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ADMlNISTRA TOR, 

Federal Aviation Admini5tration 

Complainant, Case No. 2014-GL-70-0045 

v. Docket No.: FAA-2016-4269 

VAN AIR MANUFACTURING, INC. Judge: J.E. Sullivan 

Respondent. 

RESPONDENT'S INITIAL DISCLOSURES 

PURSUANT TO RULE 26(a)(1) 

COMES NOW, Vanaif Manufacturing, Inc. ("Respondent"), by and through the 

undersigned and pursuant to Federal Rules of Civil Procedure 26(a)(l), and hereby serves upon 

all parties Respondent's Initial Disclosures: 

1. Pursuant to Rule 26(a)(l)(A)(i), the following individuals are likely to have 

discoverable infonnation that Respondent may use to supporl1heir claims: 

a. Greg Kokot (President) 

Vanair Manufacturing, Inc. 

10896 West 300 North 

Michigan City, IN 46360 

Subjects of infonnation: knowledge of events and facts surwunding 1he September 24, 

2013 incident at Midway Allport in Chicago, Illinois. 

b. Ralph Kokot (Chief Executive Officer) 

Vanair Manufacturing, Inc. 

10896 West 300 North 

Michigan City, IN 46360 

Subjects of infonnation: knowledge of events and facts suuotmding the September 24, 

2013 incident at Midway Airport in Chicago, Ulinois. 

c_ Jackie Higgins (Safety Coordinator) 

Vauair Manufacturing, Inc. 

10896 West 300 North 

Michigan City, IN 46360 

Subjects of information: knowledge of events and facts surrounding the September 24, 

2013 incident at Midway Airport in Chicago, Illinois. 

d. Terry Vittatoe 

Mobile PTO 
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6272 N. 300 West 

Michigan City, IN 46360 

CREMER SPINA SHAUGHNESSY 141003/005 

Subjects of information· knowledge of events and facts surrounding the September 24, 

2013 incident at Midway Airport in Chicago, Illinois. 

e. Ritchie V erplank 

Federal Aviation Adminio;tration 

Joint Security and Hazardous Materials Division 

2300 EMt Devon Avenue, suite 223 

Des Plaines, IL 600\ 8 

Subjects of information: knowledge of events and facts surrounding the September 24, 

2013 incident at Midway Airport in Chicago, Illinois. 

f. Paul Serafin 

Federal Aviation Administration 

Joint Security and Hazardous Materials Division 

2300 East Devon Avenue, suite 223 

Des Plaines, IL 60018 

Subjects of information: knowledge of events and facts surrounding the September 24, 

2013 incident at Midway Airport in Chicago, Illinois. 

g. Derrick Wichman 

(Address unknown) 

Subjects of information: knowledge of events and facts surrounding the September 24, 

2013 incident at Midway Airport in Chicago, Illinois. 

Respondent reserves the right to supplement this initial disclosure after additional 

discovery and investigation is tJndertaken. 

2. Pursuant to Rule 26(a)(l)(A)(ii), Respondent provides the following description 

by category of all documento, electronically stored information, and tangible things that 

Respondent has in its possession, custody or control and may be used to support its claims: 

a) Vauair Human Resource Department records; 

b) HAZMAT training materials; 

c) Correspondence between FAA and Vanairrepresentatives; and 

d) Photograph(s) from inside ofVanair facility. 

Respondent reserves the right to supplement this initial disclosure after additional 

discovery and investigation is undertaken. 

3. The Respondent is not seeking monetary damages and, accordingly, the 

computations required under Rule 26(a)(J (A)(iii) are inapplicable. To be responded t() by 

Con1plainant. Respondent denies that any penalty is appropriate. 

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4. Pursuant to Rule 25 (a)( 4), these documents are m writing, signed by 

Respondent's counsel and being served upon all parties. 

5. Pursuant to Federal Rule of civil Procedure 5(d)(l), these disclosures are not 

being filed with the Court at this time. 

CERTIFICATE OF COMPLIANCE WITH RULE 26(g) 

I HEREBY CERTIFY tbat to tbe best of my knowledge, information and belief, formed 

after a reasonable inquiry, that these documents are complete and correct as of August 30, 2016. 

Dated: August 30,2016 

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Respectfully submitted, 

Jolm S. Hoff 

Jared A. Sclmeider 

Cremer, Spina, Shaughnessy, Jansen & 

Siegert, LLC 

One North Franklin Street, 10m Floor 

Chicago, Dlinois 60606 

(312) 726-3800 Tel. 

(312) 726-3818 Fax 

jhoff@cremerspina.com 

jsclmeider@cremerspina.com 
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CERTIFICATE OF SERVICE 

I hereby certify that on August 30, 2016, I have sent by U.S. Post, the original and one 

(1) copy of the forgoing document to: 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20594 

Attention: Hearing Docket Clerk, AGC-430 

Wilber Wright Building- Suite 2Wl000 

In addition, I hereby cet1ify that on August 30, 2016, I have sent by U.S. Post and via 

facsimile, a copy of the foregoing docmnent to the following: 

Kate Bm:ber, Esq. 

Enforcement Division, Midwest Team 

2300 East Devou Avenue 

Des Plaines, IL 60018 

kate.b.uber@faa. gov 

Fax: (84 7) 294-7498 

Honorable J.E. Sullivan 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Dep.utrnent ofTrallsportation 

1200 New Jersey Avenue, S.E. (Ell-31 0) 

Washington, D.C. 20590 

Fax: (202) 366-7536 

#346537 

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M.uia Rivas