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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 

u1] 12 

~~CEIVED M-:.\M 

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COMPLAINANT'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR 

PRODUCTION OF DOCUMENTS 

To: Grant Aviation, Inc. 

through counsel 

Brent R. Cole, Esq. 

Law Office of Brent 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, by March.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 requested answers or documents/items is to be supplied by supplemental 

production pursuant to§ 13.220(i) ofthe Rules of Practice in FAA Civil Penalty Actions. 

DEFINITIONS 

1. "Documents" means, regardless of origin or location, any handwriting, note, letter, email, 

manual, memorandum, record, report, statement, study, drawing, sketch, photograph, telegram, 

telex, or message, whether reported, transcribed, punched, taped, filmed or graphically 

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represented in any manner, or material of any 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, and job 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 of the expected testimony. 

2. For each person identified in response to Interrogatory No. 1, produce a copy of each and 

every statement made by that person in which the facts and circumstances of matters at 

issue in this case are referenced or discussed. 

3. Do you intend to presenrany expert witness testimony at the hearing of this matter? If 

so, then provide a synopsis of each 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? If so, then state every fact upon which you intend to rely at the hearing in 

support of this contention, and produce a copy of each and every document you intend to 

introduce at the hearing-In this matter in support of this contention. . . .. 

5. If you contend that Grant Aviation lacks the ability to pay civil penalties totaling 

$75,000, then produce balance sheets, statement of cash flows, and income statements for 

the current as well as the last two fiscal years. 

6. If you contend that Grant Aviation lacks the ability to pay civil penalties totaling 

$75,000, then identify all outstanding loans (including lines of credit) owed in whole or 

in part by Grant Aviation, Inc., and produce copies of those loan agreements as well as 

any and all applications or updates to applications for loans or lines of credit submitted 

by Grant Aviation, Inc., during the last three years. 

7. If you 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 

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stock of Grant Aviation, Inc., and indicate the amount each person or legal entity owns or 

controls. 

8. If you contend that Grant Aviation lacks the ability to pay civil penalties totaling 

$75,000, then identify and produce a copy of each and every lease for real or personal 

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 in response to Request No. 7. 

9. To the extent not encompassed in your response to any of the foregoing items, identify 

and produce all documents upon which you expect to rely at the hearing or introduce as 

evidence in support of your position at the hearing in this matter. 

- -- -R~q~;;;dtw;-2~9lli-ciayofJanuirY--2oTf'·- · 

HOWARD L. MARTIN, JR 

Regional Counsel 

By:~~ 

3 

Glenn H. Brown 

Senior Attorney 
CERTIFICATE 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 of the Complainant's First Set of Interrogatories 

and Requests for Production by hand delivery to: 

Grant Aviation, Inc. 

through counsel 

Brent R. Cole, Esq. 

Law Office of Brent R. Cole, P.C. 

~- ~- -~N_Str~et, Suite 208 Anchorage~ AK~ 9950l-i136~ ·---=--." -.~-

I further certify that on this date I have served the original and a copy of the Complainant's First 

Set of Interrogatories 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 of the Regional Counsel 

222 West 7th Avenue #14 

Anchorage, Alaska 99513-7587 

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