U.S. DEPARTMENT OF TRANSPORTATION 

Office of Hearings 

Washington, D. C. 

The Liberty Foundation, Inc. 

FAA DOCKET NO. 2012-0477 

(EIR 2011-GL-03-0070) 

(Civil Penalty Action) 

Hon. J. E. Sullivan, Administrative Law Judge 

RECEIVED 

NOV 0 5 2013 

HEARING DOCKET 

RESPONDENT'S MOTION TO STRIKE COMPLAINANT'S OBJECTIONS 

TO RESPONDENT'S LIMITED DISCOVERY REQUESTS 

Respondent, The Liberty Foundation, Inc. (Liberty), by and through its 

undersigned attorney, respectfully moves the Court for the entry of an order striking 

Complainant's objections to Respondent's limited discovery related to Respondent's 

Amendment To Complaint. In support of its Motion, Respondent shows: 

1. Pursuant to the Court's Order served August 27, 2013 ("Order"), 

Respondent propounded both Interrogatories and Requests For Production to 

Complainant limited to the issues raised in Complainant's Amendment To Complaint. 

Attached hereto as Composite Exhibit A and made a part hereof are Respondent's 

Interrogatories and Requests For Production limited to the issues raised in 

Complainant's Amendment To Complaint. The Interrogatories and Requests for 

Production were served on Complainant's counsel by facsimile and regular U.S. Mail on 

September 11, 2013, and received by facsimile on that same date. Attached hereto as 

Exhibit B and made a part hereof are the facsimile confirmation showing delivery of 

STUART A GOLDSTEIN, P A. 

7300 North Kendall Drive, Suite380, Miami,FL 33156 

T: (305) 670-1222 F: {305) 400-0685 EMAIL: STlJARTGOLDSTEINPA@ATT.NET 
2 

Respondent's limited discovery requests to Complainant's fax machine on September 

11, 2013, as well as the envelope in which the discovery requests were mailed. 

2. Paragraph 6 of the Order requires that "any objection(s) or motions 

regarding additional discovery shall be filed within ten (1 0) days after receipt." 

Emphasis in the original. Complainant's "Response To Limited Discovery Requests" 

was served on October 17, 2013 (by mail only and not received by Respondent's 

undersigned counsel until October 22, 2013). Attached hereto as Exhibit C and made 

a part hereof is Complainant's Response To Limited Discovery Requests. Complainant 

never communicated with undersigned counsel to request additional time to respond to 

the limited discovery requests. 

3. Pursuant to Paragraph 6 of the Order, Complainant's objections to 

Respondent's limited Interrogatories and Requests For Production were required by no 

later than September 23, 2013. Therefore, Complainant's objections were made 

twenty-four days (24) late. Although the government shutdown accounts for some of 

this time, the government shutdown did not occur until eight (8) days after the due date 

for any objections. 

WHEREFORE, Respondent respectfully moves for the entry of an Order striking 

Complainant's objections to Respondent's Interrogatories and Requests For Production 

limited to the issues raised in the Amendment To Complaint. 

STUART A. GOLDSTEIN, P. A 

7300 North Kendall Drive, Suite 380, Miami,FL 33156 

T: (305) 670-1222 F: (305) 400-0685 EMAIL: .SI.\.J..6_RTGOLDSTEIN_f'A@ATT NET 
Respectfully submitted, 

STUART A. GOLDSTEIN, P. A. 

7300 North Kendall Drive, Suite 380 

Miami, FL 33156 

Tel: (305) 670-1222 

Fax: (305) 670-7065 

Email: stuartgoldsteinpa@att.net 

) 

L-A A Jl)l ;j /J <L 

By: "J !Jilt!! ({"'.Lit"~' J:p,=l-=- S'tuart A. Goldstein 

Attorney for Respondent 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that the foregoing has been served on this 

October, 2013, as set forth below: 

Christopher R. Stevenson, Esq. 

Office of the Regional Counsel 

Federal Aviation Administration 

P. 0. Box 20636 

Atlanta, GA 30320 

By Facsimile (404) 305-5223 

and regular U. S. Mail 

and that an original and one copy was served upon: 

Hearing Docket Clerk, AGC-430 

Wilbur Wright Building, Suite 2W1000 

Federal Aviation Administration 

800 Independence Avenue, S. W. 

Washington, D. C. 20591 

STUART A GOLDSTEIN, P. A. 

7300 North Kendall Drive, Suite 380, Miami,Fl 33156 

T: (305) 670-1222 F: {305) 400-0685 EMAIL: STUARTGOLDSTEINPAiillATT NET 

3 
and that a copy was served upon: 

Honorable J. E. Sullivan 

Office of Hearings, M-20 

U. S. Department of Transportation 

1200 New Jersey Avenue, S. E. (E11-310) 

Washington, D. C. 20590 

By Facsimile: (202) 366-7536 

and regular U. S. Mail 

STUART A. GOLDSTEIN, P. A. 

7300 North Kendall Drive, Suite 380, Miami,FL 33156 

T: {305) 670-1222 F: (305) 400-0685 EMAIL: STliARTGOLDSTE!Nf'A@..i!J.lb!EI 

4 
U.S. DEPARTMENT OF TRANSPORTATION 

Office of Hearings 

Washington, D. C. 

The Liberty Foundation, Inc. 

FAA DOCKET NO. 2012-0477 

(EIR 2011-GL-03-0070) 

(Civil Penalty Action) 

Hon. J. E. Sullivan, Administrative Law Judge 

RESPONDENT'S INTERROGATORIES RELATED TO 

FAA'S AMENDMENT TO COMPLAINT 

The following interrogatories are related to the Complainant's Amendment To 

Complaint dated July 31, 2013. 

INSTRUCTIONS AND DEFINITIONS 

The words "document" and "exhibit" mean every manner of document in 

whatever media including, but not limited to, electronically stored documents, and 

includes without limitation, all tangible items and papers, whether printed, recorded, 

visually reproduced, or reproduced by an other mechanical process, written or produced 

by hand, or maintained as part of any electronic or computer database, including: 

affidavits, agreements, bills, cartoons, checks, communications, contracts and other 

official documents, correspondence, emails, drawings, files, invoices, photographs, 

receipts, sketches, test results, published materials of any kind, telegrams, ledgers, 

memoranda, orders, audio or video recordings, statements, notes, summaries or 

records of telephone conversations, summaries or records of personal conversations or 

STUART A. GOLDSTEIN, P. A 

7300 North Kendall Drive, Suita380, Miami, FL 33156 

T· (305) 670-1222 F (305)400·0665 SJUARTGOI PSI.f.lHE...Jl..@.6JI.NEI A 
2 

interviews, diaries, calendars, reports, notebooks, charts, graphs, summaries or records 

of meetings or conferences, summaries or reports of investigations or negotiations, 

drafts, letters, any marginal comments or notes appearing on any documents an any 

and all other writings and data compilations. 

The words "identify" and "identity" when related to a person mean to list the 

person's name, address, telephone number, employer, and position of employment. 

When related to a document or exhibit, they mean to describe the document with 

sufficient specificity and the applicable page(s} thereof. 

To the extent a claim of privilege is made, please identify the privilege and the 

specific reasons you believe it applies. 

INTERROGATORIES 

1. With regard to new paragraph 7(b), which alleges: "The aluminum fuel tanks 

fabricated and installed in N390TH in February, 2011 by Mr. Schneider rendered the 

aircraft unsafe for flight and unairworthy": 

A. Identify which witness(es) will testify as to this allegation. 

B. As to each witness identified in answer to Interrogatory 1 A, state whether 

such witness will testify as a fact witness, an expert witness, or both. 

C. As to each witness identified as an expert witness, in whole or in part, 

provide the information required by Rules 26(a)(1 ), 26(a)(2)(A), and 26(a)(2)B) 

(including all of its subparts), Fed. R. Civ. P. 

D. As to each witness identified as a fact witness, in whole or in part, specify 

in detail the expected testimony of such witness in support of the allegations of new 

paragraph 7(b). 

STUART A. GOLDSTEIN, P. A 

7300 North Kendall Drive, Suite 380, Miami,Fl 33156 

T_ {305) 670.1222 F· (305) 400"06B5 EMAIL STUARIGOLDSJEINPA®ATTNET 
3 

E. As to each witness identified in answer to Interrogatory 1 A, identify 

precisely which exhibit{s) that witness referred to or relied upon as a basis for his/her 

expected testimony. 

2. With regard to new paragraph 16{a), which alleges: "Mr. Schneider did not make 

a maintenance record entry concerning the June 13, 2011, maintenance before 

returning the aircraft to service": 

A. Identify which witness{es) will testify as to this allegation. 

B. As to each witness identified in answer to Interrogatory 2A, state whether 

such witness will testify as a fact witness, an expert witness, or both. 

C. As to each witness identified as an expert witness, in whole or in part, 

provide the information required by Rule 26{a){1 ), 26{a){2){A), and 26{a){2)B) {including 

all of its subparts), Fed. R. Civ. P. 

D. As to each witness identified as a fact witness, in whole or in part, specify 

in detail the expected testimony of such witness in support of the allegations of new 

paragraph 16{a). 

E. As to each witness identified in answer to Interrogatory 2A, identify 

precisely which exhibit{s) that witness referred to or relied upon in his/her expected 

testimony. 

3. With regard to new paragraph S{a), which alleges: "When Mr. Schneider replaced 

the bladder fuel tanks with the fabricated aluminum tanks, he failed to use the methods, 

techniques, and practices prescribed in the current manufacturer's maintenance manual 

or instructions for Continued Airworthiness prepared by its manufacturer, or other 

methods, techniques, and practices acceptable to the Administrator": 

STUART A GOLDSTEIN, P. A. 

7300 North Kendall Drive, Suite 380. Mlaml,FL 33156 

T (305) 670-1222 F· (305) 400·0685 EMAIL· SIUARIGOl QSTEINPA@ATTNEI 
4 

A. Identify which witness(es) will testify as to this allegation. 

B. As to each witness identified in answer to Interrogatory 3A, state whether 

such witness will testify as a fact witness, an expert witness, or both. 

C. As to each witness identified as an expert witness, in whole or in part, 

provide the information required by Rule 26(a)(1 ), 26(a)(2)(A), and 26(a)(2)B) (including 

all of its subparts), Fed. R. Civ. P. 

D. As to each witness identified as a fact witness, in whole or in part, specify 

in detail the expected testimony of such witness in support of the allegations of new 

paragraph 5(a). 

E. As to each witness identified in answer to Interrogatory 3A, identify 

precisely which exhibit(s) that witness referred to or relied upon in his/her expected 

testimony. 

4. With regard to new paragraph 5(b), which alleges: "When Mr. Schneider replaced 

the bladder fuel tanks with the fabricated aluminum tanks, he failed to do the work in 

such a manner and use the materials of such a quality that the condition of the aircraft 

was restored to its original or properly altered condition": 

A. Identify which witness(es) will testify as to this allegation. 

B. As to each witness identified in answer to Interrogatory 4A, state whether 

such witness will testify as a fact witness, an expert witness, or both. 

C. As to each witness identified as an expert witness, in whole or in part, 

provide the information required by Rules 26(a)(1 ), 26(a)(2)(A), and 26(a)(2)B) 

(including all of its subparts), Fed. R. Civ. P. 

STUART A GOLDSTEIN, P. A 

7300 North Kendall Onve. SUite 380, Miamt,FL 33156 

T (305) 670-1222 F (305) 40()..0695 EMAIL. STUARTGOlDSTEINPA@AT! NET 
5 

D. As to each witness identified as a fact witness, in whole or in part, specify 

in detail the expected testimony of such witness in support of the allegations of new 

paragraph 5(b). 

E. As to each witness identified in answer to Interrogatory 4A, identify 

precisely which exhibits that witness referred to or relied upon in his/her expected 

testimony. 

5. With regard to new paragraph 18, which alleges: "On January 31, 2012, a finding 

of violation of sections 43.9(a), 43.9(d), 43.13(a), 43.13(b) of the Federal Aviation 

Regulations was entered against Mr. Schneider arising out of the above-described 

circumstances. In addition to being directly liable for violations of the Federal Aviation 

Regulations enumerated below, The Liberty Foundation is vicariously liable for the 

violations of Mr. Schneider, it's [sic] Director of Maintenance, which are detailed in the 

January 31, 2012, Order of Suspension, a copy of which is attached and incorporated 

by reference": 

A. Identify which witness(es) will testify as to this allegation. 

B. As to each witness identified in answer to Interrogatory 5A, state whether 

such witness will testify as a fact witness, an expert witness, or both. 

C. As to each witness identified as an expert witness, in whole or in part, 

provide the information required by Rules 26(a)(1 ), 26(a)(2)(A), and 26(a)(2)B) 

(including all of its subparts), Fed. R. Civ. P. 

D. As to each witness identified as a fact witness, in whole or in part, specify 

in detail the expected testimony of such witness in support of the allegations of new 

paragraph 18. 

STUART A. GOLDSTEIN, p_ A. 

7300 North Kendall Drive, Suite 380, Miami,FL 33156 

T" (305) 670·1222 F- (305) 4Q0-0685 EMAIL: SIUARTGO! OSIEINPA®AII NET 
6 

E. As to each witness identified in answer to Interrogatory SA, identify 

precisely which exhibits that witness referred to or relied upon in his/her expected 

testimony. 

6. With regard to the allegation that Respondent violated 14 CFR 43.13(a), state 

with specificity the "methods, techniques, and practices prescribed in the current 

manufacturer's maintenance manual or Instructions for Continued Airworthiness" that 

Respondent did not follow or adhere to for the work performed in February, 2011. The 

answer to this Interrogatory should include the identity of all documents upon which the 

answer is based. 

7. With regard to the allegation that Respondent violated 14 CFR 43.13(a), state 

with specificity the "methods, techniques, and practices prescribed in the current 

manufacturer's maintenance manual or Instructions for Continued Airworthiness" that 

Respondent did not follow or adhere to for the work performed in June, 2011. The 

answer to this Interrogatory should include the identity of all documents upon which the 

answer is based. 

8. With regard to the allegation that Respondent violated 14 CFR 43.13(a), state 

with specificity what tools, equipment, and test apparatus Respondent did not use but 

should have used in connection with the work performed in February, 2011. The answer 

to this Interrogatory should include the identity of all documents upon which the answer 

is based. 

9. With regard to the allegation that Respondent violated 14 CFR 43.13(a), state 

with specificity what tools, equipment, and test apparatus Respondent did not use but 

STUART A. GOLDSTEIN, P, A. 

7300 North Kendall Dnve. Suite 380, Miami,FL 33156 

T (305) 670·1222 F (305) 4Q0-0685 EMAIL· STUARIGOl QSTE!NPA®ATT NET 
7 

should have used in connection with the work performed in June, 2011. The answer to 

this Interrogatory should the identity of all documents upon which the answer is based. 

1 o. With regard to the allegation that Respondent violated 14 CFR 43.13(b), state 

with specificity the fact bases for the allegation that N390TH was not in a condition at 

least equal to its original or properly altered condition with regard to aerodynamic 

function, structural strength, resistance to vibration and deterioration, and/or other 

qualities affecting airworthiness, after the work performed in February, 2011. The 

answer to this Interrogatory should include the identity all documents upon which the 

answer is based. 

11. With regard to the allegation that Respondent violated 14 CFR 43.13(b), state 

with specificity the fact bases for the allegation that N390TH was not in a condition at 

least equal to its original or properly altered condition with regard to aerodynamic 

function, structural strength, resistance to vibration and deterioration, and/or other 

qualities affecting airworthiness, after the work performed in June, 2011. The answer to 

this Interrogatory should include the identity all documents upon which the answer is 

based. 

STUART A. GOLDSTEIN, P A. 

7300 North Kendall Dnve, Surte 380, Miam1,FL 33'156 

T (305) 670·1222 F (305) 400·0685 EMAIL STUARTGOLDSTEINPA@ATT NET 
8 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that the foregoing has been served on this I f:Jh day of 

September, 2013, as set forth below: 

Christopher R. Stevenson, Esq. 

Office of the Regional Counsel 

Federal Aviation Administration 

P. 0. Box 20636 

Atlanta, GA 30320 

By Facsimile (404) 305-5223 

and regular U. S. Mail 

STUART A. GOLDSTEIN, P. A. 

7300 North Kendall Drive, Suite 380 

Miami, FL 33156 

Tel: (305) 670-1222 

Fax: (305) 400-0685 

Email: stuartgoldsteinpa@att.net 

By:~ tiktd;: 

Stuart A. Goldstein 

Attorney For Respondent 

STUART A GOLDSTEIN, P. A 

7300 North Kendall DriVe, Suite 380. M1am1,FL 33156 

T_ (305) 670-1222 F: (305) 400-0685 EMAIL· SI!JARTGO! Q$TE!NpA®ATTNET 
U.S. DEPARTMENT OF TRANSPORTATION 

Office of Hearings 

Washington, D. C. 

The Liberty Foundation, Inc. 

FAA DOCKET NO. 2012·0477 

(EIR 2011-GL-03-0070) 

(Civil Penalty Action) 

Hon. J. E. Sullivan, Administrative Law Judge 

RESPONDENT'S REQUEST FOR PRODUCTION RELATED TO 

FAA'S AMENDMENT TO COMPLAINT 

INSTRUCTIONS AND DEFINITIONS 

The words "document" and "exhibit" mean every manner of document in 

whatever media including, but not limited to, electronically stored documents, and 

includes without limitation, all tangible items and papers, whether printed, recorded, 

visually reproduced, or reproduced by an other mechanical process, written or produced 

by hand, or maintained as part of any electronic or computer database, including: 

affidavits, agreements, bills, cartoons, checks, communications, contracts and other 

official documents, correspondence, emails, drawings, files, invoices, photographs, 

receipts, sketches, test results, published materials of any kind, telegrams, ledgers, 

memoranda, orders, audio or video recordings, statements, notes, summaries or 

records of telephone conversations, summaries or records of personal conversations or 

interviews, diaries, calendars, reports, notebooks, charts, graphs, summaries or records 

of meetings or conferences, summaries or reports of investigations or negotiations, 

STUART A GOLDSTEIN, P. A. 

7300 NoJ1h Kendall Drive, Su~e380 M1aml, FL 33155 

T (305) 670-1222 F- {305} 400-0685 SI\JAR!GO! DSTEINPAIWATINEI 
2 

drafts, letters, any marginal comments or notes appearing on any documents an any 

and all other writings and data compilations. 

The documents produced in response to this Request For Production should be 

labeled or tagged so that Respondent's attorney will know to which Request the 

produced documents relate. 

To the extent a claim of privilege is made, please identify the privilege and the 

specific reasons you believe it applies. 

DOCUMENTS TO BE PRODUCED 

1. Unless previously provided, produce a copy of each document or exhibit referred 

to in your answers to Respondent's Interrogatories Related To FAA's Amendment To 

Complaint. 

2. Unless included in your response to Document Request No. 1, produce a copy of 

all documents or exhibits which the FAA will utilize to attempt to prove Respondent is 

vicariously responsible for the conduct and/or knowledge of Rodney Schneider. 

3. Produce all documents recovered by FAA or NTSB from N390TH that have not 

been previously produced that support or relate to the charges in the Amendment To 

Complaint. 

STUART A GOLDSTEIN, P A 

7300 North Kendall Drive, Suite 380. Miami, FL 33156 

T: (305) 670-1222 F (305)400-0685 $TIIARTGOLpSTEINPA@AI~ 
3 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that the foregoing has been served on this ~day of 

September, 2013, as set forth below: 

Christopher R. Stevenson, Esq. 

Office of the Regional Counsel 

Federal Aviation Administration 

P. 0. Box 20636 

Atlanta, GA 30320 

By Facsimile (404) 305-5223 

and regular U. S. Mail 

STUART A. GOLDSTEIN, P. A. 

7300 North Kendall Drive, Suite 380 

Miami, FL 33156 

Tel: (305) 670-1222 

Fax: (305) 400-0685 

Email: stuartgoldsteinpa@att.net 

{ 

sy: A ~a Jktci: ', Stuart A. Goldstein 

Attorney For Respondent 

STUART A GOLDSTEiN, P. A 

7300 North Kendall Drive, Suite 380, M!am1, FL 3315fi 

T: (305) 670-1222 F {305) 400-0685 SJJ..1ABIUQ.I.QSllillf'.&J!'_8Il.t!fl 
Print 

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To: stuartgoldsteinpa@att.net; 

Date: Wednesday, September 11, 2013 4:03PM 

Dear Stuart A. Goldstein, 

Re: UNKNOWN 

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STUART A. GOLDSTEIN, P.A. 

731lONORTH KE'JD•\LL DRIVF. SUITE 3RO 

\!lAM!. FtORIDA 3315fi 

\ 

'''111111111'1· I' I',,,, II'' ''·1'11'1'111111''1' •.• ,,,, ,,,,,,1·1'' 

Christopher R. Stevenson, Esq 

Federal Aviation Administration 

PO Box 20636 

Atlanta GA 30320-0636 

I US POSTAGE $0.86!!~· • g) ~ FIRST -CLASS g 

FROM 33156 • !!! 

09/1112013 ~ 

stan'R!! 1 .. c: .ron 
U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

FEDERAL AVIATION ADMINISTRATION, 

Complainant, 

o~©~OW!Efm 

~ OCT 2·2 2013 ~ 

By 

vs. 

Docket No. FAA-2012-0477 

FAA Case No. 2011GL030070 

LIBERTY FOUNDATION, 

Respondent. Judge Sullivan 

FAA'S RESPONSE TO LIMITED DISCOVERY REQUESTS 

Requests for Production 

1. No documents were referred to. 

2-3. Objection. As noted in the Judge's Order authorizing additional discovery, the FAA has 

already produced all documents sought by these discovery requests, and this discovery request is 

unduly burdensome to the extent that it seeks reproduction of such documents, which have 

previously been identified and provided during the first round of discovery, in the Amendment to 

the Complaint, in the FAA's response to the motion seeking reopening of discovery, and in the 

FAA's summary judgment motion. 

Interrogatories 

1-!>. Objection. As noted in the Judge's Order authorizing additional discovery, the FAA has 

already identifio;d all witnesses sought hy these discovery requests, and this discovery request is 

unduly btudcn~ome to the extent that it seeks repetitive identification of these wimesso;~. who 

have previously been identified during the first round of discovery, in the Amendment to the 

Complaint, in the FAA's response to the motion seeking reopening of discovery, and in the 

FAA's summary judgment motion. 

6. As already admitted by the Respondent's and its then-Director ofMaintenan~:e during 

this litigation, there are no such methods, techniques, and practices with which the Respondent 

could have followed. 

7. As already admined by the Respondent and it's then-Director of Maintenance testified in 

his deposition, there are no such methods, techniques, and practices with which the Respondent 

could have followed. 

c 
8-9. Objection. The Amended Complaint made no factual allegation concerning these topics. 

Accordingly, these interrogatories are beyond the scope of discovery for this limited discovery 

period. 

I 0-11. As explained in the FAA's summary judgment motion and attachments, the use of 

heavily welded aluminum shells as fuel tanks made the aircraft vulnerable to vibrational and 

flight stresses in ways that an original or properly altered fuel tank would not have been, as 

emphasized by the brisk failure of the welding in one ofthe fuel tanks. 

Submitted this {'"f:ay of October, 2013. 

CHRISTOPHER R. STEVENSON 

Attorney 

Office of the Regional Counsel 

CERTIFICATE OF SERVICE 

I hereby certifY that the foregoing FAA's Response to Limited Discovery was sent 

one copy via certified mail to: 

Stuart A. Goldstein, P .A. 

7300 North Kendall Dr., Suite 380 

Miami, FL 33156 

Facsimile: (305) 670-7065 

~as Program Analyst 

Office of the Regional Counsel 

CCI. , ..... 

Dated