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June 30, 2011 

LieiTC M. Green ''— -• *•- < ^ 

US Departmeni ot" Transportation 

Western-Pacific Region, Office of the Regional Counsel 

PO Box '•>2007 

I.OS Ancelcs. C A 90009-2007 

y Hearing Docket Clerk 

Federal Aviyiion AdminisTratinn 

800 Independence Ave. SW 

• Room 924A 

Wa.shingion. DC2U591 

^011-04^3 

Re: fn rhc Mailer of K.S. Aviation. Inc. d/h/a Sierra Academy of Aeronautics 

CoseNo. 2011WP170009 

Judge: Not Assigned 

Dear Ms. Green and Clerk: 

Enclosed and served on you please find Respondent\'; First Requesl lor Discovery in the 

above nidUcr. 

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Enclosure 

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07/15/201 1 151 7 FAX 2024935142 FAA •^ OI-I S 21002/004 

US DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON. DC 

In the Matter of K.S. Aviation, Inc. 

d/b/a Sierra Academy of Aeronautics, 

FAA DOCKET UNASSIGNED 

FAA CASE NO. 2011WP170009 

Respondent. 

fUDGE NOT ASSIGNED 

RESPONDENT'S FIRST REQUEST FOR DISCOVERY 

TO: Federal Aviation Administration 

800 Independence Ave, SW 

Room 924A 

Washington, DC 20591 

The Respondent. K.S. Aviation, Inc. d/b/a Sierra Academy of Aeronautics, by 

ins undersigned counsel, requests thac the Administrator provide responses to the 

follovi^ing discovery requests v^ithin thirty (30) days, in accordance with Section 

821.19 ot the Rules of Practice in Air Safety Proceedings and Rules 33 and 34 of the 

Federal Rules of Civil Procedure: 

Interrogatories 

1. State the name, address, telephone number, and title of each person vi'ho. on 

behalf of the Administrator (including the Civil Aviation Security Division), 

investigated the alleged violations of the complaint, and identify each report 

rendered by such person and the custodian thereof. 
07/15/201 1 15-17 FAX 2024935142 FAA - OMS 12)003/004 

2. State the name, address, telephone number, and title of each other person 

upon whom the Administrator relies to support his Complaint that the Respondent 

violated the Federal Aviation Regulations as charged in the Complaint. 

3. State which of the persons identified in Interrogatory No. 1 and Interrogatory 

No. Z above made written statements to the Administrator concerning this case, and 

further state in whose custody each such written statement reposes. 

4. Please describe m detail each document or tangible evidence relied upon to 

support the Administrator's claim that Respondent violated the Federal Aviation 

Regulations as charged in Complaint, and the name, address, title, and telephone 

number of the person having custody of each such documentor tangible evidence. 

5. With respect to each witness whom you expect to call to give testimony in 

this case, state the follovying: 

a. Name, address, and telephone number; 

b. Name and address of his nr her employer; and 

c. The substance of the facts to which he or she is expected to testify. 

6. If you are relying on it to support the sanction sought to be imposed, state 

the violation history of the Respondent as reflected in the Administrator's records. 

Request for Production of Documents 

1. Furnish copies of any items or exhibits the Administrator intends to 

use at the hearing in this matter, including, but not limited to, 

photographs, maps, charts, documents, and reports, unless previously 

provided as a part of the Enforcement Investigative Report. 
07/15/201 1 15:17 FAX 2024935142 FAA - DMS @]004/004 

2. Furnish copies of any items that are referenced in response to the 

above interrogatories, including the releasable portion of the 

Enforcement Investigative Report unless the documents have been 

previously provided. 

Respectfully submitted. 

Da ted: ^ Sd ) -/ / 

Robert ).>Iajefc-^q. 

Counsel for Respondent 

829 Stratford Court 

Del Mar, CA 92014 

Office: 612-801-B067 

Fax: 800-405-4530 

TollPree: 888-651-2097 

CKRTIFICATF OF SERVICE 

I hereby certify that I have this date mailed, by regular mail, an original and 

one copy of the foregoing Respondent's First Request for Discovery addressed to: 

Federal Aviation Administration 

800 Independence Ave, SW 

Room 924A 

Washington. DC 2U591 

Attn: Hearing Docket Clerk 

And, further, that 1 have this date mail, by regular mail, a copy ofthe 

foregoing Respondent's First Request for Discovery addressed to: 

iJorre M. Green 

US Department of Transportation 

Western-Pacific Region, Office ofthe Regional Counsel 

PO Box 92007 

Los Angeles, CA 90009-2007 

Fax:(310)725-6816 

Dated: {^S^-//