RECEIVED 

William A. Curtright 

Respondent 

DEC 1 2 2016 

PO Box 1350 

Jefferson, OR 97352 

Telephone: (503) 209-7388 

Fax: (503) 485-0812 

HEARING DOCKET 

In The Matter Of: 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

Docket No. FAA-2015-1319 

WILLIAM A. CURTRIGHT, DBA 

R-e-s-po_n_d-en_t _____________________ _j Case No. 2014NM090046 

Judge J.E. Sullivan 

RESPONDENTS MOTION TO COMPEL 

COMES NOW Respondent, William A. Curtright, DBA respectfully files and submits 

this Motion to Compel pursuant to local rules 14 CRF 13.21 and Federal Rules of Civil 

Procedure 37(a)(1) and (2)(a)(b) Respondent hereby moves the Court be compelled to have 

Complainant respond to Discovery based on the following facts: 

1. On September 21, 2016, ALJ, J.E. Sullivan ORDERED the following: "Setting a Second 

Litigation Scheduling Conference and a Deadline to Exchange Initial Disclosures to 

September 20, 2016 and September 21, 2016 Initiation of General Discovery ... the 

parties may begin serving discovery requests pursuant to 14 C. FR.§ 13.220(b), (c), (d) 

and (e). Discovery requests must be served sufficiently early in the discovery period 

which was set for approximately sixty (60) days, to permit the service of responses (i.e., 

30 days or less after receipt) prior to the next scheduled Conference ..... A party shall 

Page 1 Respondents Motion to Compel 

Docket No. FAA-2015-1319 

Case No. 2014NM0046 

William A. Curtright,DBA 

Respondent 

Telephone: (503) 209-7388 

Fax (503)485-0812 
respond to a discovery request no later than 30 days after service of the request, unless 

otherwise agreed by the parties." Herein attached as "Exhibit A" ORDER SETTING A 

THIRD LITIGATION CONFERENE AND GRANTING/DENYING OTHER RELIEF. 

2. On October 31,2016 Respondent emailed, faxed and sent by certified mail return receipt 

(#7004-2890-0000-2884-8022) Respondents Request for Interrogatories and Production 

of Documents; and Request for Admissions to Complainant's Attorney David F. Shayne. 

Respondent received back the certified mail return receipt signed by DeeDee Smith on 

November 2, 2016 of Complainant receiving Respondents Discovery. Herein attached is 

"Exhibit B" of the Respondent Request for Interrogatories and Production of Documents 

and Request for Admissions with completed return receipt. 

A good faith effort has been made to recover the Complainant's Responses. On 

December 5, 2016, Respondent requested in writing to Complainant for a response, 

noting that if responses were not received by December 6, 2016 thirty four (34) days after 

service of Discovery, a Motion to Compel would be filed. On December 5, 2016 

Respondent called Complainant's Attorney, David F. Shayne asking for Responses. 

David F. Shayne, responded to Respondent, "I don't know why, but the discovery had 

not been docketed on my calendar." Complainant has refused to provide responses and 

has/ did not indicate that he will /would provide such information. It appears and one 

would conclude that if Complainant does not know why his discovery wasn't docketed, 

he has no business being an Attorney or once again is using trickery involved so that it 

makes the playing field unpredictable and not level. Pilots expect that there is a certain 

amount of honor, fairness and predictability with the government. As my ancestor, Fisher 

Page 2 Respondents Motion to Compel 

Docket No. FAA-2015-1319 

Case No. 2014NM0046 

William A. Curtright,DBA 

Respondent 

Telephone: (S03) 209-7388 

Fax (503)48S-0812 
Ames, Author of the First Amendment would say, "We have but a slender hold of our 

virtues; they ought therefore to be cherished with care and practiced with diligence. He 

who holds parley with vice and dishonor is sure to become their slave and victim. The 

heart is more than half corrupted, that does not bum with indignation at the slightest 

attempt to seduce it." It seems to me that the government should be held to this standard. 

Since the Plaintiff has refused to respond in a timely marmer, the Respondent moves the 

court to compel the Complainant to respond to the Discovery requests or pursuant to 

Federal Rules of Civil Procedure 37-3(A)(ii)(iii)(v)(vi) moves this court to strike all 

pleadings in whole and dismissing the action in whole with prejudice. 

Dated this 6"' day of December 2016 

Respectfully submitted, 

\) 

(;0,_~~ Dr. Wm. Ames Curtright, DBA 

Page 3 Respondents Motion to Compel 

Docket No. FAA-2015-1319 

Case No. 2014NM0046 

William A. Curtright,DBA 

Respondent 

Telephone: (503) 209-7388 

Fax (503)485-0812 
Docket No. FAA-2015-1319 

(Civil Penalty Action) 

·SERVICE LIST- BY U.S. MAIL 

ORIGINAL & ONE COPY 

Federal Aviation Administration (Fax and Certified First Class Mail) 

Attn: Hearing Docket Clerk, AGC-430 

800 Independence Avenue SW 

Washington, DC 20591 

Wilbur Wright Building, Suite 2Wl000 

Fax: (202) 267-1293 

ONE COPY 

Judge J.E. Sullivan (Fax, Email, and Certified First Class Mail) 

U.S. Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE (Ell-310) 

Washington, DC 20590 

TEL: 202-366-6941 

FAX: 202-366-7536 

David F. Shayne, FAA Attorney (Fax, Email, and Certified First Class Mail) 

Complainant's Counsel 

Northwest Mountain Region, ANM-7 

Federal Aviation Administration 

1601 Lind Ave. SW 

Renton, WA 98057 

TEL: 425-227-2165 

FAX: 425-227-1007 

Page 4 Respondents Motion to Compel 

Docket No. FAA-2015-1319 

Case No. 2014NM0046 

William A. Curtright, DBA 

Respondent 

Telephone: (503) 209-7388 

Fax (503)485-0812 
2016·09·21 12:44 DOT 2023667536 >> 

SEl:tVEI>l September 21, 2016 

IJ.S. OEJ>ARTMENT OF TRANSI'OIUATDON 

OFFICE OF HEARINGS 

WMmiNCTON, DC 

In 'f'h~ M~ttcr Of: ) 

) 

) 

) 

) 

Doci<et No. I'AA-2015-IJ 19 

WILLIAM A CURTRIGHT 

Respondent 

Case No. 2014NM090046 

OIWI!.R SETTING A THIRO UTICATHON CONFEIU!:NCE 

AND GRAN'i'ING/OILNVUNG OTi~ER REliEF 

p 1/4 

On All!jUSL I 0. 2016. an Ordel' s~tting Ll Sucond L idg:ltion Scheduling Conferenc~ und u 

Deadline to Exchll.n!i!e h1i l.iul Oisclo~urcs. und Gr~nti ng/Denyi ng Othvr Rul ier ( .. Ordd') w<~s 

filed. Amon!,l other things. this Order set a Second Rule 16 Liligniion Scheduling Ctmli:lt·encc llll' 

Tucsd<!y. September 20. 2016. at I :30 p.m. Eastet'll lime. 

011 Scpb~mhet' 9. 2016~ un Order Grunting In Pl,tt1 tho Rt1spc.111,kmt's Mo~ion Jlw Extunsic..m 

oi'Timc wo.~ 1\lcd. This Order extended the parties· cloodline l'orsetrving initial disclosure> rrom 

September 9, 2016, to September 20, 2016. 

Lakr that same cluy. on September 9. 2016.lhepl'o se Respontl~nl. Mr. William A. 

Curtright, liled the l~esrondcnt' s lnitiut Di~closures Pursuam 10 Lhc A L.l's Order of August I 0. 

2016. und FRCt' 2691(u) [sicJ. 

On s,~p!ember 19. 20 I fl. 111~. Rcspol1lkl11 lilclltl Motion tbr Dismis~al. 

On Septemb~1· 20, iO 16. the purtloR uppoared by te1ephon~ for tile Sec()nd Rulu 16 

l~itigntion Scht!duling Conl"l!tence. During this Conference the pa!'Lies discu.sst:~d u vnriely of 

liligillion procedtlntlmutters. includiniJ, the parties' initial discJosures.l11e Respondent's Motit>n 

for DismissaL the difle•·ences between disc(wery and a Freedom ol' lnl"ormmlon Act rcque~L. a 

schedule 1\,r exclmnging disc.ovcry. ~""1 n date ((Jr a Third Rule 16 Litigation Conl'crcncc. Thi~ 

o.·der codi tie~ the 01'81 rulings mode dt~rfng the September 20, 20 !6 Conl'erellCC. 

I 
2016-09-21 12:45 DOT 2023667536 >> p 2/4 

l'ursunnt to 14 C. F. R. ~§ 13 ,2()5, 13.220, and Civ. R. 16, and oftor rcvluwingall wlev~nt 

cus<JI~tw, r<)!!ulmioi1s.·stl\lcltOt·y muhodty, ~.tnd bein1:1 l'ully advised; 

l . Tltc Riisptmdent 's lli1litlcd 111<\lion l'tll" discoverY. retl\1\!Sting "o list \>I' all ilth~r 111 llll~ 

th1'0i1~ho<1t tho U nhed St<Jtcs th<H hnvc had ... lfi·i vok1us.l Acti(HlS hl'ought ugui nst them" 

(Sept~mber 9, 2016 lniti•ll Di~cl<1olll'c~, 1) is deni~!i usm1t relovan.t .t<> tho clwrgo in this 

pro~ecdinlb. To the ext.:ntthlllth~ Respondent is secldn~ to 111e a FOIA requ.,~t with tho 

FA/\, the Respondent is deemed to have mised such ~~request in the wrong i·brum. 

2. The Rcsptmdent'~ onll motion to u~tend these proceedin!JS to a date uncerlnin. so that he 

CtU1111~ a FOIA request with the FAA filr the informtllion ubt1Lil pilots (identilicd uhowl. 

is denied. 

3. Tht;Rj:!jp<mc!el1t'stu\thlt:d•Mtion l'ordiscoyery. rll_'\.u<!sting "th'lt.ollllocu•~~ntR.that hlJVI 

beenr~dttCt~d Pyl:)<tl(idShttync.' .beproclti<;Cdc. cwi.lhQUI r!;Qt\Ction'' (Seplcrnl'H!I' 9. 2016 . 

lftitiul l)lsol<lsur~s.l)is d.Cnic(J .mtliis tltnc: II' glltW]'III di~covery CKCh<tD[lll8.provc · 

iqsuf'!iel':'lll.tl1d~e~pond~nt may l'c-raisc this 1110li011. witll Ut(l.\Chlld (\()CUI1\~11tuti<lll Ulld 

pf6p~i· ~~~·g·uti1€HlL 

4. ·riwFAA 'II tirttl nwtion lor m1 immcclial<: ruling on the Rc~p<.11'\d~nt' s Scptcrhh~r 19. 2(1 I 6 

Motlun 1'01' [)isml~stlliS denlc,l. 

S, The Respondent'~ September 19, 2016 Motion tor Dismiss~! Is t-eserv~;:d ullti I alter 

Dec~mb~r8, 2016. If' general diocovery e'whttnges prove ln~uflicient. this this Motion i(H' • 1 

Dismi•~t~lrnuy b~: converted to a Suminury Judgment Motion 11fter Dc<:o~n1hur 8, 2(H6. 

6. September 2 i, 2016: lnith1tlon ol' G~ner•tl Ols~ovcry. EflectivoSepternbe~21. 2016~ 

the purtie~ m~y begin serving di~CI;)VCI'Y rc(j\IC~t~ p\lrsuonno 14 C.F.R: ~ 13,~20 (li). (c), 

(<\) tH1cl (IOJ.I)i~~ov~ry rcqueHtS must be served su!'ncicntly Cilrly in lhe discl>vcry period. 

which h~•~ hccn •ct ror "PPI'oXimttldy sixty (60) days. to permit the ~crvicc ot'r~.3ponscs 

(i.e., 30 d<1ys or k~~ ul\c1· I'Ucuipt) pri<"' w the n~xl ~el1cduled Conl~rcncc. Ucncrnl 

diSCOVCI')' includes, but is Mt limited l<l: 11(1tic~• of depOSition; I'CL]LH!SlS (\)r prmluction OJ' 

clo0Uillem~: propm111dill~ (ntcn·og<ltoric~; '"q\lesls 1·~,,. t1dmisaim1: &to. A pltrly ~h~li 

respond to <I discovery request no lmet· tllun30 days ~•Ftcr se,·vice or the request. unless 

l>lhcrwi~C Ufli'~Cd by the flUI"lico. 

7. Se1>tomber 29,2016: lnfornmi Tclephonll Conference. On September 29.2016 (2:00 

p.m. to J:OO p.m. PDT), the FAA and the Respondent shall pa11icipu1e In nn lnlbrmul 

Telephone Confe1·enco. The Resp(lnd~nl, M1·. Curtright, shall initiate the telephone cull 

Page 2 of 3 
2016-09·21 12:46 DOT 2023667536 >> p 3/4 

(ln Sopt~mb~r 29. 2016 by Cl\llingth" FI\A cclun,;el, M1·. Shayne, ut 425-227-2165 ttl 

2:OOpm. Thi$ Telephone Con/crcncc i~ 1\w the purpo~e or'condlictin~ u.pttgc-by.·pugc 

comp~ll"ison oi'the FAA lnitiull)i~clo~llt"Co whid1 wen: ruc~ivcd by the Respondent. to 

ensure that the Respondent has rec~lvcd ollthe paues or the FAA·, Initial Dlsclo~urcs. I i' 

th" partie~ wish to discuss othe1· matte1·s al"te1· the pagc-by-pag~ comJ>arison is 1\nished. 

they mtlY agree to do so. 

8. II' the September 29, 2016 In formal Tclcphon~ Conference docs nm rc::<olvc ull Mr. 

Curtright's concerns whether the Initial Disclosures he received match the cortlcntund 

numb..,roi'pllf.!O$ oi'thol FAA assen~ it mailed to him as lniti>1l Disd(l~tll'es on August II. 

2() 16. then thu Ro.~pondont nwy lilo 11 wrill"11111<>1iM lol'i"urtlw ,·eli<li'. 

9, l)uccmhcr 2, 2016: l>cndiinct'or R~~ll~'lll!in~ toOi~C(o>~~y. On oi' l!i:Hot<ll)i)c-.Jf\)oor2; 

20 ({), the partie~ ~hall .finiSh St)I"Ving ri:>Sp01lS~:! lO Ill\ yJaiJgomerlll diiiCt>Vury l"uquu,iiH. 

I . -. - ,---- <·------ .·--.-.-

1 0. lh,~ct"llbur !1. ~ll HH I :30 P-Ill· E'l"): Thii"L! Litigllfi!JJ\(Cflllfcr~ncc. ·rhc p(lf"li9S:illall 

I l~PP~'~': l:.y ... t ~.·.I_.~_ .. _P._'_,_·.'.,_·. p .. ·,·.-.~_-.:_ .•. ~ ''_.n_ .. -.• .. '".1·1· .~.~~.·.~.··._··l··.a.y •. · .. !?.~_·clo.·m·b··_-.... ~·.r. !l ... _.~l,l.·.'. 6.-.. {l:J. (J .p, '.n. - );·(}(.).p.m .. · .'.'uc·.'.'.l.c 1h~'" J: / lor" lli1rd L1t1gill1011 Cort(e,·e,ICC. I he parues shall be piiepared to d>scuss the ~tutu~ of 

Q_ discov.:ry, a schedule fQr lilillll di;;pgsltiy~ 0]1Jii(J!15, andpotcnlial henring d<l!¢~ .. :1\l 

accc>s I he Conference line, the parties shall dial 888-278-0296 and emer code 5851842. 

, J·\Jr cluri ticLttinn::; L}f thl.'l ot·dct· \H' que~tion~ with 1\.!gl\td lo lho procu.durc.u l(l hiJ followud 

in thio .:usc, pl~'''e "ontuct Mr. C<Jdy L. Smith, Attm·ney-Advi11or Ill th" Oi'li~e of" 

Hc~u·ings (202-366-6941 ). ' 

Attuohm0111: Service Lis( 

Page 3 of 3 
2016·09-21 12:46 DOT 2023667536 >> 

Docket No. FAA-20 15-1319 

(Civil Penalty Action) 

SERVICE LIST- BY U.S. MAlL 

ORIGINAL & ONE COPY 

Federal Aviation Administrntio" 

800 Independence Avenue, S. W. 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

Wllbu.r Wt·ight Building-Suite 2Wl 0001 

Mr. David F. Shayne 

Complainant '.1· Counsel 

Northwest Mountain Region, ANM· 7 

Federal Aviation Administration 

1601 Lind AvenueS. W. 

Remon, W A 98057 

TEL: 425·227-184 7 

FAX: 425·227-1007 

Dr. William Amas Curtright, DBA 

Respondent 

P.O. Box 1350 

Jefferson. OR 973 52 

TEL: 503-209-7388 

FAX: 503-485·0812 

Judge J.E. Sullivan 

U.S. Administrative J.,aw Judge 

Oftice of Heat·ings, M-20 

IJ. S. Department of Transportatil\n 

1200 New Jersey Avenue, S.E. (Ell-31 0) 

Washington, DC 20590 

TEL: 202·366-6941 

FAX: 202·366· 7536 

ONECOJ>Y 

' Se•·vic• w•• by U.S. Mall. For ~ervice in person or bY e~podited courier. use the I'OIIowlng address: federal 

Aviation Administrarlon, 600 lndepondonoe Avenuo, S,W,, Wilbu1' Wrlsht Buildil>g-Suite 2WIOOO, Woshingto11, 

DC 20591: A~ention: Heorin~ Docl<et Clerk. AOC-430. 

p 4/4 
r 

SENDER: COMPLETE THIS SECTION 

1 • Complete items 1, 2, t;tnd 3. 

7 

• Print your name and address ori the reVerse 

so tha! ~e can ·re!~rn the ""''"-'·u_yuu . 

• 

1. 

Complainant's Counsel 

.Northwest Mountain Regiori,-ANM;V 

Federal Aviation Administration 

i 1601 Lind Ave. SW -

Renton, WA 98057 

-~IJIIIIIIIIllmffillllllllllllllllfllllllll- -

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Adult Signat!Jr9 

At!ult Signature Restricted Delivery 

Certlfl9d Mall® 

Certified Mall Restricted Delivery 

.:r 

<[) OFFICIAl 

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ru Postage $ 

D Certified Fee D Pootmark D Return Receipt Fee l. D (Endorsement Required} 

D Restricted Delivery Fee ' tr (Endorsement Required) 

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ru Total Postage & Fees $ 

D Priority Mall Express® 0 Re9lstered MailTM 

0 Redstered Mall Restricted 

Delivery 

O.RetUm R.,.lptfor Merchandise · 

D Signature confirmation m . 0 Signature Confmu¢on 

Restric.teg Delivery 

Receipt 
Ames I Ames Research Inc 

From: 

Sent: 

To: 

Cc: 

Subject: 

Attachments: 

Dear Mr. Shayne, 

Ames 1 Ames Research Inc <ames@amesresearch.com> 

Monday, October 31, 2016 3:34 PM 

David.F.Shayne@faa.gov 

Ames 

FAA Case No. 2014 NM2009 William A Curtright, DBA Respondent's Requests for Interrogatories and Admissions; Request for 

Production of Documents 

DOC103116-10312016140529.pdf 

Please find attached Respondent's Requests for Interrogatories, Requests for Admissions and Requests for Production of 

Documents. I have tried to send this to you via fax three times and the fax machine has failed on your side. 

Sincerely, 

Wm Ames Curtright, DBA 

C: 503-209-7388 

-----Original Message-----

Scanned from MFP-05373780. 

Date: 10/31/2016 14:06 

Pages:66 

Resolution:300x300 DPI 

1 
William A. Curtright 

Respondent 

POBox 1350 

Jefferson, OR 97352 

Telephone: (503) 209-7388 

Fax: (503) 485-0812 

In The Matter Of: 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASIDNGTON, D.C. 

Docket No. FAA-2015-1319 

WILLIAM A. CURTRIGHT, DBA 

Case No. 2014NM090046 

Respondent 

Judge J.E. Sullivan 

RESPONDENTS' REQUEST FOR INTERROGATORIES AND PRODUCTION OF 

DOCUMENTS 

To: Complainant, Complainant of FAA Administrator Michael P. Huerta, Administrator, Federal 

Aviation Administration (the "Administrator" or Complainant") and/or its representative agent or agents, 

and/or employees In accordance with 14 CFR § 13.220 and the Federal Rules of Civil Procedure 

Rule 33 please respond to the following Interrogatories, Requests for Production of Documents, and 

Request for Admissions, separately and fully under oath. 

These discovery requests are intended to discover information and/or documents not only 

within your personal knowledge or obtainable by you, but also information in the possession of or 

obtainable by your attorneys, investigators, representatives, employees, agents, or anyone acting on 

your behalf or on their behalf. 

These discovery requests are continuing in nature and any information which may be 

discovered by you subsequent to the service and filing of your answers must be brought to the 

attention of the respondent through supplemental answers when it becomes available to you, 

and a reasonable time prior to the hearing in this matter. If there are any additions, deletions or 

Page 1 RESPONDENT'S REQUEST FQR INTERROGATORIES AND PRODUCTION OF DOCUMENTS 

REQUESTS FOR ADMISSIONS 

Docket No. FAA-2015-1319 

Case No. 2014NM0046 

William A. Curtright, DBA 

Respondent 

Telephone: (SD3)209-7388 

Fax {503)485.0812 
changes in the answers or information provided at any time prior to hearing the Complainant is 

specifically requested to so immediately inform the Respondent. If such information is not 

furnished, the Respondent at the time of the hearing will move to exclude from evidence such 

information requested and not furnished. 

The Respondent further requests that the Complainant produce, via mail or in person, the 

documents identified and designated herein for inspection and copying at the address of 

4135 Paradise Hill, S.E. Turner, Oregon 97392 

DEFINITIONS 

For purposes of these interrogatories the following abbreviations and definitions shall apply. 

I. The terms "you" and "your" mean the party to whom these interrogatories are 

addressed, and your attorneys, agents, employees, representatives, investigators, and 

any other person who is in possession of, or who has obtained information on your behalf. 

2. The term "document" means information stored in any form; any written, recorded or 

graphic matter, however produced or reproduced; and copies and drafts thereof. Without 

limiting the foregoing, "document" includes correspondence; telegrams; memoranda; 

reports; notes; drafts; minutes; contracts; agreements; books; records; vouchers; 

invoices; diaries; logs; calendar notes; computer printouts; memory programs; 

information stored in any data processing or word processing system, in whatever 

form; backup materials of any kind; card files; press clippings; newspapers or 

newsletters; sworn or unsworn statements or employees; lists; audits; tables of 

organization; deposit slips; monthly or other periodic statements; ledgers; journals; 

notices; affidavits; court papers; appointment books; minutes or records of conferences 

or telephone calls; brochures; receipts; written reports or opinions of investigators or 

experts; status reports; drawings; charts; photographs; negatives; or tape recordings 

within your possession, or subject to your control, of which you have knowledge, or 

Page 2 RESPONDENT'S REQUEST FOR INTERROGATORIES AND PRODUCTION OF DOCUMENTS 

REQUESTS FOR ADMISSIONS 

Docket No. FAA-2015-1319 

Case No. 2014NM0046 

William A. Curtright,DBA 

Respondent 

Telephone: (503) 209-7388 

Fax (503)485-0812 
to which you now have, or have had access, or of which any of your agents, attorneys, 

accountants, or consultants have knowledge. A comment or notation appearing on any 

document, not part of the original text, is to be considered as a separate 

"document." 

3. The term "identify" means: 

A. When referring to a natural person, state his/her full name, his/her present or last 

known business or home address ifthere is no business address. 

B. When referring to a document, state its title and date; identify the author or person 

who prepared it and any signatories to it; give the type of document (M, 

letter, memorandum, invoice); its present location and custodian; a surmnary of its 

contents, or principal terms and provisions; the identity of its addresses and all other 

persons receiving it or copies of it. If the docUillent so identified was, but is not 

longer, in your possession, custody and control, state what disposition has been 

made of it. Attach a copy of it to your response to these interrogatories. 

PRIVILEGE 

If, in responding to, or failing to respond to these interrogatories and requests for production 

you invoke or rely upon any privilege of any kind, state specifically the nature of the privilege; the 

basis upon which you invoke, rely upon or claim it, including any statutory or decisional reference; 

and identify all documents or other information, including contacts and communications which you 

believe to be embraced by the privilege invoked. 

DATED this 31st day of October, 2016 

Lo ~ 0----...-c_. __ ...._'-----. 

William Ames Curtright, DBA 

Page 3 RESPONDENT'S REQUEST FOR INTERROGATORIES AND PRODUCTION OF DOCUMENTS 

REQUESTS FOR ADMISSIONS 

Docket No. FAA·201S·1319 

Case No. 2014NM0046 

William A. Curtright, DBA 

Respondent 

Telephone: (503) 209·7388 

Fax (503)485·0812 
INTERROGATORIES AND REQUESTS FOR PRODUCTION 

INTERROGATORY No. 1: Describe with specificity all of the facts and arguments which you 

anticipate presenting in the course ofthe Department of Transportation (DOT) hearing in this 

matter pertaining to the civil penalty amount that the FAA seeks in this case of action. 

INTERROGATORY No.2: Describe with specificity all of the facts and arguments which you 

anticipate presenting in the course of the Department of Transportation (DOT) hearing in this matter 

pertaining to the civil penalty amount sought by the FAA in the case of action. 

INTERROGATORY No. 3: Describe with specificity all of the facts and arguments which you 

anticipate presenting in the course of the Department of Transportation (DOT) hearing in this matter 

identifying the grounds that will show a genuine issue of material fact. 

INTERROGATORY No. 4:Describe with specificity all of the facts and arguments which you 

anticipate presenting in the course of the Department of Transportation (DOT) hearing in this matter 

identifying why the FAA believes a civil penalty of $11,000.00 as being appropriate for the 

alleged violation of Section 14. C.P.R. 91.417(c). 

INTERROGATORY No. 5: Describe with specificity all of the facts and arguments which you anticipate 

presenting in the course of the Department of Transportation (DOT) hearing the FAA's explanation of 

why they are proposing an $11,000.00 fine as the civil penalty, and what forms the basis for the maximum 

amount allowed. 

INTERROGATORY No.6: Describe with specificity all of the facts and arguments which you 

anticipate presenting in the course of the Department of Transportation (DOT) hearing in this matter 

identifying why the FAA had offered a settlement of$5,000.00. 

INTERROGATORY No. 7: Describe with specificity all of the facts and arguments which you 

anticipate presenting in the course of the Department of Transportation (DOT) hearing in this matter 

identifying why the FAA had offered a settlement of$3,500.00 for full settlement of this case. 

INTERROGATORY No. 8: Identify by name, address and telephone number, all persons whom you 

discussed at your agency regarding the FAA offered settlement of$5,000.00. 

INTERROGATORY No.9: Identify by name, address and telephone number, all persons whom you 

discussed at your agency regarding the FAA offered settlement of $3,5000.00. 

INTERROGATORY No 10: Identify by name, address and telephone number all persons whom you 

know to have personal knowledge of the matters alleged in the Complaint. 

INTERROGATORY No. 1 1 : Identify by title, date, author, present custodian, and content, 

all documents, including correspondence, obtained by you or in your possession, relating to the 

Page 4 RESPONDENT'S REQUEST FOR INTERROGATORIES AND PRODUCTION OF DOCUMENTS 

REQUESTS FOR ADMISSIONS 

Docket No. FAA-2015-1319 

Case No. 2014NM0046 

William A. Curtright, DBA 

Respondent 

Telephone: (503) 209-7388 

Fax (503)485-0812 
assertions in the Complaint, and evidence that Respondent did not provide the documentation 

that was requested of him under Section 14 C.F.R. 91.417(c). 

INTERROGATORY No. 12: Identify by name, address and telephone number, all persons whom 

you intend to have testify as a factual or expert witness in support of your complaint at the hearing 

in this matter, and for factual witnesses, provide a detailed sununary of each persons anticipated 

testimony. 

INTERROGATORY No. 13: Identify by title, date, author, present custodian, and content, all 

documents which you anticipate offering into evidence at the hearing in this matter, and through 

which witness or witnesses. 

INTERROGATORY No. 14: With respect to each expert witness identified in response to 

InterrogatoryNo.l2, above, specify their specific area of expertise, and provide a synopsis of their 

credentials, background, training and experience. 

INTERROGATORY No. 1 5 : With respect to each expert you expect to call as a witness, state the 

subject matter on which the expert is expected to testify, and state the substance of the facts and 

opinions to which the expert is expected to testify, and a summary of the grounds for each such 

opinion. 

INTERROGATORY No. 16: State by name, address, telephone number, date of conversation, and 

substance of conversation, all persons with whom you have discussed the matters alleged in the 

Complaint. 

INTERROGATORY No.! 7: If you deny any or all of Requests for Admissions, please 

explain in detail the specific reason for each and every fact denied. 

INTERROGATORY No. 18: If you deny any or all of Request for Admissions please explain in 

detail the specific reason for each and every fact denied and sate specifically whether you had a 

conversation with ASI Comoy and, if so, what is your recollection of the conversation. 

INTERROGATORY No. 19: With respect to FAA attorney David F. Shayne, please describe if you 

are a permanent employee of the FAA or a contracted attorney with the FAA. 

INTERROGATORY No. 20: With respect to FAA attorney David F. Shayne, please describe if you 

are a contracted attorney with the FAA if you receive a percentage payment based on the amount of 

civil penalties are collected by you or the FAA. 

REQUEST FOR PRODUCTION NO. 1: Provide a copy of all documents referred to in your 

answer to the preceding interrogatories No. 1 through No. 20. 

Page 5 RESPONDENT'S REQUEST FOR INTERROGATORIES AND PRODUCfiON OF DOCUMENTS 

REQUESTS FOR ADMISSIONS 

Docket No. FAA-2015-1319 

Case No. 2014NM0046 

William A. Curtright, DBA 

Respondent 

Telephone: (503) 209-7388 

Fax (503)485-0812 
REQUEST FOR ADMISSIONS 

You are requested to admit the truth of the following matters. A matter is admitted unless 

responded to by November 30, 2016. A "response" includes serving an answer upon the agency 

attorney either admitting the matter, specifically denying the matter, stating why the matter cannot be 

admitted or denied, or objecting to the request, with reasons for the objection stated. 

REQUEST FOR ADMISSION No I. Admit that Attachment I is a true and correct copy of an 

electronic mail message (email) you sent to Wm. Ames Curtright, DBA on October 14, 2015 and 

an electronic mail message (email) Wm. Ames Curtright, DBA sent to you, David F. Shayne on 

October 14, 2015. 

REQUEST FOR ADMISSION No 2. Admit that Attachment 2 is a true and correct copy of a 

speed memo that was attached to the October 14, 2015 electronic mail message (email) (document 

request for admission No. 1) from the FAA in Hillsboro, Oregon to Marty G. Conroy cc: Bill 

McKibbon regarding INSPECTOR STATEMENT. 

REQUEST FOR ADMISSION No 3. Admit that Attachment 3 is a true and correct copy of the 

Complaint that the FAA filed with the United States Of America Department of 

Transportation Office of Hearings Washington, D.C. by FAA attorney David F. 

Shayne against William A. Curtright with case no. FAA Case No. 2014NM090046. 

REQUEST FOR ADMISSION No 4. Admit that Attachment 4 is a true and correct copy of a 

A SECTION B Statement of Case and Factors Affecting Sanction produced by the FAA in their 

initial disclosure statement in Case No. 2014NM090046. 

REQUEST FOR ADMISSION No 5. Admit that Attachment 5 is a true and correct copy of a 

letter to Martin G. Conroy from Dr. W. Ames Curtright, dated September 9, 2014 re: 

EIR Number 2014NM090046 with attachments of Oregon Aircraft Registration 

Certificate; Memorandum from Ben W. Davidson to William Ames Curtright dated 

August 26, 2014;medical Certificate Third Class; electronic mail message (email) 

from William Ames Curtright to Marty Conroy dated July 7, 2014 with subject 

N949JP Information, The Standard Pilot Log book. 

REQUEST FOR ADMISSION No 6. Admit that Attachment 6 is a true and correct copy of 

a electronic mail message (email) from William Ames Curtright to Marty Conroy 

dated August 28, 2014 subject N949JP Information. 

REQUEST FOR ADMISSION No 7. Admit that Attachment 7 is a true and correct copy of a a 

Page 6 RESPONDENT'S REQUEST FOR INTERROGATORIES AND PRODUCTION OF DOCUMENTS 

REQUESTS FOR ADMISSIONS 

Docket No. FAA-2015-1319 

Case No. 2014NM0046 

William A. Curtright, DBA 

Respondent 

Telephone: (503) 209-7388 

Fax IS03)485-0812 
Decision and Order in the matter of Premier Jets, Inc. with FAA Order No. 99-7 

Served August 31, 1999 with Docket No. CP97NM0005 that was sent to FAA 

attorney David F. Shayne with Respondent's additional disclosures pursuant to FRCP 

2691(a) on September 20th 23016 

REQUEST FOR ADMISSION No 8. Admit that Attachment 8 is a true and correct copy of 

a photo's of N949JP log book I, 2 and 2 produced to FAA attorney David F. 

Shayne with Respondent Initial Disclosures Pursuant to the ALJ' S Order of 

August 10, 2016 and FRCP 269(a) on September 9, 2016 by Respondent. 

REQUEST FOR ADMISSION No.9. Admit that Attachment 9 is a true and correct copy of 

a email from Scott Myers of FAA to Patty Abel dated July 30, 2015 regarding 

that they are in receipt of Mr. Curtright's email dated July 27, 2015 

REQUEST FOR ADMISSION No 1 0. Admit that Attachment I 0 is a true and correct copy 

of a electronic mail message (email) from Dr. William A. Curtright, DBA to 

Judge Richard Goodwin cc: Patricia Matthew and David F. Shayne dated August 

11, 2015 re: Reply to FAA's Motion; with electronic mail message (email) from 

patty Abel to Bill McKibbon and Scott Myers of FAA dated July 30, 2015 

regarding if they had received the documents sent on July 27, 2015. 

REQUEST FOR ADMISSION No II. Admit that Attachment II is a true and correct copy 

of a electronic mail message (email) from Dr. William A. Curtright, DBA to 

David Shayne dated July 23, 2015 regarding flight logs, weight and balance with 

attachments of FAA Approved Airplane flight manual supplement 2 with a total 

of 4 pages; Supplemental Type Certificate dated March I, 2011. 

REQUEST FOR ADMISSION No. 12 Admit that Attachment 12 is a true and 

correct copy of a letter dated July 22, 2015 from Dr. Wm. Ames Curtright, DBA 

to Bill McKibbon and Scott Myers of Flight Standards Dist. Office re: EIR 

number 2014 NM0900046 

REQUEST FOR ADMISSION No. 13 Admit that Attachment 13 is a true and 

correct copy of a letter dated May II, 2015 from Dr. Wm. Ames Curtright, DBA 

to Martin Conroy Aviation Safety Inspector re: Case No. 201'4NM090046 

REQUEST FOR ADMISSION No. 14 Admit that Attachment 14 is a true and 

correct copy of a letter dated May II, 2015 from Dr. Wm. Ames Curtright, DBA 

to Scott Myers re: FAA Case No. 21014NM090046 

Page 7 RESPONDENT'S REQUEST FOR INTERROGATORIES AND PRODUCTION OF DOCUMENTS 

REQUESTS FOR ADMISSIONS 

Docket No. FAA-2015-1319 

Case No. 2014NM0046 

William A. Curtright, DBA 

Respondent 

Telephone: (503) 209-7388 

Fax (503)485-0812 
The undersigned Complainant herein has read the foregoing answers to Respondent's Request 

for Interrogatories and Production of Documents and Request for Admissions, and they are in 

compliance with Rules 11 and 26(g) of the Federal Rules of Civil Procedure. 

DATED this_ day of ___ ~2016. 

David F. Shayne 

FAA Attorney 

CERWICATE OF SERVICE 

I hereby certify that the foregoing Respondents Request for Interrogatories and Production of 

Documents and Request for Admissions, has been served as designated by the recipient this date, to 

the following: 

David F. Shayne, FAA Attorney (Fax, Email, and Certified First Class Mail) 

Complainant's Counsel 

Northwest Mountain Region, ANM-7 

Federal Aviation Administration 

1601 Lind Ave. SW 

Renton, W A 98057 

TEL: 425-227-1847 

FAJ<:425-227-1007 

Email: David.F .Shayne@faa.gov 

William Ames Curtright, DBA Dated October 31, 2016 

Page 8 RESPONDENT'S REQUEST FOR INTERROGATORIES AND PRODUCI'ION OF DOCUMENTS 

REQUESTS FOR ADMISSIONS 

Docket No. FAA-2015-1319 

Case No. 2014NM0046 

William A. Curtright, DBA 

Respondent 

Telephone: (503) 209-7388 

Fax (503)485-0812