UNITED STATES DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C: 

RECEIVED 

IN THE MATTER OF: DOCKET NO. FAA-2011-1125 MAR 21_ 2012 

H.EAR.fNG oo· CKET 

ELITE AIR, INC., FAA NO. 201080150236 . 

Respondent, Judge JE Sullivan, 

________________________________________ / 

RESPONDENT'S FIRST DISCOVERY REQUESTS 

Pursuant to the provisions of 14 CFR§ 13.220 and Fed.R.Civ.P 36-36, please responds to 

the following Interrogatories, Requests For Production of Documents, and Requests for 

Admission separately and under oath by April13, 2012, per the Order Setting Litigation Dates 

and Procedures. 

The Defendant should answer this request in the manner directed by the Rules of Civil 

Procedure. Matters will be deemed admitted unless specific objections or denials are filed in the 

manner set forth by the Rules of Civil Procedure. If Defendant can admit only part of the matter 

upon which the admission is requested, Defendant shall specifY as much of it as is true and shall 

quality or deny the remainder. 

Each interrogatory shall be answered separately and fully in writing under oath, unless it is 

objected to, in which event the reasons for objection shall be stated in lieu of an answer. 

You may respond to the request for production by producing true and accurate copies of the 

originals to the undersigned. If you refuse to produce any docu7ments or other evidence on the 

basis of privilege or other objection, identify specifically the items withheld from production. 
Each response shall be continuing m nature so as to requrre you to file supplemental 

responses in the following circumstances: 

a. When you become aware of a fact or the identity and location of any document that is not 

identified in your original response; 

b. When your initial response was initially correct, but subsequently rendered incorrect or 

inaccurate based upon information discovered after the original response is prepared 

If you answer to any interrogatory is "n/a" or "Not Applicable", describe in detail your 

reasons for making such reply. In reply to any interrogatory, do not merely state, "see attached 

records" unless you have no additional memory of the matters referred to in the interrogatory. If 

you have any additional memory of the relevant events, describe it in detail. 

DEFINITIONS 

"Documents" include, without limitation, notes, memoranda, invoices, work orders, receipts, 

reports, letters, audio and video tapes, photographs, facsimiles, transcripts, written statements, 

records of conversations, computer disks or tapes, emails, and other tangible or intangible 

materials. 

"You" or "Your" refers to Complainant. 

"Identify" when referring to persons, reqmres you to provide the full name, address, 

telephone number, and any other information pertinent to locating such person. When pertaining 

to an object or place, "identify" means to provide the name, location or other description of such 

object or place. 

"This matter" refers to the events and circumstances underlying the allegations set forth in 

the Complaint, including amendments and other additions to the Complaint. 
REQUESTS FOR ADMISSIONS 

1. Admit that the crew of N444CW performed a complete pre-flight inspection of the 

aircraft prior to flying on each of the dates at issue. 

2. Admit that part of the pre-flight inspection determined that they would not overfly any 

maintenance item during the course plan of the flight. 

3. Admit that no maintenance inspection was overflown during the course of any flight at 

ISSUe. 

4. Admit that FAA Order 8900.1 provides that failure to fill in a blank or complete a form 

calls for a warning and not a violation. 

INTERROGATORIES 

I. If your basis for the proposed violation involves a conclusion that Elite Air has 

previously committed and error similar to the one at issue, please provide details of any 

previously alleged errors. 

2. If your answer to any of the above admission requests is "Denied", please state that 

factual basis for said denial. 
REQUESTS FOR PRODUCTIONS 

1. Your entire administrative file regarding this investigation. 

CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing has been furnished by regular US 

Mail to the following, on this 12th day of March, 2012. 

Hearing Docket Clerk 

FAA, AGC-430 Suite 2W1000 

Wilbur Wright Building 

800 Independence Avenue, SW 

Washington DC 20591 

Ryan Landers 

US Department of Transportation 

Office of Regional Counsel 

Post Office Box 20636 

Atlanta GA 30320 

,Esq. 

lite Air, Inc.