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 

Federal Aviation Administration; 

Complainant, 

JETTECH LLC; 

Respondent. 

vs. 

FAA Case Number: 2012NM030058 

FDMS No. FAA-2013-1079 

Judge Richard C. Goodwin 

ADMINISTRATOR'S REQUEST FOR DISCOVERY 

In accordance with 49 Code of Federal Regulations (C.P.R.) Section 821.19, and 

the Federal Rules of Civil Procedure, please respond to the following 

Interrogatories, Requests for Production of Documents, 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 of or 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 of its answers 

must be brought to the attention ofthe agency attorney through supplemental 

answers when it becomes available to JETTECH, and a reasonable time prior to 

the hearing in this matter. If there 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. If such 

ADMINISTRATOR'S REQUEST FOR DISCOVERY 

JETTECH LLC- FDMS No, FAA-2013-1079 

Page I of7 

KYLE LOMAZOW, FAA ATTORNEY 

TEL: (425) 227-1847; FAX: (425) 227-1007 
information is not furnished, the agency attorney at the time of the 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 of Regional Counsel, 1601 Lind Avenue 

Southwest, Renton, Washington 98057, prior to April25, 2014. 

PRIVILEGE 

If, in responding to, or failing to respond to these interrogatories and requests for 

production JETTECH invokes or relies upon any privilege of any kind, state 

specifically the nature of the 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 

Interrogatory No.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 in this matter. See Request for Production No. l. 

Interrogatory No. 2: Identity by 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 in this matter, and for factual witnesses, provide 

a detailed summary of each persons anticipated testimony. 

Interrogatory No.3: With respect to each expert witness identified in response to 

Interrogatory No. 2, above, specifY their specific area of expertise, and provide a 

synopsis of their 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 in this matter, and through which witness or witnesses the document will be 

offered. See Request for Production No. 2. 

Interrogatory No.5: With respect to each expert JETTECH expects to call as a 

witness, state the subject matter on which the expert is expected to testifY, the 

ADMINISTRATOR'S REQUEST FOR DISCOVERY 

JETTECH LLC- FDMS No. FAA·2013-l079 

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KYLE LOMAZOW, FAA ATTORNEY 

TEL: (425) 227-1847; FAX: (425) 227-1007 
substance of the facts and opinions to which the expert is expected to testify, and a 

summary of the grounds for each such opinion. 

Interrogatory No. 6: Describe with specificity all of the facts which JETTECH 

anticipates presenting in the course of the hearing in this matter pertaining to the 

avoidance or mitigation of the sanction sought by the Federal Aviation 

Administration (FAA) in this case. 

Interrogatory No.7: State by name, address, telephone number, date of conversation, and 

substance of conversation, all persons, other than legal counsel, with whom JETTECH 

discussed the matters alleged in the Complaint. 

Interrogatory No. 8: For each allegation in the Complaint that is denied-whether 

outright or as a result of having insufficient information or knowledge from which to 

form a belief as to the truth of the 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 Production No.3. 

Interrogatory No.9: For any of the requests for admissions below that are deniedwhether outright or as a result of having insufficient information or knowledge from 

which to form a belief as to the truth of the 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 in the request for admission are not correct. 

Interrogatory No. 10: Describe with specificity all facts or evidence JETTECH 

intends to rely upon in support of any affirmative defenses raised in its Answer to the 

Complaint. See Request for Production No. 4. 

Interrogatory No. 11: State the name(s) of the individual(s) from the Denver Flight 

Standards District Office JETTECH claims gave JETTECH verbal field approval as 

indicated in Paragraph 16 of JETTECH' s Answer, the date the verbal approval was 

given and what that approval consisted of. See Request for Production No. 5 

Interrogatory No. 12: Identify which FAA-approved data JETTECH used when it 

performed the work on aircraft Nl50BV on AprillO, 2012. 

ADMINISTRATOR'S REQUEST FOR DISCOVERY 

JETTECH LLC- FDMS No. FAA-20!3-I079 

Page 3 of7 

KYLE LOMAZOW, F AAATTORNEY 

TEL: (425) 227-1847; FAX: (425) 227-1007 
REQUESTS FOR PRODUCTION 

Request for Production No. 1: Provide a copy of all documents referred to in your 

answer to Interrogatory No. 1. 

Request for Production No. 2: Provide a copy of all documents referred to in your 

answer to Interrogatory No. 4. 

Request for Production No.3: Provide a copy of all documents that support your 

answer to Interrogatory No. 8. 

Request for Production No. 4: Provide a copy of all documents that support your 

answer to Interrogatory No. 10. 

Request for Production No.5: Provide a copy of all documents that support your answer 

to Interrogatory No. 11. 

REQUESTS FOR ADMISSIONS 

Instructions: Admit or deny each of the requests for admissions listed below. For 

each and every request for admission that you deny, state the basis for your denial. 

See Interrogatory No. 9 above. 

Request for Admission No. 1: Admit that JETTECH returned aircraft Nl50BV to 

service on AprillO, 2012 without any written approval from the FAA. 

Request for Admission No. 2: Admit that JETTECH returned aircraft N150BV to 

service on April 10, 2012 without a stamp or written sign off from the FAA under 

block 3 of the Forrn(s) 337 included in the data package that was mailed to the 

Denver Flight Standards District Office (FSDO) on April16, 2012. 

Request for Admission No.3: Admit that final approval for return to service upon 

completion of an alteration or repair requires the signature of an authorized 

individual under Block 7 of FAA Form 337. 

Request for Admission No. 4: Admit that the data package JETTECH mailed to the 

FAA on April16, 2012 did not include a signature from an authorized person under 

Block 7 on any of the form 337's that JETTECH submitted to the Denver FSDO on 

Apri116, 2012. 

ADMINISTRATOR'S REQUEST FOR DISCOVERY 

JETTECH LLC -FDMS No. FAA-2013-1079 

Page 4 of7 

KYLE LOMAZOW, F AAATTORNEY 

TEL: (425) 227-1847; FAX: (425) 227-1007 
Request for Admission No. 5: Admit that JETTECH' s Capabilities List dated 

3/15/2010, does not include a Cessna Model525 civil aircraft. 

Request for Admission No.6: Admit that JETTECH's Capabilities List dated 

3/15/20 I 0 does not include the Gannin units which were installed on aircraft 

Nl50BV on April!O, 2012. 

Request for Admission No.7: Admit that 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 in Request for 

Admission No. 8 deviated from the approved STC data because the installation 

included an antenna which was interfaced with the GTN installation. 

Request for Admission No.9: Admit that because the installation of the Gannin 

GDL satellite receiver mentioned in Paragraph 7 deviated from the STC approval 

was required from the FAA for the modified data. 

Request for Admission No. 10: JETTECH performed an installation of the Gannin 

GTN 750 Series Avionics System using STC Number SA02019SE-D as a basis for 

the installation data. Admit that the Cessna Model 525 Civil Aircraft is not on this 

STC's approved aircraft list. 

Request for Admission No. 11: Admit that JETTECH failed to revise the aircraft 

operating limitations by seeking approval for the issuance of an FAA approved 

Airplane Flight Manual (AFM) supplement as required by STC SA0202019SE for 

the installation referenced in Request for Admission No. I 0. 

Request for Admission No. 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 performed that work. 

Request for Admission No. 13: Admit that on April13, 2012, N150BV was 

operated on a flight departing frcm the Rocky Mountain Metropolitan Airport. 

ADMINISTRATOR'S REQUEST FOR DISCOVERY 

JETTECH LLC- FDMS No. FAA-2013-1079 

Page 5 of7 

KYLELOMAZOW,FAAATTORNEY 

TEL: (425) 227-1847; FAX: (425) 227-1007 
Reguest for Admission No. 14: Admit that JETTECH approved for return to service 

aircraft N150BV before receiving FAA data approvaL 

Respectfully submitted this 121

h day of March 2014. 

Dwight S. Williams 

Acting Regional Counsel 

By: 

le E. Lomazow 

Attorney 

Office of the 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 FOR DISCOVERY 

JETTECH LLC-FDMS No. FAA-2013-1079 

Page 6 of7 

KYLELOMAZOW,FAAATTORNEY 

TEL: (425) 227-1847; FAX: (425) 227-1007 
CERTIFICATE 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 of Michael L. Poindexter, P.C. 

2132 Montane Drive E. 

Golden, CO 80401 

Email: poinlaw@aol.com 

Dated this 12'h day of March 2014. 

Mary mith 

Office of egional Counsel (ANM-7) 

Federal Aviation Administration 

1601 LindAve. SW 

Renton, WA 98057 

(425) 227-2925 

ADMINISTRATOR'S REQUEST FOR DISCOVERY 

JETTECHLLC-FDMS No. FAA-2013-1079 

Page 7 of7 

KYLE LOMAZOW, FAA ATTORNEY 

TEL: (425) 227-1847; FAX: (425) 227-1007