In the matter of 

UNITED STATES OF AMERICA 

U. S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. 

FAA Docket No. CPlOSW0010 

Case No. 2009SW910051 

AIR Z FL YINO SERVICE, INC. 

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Chief Law Judge Ronnie A. Yoder 

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SECOND REOUEST FOR DISCOVERY 

Pursuant to the discovery guidelines set forth in section 13.220 of the Rules of Practice in 

Federal Aviation Administration Civil Penalty Actions, 13 C.F.R. § 13.220, the Administrator of 

the Federal Aviation Administration hereby requests that Respondent, Air Z Flying Service, Inc. 

("Air Z"), provide to counsel for the Administrator all of the information requested in this 

discovery request as provided below. 

The requested information should be sent to: Cole R. Milliard, Enforcement Division, 

AOC-300, Office of the Chief Counsel, Federal Aviation Administration, 800 Independence 

Avenue, S.W., Washington, D.C. 20591, facsimile (202) 267-5106, no later than 30 days after 

service of this discovery request. 

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. New 

evidence should be provided in accordance with section 13 .220(i) of the Rules of Practice, 13 

C.F.R. § 13.220(i). 

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DEFINITIONS 

1. Use of "you" and "your" refers to Air Z, Air Z's agents, Air Z's attorneys, and 

any other person(s) acting or purporting to act for or on behalf of Air Z. 

2. The words "and" and "or" shall be construed conjunctively and disjunctively as 

necessary to make the request inclusive rather than exclusive. The word "including" shall be 

construed without limitation. 

3. The words "document" and "statement" mean, without limitation, the following 

items, whether printed or recorded or reproduced by any mechanical or electronic process or 

written or produced by hand: agreements, communications, correspondence, memoranda, 

summaries or records of telephone conversations, summaries or records of personal 

conversations or interviews, diaries, graphs, reports, notebooks, note charts, plans, drawings, 

sketches, maps, summaries or reports of investigations, opinions or reports of consultants, 

photographs, motion picture films, brochures, pamphlets, advertisements, circulars, press 

releases, drafts, letters, and marginal comments appearing on any document, and other data 

compilations from which information can be obtained or translated, if necessary, into reasonably 

usable form. 

4. The words "describe" and "state" mean to set forth each fact, consideration, 

circumstance, act, omission, event, transaction, occurrence or statement which supports, refutes, 

concerns, relates or refers to the matter(s) referenced or described in the interrogatory, and in 

addition, means to identifY each oral communication and each document which concerns, refers 

or relates to such fact, consideration, circumstance, act omission, event, transaction, occurrence 

or statement. 

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INTERROGATORIES 

1. Explain in detail the basis for your denial of Request for Admission No. I in the 

Administrator's Request for Discovery and Production of Documents served December 16, 

2010. Include a detailed explanation of why the documents submitted in response to the 

Administrator's Request for Discovery and Production of Documents served December 16, 2010 

support this denial. 

2. Explain in detail the basis for your denial of Request for Admission No.2 in the 

Administrator's Request for Discovery and Production of Documents served December 16, 

2010. Include a detailed explanation of why the documents submitted in response to the 

Administrator's Request for Discovery and Production of Documents served December 16, 2010 

support this denial. 

3. Explain in detail the basis for your denial of Request for Admission No.4 in the 

Administrator's Request for Discovery and Production of Documents served December 16, 

2010. Include a detailed explanation of why the documents submitted in response to the 

Administrator's Request for Discovery and Production of Documents served December 16, 2010 

support this denial. 

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Respectfully submitted, 

1U4M£ 1JldlM 

Nicholas R. Milliard 

Attorney 

Enforcement Division 

Office of the Chief Counsel 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, D.C. 20591 
Date: January 20, 2011. 

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Telephone: (202) 267-3452 

Facsimile: (202) 267-5106 

cole.milliard@faa.gov 
CERTIFICATE OF SERVICE 

I hereby certify that I sent by U.S. mail, postage prepaid, certified return-receipt 

requested, the Administrator's Second Request for Discovery in In the Matter of Air Z Flying 

Service, Inc, FAA Docket No. CPI0SWOOI0, Case No. 2009SW910051, addressed to: 

Mr. Laurence E. Rohl 

President, Air Z Flying Service, Inc. 

355 Richmond Road, Hangar 5 

Richmond Heights, Ohio 44143 

In addition, I hereby certifY that I sent a confirmation copy by U.S. mail, postage 

prepaid, certified return-receipt requested of the foregoing document, addressed to: 

The Honorable Ronnie A. Yoder 

U.S. Department of Transportation 

Office of Hearings, M-20, Room E12-320 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

Name: --'-"~=>Z:...!'---'--'!."'"'-< I=~~:"":'--~ _ 

Date: ---'.f+-'I :L,-,--=O-t-/ -,-,,-1 1 ___ _ 

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