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 TANGO AIR, INC., d/b/a SCHUBACH AVIATION 

In the Matter of: 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

FAA Case No. 2015WP090037 

FDMS No. FA-2015-3317 

G 

s 

1 6 2015 

TANGO AIR, INC., 

d/b/a SCHUBACH AVIATION 

AMENDED NOTICE OF DEPOSITION 

AND REQUEST FOR PRODUCTION OF 

DOCUMENTS AND THINGS 

Judge: Honorable J. E. Sullivan 

To: David Shayne, Esq. 

Federal Aviation Administration 

Enforcement Division, Western Team 

Federal Aviation Administration 

1601 Lind Avenue, SW 

Renton, W A 98057 

The Notice of Deposition and Request for Production of Documents and Things, served 

July 29, 2016, is amended to reflect a change in the location and time of said deposition, in 

accordance with the agreement of counsel for the parties. 

PLEASE TAKE NOTICE that the Respondent, TANGO AIR, INC., d/b/a 
SCHUBACH AVIATION (hereinafter "TANGO") will take the oral deposition of the person 

specified below, at the date, time, and place specified for all purposes permitted by the Rules of 

Practice, Part 13, Subpart G, of the Federal Aviation Regulations, 14 CFR Sections 13.220(b): 

DEPONENT: Scott Worthington 

Federal Aviation Administration (FAA) Aviation Safety Inspector 

San Diego Flight Standards District Office 

DATE/TIME: Wednesday, August 24,2016,9:30 AM 

LOCATION: Law Offices of Ronald J. Cozad 

Premier Jet Building 

McClellan-Palomar Airport 

2100 Palomar Airport road, Suite 214 

Carlsbad, CA 92011 

Telephone: 1-760-431-8200 

Said Deponent is required to produce for inspection and copying by TANGO at the time 

and place of said deposition, the following documents: 

I. Current curriculum vitae; 

2. All writings or documents reflecting date and purpose of initial involvement in this 

matter; 

3. Writings, documents, materials and things memorializing: 

a. Correspondence and communications with FAA employees and agents 

concerning this matter, including but not limited to the allegations contained in 

the Complaint and any admissions, denials, averments or affirmative defenses set 

forth by TANGO in its Answer filed in this matter; 

b. Correspondence and communications with TANGO and its present and former 

directors, officers, employees and agents concerning this matter, including but not 

limited to the allegations contained in the Complaint and any admissions, denials, 

FAA Case No. 2015WP090037 

NOTICE OF DEPOSITION 

AND REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS 

Page2 
averments or affirmative defenses set forth by TANGO in its Answer filed in this 

matter; and 

c. Correspondence and communications with third parties relating to or obtained in 

the course of the FAA's investigation of this matter; 

4. Deponent's conclusions and opinions, if any, developed in connection with 

Deponent's investigation in and prosecution of this matter, including but not limited 

to conclusions and opinions concerning the appropriateness of the sanction sought by 

the FAA, and all facts and evidence in support of such conclusions and opinions; 

5. Copies of all writings, texts, treatises, books, articles, legal opinions, orders, 

advisory circulars, statutes, regulations or other publications or sources of information 

Complainant has reviewed, examined and/or relied upon in formulating opinions and 

conclusions as to the appropriateness of initiating and prosecuting the enforcement 

action in this matter and in computing the civil penalty proposed in this matter; 

6. All reports and notes prepared by Deponent during the course of Deponent's 

review of materials, interviews with witnesses, Federal and State employees, 

including but not limited to the NTSB, the FAA, investigators, technicians, and 

TANGO's present and former officers, directors, employees and agents; and 

7. Any other writings generated by Deponent in connection with this matter. 

The undersigned will take the deposition of the above-named deponent before a court reporter in 

the City of Carlsbad, California on Wednesday, the 24th day of August 2016 at: 

Law Offices of Ronald J. Cozad 

Premier Jet Building 

McClellan-Palomar Airport 

21 00 Palomar Airport road, Suite 214 

Carlsbad, CA 92011 

FAA Case No. 2015WP090037 

NOTICE OF DEPOSITION 

AND REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS 

Page3 
The deposition will begin at 9:30AM and continue thereafter from day to day until finished. You 

are required to be present and ready with the requested documents for reviewing and copying at the 

dates, time, and place for oral examination. 

Dated: August 12, 2016 

· Michael L. Dworkin 

Attorneys for TANGO AIR, INC, d/b/a 

SCHUBACH AVIATION 

FAA Case No. 2015WP090037 

NOTICE OF DEPOSITION 

AND REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS 

Page 4 
CERTIFICATE OF SERVICE 

The undersigned hereby certifies that on this 12th day of August 2016, a true and correct 

copy of the foregoing AMENDED NOTICE OF DEPOSITION AND REQUEST FOR 

PRODUCTION OF DOCUMENTS AND TIDNGS was served as follows: 

David Shayne, Esq. 

Attorney, Enforcement Division 

Western Team 

Federal Aviation Administration 

1601 Lind Avenue, SW 

Renton, W A 98057 

David.F .Shayne@faa.gov 

FAX: 1-425-227-1007 

(One copy via Email; one copy via FAX) 

Michael L. Dworkin 

FAA Case No. 2015WP090037 

NOTICE OF DEPOSITION 

AND REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS 

Page 5 
CERTIFICATE OF SERVICE 

The undersigned hereby certifies that on this 15th day of August 2016, a true and correct 

copy of the foregoing AMENDED NOTICE OF DEPOSITION AND REQUEST FOR 

PRODUCTION OF DOCUMENTS AND THINGS 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 via FED EX) 

David Shayne, Esq. 

Attorney, Enforcement Division 

Western Team 

Federal Aviation Administration 

1601 Lind Avenue, SW 

Renton, W A 98057 

FAX: 1-425-227-1007 

(One copy via FED EX; one copy via 

FAX) 

FAA Case No. 2015WP090037 

NOTICE OF DEPOSITION 

AND REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS 

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