465 California Street 

Suite 210 

• 

San Francisco 

California 94104 

• 

(415) 421-2500 

Fax (415) 421-2560 

www.avialex.com 

law@avialex.com 

Michael L. Dworkin and Associates 

Law Offices 

(VIAFEDEX) 

Federal Aviation Administration 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2W1000 

800 Independence Avenue SW 

Washington, DC 20591 

RE: Beltmakers, Inc. 

FAA Case No. 2011WP910400 

FDMS No. FAA-2013-0049 

Dear Hearing Docket Clerk: 

RECEIVED 

APR 2 4 2013 

HEARING DOCKET 

April 22, 2013 

Enclosed herewith for filing are an original and one copy of the First 

Request for Discovery filed on behalf of the Respondent, Beltmakers, Inc. 

Should you have any questions or concerns, please do not hesitate to contact 

me. 

cc: The Honorable Richard C. Goodwin 

Administrative Law judge 

Lisa Toscano, Esq. 

FAA,AWP-7 

Very truly yours, 

Caitlin M. Miller 

Legal Assistant 
MICHAEL L. DWORKIN #64047 

MICHAEL L. DWORKIN and ASSOCIATES 

465 California Street, Suite 210 

San Francisco, California 94104 

Telephone: (415) 421-2500 

Facsimile: (415) 421-2560 

Email: law@avialex.com 

Attorneys for BELT MAKERS, INC. 

RECEIVED 

APR 2 4 2U13 

HEARING DOCKET 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of: 

BELT MAKERS, INC. 

FAA Case No. 2011WP910400 

FDMS No. FAA-2013-0049 

BELT MAKERS, INC'S FIRST 

REQUEST FOR DISCOVERY 

TO: COMPLAINANT, THE HONORABLE MICHAEL HUERTA, ADMINISTRATOR, 

FEDERAL AVIATION ADMINISTRATION, AND HIS ATTORNEYS OF RECORD: 

COMES NOW BELT MAKERS, INC. (hereinafter, "BELT MAKERS"), the Respondent 

in this proceeding, by and through its undersigned counsel, and pursuant to Section 13.220 of the 

Federal Aviation Regulations (14 C.F.R. Sec. 13.220), requests that Complainant, within 30 days 

provide the following information: 

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1. State the name, occupation, address and telephone number of each person, including but 

not limited to percipient witnesses, investigators and experts, Complainant intends to call as a 

witness at the hearing. 

2. Provide a brief statement regarding the subject matter of the testimony of each 

witness. 

3. Provide copies of all documents Complainant intends to offer into evidence as exhibits 

at the hearing. (To the extent such documents were previously provided to BELT MAKERS as 

unredacted Items of Proof in its Enforcement Investigative Report(s ), such documents do not 

have to be provided again). 

4. Provide copies of all documents Complainant has utilized and/or relied upon in 

determining the proposed sanction in this matter. 

5. For each expert Complainant intends to call at the hearing provide a curriculum vitae 

or other document reflecting the expert's professional qualifications. 

6. For each witness Complainant intends to call at the hearing, including but not limited 

to experts, provide: 

(A) a summary of each said witness' proposed testimony; 

(B) a brief statement regarding the grounds for the opinion testimony of each expert 

witness; and 

(C) copies of any and all documents generated, prepared or reviewed by each such 

witness. 

7. If Complainant obtains additional documents not mentioned in response to Requests 

Nos. 4 and 6, BELT MAKERS requests these documents be produced as expeditiously as 

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possible. 

8. If Complainant secures additional witnesses not mentioned in response to Request 

No. 1, above, BELT MAKERS requests that Complainant expeditiously provide a supplementary 

witness list and a brief statement regarding the subject matter of the testimony of each of such 

additional witnesses. 

Dated: APRIL 22, 2013 

Attorney for BELT MAKERS, INC. 

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CERTIFICATE OF SERVICE 

The undersigned hereby certifies that on this 19th day of April, 2013, a true and correct 

copy of the foregoing BELT MAKERS. INC'S FIRST REQUEST FOR DISCVOERY was 

served as follows: 

Federal Aviation Administration 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2Wl 000 

800 Independence Avenue SW 

Washington, DC 20591 

(Original plus one copy) 

{Federal Express} 

The Honorable Richard C. Goodwin 

Administrative Law Judge 

Office of Hearings, M-20 

Department of Transportation 

1200 New Jersey Avenue, S.W. 

Washington, DC 20590 

FAX: 1-202-366-7536 

{FAX and Federal Express} 

Lisa Toscano, Esq. 

Federal Aviation Administration 

Office of the Regional Counsel 

Western-Pacific Region, A WP- 7 

15000 Aviation Boulevard 

Lawndale, CA 90261 

FAX: 1-310-725-6816 

{FAX and Federal Express} 

Caitlin M. Miller 

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