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Before the U.S. Department uf Transportation RECEIVED 

Federal Aviation Administration f£p _ „ «^.-

BEARING DOCKET 

In the rnaitcr of 

M & R1 IFT.TCOPTER 

Docket No. CPlOSOOOll 

FAA Case No. 2009SO950434 

Chief Judge Ronnie A. Yodcr 

' Respondent premises this discovery riiquest on the fact that "[r]cspondent has requested pre-trial 

meetings and hearing [sic] lo be held in Alleniown, PA." Complainant has already addressed these matters 

in its January 14, 2011. Response to Motion Lo Have the Pre-Trial Deposition of Laionva Williams at 

Gallahcr RcpoiTJng. iMIentovyn. PA: Respondent's Motion for Pre-trial Conference at Gallagher Reportine. 

Allcrttown, PA: Motion for Hearing in AllcntQwn. PA: and Respondent's Reply Lo Heaiioe Location in 

Alleniown. PA. Respondent claims that undersigned counsel "states in her [sic] pleading that Ms [sic] 

Williams 'does not regularly travel.'" Respondent, however, does not cite to any specific pleading. The 

Chief ALJ may review Complainani's pleadings on this matter and see that undersigned counsel has never 

made that .statement. 

.3;^::^ 

COIVfPLAlNANT'S RESPONSE TO M & R HELICOPTERS' MOTION FOR ^ S-f ^ 

SPECIFIC DISCOVERY - TRAVEL LOG FOR LATONY A WILLIAMS 1 ^~i ^ 

Although it captioned its request as a motion, Respondent M & R Helicopters' ^ ' -'^ 

appears to be requesting discovery from Complainant. Respondent requests an 

"unaltered work and travel log Tor 2009 and 2010" for Ms. Latonya Williams, an FAA 

Inspector in the Oflicc of Aerospace Medicine, Hrug Abatement Divi.sion. 

Complainant objects to ihis discovery request because the material sought is 

irrelevant and the request is overly broad. Ms. Williams entire work and travel schedule 

from 2009 to 2010 is neither material nor relevant lo the subject matter of this 

proceeding, i.e., alleged violations of FAA Regulations by M & R Helicopters." 
02/10/201 1 11:3 2 FAX 2024835142 FAA ^ nw^ 

•^"'^ * DMS i002/00 3 

Respectfully .submitted, 

Peter J. Lynch 

Assistant Chifif Counsel 

By: _, 

ra Ponto 

•^Attorney 

F.nforcement Division, AGC-300 

Office of the Chief Counsel 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, DC 20591 

Phone: (202)267-9863 

Facsimile: (202)267-5106 

Date: February 9, 2011 
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Certificate of Service 

1 hereby certify tliat on this date I have placed in the U.S. mail, postage prepaid, 

certified return-receipt, a copy of Complainant's Response To M&R Helicopter's Motion 

For Specific Discovery Travel Log For Latonya Williams In the Matter of M& R 

Helicopters, Docket No. CPlOSOOOl 10, FAA Case ito. 2009SO950434, addressed to: 

Dr. Michael B. Selig 

President 

M & R Helicopters, LLC 

2045 Westgate Dr., Suite 205 

Bethlehem, PA 18017 

In addition, 1 hereby certify that on this date I have sent by the U.S. mail, postage 

prepaid, certified reiurn-reeeipl and facsimile one copy of the foregoing document to; 

The Honorable Ronnie A. Yoder 

Chief Administrative Law Judge 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Wa.shington, DC 20590 

Facsimile: 202-366-7536 

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 ore copy of the foregoing document to: 

Federal Aviation Administration 

600 Independence Avenue, S.W. 

Wilbur Wright Building Suite 2W1000 

Washington, D.C. 20591 

Attn: Heiiring Docket Clerk, AGC-430 

Dated: February 9,2011