a copy ofthe same byU.S. Certified Mail, return receipt requested, and by FirstClass Mail, addressed to the following:

Name: Robert L. Toms, Jr. GibsonRivera & Toms, LLP 527 SouthLake Avenue, Suite 105 Pasadena, CA91101

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