### UNITED STATES DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS

WASHINGTON, D.C.



### IN THE MATTER OF MACH ONE AIR CHARTERS, INC. 

# H FDMS NO. FAA-2015-0643 

# lNG DOCf<ET

COMPLAINANT'S RESPONSE TO RESPONDENT'SSECOND (sic) REQUEST FOR DISCOVERY1 

### AND SUPPLEMENTAL RESPONSE 

### Complainant, through counsel, provides the following inresponse to Respondent's discovery request served onJuly 1, 2016. REQUESTS FORADMISSION



### a. Complainant admits Requests Numbers 1-9 b. Regarding Requests Numbers 10-12, Complainant denies thatthey are preciselythe same but admits that in each requestthe cited allegations are referringto the same basic facts.

c. Regarding Requests Numbers 13-15, Complainant admits thatthe complaint inthe certificate action against Leigh W. Crumpton (Exhibit A) included allegations that he violated the referencedregulations. d. RegardingRequestsNumbers 16-17, Complainant denies that they are preciselythe same but admits that in eachrequest the cited allegations are referring to the same basic facts.

e. Regarding Requests Numbers 18-20, Complainant admits that the complaint inthe certificate action against Jennifer R. Johnson (Exhibit C) included allegations that she violated the referencedregulations. f. 

### Regarding Request Number 21, Complainant admits that based on instructions from Respondent, Signature TechAir did notperform any check onthe circuitbreaker for the left engine air intake anti-ice system, but its chiefinspector, Tom Thunstrom, did confirmthat the circuit breaker was popped, which was consistent withthe note he found in the aircraft's records.

1 Respondent's second discoveryrequest was served onJuly 10, 2015. 

### I

### g. Regarding RequestNumber 22, Complainant admits Signature TechAir did not perform an check onthe circuitbreaker for the left engine air intake anti-ice system other than, as noted above, confirmthatthe circuit breakerwas, indeed, popped. h. Regarding Request Number 23, Complainant admits thatneitherteclmician who performedmaintenance onthe aircraft that day turned onboth ofthe switches necessary to check the outside air temperature gauge inthatparticular aircraft. 

### INTERROGATORIES l.A. Such facts are included inthe above responses. LB. JeffBuzzell, Tom Thunstrom, and ClintDeMars. l.C. All such documents have previously beenproduced. 2. Thatto testthe outside air temperature gauge in civil aircraft N881A, it is necessary to flip two switches. 

### SUPPLEMENTAL RESPONSE Complainant supplements its previous responses to discovery withthe attached emails recently received from Global Aviation Services.

Servedthis 29th day ofJuly 2016. PatriciaA. MeNall Acting Assistant ChiefCounsel

for Enforcement

By:

2 

# oen;;H. Brown Enforcement Division, Western Team 222 W 7thAvenue Box 14 Anchorage, AK99513-7587 email: glenn.brown@faa.gov telephone: (907) 271-5271 (direct) (907) 271-2800 (fax)

### CERTIFICATE OF SERVICE



### Re: Mach One Air Charters, Inc. FDMS No. FAA-2015-0643 I hereby certifythat onthis date I have served a copy ofthe foregoing COMPLAINANT'S RESPONSE TO RESPONDENT'S SECOND (sic) REQUEST FORDISCOVERY AND SUPPLEMENTAL RESPONSE 

### by postage-prepaid, certified mail, returnreceipt requested and by either facsimile transmission or electronic mail, as indicated, to the following: The Honorable Douglas M. Rawald Administrative LawJudge Office ofHearings, M-20 US Department ofTransportation 1200 NewJersey Avenue, S.E. (Ell-310) Washington, DC 20590 Fax: 202-366-7536 StevenL. Graff, Esq. Steven L. Graff, Inc. 43399 Calle DeVelardo Temecula, CA 92592 Email: aviationcounsel@aol.com I further certify that on this date I have served the original and one copy ofthe foregoing COMPLAINANT'S RESPONSE TO RESPONDENT'S SECOND (sic) REQUEST FOR DISCOVERYAND SUPPLEMENTAL RESPONSE 

### bypostage-prepaid, certified mail, returnreceiptrequested and facsimile, addressed as follows: Federal Aviation Administration 800 Independence Avenue, S.W. Washington, DC 20591 ATTN: Hearing Docket Clerk,AGC-430 Wilbur Wright Building-Suite 2Wl000 Fax: (202) 267-1293 DATED: 

# SJd :2**~** 

# XI(p

Federal Aviation Administration Office ofRegional Counsel 222 West 7thAvenue, Box 14, AAL-7 Anchorage, Alaska 99513-7587

3-----Original Message----- From: Doug Ray [mailto:dray5(r?globalaviation.netl Sent: Wednesday, July 27,2016 9:07 AM To: Hernandez, Ricardo (FAA) Subject: FW: Ops Specs -----Original Message----- From: Machone Maintenance [mailto:maintenance({i;'!Tioaci.com] Sent: Wednesday, May 14, 2014 4:34PM To: Doug Ray Subject: RE: Ops Specs Give me a call562-912- 9481 -----Original Message----- From: DougRay [mailto:dravS:li::globalaviation.netl Sent: Wednesday, May 14,2014 12:45 PM To: Machone Maintenance Subject: FW: Ops Specs Attached is ops and DrugDougRay Global Aviation Services, Inc. 281-443-3533 281-443-0332 fax dray5@global-aviation.net-----Original Message----- From: Doug Ray [mailto:drav50,gJoba1- aviation.nct] Sent: Wednesday, July 27,2016 9:08 AM To: Hernandez, Ricardo (FAA) Subject: FW: Ops Specs -----Original Message----- From: Machone Maintenance [mailto:maintenance(Q':moaci.com] Sent: Wednesday, May 14, 2014 5:04PM To: Doug Ray Subject: RE: Ops Specs Ok thanks

. -----Original Message----- From: Doug Ray [mailto:drav5r(i;globalaviation.net] Sent: Wednesday, May 14, 2014 3:02 PM To: Machone Maintenance Subject: RE: Ops Specs They didn't get to do the ops today on OAT will be done first

am DougRay Global Aviation Services, Inc. 281-443-3533 281-443-0332 fax dray5@global-aviation.net-----Original Message----- From: DougRay [mailto:drav5({i'glohalaviation.nct] Sent: Wednesday, July 27,2016 10:06 AM To: Hernandez, Ricardo (FAA) Subject: FW: Ops Specs Doug Ray Global Aviation Services, lnc. 281-443-3533 281-443-0332 fax dray5@global-aviation.net -----Original Message----- From: DougRay [mail1o:drav5(rlJgloba1- aviation.nct] Sent: Thursday, May 15,2014 1:07 PM To: 'Machone Maintenance' Subject: RE: Ops Specs Need your HAPP# And some details ofthe Radar failure? Doug Ray Global Aviation Services, Inc. 281-443-3533 281-443-0332 fax dray5@global-aviation.net -----Original Message----- From: Machone Maintenance [mailto:maintenance(il'lTioaci.coml Sent: Thursday, May 15, 2014 11:24AM To: DougRay Subject: RE: Ops Specs Okthanks you needto call me and we will go overthe signoff. -----Original Message----- From: Doug Ray fmailto:drav5Wglobal-**~viatio.n~'l'Cl]** Sent: Thursday, May 15, 2014 8:38 AM To: Machone Maintenance Subject: RE: Ops Specs We found faulty socket in the cannon plug that powers the OAT indicator, we are moving forward with thisdiscrepancy. Doug Ray Global Aviation Services, lnc. 281-443-3533 281-443-0332 fax dray5@global-aviation.nct-----Original Message----- From: Doug Ray [mailto:dra\'5(ifg1oba1- aviation.net] Sent: Wednesday, July 27, 2016 9:08 AM To: Hernandez, Ricardo (FAA) Subject: FW: Invoice -----Original Message----- From: Doug Ray [mailto:dra\'5@globalaviation.net] Sent: Thursday, May 15,2014 12:33 PM To: 'Machone Maintenance' Subject: FW: Invoice See attached invoice and Credit card form for services. DougRay Global Aviation Services, Inc. 281-443-3533 281-443-0332 fax dray5@global-aviation.net

### BUSH INTERCONTINENTALAIRPORT Gl,OBALAVIATiON SE.fW!CES.1NC. 17725j,EK. BOULEVARD, SUITE 207 H,OtJSTON,TEXAS 770;32-o$013 U.S.A.


### CREDIT CARD AUTHORIZATION FORM

Please fill outthe following form entirely. I hereby authorize Global Aviation Services, Inc. to proceed with processing of payment ofmy purchase to the following credit card: Customer Name:--------------------- Type ofCredit Card: 

## 0 Visa 

## 0 MasterCard 

## 0 American Express Credit Card#:-------------------- Expiration Date:

_______ _ Security Code:

____ _ Amount of Purchase:------------------ Credit Card Surcharge:------------------ Total Amount Authorized:---------------- Purchase Order#:------'--------------

Below section required to completetransaction: Name on credit card:

________________ _ Credit Card Billing Address:-------------,----- Credit Card Billing City/State:---------------- Credit Card Billing Zip Code:

________________ _ Print Name & Title:

__________________ _ Signature/Date:---------------------

TELEPHONE (281} 443-3533 '" FAX (281) 443-0332

### From: Doug Ray [mailto:drayS@qlobal-aviation.net] Sent: Friday, May 16, 2014 8:31 AM To: 'Machone Maintenance' Subject: Radar Albert, We couldn't duplicate anytrouble with your radar in Citation N881A. Aircraft is ready, I need to inform accounting who will be paying? Doug Ray Global Aviation Services, Inc. 281-443-3533 281-443-0332 fax drayS@globa1-aviation.net

### Brown. Glenn (FAA) From: Sent: To: 

### Cc: Subject:

Ms. Toscano, Hernandez, Ricardo (FAA) Wednesday, July 27, 2016 8:39 AM Toscano, Lisa M (FAA) Brown, Glenn (FAA); Frable, Keith A (FAA); Serrano, Gabriel (FAA) Doug Ray Global Aviation Services

This morning I spoke to Doug Ray from Global Aviation Services in Houston TX. The repair station that conducted maintenance on N881A operated by Mach One Air Charters in Chino CA. Mr. Ray stated that he remembered that the maintenance request came from the home base in Chino, from the Director of Maintenance for Mach One, it did not come from the pilots. Regards,

Aviation Safety Inspector ricardo.hernandez@faa.gov AWP-RAL-FSD0-21 6961 Flight Road Riverside, California 92504 951-276-6701 Ext 235

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