01/21/2010 14:10 FAX 2024935142 FAA + DMS glOOI/OOB 

RECEIVFn 

SCOTT R.MO.miS " S ^AWM20» 

FAA OFFICE OF REGIONAL COUNSEL HEARJWr^ nnr-i^cr— 

1601LIND AVE, SW ' 11 ^'"^^3 UUL^^ t J 

RENTON, WASHINGTON 98057 

TELEPHONE: 425.227.1417 

FACSIMILE: 425.227.IOO7 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Mailer of: 

Frontier Airlines, Inc. 

FAA DOCKET CP 09NM0013 

FAA Case No. 2009NM210020 

DMS No. FAA-2009-1040 

Judge Goodwin 

COMPLAINANT'S INITIAL DISCOVERY REQUEST 

To: Respondent 

In accordance with 14 CFR Sections 13.220 and the Federal Rules of Civil Procedure, 

please respond to the following Interrogatories, Requests for Production of Documents, and 

Request for AdmLssions, separately and fully under oath by February 5,2010. 

These discovery requests are intended to discover information and/or documents not only 

within your personal knowledge or obtainable by you, but also infomiation in the possession of or 

obtainable by your aliomeys, investigators, representatives, employees, agents, or anyone acting on 

your behalf or on their behalf. 

These discovery requests are continuing in nature and any information which may be 

discovered by you subsequent to the service and filing of your answers must be brought to the 

attention of the agency atiomey through supplemental answers when it becomes available to you, at 

a reasonable time prior to the hearing in this matter. If there are any additions, deletions or changes 

in the answers or information provided at any time prior to hearing the Respondent is specificSly 

requested to so immediately inform the agency attorney. If such information is not furnished, the 

agency attorney at the time of the hearing will move to exclude from evidence such information 

requested and not furnished. 

The agency attorney further requests thai the Respondent produce the documents identified 

and designated herein for inspection and copying at the FAA Office of Regional Counsel, Suite 

570,1601 Lind Avenue, SW, Renton, Washington 98057, by February 5,2010. 

FRJVILEGE 

If, in responding to, or failing to respond to these inteirogatorics, requests for admission and 

requests for production you invoke or rely upon any privilege of any kind, state specifically the 

nature of the privilege; the basis upon v/hich you invoke, rely upon or claim it, including ajiy 
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stattJtory or decisional reference; and identify all documents or other inlbrmaiion, including 

t^ntacts and communicatioi^ which you believe to be embraced by the privilege invoked. 

DATED this 5th day of January 2010. 

I'lTR MORRIS 

- AA Attorney 

Complainant*!; Initial Discovery Request 

Frontier Airlines - CP09NM0013 

Page 2 of6 

ScoTT R. MORKis. FAA ATTORNEY 

TEL: 425.227.1417; FAX: 425,227.1007 
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INTERROGATORIES AND REQUESTS FOR PRODUCl ION 

Interrogatory^ No. 1: Identify by name, address and telephone number all persons whom you know 

to have personal knowledge of the matters alleged in the Complaint. 

Interrogatory No. 2: Identify by title, date, author, present custodian, and content, all documents, 

including correspondence, obtained by you or in your possession, relating to the assertions in the 

Complaint, your appeal, your answer, and any affumativc defenses which you anticipate raising in 

this matter. 

REQUEST FOR PRODUCTION NO. 1: Provide a copy of all documents referred to in your 

answer to the preceding interrogatory. 

Interrogatory No. 3: Identily by name, address and telephone number, ail persons whom you intend 

to have testify as a factual or expert witness in your defense at the hearing in this matter, and for 

factual wimesses, provide a detailed summaiy of each persons anticipated testimony. 

Interrogatory No. 4: Identily by title, date, author, present custodian, and content, all documenis 

which you anticipate offering into evidence at the hearing in this matter, and through which witness 

or wimesses. 

REQUEST FOR PRODUCTION NO. 2: Provide a copy of all documents referred to in your 

answer to the preceding interrogatory. 

Interrogatory No. S: With respect to each expert witness identified in response to Inieirogatory No. 

3, above, specify their specific area of expertise, and provide a synopsis of their credentials, 

background, training and experience. 

InteiTogatorv No. 6: With respect to each expert you expect to call as a wimess, state the subject 

matter on which the expert is expected to testify, and state the substance of the facts and opinions to 

which the expert is expected to testify, and a summary of the groimds for each such opinion. 

Interrogatoiv No. 7: State by name, address, telephone number, date of conversation, and substance 

of conversation, all persons [other than legal counsel or spouse] with whom you have discussed the 

matters alleged in the Complaint. 

Interrogatory No. 8: Describe with specificity all of the facte which you anticipate presenting in the 

course of the hearing in this matter pertaining to the avoidance or mitigation of the sanction sought 

by the FAA in this case. 

Interrogatory No. 9: Describe with specificity any and all alTirmative defenses you intend to assert 

and who are you oITering as witnesses in support of these defenses? Provide the name and address 

of said witnesses. 

REQUEST FOR PRODUCTION No. 3: Provide a copy of all documents refeired to in your 

answer to the preceding two interrogatories. 

Interrogatory |^lo. 10: Describe with specificity all of the documents you anticipate presenting in 

the course of the hearing in this matter to substantiate any financial inability to pay the proposed 

sanction sought by the FAA in this case. 

Comploinanrs Initial Discovery Request 

Fronlicr Airlines - CP09NM0013 

Page 3 of6 

SCOTTR. MORRIS, FAA ATTORNEY 

TEL: 425.227.1417: FAX; 425.227.1007 
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REQUEST FOR PRODUCTION NO. 4: Provide a copy of all Exhibits that you will present 

during the hearing in this matter. 

Interrogatory 11: Describe with specificity what facts or evidence Frontier relies upon in support of 

any aflirmative defenses raised in its Answer to the Amended Complaint 

REQUEST FOR PRODUCTION NO. 5: Provide a copy of all documents that support your 

response to Interrogatory No. 11 above, 

REQUEST FOR PRODUCTION NO. 6: Provide a copy of any preliminary and/or final report 

received by Frontier from Millionaire Air concerning the maintenance performed that is the subject 

of the Complaint. 

fnterrogaiorv 12: Describe with specificity what facts, documents, or other evidence Frontier relies 

upon to deny Paragraph 4 of the Complaint as slated in its Answer. 

Interrogatory 13: Describe with specificity what facts, documents, or other evidence Frontier relies 

upon to deny Paragraph 9 of the Complaint as stated in its Answer. 

REQUEST FOR PRODUCTION NO. 7: Provide a copy of all documents that support your 

response to Interrogatory No. 13 above. 

Interrogatory 14: Describe with specificity what facts, documents, or other evidence Frontier relies 

upon to deny Paragraph 12 of the Complaint as stated in its Answer. 

REQUEST FOR PRODUCTION NO. 8: Provide a copy of all documents that support your 

response to Interrogatory No. 14 above. 

Interropatoryl5: Describe with specificity what facts, documents, or other evidence Frontier relies 

upon to deny Paragraph 13 of the Complaint as stated in its Answer. 

REQUEST FOR PRODUCTION NO. 9: Provide a copy of all documents that support your 

response to Interrogatory No. 15 above. 

Interrogatory 16: Describe with specificity what facts, documenis, or other evidence Frontier relies 

upon to deny Paragraph 15 of the Complamt as staled in its Answer. 

REQUEST FOR PRODUCTION NO. 10: Provide a copy of all documents that support your 

response to Interrogatory No. 16 above. 

Complainant's Initial Discoveiy Request 

Frontier Airlines-CP09NM0013 

Page 4 of6 

SCOTT R. MOWtfS. FAA ATTORNEY 

TEL: 425.227.1417; FAX: 425,227.1007 
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REQUEST FOR ADMISSIONS 

Under 14 C.F.R. 13.220(b) and Rule 36 of the Federal Rules of Civil Procedure, you are requested 

to admit the truth of the following matters. A matter is admitted unless responded to in a 

reasonable time. The Rules of Practice in FAA Civil Penalty Actions, 14 C.F.R. 13.220(d), defmes 

a reasonable time to be 30 days. The agency requests tliat an answer is served upon the agency 

attorney either admitting the matter, specifically denying the matter, stating why the matter cannot 

be admitted or denied, or objecting to the request, wiih reasons for the objection stated within 30 

days of the date of service upon you, to wit: February 5,2010. 

REQUEST FOR ADMISSION NO 1: Admit ihat in Fiscal Year 2009 Frontier had operating 

revenues in excess of $100,000,000. 

REQUEST FOR ADMISSION NO 2: Admit that in Fiscal Year 2008 Frontier had operating 

revenues in excess of $100,000,000. 

REQUEST FOR ADMISSION NO. 3: Admit thai Frontier Airlines employs more than 1500 

employees. 

REQUEST FOR ADMISSION NO. 4: Admit that Frontier Airlines has the financial shility to pay 

the $350,000 requested civil penally. 

REQUEST FOR ADMISSION NO. 5: Admit that Frontier Airiines General Maintenance Manual, 

section 30.05, dated 12/31/07, was in effect on October 28 and 29,2008. 

Complainant's Initial Discovery Request 

Frontier Airlines - CP09NM0013 

Page 5 of6 

ScoTT B. MORRIS, FA A ATTORNEY 

TEL: 425.227.1417; FAX: 425.227.1007 
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CERTIFICATE OF SERVICE 

I hereby certify that the foregoing Complainant's Initial Discovery Request has been served via 

facsimile and certified mail - Return Receipt Requested this date, to the following: 

The Honorable Richard C. Goodwin 

Office of hearings, M-20 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor, Rm El 2-320 

Washington, D.C. 20590 

TEL: 202.366.2139 

FAX: 202.366.7536 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, D.C. 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building - Suite 2W1000 

FAX: 202.493.5020 

Jennifer E. irock, Esq. 

Pillsbury Winlhrop Shaw Pittman, LLP 

2300 N Street, NW 

Washington,DC. 20037-1122 

TEL: 202.663.8000 

FAX: 202.663.8007 

Dated this 5th day of January, 2010. 

<^tW^ Sl>\JBUJrN^ 

SHERI BROWN 

Office of Regional Counsel (ANM^T) 

Federal Aviation Administration 

1601 Lind Ave, SW 

Renton, WA 98057 

425.227.2925 

Complainant's Initial Discovery Request 

Frontier Airlines - CP09NM0013 

Page 6 of 6 

ScoTT R, MORRIS, FA A AnoiiNEY 

TEL; 425.227.1417; FAX: 425-227.1007