### Inthe matter of Before the U.S. Department ofTransportation Federal Aviation Administration

DocketNo. TBA 

# RECEIVED SEP- 3 2013 HEARING DOCKET

TRANS TIME EXPRESS ) 

### ) ) ) 

### ) ) FAA Case No. 2011SW700220 The Honorable Ronnie A. Yoder

MOTION TO COMPEL DISCOVERY Pursuant to 14 C.F

### .R. 

### § 13 .220(m), Complainant files this Motionto Compel Discovery. On February 20, 2013, Complainant served on Respondent a request for discovery, requesting that the responses to the discovery request be received by March 22,2013. (Attachment A). On AprilS, 2013, Respondent sent an email to Complainant indicating thatthe responses wouldbe mailed on April6, 2013. (Attachment B). On AprilS, 2013, Complainant spoke with Counsel for Respondent who indicated that Respondent's discovery responses would be sent out April 9, 2013. On April 15, 2013, Complainant received by email Respondent's discovery response. (Attachment C). Respondent's response to discovery was incomplete, and did not include responses to Complainant's interrogatories or request for production ofdocuments. On August 6, 2013, Complainant again requested that Respondent provide responses to the February 20, 2013 discovery request, and on August 9, 2013, Complainant requested that Respondentprovide a time frame for receiving the discovery response. (Attachments D and E). On August 13, 2013, Counsel for Respondent indicated that Respondent was on vacation and those responses "should" be provided in 10 days. (Attachment E). Complainant responded that ifRespondent did notprovide the discovery in 10 days,

### Complainant would be filing a Motion to Compel Discovery. (Attachment F). On August 21, 2013, Counsel for Respondent indicated that he was meeting with his client that evening and would provide the remaining discovery the next day. (Attachment F). On August 23, 2013, Complainant informed Respondent that she had not received the remaining discovery, and inquired again when Respondent would be sending the remaining discovery. (Attachment G). The same day, Responded replied that he would be sending the remaining discovery by email on August 24, 2013. (Attachment H). To date, Complainant has notreceived the remaining discovery. 14 C.F.R. § 13.220(m) authorizes a party to make amotionto compel discovery if
a person refuses to produce documents ortangible items in response to a discovery request. To date, Respondent has refused to produce documents or tangible items in response to Complainant's discovery request that was served on Respondent in February. The parties have agreed that August 30, 2013 serve as the deadline for filing stipulations, filing witness lists and summaries oftestimony, and exchanging exhibits. Unless Complainantreceives responses to the February 20, 2013 discovery request by August 28, 2013, Complainant will not have adequate time to prepare the filings and exhibits prior to the August 30,2013 deadline. The items Complainant has sought through discovery are reasonable and relate directly to the matters to be resolved in this proceeding. Respondent's responses to the February 20, 2013, request for discovery are needed as soon as possible so that Complainant can fairly prepare for the hearing in this matter and adhere to the schedule that was agreed upon in accordance with the Scheduling Order.

2

### WHEREFORE, Complainant respectfully requests that the Administrative Law Judge grant Complainant's motion and issue an order compelling Respondent to provide
a response to Complainant's discovery request by no later than August 28, 2013.
Respectfully submitted, Peter Lynch Assistant ChiefCounsel

for Enforcement



# . By:

### --::"'--=--""'""---~A-­ Sabrina Jawed, Enforcement Division, AGC-300 Office ofthe ChiefCounsel Federal Aviation Administration 800 Independence Avenue, S.W. Washington, DC 20591 Phone: (202) 267-8839 Facsimile: (202) 267-5106 Email: Sabrina.Jawed@faa.gov

Dated: August 26, 2013

3

### Certificate ofService I hereby certify that on this date I have placed in the U.S. mail, postage prepaid, certified return-receipt, and by electronic transmission, a copy ofComplainant's Motion to Compel Discovery In the Matter of Trans Time Express, 

### DocketNo. TBA, FAA Case
no. 2011SW700220, addressed to: Cameron Niakan, Esq. 10101 Grosvenor Pl. #620 Rockville, MD 20852 In 

### addition, I hereby certify that on this date I have sent by the U.S. mail, postage prepaid, certifiedreturn-receipt and facsimile one copy ofthe foregoing document to: The Honorable Ronnie A. Yoder ChiefAdministrative Law Judge U.S. Department ofTransportation Office ofHearings, M-20 1200 New Jersey Avenue, S.E. (Ell-310) Washington, DC 20590 Facsimile: 202-366-7536 In addition, I hereby certify that onthis date I have sent by the U.S. mail, postage prepaid, certified return-receipt, the original and one copy ofthe foregoing document to: Federal Aviation Administration 800 Independence Avenue, S.W. Washington, D.C. 20591 Attn: Hearing Docket Clerk, AGC-430 Wilbur Wright Building- Suite 2Wl000

4

### V .LN3WH3V.L.LV

### Before the U.S. 

### Department ofTransportation Federal Aviation Administration

In the matter of TRANS TIME EXPRESS ) ) ) ) ) ) 

### Docket No. TBA FAA Case No. 201ISW700220 Judge Ronnie A. Yoder
COMPLAINANT'S INTERROGATORIES. REOUEST FORPRODUCTION OF DOCUMENTS, AND REOUEST FORADMISSIONS Pursuant to Rule 220 ofthe Rules ofPractice in FAA Civil Penalty Actions, 14 C.F.R. 

### § 13.220, the Complainant, Federal Aviation Administration (FAA), hereby requests that Respondent, within 30 days after service ofthis request, provide to undersigned counsel for Complainantthe information requested in this discovery request
as described below. Specifically, the requested information should be sentby facsimile
or other expedited means to: Charles Raley, Attorney, Enforcement Division, AGC-300, Office ofthe ChiefCounsel, 800 Independence Avenue, S.W., Washington, D.C. 20591, facsimile (202) 267-5106, so that it is received by undersigned counsel no later than March 22,2013. Pnrsuant to 

### Rule 207 ofthe Rules ofPractice in FAA Civil Penalty Actions, 14 C.F.R. § 13.207, the response to this discovery request must be signed by the attorney of record for the Respondent, the Respondent, or the Respondent's representative. This discovery is a continuing request, through the date ofthe heating 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.
1Forpurposes ofthe Interrogatories, Requests for Production ofDocuments and Requests for Admission, the use of"you" and "yoU!'" refers to Respondent, Respondent's agents, Respondent's attorneys, and any other person(s) acting or purporting to act for or onbehalfofRespondent. 

### INTERROGATORIES UNDER 14 C.F.R. § 

### 13.220(k) I. ldentizy each and every person you intend to call as a witness inthis proceeding, byproviding the person's name, occupation, business address, and phone number (including land lines and cell phones). 2. For each witness identified in response to Interrogatory I, identify the nature of the testimony to be provided (i.e., factual witness or expert witness) and summarize the substance ofthe testimony to be provided. 3. For each person identified as an expert in Interrogatory No.2, provide a statement ofthe substance ofthe facts and opinions to which the witness is expected to testizy; a narrative summary ofthe grounds for each opinion to which the witness will testizy; and detail the expertise possessed by each expert witness in the subject matter area on which the witness 

### will opiue. 4. List all exhibits you intend to use at the hearing in this case. 5. Identizy any and all documents in your possession that concern, refer to, or involve the circumstances set forth in the Complaint in this proceeding. 6. Describe with particularity each and every fact on which yourely to support each and every denial contained in yoU!' Answer to the Complaint in this case. 7. Describe with particularity the reasons why you cannot admit or deny allegations contained in the Complaint as reflected in your Answer to the Complaint in this



### 2case with the statements that "TIE is without sufficientknowledge orinformation to admit or deny the allegation." 8. Describe with particularity each and every fact on which you rely to support each and every affirmative defense contained in your Answer to the Complaint in this
case. 9. IdentifY the person listed 

### in FedExU.S. Airbill 8668 4774 3122 as "Ben" in the Sender's Name box by providing the person's name, occupation, business address, and phone number (including land lines and cell phones). See Attachment 1. I0. IdentifY all employees involved in picking up, classifYing, describing, packaging, marking, and labeling the shipment assigned FedEx Airbill number 8668 4774 3122 for transportation in commerce byairbyproviding each person's name, occupation, business address, and phone number (including 

### land lines and cell phones). 

### REQUESTS FORPRODUCTION OF DOCUMENTS UNDER 14 C.F.R. § 

### 13.220(b) 1. Copies ofeach and every document that you intend to introduce as evidence in this case. 2. Copies ofany statements made bywitnesses identified in the preceding Interrogatories concerning, referring to, or involving the circumstances set forth in the Complaint. 3. A current copy ofthe curriculum vitae for each expert identified in response to the preceding Interrogatories.



### 34. Copies ofall documents that support each and every denial, ifany, contained in yourAnswer to the Complaint in this case. 5. Copies ofall documents that support each and every affirmative defense, ifany, contained in your Answer to the Complaint in this case. 6. Copies ofall correspondence between you and Bandas Law Firm. 

### REQUESTS FOR ADMISSION UNDER 14 C.F.R. § 

### 13.220(1) Please provide responses to the following admissions. For 

### all denials, please provide with particularity each and every fact on which you rely to support each and every denial. Ifyou are unable to admit ordeny thetruth ofthe matter, please provide evidence that a reasonable inquiry into the matter or that the information known to, or readily obtainable by, you is insufficient to enable you to admit or deny the matter. 1. You were contracted by Bandas Law Firmto provide transportation for certain items. Admit
__ Deny
__ 2. The items you picked up for Bandas Law Firm were ten twenty-two fluid ounce plastic bottles ofMasterjackDrain Opener. Admit
__ Deny
__ 3. Youpackaged the items that you picked up for Bandas Law Firm. Admit
__ Deny
__ 4. Prior to July 28, 2011, you did notprovide hazardous materials training to your employees in accordance with 49 C.F.R. § 173.l(b). Admit
__ Deny
__



### 45. Prior to July 28, 2011, you did not provide hazardous materials training to your employees in accordance with 49 C.F.R. 

### § 172.702(a). Admit
__ Deny
__ 6. Prior to July 28, 2011, you did not provide hazardous materials training to your employees with regard to any Department ofTransportation Hazardous Materials Regulations. Admit
__ Deny
__ 7. The shipment you made on behalfofBandas Law Firm that is the subject ofthis matter was not have accompaniedby shipping papers identifying the hazardous nature of the contents contained therein. Admit
__ Deny
__ 8. The shipmentyou made on behalfofBandas LawFirm that is the subject ofthis matter did nothave accompanying shipping papers identifYing the hazardous nature of the contents contained therein. Admit
__ Deny
__ 9. The shipment you made on behalfofBandasLaw Firm that is the subject ofthis matter did nothave accompanying shipping papers containing the certifications required under the Department ofTransportation Hazardous Materials Regulations. Admit
__ Deny
__ 10. The shipmentyou made on behalfofBandas Law Firm that is the subject ofthis matter didnot have accompanying shipping papers that included the identification number as shown in Column (4) ofthe49. C.F.R. section 172.101 table. Admit
__ Deny
__



### 511. The shipment you made on behalfofBandasLaw Firm that is the subject ofthis matter did not have accompanying shipping papers that included the proper shipping iiaine as shown in Column (2) ofthe 49. C.P.R. section 172.101 table. Admit
__ Deny
__ 12. The shipment you made on behalfofBandasLaw Firm that is the subject ofthis matter did not have accompanying shipping papersthat included the hazard class or division number as shown in Column (3) ofthe 49. C.P.R. section 172.101 table. Admit
__ Deny
__ 13. The shipment you made on behalfofBandasLaw Firm that is the subject ofthis matter did nothave accompanying shipping papers that included the packaging group as shown in Column (5) ofthe 49. C.P.R. section 172.101 table. Admit
__ Deny
__ 14. The shipmentyou made on behalfofBandas Law Firm that is the subject ofthis matter did not have accompanying shipping papers that included the total netmass ofthe material per package. Admit
__ Deny
__ 15. The shipment you made on behalfofBandasLaw Firm that is the subject ofthis matter did not have accompanying shipping papers that included the number and type of packages by description. Admit
__ Deny
__

616. The shipment you made on behalfofBandas Law Firm that is the subject ofthis matter was notmarked in accordance with the Department ofTransportation Hazardous Materials Regulations. Admit
__ Deny
__ 17. The shipment you made on behalfofBandas Law Firm that is the subject ofthis matter was not marked with the shipping name and identification number ofthe hazardous materials contained therein. Admit
__ Deny
__ 18. The shipment you made on behalfofBandas Law Finn that is the subject ofthis matter was not marked with orientation markings. Admit
__ Deny
__ 19. The shipment you made on behalfofBandas Law Firm that is the subject ofthis matter was not labeled in accordance with the Department ofTransportation Hazardous Materials Regulations. Admit
__ Deny
__ 20. The shipment you made on behalfofBandas Law Firmthat is the subject ofthis matter did not have accompanying emergency response information 

### in accordance with the Department ofTransportation Hazardous Materials Regulations. Admit
__ Deny
__ 21. The shipment you made on behalfofBandas Law Firm that is the subject ofthis matter was not shipped in a package that met the requirements ofthe Department of Transportation Hazardous Materials Regulations. Admit
__ Deny
__



### 7Respectfully submitted, Peter Lynch Assistant ChiefCounsel

for Enforcement 

# By:a:z

Charles Raley, Attorney EnforcementDivision, AGC-300 Office ofthe ChiefCounsel Federal Aviation Administration 800 Independence Avenue, S.W. Washington, DC 20591 Phone: (202) 267-3357 Facsimile: (202) 267-5106 Email: charles.raley@faa.gov

Dated: February 20, 2013



### 8Certificate ofService 

### I hereby certifY that onthis date I have placed in the U.S. mail, postage prepaid, certified return-receipt, 

### acopy ofthe COMPLAINANT'S INTERROGATORIES, REQUEST FOR PRODUCTION OF DOCUMENTS, AND REQUEST FOR ADMISSIONS in the
case of

### In the 

### Matter of Trans Time Express, FAA Case no. 20IISW700220, addressed to: Cameron Niakan, Esq. 10101 

### Grosvenor Pl. 

### #620 Rockville, MD 20852 

# c;Q
Dated: February 20, 2013

901



### I .LN:iiWH:::>V.L.L V

### H .LN:!IWH:JV.L.LV

### Re: Trans Time Express CameronN. to: Sabrina Jawed 04/05/2013 12:13 PM Cc: Charles Raley Please respond to "Cameron N." Show Details
History: This message has been replied to. 

### Sabrina: Page 1 of 1



### Sorry about the delay. We just received the discovery from our client. I am mailing it to you tomorrow (I could also e-mail it to you). Our client is open, and interested in a settlement. Please let me know how we could proceed. Yours, Cameron
From: "Sabrina.Jawed@faa.gov" <Sabrina.Jawed@faa.gov> To: cameronee@yahoo.com Cc: Charles.Raley@faa.gov Sent: Friday, April 5, 2013 11:27 AM Subject: Trans Time Express Cameron, We have not yet received your discovery, which I understand was supposed to be received by March 28, 2013. Has the discovery been sent? Additionally, is your client still interested in pursuing settlement in this case?
Thank you, Sabrina S. Jawed Federal Aviation Administration Office of Chief Counsel Regulations Division Phone: 202.267.8839 

### Fax: 202.267.7971



### file:/

### I /C:/Users/Sabrina%20Jawed/ AppData!Local/Temp/notesFFF692/-webI014.htm 8/13/2013

### :J .LNID\IH:JV.LLVForpurposes ofthe Interrogatories, Requests for Production ofDocuments and Requests for Admission, the use of"you" and ''your" refers to Respondent, Respondent's agents, Respondent's attorneys, and any other person(s) acting or purporting to act for or on behalfofRespondent. INTERROGATORIES UNDER 14 C.F.R. § 13.220(k) 

### I. IdentifY each and every person you intend to call as a witness in this proceeding, by providing the person's name, occupation, business address, and phone number (including land lines and cell phones). 2. Foreach witness identified inresponse to Interrogatory 1, identifY the nature of the testimony to be provided (i.e., factual witness or expert witness) and summarizethe substance ofthe testimony to be provided. 3. For each person identified as an expert in Interrogatory No.2, provide a statement ofthe substance ofthe facts and opinions to which thewitness is expected to testifY; a narrative summary ofthe groundsJor each opinion to which the witness will testifY; and 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 at the hearing in this case. 5. Identify any and all documents in your possession that concern, refer to, or involve the circumstances set forth in the Complaint in this proceeding. 6. Describe with patticularity each and every fact on which you rely to support each and every denial contained in your Answer to the Complaint in this case. 7. Describe with particularity the reasons why you cannot admit or deny allegations contained inthe Complaint as reflected in your Answer to the Complaint in this

2case with the statements that "TIE is without sufficient knowledge or information to admit or deny the allegation." 8. Describe with particularity each and every fact on which you rely to support each and every affirmative defense contained inyour Answerto the Complaint in this
case. 9. IdentifY the person listed in FedEx U.S. Airbi118668 4774 3122 as "Ben" inthe Sender'sName boxby providing theperson's name, occupation, business address, and phone number (including land lines and cell phones). See Attachment I. 

### 10. IdentifY all employees involved in pickingup, classifying, describing, packaging, marking, and labelingthe shipment assigned FedExAirbill number 8668 4774 3122 for transportation in commerce by air byproviding each person's name, occupation, business address, and phonenumber (including land lines and cell phones). 

### REQUESTS FORPRODUCTION OFDOCUMENTS UNDER 14 C.F.R. 

### § 13.220(b) 

### l. Copies ofeach and every document thatyou intend to introduce as evidence in this case. 2. Copies ofany statements made by witnesses identified in the preceding Interrogatories concerning, referring to, or involving the circumstances set forth in the Complaint. 3. A current copy ofthe curriculum vitae for each expe1t identified in response to the preceding Interrogatories.



### 3

# !

4. Copies ofall documents that support each and every denial, ifany, contained in your Answer to the Complaint 

### in this case. 5. Copies ofall documents that support each and every affirmative defense, ifany, contained in your Answer to the Complaint in this case. 6. Copies ofall correspondence between you and Bandas Law Firm. 

### REQUESTS FOR ADMISSION UNDER 14 C.F.R. § 

### 13.220(1) Please provide responses to the following admissions. For all denials, please provide with particularity each and every fact on which yo11 rely to support each and every denial. Ifyou are unable to admit or deny the truth ofthe matter, please provide evidence that a reasonable inquiry into the matter orthat the information known to, or readily obtainable by, you is insufficient to enable you to admit or deny the matter. 1. You were contracted by BandasLawFirm to provide transportation for certain items. Admit

# j{_ Deny
__ 2. The items you picked up for Bandas Law Firm were ten twenty-two fluid ounce plastic bottles ofMasterjack Drain Opener. Admit_:f._ Deny
__ 3. You packaged the items that you picked up for Bandas LawFirm. Admit 

# X Deny
__ 4. Prior to July 28, 2011, you did not provide hazardous materials training to your employees in accordance with 49 C.P.R.§ 173.l(b). Admit
__ Deny
__



### 45. Priorto July 28, 2011, you did not provide hazardous materials training to your employees in accordauce with 49 C.F.R. § 172.702(a). 

### Admit
__ Deny
__ 

### 6. Priorto July 28, 2011, you did not provide hazardous materials training to your employees withregard to any Department ofTrausportationHazardous Materials Regulations. 

### Admit
__ Deny
__ 7. The shipment you made on behalfofBandas Law Firm that is the subject ofthis matterwas nothave accompanied by shipping papers identifYing the hazardous nature of the contents contained therein. 

### Admit_){_ Deny
__ 

### 8. The shipment you made onbehalfofBandas Law Firm thatis the subject ofthis matter did nothave accompanying shipping papers identifYing the hazardous nature of the contents contained therein. 

### Admit

# 1._ Deny
__ 

### 9. The shipmentyou made on behalfofBaudasLawFirmthat is the subject ofthis matter did nothave accompanying shipping papers containing the certifications required under the Department ofTransportation Hazardous Materials Regulations. 

### Admit

# _i_ Deny
__ 10. The shipment you made on behalfofBandas Law Firm that is the subject ofthis matter did not have accompanying shipping papers that included the identification number as shown in Column (4) ofthe 49. C.F.R. section 172.101 table. 

### Admit 

# 1 Deny
__

511. The shipment you made on behalfofBandas Law Fhmthat is the subject ofthis matter did not have accompanying shipping papers that included the proper shipping
name as shown in Column (2) ofthe 49. C.F.R. section 172.101 table. Admit

# _x_ Deny
__ 12. The shipment you made on behalfofBandasLaw Firm that is the subject ofthis matter did nothave accompanying shipping papers that included the hazard class or division number as shown in Column (3) ofthe 49. C.F.R. section 172.101 table. Admit

# _:i_ Deny
__ 13. The shipmentyou made onbehalfofBandas Law Firm that is the subject ofthis matter did nothave accompanying shipping papers that included the packaging group as shown in Column (5) ofthe 49. C.F.R. section 172.101 table. Admit

# _2{_ Deny
__ 14. The shipment youmade on behalfofBandasLaw Finn that is the subject ofthis matter did nothave accompanying shipping papers that included the total net mass ofthe material per package. Admit

# X Deny
__ 15. The shipment you made on behalfofBandas Law Firm that is the subject ofthis matter did nothave accompanying shipping papersthat included the number and type of packages by description. Admit

# _t_ Deny
__

616. The shipmentyou made on behalfofBandasLaw Firmthat is the subject ofthis matter was notmarked in accordance witbtbe Department ofTransportation Hazardous Materials Regulations. Admit

# A Deny
__ 17. The shipmentyou made on behalfofBandasLaw Firm that is the subject ofthis matter was not marked witb tbe shipping name and identification number ofthe hazardous materials contained therein. Admit

# A Deny
__ 18. The shipmentyoumade on behalfofBandas LawFirm that is the subject ofthis matter was not marked with orientation markings. Admit

# X Deny
__ 19. The shipmentyou made on behalfofBandas Law Firm that is the subject ofthis matter was not labeled in accordance with the Department ofTransportation Hazardous Materials Regulations. Admit )( Deny
__ 20. The shipment you made on behalfofBandasLawFinn that is the subject ofthis matter did not have accompanying emergency response information in accordance with the Department ofTransportation Hazardous Materials Regulations. Admit

# A Deny
__ 21. The shipment you made onbehalfofBandas Law Firm that is the subject ofthis matter was not shipped in a package thatmet the requirements ofthe Department of Transp01tation Hazardous Materials Regulations. Admit 

# x· Deny
__

7

# ! I
Respectfully submitted, Peter Lynch Assistant ChiefCounsel

for Enforcement 

# By:c;;r;z

Charles Raley, Attorney Enforcement Division, AGC-300 Office ofthe ChiefCounsel Federal Aviation Administration 800 Independence Avenue, S.W. Washington, DC 20591 Phone: (202) 267-3357 Facsimile: (202) 267-5106 Email: charles.raley@faa.gov

Dated: February 20, 2013



### 8Certificate ofService

· I hereby certify that on this date I have placed in the U.S. mail, postage prepaid, certified

return-receipt, a copy ofthe COMPLAINANT'S INTERROGATORIES, REQUEST

,. FORPRODUCTION OF DOCUMlENTS, AND REQUEST FOR ADMISSIONS in the
case of

### In the 

### Matter of Trans Time Express, FAA Case no. 2011SW700220, addressed to: Cameron Niakan, Esq. I 10101 Grosvenor Pl;. #620 Rockville, MD 20852 

# c;Q
Dated: February 20, 2013

# ~\_~~**\.C:)~"-~**

9

### 0!



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### <I 

### .LN:.IWH;JV.L.LV

### Re: Trans Time Express Discovery CameronN. to: Sabrina Jawed 08/06/2013 05:21 PM Cc: Charles Raley Please respond to "CameronN." Show Details
History: This message has beenreplied to. 

### Sabrina: I'll make sure you have them soon. Thnx, Cameron**~~-u~-~~~··----~-·--- ~--~"~-,,.~,-~m"""**  From: "Sabrina.Jawed@faa.gov" <Sabrina.Jawed@faa.gov> To: Cameron N. <cameronee@yahoo.com> 

### Cc: Charles.Raley@faa.gov Sent: Tuesday, August 6, 2013 5:20 PM Subject: Re: Trans Time Express Discovery Cameron, We received your client's responses to our requests for admissions. We are missing responses to our interrogatories and requests for production of documents. Best, Sabrina S. Jawed Federal Aviation Administration Office of Chief Counsel Regulations Division Phone: 202.267.8839 Fax: 202.267.7971

From: To: Cc: Date: "Cameron N." <cameronee@yahoo.com> Sabrina Jawed/AWA/FAA@FAA Charles Raley/AWAJFAA@FAA 08/06/2013 05:19PM 

### file:///C:/Users/Sabrina%20Jawed/ AppData!Local/Temp/notesFFF692/-web6174.htm Page 1 of3

8113/2013

### Page2 of3
Subject: Re: Trans Time Express Discovery



### Sabrina: I remember submitting 

### something to FAA, answered by my client. What do you already have,· and what are you missing? Cameron**~~---·----···-----·-··-·----·-·--------·-·····--··** From: "Sabrina.Jawed@faa.gov'' <Sabrina.Jawed@faa.gov> To: Cameron N. <cameronee@yahoo.com> Cc: Charles.Raley@faa.gov Sent: Tuesday, August 6, 2013 5:07 PM Subject: Re: Trans Time Express Discovery Cameron, Please find attached an electronic version ofthe discovery requests we mailed yourclient on February 20, 2013. Best, Sabrina S. Jawed Federal Aviation Administration Office of Chief Counsel Regulations Division Phone: 202.267.8839 Fax: 202.267.7971

Frorn: To: Date: Subject:



### Sabrina: "Cameron N." <cameronee@yahoo.cum> Sabrina Jawed/AWA/FM@FAA 0810612013 04:29PM Re: Trans Time Express Discovery



### I am not sure ifwe ever received anything else, other than the "Request for Admissions". Kindly send them again, and I'll make sure they are responded to.



### file:///C:/Users/Sabrina%20Jawed/**AppData/Local/Temp/notesFFF692/~web617**

### 4.htm 8/13/2013

### i Yours, Cameron

From: "Sabrina.Jawed@faa.gov" <Sabrina.Jawed@faa.gov> To: cameronee@yahoo.com Cc: Charles.Raley@faa.gov Sent: Tuesday, August 6, 2013 2:41 PM Subject: Trans Time Express Discovery Cameron, 

### Page 3 of3

Could you please provide us with the outstanding discovery we requested? We received your client's responses to our requests for admissions, but are missing responses to our interrogatories and requests for production of documents. Additionally, have you received a response from your client on our outstanding settlement offer? Thank you, Sabrina S. Jawed Federal Aviation Administration Office of Chief Counsel Regulations Division Phone: 202.267.8839 Fax: 202.267.7971



### file:///C:/Users/Sabrina%20Jawed/ AppData!Local/Temp/notesFFF692/-web6174.htm 8113/2013

### :!1 .LN:!IWH:JV.L.LV

### Re: Trans Time Express Discovery CameronN. to: Sabrina Jawed 08/13/2013 06:25AM Please respond to "CameronN." Show Details History: This message has been forwarded. Sabrina: My client may be in vacation. I should have them for you in ten days. Thanks, Cameron From: "Sabrina.Jawed@faa.gov" <Sabrina.Jawed@faa.gov> To: Cameron N. <cameronee@yahoo.com> Cc: Charles.Raley@faa.gov Sent: Friday, August 9, 2013 1:07 PM Subject: Re: Trans Time Express Discovery Cameron, When should we expect to receive the outstanding discovery? Thank you, Sabrina S. Jawed Federal Aviation Administration Office of Chief Counsel Regulations Division Phone: 202.267.8839 Fax: 202.267.7971**·-~~···.~~~~~-·**



### file:/

### I /C:/Users/Sabrina%20Jawed/**AppData!Local/Temp/notesFFF692/~web0052.htm** 

### Page 1 of 1

8/13/2013

### II .LN;:tiWH;)V.L.LV

### Re: Trans Time Express Discovery 

## 0 Sabrina Jawed to: Cameron N. 08/13/2013 01 :45 PM AGC-200, lnt'l Law, Legislation & Regs Div.**~~~~~~C:.;.c:.;:** Charles Raley**··--~····---~--~~~~~ ~"~"~"~"·~,~=**  Cameron, Thank you for letting me know that we should expect the remaining discovery in ten days. Because we agreed that August 30, 2013 would serve as the deadline for filing stipulations, witness lists and summaries ofthe testimony, and exchanging exhibits, we need to receive the remaining discovery as soon as possible in order to have adequate time to prepare the filings and exhibits. Ifwe do not receive the discovery in the next ten days, we will be filing a Motion to Compel Discovery. Best, Sabrina S. Jawed Federal Aviation Administration Office of Chief Counsel Regulations Division Phone: 202.267.8839 Fax: 202.267.7971**~** 

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### H .LN:>IW:>IH:JV.L.LV

### Re: Trans Time Express Discovery cameronee to: Sabrina Jawed 08/23/201311:50AM Please respond to cameronee Show Details Sabrina: Page 1 of2

My apologies. I am waiting on a couple ofitems from the client. You should have them by e-mail tomorrow. Thnx, Cameron
Senl via the Smnsung Galaxy STMIIT. an AT&T 4G LTE smanphone 

### Sabrina.Jawed@faa.gov wrote: Cameron, I have not yet received the remaining discovery from you. Will we be receiving it today? Best, Sabrina S. Jawed Federal Aviation Administration Office of Chief Counsel Regulations Division Phone: 202.267.8839 Fax: 202.267.7971

From: To: Date: Subject



## Sabrina: "Cameron N." <cameronee@yahoo.com> Sabrina Jawed/AWA/FAA@FAA 08/21/2013 09:16AM Re: Trans Time Express Discovery



## I am meeting with my clients tonight and I am supposed to receive the package from them. I should be able to e-mail you the remaining discovery to you tomorrow, and mail it as well. file:///C:/Users/Sabrina%20Jawedl**AppData/Local/Temp/notesFFF692/~web** 

### 1489.htm 8/26/2013