05/13/2011 15:23 4252271007 ANM7 PAGE 02/12 

1 

2 

.3 

1 

5 

6 

7 

e 

9 

10 

11 

12 

13 

14 

IS 

le 

17 

IS 

J9 

20 

21 

22 

23 

24 

2S 

2f 

27 

28 

29 

30 

31 

32 

33 

34 

35 

35 

37 

38 

39 

40 

•4 3. 

42 

<t3 

44 

45 

46 

47 

4B 

49 

50 

51 

52 

53 

SCOTT R, MORRIS 

FAA OFFICE OF REGIOMAL COUNSEL 

1601 LlND AVE., SW 

SJENTON, WASHINGTOM 98057 

TELEPHONE: 425.22 7.1417 

FACSIMILE: 425.227.1007 

-.'!Vit:hl Cr-.r-r, , 

^UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of. 

USA GAMACHE-WORTMAN 

FAA DOCKET CP1OAL0005 

FAA Case No. 2009AL700103 

DMSNo. FAA-2010-1081 

MOTION TO DEEM ADMITTED 

COMPLAINANT'S REQUESTS FOR 

ADMISSIONS AND MOTION TO 

COMPEL DISCOVERY 

To: Honorable Richard C- Goodwin 

Complainant, throu^ his undersigjjed counsel, pursuant to Rules of Practice 13.220(1)(1), hereby 

moves tliat the Requests for Admissions filed by the Complainant back on March 30, 20] 1 are 

deemed admitted, Additionally, pursuant to Rules of Practice 13.220(mX Complainant hereby 

moves thai the ALJ issue an Order to Compel Respondent to comply with Complainant's discovery 

requests. 

1. On November 4, 2010, Respondent requested a hearing in response to the Complainant's 

finai. Notice of Proposed Civil Penalty, On November 23, 2010, the Agency issued a Complaint 

in this case, 

2. On February 9, 2011, after Complainant filed a Motion for Decision and Renewed 

Motion for Decision, tlie ALJ issued an Order to Show Cause, giving Respondent imtil February 

25, 2011, to respond lo his Order, 

3. On March 16, 2011, more than, two weeks later than the AL.T's ordered deadline. 

Respondent subn]i..ttted a document to the ALJ only purportedly answering the Complaint. Based 

on this document, the ALJ denied Complainant's Motion for Decision and issued an Amended 

procedural Order. 

4. On March 30, 2011, Complainant filed its Initial Discovery Request, which included 

interrogatories, requests for production of documents, arid requests for admissions. Consistent 

•vsitb Rule 13.220(d), Complainant gave Respondent more than 30 days to comply with 

discovery— April 30, 2011. See Exhibit 1. Of. note, in its Initial Discovery Kequest, 

Complninauc's Motion to Deem Admitted it Motion to Compel Discovery 

In the Matter of Lisa Gamache-Wonman - CPlOALOOOOf 

Page J. of 4 

SCOTT R. MOXRIS, FAA AtroRNEY 

TFX:42S.227.14 1 7; PAX;-125,227.1007 

SLO/SOO® swa VVJ StLSeetSO S XVJ 80:S L LLOS/iL/S O 
05/13/2011 15:23 4252271007 ANM7 PA6E t)3/12 

1 

2 

3 

4 

5 

6 

7 

5 

9 

•10 

11 

12 

13 

14 

IS 

16 

17 

16 

19 

7.0 

21 

22 

23 

24 

25 

SE 

27 

28 

29 

30 

31 

32 

3.3 

34 

35 

3$ 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

•49 

SO 

• 3 1 

52 

53 

Complainant's counsel informed Respondent of the consequences for failing to respond to its 

discovery request in a limely manner in bold underlinf: 

5. Respondent claims financial hardship in the document it provided to the ALJ, In response 

this assettion. Complainant's discovery request specifically included a request that she produce 

documentation of this alleged fmancial hardship by producing copies of her federal income tax 

returns. 

6. On May 5, 2011, Complainant sent Respondent a letter reminding her - ^ yet again — of 

her obligation to comply with discovery and extending her due date to comply with her discovery 

obligations to May 12, 2011. In this letter. Complainant's counsel specifically informed her that 

Complainant would seek sanctions for her failure to comply with her discovery obligations. See 

Exhibit 2. 

7. As of this date, Respondent — yet again — has failed to respond to Complainant's 

correspondence. No good cause has been offered for why Respondent could not comply with her 

discovery obligations. 

Argument 

8. Tlic Respondent has had ample opportunity lo comply with Complainant counsel's 

discovery requests. Respondent has been placed on notice of the consequences of failure lo comply 

with the Court's Order, Although Respondent is proceeding pro se, she cannot be allowed to 

continually ignore documents filed in the proceedings that she has requested. 

9. The FAA rules makes the consequences a party faces when they do not comply with 

discovery clear; one portion of die rule addresses requests for admissions and anolher portion 

addresses the o'iier discoveiy tools, 

10. For requests for admission, Rule 13,220(1X1) provides: 

(1) Time. A party's failure to respond to a request for admission, in writing and 

signed by the attorney or the party, not later than 30 days aftei service of the request, 

is deemed an a<;1;nijp^j(;>p of tlie truth of the statement or statements contained in the 

request for admission. The administrative law judge may determine that a failure to 

respond to a request for admission is not deemed an admission of the trutli if a party 

shows that the failure was due to circumstances beyond-tfag control of the party or 

the party's attorney [emphasis added]. 

11 - Respondent has made no demonstration or offered any explanation for why the requests for 

admissions could not be answered. Furthermore, tliere was no response to the Complainant's letter 

warning Respondent of tlie consequences of failing to comply with, discovery. Complainant's 

counsel has demonstrated some flexibility in discovery and even warned the Respondent of his 

intended actions prior to this motion. Therefore, unless the ALJ affirmatively finds thai the failure 

to answer the Request for Admissions was due to circumstances beyond the Respondent's control, 

by Rule 13.220(1)(1)5 the requests for admissions submitted by Complainant are deemed admitted. 

Complainant specific^ly asks the AU to so rule. 

12. For other fomis of discovery, Rule i3.220(m) requires the Complainant to liJc a motion to. 

compel prior to seeking sanction for the remaining portions of his discovery request: 

ComplairiMt's Motion w Uoem, Admitted & Motion to Compel Discovery SCOTT R. MORJUS, FA A ATTORNEY 

In the Matter of Ll-w Camftche-'WoTtmaii -CP10AL00005 TEL; 425.227.1417; FAX: 425,227,1007 

Page 2 of 4 

SLO/eoo® swa <• VVd stiseBtsos XVd GO:S L LLOS/IL/S O 
05/13/2P11 15:23 42522710137 ANM7 PAGE 0d/12 

1 

2 

3 

5 

£ 

7 

8 

10 

11 

12 

13 

14 

15 

le 

17 

le 

IS 

20 

21 

22 

23 

24 

25 

2S 

37 

26 

29 

30 

31 

32 

33 

34 

35 

36 

3 7' 

36 

39 

40 

41 

42 

43 

44 

45 

46 

47 

4S 

49 

50 

51 

52 

53 

,., if a person reflises to answer a question during a deposition, a party fails or 

refuses to answer an interrogatory, if a person gives an evasive or incomplete during 

a deposition or when responding to an interrogatory, or a party fails or refuses to 

produce documents or tangible items. 

Respondent has also failed to respond to Complaii^ant's Interrogatories and Requests for Production 

of certain documents. This ha^ occurred despite prior Motions for Decision for failing to respond to 

pleadings, the ALJ's procedural order, the admonition in bold upderlined type of the consequences 

of failing to comply wi.th her discovery obhgations, and issuing a warning letter addressing the 

consequences of failing to comply with discovery. This motion requests the ALJ issue a discovery 

order and show cause order giving Respondent 10 days to explain why she should not be 

sanctioned, consistent with Rule 13,220(n), fox failing to comply with her discovery obligations. 

13. In short, the Respondent has failed to comply with her obligation to communicate in the 

hearing process that she has requested and has failed to comply with her discovery obligations 

consistent with Rule 13.220. There should be tangible consequences for these actions; the 

Complainant should not be continually required to chase the Respondent in this process. 

14, THEREFOPJE, Complainant requests the following from the ALJ: 

a. Pursuant to Rule 13.220(1)(1), Complainant's requestB for admissions be deemed 

admitted, 

b. Pursuant to Rule 13>220(m), issue a discovery and show cause order to compel 

compliance with Complainant's discovery request and require the Respondent to 

comply with her discovery obligation within 10 days, or face sanctions under 

Rule 13.220(n). 

c. Warn Respondent that failure to comply can result in sanctions, including denial 

of the use of any documents, witnesses, or other evidence not provided in her 

responses to discovery. 

DATED this 13th day of May 2011. 

SCOTT R. MORRIS 

FAA Attorney 

* See In the Manej of Citv of Bridgeport. CoTmectic.^- CP09NEO001, 2010 WT- 2209964, ALJ's Order Denying 

Motion for Reconsideration (May 28, 2010)("T!bc sanction was imposed after fair wamjng. It is appropriate lo the 

offense, in that a party who has hidden its infonmaiion from tlie other party oannoi, in all faiincss, be peraiitted to 

imcloak relevant infornis-tion on the eve of the hearing.") 

Complainant's Motion to Deem Admitted &. Motion to Compel Discovery ScCTr R, MORR:S, PAA ATTORNEY 

lntheMB.ttcrofLisa.GftTTvach©-WortmaB -CPIOAL-OOOOS TEL; 425.227.UV7.FAXL42S,227,1007 

PogcS of 4 

jLo^^QOlg SNQ <• VVJ StLSSetSOS XVJ GO:SL LL02/a/S0 
RiS/r.V2ail 15:2 3 

1 

2 

3 

4 

5 

6 

7 

9 

5 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

.28 

29 

30 

31 

32 

33 

34 

35 

36 

•37 

38 

39 

40 

41 

42 

43 

4 4 

45 

45 

47 

49 

43 

50 

51 

«i2 

53 

4252271807 ANM7 

CERTIFICATE OF SERVICE 

PA6E 05/1 2 

I^hereby certify that the foregoing Complainant's Motion to Deem Admitted and Motion to 

Compel Discovery has been served via facsimile and certified mail - Return Receipt Requested 

this date, to the following: . 

The Honorable Richard C. Goodwin 

Office of hearings, M-20 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor, Rm El2-320 

Washington, D.C. 20590 

TEL: 202.366.2139 

FAX: 202.366.7536 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, D.C. 20591 

Attn; Hearing Docket Clerk, AGC-430 

Wilbur Wright Building - Suite 2W1000 

FAX: 202.493,5020 

I hereby certify that the foregoing Complainant's Motion to Deem Admitted and Motion to 

Compel Discovery has been served via Regular and Certified Mail - Return Receipt Requested 

this date, to the following: 

Lisa Garaache-Wortman 

P.O. Box 12793 

01ympia,WA 9S508-2793 

TEL: 360.866.0892 

Dated this 13th day of May, 2011. 

MoifairChin, -^ ^^^< — 

Office of Regional Counsel (ANM-7) 

Federa l Aviatio n Administratio n 

1601 Lind Ave. SW 

Renton, WA 98057 

425.227.2160 

Complajphint's Motion to Deetn Admitted & Modon w Compel Discovery 

In the Matter of Lise Giim»ehc-Wonman - CP 10A].^0OOOS 

Page 4 of 4 

SCOTT R. MOEWS, FAA ATTORNEY 

TEL; 425.227,1417; FAX: 425.227.1007 

ZLO/SOO ® swa VVd si?L9eet?sos xvd GO^SL LLOS/U/S O 
05/1:3/2011 15:23 4252271007 ANM7 PAGE 06/1 2 

1 

2 

3 

4 

S 

c 

7 

e 

s 

10 

11 

12 

13 

14 

15 

IS 

17 

18 

19 

20 

21 

22 

23 

24 

2S 

2£ 

27 

26 

29 

30 

31 

32 

33 

34 

3S 

3£ 

3? 

38 

39 

40 

41 

42 

43 

44 

4S 

4E 

47 

40 

49 

50 

SI 

52 

S3 

SCOTT KMoRjys 

FAA OFHCE OF REGIONAL COUMSEL 

1601 LlND'A-VB^SW 

RENTON, WASHINGTON 98057 

TELEPHONE: 425.227.1417 

FACSIMILE: 425.227.1007 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of: 

Lisa Gamache-WoitmaJi 

FAA DOCKET CP10AL0005 

FAA Case No. 2009AL700103 

DMSNo. FAA-2010-lOEr 

Judge Goodwin 

COMPLAINANT'S rNTTlAL DISCOVERY REQUEST 

To: Respondent 

In accordance with 14- C J.R. § 13.220 and the Federal Rules of Civil Procedure, please 

respond to the following Interrogatories, Requests for Production of Docuroeuts, and Request for 

Admissions, s^arately and ftiUy under oa.th by April 30.2011. 

These discovery requests are intended to discover infoimation and/or documents not only 

within your personal knowledge or obtainable by you, but also information in the possession of or 

obtainable by your attorneys, investigators, rqpreseaitatives, employees, agents, or anyone acting on 

yotir behalf ot on their behalf. 

These discovery requests are continuing in nature and any iafbimatiQn which may be 

discovered by you subsequent to the service and filing of your answers mu5t be brought to the 

attention of lie agency attorney through supplemental answers when it becomes availsiik.to you, at 

a reasonable time prior to the heamig in this matter. If there are any additions, deletions or changes 

in the answers or infoimation provided at any time prior to hearing the Respondent is specifically 

requested to so immediately inform the agency attorney. If such information is not fiimished, the 

agency artomey at the time of the hearing wiU move to exclude fixim evidence such infonnation 

requested and not furnished 

TTie agency axiomey fizrther requests that the Respondent produce the docvmients identified 

and designated herein for inspection and copying at the Federal Aviation Adimnistratiou (FAA) 

Office of Regional Counsel, Suite 570,1601 Liud Avenue, SW, Renton, Washington 98057, by 

April 30.2011. 

SHOULD YOU FAIL TO AT>JS\yir,P TgESE DISCOVERY REQUESTS. AGENCV 

COUNSEL Wn,T, MOVE TO COMPELTfflS DISCOVERY. FAILURE TO COMPLY 

WTTH YOUR DISCOVERY OBLIGATIONS CAN RESULT EN PRECLUSION OF 

DNTORMATIO N YOU WISH TO PRESENT AT A HEARING. 

Complainant's Initial Discovery RenTiest ScoTi IL Mowus, FA A ATTORNEY 

Lisaaafliac}je-WoraDan-CPlOAL0005/2009AL700103 TEL: 425.227.1417; FAX: «5,227.]007 

Paec 1 otS 

Ex,, J 

SL0/900ia swa <• VVd StLSe6t303 XVd G0:2L LLOS/iL/SO 
05/13/2011 15:23 4252271007 ANM7 PAGE 07/12 

1 

2 

3 

4 

5 

S 

7 

S 

9 

10 

11 

12 

13 

14 

15 

IS 

17 

1 ^ 

19 

20 

2 1 

22 

23 

24 

2S 

2€ 

27 

. 28 

2$ 

30 

3 1 

32 

33 

34 

35 

2€ 

37 

38 

39 

HO 

41 

4 2 

43 

44 

45 

46 

47 

4 3 

49 

SO 

51 

52 

S3 

PRIVILEGE 

If, in responding to, or failirig to respond to these Intexrogatories, requests for admission and 

requests for production you invoke or rely q>on any privilege of any kind, state specifically lie 

narurc of the privilege; tiie basis upon which you invoke, rely upon or claim it, including any 

statutory or decisional reference; and identify all dncnmf^t^ or other iiiformalion, including 

contacts and communications, which you believfe to be embraced by the privilege invoked 

DATED this 3,0th day of March 2011. 

FAA Attorney 

Complainant's Initial Discovery Re<jiittst 

Lisa Oamaehe-Wortnwn - CP10AL0O(J5/2OO9AL7O0103 

Pafe 2 oT6 

SCOTT F . MQVJNS, FAA ATTORNEY 

TEL: 425,227.1417; FAX: 425.227.1007 

SLO/iOOia swo VVd StLSSGtSOS XVd 60:SL LL02/iL/S0 
05/13/2011 15:23 4252271307 ANM7 PAGE 08/12 

1 

2 

3 

4 

S 

6 

7 

e 

9 

10 

11 

12 

13 

14 

IS 

16 

17 

le 

19 

20 

21 

22 

23 

24 

25 

2€ 

27 

26 

2B 

30 

31 

32 

23 

34 

35 

36 

37 

36 

75 

40 

41 

42 

43 

44 

45 

4S 

47 

4B 

49 

50 

51 

52 

53 

PfTERROGATORIES AND REOUESTS FOR PRODUCTION 

IntgiTogatorvNo. 1: Identiiy by name, address and telephone number all persons ^^om you know 

to have personal knowledge of the m^ieis alleged in'the Complaint 

Interrogatory No. 2; Identify by title, dale, author, present ctistodian, and content, all documents. 

including coirespondehce, obtained by you or in your possession, relating to the assertions in the 

Complaint, your appeal, your answer, and any affirmative defenses which you anticipate raising in 

this matter. 

REQUEST FOR PRODUCTION NO.. 1: • Provide a copy of all documents you refetjed to in your 

answer to the preceding Interrogalory. 

In.teiToga.tory No. 3: Identify by name, address and telephone number, all persons whom you intend 

to have testify as a factual or expert witaess in your defense at the hearing in this matter, and for 

factual witnesses, provide a detailed summary of each persons anticipalcd testimony. 

Interropfatorv No. 4: Identify by title, daie, author, present custodian, and content, all documents 

which you anticipate offering into evidence at the hearing in this matter, and through wt)d,ch wimess 

or witnesses. 

REQUEST FOR PRODUCTION NO. 2: Provide a copy of all documecTS referred to in your 

answer to the preceding Interrogalory. 

Interrogatory No. 5: With respect to each expert witoess identified in response to In.terrogatory 

No. 3, above, specify their specific area of expertise, and provide a synopsis of their credentials,, 

background, training, and experience. 

IntciTogatcrv No. 6: With respect to each expert you ej^ect to call as a witness, state the subject 

matter on which the expert is expected to testify, and state the substance of the facts and 6pini.ons to 

which the expert is expected to testify, and a summary of the grounds for each such opinion. 

InterrogatoTY No. 7: State by name, address, telephone number, date of conversation, and substance 

of conversation, all persons [o1±ier than legal counsel or spouse] with whom you have discussed the 

matters alleged in the Complaint. 

IntecrogatoryNo. 8: Describe with specificity all of tb.e facts v«idch you anticipate presenting in the 

course of the hearing in this matter pcrtainiag to the avoidaiice or mitigation of die sanction sought 

by the FAA in this case. 

Interrogatory No.;9:' Describe with specificity all of the documents you anticipate presenting in the 

course of the hearing in this matter to substantiate any financial inability to pay the proposed 

sanction so\]^t by &e FAA in this case. 

REQUEST FOR PRODUCTION NO. 3: Provide a copy of all Exhibits that you wili present 

during the bearing in this matter. 

Interrogatory No. 10: Describe with 5peciJ5,dfy facts or eviden.ce you rely upon in support of any 

afBncadve defenses raised in any Answer to the Complaint 

Corttplainanf s Inifiaj Discovery Request SCOTTK. MORWS, FA A ATTOKMETT 

UsaGamachc-WQrtnan-CPlOAL0005/2009AL700]03 TEL: 425.227.1417; FAX: 42S.227.1007 

Page 3 of 6 

SL0/800i a swa * VVd . StLSeeiJSOS XVd GO-Z L LL02/iL/9 0 
05/13/2011 15:23 4252271007 ANM7 PAGE 0^/12 

1 

2 

3 

4 

5 

6 

7 

S 

s 

10 

II 

12 

13 

14 

IS 

IS 

17 

18 

19 

20 

21 

22 

23 

34 

25 

26 

27 

2a 

29 

30 

31 

ii2 

33 

34 

35 

36 

37 

39 

40 

41 

42 

43 

44 

45 

46 

47 

4B 

<9 

So 

SI 

52 

S3 

REQUEST FOR PRODUCTION NO. 4: Provide a copy of all documents that support your 

response to InteiTogatoiy No. 10. 

Interrogatory No. 11: Provide the dates when you used the mailing address P.O. BQX 570 Seward. 

Alaska 99664 

Inteiroegtorv No. 12: Provide the dates when you tjsed the mailing address P.O. Box 21S6, Ocean 

Shores, WA 98569 

hiteiTogatoTvNo. 13: Provide the dates when you used the mailing address 4432 211* Street SW. 

Lynnwood, WA 98036 

Interrogatory No. 14: Provide the dales whai you used the mail-fT;(o address 5705 51'* Avenue NW 

Olyiupia, WA 9S502 

Interrogatory No. 15: Provide the dates when you used the mailing address P.O. Box 12793, 

Olympia, WA 98508 

Xateiroggtorv No. 16: What is your dale of birth? 

REQUEST FOR PRODUCTTQN NO. 5: Provide a copy of your 2007 - 2010 Federal Income Tax 

returns. 

Compbitiant' s Initial Discovery Request SCOTT R. MORBis. FAA ATTORNFy 

Lisa Gamacbe-Wortman - CP10AL0005/2009AL700103 TEL: 425.227.] 417; FAX: 425.227.1007 

Page 4 of 6 

SLO/eOO E SWO <• VVd StLSeetSOS XVd 0L:S L LL03/iL/90 
05/i;t/2011 15:23 4252271007 ANM7 PAGE 16/12 

1 

2 

3 

4 

5 

€ 

7 

a 

9 

10 

11 

12 

13 

14 

IS 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

3 2 

33 

34 

35 

36 

3? 

33 

39 

40 

41 

42 

43 

44 

45 

46 

*7 

48 

49 

SO 

El 

52 

53 

REQUEST FOR ADMISSIONS 

Under 14 C.FJEL § 13.220(b) and Rule 36 of the Federal Rules of Civil Procedure, you are 

requested to adzxiit the truth of the following matters. A matter is admitted unless responded to in a 

reasonable time. The Rules ofPractice in FAA Civil Penalty Actions, 14C.F.R. § 13.220(d), 

defines a reasonable time to be thirty (30) days. The agency requests thai an answer is served upon 

the agency attorney either admitting the matter, specifically denying the matter, staling why the 

matter cannot be admitted or denied, or objecting to the request, with reasons for the objection 

stated within thirty (30) days of the date of service upon you, to vvit: April 30,2011, IfYoafailto 

respond to these requests for admissions in writing, the facts contained therein are deemed 

admitted, absent a ludge^s ruling that your failure to ansryer was due to circ:tirn^Anpp-<a 

beyond vour control See 14C.F.R. § 13.220(1X1)-

REQUEST FOR ADMISSION NO 1: Admit that you have also gone by the .name Lisa Stedman. 

REQLTEST FOR ADMISSION NO 2: Admit that you have also gone by the name Lisa Raniala. 

CoTnplainant' s Initial Discovery Request SCOTT R. MOERIS, FAA AnORJors' 

Lisa Gamache-Wortman - CP10AL0005/20OPAL7O0103 TEL; 425.227.1417; FAX: 425,227.1007 

Page 5 of 6 

jLO/OLOi a swa <r VVd StLSSetSO S XVd 0L:3 L UOS/iL/S O 
05/1:3/2011 15:23 4252271007 ANM7 PAGE 11/12 

1 

2" 

4 

5 

6 

1 

8 

9 

10 

11 

•12 

13 

14 

IS 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

26 

2d 

30 

31 

32 

33 

34 

35 

36 

37 

3B 

39 

40 

41 

42 

43 

44 

45 

4 6 

47 

49 

45 

50 

SI 

52 

53 

CERTIFICATE OF SERVICE 

I hereby certify that the foregoing Complainant's Initial Discovery Request has been served via 

Regular and Certified Mail - Return Receipt Requested this date, to the following: 

Lisa GamajcheTWortman 

P.O. Box 12793 

Olympia, WA 98508-2793 

Dated this 30th day of March, 2011. 

L4.^Ui ^ 

lOlFAm. CHIN 

Office of Regional Counsel (ANM-7) 

Federal, Aviation Administration 

1601,Lind Ave. SW 

Renton, WA 98057 

425.227.2160 

JD 

n-

-n 

vr 

tr 

rn r^ 

C3 

a 

C3 

•S3 

1=1 

a 

IT 

a 

U.S. Postal Service!-

CERTIFIED MAIL^, RECEIPT 

(Da;nestie Mai l Only; No Insurance Coverage Provided) 

For Jelivery irformaHon visit our wcbsilo ai iTMivj.uEp?..coinrj 

Panajq 

Cenined Fee 

Prwn l>»e«lpi Fwi 

Reameted DsKvery F«e 

fEndoraemanl HeouiKxii 

ICIA I 

1 

.v.,v •?;.,i i> . 

Hers 

Lisa Gamache-Wortman 

P.O. Box 12793 

Olympia, WA 98508-2793 

Complunmi'i Initial DlEcoveiy Rei^uest 

Lisa Gamache-Woranar - CP 10AL0005/2009 AL700103 

Pige6or6 

SCOTTB. MORKIS. FAA ArrOKNEY 

TEL: 425.227.1417; FAX: 425.227.1007 

3t0/U0i a SWO VVd SfrLSeei?S03 XVdOUZ l U02/iL/S 0 
05/13/2011 15:23 4252271007 ANM7 PAGE 12/12 

Ri < 

O 

U.S. Department 

Of Transportation 

Federal Aviation 

Admmistration 

Office of Regional Counsel 

May 5, 2011 

Northwest Motmtain Regioa. 

Colorado, Idaho, Montana 

Oregon, Utah, Washington 

Wyoming 

1601 Lind Avenue S.W. 

Renton, Washington 98057. 

Tel: (425)227-1417 

Fax:(425)227-1007 

SeOTT.MORRtS@P,iiji,.GOV 

Case No. 2009AL700103 

"FAA Docket CP 1OAL0005 

VL^ REGULAR AND CERTIFIED MAIL - RETURN RECEIPT REQUESTED 

Ms. Lisa Gamache-Wortman 

P.O. BOX 12793 

Olympia, WA 98508-2793 ' 

RE: No response to the Agency's Request for Discovery 

Dear Ms. Gamache-Wortman: 

Your responses to your discovery obligation compliance: was due to me, no later than 

April 30, 201L In this litigation process, you are required to communicate and participate in this 

process. You will forfeit certain rights when, you fail to participate or communicate with me in 

this process. I am not required to continually pursue you for infonnation and compliance in this 

process. It is a courtesy I am afFordihg you. 

I wiU extend your deadline to May 12,2011 to comply with my discovery requests. If I 

have not received substantive responses to my discovery requests by then, I will be forced to file 

a motion to compel and to seek sanctions. One of the sanctions that I will seek is to preclude you 

from' presenting any evidence al the hearLng that you have not disclosed to me in the discovery 

process. This would include evidence to support your claim of financial hardship. 

Should you have any questions about this matter, again please contact me immediately. 

Rega 

cA^ 

5C0TTR. MORRIS 

FAA Attorney 

^^^Z 

SLO/SLOi a swa ^ VVd StLSEBtSO S XVd 0L:3 L U02/iL/S 0