ADMINISTRATOR, 

Federal Aviation Administration 

Complainant, 

v. 

VAN AIR MANUFACTURING, INC. 

Respondent. 

Case No. 2014-GL-70-0045 

Docket No.: FAA-2016-4269 

Judge: J.E. SulliR r~ r 

t:.u D 

RESPONDENT'S INITIAL DISCLOSURE~ 

PURSUANT TO RULE 26(a)(l) 

SEP 2 9 2016 

HEARING DOCKET 

COMES NOW, Vanair Manufacturing, Inc. ("Respondent"), by and through the 

undersigned and pursuant to Federal Rules of Civil Procedure 26(a)(l ), and hereby serves upon 

all parties Respondent's Initial Disclosures: 

1. Pursuant to Rule 26(a)(l )(A)(i), the following individuals are likely to have 

discoverable information that Respondent may use to support their claims: 

a. Greg Kokot (President) 

V anair Manufacturing, Inc. 

10896 West 300 North 

Michigan City, 1N 46360 

Subjects of information: lmowledge of events and facts surrounding the September 24, 

2013 incident at Midway Airport in Chicago, Illinois. 

b. Ralph Kokot (Chief Executive Officer) 

V anair Manufacturing, Inc. 

10896 West 300 North 

Michigan City, 1N 46360 

Subjects of information: knowledge of events and facts surrounding the September 24, 

2013 incident at Midway Airport in Chicago, Illinois. 

c. Jackie Higgins (Safety Coordinator) 

V anair Manufacturing, Inc. 

10896 West 300 North 

Michigan City, 1N 46360 

Subjects of information: knowledge of events and facts surrounding the September 24, 

2013 incident at Midway Airport in Chicago, Illinois. 

d. Terry Vittatoe 

Mobile PTO 
6272 N. 300 West 

Michigan City, IN 46360 

Subjects of iuformation: knowledge of events and facts surrounding the September 24, 

2013 incident at Midway Airport in Chicago, Illinois. 

e. Ritchie Verplank 

Federal Aviation Administration 

Joint Security and Hazardous Materials Division 

2300 East Devon Avenue, suite 223 

Des Plaines, IL 60018 

Subjects of information: knowledge of events and facts surrounding the September 24, 

2013 incident at Midway Airport in Chicago, Illinois. 

f. Paul Serafin 

Federal Aviation Administration 

Joint Security and Hazardous Materials Division 

2300 East Devon Avenue, suite 223 

Des Plaines, IL 60018 

Subjects of information: knowledge of events and facts surrounding the September 24, 

2013 incident at Midway Airport in Chicago, Illinois. 

g. Derrick Wichman 

(Address unknown) 

Subjects of information: knowledge of events and facts surrounding the September 24, 

2013 incident at Midway Airport in Chicago, Illinois. 

Respondent reserves the right to supplement this initial disclosure after additional 

discovery and investigation is undertalcen. 

2. Pursuant to Rule 26(a)(l )(A)(ii), Respondent provides the following description 

by category of all documents, electronically stored information, and tangible things that 

Respondent has in its possession, custody or control and may be used to support its claims: 

a) Vanair Human Resource Department records; 

b) HAZMAT training materials; 

c) Correspondence between FAA and V anair representatives; and 

d) Photograph(s) from inside ofVanair facility. 

Respondent reserves the right to supplement this initial disclosure after additional 

discovery and investigation is undertaken. 

3. The Respondent is not seeking monetary damages and, accordingly, the 

computations required under Rule 26(a)(l(A)(iii) are inapplicable. To be responded to by 

Complainant. Respondent denies that any penalty is appropriate. 

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4. Pursuant to Rule 25(a)(4), these documents are m writing, signed by 

Respondent's counsel and being served upon all parties. 

5. Pursuant to Federal Rule of civil Procedure 5(d)(1), these disclosures are not 

.............................. ])eil1gfiled\Vitlltl1e Co111·tatthisti!l1e .......................... . 

CERTIFICATE OF COMPLIANCE WITH RULE 26(g) 

I HEREBY CERTIFY that to the best of my knowledge, information and belief, formed 

after a reasonable inquiry, that these docun1ents are complete and correct as of August 30, 2016. 

Dated: August 30, 2016 

Respectfully submitted, 

(JghnS 

~s Hoff 

3 

JohnS. Hoff 

Jared A. Schneider 

Cremer, Spina, Shaughnessy, Jansen & 

Siegert, LLC 

One North Franklin Street, 101

h Floor 

Chicago, Illinois 60606 

(312) 726-3800 Tel. 

(312) 726-3818 Fax 

jhoff@cremerspina.com 

j schneider@cremerspina.com 
CERTIFICATE OF SERVICE 

I hereby certify that on August 30, 2016, I have sent by U.S. Post, the original and one 

(1) copy of the forgoing document to: 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20594 

Attention: Hearing Docket Clerk, AGC-430 

Wilber Wright Building- Suite 2Wl 000 

In addition, I hereby certify that on August 30, 2016, I have sent by U.S. Post and via 

facsimile, a copy of the foregoing document to the following: 

Kate Barber, Esq. 

Enforcement Division, Midwest Team 

2300 East Devon Avenue 

Des Plaines, IL 60018 

kate.barber@faa.gov 

Fax: (847) 294-7498 

Honorable J.E. Sullivan 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. (Ell-310) 

Washington, D.C. 20590 

Fax: (202) 366-7536 

#346537 

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Maria Rivas