Inthe matter of UNITED STATES OF AMERICA U. S. DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION WASHINGTON, D.C.

FAADocketNo. CPlOSW0010 Case No. 2009SW910051 AIR Z FLYINO SERVICE, INC. ) 

### ) ) ) 

### ) ChiefLawJudge Ronnie A. Yoder 

### ----------------------------) SECOND REOUEST FORDISCOVERY Pursuant to the discovery guidelines set forth in section 13.220 ofthe Rules ofPractice in Federal Aviation Administration Civil Penalty Actions, 13 C.F.R. 

### § 13.220, the Administrator of the Federal Aviation Administration hereby requests that Respondent, AirZ Flying Service, Inc. ("Air Z"), provide to counsel for the Administrator all ofthe informationrequested in this discovery request as providedbelow. The requested information should be sent to: Cole R. Milliard, Enforcement Division, AOC-300, Office ofthe ChiefCounsel, Federal Aviation Administration, 800 Independence Avenue, S.W., Washington, D.C. 20591, facsimile (202) 267-5106, no later than 30 days after service ofthis discovery request. 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 ifnew or different information or new or different documents are obtained during the pendency ofthis matter. New evidence should be provided in accordance with section 13.220(i) ofthe Rules ofPractice, 13 C.F.R. 

### § 13.220(i).

1DEFINITIONS 1. Use of"you" and "your" refers to AirZ, Air Z's agents, AirZ's attorneys, and any otherperson(s) acting or purporting to act for or on behalfofAir 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 orrecorded or reproduced by any mechanical or electronic process or written or produced byhand: agreements, communications, correspondence, memoranda, summaries or records oftelephone conversations, summaries or records ofpersonal conversations or interviews, diaries, graphs, reports, notebooks, note charts, plans, drawings, sketches, maps, summaries orreports ofinvestigations, opinions orreports ofconsultants, 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, ifnecessary, 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
orrelates to such fact, consideration, circumstance, act omission, event, transaction, occurrence
or statement.

2INTERROGATORIES 1. Explain in detail the basis for your denial ofRequest for AdmissionNo. I in the Administrator's Request for Discovery and Production ofDocuments served December 16, 2010. Include a detailed explanation ofwhy the documents submitted in response to the Administrator's Request for Discovery and Production ofDocuments served December 16, 2010 support this denial. 2. Explain in detail the basis for your denial ofRequest for Admission No.2 in the Administrator's Request for Discovery and Production ofDocuments served December 16, 2010. Include a detailed explanation ofwhy the documents submitted in response to the Administrator's Request for Discovery and Production ofDocuments served December 16, 2010 support this denial. 3. Explain in detail the basis for your denial ofRequest for AdmissionNo.4 in the Administrator's Request for Discovery and Production ofDocuments served December 16, 2010. Include a detailed explanation ofwhy the documents submitted inresponse to the Administrator's Request for Discovery and Production ofDocuments served December 16, 2010 support this denial.

3 Respectfully submitted, 

# 1U4M£

# 1JldlM Nicholas R. Milliard Attorney Enforcement Division Office ofthe ChiefCounsel Federal Aviation Administration 800 Independence Avenue, S.W. Washington, D.C. 20591Date: January 20, 2011.



### 4 Telephone: (202) 267-3452 Facsimile: (202) 267-5106 cole.milliard@faa.govCERTIFICATE OF SERVICE
I hereby certify thatI sentby U.S. mail, postage prepaid, certified return-receipt requested, the Administrator's Second Request for Discovery inIn the Matter of AirZ Flying Service, Inc, FAA DocketNo. 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 ofthe foregoing document, addressed to: The Honorable Ronnie A. Yoder U.S. Department ofTransportation Office ofHearings, M-20, Room E12-320 1200 NewJersey Avenue, S.E. Washington, D.C. 20590

Name:

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