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UNITED STATES DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

IN THE MATTER OF 

PRECISION DISPLAYS AND TOOLS 

FAA DOCKET NO. CP09AL0008 

(Civil Penalty Proceeding) 

DMS NO. FAA-2009-0733 

COMPLAINANT'S FIRST SET OF REQUESTS FOR ADMISSION, 

INTERROGATORIES, AND REQUESTS FOR PRODUCTION OF DOCUMENTS 

To: Robert Persekian, Owner 

Precision Displays and Tools 

Pursuant to 14 C.F.R. § 13.220, the Complainant, by and through its Regional Counsel, 

requests that you, by June 14, 2010, make the requested admissions, answer the following 

interrogatories under oath, and identify and produce the requested documents for inspection and 

copying at the Office of the Regional Counsel, Alaskan Region FAA, 222 W. 7* Avenue, Box 

14, Anchorage, Alaska 99513-7587. 

These requests are deemed continuing, and any information secured after answering 

and/or supplying the requested answers or documents/items is to be supplied by supplemental 

production pursuant to § 13.220(i) of the Rules of Practice in FAA Civil Penalty Actions. 

BE ADVISED that 14 C.F.R. § 13.220(1)(1) states, "A party's failure to respond to a 

request for admission, in writing and signed by the attorney or the party, not later than 30 days 

after service of the request, is deemed an admission of the truth of the statement or statements 

contained in the request for admission." 

DEFINITIONS 

1. "Documents" means, regardless of origin or location, any handwriting, note, letter, 

manual, memorandum, record, report, statement, study, drawing, sketch, photograph, telegram, 

telex, or message, whether reported, transcribed, punched, taped, filmed or graphically 

represented in any maimer, or material of any kind in the possession of subject to the control of, 

or within the knowledge of. Respondent and/or his employees, agents, consultants, or experts. 
2. "Identify" and/or "state the identity of with reference to individuals means state the 

name, current or last known address, employer, and job description or title, and telephone 

number. 

3. "Identify all documents" means state the date and author imless apparent from the 

document. 

4. As listed herein, singular pronouns also include the plxoral. 

5. "You," "your," and "Respondent" as used herein refer to Precision Displays and Tools, 

the Respondent in this matter. 

REQUESTS FOR ADMISSION 

Please admit the truth of each of the following statements: 

1. On or about May 9,2008, Precision Displays and Tools used an employee, Lewis 

Lourenco, to offer a shipment to Alaska Airlines for transportation by air from 

Ketchikan, Alaska, to San Diego, California. 

2. The above shipment was offered to Alaska Airlines on Air Waybill No. 02773106434. 

3. The above shipment is described on the above air waybill as consisting of 14 pieces with 

a total weight of 748 pounds and consisting of tools, ladder, and totes. 

4. The above air waybill is marked to indicate that the shipment does not contain dangerous 

goods. 

5. The above shipment included a one-quart can of Surmyside lacquer thinner, a one-pint 

can of Minwax Polyshades stain, three 16-ounce cans of 3M Super 77 multipurpose 

adhesive, and two-12-ounce cans of Premium Decor spray paint. 

6. Surmyside lacquer thiimer, Minwax Polyshades stain, 3M Super 77 multipurpose 

adhesive, and Premium D^cor spray paint are all hazardous materials under the 

Hazardous Materials Regulations. 

7. The above shipment was not marked or labeled in any matter that would indicate that it 

contained hazardous materials. 

8. There was no shipper's declaration for dangerous goods that was submitted to Alaska 

Airlines wdth the above air waybill, and no dangerous goods are identified on the above 

air waybill. 
r 

9. At the time he offered the above shipment, Lewis Lourenco had not received the training 

specified in subpart H of part 172 of the HMR within the preceding three years, and he 

was not working under the direct supervision of a properly trained and knowledgeable 

hazmat employee. 

10. At the time Lewis Lourenco offered the above shipment, Precision Displays and Tools 

did not have a record of current training for Lewis Lourenco that contained the 

information specified in Section 172.704(d) of the HMR. 

INTERROGATORIES AND REQUESTS FOR PRODUCTION 

1. For each of the above requests for admission that you do not admit, explain what specific 

facts or contentions in each statement you believe are not true, state all facts that support 

your beliefs in this regard, and produce all documents that support these beliefs. 

2. Identify each person whom you intend to call as a witness at the hearing in this matter, 

and for each such witness, provide a summary of the expected testimony. 

3. For each person identified in response to Interrogatory No. 2, produce a copy of each and 

every statement made by that person in which the facts and circumstances of matters at 

issue in this case are referenced or discussed. 

4. Do you intend to present any expert witness testimony at the hearing of this matter? If 

so, then provide a synopsis of each expert witness' testimony, state the grounds for each 

expert opinion, and produce a curriculum vitae for each expert witness. 

5. Do you contend that Precision Displays and Tools lacks the ability to pay the proposed 

civil penalty? If so, then state every fact upon which you intend to rely at the hearing in 

support of this contention, and produce a copy of each and every document you intend to 

introduce at the hearing in this matter in support of this contention. 

6. To the extent not encompassed in your response to any of the foregoing items, identify 

and produce all documents upon which you expect to rely at the hearing or introduce as 

evidence in support of your position at the hearing in this matter. 

Requested this 12"" day of May 2010. 

HOWARD L. MARTIN, JR 

Regional Counsel 

Glerm H. Brown 

Senior Attorney 
CERTIFICATE OF SERVICE 

Re: Precision Displays and Tools 

FAA Docket No. CP09AL0008 

DMS No. FAA-2009-0733 

I hereby certify that on this date I have served a copy of the COMPLAINANT'S FIRST SET 

OF REQUESTS FOR ADMISSION, INTERROGATORIES, AND REQUESTS FOR 

PRODUCTION OF DOCUMENTS by postage-prepaid, certified mail, return receipt requested 

and facsimile to the following: 

The Honorable Richard C. Goodwin 

Office of Hearings, M-20; 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor, Room El2-320 

Washington, DC 20590 

FAX: (202)366-7536 

Robert Persekian, Owner 

Precision Displays and Tools 

1555 Alum Rock Avenue, Suite 20 

San Jose, CA 95116 

FAX: (408)251-7990 

I further certify that on this date I have served the original and two copies of the 

COMPLAINANT'S FIRST SET OF REQUESTS FOR ADMISSION, 

INTERROGATORIES, AND REQUESTS FOR PRODUCTION OF DOCUMENTS by 

postage-prepaid, certified mail, return receipt requested and facsimile, addressed as follows: 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building—Suite 2 W1000 

FAX: (202)493-5020 

DATED: <^ ^ ^J^ ^O/ O 

^^^^^ ^ 

Federal Aviation Administration 

Office of Regional Counsel 

222 West 7th Avenue, Box 14, AAL-7 

Anchorage, Alaska 99513-7587