01/25/2011 17;39 FAX 2024935142 FAA + DMS i^ooi/ooa 

Michael Selig. MD, FACC , CF(-H 

2816 Orefield Road 

Allentown, PA. 18104 

CEIVEL: 

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U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

Federal Aviation Administration 

Laura Ponto, Latonyo Williams 

Complainants 

M & R Helicopters, LLC. 

Respondent 

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Honorable Judge Ronnie Yoder 

Docket: 2010-1211 

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RESPONDENT'S REPLY TO THE MOTION TO COMPEL DISCOVERY 

AND NOW, comes respondent, MICHAEL B. SELlG, MD, FACC, 

principle for MR Helicopters, LLC. (MRH) (non-existent since 2009) whom avers 

and files the following reply to MOTION to COMPEL DISCOVERY of information 

requested of Latonya Williams and Laura Ponta, Esq. past the 30 day period 

according to Rule 13.220 (d). 

1. On December 2, 2010, respondents motion to compel discovery 

was faxed and mailed to Mr Ponto. 

2. Ms Ponto came around to answering that motion by document 

received on December 20, 2010, thereby 10 days past the deadline and In 

breach of §13.218(d). 

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3. Complainant errs in alleging that there is no outstanding discovery. 

4. Ms Williams did not provide the requested specific regulations, 

language, details, references or training with regard to her referenced specific 

regulation changes. 

5. On October 22, 2010, respondent was served with an incomplete 

investigative file which included several altered, redacted and spoliated 

documents. The unaltered documents were requested and the references 

cited concerning document and evidence withholding. 

6. On October 27, 2010, a letter was faxed and addressed to Ms Ponto 

requesting o complete copy of all the Regulations referenced in her complaint, 

inclusive of adoption dates and revision dates io cor^firrn prior statements made 

on behalf of the parties. 

7. In the letter of October 27, 2010, respondent requested full, unaltered 

copies of documents that were produced in the incomplete Investigation file, 

that were either stricken, blocked out, redacted or spoliated. 

8. In the letter of October 27, 2010, it was requested to provide the 

reference of Jordon v Department of Juslice that Ms Ponto cited in her 

correspondence. 

9. In the letter of October 27, 2010, it was requested to provide the 

reference for policies on disclosure restrictions. 

10. In the letter of November 24, 2010, the above items were requested 

a second time. 

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11. The parties did not follow the standard practice pertaining to rules of 

evidence of attaching referenced documents. 

12. In violation of Rule 13.220 (d) the parties hove not responded by way 

of objection or production of discovery that is now passed the 30 day deadline 

period. 

WHEREFORE, the respondent prays that this Honorable Court will either dismiss 

the case on the basis of violating Rule 13.220 (d) or compel the parities Latonya 

Williams and Laua Ponta to produce the requested documents. 

Respectfully Submitted, 

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Date ., . V^' 

Michael B. Selig, MD, FACC. V^^ ^' ^ 

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