In the matter of 

Before the U.S. Department of Transportation 

Federal Aviation Administration 

RECEIVED 

JUN 0 9 2014 

HEARING DOCKET 

TRANS TIME EXPRESS 

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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 of the Rules of Practice 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 of this 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 of the 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 of the Rules of Practice in FAA Civil Penalty Actions, 14 

C.F.R. § 13.207, the response to this discovery request must be signed by the attorney of 

record for the Respondent, the Respondent, or the Respondent's representative. 

This discovery is a continuing request, through the date of the 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 of this matter. 
For purposes of the Interrogatories and Request for Production of Documents, 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 behalf of 

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 of Documents, 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 of each and every picture of the Master Jack Drain Opener bottle provided 

to Trans Time Express by Bandas Law Firm as referenced on page 5 of the 

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). 

2. A copy of the invoice as referenced on page 5 of the 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 Chief Counsel 

for Enforcement 

By;~~ SabrillaJliW;d,Offiey 

Enforcement Division, AGC-300 

Office of the Chief Counsel 

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 of Service 

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 of the COMPLAINANT'S 

ADDITIONAL INTERROGATORIES AND REOUEST FOR PRODUCTION OF 

DOCUMENTS in the case of In the Matter of Trans Time Express, FAA Case no. 

2011 SW700220, addressed to: 

Cameron Niakan, Esq. 

10 I 0 I 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 of the 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 A 
subject matter area on which the witness will opine. 

ANSWER: NIA. 

4. List all exhibits you intend to use at the hearing in this case. 

ANSWER: Respondant' s Exhibit # 1: Copy of the shipping label used to ship the 

material to Bandas Law firm 

5. IdentifY any and all documents in your possession that concern, refer to, or 

involve the circumstances set forth in the 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 which you rely to support each 

and every denial contained in your Answer to tbe Complaint in this case. 

ANSWER: The testimony of our witoesses will show that we were not at fault. 

7. Describe with particularity the reasons why you cannot admit or deny allegations 

contained in the Complaint as reflected in your Answer to the Complaint in this 

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case with 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 had more particular knowledge about this event, are no longer with the 

company. 

8. Describe with particulari1y each and every fact on which you rely to support each 

and every affirmative defense contained in your Answer to the Complaint in this 

case. 

ANSWER: The answers were given based on experience about the day-to-day 

operations, and what must have happened. 

9. Identify the person listed inFedEx U.S. Airbill 8668 4774 3122 as ''Ben" in the 

Sender's Name box by providing the person's name, occupation, business 

address, and phone number (including land lines and cell phones). See 

Attaclunent I. 

ANSWER: Bahman Mehdyoun, manager, Trans Time Express 

1730 Lynn st. Arlington, VA 22209 

tel: (202)528-2200 

I 0. Identify ail employees involved in picking up, classifYing, describing, packaging, 

marking, and labeling the shipmentassignedFedExAirbill number 86684774 

3122 for transportation in commerce by air by providing each person's name, 

occupation, business address, and phone number (including land lines and cell 

phones). 

ANSWER: Bahman Mehdyoun, manager, Trans Time Express 
ATTACHMENT B 
Our office needs you to pick up lO (22oz.) bottles ofMasterjack Drain Opener from 

Fischer Hardware 

6129 Backlick Road 

Springfield, VA22150 

Ph: 703-451-3700 

They are about $15.00 per bottle. I have attached a picture of the bottle for you to review. 

Once they are picked up, please take them to a Fed Ex location and have them use our account 

#328983125. Ifthey need to use multiple boxes that is fine Have them use a billing reference of 

Amy Fields and then ship them to: 

Bandas Law Firm 

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 of good faith I am leaving our credit card info to leave on file until the invoice is paid. 

AMEX 

Robert J. Sigler 

Bandas Law Firm, P.C. 

Card#: 3715 515617 02054 

4 digit code: 6315 

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