U.S. DEPARTMENT OF TRANSFORATION 

FEDERAL AVIATION ADMINISTRATION O C/ ^ jT-1 * 

OFFICE OF HEARINGS ' ^Cl\//^t\ 

WASHINGTON, D.C. ^ ^L J 

DOCKET IN THE MATTER OF 

AIREVACINC. 

— i 

FAA DOCKET NO. CP10CE0002 '^• 

(Civil Penalty Action) 

DMS No. FAA - 2010 - 0024 r^ 

_ - -i 

IN THE MATTER OF 

AIR EVAC, INC. 

FAA DOCKET NO. CPlOCEOOOl 

(Civil Penalty Action) 

DMS No. FAA - 2010 - 0022 

SECOND SET OF DISCOVERY REOUESTS TO COMPLAINANT FAA 

COMES NOW Respondent Air Evac, Inc. in the consolidated matter, FAA Docket No. 

CP10CE002 and FAA Docket No. CPlOCEOOOl and hereby requests that the Complainant 

respond to the following discovery within thirty (30) days from the date service hereof. 

DISCOVERY 

REQUEST: Please respond to the discovery requests which were served upon you on 

May 25, 2010, eind to which you have not yet responded. A copy of these discovery requests are 

attached hereto as Exhibit A. 
RESPONSE: 

INTERROGATORY NO. 1: Please state the name, occupation, business address 

and telephone number of any person or persons known by Complainant to have relevant 

knowledge of and/or information about these matters in these proceedings. 

RESPONSE: 

INTERROGATORY NO. 2: Please provide a summary of the substance and 

basis of the knowledge of each person identified in the interrogatory immediately previous to this 

interrogatory. 

RESPONSE: 

INTERROGATORY NO. 3: Please describe each exhibit other than a document 

Respondent intends to introduce into evidence at the proceeding. 

RESPONSE: 

REOUEST TO PRODUCE DOCUMENTS 

DOCUMENT REQUEST NO. 1: Please produce copies of all documents 

Complainant intends to introduce into evidence in these proceedings to include, but not be 
limited to reports, letters, memoranda, writings, photographs, drawings, sketches, computer data, 

audio recording, transcripts and video recording. 

RESPONSE: 

DOCUMENT REQUEST NO. 2: Please produce a copy of all prior written statements 

made by any person identified in any of the responses to these interrogatories, including the first 

discovery requests, which relates in any manner or has any bearing on the incidents at issue in 

these proceedings. 

RESPONSE: 

DOCUMENT REQUEST NO. 3: Please provide a description of any non-document 

exhibit not otherwise being capable of being copied or reproduced which Complainant intends to 

introduce into evidence in these proceedings. 

RESPONSE: 

DOCUMENT REQUEST NO. 4: Please produce a copy of each document which 

Complainant has identified or developed in any further investigation that has taken place in this 

matter subsequent to the investigative file regarding each of the Administrators' Amended 

Complaints. 

RESPONSE: 
Respectfully submitted, 

COOLING, & HERBERS 

fe 2400 

Kansas City, MO 64105 

Telephone: (816)474-0777 

Facsimile: (816)472-0790 

iramsev(a),coolinglaw.com 

ATTORNEYS FOR RESPONDENT 

AIR EVAC EMS, INC. 

CERTIFICATE OF SERVICE 

I hereby certify that on the 30"^ day of June 2010,1 forwarded one (1) copy of the 

foregoing via fax transmission and United States regular mail, postage prepaid to: 

The Honorable Richard C. Goodwin 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor, Room El2-320 

Washington, D.C. 20590 

FAX: 202-366-7536 

Federal Aviation Administration 

800 Independence Avenue, SW 

Wilbur Wright Building, Room 2014 

Attention: Hearing Docket Clerk, AGC-430 

Washington, D.C. 20591 

FAX: 202-493-5142 

Mark G. Camacho 

Senior Enforcement Attorney 

Federal Aviation Administration 

Office of Regional Counsel 

901 Locust, Room 506 

Kansas City, MO 64106-2641 

FAX: 816-329-3771 
r^ 

U.S. DEPARTMENT OF TRANSFORATION 

FEDERAL AVIATION ADMINISTRATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

IN THE MATTER OF 

AIREVACINC. 

FAA DOCKET NO. CP10CE0002 

(Civil Penalty Action) 

DMS No. FAA - 2010 - 0024 

IN THE MATTER OF 

AIR EVAC, INC. 

FAA DOCKET NO. CPlOCEOOOl 

(Civil Penalty Action) 

DMS No. FAA - 2010 - 0022 

DISCOVERY REOUESTS TO COMPLAINANT FAA 

INTERROGATORIES 

INTERROGATORY NO. 1: Please identify each person you intend to call as a 

factual witness in this proceeding described in each of your Amended Complaints by 

providing the person's name, occupation, business address, and telephone number. 

RESPONSE: 

EXHIBIT 
INTERROGATORY NO. 2: Please provide the substance of the testimony to be offered 

by each of the witnesses identified in Interrogatory No. 1. 

RESPONSE: 

INTERROGATORY NO. 3: Please identify each person you intend to call as an 

expert or investigative witness in support of the allegations in each of your Amended 

Complaints in this proceeding by providing the person's name, occupation, business 

address, and telephone number. 

RESPONSE: 

INTERROGATORY NO. 4: With respect to each expert or investigative witness 

you intend to call as a witness in the proceeding for each of your Amended Complaints, 

please state the subject matter upon which each expert or investigative witness is 

expected to testify, the facts and opinions comprising the testimony of each expert or 

investigative witness, and a summary of the grounds for each opinion or conclusion 

RESPONSE: 

INTERROGATORY NO. 5: Please identify any and all documents in your possession 

that concern, refer to, or involve the circumstances set forth in each of the Amended 

Complaints. 

RESPONSE: 
INTERROGATORY NO. 6: Please describe in detail the factual basis the allegations 

set for the in each of the Amended Complaints. 

RESPONSE: 

REQUEST FOR THE PRODUCTION OF DOCUMENTS 

DOCUMENT REQUEST NO. 1: Please provide a complete up to date copy of the 

investigator's file regarding each of the Administrator's Amended Complaints. 

RESPONSE: 

DOCUMENT REQUEST NO. 2: Please produce a copy of each authority upon which 

you intend to rely in your support of each of the Amended Complaints. 

RESPONSE: 

Respectfully submitted, 

COOLING & HERBERS 

le^'E^J^Rafhsey 

llOO^i n Street, SuiYe 2400 

Kansas City, MO 6^05 

Telephone: (816)474-0777 

Facsimile: (816)472-0790 

iramsey(S),coolinglaw.com 

ATTORNEYS FOR RESPONDENT 

AIR EVAC EMS, INC. 
CERTIFICATE OF SERVICE 

I hereby certify that on the /- \ day of May 2010,1 forwarded one (1) copy 

of the foregoing via fax transmission and United States regular mail, postage prepaid to: 

The Honorable Richard C. Goodwin 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor, Room £12-320 

Washington, D.C. 

FAX: 202-366-7536 

Federal Aviation Administration 

800 Independence Avenue, SW 

Wilbur Wright Building, Room 2014 

Attention: Hearing Docket Clerk, AGC-430 

Washington, D.C. 20591 

FAX: 202-493-5142 

Mark G. Camacho 

Senior Enforcement Attorney 

Federal Aviation Administration 

Office of Regional Counsel 

901 Locust, Room 506 

Kansas City, MO 64106-2641 

FAX: 816-329-3771 

F:\Cases\FAA ENFORCEMENT ACTIONS\AIR EVAC\Pleadings\Consolidated\lst Set of Interrogatories and Req. for 

Prod.May25.2010.doc