KYLE E. LOMAZOW FAA OFFICE OF REGIONAL COUNSEL 1601 LIND AVE., SW RENTON, WASHINGTON 98057 TELEPHONE: (425)227-1847 FACSIMILE: (425)227-1007 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS

WASHINGTON, D.C. MICHAEL J. HUERTA, Administrator FederalAviation Administration; Complainant,

JETTECH LLC; Respondent. vs. FAA Case Number: 2012NM030058 FDMS No. FAA-2013-1079 Judge Richard C. Goodwin



### ADMINISTRATOR'S REQUEST FORDISCOVERY

In accordance with 49 Code ofFederal Regulations (C.P.R.) Section 821.19, and the Federal Rules ofCivil Procedure, please respond to the following Interrogatories, Requests for Production ofDocuments, and Request for Admissions, prior to April 25, 2014. These discovery requests are intended to discover information and/or documents not only within your personal knowledge or obtainable by JETTECH, LLC (JETTECH), but also information in the possession ofor obtainable by JETTECH's attorneys, investigators, representatives, employees, agents, or anyone acting on JETTECH's behalf. These discovery requests are continuing in nature and any information which may be discovered by JETTECH subsequent to the service and filing ofits answers mustbe brought to the attention ofthe agency attorney through supplemental answers when it becomes available to JETTECH, and a reasonable time prior to the hearing inthis matter. Ifthere are any additions, deletions or changes in the answers or information provided at any time prior to hearing the Respondent is specifically requested to so immediately inform the agency attorney. Ifsuch

ADMINISTRATOR'S REQUEST FOR DISCOVERY JETTECH LLC- FDMS No, FAA-2013-1079 Page I of7 KYLE LOMAZOW, FAAATTORNEY TEL: (425) 227-1847; FAX: (425) 227-1007information is not furnished, the agency attorney at the time ofthe hearing will move to exclude from evidence such information requested and not furnished. The agency attorney further requests that the Respondent produce the documents identified and designated herein for inspection and copying at the Federal Aviation Administration, Office ofRegional Counsel, 1601 Lind Avenue Southwest, Renton, Washington 98057, prior to April25, 2014. PRIVILEGE If, inresponding to, or failing to respond to these interrogatories and requests for production JETTECH invokes orrelies upon any privilege ofany kind, state specifically the nature ofthe privilege; the basis upon which JETTECH invokes, relies upon, or claims it, including any statutory or decisional reference; and identify all documents or other information, including contacts and communications which JETTECH believes to be embraced by the privilege invoked. INTERROGATORIES InterrogatoryNo.1: IdentifY all documents, including correspondence, obtained by JETTECH, LLC (JETTECH) or in its possession, relating to the assertions in the Complaint, JETTECH's Appeal, its Answer, and any affirmative defenses which JETTECH anticipates raising inthis matter. See Request for ProductionNo. l. Interrogatory No. 2: Identityby name, address and telephone number, all persons whom JETTECH intends to have testifY as a factual or expert witness in JETTECH's defense at the hearing inthis matter, and for factual witnesses, provide a detailed summary ofeach persons anticipated testimony. Interrogatory No.3: With respect to each expert witness identified in response to Interrogatory No. 2, above, specifY their specific area ofexpertise, and provide a synopsis oftheir credentials, background, training and experience. Interrogatory No. 4: IdentifY by title, date, author, present custodian and content, all documents which JETTECH anticipates offering into evidence or using at the hearing inthis matter, and through which witness or witnesses the document will be offered. See Request for ProductionNo. 2. Interrogatory No.5: With respect to each expert JETTECH expects to call as a witness, state the subject matter on whichthe expert is expectedto testifY, the

ADMINISTRATOR'S REQUEST FORDISCOVERY JETTECH LLC- FDMS No. FAA·2013-l079 Page 2 of7 KYLELOMAZOW, FAAATTORNEY TEL: (425) 227-1847; FAX: (425) 227-1007substance ofthe facts and opinions to whichthe expert is expected to testify, and a summary ofthe grounds for each such opinion. Interrogatory No. 6: Describe with specificity all ofthe facts which JETTECH anticipates presenting inthe course ofthe hearing in this matterpertaining to the avoidance or mitigation ofthe sanction sought bythe Federal Aviation Administration (FAA) inthis case. Interrogatory No.7: State byname, address, telephone number, date ofconversation, and substance ofconversation, all persons, otherthanlegal counsel, with whom JETTECH discussed the matters alleged in the Complaint. Interrogatory No. 8: For each allegation inthe Complaintthat is denied-whether outright or as a result ofhaving insufficient information or knowledge from which to form a beliefas to the truth ofthe allegation-state with specificity the facts that are the basis for that denial as well as the inquiries taken to determine that the allegation in the complaint is not correct. See Request for ProductionNo.3. Interrogatory No.9: For any ofthe requests for admissions belowthat are deniedwhether outright or as a result ofhaving insufficient information orknowledge from whichto form a beliefas to the truth ofthe allegation- state with specificity the facts and evidence which are the basis for that denial as well as the inquiries taken to determine that the facts inthe request for admission are not correct. Interrogatory No. 10: Describe with specificity all facts or evidence JETTECH intends to rely upon in support ofany affirmative defenses raised inits Answer to the Complaint. See Request for Production No. 4. Interrogatory No. 11: State the name(s) ofthe individual(s) from the Denver Flight Standards District Office JETTECH claims gave JETTECH verbal field approval as indicated in Paragraph 16 ofJETTECH's Answer, the date the verbal approval was given and whatthat approval consisted of. See Request for ProductionNo. 5 Interrogatory No. 12: Identify which FAA-approved data JETTECH used when it performedthe work on aircraftNl50BV onAprillO, 2012.

ADMINISTRATOR'S REQUEST FORDISCOVERY JETTECH LLC- FDMS No. FAA-20!3-I079 Page 3 of7 KYLELOMAZOW, FAAATTORNEY TEL: (425) 227-1847; FAX: (425) 227-1007REQUESTS FORPRODUCTION Request for Production No. 1: Provide a copy ofall documents referred to inyour answer to Interrogatory No. 1. Request for Production No. 2: Provide a copy ofall documents referred to inyour answer to InterrogatoryNo. 4. Request for Production No.3: Provide a copy ofall documents that support your answer to Interrogatory No. 8. Request for ProductionNo. 

## 4: Provide a copy ofall documents that support your answer to Interrogatory No. 10. Request for ProductionNo.5: Provide a copy ofall documents that support your answer to Interrogatory No. 11. 

### REQUESTS FORADMISSIONS Instructions: Admit or deny each ofthe requests for admissions listed below. For each and every request for admission thatyou deny, state the basis for your denial. See InterrogatoryNo. 9 above. Request for Admission No. 1: Admit that JETTECH returned aircraftNl50BV to service onAprillO, 2012 without any written approval from the FAA. Request for AdmissionNo. 2: Admit that JETTECH returned aircraft N150BV to service onApril 10, 2012 without a stamp or written sign offfrom the FAAunder block 3 ofthe Forrn(s) 337 included inthe data package that was mailed to the DenverFlight Standards District Office (FSDO) onApril16, 2012. Request for AdmissionNo.3: Admit that final approval for return to service upon completion ofan alteration orrepair requires the signature ofan authorized individual under Block 7 ofFAA Form 337. Request for Admission No. 4: Admitthat the datapackage JETTECHmailedto the FAA onApril16, 2012 did not include a signature from an authorized personunder Block 7 on any ofthe form 337'sthat JETTECH submitted to the Denver FSDO on Apri116, 2012.

ADMINISTRATOR'S REQUEST FORDISCOVERY JETTECH LLC -FDMS No. FAA-2013-1079 Page 4 of7 KYLE LOMAZOW, FAAATTORNEY TEL: (425) 227-1847; FAX: (425) 227-1007Request for Admission No. 5: Admit that JETTECH's Capabilities List dated 3/15/2010, does not include a CessnaModel525 civil aircraft. Request for Admission No.6: Admit that JETTECH's Capabilities List dated 3/15/20I0 does not include the Ganninunits which were installed on aircraft Nl50BV on April!O, 2012. Request for AdmissionNo.7: Admitthat the Gannin GDL satellite receiver JETTECH installed on aircraft N150BV on April!O, 2012 deviated from Supplemental Type Certificate (STC) SA01487SE-D. Request for Admission No.8: Admit that the installation mentioned inRequest for Admission No. 8 deviated from the approved STC data because the installation included an antenna which was interfaced withthe GTN installation. Request for Admission No.9: Admitthat because the installation ofthe Gannin GDL satellite receiver mentioned inParagraph 7 deviated from the STC approval was required from the FAA for the modified data. Request for Admission No. 10: JETTECH performed an installation ofthe Gannin GTN 750 Series Avionics System using STC Number SA02019SE-D as a basis for the installation data. Admitthat the CessnaModel 525 Civil Aircraft is not onthis STC's approved aircraft list. Request for Admission No. 11: Admitthat JETTECH failed to revise the aircraft operating limitations by seeking approval for the issuance ofan FAA approved Airplane Flight Manual (AFM) supplement as required by STC SA0202019SE for the installationreferenced inRequest for AdmissionNo. I0. Request for AdmissionNo. 12: Admit that JETTECH sent the Denver FSDO a data package requesting field approval.for the work performed on aircraft Nl50BV five (5) days after JETTECH had already performedthat work. Request for Admission No. 13: Admitthat on April13, 2012, N150BV was operated on a flight departing frcm the Rocky MountainMetropolitan Airport.

ADMINISTRATOR'S REQUEST FORDISCOVERY JETTECH LLC- FDMS No. FAA-2013-1079 Page 5 of7 KYLELOMAZOW,FAAATTORNEY TEL: (425) 227-1847; FAX: (425) 227-1007Reguest for AdmissionNo. 14: Admit that JETTECH approved for return to service aircraftN150BV before receiving FAA data approvaL Respectfully submitted this 121h day ofMarch 2014. Dwight S. Williams Acting Regional Counsel

By: le E. Lomazow Attorney Office ofthe Regional Counsel (AMN-7) Federal Aviation Administration 1601 Lind Avenue, SW Renton, W A 98057 (425) 227-1847 (425) 227-1007 FAX E-mail Address: kyle.lomazow@faa.gov

ADMINISTRATOR'S REQUEST FORDISCOVERY JETTECH LLC-FDMSNo. FAA-2013-1079 Page 6 of7 KYLELOMAZOW,FAAATTORNEY TEL: (425) 227-1847; FAX: (425) 227-1007CERTIFICATE OF SERVICE



### I hereby certify that the foregoing Administrator's Request for Discovery has been served via Email and Certified Mail -Return Receipt Requested this date, to the following: Federal Aviation Administration (Original and one copy) Attn: Hearing Docket Clerk, AGC-430 Wilbur Wright Building800 Independence Avenue SW Washington, D.C. 20591 Email: Richard.Goodwin@dot.gov Patricia.Matthews@dot.gov Michael 

### L. Poindexter, Esq. The Law Offices ofMichael L. Poindexter, P.C. 2132 Montane Drive E. Golden, CO 80401 Email: poinlaw@aol.com

Dated this 

### 12'h day ofMarch 2014.

Mary mith Office of egional Counsel (ANM-7) Federal AviationAdministration 1601 LindAve. SW Renton, WA 98057 (425) 227-2925

ADMINISTRATOR'S REQUEST FORDISCOVERY JETTECHLLC-FDMS No. FAA-2013-1079 Page 7 of7 KYLE LOMAZOW, FAAATTORNEY TEL: (425) 227-1847; FAX: (425) 227-1007