02/19/2010 14;01 FAX 2024935142 

02/02/2010 13:16 4043055223 

FAA * DMS 

FAA REQIDNAL COUNSEL 

0 002/005 

PA6E 02/05 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

FEDERAL AVIATION ADMINISTRATION, 

CoiTLplaijiaTit, 

vs. 

SKYDIVE KENTUCKY LLC 

Respondent. 

FAA Deckel No. 2008CE170150 

Judge Not Assigned 

AGENCY'S REQUEST FOR DISCOVERY 

AND PRODUCTION OF DOCUMENTS 

Pursuant to Rules 26(b) and 34(a) of the Federal Rules of Civil, Procedure, the discovery 

guidelines set forth in case precedent, and Section 13.220 of the Rules of Practice in FAA Civil 

Penalty Actions [14 C.F.R. §13.220], the Agency, the Complainant, by ard through the 

undersigned counsel, hereby propounds the following Request for Production, and 

IntotTogalories, and requests your responses not later than 3D days of service oFthis request. 

Ansvvcr each Interrogatory separately and fully in writing under oath, unless it is objected to, in 

•which event tlie reasons for objection shall be stated in lieu of an answer. The answers are to be 

signed by the person making them, and the objections signed by tJie attorney making them. 

You may respond to the Requests for Production by producing true and accurate copies of the 

originals, Jf you refuse to produce any documents or other evideiicc on the basis of privilege or 

other objection, identify specifically the items withheld from p.roduction. 

These discovery requests shall be continuing in nature 50 as to require you to file supplemental 

responses in the following circumstances: 

(a) When you become aware of the identify and location of any witness, lay or expert, 

who is not identified in your original response; or 
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(b) When your original response was initially correct, but subsequently rendered 

incorrect or inaccurate based upon infonnation discerned after the original 

response is prepared. 

DEFINITIONS 

"Documents" include, without limitation, notes, memoranda, invoices^ work orders, receipts, 

reports, letters, audio and video tapes, photographs, facsimiles, transcripts, written statements, 

records of conversations, computer disks or tapes, and other tangible materials. 

"Yovi" or "your" refers to Respondent and his agents, officers, or employees. 

"Identify," when referring to persons, reqaires you to provide the fiill name, address, leleplionc 

number (business and residence, where available) and any other information pertinent to locating 

such person. When pertaining to an object or place, "identify" means to provide the name, 

location or other description of sucli object or place. 

"This matter" refers to the events and circumstances underlying the allegations set forth in the 

Complaint. 

TNTERROGATORIES 

1. The name, occupation, and business address of each person Respondent intends to 

call as a witness in this proceeding. 

2. The subject matter upon which each intended witness is expected to testify, ihc 

facts and opinions as to which each intended witness is expected to testify, and a summairy of the 

grounds for each opinion. 

3. To the extent that any expert witness is expected to testify, identifiy any reports 

and records that form the basis for this testimony. 

4. If you deny any of the allegations of the Complaiiil, explain the factual basis for 

each denial, and identify witnesses and exhibits you anticipate offering as evidence for such 

factual bases, 

REQUESTS FOR PRODUCTION 

1. To the extent that any expen: witness is expected to testify, reports and records 

that form rlie basis for this testimony. 
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2. Copies of any documents which Respondent intends to introduce into evidence 

and which have not already been submitted to the Agency. Please identify those documents 

which have already been submitted to the Agency. 

3. The financial statement found attached to this .request completed under oath by the 

Respondent. 

me .information requested herein should be submitted within thirty (30) days apcr service of this 

document to; 

TanceshaD. Marshall 

Federal Aviation Administration 

Office of the Regional Counsel, ASO-7 

Southern Region 

P.O. Box 20(i36 

Atlanta, GeoTgia 30320 

Telephone: (404) 305-5200, facsimile (404) 305-5223. 

Rcspectfiilly submitted this <^ day of Februaryr, 2010. 

TANEESHA D. MARS | 

Attorney 

Office of the Regional Counsel 
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CERTIFlCf TE OF SERVICE 

I hereby certify that the foregoing Agency's Request for Discovery and Production of 

Docioments has been sent by facsimile & Regular Mail to: 

Hearing Docket 

FAA, AGC-400, Room 2014 

600 Independence Avenue, SW 

Washington, DC 20591 

(.Fax) 202-267-5919 

Allen K. Gailor, Esq. 

Gailor Law Office 

730 West Market Street 

100 Professional Arts Building 

Louisville, KY 40202-2744 

Fax (502) 584-4848 

FEB 2 2010 

Dated