In the matter of 

Before the U.S. Department of Transportation 

Federal Aviation Administration 

Docket No. 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 Motion to 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 that the responses would be 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 of documents. 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 

Respondent provide 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 if Respondent did not provide 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 not received the remaining discovery. 

14 C.F.R. § 13.220(m) authorizes a party to make amotion to compel discovery if 

a person refuses to produce documents or tangible 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 of testimony, and exchanging exhibits. Unless 

Complainant receives 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 Chief Counsel 

for Enforcement 

. 

By: --::"'--=--""'""---~A-­ Sabrina Jawed, 

Enforcement Division, AGC-300 

Office of the Chief Counsel 

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 of Service 

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 of Complainant's Motion 

to Compel Discovery In the Matter of Trans Time Express, Docket No. 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, certified return-receipt and facsimile one copy of the foregoing document to: 

The Honorable Ronnie A. Yoder 

Chief Administrative Law Judge 

U.S. Department of Transportation 

Office of Hearings, M-20 

1200 New Jersey Avenue, S.E. (Ell-310) 

Washington, DC 20590 

Facsimile: 202-366-7536 

In addition, I hereby certify that on this date I have sent by the U.S. mail, postage 

prepaid, certified return-receipt, the original and one copy of the 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 2Wl 000 

4 
V .LN3WH3V.L.LV 
Before the U.S. Department of Transportation 

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 FOR PRODUCTION OF 

DOCUMENTS, AND REOUEST FOR ADMISSIONS 

Pursuant to Rule 220 of the Rules of Practice 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 Complainant the information requested in this discovery request 

as described below. Specifically, the requested information should be sent by facsimile 

or other expedited means to: Charles Raley, Attorney, Enforcement Division, AGC-300, 

Office of the Chief Counsel, 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 of the 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 of the 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 of this matter. 

1 
For purposes of the Interrogatories, Requests for Production of Documents 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 

on behalf of Respondent. 

INTERROGATORIES UNDER 14 C.F.R. § 13.220(k) 

I. ldentizy 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. 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 of the testimony to be provided. 

3. For each person identified as an expert in Interrogatory No.2, provide a statement 

of the substance of the facts and opinions to which the witness is expected to 

testizy; a narrative summary of the 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 you rely 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 

2 
case 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 in your Answer to the Complaint in this 

case. 

9. IdentifY the person listed in FedEx U.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. 

I 0. IdentifY all employees involved in picking up, classifYing, describing, packaging, 

marking, and labeling the shipment assigned FedEx Air bill number 8668 4 77 4 

3122 for transportation in commerce by air by providing each person's name, 

occupation, business address, and phone number (including land lines and cell 

phones). 

REQUESTS FOR PRODUCTION OF DOCUMENTS UNDER 

14 C.F.R. § 13.220(b) 

1. Copies of each and every document that you intend to introduce as evidence in 

this case. 

2. Copies of any 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 of the curriculum vitae for each expert identified in response to the 

preceding Interrogatories. 

3 
4. Copies of all documents that support each and every denial, if any, contained in 

your Answer to the Complaint in this case. 

5. Copies of all documents that support each and every affirmative defense, if any, 

contained in your Answer to the Complaint in this case. 

6. Copies of all 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. If you are unable to admit or deny the truth of the 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 Firm to 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 ofMasterjack Drain Opener. 

Admit __ Deny __ 

3. You packaged the items that you picked up for Bandas Law Firm. 

Admit __ Deny __ 

4. Prior to July 28, 2011, you did not provide hazardous materials training to your 

employees in accordance with 49 C.F.R. § 173.l(b). 

Admit __ Deny __ 

4 
5. 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 of Transportation Hazardous Materials 

Regulations. 

Admit __ Deny __ 

7. The shipment you made on behalf ofBandas Law Firm that is the subject of this 

matter was not have accompanied by shipping papers identifying the hazardous nature of 

the contents contained therein. 

Admit __ Deny __ 

8. The shipment you made on behalf ofBandas Law Firm that is the subject of this 

matter did not have accompanying shipping papers identifYing the hazardous nature of 

the contents contained therein. 

Admit __ Deny __ 

9. The shipment you made on behalfofBandas Law Firm that is the subject of this 

matter did not have accompanying shipping papers containing the certifications required 

under the Department of Transportation Hazardous Materials Regulations. 

Admit __ Deny __ 

10. The shipment you made on behalfofBandas Law Firm that is the subject of this 

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 __ Deny __ 

5 
11. The shipment you made on behalf ofBandas Law Firm that is the subject of this 

matter did not have accompanying shipping papers that included the proper shipping 

iiaine as shown in Column (2) of the 49. C.P.R. section 172.101 table. 

Admit __ Deny __ 

12. The shipment you made on behalfofBandas Law Firm that is the subject ofthis 

matter did not have accompanying shipping papers that included the hazard class or 

division number as shown in Column (3) of the 49. C.P.R. section 172.101 table. 

Admit __ Deny __ 

13. The shipment you made on behalfofBandas Law Firm that is the subject ofthis 

matter did not have accompanying shipping papers that included the packaging group as 

shown in Column (5) of the 49. C.P.R. section 172.101 table. 

Admit __ Deny __ 

14. The shipment you made on behalf of Bandas Law Firm that is the subject of this 

matter did not have accompanying shipping papers that included the total net mass ofthe 

material per package. 

Admit __ Deny __ 

15. The shipment you made on behalf ofBandas Law Firm that is the subject of this 

matter did not have accompanying shipping papers that included the number and type of 

packages by description. 

Admit __ Deny __ 

6 
16. The shipment you made on behalf ofBandas Law Firm that is the subject of this 

matter was not marked in accordance with the Department of Transportation Hazardous 

Materials Regulations. 

Admit __ Deny __ 

17. The shipment you made on behalf ofBandas Law Firm that is the subject of this 

matter was not marked with the shipping name and identification number of the 

hazardous materials contained therein. 

Admit __ Deny __ 

18. The shipment you made on behalfofBandas Law Finn that is the subject of this 

matter was not marked with orientation markings. 

Admit __ Deny __ 

19. The shipment you made on behalf ofBandas Law Firm that is the subject of this 

matter was not labeled in accordance with the Department of Transportation Hazardous 

Materials Regulations. 

Admit __ Deny __ 

20. The shipment you made on behalf ofBandas Law Firm that is the subject of this 

matter did not have accompanying emergency response information in accordance with 

the Department of Transportation Hazardous Materials Regulations. 

Admit __ Deny __ 

21. The shipment you made on behalfofBandas Law Firm that is the subject of this 

matter was not shipped in a package that met the requirements of the Department of 

Transportation Hazardous Materials Regulations. 

Admit __ Deny __ 

7 
Respectfully submitted, 

Peter Lynch 

Assistant Chief Counsel 

for Enforcement 

By:a:z 

Charles Raley, Attorney 

Enforcement Division, AGC-300 

Office of the Chief Counsel 

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 

8 
Certificate of Service 

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

return-receipt, a copy of the 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. 20 II SW700220, addressed 

to: 

Cameron Niakan, Esq. 

10101 Grosvenor Pl. #620 

Rockville, MD 20852 

c;Q 

Dated: February 20, 2013 

9 
01 

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/-web I 0 14.htm 8/13/2013 
:J .LNID\IH:JV.LLV 
For purposes of the Interrogatories, Requests for Production of Documents 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 behalf of Respondent. 

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. For each witness identified in response to Interrogatory 1, identifY the nature of 

the testimony to be provided (i.e., factual witness or expert witness) and 

summarize the substance of the testimony to be provided. 

3. For each person identified as an expert in Interrogatory No.2, provide a statement 

of the substance of the facts and opinions to which the witness is expected to 

testifY; a narrative summary of the 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 in the Complaint as reflected in your Answer to the Complaint in this 

2 
case 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 in your Answer to the Complaint in this 

case. 

9. IdentifY the person listed in FedEx U.S. Airbi118668 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 I. 

10. IdentifY all employees involved in picking up, classifying, describing, packaging, 

marking, and labeling the shipment assigned FedExAirbill number 8668 4774 

3122 for transportation in commerce by air by providing each person's name, 

occupation, business address, and phone number (including land lines and cell 

phones). 

REQUESTS FOR PRODUCTION OF DOCUMENTS UNDER 

14 C.F.R. § 13.220(b) 

l. Copies of each and every document that you intend to introduce as evidence in 

this case. 

2. Copies of any 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 of the curriculum vitae for each expe1t identified in response to the 

preceding Interrogatories. 

3 
! 

4. Copies of all documents that support each and every denial, if any, contained in 

your Answer to the Complaint in this case. 

5. Copies of all documents that support each and every affirmative defense, if any, 

contained in your Answer to the Complaint in this case. 

6. Copies of all 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. If you are unable to admit or deny the truth of the 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 Firm 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 Law Firm. 

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 __ 

4 
5. Prior to 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. Prior to July 28, 2011, you did not provide hazardous materials training to your 

employees with regard to any Department ofTrausportation Hazardous Materials 

Regulations. 

Admit __ Deny __ 

7. The shipment you made on behalf ofBandas Law Firm that is the subject of this 

matter was not have accompanied by shipping papers identifYing the hazardous nature of 

the contents contained therein. 

Admit_){_ Deny __ 

8. The shipment you made on behalf ofBandas Law Firm that is the subject of this 

matter did not have accompanying shipping papers identifYing the hazardous nature of 

the contents contained therein. 

Admit 1._ Deny __ 

9. The shipment you made on behalf ofBaudas Law Firm that is the subject of this 

matter did not have accompanying shipping papers containing the certifications required 

under the Department of Transportation Hazardous Materials Regulations. 

Admit _i_ Deny __ 

10. The shipment you made on behalf ofBandas Law Firm that is the subject ofthis 

matter did not have accompanying shipping papers that included the identification 

number as shown in Column (4) of the 49. C.F.R. section 172.101 table. 

Admit 1 Deny __ 

5 
11. The shipment you made on behalf ofBandas Law Fhm that is the subject of this 

matter did not have accompanying shipping papers that included the proper shipping 

name as shown in Column (2) of the 49. C.F.R. section 172.101 table. 

Admit _x_ Deny __ 

12. The shipment you made on behalf ofBandas Law Firm that is the subject of this 

matter did not have 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 shipment you made on behalfofBandas Law Firm that is the subject ofthis 

matter did not have accompanying shipping papers that included the packaging group as 

shown in Column (5) of the 49. C.F.R. section 172.101 table. 

Admit _2{_ Deny __ 

14. The shipment you made on behalf ofBandas Law Finn that is the subject of this 

matter did not have accompanying shipping papers that included the total net mass of the 

material per package. 

Admit X Deny __ 

15. The shipment you made on behalfofBandas Law Firm that is the subject ofthis 

matter did not have accompanying shipping papers that included the number and type of 

packages by description. 

Admit _t_ Deny __ 

6 
16. The shipment you made on behalf ofBandas Law Firm that is the subject of this 

matter was not marked in accordance witb tbe Department of Transportation Hazardous 

Materials Regulations. 

Admit A Deny __ 

17. The shipment you made on behalfofBandas Law Firm that is the subject ofthis 

matter was not marked witb tbe shipping name and identification number of the 

hazardous materials contained therein. 

Admit A Deny __ 

18. The shipment you made on behalf ofBandas Law Firm that is the subject of this 

matter was not marked with orientation markings. 

Admit X Deny __ 

19. The shipment you made on behalfofBandas Law Firm that is the subject of this 

matter was not labeled in accordance with the Department of Transportation Hazardous 

Materials Regulations. 

Admit )( Deny __ 

20. The shipment you made on behalfofBandas Law Finn that is the subject of this 

matter did not have accompanying emergency response information in accordance with 

the Department of Transportation Hazardous Materials Regulations. 

Admit A Deny __ 

21. The shipment you made on behalf ofBandas Law Firm that is the subject of this 

matter was not shipped in a package that met the requirements of the Department of 

Transp01tation Hazardous Materials Regulations. 

Admit x· Deny __ 

7 
! I 

Respectfully submitted, 

Peter Lynch 

Assistant Chief Counsel 

for Enforcement 

By:c;;r;z 

Charles Raley, Attorney 

Enforcement Division, AGC-300 

Office of the Chief Counsel 

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 

8 
Certificate of Service 

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

return-receipt, a copy of the COMPLAINANT'S INTERROGATORIES, REQUEST ,. 

FOR PRODUCTION 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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·SAFER Web - Company Snapshot TRANS US f "''C http://safer.fmcsa.dot.gov/query.asp 

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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 "Cameron N." 

Show Details 

History: This message has been replied 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:/U sers/Sabrina%20Jawed/ AppData!Local/Temp/notesFFF692/-web617 4.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 of the discovery requests we mailed your client 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 if we 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:/U sers/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:/U sers/Sabrina%20Jawed/ AppData!Local/Temp/notesFFF692/-web617 4.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 "Cameron N." 

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:/U sers/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 of the 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. If we 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 
~ .LN3W3H:JV.L.LV 
H .LN:>IW:>IH:J V .L.L V 
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 of items 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