UNITED STATES DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C: 

# RECEIVED
IN THE MATTER OF: DOCKETNO. FAA-2011-1125 

## MAR 

## 21_2012 

# H.EAR.fNG 

# oo·CKET FAA NO. 201080150236 . ELITE AIR, INC., Respondent, JudgeJE Sullivan,



## ________________________________________ / RESPONDENT'S FIRST DISCOVERY REQUESTS Pursuant to the provisions of 14 CFR§ 13.220 and Fed.R.Civ.P 36-36, pleaseresponds to the following Interrogatories, Requests For Production ofDocuments, and Requests for Admission separately and under oathbyApril13, 2012, perthe 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 bythe Rules ofCivil Procedure. IfDefendant can admit onlypart ofthe matter upon which the admission is requested, Defendant shall specifY as much ofit as is true and shall quality ordenytheremainder. Each interrogatory shall be answered separately and fully in writingunder oath, unless it is objected to, in which eventthe reasons for objection shall be stated in lieu ofan answer. You may respond to the request for production byproducing true and accurate copies ofthe originals to the undersigned. Ifyou refuse to produce any docu7ments or other evidence on the basis ofprivilege or other objection, identify specificallythe 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 youbecome aware ofa fact or the identity and location ofany document that is not identified in your original response; b. When your initial response was initially correct, but subsequentlyrendered incorrect or inaccurate based upon information discovered after the original responseisprepared 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 ofthe matters referred to in the interrogatory. If youhave any additional memory ofthe relevant events, describe itin 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 informationpertinent to locating such person. When pertaining to an object or place, "identify" means to provide the name, location or other description ofsuch object orplace. "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 FORADMISSIONS
1. Admit that the crew of N444CW performed a complete pre-flight inspection of the aircraft priorto flying on each ofthe dates at issue.
2. Admit that part ofthe pre-flight inspection determined that they would not overfly any maintenance item during the courseplan ofthe 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 awarning and not aviolation. 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 FORPRODUCTIONS
1. Your entire administrative file regarding this investigation.

CERTIFICATE OF SERVICE I hereby certifythat a true and correct copy ofthe foregoing has been furnished byregularUS Mail to the following, onthis 12th day ofMarch, 2012. Hearing Docket Clerk FAA, AGC-430 Suite 2W1000 WilburWrightBuilding 800 Independence Avenue, SW Washington DC 20591 Ryan Landers US Department ofTransportation Office ofRegional Counsel Post Office Box 20636 AtlantaGA 30320 ,Esq. liteAir, Inc.