U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

IN THE MATTER OF RECEIVED 

MACH ONE AIR CHARTERS, INC. JUL 2 0 2015 

FDMS NO.: FAA-2015-0643 HEARING DOCKET 

ASSIGNED TO THE HONORABLE RICHARD C. GOODWIN, ALJ. 

RESPONDENT'S RESPONSE TO COMPLAINANT'S REQUEST FOR 

ADMISSIONS, INTERROGATORIES AND REQUESTS FOR PRODUCTION OF 

DOCUMENTS. 

ANSWERING PARTY: 

ASKING PARTY: 

MACH ONE AIR CHARTERS, INC. 

FEDERAL AVIATION ADMINISTRATION 

COMES NOW the Respondent MACH ONE AIR CHARTERS, INC., and 

pursuantto 14 C.F.R. §13.220 of the Rules of Practice in FAA Civil Penalty Actions, 

responds to the Requests of Admissionss, Interrogatories, and Requests for 

Production of Documents (Set No. 1) served upon it by the Administrator of the 

Federal Aviation Administration as follows. 

These responses are made solely for the purpose of this action. Each 

response is subject to all appropriate objections (including, but not limited to, 

objections as to confidentiality, relevancy, propriety and admissibility) which would 

require the exclusion of any admission, denial or statement contained herein if the 

questions/requests were answered by a witness present and testifying in court. All 

such objections and grounds are reserved and may be interposed at the time of 

Pa e 1 

RESPONDENT'S RESPONSE TO COMPLAINANT'S REQUEST FOR ADMISSIONS, INTERROGATORIES AND REQUESTS 

FOR PRODUCTION OF DOCUMENTS 
trial. 

Respondent has not yet completed its investigation of the facts related to the 

action; has not yet interviewed all witnesses in this action; has not yet completed its 

discovery in this action; and has not yet completed its preparation for trial. 

Consequently, the following responses are given without prejudice to Respondent's 

right to produce, at time of trial, subsequently discovered evidence relating to the 

proof of presently known material facts and to produce all evidence, whenever 

discovered, relating to the proof of subsequently discovered material facts. Except 

for explicit facts admitted herein, no admission of any nature whatsoever are implied 

or should be inferred from these responses. 

Respondent shall amend these discovery responses when such further 

information becomes known to Respondent. 

REQUESTS FOR ADMISSIONS 

1. Objection. The use of the wording "not functioning properly" is vague and 

ambiguous. Further, the RFA calls for a legal conclusion. However, without 

waiving such objection, if the outside air temperature gauge did not conform to or 

operate in accordance with the type design, then Respondent admits that the 

aircraft was unairworthy. However, Respondent contends that the outside air 

temperature gauge was operating within all acceptable limits during the flights in 

question. 

2. Objection. The use of the wording "not functioning properly" is vague and 

ambiguous. Further, the RFA calls for a legal conclusion. However, without 

waiving such objection, if the left engine air intake anti-ice system did not conform 

to or operate in accordance with the type design, then Respondent admits that the 

Pa e 2 

RESPONDENTS RESPONSE TO COMPLAINANT'S REQUEST FOR ADMISSIONS, INTERROGATORIES AND REQUESTS 

FOR PRODUCTION OF DOCUMENTS 
aircraft was unairworthy. However, Respondent contends that the left engine air 

intake anti-ice system was operating within all acceptable limits during the flights in 

question. 

3. Admit 

4. Objection. Vague and Ambiguous. The Request for Admission is 

incomprehensible and on that basis Respondent must therefore deny the same. 

INTERROGATORIES AND REQUESTS FOR PRODUCTION 

1. [RFA No. 1 and RFA No. 2] Respondent contends that both the outside air 

temperature gauge as well as the left engine air intake anti-ice system were 

operating properly, and if they were not, Respondent, as the holder of the Part 135 

Air Carrier/Commercial Operator Certificate was not put on notice that the same 

were not operating properly. The aircraft was being operated by an experienced 

flight crew, who had received proper company training in the aircraft and who the 

company expected would notify them in the event of any unairworthy issues with the 

aircraft, specifically, after they left St. Paul, Minnesota. 

[RFA No.4] The inquiry doesn't make any sense. 

2. Respondent has not yet prepared for trial and may amend this witness list in 

the future. However, at the present time Respondent intends to call the following 

individuals 

1. H. DAN HILL, Chief Pilot for Respondent and President/CEO, Mach 

One Air Charters, Inc., 7000 Merrill Avenue, Box 63, Chino, CA 91710, (909) 

597-8461. Mr. Hill will testify as to his discussions with the PIC and with 

individuals at Signature TechnicAir regarding what inspections, if any, were 

to be performed on the aircraft. Mr. Hill will also testify that he was never 

Pa e 3 

RESPONDENT'S RESPONSE TO COMPLAINANT'S REQUEST FOR ADMISSIONS, INTERROGATORIES AND REQUESTS 

FOR PRODUCTION OF DOCUMENTS 
notified that the aircraft had been determined to be unairworthy. 

2. JOHN JORGENSEN, Director of Operations, Mach One Air Charters, 

Inc., 7000 Merrill Avenue, Box 63, Chino, CA 91710, (909) 597-8461. Mr. 

Jorgensen will testify as to pilot training, company manuals setting forth pilot 

responsibility for maintenance when away from home base as well as any 

contact he may have had with Signature TechnicAir. Mr. Jorgensen will also 

testify as to any notification the company may have had from TechnicAirthat 

the aircraft may not have been airworthy. 

3. ALBERT CUEVAS, Prior Director of Maintenance, Mach One Air 

Charters, Inc., 7000 Merrill Avenue, Box 63, Chino, CA 91710, (909) 597-

8461. Mr. Cuevas will testify as to whether he was notified of any mechanic 

problem with the aircraft and will further testify as to how the Outside Air 

Temperature Gauge works. 

4. LEIGH CRUMPTON, P.O. Box 825, Acton, CA 92510. Mr. Crumpton 

was the PIC on the flight and will testify about his discussions with Mr. Hill 

about any issues he had on the flight. He will further testify that he was 

never contacted by Signature TechnicAir and informed that the aircraft was 

unairworthy. He will further testify that he was never provided any 

documentation by Signature TechnicAir which indicated the aircraft was 

unairworthy and will further testify that the flights from St. Paul to Houston 

were uneventful and everything worked on the aircraft. 

5. JENNIFER JOHNSON, 2550 E. Riverside Drive, #148, Riverside, CA 

91761. Ms. Johnson was the SIC on the flight. She will further testify that 

she was never contacted by Signature TechnicAir and informed that the 

Pa e4 

RESPONDENT'S RESPONSE TO COMPLAINANT'S REQUEST FOR ADMISSIONS, INTERROGATORIES AND REQUESTS 

FOR PRODUCTION OF DOCUMENTS 
aircraft was unairworthy. She will further testify that she was never provided 

any documentation by Signature TechnicAir which indicated the aircraft was 

unairworthy and will further testify that the flights from St. Paul to Houston 

were uneventful and everything worked on the aircraft. 

6. RICARDO HERNANDEZ, FAA-Aviation Safety Inspector, Flight 

Standards District Office, 6961 Flight Road, Riverside, CA 92504. Inspector 

Hernandez will testify that he was the individual who first contacted Mach 

One Air Charter and informed them of the alleged unairworthy condition of 

the aircraft. He will testify as to the initial reaction of the individuals at the 

meeting. 

7. JOSH CHIN, P.O. Box90083, City of Industry 91715, (708) 888-0778. 

Mr. Chin is a computer expert and will testify as to how email operates. He 

will provide expert opinion that the fact that an email may have been sent is 

not a guarantee that it is received by the intended recipient. 

8. EXPERT NOT YET DESIGNATED. This expert will be a maintenance 

expert to testify as to how the Outside Air Temperature gauge worked on the 

aircraft and the proper method for testing the same. 

9. EXPERT NOT YET DESIGNATED. Respondent also intends to call an 

expert witness on Custom and Usage and Industry Standards regarding 

reliance by the company on competent and trained flight crew .. 

3. No written statements have been made other than for Jennifer Johnson, said 

statement in the possession of the Complainant. 

4. Yes. 

Pa e5 

RESPONDENT'S RESPONSE TO COMPLAINANT"$ REQUEST FOR ADMISSIONS, INTERROGATORIES AND REQUESTS 

FOR PRODUCTION OF DOCUMENTS 
1. JOSH CHIN, P.O. Box90083, Cityoflndustry91715, (708) 888-0778. 

Mr. Chin is a computer expert and will testify as to how email operates. He will 

provide expert opinion that the fact that an email may have been sent is not a 

guarantee that it is received by the intended recipient. Respondent does not yet 

have Mr. Chin's CV but will be provided to complainant as soon as received. 

2. EXPERT NOT YET DESIGNATED. This expert will be a maintenance 

expert to testify as to how the Outside Air Temperature gauge worked on the aircraft 

and the proper method for testing the same. 

3. EXPERT NOT YET DESIGNATED. Respondent also intends to call an 

expert witness on Custom and Usage and Industry Standards regarding reliance by 

the company on competent and trained flight crew. 

5. No. 

6. Respondent has not yet completed its investigation into this matter and 

reserves the right to amend its response herein when further documents are 

obtained. At the present time, Respondent intends to rely upon the documents and 

statements contained in the FAA's Items of proof. Respondent intends to take the 

depositions of personnel from Signature TechnicAir and any documents discovered 

during such depositions may also be introduced. Respondent will also submit 

portions of Mach One Air Charter, Inc.'s General Operations Manual (GOM), which 

are referenced as H-1/R-13/10-10-13 and F-1/R-11/11-5-2010 (copies enclosed). 

[signature on following page] 

Pa e6 

RESPONDENT'S RESPONSE TO COMPLAINANT'S REQUEST FOR ADMISSIONS, INTERROGATORIES AND REQUESTS 

FOR PRODUCTION OF DOCUMENTS 
DATED: July IS 2015 

STEVEN L. GRAFF, INC. 

A Professional Law Corporation 

Attorney at law 

43399 Calle De Velardo 

Temecula, CA 92592 

(951) 303-6400 tel 

(800) 839-7777 toll free 

aviationcounsel@aol.com 

Attorney for Respondent 

Pa e 7 

RESPONDENT'S RESPONSE TO COMPLAINANT'S REQUEST FOR ADMISSIONS. INTERROGATORIES AND REQUESTS 

FOR PRODUCTION OF DOCUMENTS 


Curriculum Vitae 

Joshua Chin 

City of Industry, CA 

562-646-7095 josh.chin@net-force.net 

Education 

In Progress California State Polytechnic University, Pomona, California 

2016 Candidate, Master of Science in Business Administration in 

Information Assurance 

2010 College of Business Administration 

California Slate Polytechnic University, Pomona, California 

Degree: Bachelor of Science in Business Administration, 

Major: Computer Information Systems (CIS) 

Major academic courses: Internet Security/Computer Information Systems 

Security Professional, Information Systems Auditing, Network Security, Web 

Applications Security, Computer Forensics 

Relevant Experience 

Managing Partner and Executive Director 

Net Force, City of Industry, CA 

Major Client Projects Include: 

• Internal Penetration Test 

• External Penetration Test 

• Social Engineering Assessment 

• Incident Response 

• Employee Investigation 

• Electronic Discovery Collection and Processing 

• Cisco Network Security 

Director of Operations, Security 

Media Company, City of Industry, CA 

Forensics Examiner and Information Systems Auditor 

Canaudit, Inc, Simi Valley, CA 

Professional Certifications 

May 2012 - Present 

February 2001 - Present 

July 2010- May 2012 

National Security Agency (NSA) Center of Academic Excellence (CAE) 

• NSA NSTISSI 4011: National Training Standard for Information System Security 

Systems Professional 

• NSA CNSSI 4012: National Information Assurance Training Standard for Senior 

Systems Managers 
Teaching Experience 

CyberPatriot Cyber Security Mentor 20 13 - Present 

CyberPatriot VII (2014-2015)- Troy High School, Fullerton, CA 

CyberPatriot VII (2014-2015)- St. Marks Lutheran School, Hacienda Heights, CA 

CyberPatriot VII (20 14-20 15) - Robert F. Kennedy Community Schools, Los Angeles, CA 

CyberPatriot VI (2013-2014)- Troy High School, Fullerton, CA 

National Finalist Team 

- 1 '' Place Digital Crime Scene 

- 2nd Place Cisco Challenge 

- 41

h Place Overall in the Nation 

Cyber Camp Advisor for the US Cyber Challenge 

- 2015- Lead Cyber Camp Advisor for the Illinois State Camp 

- 2014- Lead Cyber Camp Advisor for the Western Regional Camp 

- 2014- Lead Cyber Camp Advisor for the Illinois State Camp 

- 2013- Lead Cyber Camp Advisor for the Western Regional Camp 

- 2012- Lead Cyber Camp Advisor for the Southern California Camp 

- 2012- Cyber Camp Advisor for the Eastern Regional Camp 

- 2011 - Cyber Camp Advisor for the Southern California Camp 

CyberSecurity Day Camp Instructor 

San Jose State University, San Jose, CA 

-Gritting (April 5, 2014) 

-Introduction to Digital Forensics (April 6, 2013) 

Professional Development Lecturer for Canaudit, Inc. Simi Valley, CA 

- IT Audit and Security Bootcamp (December 8-10 201 0) 

-Computer Forensics (October 5-7 2010) 

Guest Lecturer, Cal-Poly Pomona, Pomona, CA 

Forensic and Security Technology Club (FAST) 

- Introduction to Forensics, Security and the Changing Landscape 

- Introduction to Social Engineering 

Presentations and Research Projects 

"Metasploit Kung-Fu" 

20 12 - Present 

U.S. Cyber Challenge- Moraine Valley Community College, Palos Hills, IL (July 2014) 

"Gritting" 

U.S. Cyber Challenge San Jose State University Day Camp, San Jose, CA (April2014) 

"Business Continuity/Disaster Recovery" 

Information Systems Audit and Control Association, Los Angeles, CA (February 2014) 

"Security Operations Center Best Practices" 

Information Systems Audit and Control Association, Los Angeles, CA (January 2014) 

"Information Security Soft Skills -Incident Handling Case Studies" 

Information Systems Audit and Control Association, Los Angeles, CA (December 2013) 
"Changes in Vendor Management and California Data Breach Laws" 

Information Systems Audit and Control Association, Los Angeles, CA [November 20 13) 

"Failure is an Option" 

BSides Security Conference- Orange County, Orange, CA [September 2013) 

"Introduction to Digital Forensics" 

U.S. Cyber Challenge San Jose State University Day Camp, San Jose, CA [April2013) 

"Chief Information Security Officer Forum: Wi-Fi Security Challenges" 

Information Systems Audit and Control Association, Los Angeles, CA [January 2013) 

"Chief Information Security Officer Forum: SSAE16 SOC 2 User's Guide" 

Information Systems Audit and Control Association, Los Angeles, CA [November 2012) 

"Non-Traditional Data Breaches in Social Media" 

2012 High Tech Crimes Investigation Association International Conference, Hershey, PA 

[September 20 12) 

"Face Who? Wiki-What? Yelp Where? Linked-When? Why Space?" 

Brea Olinda High School. Brea, California [April28, 2012) 

Publications and Contributions 

A look ahead: Forecasts for 2014- SC Magazine. [n.d.). Retrieved December 20,2013, 

from http:lfwww .scmagazine .com I a-look-ahead-forecasts-for-2014/ article/320599/ 

Awards 

• 3•d Place Finalist- 2013 Symantec Cyber Readiness Challenge- Summerlin, NV 

• 3•d Place Finalist- 2013 Symantec Cyber Readiness Challenge- Mountain View, 

CA 

• 2nd Place Finalist- 2012 Symantec Cyber Readiness Challenge- Irvine, CA 

• 2nd Place Winner in Capture the Flag Competition- 2010 US Cyber Challenge 

California Cyber Camp 

• 2nd Place in Computer Forensics- 2010 Information Technology Competition 

Professional Associations 

• High Tech Crimes Investigator Association [HTCIA) 

o 2014- 2015- Southern California Chapter Secretary 

o 2013- 2014- Southern California Chapter President 

o 2012- 2013- Southern California Chapter First Vice President 

• Information Systems Audit and Control Association [ISACA Los Angeles) 

o 2013- Present- Vice-Chair, Cybersecurity Interest Group 

• Open Web Application Security Project, Los Angeles [OW ASP-LA) 

• BSides Los Angeles Conference Organizer 

o 2014- Present- BSidesLA Board Member 

• FBI lnfragard, Los Angeles 

• United States Secret Service Los Angeles Electronic Crimes Task Force 
CERTIFICATE OF SERVICE 

I hereby certify that I have this day, placed in the United States mail, postage 

prepaid, a copy of the RESPONDENT'S RESPONSE TO COMPLAINANT'S 

REQUEST FOR ADMISSIONS, INTERROGATORIES AND REQUESTS FOR 

PRODUCTION OF DOCUMENTS addressed to: 

GLENN H. BROWN, ESQ. 

Office of the Regional Counsel 

FEDERAL AVIATION ADMINISTRATION 

222 W. 7TH Avenue #14 

Anchorage, Alaska 99513-7586 

I hereby further certify that I have this day, placed in the United States mail, postage 

prepaid, the original and copy of the RESPONDENT'S RESPONSE TO 

COMPLAINANT'S FIRST REQUEST FOR DISCOVERY addressed to: 

FEDERAL AVIATION ADMINISTRATION 

The Hearing Docket, AGC-430 

Wilber Wright Building - Room 2W1 000 

800 Independence Avenue, S.W. 

Washington, D.C. 20591 

I declare under penalty of perjury under the laws of the state of California that the 

foregoing is true and correct and that this document is executed on Julyli._ 2015 

at Temecula, California. 

Pa e 8 

RESPONDENT'S RESPONSE TO COMPLAINANT'S REQUEST FOR ADMISSIONS, INTERROGATORIES AND REQUESTS 

FOR PRODUCTION OF DOCUMENTS 
July 13, 2015 

43399 Calle De Velardo 

Temecula, CA 92592 

(951) 303-6400 tel.- (951) 303-0723 fax 

Aviationcounsel@aol.com 

FEDERAL AVIATION ADMINISTRATION 

The Hearing Docket, AGC-430 

Wilber Wright Building - Room 2W1 000 

800 Independence Avenue, S.W. 

Washington, D.C. 20591 

Re: FAA adv. MACH ONE AIR CHARTERS, INC. 

FDMS NO.: FAA-2015-0643 

RECEIVED 

JUL 2 0 2015 

HEARING DOCKET 

TRANSMITTAL COVER SHEET 

The enclosed documents are for your file and/or appropriate action.