07/22/201 0 15:4 3 FAX 2024935U 2 FAA •» QMS 0001/004 

UNITED STATES OF AMERICA ,.,.,-., . r^." ; p r-n^ 

DEPARTMENT OF TRANSPORTATION" ^ -"' 

I Vl 2 2 2010 

OCKET 

§ 

§ 

In the Matter of: § FAA Docket N0.CPIOSWOOO6 

§ HON. RICIIARD C. GOODWIN 

AMERICAN AIRLINES, INC. § DMSNo. FAA-2010-0532 

§ 

§ 

COMPLAINANT'S INTERROGATORIF.S AND 

REOUEST FOR PRODUCTION OF DOCUMENTS 

• C D 

--a 

C 3 

TO: AMERICAN AIRLINES, INC. 

Evan P- Singer, 

Jones Day 

2727 North Harwood St. 

Dallas, TX 75201-1515 

Pursuant to Rule 220 of the Rules of Practice (14 C.F.R., Section 13.220) Complainant requests that 

the Respondent, answer the following interrogatories and produce copies of the requested documents 

by mailing them to Yolanda Ayala Dernal, Office of the Regional Counsel, Federal Aviation 

Administration, Southwest Region, Fort Worth, Texas 76193-0007. 

These requests are deemed continuing, and any information secured aller answering and/or supplying 

the requested answers or documcnis/iiems is to be supplied by supplemental production pursuant to 

Section 13.220. 

DEFINITIONS 

1) "Documents", shall mean, regardless of origin or location, any handwriting, note, letter, 

manual, memorandum, record, report, statement, study, drawing, sketcii, photograph, telegram, lelex, 

or message, whether reported, transcribed, punched, taped, filmed or graphically represented in any 

manner or material of any kind in the possession of subject to the control of, or within the knowledge 

of, the Respondent's and/or his employees, agents, consultants, experts or contractors. 

2) "Identity" and/or "slate the identity of with reference to individuals means state the name, 

current or last known address, employer and job description or title, and telephone number. 

3) "Identify all documents" mean.s state the date, and author, unless apparent from the document. 

4) As listed herein, singular pronouns also include the plural. 
07/22/201 0 15:4 3 FAX 202493514 2 FAA •> DMS 0002/004 

INTERROGATORIES AND REQUESTS FOR DOCUMENTS TO BE PRODUCED 

1. Identify each person whom you expect to call as a witncs.<! at the hearing of this 

matter, 

2. State the subject matter on which you expect each person to testify, ilic substance of 

the facts and opinions, if any, and a summary of the grounds for each opinion. 

3. Identify and produce all tangible reports, documents, photographs, videotapes, 

diagrams, physical models, compilations of data, and other material.'? prepared by an 

expert or for an expert in anticipation of the expert's testimony on behalf of 

Respondent at the hearing or a deposition for this enforcement action. 

4. Identify and produce all tangible reports, document-^, photographs, videotapes, 

diagrams, physical models, compilations of data and other materials prepared by an 

expert used for consultation which forms a basis cither in whole or in part of the 

opinions of an expert who is to be called as a witness by Respondent for this 

enforcement action. 

5. Identify and produce all resumes or curriculum vitae of any experts or rebuttal experts 

which you may call to testify at the hearing of this matter or of any consulting expert 

who has generated any document reviewed by a testifying expert or rebutt:al expert. 

6. Identify and produce all documents sent by, received from, concerning or reviewed by 

any experts, including rebuttal experts who will or may testify at the hearing. 

7. Identify and produce all documents evidencing, reflecting, or relating to any fee or 

compensation arrangements or agreements you have with any expert witness. 

8. Identify and produce all documents pertaining to the location and identity of any 

persons with knowledge about the Incident or persons having knowledge of other 

facts relevant to this enforcement action. 

9. Identify and produce all written documents, relating to each conversation between 

Respondent and each person who Respondent intends on calling as a witness in this 

matter in which the matters in the Complaint were discussed. 

10. Identify and produce all correspondence between Respondent and each person 

Respondent intends to call as a witness in this matter. 

11. List all affirmative defenses that Respondent intends to raise at the hearing in this 

matter. 
07/22/201 0 15:4 4 FAX 202493514 2 FAA •> DMS 12003/004 

12. For each affirmative defense, identify and produce all documents which support this 

defense. 

13. Identify and produce all documents evidencing, reflecting, or relating to the details or 

events surrounding the Incident, including but not limited to all notes or reports 

relating to the Incident and all recordings and statements given in connection with the 

Incident. 

14. Identi fy and produce all picmres, photographs, slides, drawings, graphs, cliarts, 

videotapes, recordings, or other visual or audio representations demonstrating, 

reflecting, portraying, or intending to demonstrate, illustrate, or recreate the Incident. 

15. Identify and produce all documents, including photographs, audio visual tapes, or 

films, portraying or depicting the Incident site. 

16. Identify any physical evidence pertaining lo the Incident which is in the po.ssession, 

custody, or control of Respondent, 

17. Identify and produce all documents evidencing or relating to statements taken from 

Re.spondent or from any of Respondent's supervi.sors, fellow employees, agents, or 

representatives regarding the Incident. 

18. Identify and produce all documents concerning the Incident prepared by Respondent. 

19. Identify and produce a copy of all information stored as computer data and relating vo 

or evidencing Respondent's violation of Federal Aviation Regulation.^ a.? described in 

the Complaint. 

20. Identify and produce all documents relating to or evidencing Respondent's violation of 

Federal Aviation Regulations as described in the Complaint. 

21. To the extern not encompassed in your response to any of the foregoing items, identify 

and produce all documents upon which you expect to rely at the hearing or introduce 

as evidence in .support of your position at the hearing in this matter. 

Respectfully submiited, 

LYNETTE WORD 

Regional Counsel 

Southwest Region 

Yolanda Ayala Bcmal 

Attorney 
07/22/201 0 15:4 4 FAX 202493514 2 FAA •> DMS @l004/004 

Federal Aviation Administration 

Office of the Regional Counsel 

(817)222-5070 

FAX 222-5945 

CERTIFICATE OF SERVICE 

1 hereby certify that on July 21, 2010, an original and one copy of COMPLAINANT'S 

INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS was sent by 

Federal Express Mail to: 

Federal Aviation Administration 

600 Independence Avenue, S.W, 

Wilbur Wright Building - Room 2 W1000 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

I hereby certify that on July 21, 2010, a copy of COMPLAINANT'S INTERROGATORES 

AND REQUESTS FOR PRODUCTION OF DOCUMENTS was sent by Federal Express Mail to: 

'! he Honorable Richard C. Goodwin 

US Deparhnent of Transportation, Office of Hearings, M-20 

1200 New New Jersey Avenue, S.E. 

East Building Ground Floor, Room E12-320 

Wa.shington, DC 20590 

Evan P. Singer, 

Jones Day 

2727 North Harwood St. 

Dallas, TX 75201-1515 

Sylvia C. Twa, Paralegal 

Office of Regional Counsel 

Federal Aviation Administration 

Fort Worth, TX 76137 

Date; July 21, 2010