U.S. DEPARTMENT OF TRANSPORTATAION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

FEDERAL AVIATION ADMINISTRATION, 

Complainant, 

V. 

CLOUD DANCER AVIATION AND FLYING CLUB, INC. 

Respondent. 

MAR 2 2 2CI0 

iEARING DOCKET 

FAA Docket No: 

Judge 

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JUDGE NOT YET ASSIGNED CD 

UJ -,-,co i - o RESPONDENT'S INTERROGATORIES TO COMPLAINANT oo o 

J 23 

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Respondent, CLOUD DANCER AVUTION AND FLYING CLUB, INC, through counsel an F 

notifies the Court that a set of interrogatories, including subparts, has been propounded upon the 

Complainant, to be answered in writing, individually, under oath, and within the time and manner 

prescribed by the Federal Administrators Rule. 

Certificate of Service 

I HEREBY CERTIFY that the foregoing was submitted via mail on this i ^ day of March 2010 to 

Andrea Michelle Harper, Esq., Office of Regional Counsel, ASO'7, Southern Region, P.O. Box 20636, 

Atlanta, GA 30J20. 

Respectfully submitted, 

Dennis R. Haber, PA 

892SSW148 Street, Suite 200 

Miami, Fl 33176 

Phone: 30S-256'30C 

Fax: 305'256--300/ / 

Denms i^nnai 

FBN: 660 

1, Esq. 
INSTRUCTIONS 

The following instructions apply with re^>ect to each Interrogatory: 

A. If you cannot answer any Interrogatory after conducting a reasonable 

investigation, you should so state; however, you must answer to the extent you can state what 

information you do have, what information you cannot provide, and stating what efforts you 

have made to obtain the unknown information 

B. You should provide all information, including that learned through hearsay, which 

is known by you, your agents, employees, or attorneys, or appearing in your records. 

C. For each separate Interrogatory or subpart thereof, identify the person (if different 

than you) who supphed the response or answer. 

D. If a privilege not to answer is claimed, identify each matter as to which the 

privilege is claimed, the nature of the privilege, and the legal and factual basis for each such 

claim. 

E. If a refusal to answer any Interrogatory is based on grounds that it is burdensome, 

identify the number and nature of the documents needed to be search, the location of the 

documents, and the number of persons, hours and costs required to conduct the search. 

DEFINITIONS 

F. The term "you" or "your" means Federal Aviation Administration /Administrator 

G. The term "person" shall mclude natural persons, proprietorships, corporations, 

associations, partnerships, groups, committees and/or organizations of any kind. 

H. The term "relating to" means containing reference to, describing, explaining, 

includmg, sup^lementmg, verifying, evidencing, supporting, contradicting, and/or referring to. 

I. The term "document" shall include writing of any kind. 

J. The term "statement" includes any oral or viTitten assertion, regardless of form, 

which broadly construed, may relate to the subject matter called for in the request. 

K. Respondent means Cloud Dancer Aviation and Flying Club. Inc. 

L. Complainant shall mean Federal Aviation Administration/ FAA. 

M. "Agreement" or "Contract" means the document you attached to your Complaint in this matter 

and which you allege. 
INTERROGATORIES 

Please state the name, address, and contact information for the FAA representative who sought to 

do the inspection. 

2. Please set forth the name and contact information for the Administrator and/or supervisory 

personnel who reviewed the file in anticipation of complaint being filed, including but not limited 

to, immediate supervisors of the Representative seeking the inspection. 

3. Please state the name of the inspector who did the final inspection. 

4. Please Hst all FAA/FSDO personnel who had involvement in this file and state the scope of their 

involvement. 
INSTRUCTIONS 

The following instructions apply with respect to each Interrogatory: 

A. If you cannot answer any Interrogatory after conducting a reasonable 

investigation, you should so state; however, you must answer to the extent you can state what 

information you do have, what information you cannot provide, and stating what efforts you 

have made to obtain the unknown information 

B. You should provide all information, including that learned through hearsay, which 

is knovwi by you, your agents, employees, or attorneys, or appearing in your records. 

C. For each separate Interrogatory or subpart thereof, identify the person (if different 

than you) who suppHed the response or answer. 

D. If a privilege not to answer is claimed, identify each matter as to which the 

privilege is claimed, the nature of the privilege, and the legal and factual basis for each such 

claim. 

E. If a refusal to answer any Interrogatory is based on grounds that it is burdensome, 

identify the number and nature of the documents needed to be search, the location of the 

documents, and the number of persons, hours and costs required to conduct the search. 

DEFINITIONS 

F. The term "you" or "your" means Federal Aviation Administration /Administrator 

G. The term "person" shall include natural persons, proprietorships, corporations, 

associations, partnerships, groups, committees and/or organizaticwis of any kind. 

H. The term "relating to" means containing reference to, describing, explaining, 

including, supplementing, verifying, evidencing, supporting, contradicting, and/or referring to. 

I. The term "document" shall include vmting of any kind. 

J. The term "statement" includes any oral or written assertion, regardless of form, 

which broadly construed, may relate to the subject matter called for in the request. 

K. Respondent means Cloud Dancer Aviation and Flying Club. Inc. 

L. Complainant shall mean Federal Aviation Administration/ FAA. 

M. "Agreement" or "Contract" means the document you attached to your Complaint in this matter 

and which you allege. 
r^,• 

INTERROGATORIES 

1. Please state the name, address, and contact information for the FAA representative who sought to 

do the inspection. 

2. Please set forth the name and contact information for the Administrator and/or supervisory 

personnel who reviewed the file in anticipation of complaint being filed, including but not hmited 

to, immediate supervisors of the Representative seeking the inspection. 

3 . Please state the name of the inspector who did the final inspection. 

4. Please hst aU FAA/FSDO personnel who had involvement in this file and state the scope of their 

involvement.