JEFFREY HARPER 

FAA OFFICE OF REGIONAL COUNSEL 

1601 LIND AVENUE SOUTHWEST 

RENTON, WASHINGTON 98057 

TELEPHONE: (425) 227-2161 

FACSIMILE: (425) 227-1007 

RECEIVED 

NOV ... 5 2012 

HEARING DOCKET 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matters of: 

Leading Edge Aviation, Inc. 

To: Leading Edge Aviation, Inc. 

FAA Case No. 2011NM070089 

DMS No. FAA-2012-0783 

Honorable Richard C. Goodwin 

Complainant's Supple.mental 

Discovery Responses 

Pursuant to 14 C.P.R.§ 13.220, and consistent with Fed.R.Civ.Pro. 26 and 34, Complainant 

supplements its responses to Respondent's Discovery Requests served September 7, 2012. 

Complainant is aware of and understands the continuing nature of his discovery obligation. 

This is not a complete production; in light of expansive scope of a number of Respondent's 

Requests, records review to identify responsive documents is ongoing. This discovery will be 

supplemented as necessary should additional responsive documents be discovered. Where an 

objection is noted, but a substantive response is provided, the substantive response is 

provided without waiving the objection. 

All responses are subject to objections as documented in the privilege log provided 

contemporaneously with these responses. 

Drafts of pleadings, to include copies with comments by FAA personnel, and other 

documents generated in anticipation of litigation, will not be produced, as privileged under 

the Attorney Work Product and Deliberative Process privileges. 

Complainant supplements its document production, previously served on October 9, 2012, 

with the enclosed documents. 
-------------------~ 

Bates Nos. 002403-002492 are designated as encompassing the file "Relocation of Repair· ... 

Station.PDF." Bates Nos. 002493-002582 are designated as encompassing the file 

"RSM_ QM- 06-27-09.pdf." Bates Nos. 002583-002672 are designated as encompassing the 

file "RSQM-Rev l.pdf." Due to security measures placed on those files by Respondent, Bates 

numbers could not actually be applied. These files are included within the PDF portfolio 

entitled "Document Production (Set 04)(Redacted)(Certification Documents-

-------m~~~~nL~d~'--------------------------------------------

Respectfully submitted this 31st day of October, 2012. 

FAA Attorney 

JMH/mas 

Complainant's Responses to Respondent's Requests for Production 

Leading Edge Aviation, Inc. 

DMS Nos. FAA-2012-0783 

Page 2 of3 

JEFFREY M. HARPER, FAA ATTORNEY 

TEL: 425.227.1417; FAX: 425.227.1007 
CERTIFICATE OF SERVICE 

I hereby certify that the foregoing Responses to Respondent's Requests for Production has 

been served via facsimile (without produced documents) and Certified Mail- Return Receipt 

Requested (without produced documents) this date, to the following: 

The Honorable Richard C. Goodwin 

Office of Hearings, M-20 

1200 New Jersey Avenue, S.E. (E11-310) 

Washington, D.C. 20590 

TEL: (202) 366-2139 

FAX: (202) 366-7536 

Federal Aviation Administration (Original and one copy) 

800 Independence A venue SW 

Washington, D.C. 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2Wl 000 

Fax: (202) 493-5142 

I hereby certify that the foregoing Responses to Respondent's Requests for Production has 

been served via facsimile (without produced documents) and Certified Mail- Return Receipt 

Requested (with produced documents) this date, to the following: 

Fred C. Begy, Esq. 

Chuhak & Tecson 

30 South Wacker Drive, Suite 2600 

Chicago, IL 60606 

Tel: (312) 855-5442 

Fax: (312) 444-9027 

DATED this 31st day ofOctober, 2012. 

Mary Ann Smith 

Office of Regional Counsel (ANM-7) 

Federal Aviation Administration 

1601 Lind Ave. SW 

Renton, WA 98057 

(425) 227-2925 

Complainant's Responses to Respondent's Requests for Production 

Leading Edge Aviation, Inc. 

JEFFREY M. HARPER, FAA ATTORNEY 

TEL: 425.227.1417; FAX: 425.227.1007 

DMS Nos. FAA-2012-0783 

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