n^^ART!€HT Or 

U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

IN THE MATTER O? 

JACK B. BARBER 

FAA DOCKET NO. 

(Civil Penalty Action) 

DMS No. 

RECEIVED 

NOV 1 8 2010 

J • :EARING DOCKET 

COMPLAINANT'S FIRST REQUEST FOR DISCOVERY 

In accordance with section 13.220 of tlie Rules of Practice in FAA Civil Penally Actions, 

14 C.F.R. § 13.220, the Complainant requests that Respondent Jack B. Barber provide to 

undersigned counsel the information and documents sought in the interrogatories and requests 

for production of documents set forth below on or before Monday, December 20, 2010. 

Under 14 C.F.R. § 13.220(i), this is a continuing request, through the date of the hearing 

in this matter, for Respondent to supplement or sunend his responses to the requests set forth 

below as soon as new or different information becomes known to him. 

DEFINITIONS 

1. The use of the words "you" and "your" refers to Jack B. Barber, his agents, his 

attorneys, and any other per5on(s) acting or purporting to act for him or on his 

behalf. 

2. Requests for statements include all statements recorded by any means including, 

but not limited to, printed or typewritten statements, handwritten statements; or 

notes, e-mail, electronic recordings, and statements contained in memoranda, 

correspondence, or other documents. 

SOO/LOOl g SWO <• WVd 3tLSe6t20S XVd OO'.at 0103/81/1 1 
3. Requests for documents include all writings, drawings, graphs, tables, charts, 

photographs, and other data compilation-s from which information can be obtained 

or from which information can be translated, if necessary, into usable form. 

INTERROGATORIES 

1. Provide the name, occupation, and business address of each person you intend to 

call as a witness in this proceeding. 

2. For each witness identified in Interrogatory No. 1, identify the nature of the 

testimony to be provided (i.e., fact witness or expert witness), the subject matter 

about which each witness is expected to testily, and provide a summary of the 

testimony to be provided. 

3. For each witness identified as an expert in Interrogatory No. 2, identify the facts 

and opinions comprising the testimony of each wiiness; provide a summary of the 

grounds for each opinion; and detail the expertise possessed by each expert 

witness in the subject matter area on which the witness will testify. 

4. List all exhibits you intend to introduce as evidence in this case. 

5. Identify ail documents in your po.s.session that concern, refer to, or involve the 

circumstances set forth in the Complaint. 

6. Describe with particularity each and every fact on which you rely to support each 

and every denial, if any, that are or will be contained in your Answer to the 

Complaint. 

7. Describe with particularity each and every fact on which you rely to support each 

and every affirmative defense, if any, that are or will be contained in your Answer 

to the Complaint. 

500/300 ® SNG . VVJ ZH9t^VZ0Z KVJ 00^31 0L02/81/LL 
REQUESTS FOR PRODUCTION OF DOCUMENTS 

1. Copies of all documents that you intend to introduce as evidence in this ca.se. 

2. Copies of all statements made by witnesses identified in the preceding 

inteaogatories concerning, referring to, or involving the circumstances set forth in 

the Complaint. 

3. A cuixent copy of the curriculum vitae for each expeit identified in response to 

Interrogatory No. 2. 

4. Copies of all documents that support each and every denial, if any, that are or will 

be contained in your Answer to the Complaint. 

5. Copies of all documents that support each and every affirmative defense, if any, 

that are or will be contained in your Answer to the Complaint. 

6. Copies of all documents to which you referred, or upon which you relied, in 

answering the preceding interrogatories. 

7. You must identify all documents for which you claim privilege or any other 

objection as a ground for non-produciion. You must identify' these documents 

chronologically as follows: 

a. date: 

b. title; 

c. type of document (e.g., memorandum, report, chart, e-mail, etc.); 

d. subject matter (without revealing the information for which privilege or 

statutory authority to withhold is claimed); 

e. factual or legal basis for the claimed privilege, or any other authority which 

provides the claimed ground for privilege. 

y^Vj Sn9S6f302 XVi 00:9L 0L0S/8L/LL 
Respectfijlly submitted, 

Peter J, Lynch 

Assistant Chief Counsel 

Enforcement Division, AGC-300 

By: Amanda K. Bmchs 

Attorney, AGC-300 

Federal Aviation Administration 

Office of the Chief Counsel 

800 Independence Ave., S.W. 

Washington, D.C. 20591 

(202) 493-5548 

(202) 267-5106 (fax) 

Dated: November 18, 2010 

soo/t^ooia SWO VVd StPLSeGfSOZ XVd L0:9 L 0LOS/8L/I L 
CERTIFICATE OF SERVICE 

I certify that on thi.s date I sent by certified mail, return-receipt requested, a copy of the 

Complainant's First Request for Discovery in Matter of Jack B. Barber, FAA Docket No. , 

FAA Case No. 2010AL910023 to; 

Jack B. Barber 

4501 Aircraft Drive 

Anchorage, AK 99502 

1 also certify that on this date I hand-delivered the original and one copy of the 

foregoing document to: 

Federal Aviation Administration 

600 hidependence Avenue, S.W. 

Wilbur Wright Building - Suite 2W1000 

Washington, D.C. 20591 

Attn: Hearing Docket Clerk, AGC-430 

^,^.^^1^3^ £w ^ 

Dated: November 18,2010 

SOO/SOO® SMO <- VVd StLSSetSOS XVd L0:9L 0L0S/8L/IL