### U.S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATIONADMINISTRATION OFFICE OF HEARINGS

WASHINGTON, D.C.

IntheMatter ofJetLogistics, Inc. FAA-2013-0290 TheHonorableJ.E. Sullivan 

# RECEIVED MAY 1 6 2014 

## HEARING DOCKET

AGENCY'S RESPONSE TO RESPONDENT'S SUPPLEMENTAL DISCOVERY REQUEST



### Pursuant to Rules 26 and 33 ofthe Federal Rules ofCivil Procedure, Complainant Michael P. Huerta, Administrator ofthe Federal Aviation Administration ("FAA" or "Complainant") objects
to the entirety Respondent's Supplemental Discovery request as untimely. See Exhibit# I. Pursuant to Judge Sullivan's Order Setting Litigation Dates and Procedures served on October 30, 2013, the deadline for the parties to submit supplemental discovery requests was on March 21, 2014. See Exhibit# 2. The Respondent's Supplemental Discovery Request was not served upon the Administrator until April24, 2014. See Exhibit# 3. Therefore, the Administrator respectfullyrequests thatthe Administrative Judge sustainthe Administrator's objection.
Respectfully submitted, Alfred R. Jolmson, Jr. Regional Counsel

### By: Daniel Kohlmeyer Attorney Federal Aviation Administration 1Aviation Plaza Jamaica, NY 11434 Telephone: 7(18) 553-3266 Facsimile: (718) 995-5699 Date:

2

### CERTIFICATE OF SERVICE I hereby certify that on this day copies ofthe foregoing Agency's response to Respondent's Supplemental Discovery Request were placed in the United States mail via Certified MailReturn ReceiptRequested andviatelefax as follows: The HonorableJ.E. Sullivan Administrative LawJudge Office ofHearings, M-20 Room Ell-310 U.S. Department ofTransportation 1200 NewJersey Avenue, S.E. Washington, D.C. 20590 FAX: (202)-366-7536 Federal AviationAdministration 800 Independence Avenue, S.W. Attn: Hearing Docket Clerk, AGC-430 Wilbur WrightBuilding- Room 2014 Washington, D.C. 20591 Jet Logistics Inc. W. Ashley Smith, Jr. President 5400 AirportDrive Charlotte, NC 28208 FAX: (919) 840-0554

Date: 

## UiaJ. Hoops Paralegal Specialist Office ofRegional Counsel I AviationPlaza Jamaica, NY 11434

3

# EXHIBIT# 1speeches or articles; publications; transcripts oftelephone conversations; phone mail; electronic-mail; microfilm; microfiche; tape or disc recordings; and computerprint-outs. Theterm "document" also includes electronically stored data from which information can be obtained either directly or by translation through detection devices orreaders; any such document is to be produced in areasonably legible and usable form. The term "document" includes all drafts ofa document and all copies that differ in any respect from the original, including any notation, underlining, marking, or information not on the original. The term also includes information stored in, or accessible through, computer or other information retrieval systems (including any computer archives orback-up systems), together with instructions and all other materials necessary to use or interpret such data compilations. Without limitation on the term "control" as used in the preceding paragraph, a document is deemed to beinyour controlifyou have the right to secure the document or a copy thereoffrom another person. 7. "Identify" or "identity" means to state or a statement of:

a. in the case ofa person other than a natural person, its name, the address ofits principal place ofbusiness (including zip code), its telephone number. b. in the case ofa natural person,his orher name, business address and telephone number, employer, and title orposition;

c. in the case ofa communication, its date,**type(~.** telephone conversation or discussion), the place where itoccurred, the identity ofthe person who made the communication,the identity ofthe person who received the communication,the identity ofeach otherperson when itwas made, and the subject matter discussed; d. in the case ofa document, the title ofthe document, the author, the title or position of the author, the addressee, eachrecipient, the type ofdocument, the subject matter, the date ofpreparation, and its number ofpages; and

e. in the case ofan agreement, its date, the place where itoccurred, the identity ofall persons who were parties to the agreement, the identity ofeach person who has knowledge ofthe agreement and all other persons present when it was made, and the subject matter ofthe agreement. 8. "Including" means including,but not limited to. 9. "Person" means any natural person, corporation, company,partnership,joint venture, firm, association, proprietorship, agency,board, authority, commission, office orother business or legal entity, whether private or governmental.10. "Relating to" means containing, constituting, considering, comprising, concerning, discussing, regarding, describing, reflecting, studying, commenting orreporting on, mentioning, analyzing, orreferring, alluding, or pertaining to, in whole orin part. 11. "Relevanttime period" means the time period stated in paragraph 1 ofthe Instructions. 12. "Year" means calendar year or the twelve-month period on which your records are based; ifthe latter is used in responding to a interrogatory, specify the twelve month period used. 13. The singular form ofa noun or pronoun shall be considered to include within it's meaning the plural form ofthe noun orpronoun, and vice versa; and the past tense shall include the present tense where the clear meaning is not distorted. The term "or" shall mean "and" and vice-versa, as necessary to bring within the scope ofthe following interrogatories all information or documents that would be excluded absent this definition. II. Instructions 1. Unless otherwise specified, these interrogatories are limited to the time period from January 1, 2008, to and including the date ofservice ofthese interrogatories. 2. Unless otherwise specified, the information called for by these interrogatories is limited in scope to information relating to the functions and operations ofthe FAA, it's employees,representatives, and agents, and the operation oforby JetLogistics,Inc., Air Carrier Certificate ZP7A. 3. Where knowledge, information, ordocuments are requested, suchrequest encompasses knowledge, information or documents in your possession, custody orcontrol, or in the possession, custody or control ofyour staff, agents, employees,representatives and, unless privileged, attorneys, or any otherperson who has possession, custody or control ofyour proprietary knowledge, information ordocuments. 4. Pursuantto Fed. R. Civ. P. 26(e), you are under a duty seasonably to amend any answer to these interrogatories for which you learn that the answer is in some material respect incomplete or incorrect and ifthe additional or corrective information has not otherwise been made known to us during the discovery process or in writing. 5. For any interrogatory orpart ofan interrogatory which you refuse to answer under a claim ofprivilege, submit a sworn or certified statement in which you identify the nature ofthe information withheld; specify the grounds ofthe claimedprivilege and the paragraph ofthese interrogatories to which the information is responsive; and identify each person to whom the information, or any part thereof, has been disclosed.6. Answer each interrogatory fully. Ifyou objectto any interrogatory, state the reasons for objection and answer to the extent the intenogatory is not objectionable. Ifyou are unable to answer an intenogatory fully, submit as much information as is available, explain why your answer is incomplete, and identify or describe all other sources ofmore complete or accurate information. 7. For any record or documentresponsive orrelating to these interrogatories which is known to have been destroyed orlost, or is otherwise unavailable, identify each such document by author, addressee, date, number ofpages, and subject matter; and explain in detail the events leading to the destruction orJoss, orthe reason for the unavailability of such document. III. Intenogatories 1. Please provide all conespondence between FAA inspectors Todd Kuhn and Norman Robinson concerning the checks completed in accordance with 14CFR Part 135.299 that Mr. Robinson conducted on behalfofthe FAA on April3, 2012, in Van Nuys, CA., for pilots Luis Alberto Rios, and Robin ScottDill. 2. Please provide all correspondence between the VNY FSDO and the CLT FSDO concerning the checks conducted by Mr. Norman Robinson on April3, 2012 for pilots Luis Alberto Rios, and Robin Scott Dill in accordance with 14CFR Part 135.299. 3. Please describe any specific training Mr. Kuhn has completed specifically for FAA investigation practices, techniques, and acceptedprocedures. 4. Please describe how many Letters ofInvestigation (LOI) orEnforcement Investigative Reports (EIR)s Mr. Kuhn has issued specifically for alack of training documentation. 5. Mr. Kuhn describes in one ofhis EIR documents for Kenneth Vojtathatthe request for Hawaii operations was "denied after discussion with the navigation specialist". Please provide a copy ofthe letter mailed to respondent stating the official request was officially denied. 6. Please explain why Mr. Kuhn has been asked to attend Ethics training eight (8) times during his FAA career. 7. Please provide the course outline, course description, and curriculum for the course Mr. Kuhn attended on March 7, 2012, titled "Conducting an Investigation". 8. Please provide the course outline, course description, and curriculum for the course Mr. Kuhn attended on March 7, 2012, titled "The Basics ofEthical Behavior".Certificate ofService

I hereby certify that on this day copies ofthe foregoing Respondent's Interrogatories were placed in the United States mail, postage prepaid, CertifiedMail- Return Receipt Requested addressed as follows: TheHonorable J.E. Sullivan Administrative Law Judge Office ofHearings, M-20 U.S. Department ofTransportation 1200NewJersey Avenue, S.E. (Ell-310) Washington, DC 20590 TEL: 202-366-2132 FAX: 202-366-7536

Mr. Jose Nieves Complainant's Counsel Federal Aviation Administration Office ofRegional Counsel, Eastern Region I Aviation Plaza Jamaica, NY 11434 TEL: 718-553-3278 FAX: 718-995-5699

Mr. W. Ashley Smith Jr. Respondent Lay Representative Jet Logistics, Inc. 5400 Airport Drive Charlotte, NC 28208 TEL: 919-840-0555 FAX: 919-840-0554 Date:

________ _ W. Ashley Smith Jr. RespondentLay Representative

# EXHIBIT# 2

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In The Matter Of: JET LOGISTICS, INC. Respondent 

## SERVED: October30, 2013
U.S. DEPARTMENT OFTRANSPORTATION OFFICE OF HEARINGS WASHINGTON, DC ) ) ) ) ) 

### DocketNo. FAA-2013-0290 CaseNo. 2012EA680047

ORDERSETTINGLITIGATION DATES AND PROCEDURES 

### On September24, 2013, the parties appearedby telephone for a Rule 16 Litigation Scheduling Conference, and discussed their calendar availability, hearing dates, and other litigation procedural matters. On September

### 24, 2013, an Order Granting Continuance and Other Relief

### was filed. On October 

### 30, 2013,the parties appeared bytelephone for a second Rule 16 Litigation Scheduling Conference, and discussed theircalendar availability, hearing dates, and

### other litigation procedural matters. Pursuantto 14 C.F.R. §13.205(a)(l), (6) and (7), Civ. R. 16, 14 C.F.R. §13.217, and 14 C.F.R. §

### 13.220, and after reviewing 

### all relevant caselaw, regulation, statutory authority, and being 

### fully advised;

IT IS HEREBYORDERED: A. 

### The litigation dates and hearing dates are hereby set 

### as follows 1. 

### November 15, 2013: 

### Deadline for Initial 

### Disclosures. The last.date 

### for the parties to 

### serve each other with initial disclosures pursuant to Civ. R. 26(a)(l)(A). 

### 2. November 18,2013: General

### Discovery StartDate. 

### On orbefore July 1, 

### 2013, the parties shall begin serving additional general discovery requests pursuant 

### to CR 26- CR 36 and 14 C.F.R. §13.220(b) and (e).

### This includes, but is not limited to: notices of deposition; subpoenas duces Jecum; 

### interrogatories; requests for production of documents, etc, 3. Service oflnterrogatories. Pursuant to 14 

### C.F.R. §

### 13.220(k)(l), a party shaH not serve 

### more thanthirty (30) 

### interrogatories to each other, and each subpart ofan interrogatory shall 

### be counted as 

### a separate 

### interrogatory.

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### 1of4

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4. 

### Motions Regarding Interrogatories. Pursuant to 14 

### C.F.R. § l3.220(m) 

### and Paragraph D herein, any motions to compel for deficient interrogatoryresponse(s) shall be filed within ten (10) 

### days after receipt ofthe objection ordeficient answer. 5. 

### February 7,2014: Initial 

### ExpertDisclosures. On or before July 22, 2013 

### the parties shall exchange initial expert disclosures pursuantto CR26(a)(2). 

### 6. February28,2014: 

### ExpertRebuttal Disclosures. On or before August 6, 2013, the parties shall exchange expertrebuttal disclosures. 7. 

### March 14,2014: 

### Deadline for Completing General Discovery. The last date for both parties to finish serving answers to 

### all additional general discovery requests pursuantto CR 26- 

### CR 36 

### and 14 

### C.F.R. §J3.220(b) and (e). 

### This includes, but is not limitedto,the taking ofdepositions and serving responses to all requests for production, etc. 8. 

### March 21, 2014: 

### SupplementalDiscovery RequestDeadline.The last date fotboth partiesto complete service ofall supplemental discovery requests based on the general discovery exchange, including but not limited to any notices ofsupplemental depositions, and otherrequests. 

### 9. April 25, 2014: Deadline for 

### Completing Supplemental Discovery. Deadline for both parties to finish taking supplemental depositions, and respondingto and serving answers to all supplemental discovery requests pursuantto 

### CR26- 

### CR 36 

### and 14

### C.F.R. §13.220(i). 

### I0. May 

### 9, 2014: 

### Deadlines forFilingDispositive Motion(s). The last date for both parties to file any/all pre-hearing dispositive motions, including Default Motions and/or Summary JudgmentMotions. 

### a) May 23,2014: Deadline forfiling Answer to Dispositive Motion(s); b) 

### June6,

### 2014: Deadline for filing Reply (ifany), 11. June 18, 2014: 10:00am·11:30am 

### EST. Telephone conference for oral argument on dispositive motions. N.B. 

### lftheparties do notfile dispositive motions, then this Telephone Conference will be automatically converted and held as a Pre-Hearing Status Conference. 12. 

### July 18, 2014: 

### Listof

### Witnesses/Exchange of

### Exhibits due date. The lastdate 

### for each partyto serve and file the following: a) A list ofthe witnesses the party intends to call; b) A short statement ofthe testimony expected from each such witness; c) The resume ofeach witness who will be offered as an expert; and d) The documents the party intends to offer in evidence (pre-marked as noted in 

### paragraph E. infra). 

### 13. 

### July 18,2014: 

### Written Stipulations and/orMotions in Limine

### due date. The deadline for filing written stipulations and/or Motions in Limine. Page 2of4

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14. 

### July 

### Z9, 2014-July 31, 2014: Hearing

### dates. Based on theparties' agreement, the Hearing will take three (3) 

### days or less. The Bearing will begin on Tuesday, July 29, 2014 (9:00 

### a.m•S:OO p.m. EST) 

### in Charlotte, North Carolina and end onThursday,July 31, 

### 2014 (9:00 

### a.m.-5:00 p.m. 

### EST). The specific location ofthe Hearing will be provided to theparties prior to the Hearing. B. Requests for modification ofthe litigation dates setf'orth inparagraph Amay be made by written Motion. 

### Before filing such 

### aMotion, however, theparty seeking the modification shall contact the opposing party and 

### seek to arrive at mutually convenient alternative date(s). Areport onthe result ofthisdiscussion shall be included bythe movant in the Motion. C. Discovery requests or documents complyingwithdiscoveryrequests need notbe filed in this case with the Office ofHearings, except as part ofa motion regarding disputed discovery, or 

### as partofamotion to compel discovery. D. Any Motions regarding discovery, including a Motionto Compel Discovery, must be filed within ten (10) 

### calendar days after service ofa deficient response or afterthe response to the discovery is due, whichever occurs 

### first. Motions to Compel and other discovery motions must be accompanied by the relevant discovery requests and responses, and 

### adeclaration by the moving party, pursuantto Civ. 

### R. 37(a)(l), thatthe movanthas conferred or attempted to confer in good faith with the party alleged to 

### have failed to make discovery or disclosure. The Civ. R. 37(a)(l) declaration shall specifically indicate the efforts made by the movantto resolve the dispute and identify which discovery matters remain indispute. Statements in opposition to discovery motions must be filed within ten (10) 

### calendardays after service of themotion. The failure to timely file objections to discovery may result in the objections being deemed waived. Belated service ofburdensome discovery requests may also be grounds for denial ofa 

### motion to 

### compel compliance with such requests. 

### E. Eachparty must bring to the hearing at least three copies of

### any documents 

### it intends tooffer in evidence as exhibits (onefor the Judge and two for the official reporter). The 

### exhibits musthave an index cover sheet, and should bepre-marked. Complainant's exhibits should bemarked "C-1," "C-2," "C-3," etc. Respondent's exhibits should be marked "R-1," R

### 2.," "R-3/' etc. 

### F. Atthe hearing, there 

### will be the opportunity for direct examination, crossexamination, redirectexamination and re-cross-examination ofeach witness. Only one representative ofaparty may cross-examine awitness on behalfofthatparty. Pursuantto 14 C.F.R. §13.205 and 14 C.F.R. §13.222, the Federal Rules ofEvidence will beutilized as a guideline in determining the admission ofall evidence. G. Priorto the hearing date(s), ifaparty wishes to schedule oral argument on any motion, or set 

### up any type oftelephone conference on 

### the Judge's calendar, the party shall first confer with opposing counsel about mutually agreeable alternate dates, and then Mr. Cody L. 

### Smith, Attorney-Advisor, atthe 

### Office ofHearings (202-366-6941) as soon as possible,with at Page3of42013-10-30 

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least three {3) mutually-agreed, proposed alternate dates/times for the Judge's consideration. 

### The movant shall be responsible for contactingthe Office ofHearings. H. 

### Attorney Withdrawal: );!ursuantto 14 

### C.F.R. §13.218, 

### an attorney who wishes to withdraw from representing 

### aparty 

### must 

### file aMotion to Withdraw. 

### In this Motion, In this Motion, the attorney shall confirm the following: I. 

### The date, address, and method by 

### whichthe Respondentwas served with written notice ofthe attorney's intent to withdraw; 2. The name ofthe designated agent/lay representative ifthe R<:Spondent in the action is a business entity; 3. 

### The currentbusiness address, telephone number, and fax number ofthe Respondent and of

### its designatedbusiness agent;

. 4. 

### The date and 

### method by which the Respondentwas notified in writing ofthe pending hearing dates in this litigation, as well as the pendingpre-hearing discovery deadlines and telephone conferences; and 

### 5. The date and method by which the Respondent was provided a copy ofall Orders issued in this litigation, as well as any 

### other legal documents to which the Respondent is entitled.

1. 

### AdditionalTime for 

### Respondent to 

### AnswerMotion: 

### The parties' agreementto allow the Respondent twenty (20) days to respond to an FAA Motion for Summary Judgment on the admitted violations (i.e., (b), (c) and (d) in the FAA's Complaint), due to be filed in the next few weeks, is confirn1ed and adopted. J. 

### For clarifications ofthis order orquestions with regard to the procedures to be followed in this case, please contactMr. Cody L. 

### Smith, Attorney-Advisor, at the Office of Hearings (202-366-6941).



### Attachment: Service List

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### FDMS No. FAA-2013-0290 

### (Civil Penalty Action) SERVICELIS'f- BY U.S. MAIL



### Federal Aviation Administration 800 Independence Avenue, S.W. Washington, DC 20591 ORIGINAL & 

### ONE COPY



### Attention: Hearing Docket Clerk, AGC-430 Wilbur Wright Building-Suite 2W1000 1



### Mr. Jose L. Nieves 

### Complainant 's Counsel Federal Aviation Administration ONE COPY



### Office oftheRegional Counsel, Eastern Region 1

### Aviation Plaza Jamaica, 

### NY 11434 

### TEL: 718-553-3278 FAX: 

### 718-995·5699 Mr. W. Ashley Smith, Jr. 

### RespondentLayRepresentative 

### Jet Logistics, Inc. 5400 Airport Drive Charlotte, NC 

### 28208 TEL: 919-840-0555 Judge J.E. Sullivan US. Administrative

### LawJudge 

### Office ofHearings, M-20 U.S. Department

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

### Washington, DC 20590 TEL: 202-366-2132 FAX: 

### 202-366-7536

1 Service wos by U.S. Mail. For service in peroon or byexpedited courier, use the followinsnddress: Federal Aviation Administration, 600 lndcpondcnce Avenue, S.W., Wilbur Wright Buildins-Suite2WTOOO, Wnshington, DC 20591; Attention: Hearing Docket Clerk, AGC-430,

# EXHIBIT# 3Fw: Supplemental Interrogatories Brendan Kelly to: Daniel Kohlmeyer AEA-007, Office of Regional Counsel This message

Brendan A. Kelly Supervisory Attorney FAA Eastern Region, AEA-7 Tel: 718-553-3269 Fax: 718-995-5699 Email: brendan.kelly@faa.gov ----Forwarded by Brendan Kelly/AEA/FAA on 04/28/2014 10:50 AM---- From: To: Date: Subject:

Mr. Kelly, "W. Ashley Smith Jr." <ashley@jetlogistics.us> AEA-007, Office of Regional Counsel Brendan Kelly/AEA/FAA@FAA, 04/25/2014 02:27 PM FW: Supplemental Interrogatories 04/28/2014 10:52 AM

I sent this to Mr. Nieves and I got his out of office message to contact you. I assume this case will be placed with another attorney in the office, but to prevent from missing a deadline in the scheduling order I'm laking a shot in the dark at your email address. Iwill also mail this to you and Mr. Nieves with the assumption his replacement is receiving his mail. I left you a voice mail on your office number. Please return my call at your convenience, 919-840-0555. This hearing for this case is set for the end ofJuly and there is still much to be done. I'd like to discuss things with you, or Mr. Neives' replacement, as soon as possible so we can keep the schedule as it is set. I'm very eager to getthis entire situation behind us so we can move on to more important things. Thank you for your time. 

### W. Ashley Smith Jr., ATP/ME, A&P/IA, CAM, CMTE President Main Office: Email: Web: 919.840.0555 ashley@jetlogistics.us http://www.jetlogistics.us http://www.jetloqisticstechnical.us
Jet Logistics Inc. (FAAAir Carrier #ZP7A427J) Jet Logistics Technical Services, LLC. (FAA CRS #R40R880N) Mailing Address: PO Box 19596, Charlotte, NC 28219 Shipping Address: 5400 Airport Drive, Charlotte, NC 28208

Offices located in: Charlotte, Raleigh, Las Vegas ApprovedAir Carrier- U.S. Department ofDefense (DoD), UnitedNations & NASA I IS-BAO (STAGE 3), Wyvern Registered OperatorI GSA Schedule Contract#GS-33F-0017XCONFIDENTIALITY/DISCLAIMER NOTICE: the information contained in this email and any attachments may be legally privileged and confidential. Ifyou are not an intended recipient, you are hereby notified that any distribution, dissemination or copying of this email is strictly prohibited. If you have received this email in error, please notify the sender and permanently delete the email and any attachments immediately. You should not retain, copy or use this email or any attachments for any purpose, nor disclose any or all parts of the contents to any other party. Jet Logistics Inc. accepts no liability for any errors or omissions contained herein. This message is not intended to represent an electronic signature or similar binding acceptance or authorization on behalf ofJet Logistics Inc. under applicable law unless otherwise expressly indicated herein.

From: "W. Ashley Smith" <ashley@jetlogistics.us> Date: Thursday, April 24, 2014 at 11:59 PM To: Jose Nieves <Jose.Nieves@faa.gov> Subject: Supplemental Interrogatories Mr. Nieves, Attached is our request for supplemental interrogatories. A hard copy will be mailed to both you and Judge Sullivan's office. My apologies for the 11th hour notice, so please take a few days to complete the request if needed. I'm certain a few ofthese will take some research to find. Thank you, and have a great weekend. 

### W. Ashley Smith Jr., ATP/ME, A&P/IA, CAM, CMTE President Main Office: Email: Web: 919.840.0555 ashley@jetloqistics.us http://www.jetlogistics.us http://www.jetlogisticstechnicaI.us Jet Logistics Inc. (FAA Air Carrier#ZP7A427J) Jet Logistics Technical Services, LLC. (FAA CRS #R40R880N) Mailing Address: PO Box 19596, Charlotte, NC 28219 Shipping Address: 5400 Airport Drive, Charlotte, NC 28208

Offices located in: Charlotte, Raleigh, Las Vegas ApprovedAir Carrier- U.S. DepartmentofDefense (DoD), UnitedNations & NASA //S-BAO (STAGE 3), Wyvern Registered OperatorI GSA Schedule Contract#GS-33F-0017X

CONFIDENTIALITY/DISCLAIMER NOTICE: the information contained in this email and any attachments may be legally privileged and confidential. Ifyou are not an intended recipient, you are hereby notified that any distribution, dissemination or copying of this email is strictly prohibited. If you have received this email in error, please notify the sender and permanently delete the email and any attachments immediately. You should not retain, copy or use this email or any attachments for any purpose, nor disclose any or all parts of the contents to any other party. Jet Logistics Inc. accepts no liability for any errors or omissions contained herein. This message is not intended to represent an electronic signature or similar binding acceptance or authorization on behalf ofJet Logistics Inc. under applicable law unless otherwise expressly indicated herein.

Request for Supplemental Interrogatories.pdf