01/07/201 0 12:4 6 FAX 202493514 2 FAA •>• DMS IgOOI/OO S 

'DECEIVED 

DFX ) 8 2DQ9 

DEroRo Tim UNITED S'MT£^SDEPAi^tNiEN-r OF Tidfe^^HWficJJOCKE T 

TN THE MATTER OF 

SOUTHWEST AIRFRAME AND TANK 

SERVICES, 

Rcspondcm, 

FAA Investigation No.: 2008SO700215 

FAA Docket No.: CPSOOOIO 

DMS No. FAA-2009-0723 

Tiie Honorable Judge Isaac D. Benkin 

RESPONDENT'S FIRST SUFPLEMENT 

TO DISCOVERY RESPONSES 

The Respondent, SOUTHWEST AIRFRAME AND TANK SERVICES, 

respectfully supplements the Respondent's Discovery Responses (served 

October 14, 2009) in the above-captloned matter by providing the attached 

document (December 14, 2009 Letter from Joel Ramirez). 

The attached document is responsive to interrogatory one in that it 

identifies a witness expected to testify and provides the substance of his 

testimony. 

The attached document is also responsive to the spirit (if not the letter) of 

interrogatory nine in that it Identifies a Respondent's Employee who spoke with 

Alexsey Pyatigorsky on the day before the day of the shipment and provides the 

details of the conversation. Please note that it describes a conversation on 

March 2 (the day before the day of the shipment), which is the same date as the 

other conversations previously disclosed. 

RESPECTFULLY SUBMITTED this 17*^ day of December, 2009. 

WASHINGTON AVIATION GROUP, PC AND THE 

LAW OFFIje^QS OF JASON A DICKSTEIN 

By N A- -

Jason Dickstein 

Washington Aviation Group, PC and the 

Law Offices of Jason A. Dickstein 

2233 Wisconsin Avenue, NW, Suite 503 

Washington, DC 20007 

Tel: (202) 626-6776 

Fax; (202) 628-8948 

Attorney for Respondent 

SOUTHWEST AIRFRAME AND lANK'S FIRST Washington Aviaiion Group, PC and the 

SUPPLCMLN1 10 DISCO VLiRY RESPONSES Law Offices of Jason A. Dickstein 

Page 1 2233 Wisconsin Avenue, NW, Suite 503 

Washingron, IK: 20007 - Tel: 202-S28-8947 
01/07/2010 12:4G FAX 2024935142 FAA + DMS @l002/003 

S«WJI*T « 

SOUTHWECT AntFRAME 

* TANK SERVICES 

9840 MotDDc Drive. Saite 105 

I>dtaB>TX7S220 

niODe:(S0O)4ti6-8223 

Fbone: (214)902-8223 

C.ILS. * WUTR592X 

December 14. 2009 

Jason Dickstein 

Washington Aviation Group 

Law Offices of Jason Dickstein 

734 15th Street, NW Suite 705 

Washingtoa DC 20005 

Mr. Dickstein, 

On March 2. 2008, Mr. Alex Pyatigorski and I completed the required final leak check on the 

aircrall we were working at Hawker Beechcisft Senrices in Tampa Florida. As we were on our 

way back to our hotel to check out in Alex's personal vehicle, we were involved in an accident 

due to Alex texting on hia phone. The acddent reaulted in the truck being inoperaMe and had 

to be towed to a local repair shop. I was with Akx in the tow truck and in the repair shop 

when he called John Stewart to inform him of the accident and he asked John if he could rent 

a car to return to Port Lauderdale, until he coukl make arrangements with his insuranoe 

company. I also spoke with John, on Alex's phone, at this time re^rdin g the accident and the 

authorised rental car while we waited on Alex's brother>n-law to pick us up. Once Alex's 

brother-n-Iaw picked u s up, they dropped me a t the hotel where I cau^ t a shuttle to ttie 

airport. As I left Alex, it was my understanding that he was going to rent a car and 6TVV« back 

to Ft Lauderdale with his tools a s authorized tiy John. 

Sincerely, 

Joel Ramirez 

Southwest Aiifiame tk Tank Services 
01/07/2010 12:4G FAX 2024935142 FAA DMS 12003/003 

CERTIFICATE OF SERVICE 

RE: In the Matter of Southwest Airframe and Tank Services (FAA Docket No.: 

CPSO0010, DMS No. FAA-2009-0723). 

The undersigned hereby certifies that she caused the attached 

• ANSWER TO AMENDED COMPLAINT 

• RESPONDENT'S FIRST SUPPLEMENT TO DISCOVERY RESPONSES 

to be filed, at the following locations, by FedEx two-day sen/ice, on the date indicated 

below: 

Federal Aviation Administration (Original and One Copy) 

600 Independence Avenue, SW. 

Wilbur Wright Building—Suite 2W1000 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

Tel: (202) 385-8229 

And that she caused it to be served at the following locations, by FedEx two-day 

service: 

The Honorable Isaac D, Benkin 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

East BIdg Ground Floor, Room E12-320 

Washington, DC 20590 

FAX; (202) 366-7536 

Gerald Ellis, Attorney 

Office of the Regional Counsel 

Federal Aviation Administration 

1701 Columbia Ave. 

College Park, GA 30337 

TEL: (404) 305-5200 

FAX: (404) 305-5223 

.'7 /3fe*-^-^2009 

Date 

SOUTHWEST AfRFRAME AND TANK 

CERTIFTCATl: Ol' SliRVICE 

Washington Aviarion Group, PC and The 

Law Offices of Jdson A. Dickstein 

2233 Wisconsin Avenue, NW, Suite 503 

Washington, DC 20007 mTel: 202-628-8947