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Law Office of Joseph W. Geldhof 

2 Marine Way, Suite 207 RECEIVED 

Juneau, Alaska 9.9801 JUL 12 2012 Telephone: (907)586-8193 

E-mail: joeg@alaska.com 

Counsel for Respondent Scott Novak HEARING DOCKET. 

U.S.-DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, DC 

ill the Matter of: !"·· •• ) 

) w 

SCOTT NOVAK, 

Respondent. 

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) FAA .Docket Number: Currently Unassigned 

) FDMS NO. FAA-2012- 0206 

RESPONSE-BYSCOT't.NOVAK TO COMPLAINANT'S FIRST SET OF REQUESTS 

FOR ADMISSION, INTERROGATOIRES AND 

REQUEST FORPROJlCU~'fiON <?F UO.CUMENTS ' 1 •. l • • L.~o , , • • ' - ~ ' ' • , • I 

Scott Novak, Respondent in the above-captioned action, responds to Complainant's discovery 

i:eq~~sts, as follows: 

REQUESTS FOR ADMISSION 

1. I offered on: behalf of my daughter, Ericka, a pickup-truck load of household goods, 

described to me as furniture, mattress and GEN SO-{\ per air bill 027-8385-7546. To 

the best of my knowledge, all the stuff my daughter asked me to ship was just 

household goods and not anything that was hazardous. 

2. I believe the shipment I sent was assigned Alaska Airlines Air Waybill' No. 027-8385-7546. ,. ' I ' • ''! J • •• 

3. It states that the shipme~ts was furniture, mattr~ss and GEN SOA, which is ~hat I was told 

was in the containers. . ' ' \~ •, 

.• .l. ; 

4. Yes. •\ ' . . ~ . ' 

5. Yes. To the best.ofmylru..owledg~ t4e shipment did;·n0t-contain dangerous goods. • \ • : ' • < .\ ~~' ' ' < •' <. ~ .'> • ' > •. <, ' 'I ' ' 

Scott Novak's.Resp~·se to Discovery Reqii¢sts ·· ; · 7 

FAAv. Novak " ·' ·· · · · "' .. · · · ·' · 

FDMS No. FAA-2012-0206 

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6. The security screening document for furniture and household supplies was completed by 

someone other than me. I cannot attest to its completeness or accuracy. 

7. Yes. To the best of my knowledge the shipment did not contain any explosives, 

incendiaries, or individuals. The shipment was for household supplies. 

8. Not to my knowledge. 

7 9. Yes. 

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10. Yes. 

10 11. Yes. 

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12. Yes 

INTERROGATORIES AND REQUEST FOR PRODUCTION . 

1. I didn't have a clue that there was any fingernail polish in the shipment. The contents were 

described by my daughter as household goods, including a mattress and other stuff she 

needed moved to Juneau. There wasn't any discussion about anything being 

dangerous in the boxes. There are not any documents about my lack of knowledge or 

photographs that I have. I didn't know and was not trying to do anything wrong. 

2. If knew what the definition of dangerous goods or hazardous goods was and ifi had any 

knowledge that the stuff in the shipment was dangerous or hazardous, why would I not 

say so. Ifi had known, the easy thing would have been to throw the stuff away. All I 

was trying to do was help my daughter get her gear to Juneau. 

3. I will testify and probably my daughter. Wewill both testify that the contents of the 

shipment belonged to her, that we decided to ship the stuff by air at the last minute 

when it became necessary, that I didn't pack the shipment and had no knowledge about 

the contents and that this is another example of how trying to help your kids in the 

modern world fits the popular notion that no good deed goes unpunished when it 

comes to dealing with the government anymore. 

Scott Novak's Response to Discovery Requests 

FAAv.Novak 

FDMS No. FAA-2012-0206 

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1 4. There are no "statements" to produce. 

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5. No. 

4 6. No. 

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~-~ -~-~.---There-do-net-appear-to-beany~addi-tionahlocuments-inihe-pussessitm<Jf~he Responaem--~--

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_ that are not already in the possession of the FAA related to this dispute or which 

Respondent intends to rely on at the hearing. 

On my oath, I affirm that the responses to the interrogatories and requests for 

admissions ari true tf:1d correct to the best of my knowledge. 

9 E~ . DATED z~ili day of JWle, 2012 at Juneau, ~las:__ L __ )ut?t/ ~ . . ·- v 

Scott Novak 

~'f 'II_ 

SUBSCRIBED and SWORN to before me this 2'8.th day of June, 2012 

df~ M . ~tv1Uo~ Notary Public in and for Alaska 

My Commission Expires:~\..Jll9 1

2bl5" 

.................. __ ......_ _______ _ 

Notary Public 

~ LINDA M. ENRIQUEZ 

State of Alaska 1 My Commission Expires Jul. 9, 2015 

lafflrm with regard to responses to requests for production and objections 

made, if any, that the responses made above are correct and complete. 

DATED this ~r day of JWie, 2012 at JWieau, Alaska. 

(\r) 'rv~ LAW OFFICE OF 

JOSEPH W. GELD Att7 Scott N Yak 

'-""' 

Joseph W. ldhof 

Alaska Bar # 8111097 

Scott Novak's Response to Discovery Requests 

FAAv.Novak 3 

FDMS No. FAA-2012-0206 
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CERTIFICATION 

I certify that on this date, a copy 

of this document was sent via FAX 

to: 

5 Glenn H. Brown, 

_____ 11_-->JS-""enLUiw:o~r Atto-r-D-ey---------------------------~-

6 Office of the Regional Counsel 

Federal Aviation Administration 

7 Office of the Regional Counsel 

8 ~-7 

222 West 7th Avenue, Box 14 

9 Anchorage, Alaska 99513-7587 

FAX: (907) 271-2800 

I further certify that on this date, a copy 

of this document was sent via 

USPS: 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

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Wilbur Wright Building -- Suite 2W1 000 

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A copy of this document was also via USPS to: 

Glenn H. Brown, 

Senior Attorney· 

Federal Aviation Administration 

Office of the Regional Counsel 

AAL-7 

222 West 7th Avenue, Box 14 

Anchorage, Alaska 99513-7587 

1.. ., ,~ ·'? .tJ ' . .,. DATE: "· -.H .. :;; v"l '"'r , .:;.._ 

Joseph 5:4" W. Geldhof 

Scott Novak's Response to Discovery Requests 

FAA v.Novak 

FDMS No. FAA-2012-0206 

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