11/05/2014 11:19 4252271007 

Jeffrey M. Harper 

FAA Office of Regional Counsel 

1601 Lind Avenue Southwest 

Renton, Washington 9805 7 

T (425) 227·2161 

F (425) 227-1007 

ANM7 PAGE 02/07 

UNITED STATES OF MERICA 

DEPARTMENT OF TRAN PORTATION 

WASHINGTON, .C. 

I 

In the Matter of: 

Air Medical Resomce Group, Inc. 

, 

DMS No. FAA-2014-0551 ~AA Case No. 2014WP9l0076 

Jonorable Richard C. Goodwin 

COMPLAINANT'S INITIAL DIS OVERY REQUEST 

To Respondent: 

In accordance with 14 C.F.R § 13.220 and the Federal Rules of Civil Procedure, please 

respond to the followi.ng Interrogatories, Requests for reduction of Documents, and 

Request for Admissions, separately and fully under oa December 6, 2014. 

These discovery requests are intended to discover info ation and! or documents not only 

within your personal knowledge or obtainable by you, ut also information in the possession 

of or obtainable by your attorneys, investigators, repr entatives, employees, agents, or 

anyone acting on your behalf or on their behalf. 

TI1ese discovery requests are continuing in nature an.d y information which may be 

discovered by you subsequent to the service and filing fyour answers must be brought to 

the attention of the agency attorney through suppleme tal answers when it becomes 

available to you, !l1 a reasonable time prior to the h~g in this matter. If there are any 

additions, deletions or changes in the answers or infoftion provided at any time prior to 

the heating Respondent is specifically requested to so · mediately inform the agency 

attorney. If such information is not furnished, tbe agen~y attomey at the tim.e of the hearing 

will move to exclude from evidence such informati.onlequested and not furnished. 

The agency attorney further requests that the Respond· nt produce the documents identified 

and designated herein for inspection and copying at th Federal Aviation Admin.i.stration 
11/05/2014 11:19 4252271007 ANM7 

(FAA) Offi.ce of Regional Counsel, Suite 570, 1601 Lind Avenue, Southwest, Renton, 

Washington 98057, by December6, 2014. 

Privilege 

If, in responding to, or failing to respond to these Interrogatories, Requests for Admission 

and Requests for Production you invoke or rely upon any privilege of any kind, state 

specifically the nature of the privilege; the basis upon which you invoke, t:ely upon, or claim 

it, including any statutory or decisional reference .if applicable; and identif'y all documents or 

other infonnation, including contacts and commtmications, which you believe to be 

embraced by the privilege invoked. 

DATED this 6'b day ofNovernber, 2014. 

D!gitally sigMd by JEFFREY M 

liARPER 

<"1:.:<··---..._... . ... . ...... DN; r!i:OUS, o~u.s. Government, 

OU.,...·ANM, ou~ANM, cn=JEFrRE:Y M 

HARPER fM.Harper 

FAA Attorney 

Date: 201 <1, ll,06 07:42.;32 •08'00' 

PAGE 03/07 

Complainant's Initial Discovery Ree~uest 

In the Matter of Air MeOical Resource Group, lnc. 

DMS No. F'AA-2014-0551; FAA Case No. 2014WP910076 

Page 2 of 6 

Jeffrey M. Harper. FAA Attor~ey 

T (425) 227-2161 

F (425) 227·1007 
11/05/2014 11:19 4252271007 ANM7 PAGE 04/07 

lole rrogatories 

Interrogatory No. 1: Identify by name, address, and telephone number all persons whom Air 

Medical Resource Group, Inc. knows to have personal knowledge of the matters alleged in 

the Complaint. 

Interrogatory No. 2: Identify by title, date, author, present custodian, and content, all 

docum.ents, including correspondence, obtained by you or in your possession, relating to the 

assertions in the Complaint, your appeal, your answer, and any affirmative defenses which 

you anticipate raising in this matter. See Request for Production No. J. 

Interrogatory No.3: Identify by name, address, and telephone number, all persons whom 

you intend to have testify as a factual. or expert vvitness in your defense at the hearing in this 

matter, and for factual witnesses, provide a detai.Jed summary of each person's anticipated 

testimony. 

Interrogatory No. 4: Identify by title, date, autho~. present custodian, and content, all 

documents which you anticipate offering into evidence or using at the hearing in this matter, 

and through which witness or witnesses the document will be offered. See Request for 

Production No.2. 

Interrogatory No. 5: With respect to each expert witness identi.fied in response to 

Interrogatory No.3, specify their specific area of expertise and provide a synopsis of their 

credentials, background, training, and experience. 

Interrogatory No.6: With respect to each expert you expect to call as a witness, state the 

subject matter on which the expert is expected to testify, the substance of the facts and 

opinions to which the expert is expected to testify, and provide a summary of the grounds 

for each such opinion. 

Interrogatory No. 7: Describe with specificity all facts and evidence you intend to rely upon 

in support of any affirmative defenses raised in any Answer to the Complaint. See Request 

for Production No. 3. 

Interrogatory No. 8: Describe with specificity all of the facts which you anticipate 

presenting in the course of the hearing in this matter pertaining to the avoidance or 

mitigation ofthe sanction sought by the FAA in this case. See Request for Production No.4. 

Interrogatory No.9: For each allegation in the Complaint that is denied-whether outright 

or as a result of having insufficient information or lmowledge from which to furm a belief as 

to the truth of the allegation, in whole, or in part-state with specificity th.e facts that are th.e 

Complainant's Initial Discovery Request 

In the Matter of Air Medicel Resource Group, Inc_ 

OMS No. FAA·2D:14·0551: FAA Case No. 2014WP910076 

Page3 of6 

Jeffrey M. Harper, FAA Attorney 

T (425) 227·2161 

F (425) 227-1007 
11/05/2014 11:19 4252271007 ANM7 

basis for that denial as well as the inquiries taken to determine that the allegation in the 

Complaint is not correct See Request for Production No. 5. 

PAGE 05/07 

IntEm"ogatozy No. 10: For any Requests for Admissions that are denied-whether outright or 

as a result of having insufficient information or knowledge from which to form a belief as to 

the truth of the allegation, in whole, or in part-state with specificity the facts and evidence 

which are the basis for that denial as well as the inquiries taken to detennine fuat fue facts in 

the request for admission are not correct. See Request for Production No.6. 

Requests for Production 

Request for Production No. l: Provide a copy of all documents referred to in your answer to 

Interrogatory No. 2 

Request for Production No. 2: Provide a copy of all documents referred to in your answer to 

Interrogatory No. 4. 

Request for Production No. 3: Provide a copy of all documents that support your answer to 

Interrogatory No. 7. 

Request for Production No.4: Provide a copy of all documents that support your answer to 

Interrogatory No. 8. 

Request for Production No. 5: Provide a copy of all documents that support your answer to 

Interrogatory No. 9. 

Request for Production No. 6: Provide a copy of all docuro.ents that support your answer to 

Interrogatory No. 10. 

Request fo~: P~:oduction No. 7: Provide a copy of all exhibits that AMRG intends to offer as 

evidence or will use during any hearing in this oo.atte.r. 

Request for Production No. 8: Provide all docum.ents documenting, reflecting, 

memorializing, summarizing, or otherwise referring to or related to th.e hire date of the 

following employees, including but not limited to !ntemal Revenue Service Fonn W-4 

(Employee's Withholding Allowance Certificate), Department ofHomeland Security, U.S. 

Citizenship and Immigration Services Form I-9 (Employment Eligibility Verification), job 

applications, first pay slip/stub/advice, health benefits election forms, and duty time records 

for first montl1 of employment: 

Fabio Aiello Ryan Burgoyne 

Complainant's Initial Discovery ReCJuest 

In the Matter of Air Medical Resource Group, Inc. 

DMS No. FAA-20:1.4-0651; FAA case No. 2014WP910076 

Page 4 of 6 

David Coyote 

Jeffrey M. Harper, FAA Attorney 

T (425) 227·2161 

F (425) 227·1007 
11/05/2014 11:19 4252271007 

Jonathan Dabel 

Jose H~mandez II 

Robert White 

ANM7 

Chris Ewald 

Carlos Marrero Soto 

Craig Young. 

Bryce Frankenberry 

Douglas Study 

Request for Production No. 9: Provide a copy of AMRG's federal tax returns covering the 

period calendar year 2012 through calendar year 2014. 

Requests for Admission 

PAGE 06/07 

Under 14 C.F.R. § l3.220(b) and Rule 36 of the Federal Ru1es of Civil Procedure, you are 

requested to admit the trutl1 of the following matters. A matter is admitted unless responded 

to in a reasonable time. The Rules of Practice in FAA Civil Penalty Actions, 14 C.F.R. 

§ 13.220(d), defines a reasonable time to be 30 days. The agency requests that an answer be 

served upon the agency attorney either admitting the matter, specifically denying the Jnatter, 

stating why the matter cannot be admitted or denied, or objecting to fue request, with 

reasons for fu.e objection stated wifuin 30 days of the date of service upon you, th.ai is, 

December 6, 2014 

Request for Admission No. 1: Adm.itAMRG has 6 or more aircraft on its air carrier 

certificate. 

Request for Admission No. 2: Admit that AMRG has 6 or more pilots. 

Request for Admission No. 3: Adm.i.t AMRG has the financial ability to p~y ilie proposed 

$12,000 civil penalty. 

Complainant's Initial Discovery Request 

In the Matter o1 Air Medical Resource Group, Inc. 

DMS No. FM·2014·0551: FAA Case No. 2014WP910D76 

Page 5 of6 

Jeffrey M. Harper, FAA Attorney 

T (425) 227·2161 

F (425) 227·1007 
11/05/2014 11:19 4252271007 ANM7 PAGE 07/07 

CERTIFICATE OF SERVICE 

I hereby ceytify 1hat the foregoing Complainant's Initial Discovery Request has been served 

via facsimile and Certified Mail-Return Receipt Requested this date, to the following: 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2W1 000 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, DC 20591 

Fax: (202) 493-5142 

I hereby certifY 1hat the foregoing Complainant's Initial Discovery Request has been served 

via facsimUe, Certified Mail- Return Receipt Requested, and e-mail this date, to 1he 

following: 

The Honorable Richard C. Goodwin 

Office of Hearings, M-20 

1200 New Jersey Avenue, S.E. (E11-310) 

Washington, DC 20590 

Fax: (202) 366-7536 

richard.goodwin@dot.gov 

I hereby certify 1hat 1he foregoing Complainant's Initial Discovery Request has been served 

via Certified Mail- Return Receipt Requested, to th.e following: 

Gregory S. Winton, Esq. 

The Aviation Law Firm 

1997 Annapolis Exchange Parkway, Suite 300 

Annapolis, MD 21401 

Te.l: (301) 294-8550 

Fax: (866) 568-9886 

greg@aviationlawexperts.com 

Dated this 61

il day of November, 2014 . 

1

. ·[/&liL>.~/u;;&-~ Dana Stephenson 

Office ofRegional Counsel (ANM-7) 

Federal Aviation Adw,inistration 

1601 Lind Ave. SW 

Renton, WA 98057 

(425) 227-2164 

Complaloanfs Inlti:a.l Discovery Request 

Air Medical Resoutce Group; Inc. 

Jru:~ru;y M. HARPER, FAA AITORNJ!Y 

T (425) 227-2161: F (4ZS) 227-1 007 

DMS No. F AA·2D 14·0552 l"l---.:: -C'C 
11/85/2814 11:19 4252271087 ANM7 

FACSIMILE MESSAGE 

FEDERAL A VJA TION ADMINISTRATION 

OFFICE OF REGIONAL COUNSEL 

ANM-7 

1601 LJND AVENUE S.W. 

RENTON, WASHINGTON 98057 

PAGE Sl/87 

The information contained in this facsimile message is legally privileged and confidential 

information and is intended only for the use of the individual named on this cover sheet. 

If the reader of this message is not the intended recipient, you are hereby notifi.ed that any 

use, dissemination, distribution, or copy of this facsimile is strictly prohibited. If you 

have received this facsimile in error, please immediately 110tify us by telephone at 

425-227-2007. 

DATE: 

TO: 

FAX NO.: 

PHONE NO.: 

RE: 

November 6, 2014 

Docket Clerk. AGC-430 

202-493-5142 

Air Medical Resources 

Group, Inc. 

DMS No FAA- 2014-

0551 

NO. PAGES: 7 including cover 

FROM: Jeffrey M. Harper 

FAX NO.: 425-227-1007 

PHONE NO.: 425-227-2161 

EMAIL: JEFFREY.HARPER@FAA.GOV 

Complainant's Initial Discovery Request.