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., . ' ::·- "(" (\**.,,~~** f'"' !'"') \ UNITED STATES DEPARTMENT OF TRANSPORTATION; l);·-:J·J" OFFICE OF HEARINGS

WASHINGTON, D.C.

IN THE MATTER OF GRANT AVIATION, INC. FAA DOCKET NO. [TO BE ASSIGNED]

__0 ,,**~< c~**  _ ._**((;iyill?~!H~lty Pro~et:,~!t:l~)**  DMS NO. FAA-2012-1261 

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# ~~CEIVED M-:.\M**~tttfm~**

COMPLAINANT'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS
To: Grant Aviation, Inc. through counsel Brent R. Cole, Esq. Law Office ofBrent R. Cole, P.C. 821 N Street, Suite 208 Anchorage, AK 99501-2136

Pursuant to 14 C.F.R. § 13.220, the Complainant, by and through its Regional Counsel, requests thatyou, byMarch.i,20l3,
..make the requested admissigns,.answer the foJlqwi_Il,g interrogatories under oath, and identify and produce the requested documents for inspection and copying at the Office ofthe Regional Counsel, Alaskan Region FAA, 222 W. 7th Avenue, Box 14, Anchorage, Alaska 99513-7587. These requests are deemed continuing, and any information secured after answering and/or supplying the requestedanswers or documents/items is to be supplied by supplemental production pursuant to§ 13.220(i) ofthe Rules ofPractice inFAA Civil Penalty Actions. DEFINITIONS 1. "Documents" means, regardless oforigin or location, any handwriting, note, letter, email, manual, memorandum, record, report, statement, study, drawing, sketch, photograph, telegram, telex, ormessage, whether reported, transcribed, punched, taped, filmed or graphically

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represented in any manner, or material ofany kind in the possession of, subject to the control of, or within the knowledge of, Respondent and/or his employees, agents, consultants, or experts. 2. "Identify" and/or "state the identity of'' with reference to individuals means state the name, current or last known address, employer, andjob description or title, and telephone number. 3. "Identify all documents" means state the date and author unless apparent from the document. 4. As listed herein, singular pronouns also include the plural.**~** 

### __**-~---5~-~~''YOll:~** 

### __**"yp~r:'** ,and**"~~s_po.u~e_nt" a~~_psed**  herein refer to Grant Aviation, Inc., the Respondent in this matter. · -- · __,- · - -- -- - 

### INTERROGATORIES AND REQUESTS FOR PRODUCTION 1. Identify each person whom you intend to call as a witness at the hearing in this matter, and for each such witness, provide a summary ofthe expected testimony. 2. For each person identified in response to InterrogatoryNo. 1, produce a copy ofeach and every statement made by that person in which the facts and circumstances ofmatters at issue in this case are referenced or discussed. 3. Do you intend to presenrany expert witness testimony at the hearing ofthis matter? If so, then provide a synopsis ofeach expert witness' testimony, state the grounds for each expert opinion, and produce curriculum vitae for each expert witness. 4. Do you contend that Grant Aviation, Inc., lacks the ability to pay civil penalties totaling $75,000? Ifso, then state every fact upon which you intend to rely at the hearing in support ofthis contention, andproduce a copy ofeach and every document you intend to introduce at the hearing-

# In this matter in support ofthis contention.
. . .. 5. Ifyou contend that Grant Aviation lacks the ability to pay civil penalties totaling $75,000, then produce balance sheets, statement ofcash flows, and income statements for the current as well as the last two fiscal years. 6. Ifyou contend that Grant Aviation lacks the ability to pay civil penalties totaling $75,000, then identify all outstanding loans (including lines ofcredit) owed in whole or in part byGrant Aviation, Inc., and produce copies ofthose loan agreements as well as any and all applications or updates to applications for loans or lines ofcredit submitted by Grant Aviation, Inc., during the last three years. 7. Ifyou contend that Grant Aviation lacks the ability to pay civil penalties totaling $75,000, then identify each person or other legal entity that owns and/or controls the

2stock ofGrantAviation, Inc., and indicate the amount eachperson or legal entity owns or controls. 8. Ifyou contend that Grant Aviation lacks the ability to pay civil penalties totaling $75,000, then identify and produce a copy ofeach and every lease for real orpersonal property, including leases for aircraft and space, that involve Grant Aviation, Inc., as the lessee and a lessor that is or is partially owned or controlled by a person or legal entity identified inresponse to Request No. 7. 9. To the extent not encompassed in yourresponse to any ofthe foregoing items, identify and produce all documents upon which you expect to rely at the hearing or introduce as evidence in support ofyourposition at the hearing in this matter.

- --**-R~q~;;;dtw;-2~9lli-ciayofJanuirY--2oTf'·-** · HOWARD L. MARTIN, JR Regional Counsel

# By:~~

3 Glenn H. Brown SeniorAttorneyCERTIFICATE OF SERVICE Re: Grant Aviation, Inc. FAA Case No. 2011AL030075 DMS NO. FAA-2012-1261 I hereby certify that on this date I served a copy ofthe Complainant's First Set ofInterrogatories and Requests for Production by hand delivery to: Grant Aviation, Inc. through counsel Brent R. Cole, Esq. Law Office ofBrent R. Cole, P.C.**~- ~-** **-~N_Str~et,** Suite 208**Anchorage~ AK~** **9950l-i136~** ·---=--."**-.~-**
I further certify that onthis date I have served the original and a copy ofthe Complainant's First Set ofInterrogatories and Requests for Production by postage-prepaid, certified mail, return receipt requested, addressed as follows: Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591 ATTN: Hearing Docket Clerk, AGC-430. Wilbur Wright Building- Suite 2W1000

Office ofthe Regional Counsel 222 West 7th Avenue #14 Anchorage, Alaska 99513-7587

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