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•":L!;ARTMENTOF 

TR/\M3P0RTAT!GN 

•^OCKETOI^ERATiONS 

ZO!t Cr|? 3 A S: i 8 RECEIVED 

OCT 2 5 2011 

HEARING DOCKET 

John C. Doubck 

DOUDCK, PYFHK & FOX, LLP 

307 N. Jackson 

P.O. Box 236 

Helena, M T 5%24 

Attorney for Respondent 

UNITED STATES OF AMERICA 

DEPARTMENT OF TR.\NSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. dbi\'bL^'^3 

J. RANDOLPH BABBITT, Administrator ) PAA DOCKET CP UNASSIGNED 

Federal Aviation Administration. ) 

) I-AA Case No.: 2011NM190012 

Complainant, ) 

) RESPONDENT'S RESPONSES 

MAUREEN T. WILSON-DOUBEK ) JO COMPT,AINANT' S 

) DISCOVERY REQUESTS 

Respondent. ) Judge Unassigncd 

CoiTies now Respondent and responds to Complainant's initial discovery rct^ucMS 

as Ibllows: 

INTERROGATORY NO. 1: Describe with specificity all ol'the facts and 

arguments which you anlicipale presenting in the course of the DOT hearing in this 

matter pertaining to the avoidance or mitigation of the sanction sought by the FAA in this 

ca.<^e. 

ANSWER: Maureen Wiison-Doubek. hereatter referred to as Respondent, 

purchased a small bottle of wine alter passing through security and before she got on the 

airplane. She was never told and believed that it was perfectly proper and lawful for her 

to buy the wine at the counter which was in the boarding/wailing area. Others would 

purchase wine and drink it on the airplane and no one ever told her that was improper or 

unlawful. Indeed, she had worked at that same counter previously and no one had ever 

told her that she needed to inform any of the purchasers that they could purchase hut not 

drink the wine when Ihey boarded the airplane. Insofar as mitigation is concerned, 

Respondent receives Social Security Disability benefits. 
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INTERROGATORY NO. 2: Identify by name, address and telephone number all 

persons whom you know to have personal knowledge of the matters alleged in the 

Complaim. 

ANSWER: Respondent inlends to call the proprietor of the counter which she 

has described in the previous answer to Interrogatory No. 1 to testify in a similar vein, 

that is. that no one is told they cannot consume the beverage which they purchase from 

that area once they board the /light. Respondent has already provided a letter from thai 

individual. 

INTERROOA rORY NO. 3: Identify by title, date, author present custodian, and 

content, all documenis. including correspondence, obtained by you or in your possession, 

relating to the assertions in the Complaint, your appeal, your answer, and any aftlimative 

defenses which you anticipate raising in this matter. 

ANSWER; Nothing beyond what has already been submitted. 

rNTERROGATORY NO. 4: Identify by name, address and telephone number, all 

persons whom you intend to have testify a.s a factual or expert witness in your defense at 

the hearing in this matter, and for factual witnesses, provide a detailed summary of each 

persons anticipated te.-itimony. 

ANSWT£R: Respondent does intend to call as witnesses by deposition or in 

person the two flight attendants on board the involved aircraft. The female flight 

auendant, will tesiif}', Respondent expects, thai the male attendant treated Respondent 

nidcly by telling her .*;he was in trouble for taking a drink from the wine bottle and not 

explaining the situation or the limitations on consumption of wine not purchased aboard 

the aircraft. Respondent will testify aa vvill the proprietor of the service counter in.side the 

secured area of the terminal. Their testimony will be in accord with the letter which was 

submitted by the vendor/proprietor and the information and facts asserted in 

Respondent's Answer. 

INTERROGATORY NO. 5: Identify by title, date, auUior, present custodian, and 

content, all document'; which you anticipate offering into evidence at the hearing in this 

matter, and through which wimess or witnesses. 

ANSWER: Because certain of the wimesses may need to be deposed. 

Respondent cannot answer this Interrogatory No. 5 beyond answering that she intends to 

testify and she will call the vendor/proprietor of the counter. They will testify that wine 

is sold to people within the secured area of the airport, that many people take that wine 

aboard and drink it aboard to the best of their knowledge and experience. 
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INTERROGA'fORY NO. 6: With respect to each expen witness identilled in 

response to Interrogator^' No. 4. above, specify their specific area of expertise, and 

provide a synopsis of their credentials, background, training and experience. 

ANSWER: No expert witnesses are anticipated. 

INTERROG.ATORY NO. 7: With respect to caeh expert you expect to call as a 

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

substance of the facts and opinions to which the expert is expected to testily, and a 

summary of the grounds for each such opinion. 

ANSWER: No expert witnesses aie diuicipatcd. 

INTERROGATORY NO. 8: Slate by name, address, telephone number, dale of 

conversation, and sub.'^iance of conversation, all persons [other than legal counsel or 

spouse] with whom you have discussed the matters alleged in the Complaint. 

ANSWER: Respondent has not talked to anyone other than the 

proprietor/vendor of the counter which sells wine within the .'secured area of the terminal. 

INTERROGATORY NO. 9: If you deny Request for Admission No. 3 in all or 

part, please provide a detailed and specific description of the events referenced in 

Attachment One to the best of your knowledge and recollection. 

ANSWER; Yes. the Attachment No. 1 is inaccurate as described below in my 

Response to Admission No. 3. 

REQUEST FOR PRODCUTION NO. 1: Provide a copy of all documents 

refened tn in your answer to the preceding interrogatories No. 1 through No. 9. 

RHSPONSl'^' Nothing other than what I have previou.sly stated herein. 

INQUEST FOR ADMISSION NO. 1: Admit that on December 4, 2010, 

you were a passenger aboard Horizon Airlines flight UIMZ that departed from Helena, 

Montana enroule to Seattle, Wdshinglon which is the same llight referenced in the 

Amended Complaint filed in this matter. 

RESPONSE: Admitted 

REQUEST FOR ADMISSION NO. 2; Admit that, during the night 

referenced in Request For Admission No. 1, you consumed the contents of a bottle of 

wine that had not been provided by crew members aboard the flight referenced in 

Request For Admission No. 1. 

3. 
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RESPONSE.' Admitted, except that Respondent does not know from where the 

vendor obtained the wine which she purchased and consumed on flight. 

REQUEST FOR ADMISSION NO. 3: Admit that Attaclimcnt One is im 

accurate description of the event surrounding your consumption of the bottle wine 

relerenced m Reque.st For Admission No. 2. 

RESPONSE: Attachment No. 1 is inaccurate. Attachment No. 2 is accurate, in 

regard to Attachment No. 1, the male flight attendant was very rude and condescending 

and yelled. He was anything but polite. He simply told me I could not drink the wine 

aboard. Eater on 1 was lold that because he hhd not .sold it to me, I could not drink it, but 

by that lime ! had already drank the wine. I lold the flight aLlendanl that i purchased the 

wine inside the airport within the secured area and that I had also worked there for a time 

and at no time was I ever told so that I could tell purchasers that they could not dnnk the 

wine which they purchased from me. I thought it was perfectly permissible and I know 

the owner of the convenience counter imderslood this the same way. And. I had been 

instructed by security that the only rule there was concerning the small bottles of wine 

was that I needed to tell people that they could not have an open container between 

iecurily and the plane. They needed to leave the bottles unopened until they got aboard. 

There is no rule contrary to that instruction anywhere in the airport or secured area to my 

knowledge. I tried to tell the steward that but he would not listen. He was simply upset 

that 1 had not purchased the wine from him and that is what he told mc. The male tight 

attendant says in his attachment that he did not serve me any more alcohol and that I did 

not "further misbehave the rest of the Ilighi." First of all, I never misbehaved on any 

portion of the flight. Second of all, after he treated me so rudely I certainly did not a.-^k 

him to serve mc any alcohol. 

REQUEST FOR ADMISSION NO. 4: Admit that Attachment i wo is a true 

and accurate copy of a letter you wrote to FAA Inspector Steve Albert. 

RESPONSE: Admitted. Il is Respondent's letter. 

DATED this '- ^ day of October, 2011. 

DOUBEK, PYFER & FOX, LLP 

John C/t)oubek 

Attorney for .Maureen Wilson-Doubck 
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CERI'IFICATE OF SERVICE 

I hereby certify that on the j^ ^ day of October. 2011,1 served a true and 

correct copy of the foregoing upon opposing counsel via USPS :il Helena, Montana. 

addressed as foliow.s 

Federal Aviation Adminislralion 

800 Independence Avenue SW 

Washington, DC 20591 

Atin: Hearing Docket Clerk, AGC-430 

Wilbur Wright Hidg. •• Ste2Wli)00 

David F. Shayne 

F A A Ofiicc of Regional Counsel 

1601 LindAve.^SW 

Renton, WA98057 

.m /v.