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 16 2015

TANGO AIR, INC., d/b/a SCHUBACH AVIATION AMENDED NOTICE OF DEPOSITION AND REQUEST FORPRODUCTION OF DOCUMENTS AND THINGS Judge: Honorable J. E. Sullivan

To: David Shayne, Esq. Federal Aviation Administration EnforcementDivision, Western Team Federal AviationAdministration 1601 LindAvenue, SW Renton, WA 98057 TheNotice ofDeposition and Request for Production ofDocuments and Things, served July 29, 2016, is amended to reflect a change inthe location and time ofsaid deposition, in accordance with the agreement ofcounsel for the parties. PLEASETAKENOTICE that the Respondent, TANGO AIR, INC., d/b/aSCHUBACH AVIATION (hereinafter "TANGO") will take the oral deposition ofthe person specified below, atthe date, time, and place specified for all purposes permitted by the Rules of Practice, Part 13, Subpart G, ofthe 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 ofRonald 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 ofsaid deposition, the following documents: I. Current curriculum vitae; 2. All writings or documents reflecting date and purpose ofinitial involvementin this matter; 3. Writings, documents, materials and things memorializing:
a. Correspondence and communications withFAA employees and agents concerning this matter, includingbutnot limitedto 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 butnot limited to the allegations contained inthe Complaint and any admissions, denials,

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NOTICE OF DEPOSITION AND REQUEST FORPRODUCTION OF DOCUMENTS AND THINGS Page2averments 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 ofthe FAA's investigation ofthis matter; 4. Deponent's conclusions and opinions, ifany, developed in connection with Deponent's investigation in and prosecution ofthis matter, including but not limited to conclusions and opinions concerning the appropriateness ofthe sanction soughtby the FAA, and all facts and evidence in support ofsuch conclusions and opinions; 5. Copies ofall writings, texts, treatises, books, articles, legal opinions, orders, advisory circulars, statutes, regulations or otherpublications or sources ofinformation Complainant has reviewed, examined and/or relied upon in formulating opinions and conclusions as to the appropriateness ofinitiating andprosecuting the enforcement action in this matter and in computing the civil penalty proposed inthis matter; 6. All reports and notes prepared by Deponent during the course ofDeponent's review ofmaterials, interviews with witnesses, Federal and State employees, including but not limitedto 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 ofthe above-named deponentbefore a courtreporter in the City ofCarlsbad, California onWednesday, the 24th day ofAugust 2016 at: Law Offices ofRonald J. Cozad Premier Jet Building McClellan-Palomar Airport 2100 Palomar Airportroad, Suite 214 Carlsbad, CA 92011

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NOTICE OF DEPOSITION AND REQUEST FORPRODUCTION OF DOCUMENTS AND THINGS Page3The 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, andplace for oral examination.

Dated: August 12, 2016

· Michael L. Dworkin Attorneys for TANGOAIR, INC, d/b/a SCHUBACHAVIATION

FAA Case No. 2015WP090037

NOTICE OF DEPOSITION AND REQUEST FORPRODUCTION OF DOCUMENTS AND THINGS Page 4CERTIFICATE OF SERVICE The undersigned hereby certifies that on this 12th day ofAugust 2016, a true and correct copy ofthe foregoing AMENDED NOTICE OF DEPOSITIONAND REQUEST FOR PRODUCTION OFDOCUMENTS AND TIDNGS was served as follows:
David Shayne, Esq. Attorney, EnforcementDivision Western Team Federal Aviation Administration 1601 Lind Avenue, SW Renton, WA 98057 David.F.Shayne@faa.gov FAX: 1-425-227-1007 (One copy viaEmail; one copy via FAX)

Michael L. Dworkin

FAA Case No. 2015WP090037

NOTICE OF DEPOSITION AND REQUEST FORPRODUCTION OFDOCUMENTS AND THINGS Page 5CERTIFICATE OF SERVICE The undersigned hereby certifies that onthis 15th day ofAugust 2016, a true and correct copy ofthe foregoing AMENDED NOTICE OF DEPOSITION AND REQUEST FOR PRODUCTION OFDOCUMENTS AND THINGS 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 via FEDEX)
David Shayne, Esq. Attorney, Enforcement Division Western Team Federal Aviation Administration 1601 LindAvenue, SW Renton, WA 98057 FAX: 1-425-227-1007 (One copy via FEDEX; one copy via FAX)

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