In the matter of Before the U.S. Department ofTransportation Federal Aviation Administration 

# RECEIVED JUN 09 2014 

## HEARING DOCKET

TRANS TIME EXPRESS ) ) ) ) ) ) Docket No. 2011 SW700220 FAA Case No. 2011SW700220 Judge Ronnie A. Yoder

COMPLAINANT'S ADDITIONAL INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS Pursuant to Rule 220 ofthe Rules ofPractice in FAA Civil Penalty Actions, 14 C.F.R. § 13.220, the Complainant, Federal Aviation Administration (FAA), hereby requests that Respondent, within 7 days after service ofthis request, provide to counsel for Complainant the information requested in this discovery request as described below. Specifically, the requested information should be sent by facsimile or other expedited
means to: Charles Raley, Attorney, Enforcement Division, AGC-300, Office ofthe Chief Counsel, 800 Independence Avenue, S.W., Washington, D.C. 20591, facsimile (202) 267-5106, so that it is received no later than June II, 2014. Pursuant to Rule 207 ofthe Rules ofPractice in FAA Civil Penalty Actions, 14 C.F.R. § 13.207, the response to this discovery request must be signed bythe attorney of record forthe Respondent, the Respondent, or the Respondent's representative. This discovery is a continuing request, through the date ofthe hearing in this matter, for Respondent to supplement or amend his answers and produce documents if
new or different information or new or different documents are obtained during the pendency ofthis matter.

### For purposes ofthe Interrogatories and Request for Production ofDocuments, the
use of"you" and "your" refers to Respondent, Respondent's agents, Respondent's attorneys, and any other person(s) acting or purporting to act for or on behalfof Respondent. INTERROGATORIES UNDER 14 C.F.R. § 13.220(k) 

### I. Identify both the "driver" and "other employee" you referred to in your answer to Complainant's Interrogatory #7 contained in Respondent's Respond [sic] to Complainant's Interrogatories, Request for Production ofDocuments, and Request for Admissions dated May 22, 2014 (Attachment A), by providing each person's full name, address, and phone number. REQUESTS FOR PRODUCTION OF DOCUMENTS UNDER 14 C.F.R. § 13.220(b) 

### I. A copy ofeach and every picture ofthe MasterJack Drain Opener bottle provided to Trans Time Express by Bandas Law Firm as referenced on page 5 ofthe attachments to Respondent's Respond [sic] to Complainant's Interrogatories, Request for Production ofDocuments, and Request for Admissions dated May 22, 2014 (Attachment B). 2. A copy ofthe invoice as referenced on page 5 ofthe attachments to Respondent's Respond [sic] to Complainant's Interrogatories, Request for Production of Documents, and Request for Admissions dated May 22, 2014 (Attachment B).
[Signature Page Follows]

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### Respectfully submitted,

Peter Lynch Assistant ChiefCounsel

for Enforcement

# By;~~ SabrillaJliW;d,Offiey Enforcement Division, AGC-300 Office ofthe ChiefCounsel Federal Aviation Administration 800 Independence Avenue, S.W. Washington, DC 20591 Phone: (202) 267-8839 Facsimile: (202) 267-5106 Email: Sabrina.Jawed@faa.gov

Dated: June 4, 2014

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### Certificate ofService I hereby certify that on this date I have placed in the U.S. mail, postage prepaid, certified return-receipt, and sent by FED EX overnight mail, a copy ofthe COMPLAINANT'S ADDITIONAL INTERROGATORIES AND REOUEST FORPRODUCTION OF DOCUMENTS in the case ofIn the Matter of Trans Time Express, FAA Case no. 2011SW700220, addressed to: Cameron Niakan, Esq. 10I0I Grosvenor Pl. #620 Rockville, MD 20852 In addition, I hereby certify that on this date I have sent by the U.S. mail, postage prepaid, certified return-receipt, the original and one copy ofthe foregoing document to: Federal Aviation Administration 800 Independence Avenue, S.W. Washington, D.C. 20591 Attn: Hearing Docket Clerk, AGC-430 Wilbur Wright Building- Suite 2Wl000

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### ATTACHMENT Asubject matter area onwhich the witness will opine. ANSWER: NIA. 4. List all exhibitsyou intendtouse atthe hearing inthis case. ANSWER: Respondant's Exhibit # 

### 1: Copy ofthe shipping label used to ship the material to Bandas Law firm 5. IdentifY any and all documents in yourpossession that concern, refer to, or involve the circumstances set forth inthe Complaint in this proceeding. ANSWER: No other documents, except for Respondant's exhibit#l, at this time. 6. Describe with particularity each and every fuct on whichyou rely to support each and every denial contained in yourAnswer totbe Complaint in this case. ANSWER: The testimony ofourwitoesses will showthat we were not at fault. 7. Describe with particularity thereasons why you cannot admit ordeny allegations contained inthe Complaint as reflected in your Answer to the Complaint inthis

I!icasewith the statements that 'TTE is without sufficient knowledge or information to admit or deny the allegation." ANSWER: The driver who handled this transaction, and another employee who may have hadmore particular knowledge about this event, are no longer with the company. 8. Describe with particulari1y each and every fact onwhich yourely to support each and every affirmative defense contained inyour Answer tothe Complaint inthis
case. ANSWER: The answers were given based on experience about the day-to-day operations, andwhatmusthave happened. 9. Identify theperson listed inFedExU.S. Airbill 8668 4774 3122 as ''Ben" in the Sender'sName box by providing the person's name, occupation, business address, and phone number (including land lines and

### cell phones). See Attaclunent I. ANSWER: BahmanMehdyoun, manager, Trans TimeExpress 1730 Lynn st. Arlington, VA 22209 tel: (202)528-2200

I 0. Identify ail employees involved inpicking up, classifYing, describing, packaging, marking, and labelingthe shipmentassignedFedExAirbill number 86684774 3122 for transportation in commerce by airby providing each person's name, occupation, business address, andphone number (including landlines and cell phones). ANSWER: BahmanMehdyoun, manager, Trans TimeExpress

### ATTACHMENT BOur office needs you

### to pick up lO (22oz.) bottles ofMasterjack Drain Opener from

Fischer Hardware 6129 BacklickRoad Springfield, VA22150 Ph: 703-451-3700
They are about $15.00 per bottle. I have attached a picture ofthebottle for youto review.

Once they are picked up, please take themto a Fed Ex location and have them use our account #328983125. Ifthey needto use multiple boxes that is fine Have them use a billing reference of Amy Fields and then ship them to:

Bandas LawFirm 500 N. Shoreline Blvd., Suite 1020 Corpus Christi, Texas 78401

Once shipped please send me an invoice for your services rendered and we will remit payment. 

### As a show ofgood faith I am leaving our credit card info to leave on file until the invoice is paid. AMEX Robert

### J. Sigler Bandas LawFirm, P.C. Card#: 3715 515617 02054 4 digit code: 6315


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