/ 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

RE( SIVED 

APR - 6 m ^ 

[ .BARING DOCKET 

RANDY BABBETT, ADMINISTRATOR, 

FEDERAL AVIATION ADMINISTRATION), 

Complainant, 

vs. 

HI-FLI AVIATION TOO LLC, 

Respondent. 

FAACaseNo. 2009SO130017 

RESPONDENT'S REQUEST 

FOR PRODUCTION TO 

THE COMPLAINANT 

C3 

- - 0 

O 

TO: RANDY BABBETT, ADMINISTRATOR and ROBERT B. DIXON, ESQUIRE, 

ATTORNEY FOR THE COMPLAINANT 

Respondent, above named, pursuant to 49 CFR 821.19 and Rule 34 of the Federal Rules 

of Civil Procedures, hereby serves the following Requests for Production on the Complainant, 

Randy Babbett (the "Administrator"): 

1. Any and all documents in your care, custody and control which pertain to the 

matters set forth in the Final Notice of Proposed Civil Penalty dated February 12,2010. 

2. Any and all documents upon which you plan to rely at an Administrative Hearing 

pertaining to this matter. 

3. Any and all documents contained in the EIR file pertaining to Hi-Fli Aviation 

Too, LLC ("Hi-Fli"). 

4. Any and all documents evidencing any wrongdoing by Hi-Fli. 
5. Any and all documents which support your contention that Hi-Fli was the 

operator of N843RM, or flights alleged in the Complaint. 

6. Any and all documents which support yoxir contention that Hi-Fli utilized the 

services of Tobin Williamson as pilot in command. 

7. Any an all documents which support your contentions raised in paragraph 7 of the 

Complaint that "Mr. Williamson had not passed a written or oral test, a competency check, or a 

flight check .. . as required under Part 135 of the Federal Aviation Regulations." 

8. Any and all documents which support the contention raised in paragraph 8 that 

the Federal Aviation Regulations required the Respondent to have an air carrier certificate issued 

to it. 

9. Any and all documents which support the contention that any flight relevant 

herein was careless and/or reckless. 

10. Any and all correspondence (including emails, memos, phone logs, etc.) between 

the FAA Columbia FSDO and other FAA persormel, any witnesses, or third parties regarding 

this case. 

11. Copies of any and all correspondence and communications, to include records of 

any and all telephone conversations, between anyone working at or for the Federal Aviation 

Administration, including, but not limited to, inspectors of the FAA Columbia FSDO and any 

third parties. 

12. Any and all documents referred to in Petitioner's Answers to Respondent's 

Interrogatories served concurrently herewith. 
13. Any and all photographs or digital images taken by any personnel of the FAA in 

connection with the investigation which is the subject of this action. 

Columbia, South Carolina 

April 1,2010 

,PA 

lodge 

1889 

n Main Street, 22"'' Floor (29201) 

Columbia, SC 29211-1889 

803-779-3080 

803-765-1243 (fax) 

jhodge@hsblawfirm.com 

ATTORNEYS FOR THE RESPONDENT 
U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

RANDY BABBETT, ADMINISTRATOR, 

FEDERAL AVIATION ADMINISTRATION) 

Complainant, 

vs. 

HI-FLI AVIATION TOO LLC, 

Respondent. 

FAACaseNo. 2009SO130017 

CERTIFICATE OF SERVICE 

I, the undersigned employee of Haynsworth Sinkler Boyd, P.A., do hereby certify that I 

have caused the foregoing to be served via U.S. mail, postage prepaid, or by other delivery as 

indicated, to all parties of record at the addresses shown below. 

1. Respondent's Request for Production to the 

Complainant 

Parties of Record 

Hearing Docket Clerk 

FAA, AGC-430, Suite 2W1000 

Wilbur Wright Building 

800 Independence Avenue, SW 

Washington, DC 20591 

(Orig. + 3 copies) 

Robert B. Dixon, Esquire 

Federal Aviation Administration 

Office of the Regional Counsel - ASO-7 

P.O. Box 20636 

Atlanta, GA 30320 

Date: April 1,2010 

HAYNSWORTH SINKLER BOYD, P.A. 

By: L&u^,^^^ Ui^^^^Ct/<~^ -s^c^^^ 

Elaine C. Smith-Foster 

Legal Secretary 

Columbia: 1331191 v.l