JEFFREY HARPER FAA OFFICE OF REGIONAL COUNSEL 1601 LIND AVENUE SOUTHWEST RENTON, WASHINGTON 98057 TELEPHONE: (425) 227-2161 FACSIMILE: (425) 227-1007 

# RECEIVED NOV
... 52012 

# HEARING DOCKET
UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS

WASHINGTON, D.C.

Inthe 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 Pursuantto 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. Complainantis aware ofand understands the continuing nature ofhis discovery obligation. This is not a complete production; in light ofexpansive scope ofa number ofRespondent's Requests, records reviewto 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 substantiveresponse is provided, the substantiveresponse is provided without waiving the objection. All responses are subjectto objections as documented inthe privilege log provided contemporaneously with these responses. Drafts ofpleadings, to include copies with commentsbyFAA personnel,and other documents generated in anticipation oflitigation, will not beproduced, 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 ofRepair·

... 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." Dueto security measures placed onthose files by Respondent, Bates numbers couldnot actually be applied. These files are included withinthe PDF portfolio entitled "DocumentProduction (Set 04)(Redacted)(CertificationDocuments-

### -------m~~~~nL~d~'-------------------------------------------- Respectfully submittedthis 31stday ofOctober, 2012.

FAAAttorney JMH/mas

Complainant's Responses to Respondent's Requests for Production Leading Edge Aviation, Inc. DMS Nos. FAA-2012-0783 Page 2 of3 JEFFREYM. HARPER, FAAATTORNEY 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 (withoutproduced documents) this date, to the following: The Honorable Richard C. Goodwin Office ofHearings, M-20 1200 NewJersey Avenue, S.E. (E11-310) Washington, D.C. 20590 TEL: (202) 366-2139 FAX: (202) 366-7536 Federal AviationAdministration (Original and one copy) 800 Independence Avenue SW Washington, D.C. 20591 Attn: Hearing Docket Clerk, AGC-430 Wilbur Wright Building- Suite 2Wl000 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 ofRegional 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. JEFFREYM. HARPER, FAAATTORNEY TEL: 425.227.1417; FAX: 425.227.1007 DMS Nos. FAA-2012-0783 Page 3 of3