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 IndependenceAvenue SW Washington, DC 20591

RE: Beltmakers, Inc. FAA Case No. 

### 2011WP910400 FDMS No. 

### FAA-2013-0049

Dear Hearing Docket Clerk: 

# RECEIVED APR 242013 HEARING DOCKET April 22, 2013

Enclosed herewith for filing are an original and one copy ofthe First Request for Discovery filed on behalfofthe Respondent, Beltmakers, Inc. Should you have any questions or concerns, please do nothesitateto contact me.

cc: The Honorable Richard C. 

### Goodwin Administrative Lawjudge Lisa Toscano, Esq. FAA,AWP-7 Very trulyyours,
Caitlin M. Miller Legal AssistantMICHAEL 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 242U13 

## HEARING DOCKET

UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS

WASHINGTON, D.C.

Inthe Matter of:

BELT MAKERS, INC. FAA Case No. 2011WP910400 FDMS No. FAA-2013-0049
BELT MAKERS, INC'S FIRST REQUEST FORDISCOVERY

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 inthis proceeding, by and through its undersigned counsel, and pursuantto Section 13.220 ofthe Federal Aviation Regulations (14 C.F.R. Sec. 13.220), requests that Complainant, within 30 days provide the following information: 11. State the name, occupation, address and telephone number ofeachperson, including but not limited to percipient witnesses, investigators and experts, Complainant intends to call as a witness at the hearing. 2. Provide a briefstatement regarding the subject matter ofthe testimony ofeach witness. 3. Provide copies ofall 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 ofProofinits Enforcement Investigative Report(s), such documents do not have to be provided again). 4. Provide copies ofall documents Complainant has utilized and/or relied upon in determining the proposed sanction inthis matter. 5. For each expert Complainant intends to call atthe 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 ofeach said witness' proposed testimony; (B) a briefstatement regarding the grounds for the opinion testimony ofeach expert witness; and (C) copies ofany and all documents generated, prepared or reviewed by each such witness. 7. IfComplainant obtains additional documents not mentioned inresponse to Requests Nos. 4 and 6, 

### BELT MAKERS requests these documents be produced as expeditiously as
2possible. 8. IfComplainant 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 briefstatement regarding the subject matter ofthe testimony ofeach ofsuch additional witnesses. Dated: APRIL 22, 2013

Attorney for BELT MAKERS, INC.



### 3CERTIFICATE OF SERVICE The undersigned hereby certifies that onthis 19th day ofApril, 2013, a true and correct copy ofthe foregoing BELT MAKERS. INC'S FIRST REQUEST FORDISCVOERY was served as follows: Federal Aviation Administration Attn: Hearing Docket Clerk, AGC-430 Wilbur Wright Building- Suite 2Wl000 800 Independence Avenue SW Washington, DC 20591 (Original plus one copy) {Federal Express} The Honorable Richard C. Goodwin Administrative Law Judge Office ofHearings, M-20 Department ofTransportation 1200 New Jersey Avenue, S.W. Washington, DC 20590 FAX: 1-202-366-7536 {FAXandFederal Express} Lisa Toscano, Esq. Federal Aviation Administration Office ofthe Regional Counsel Western-Pacific Region, AWP- 7 15000 Aviation Boulevard Lawndale, CA 90261 FAX: 1-310-725-6816 {FAXandFederal Express}

Caitlin M. Miller

4