02/2G/2010 1G:58 FAX 2024935142 FAA + DMS 

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0001/012 

scorrR. MOKRis 

FAA OFFICE OF RF,GIONAL COUNSEL 

l601.LiNi)Avi;.,sw 

REN'ION, WASlirMGTON 98057 

TELEPHONE: 425.227.1417 

FArsiMlI.P.: 425.237.1007 

FEB 1 7 20W 

^ :iCKET 

UNI lED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of: 

Frontier Airlines, Inc. 

TAA. DOCKET CV 09NM0013 

FAA Case No. 2009NM21()()2() 

DMS No. FAA-2(J()9-1()4() 

-Tudge Goodwin 

COMIM.AINAINT'S RESPONSE TO RESPONDENT'S INITIAL DISCOVERY 

REQUESI 

Complainant, through her undersigned coiuisel, hereby responds to Respondent's initial discovery 

request, served on January 6, 2010. Complainant reserves the right to supplement this response if 

additional documents or witnesses come to its attention. 

DOCUMENT REQUESTS. 

1. A copy of any and all documents identified in your responses to the accompanying 

interrogatories. 

Rc3por.gc: See attached or refer to response lo Requests for Produciion Nos. 2 and '.i. 

2. A copy of your entire file with respect to Livcstigaiion and Case No. 2008NM210020, 

including a complete copy of the Enforcement. Investigative Report ('EIR'"), and a copy of 

all memoranda, notes, e-mail, bulletins, advisories or other writing of any kind or description 

prepared by any person employed by the FAA concerning this case. This may include, but is 

not limited to, any recommendation whenever made as well as any documents, notes, e-mail, 

memoranda, bulletins, advisories or other writing related to any review of this case. 

RcspoJisc: Objection overly broad and requests information concerning the Agency's 

deliberative process, attorney-client privileged information and attorney work product. 

Complainani's Respon.sc to Rcspondeni's Iniii^J 

Discovery Request 

FiOnlier Airlines - CP09NMOOI3 

Puyc I of J 2 

SCOriR. MoKBi.'i, FA A ATTORNEY 

TE[,: 42.'5.227.14I7; FAX: 425.227.1007 
02/2G/2010 1G:58 FAX 2024935142 FAA * DMS 0002/012 

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product documents which are withheld and will not be further identiiiod as well as privileged 

communications concerning this mailer between counsel and FAA officials. 

Subject 10 these objections, the Complainant responds as follows: 

- Section C of the case file has previously been produced and will not be produced anew. This 

copy was provided on March 27, 2009, However, there may be additional Items of Proof (lOFs) 

that were not produced in this response. ITiercfore, out of an abundance of caution the Response 

provides copies of iOPs 17 - 19, and 21 - 32. There was no lOP 20. 

- The Agency has a copy of the presentation materials presented by Frontier during the 

September 9, 2009 informal conference. They also arc not being copied as they were previously 

provided by Frontier. However, if it requests another copy it will be provided. 

- Documents in addition to those described above and not privileged arc attached and are aij 

follows: 

Statement of John Tafi, dated September 17, 2009 (I page) 

Statement of William Hoddenbach, dated September 16, 2009 (1 page) 

Email subj: Fw: Frontier's Brake fm Tom Sciacca to Scott Morris, dated 01/04/2010 

(3 pages) 

Frontier Document Control Procedures, 05.10 Technical Publications Department, 

dated 06/11/07, pages 1 and 2. 

Fronficr Airbus MEL/CDI, Preamble, 10.05, dated 12/14/07, pages I -16 

Fronfier Dispatch release printouts (5 pages) 

Resume of Peter S. Neff (4 pages) 

Resume of Ron Reeves (4 pages) 

Resume of Tom Sciacca (3 pages) 

Resume of JC Moreno (1 page) 

Resume of led Hutton (3 pages) 

Resume of Brian Schooley (2 pages) 

Frontier GMM 15.07, Daily Check Program (4 pages) 

Color photos of brake from CoiTinuter screen (2 pages) 

Frontier's violation history (7 pages) 

FAA MMEL Policy Letter 25, Revision 14 (7 page.s) 

I'rontier J-og pages 416096,416099, 419202, 419203, and 419205 (5 pages) 

a. 

b. 

c. 

c. 

f. 

gh. 

Jm, 

n, 

0. 

P3. A copy of any and all documents tliat contain any type of report or information prepared by, 

conveyed to, or received by, any employee of the FAA that touches upon or concerns the 

facts and circumstances siurounding the alleged violation and the subsequent I<"AA 

investigation. 

Response: Objection overly broad and requests information concerning the Agency's 

deliberalive process, attorney-client privileged informafion and attorney work product. 

Ci'tmplainam's Response lo Respondent's liiilial 

Discovery Request 

Froniier Airlines CPOdNMOOl? 

Page 2 of 12 

SCOITR. MoHJtis:. 1"AA ArroRNEV 

TEL; 425.227.1417; FAX: 42:i.227 1007 
02/2G/2010 1G:58 FAX 2024935142 FAA •>• DM S 0003/012 

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Documents being withheld include the EIR sections A and B, the EDT worksheet, and 

coordinating Memoranda to AGC-300 concerning this case. In addition there are attorney work 

product documents which are witWteld and will not be further identified. Otherwise refer 10 

response 10 Request for Production 2 above. 

4. A copy of any and all documents containing statements provided by FAA employees who 

have knowledge of the alleged violation and that relates to the alleged violation. 

Response: See response to Request for Production 2, above. 

5. A copy of any and all documents containing statements provided by any other person, not 

covered in Requests for Production Nos. 3 and 4, who has knowledge the alleged violation 

and that relates to the alleged violation, including employees or agents of Frontier, the 

Aircraft manufacturer, and any other entity involved in ihis matter. 

Response: Sec response to Request for Produciion 3, above. 

6, A copy of all correspondence that FAA employees have received regarding this case as well 

as all related enforeemem cases. 

Response: See responses to Request for Production Nos. 2 and 3. All non-privikgcd related 

correspondence is attached. 

7. A copy of all related civil penalty actions, guidance tables, or sanction information on which 

the FAA relied in arriving at the recommended civil penalty action in this case. 

Response: Sec FAA Order 2150.3 B, a copy of which is available on the FAA website 

(www.faa.gov) and so it is not being produced. Copies of the files related to prior civil penalty 

actions will not be produced as thai v^ould be unduly burdensome and not lead to relevant 

material to this case. However, an extract of the electronic record of Frontier's violation 

history from 2003 - 2009 is attached. 

REQUEST FOR INTERROGAlORIES 

1. Please set forth in detail the exact amount of the $350,000 proposed civil penalty associated 

with each alleged violation set forth in subparagraphs ll(l)(a) through II(l)(d) of your 

Amended Complaint. 

Response: Objection. The request asks for deliberative and work product material. Without 

waiving this objection, this amount is consistent with FAA Order 2150,3B, chapter 7 and 

Appendix B. l"or multiple flight violations, those violations are capped per Chapter 7, paragraph 

Complainnni's Response (o Respondent's Initial 

Discovery Request 

iTOniier Airlines - CT09NM0013 

l'agc3on2 

ScrtnT R. MORRfS, KAA ATTORNRY 

TFL: 12.';.227.H17; I-'AX: 425.227,1007 
02/2G/2010 1G:58 FAX 2024935142 FAA •»• DMS 0004/012 

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7.b, figure 7-1, for the fligiits that occurred after the brakes was improperly MEL'd in Salt Lake 

City, UT. 

2. Please set forth in detail each fact that fomis the basis for your allegation in: 

a. Paragraph 1(5) (sic) of your Amended Complaint, that; "Frontier's GMM, section 30.05 set.s 

forth the brake wear limit for its aircrall and requires the removal of brakes when there is 1/16 of 

an inch or less wear pin showing." 

Response: Although the initial Aircraft Flight Log #416095 states that the Brake v^^as 'Beyond 

Limits', tlien it was subsequently revised to state '#2 Brake to be less than 1/16'*', Not Flush, both 

Aircraft Flight Log pages indicates that the brake met the requirements for removal and 

replacement. GMM 30.05 clearly states that during a Daily Check and Higher Check Level (SLC 

performed Heavy Check), 'Remove brakes when there is 1/16"^ of an inch or less wear pin 

showing.' 

b. Paragraph 1(8) of your Amended Complaint, that: "Frontier's CAMP prohibits the use of the 

MEL when the brake wear indicator is fliLsh or recessed in the brake housing as was the case 

here," Plea.se further specify the facts thai form the basis for your conclusion that the brake wear 

indicator was flush or recessed. 

Response: Frontier's Repair Order, dated Nov 4, 2008, provides the defect and removal 

information, which states that "During a heavy check, found #2 brake indicator below limits," 

Frontier Airlines sent the brake in question to BF Goodrich in Santa Fe Springs, California on 

Nov 7, 2008. According to ihc Overliaui Service Report from BF Goodrich (also to be added as 

an lOP), the brake pin indicator was indeed below 1/16'*' of an inch. Sec D095 and GMM 

section for MEL management by MCC. 

c. Paragraph 1(12) of your Amended Complaint, that: "The brake was overheating because it was 

not bled per the maintenance instructions specified in the maintenance manual and the MEL "M" 

procedures," 

Response: When the hydraulic line is disconnected, the brake assembly retains its pressure, thus 

causing the brake to remain in an engaged position. When the brake is 'bled', it removes the 

pressure, which disengages the brake, allowing it lo rotate without causing friction, preventing a 

heat build-up as it rotates. Even though the brake was beyond limits, ihe brake might not be 

enough to stop an aircraft durmg landing or emergency, but it will still cause a rise in temperature 

during aircraft movement if the system is not bled. See also log page documenting the BTB due 

to overheating brake and statement by Greg TafL. 

d. Paragraph 1(13) of your Amended Complaint that: "Frontier Maintenance Control Center 

(MCC) called SLC contract maintenance and directed them lo re-bleed the HI brake assembly per 

MEL 32-42-01 A." 

Complainant's Response to Respondent's Initial 

Discovery Request 

Frontier Airlines - CP09NM00I3 

SCOTT R. MORHIS, FAA ATTORNEY 

TEL: 425.227,Ml7; FAX: 425.227.1007 
02/2G/2010 1G:59 FAX 2024935142 FAA DMS 21005/012 

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Response: SLC contj-act maintenance was in contact with MCC that morning. After the aircraft 

had a 'Block Turn Back (BTB)' due to excessive heat build-up on the U-2 wheel, MCC instructed 

contract maintenance to re-bleed the brake. All contract maintenance providers (outside of DEN, 

PHX, MCf) arc instructed to get a hold of MCC to get instructions regarding any maintenance to 

be performed and how to sign off an Aircraft Flight Log. See GMM procedures for MCC al 

SLC; the log page documenting the BTB due to brake overheating; and MEL 32-42-01A 

0. Paragraph 1(14) of your Amended ComplaiiU that: After the brake was re-bled, Frontiei" 

operated the N938FR for eleven (11) flights while in an unairworthy condition because the # 2 

wheel brake was worn beyond limits and improperly deferred." Please further spccily the facts 

that form ihe basis for your conclusion ihat tlie brake was improperly deferred. 

Response: MKL 32-42-01A provides dispatch for an inoperative brake. Tliere is no MEL 

dispatch for a brake 'beyond limits'. According lo ihe mechanic and MCC that evening, the 

brake was beyond limits, and it was deferred improperly under those pretenses. By Frontier 

allowing the brake to be incorrectly MEL, not finding out that there was a brake and available 

manpower on station that evening, noi notifying DEN of an impending brake change (it flew in 

and out of DEN more than 5 times). Frontier allowed the aircraft to fly in an un-airworthy 

condition. See statement of Greg Tafl and William Hoddenback, Frontier's SLC inventory 

history and its operation report Oct 29 - 31, 2008 

f Paragraph 1(15) of your Amended Complaint, thai: "Further, on October 31, 2008, Aviation 

Safety Inspectors, while performing surveillance discovered that the mechanic that performed the 

heavy check inspection back on October 28, 2008 had failed lo comply with the MEL "M" 

procedure becaase he failed to properly secure the brake ho.se." 

Response: Both AS! Moreno and Reeves saw aircraft N938FR at the gate, they decided lo take a 

look at the brake because it was noted earlier that day that it was on the MEL list. When they 

approached the aircraft, they were greeted by two Frontier mechanics. As they all looked at the 

brake in question, it was immediately notice by all that it was incorrectly secured. The MEL 

instructs to wind lock-wire around the tape attached to the hydraulic sleeve, and then attach the 

loose hydraulic sleeve to the hexagonal head of ihe fixed half coupling. The hydraulic .<;!ec\e v.. i^ 

secured to another hydraulic line using a strap-tie. See log page. 

g. Pajagiaphl(16)of your Amended Complaint, that: "Frontier operatedN938FR in violation of 

its operations specifications." 

Response; Operation Specification D072, CAMP, is summarized simply when it states tliat each 

aircraft and its component parts, accessories, and appliances are maintained in an airworthy 

condition in accordance with the time limits for the accomplishment of the routine checks of the 

aircraft. When Frontier's MCC incorrectly authorized the MEL for the brake. Ops Specs D072, 

CAMP, was circumvented and Frontier violated the FAR'.s. When a MEL is applied lo an 

aircraft, the type certificate is temporaiily amended. Wlien the MEL procedures are not 

Complainant's Response to Respondent's Initial 

Discovery Reqiicsl 

Krortier Airlines - CP09N.MOOI3 

Page 5 of 12 

SCOTTR. MORJUS, l-'AA AntJRNl-JY 

TI-.I,; <J25.227.1417; h'AX; 425.227.1007 
02/2G/2010 16:59 FAX 2024935142 FAA + DMS gl006/012 

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accomplished per the MEL, the aircraft is no longer airworthy because it no longer conforms to 

the amended type certificate. MEL conditions and limilalions do not relieve the operator fiom 

determining that the aircraft is in condition for safe operation with items of equipment 

inoperative. When using the MEL, compliance with the stated intent of the preamble, definitions, 

and the conditions and limitations specified in the MEL is required. 

3. Please identify each individual willi personal knowledge of the alleged violation, including 

wiihoui limitation, each employee or agent of the Federal government or any other person 

who assisted in the investigation of the mailers set forth in the Amended Complaint. 

Response: The following persons are disclosed: 

Principal Maintenance Inspector Tom Sciacca 

Rocky Mountain CMO 

26805 E. 68* Ave., #200 

Denver, CO 80249-6361 

(303)342-1100 

Summary of Testimony: PMI Sciacca will testily about the Frontier's CAMP program; 

integration of the CAMP program; troubleshooting procedures; required logbook entries; 

requirements to clear a log entries; compliance with the MEL and the required maintenance 

associated wiih MELing the brake. He will render an opinion concerning the violations in the 

Complaint, that the aircraft was unairworthy, that improper maintenance was performed on the 

aircraft, that the maintenance was improperly deferred, and what were the proper maintenance 

procedures that Frontier should have followed under its CAMP . 

Inspector .IC Moreno 

Rocky Mountain CMO 

26805 E. 68'" Ave., #200 

Denver, CO 80249-6361 

(303)342-1100 

Summary of Testimony;. 

Inspector Moreno will testify about his investigation and his personal observations of the brake 

on N938FR; MEL procedures; the brake system; required maintenance entries; documentary 

evidence he gathered; statements gatliercd during the investigation; Frontier MCC operations; the 

existence of a brake at SLC; FAA Order 2150.3B sanction guidance. He will render an opinion 

concerning the violations in the Complaint, that the aircraft was unairworthy, that improper 

maintenance was performed on the aircraft, that the maintenance was improperly deferred, and 

what were the proper maintenance procedures that F'ronticr should have followed under its 

CAMP. 

Inspector Ronald Reeves 

Seattle FSDO 

Compliiinant'.s Response to I^spondcnt's Initial 

Discovery Request 

hionticr Airlines - CP09NMOOI3 

Page 6 of 12 

Scorr R, MORRIS, KA A ATICJRKEV 

IT-L: 425.227,HI7; FAX: 425.227.1007 
02/26/2010 16:59 FAX 2024935142 FAA DMS 21007/012 

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1601 LindAve, SW 

Rcnton, WA 98057 

(425)227-1802 

Summary of Testimony: Summary: inspector Reeves will testify about his investigation and his 

personal observations olthc brake on N938FR; the existence of a brake ai SLC; MEL 

procedures; the brake .system; required maintenance entries; documentary evidence he gathered; 

statements gathered during the investigation; Frontier MCC operations; FAA Order 2150.3B 

sanction guidance. He will render an opinion concerning the violations in the Complaint, that the 

aircraft was unairworthy, that improper maintenance was perfonned on the aircraft, that the 

maintenance was improperly deferred, and what were the proper maintenance procedures that 

Frontier should have followed under its CAMP. 

Inspector Andy Gambardella 

Rocky Mountain CMO 

26805 E. 68^** Ave., #200 

Denver, CO 80249-6361 

(303)342-1100 

Principal Operations Inspector Steve Scully 

Rocky Mountain CMO 

26805 E. 68^" Ave., #200 

Denver, CO 80249-6361 

(303)342-1100 

Airworthiness Supervisor Joe Hanley 

Rocky Mountain CMO 

26805 E. 68"' Ave., #200 

Denver, CO 80249-6361 

(303)342-1100 

Rich Palmersheim 

Frontier Airlines 

7001 Tower Road 

Denver, CO 

FJ Riggio 

Frontier Airlines 

7001 Tower Road 

Denver, CO 

Dave Pagelinan 

Millionaire 

303 North 2370 West 

CotnpIainanl'.'S Response lo Respondent's Initial ScOTTR, MuRRIS, 1-AA Ai lOiiNiir 

Di.seovery Request 

Frontier Airlines - Cl^09NMOO 13 Tlvl,; 425.227,) 417; pAX: 425.227.1007 

Puj4c 7 of 12 
02/2S/2010 1G:59 FAX 2024935142 FAA QMS 12008/012 

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Salt Lake City, UT 84116 

(801)359-2085 

Summary of Testimony; 

John G. Taft 

Millionaire 

303 North 2370 West 

Salt Lake City, UT 84116 

(801)359-2085 

Summary of Testimony: See his v/ritten statement 

David Krill 

Frontier Airlines 

7001 Tower Road 

Denver. CO 

William Hoddenbach 

Director of Maintenance 

Million Air - SLC 

303 North 2370 West 

Sail Lake City, UT 84116 

(801).933-7542 

Summary of Testimony: See his written statement 

4, Identify the name, title, address and business or home telephone number of each v^atness 

whose testimony the FAA intends to proffer, and provide a short statement of the substance ol" 

the testimony to be offered by each witness in his or her testimony. 

Response: Objection to the extent of the home telephone number. However a business 

telephone number will be provided. The indiv iduals with Sunuiuiries in Rosponse a^ 

Interrogatory No. 3 above are those the Agency currcnlly anticipates using as witnesses in this 

case. 

In addition to those specifically referenced in Kesponse to Inierrogatory No. 3, the following 

additional witnesses are disclosed: 

Airworthiness Specialist Ted Hution 

ANM-240, Suite 560 

1601 Lind Ave., SW 

Renton, WA 98057 

(425)227-2240 

Complainant's Response to Responduni's Initial 

Di.ICO very Request 

Frontier Airlines - Cr09NM0013 

Page 8 of 12 

iioo'i'r R. MouRis, FAA ATTORNEY 

TFX: 425.227.1417; PAX: 425,227.1007 
02/26/2010 16:59 FAX 2024935142 FAA + DMS [009/012 

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Summary: FAA Order 2150,3B sanction guidance; maintenance records and requirements for 

Part 121 operators; CAMP requirements. lie will render an opinion concerning the violations in 

the Complaint, that Frontier violated its CAMP, that the aircraft was unairworthy, and the proper 

procedures the mechanic and Frontier shouid have foiiowcd. 

Airworthiness Specialist Brian Schooley 

ANM-240, Suite 560 

1601 LindAve., SW 

Renton, WA 98057 

(425) 227-2240 

Summary: FAA Order 2150.3B sanction guidance; maintenance records and requirements for 

Part 121 operators; CAMP requirements. He will render an opinion concerning the violations in 

the Complaint, thai Frontier violated its CAMP, that the aircraft wa.s unairworthy, and the proper 

procedures the mechanic and Frontier should have followed. 

Peter S. Neff 

Aircraft Evaluation Group 

1601 Lind Ave, SW 

Renton, WA 98057 

(425)917-6628 

Currently detailed at Flight Standards, AFS 202 in Washington, D.C. 

Summary: FAA policy on use of a MEL. Application of the Airbus/Frontier's MEL to this case, 

explaining the requirements of the provisions of the Frontier MEL Main Braking System 

provisions to the facts of this case. He will render an opinion concerning whether or not Frontier 

complied with its MEL, why not that Frontier violated its CAMP, that the aircraft was 

unairworthy, and the proper procedures the mechanic and Frontier should have followed. 

Note: For interrogatories 3 and 4 above, the Agency lias not made a linal determination of which 

witnesses will testily lo which violations. Flowever, at a minimum AS! Reeves, AS I Moreno, 

and PMI Sciacca will testify concerning these violations. 

5. Please identify the dates and times that the individuals identified in Interrogatories Nos,. 3 

and 4 will be available for a deposition by Frontier's counsel, Pillsbury Winthrop Shaw 

Pitlman LW, in Denver, CO. 

Response: Currently, the following days seem to work for I-'AA employees. 

a. 

b. 

c. 

d, 

e. 

March 3-5 

The week of March 22 (less Inspector Reeves) 

The week of April 12 

April 22, 23 

The week of April 26 

Complainani'.s Response to Respondent's Initial 

Discovery Request 

Frontier Airlines - C'P09NM0013 

PttgcVon2 

scorr R, MORRIS, l-AA .'\TrORNty 

Tl'l,; 13.5,227.1417; FAX: 425.227.1007 
02/26/2010 16:59 FAX 2024935142 FAA DMS 2)010/012 

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f The first 3 weeks in May 

Later dates may be available as well. 

6. With respecl to each witness named in Interrogatory No. 4 who is an expert witness: (a) 

identify the topics about which the expert is expected to testify; (b) describe ihe substance of 

ihe facts and opinions to wliich ihe expert is expected to testify (c) provide a summary oJ" 

the basis for each opinion; and (d) provide a copy of any document describing the expert's 

professional qualifications, if the Complainant intends to introduce into evidence or otherwise 

rely on said document. 

Response: See responses to intenogatory nos. 3 and 4. All FAA employees whose name is 

followed by a summary of expected testimony may also be quahfied a-s an expert witness as 

referenced in their summary of expected testimony. See attached copies of the Agency's expert 

witnesses qualifications. 

7. To the extent the Complainant's response to the above questions do not include it, provide 

statements of all individuals who cither .spoke to, or were interviewed by, the Complainant 

regarding this case. 

Response: Objection concerning attorney work product. None other are currently known. 

8. Identity and produce copies of any and all documents on which the Complainant anticipates 

relying, or will rely, in furtherance of the case it will present in this case before the 

administrative law judge. This request includes, but is not limited to, documents tliat the 

Complainant intends to introduce into evidence. 

Response: See the previously provided documents, the documents produced by Frontier during 

its September 9, 2009 informal conlerence, and the documents attached to this response. 

9. Identify with specificity the documents and/or witnesses' le.stimony that the FAA intends lo 

produce in support of and set forth in detail each fact that forms the ba.sii; tor. iis iiilcgation 

that Reijpondent Froniicr violated 14 C.F.R. § 119.5(g). 

Response: See the previously provided documents, the documents produced by Froniicr during 

its September 9, 2009 inibrmal conference, and the documents attached to this response. In 

particuUu-, see the air carrier certificate, OpSpec D085 and 1)072, exuracls of its GMM, and MEI. 

10. Identify with specificity the documents and/or witnesses' testimony that the FAA intends to 

proffer in support of, and set forth in detail each fact that forms ihe basis for, its allegation 

that Kespondeni Frontier violated 14 C.F.R. § 119.5(1). 

Complainani's Response to Respondent's Initial 

Di.scoveiy Request 

h'rontici' Airlines - CPO^NMOOU 

I'ajcie 10 of 12 

SCOTT R. MORRIS, I-AA AnonNi'V 

lEU: 425.227,1417; FAX: 425.227,1007 
02/26/2010 16:59 FAX 2024935142 FAA DMS 0011/012 

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Response: See the previously provided documents, the documents produced by Frontier during 

its September 9, 2009 inibrmal conference, and the documents attached to this rxisponge. 

11. Identify with specificity the documents and/or witnesses' testimony that the FAA inlcnd.s lo 

proffer in support of, and set forth in detail each fact that forms the basis for, its allegation 

thai Respondent Frontier violated 14 C.F.R § 121.153(a)(2), 

Response: Sec the previously provided documents, the documents produced by Frontier during 

its September 9,2009 infonnal conference, and the documents attached to this response. See in 

particular, the a/c flight logs and extracts from Frontier's GMM and MEL. 

12. Identify with specificity the documents and/or witnesses' testimony that the FAA intends to 

proflcr in support of and .'5et forth in detail each fact thai fomi the basis for, its allegation char 

Respondent Frontier violated 14 C.F.R. § 121,628(a)(5): 

Response: See the previously provided documents, the documents produced by Frontier during 

its September 9, 2009 informal conference, and the documents attached to ihis response. 

Submitted thi.s 3rd day of Fcbrutu-y 2010 

R. Morris 

FAA Enforcement Attorney 

Complainunt's Response to RespondenCs Initial 

Di-scovery Request 

Fninlier Airlines - d'OWMOOl ?< 

Pujje II of 12 

Scorr R.MOKRI.5, FAA ATTORNEY 

TP.l,; 425.227.1417; FAX; 425,227.1007 
02/26/2010 17:00 FAX 2024935142 FAA DMS @!012/012 

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CERTIFICATE OF SERVICE 

1 hereby certify that the foregoing Coniplainant's Initial Response lo Respondent's Initial 

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

this date, to the following: 

The Honorable Richard C. Goodwin (without Exhibits) 

Office of hearings, M-20 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor, Rm El 2-320 

Washington, D.C. 20590 

TEL: 202.366.2139 

FAX: 202.366.7536 

Federal Aviation Administration (without Exhibits) 

800 Independence Avenue SW 

Washington, D.C. 20591 

Aim: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building - Suite 2W1000 

FAX: 202.493.5020 

The foregoing Complainant's Initial Response to Respondent's Initial Discovery Request has been 

served via Federal Express Courier to and Fax to: 

Jennifer E. Trock, Esq. 

Pill.sbury Winthrop Shaw Pittman, LLP 

2300 N Street, NW 

Washington, D.C. 20037-1122 

TEL: 202.663.8000 

FAX: 202.663.8007 

I.>at.ed thi.s 3rd day of Februaiy, 2010, 

MOIFAIR CHIN 

Office of Regional Counsel (ANM-7) 

Federal Aviation Administration 

1601 LindAve. SW 

Renton, WA 98057 

425.227.2160 

Cornplaiminl's Response lo Respondent's Inilial 

Discover)' RcqncM 

Frontier Airlines - CP09NMO013 

Page 12 of 12 

ScOff R. Mounts, 1-AA.A.riOH.NtY 

TO.: 425.227,1417; FAX: 425.227,1007