02/03/2012 10:28 '4252271007 ANM7 PAGE 02/0B 

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JEFFREY M. HARPER 

FAA OFFICE OF REGIONAL COUNSEL 

1601 LlND A^'ENUE SOUTH^^ST 

.RENTOK, WASHINGTON 98057 

TELEPHON-E: (425)227-2161 

FACSIMF^E: (425) 227-1007 

DOCKET Of^lin/MlUi^io 

inn [:.:n - ^. P l^ U 1 

UNITED STATES O F AMERIC A 

DEPARTMEN T O F TRANSPORTATION 

OFFICE O F HEARINGS 

WASHINGTON, D.C. 

FAA Case No. 2011NM070021 

DMSNo. FAA-2011-04S4 

In the Matter of: 

Cornerstone Aviation, Inc. 

FAA Case No. 2011NM070022 

DMSNo. FAA-20n-04Sl 

FAA Case No. 2011NM070042 

DMS No. FAA-20n-0489 

Judge Richard C. Goodwin 

TO: Comer Stone Aviation, Inc. 

COMPLAINANT'S SECOND DISCOVERY REQTJEST 

tn accordance with 14 Code of Federal Regulation (C.F.R.) Section 13.220 and the Federal Rules of 

Civil Procedure, please respond to the following Interrogatories, Requests for Production of 

Documents, and Request for Admissions, separately and fully under oath by March 5,2012. 

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 

agency attorney through supplemental answers when it becomes available to you, at a reasonable 

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

answers or information provided at any time prior to hearing the Respondent is specifically 

requested to so immediately inform the agency attorney. If such information is not furnished, the 

agency attorney at the time of the hearing will move to exclude from evidence such 

information requested and not furnished. 

Complainant's 2nd Discovery Request 

ComcistoneAviation, iQc.-2011NMf)7002I. 

2011NM070022. 2011NM070042 

Page 1 of 5 

JEFTUEY M. HARPER, FAA ATTOTIWP,^ 

TEL: (425) 227-2161; FAX: (425) 227-1007 
e2/03/'2Q12 10:28 4252271B07 ^NM7 PAGE 33/66 

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The agency attorney fiortlier requests that the Respondent produce the documents identified and 

designated herein for inspection and copjTng at the Federal Aviation Administration (FAA) Ofiice 

of Regional Counsel, Suite 570,1601 Lind Avenue, Southwest, Renton, Washington 98037, by 

March 5, 2012. 

SHOULD YOU FAIL TO ANSWER THESE DISCOVERY REQUESTS, AGENCY 

COUNSEJ^ WILL MOVE TO COMPEL DISCOVERY. FAILURE TO CO^IPLY WITH 

YOUR DISCOVERY OBLIGATIONS CAN RESULT IN PRECLUSION OF 

INFORMATION YOU WISB TO PRESENT AT A HEARING* 

PRIVTLEGE 

If, m responding to, or failing to respond to these hiterrogatories, Requests for Admission and 

Requests for Production you invoke or rely upon any privilege of any kj.n.d, State specifically the 

nature of the privilege; the basis upon which you invoke, rely upon, or claim it, including any 

stamtory 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 3rd day of February', 2012. 

ief&ey M. Harper 

FAA Attorney 

ComplainpTit's 2nd Discovery Request 

Comcr^onc Avialion, Inc. - 2011NM070021, 

201 lNM0'/0022, 2O11NM07OO42 

Page 2 of 5 

JEFFR:EY.M. HAKFER, FAA ATTORNEY 

TEL: (425) 227-2161; FAX: (425) 227-1007 
02/03/2012 10:28 4252271007 

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•M-M 

INTERROGATGRIES 

InteiTogatorvNo. 11: State v^ith specificity.tiie grounds and evidence upon which Cornerstone 

Aviation^ Inc. will rely to argue that the proposed sanction is excessive and should be reduced. See 

Request for Production No. 6. 

REQUESTS FOR PRODUCTION 

Request for Production No. 5: Provide a copy of Cornerstone Aviation, Inc.'s Federal tax returns 

for the last three (3) tax years, includmg all supporting schedules and documents. 

Request for Production No. 6: Provide a copy of the evidence referred to in your answer to 

Interrogatory No. 11. 

REQUEST FOR ADMISSIONS 

Under 14 Code of Federal Regulations (C.F.R.) Section 13-220(b) and Rule 36 of the Federal Rules 

of Civil Procedure, 3'ou are requested to admit the truth of the following matters. A matter is 

admitted unless responded to in a reasonable time. The Rules of Practice in FAA Civil Penalty 

Actions, 14 C.F.R. Section 13.220(d), defmes a reasonable time to be thirty (30) days. The agency 

requesttJ that an answer is serv'ed upon the agency attorney either admitting the matter, specifically 

den>Tng the matter, stating why tlie matter cannot be admitted or denied, or objecting to the request, 

with reasons for the objection stated within thirty (30) days of tiie date of service upon you, tliat is, 

March 5,2012. 

IF YOU FAIL TO RESPOND TO THESE REQUESTS FOR ADMISSIONS EV WRITING, 

THE FACTS CONTAINED THEREIN ARE DEEMED ADMITTED, ABSENT A JLTDGE*S 

RULING THAT YOUR FAILURE TO ANSWER WAS DUE TO CIRCUMSTANCES 

BEYOND YOUR CONTROL. See 14 C.F.R. Section 13.220(0(1). 

As a reminder, Interrogatory No. 10 asks "For any of the requests for adnussions below that is 

denied, state with specificity the facts that are the basis for tiiat denial as well as the inqmries taken 

to determine that the facts in the request for admission are not correct." 

Request for Admission No. 18: AdmJt that tlie $5,000 penalty sought in Case No. FAA-2011'0481 

is consistent with the Administrator's sanction guidelmes found in FAA Order 2150.3B, 

Request for Admission No. 19: Admit that the $5,000 penalty sought m Case No..FAA-2011-04S4 

is consistent \sith the Administrator's sanction guidelines found in FAA Order 2150.3B. 

Request for Adjnission No. 20: Admit that the $5,000 penalty sought in Case No. FAA-2011-0489 

is consistent with the Administrator's sanction guidelines found in FAA Order 2150.3B. 

Request for Admission No. 21: Admit that Cornerstone Aviation, hic. qualifies as a small business 

for Federal Government Programs. 

PAGE 04/0b 

Compljiinant's 2nd Discovery Request 

Cornerstone Aviation, Inc. - 2011NM070021 

2011NM070Q22. 201INM07OO42 

Page 3 of 5 

JEFFREY M. HAKFER, FAA ATTORNEY 

TBL: (425) 227-2161; F;\X: (425) 227-1007 
02/03/2012 10:28 4252271007 ^NM7 PAGE Q5/Q6 

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Request for Admission No. 22: Admit that Cornerstone Aviation, Inc. has been in business since 

2003. 

Request for Admission No. 23: Admit that Cornerstone Aviation, Inc. has the financial ability to 

pay the S5,000 penalty sought in case No. FAA-2011-04S1. 

Request for Admission No. 24: Admit that Cornerstone Aviation, Inc. has the financial.abihty to 

pay the $5,000 penalty souglit in case No. FAA-2011 -0484. 

Request for Admission No. 25: Admit that Cornerstone Aviation, Inc. has the financial ability to 

pay the $5,500 penalty sought in case No. FAA-2011 -0489. 

Complainant's 2nd Discovery Request 

Cornerstone Aviation, Inc-2011NM07002I. 

2011NM070022, 2011NM070042 

Page 4 of 5 

JEFFREY M. HARP^^ FAA ATTORNEY 

TEL: (425) 227-2161: F.\X: (425) 227-1007 
02/03/2812 10:28 4252271007 ANM7 PAGE 06/Q& 

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CERTIFICATE O F SERVICE 

I hereby certify that tlie foregoing Complainant's Second Discovery Request has been served via 

tacsiraile and Cerfified Mail - Return Receipt Requested this date, to tlie following: 

Honorable Richard C, Goodwin 

Office of hearings, M-'20 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

FAX: 202.366.7536 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building - Suite 2W1000 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, D.C. 20591 

FAX: 202.493.5020 . 

Susan Horstman 

Chief Executive Officer 

Cornerstone Aviation. Inc. 

337 North 2370 West i^l 30 

Salt Lake Citv, UT S4116 

FAX: (801) 355-2754 

Dated this 3rd, day of February, 2012. 

MOIFAIR CHIN 

Office of Regional Counsel (ANWI-7) 

Federal Aviation Administration 

1601 Lind Ave. SW 

Renton, WA" 9805 7 

425.227.2160 

ComplainanT's 2nd Discovery Request 

Comersrone Aviation, Inc. -201INM070021, 

2011"NM070022, 2011NM070042 

Page 5 of5 

JEFFREY M. J-IARPER, FAA ATTORNEY 

TEL: (425) 227-2161; FAX: (425) 227-1007