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Before the U.S. Department of Transportation 

Federal Aviation Administration FEB 2 3 20tf 

lEARING rrK^KET 

In the matter ol' 

M & R HELICOPTER 

COMPLAINANT'S RESPONSE TO M A R HELICOPTERS* MOTION FOR 

CD 

Complainant hereby files its response lo Respondent M & R Helicopter.<; 

(Respondent) Moiion for Defmite Requested Discovery. This appears Lo be another 

motion lo compel because Respondem aslcs for relief from the Chief Administrative Law 

Judge, i.e. that "this Honorable Court will mandate the following discovery under Ride 

13.220(d)." 

Complainant respectfully requests that the Chief Administrative Law Judge refer 

to Complainani't) Response to Motion to Compel filed on December 15, 2010, and 

Complainani'.s Re.sponse to M&R's Motion Lo Compel Discovery and New MatterFailure to Provide Requested Referenced Evidence filed on January 14, 2011. With 

regard to Respondent's request to depose Cynthia Dominik, Complainant respectfully 

requests that the Chief Administrative Law Judge refer to Complainant's Opposition to 

Motion for Deposition of Cynthia Dominik. filed on January 31, 2011, With rceard lo 

Respondent'.s request to depose Latonya Williams, Complainant respectfially requests that 

the Chief Administrative Law Judge refer to Complainani's response to Respondents: 

Motion to have pretrial deposition of Latonva Williams at Gallagher repoiting in 

n t..-_'v;: 

Docket No. CPlOSOOOll — 

FAA Case No. 2009SO950434 gS 

Chief Judge Ronnie A. Yoder ~'?:;23-j 

ni^r n 

DEFTNITE REQUESTED DISCOVERY ^ ^^ 
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Allentown. PA tiled on January 14, 2011. Complainant objects lo paragraph 8 as vague 

and ambiguous. 

WHEREFORE, Complainant respectfully requests that the Chief Administrative 

Law Judge deny Respondent's Motion for Definite Requested Discovei-y. 

Re.spectfully submitted, 

Peter J, Lynch 

Assistant Chief Counsel 

/ L^oraPonto 

I yAttomey 

^ ^ Enforcement Division, AGC-300 

Office of the Chief Counsel 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, DC 20591 

Phone: (202)267-9863 

Facsimile: (202)267-5106 

Date: February 16, 2011 
03/10/201 1 16:5 0 FAX 202493514 2 FAA ^ DMS 0003/003 

Certificate of Service 

I hereby certify thai on tliis date I have placed in the U.S. mail, postage prepaid, 

certified return-receipt, a copy of Complainant's Response To M&R Helicopter's Motion 

for Definite Reque.sted l)i.scovcrv In ihe Matter ofM & R Helicopters, Docket No. 

CPlOSOOOl 10, FAA Case no. 2009SO950434, addressed to: 

Dr. Michael B. Selig 

President 

M &R Helicopters, LLC 

2045 Westgate Dr., Suite 205 

Bethlehem, PA 18017 

In addition, I hereby certify that on this date 1 have sent by the U.S. mail, postage 

prepaid, certified remra-receipt and facsimile one copy of the foregoing document to: 

The Honorable Ronnie A. Yoder 

Chief Administrative Law Judge 

U.S. Department of'transportation 

1200 New Jersey Avenue, S.L. 

Wasliington, DC 20590 

Facsimile: 202-366-7536 

In addition, I hereby certify that on this date I have sent by the U.S. mail, postage 

prepaid, certified return-receipt, the original and one copy of the foregoing document to: 

Federal Aviation Administration 

600 Independence Avenue, S.W. 

Wilbur Wright Building - Suite 2Wl000 

Washington, D.C. 20591 

Attn: Hearing Docket Clerk, AGC-430 

Dated: February 16,2011