ARARTMEHTOF 

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' ' /r-': p;'Qf7[ij,Yr Before the U.S. Department of Transportation 

" " Federal Aviation Administration 

m i JAN 10 A iu: 3U Hi 

In the matter of 

M&RHELICOPTER 

Ci 

Docket No. CPIOSOOOll 

FAA Case No. 2009SO950434 

Judge Richard C. Goodwin 

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COMPLAlNANT^S SUPPLEMENTAL RESPONSE TO RESPONDENT'S 

DISCOVERY REQUEST 

Pursuant to 14 C.F.R. § 13.220(i), Complainant files this Supplemental Response to 

Respondent's discovery request.' Specifically, with regard to Respondent's request for 

"[a] complete list of each and every person intended to be called as a witness" and their 

"[t]itle, occupation, employer, business address, curriculum vita, license and certification 

numbers, educational background and complete credentials," Complainant provides the 

following additional witnesses: 

• Virginia Lozada, Eastern Compliance & Enforcement Center Manager, Office of 

Aerospace Medicine, Drug Abatement Division, FAA Miami Compliance & 

Enlbrcement Field Office, 2895 S.W. 145^ Ave., Miramar, FL, 33027. 

With regard to Respondent's request for "[t]he nature of the stated testimony to be 

provided (factual witness or expert witness), by each individual, the subject matter upon 

which each witness is expected to testify, the "nature of knowledge possessed by each 

witness and the facts to which each witness is expected to testify," Complainant provides 

the following: 

' Respondent's discovery requests appear at paragraph 13 in Respondent's Reply to Complainanrs Motion 

to Compel Discovery filed on August 9, 2011. 
• Virginia Lozada is expected to testify as to the Drug Abatement inspection of 

M &* R Helicopters and the subsequent investigation. Her testimony will include 

discussion of M & R Helicopters' Air Carrier Certificate and operations specifications, 

including those operations specification relating to M & R Helicopters' Antidrug and 

Alcohol Prevention Program. She will also testify that Edward Baker was not included in 

either M & R Helicopters' DOT-mandated drug or alcohol testing programs or in his own 

DOT-mandated drug or alcohol testing programs. 

In addition. Complainant may call a representative from the Aviation Safety 

Organization at the FAA to provide rebuttal testimony if necessary regarding the 

requirements of a part 119 certificate holder with operations specifications authorizing it 

to conduct part 135 operations, specifically as they apply to M & R Helicopter's 

operational status. 

Respectfiilly submitted, 

Peter Lynch 

Assistant Chief Counsel 

for Enforcement 

Charles Raley, Attorney 

Enforcement Division, AGC-300 

Office of the Chief Counsel 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, DC 20591 

Phone: (202)267-3357 

Facsimile: (202)267-5106 

Email: Charles.^alev(a^faa.^ov 

Dated: December 30, 2011 
Certificate of Service 

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

certified return-receipt, a copy of Complainant's Supplemental Response to Respondent's 

Discovery Request In the Matter ofM & R Helicopter, Docket No. CP1OSOOO110, 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 return-receipt and facsimile one copy of the foregoing document to: 

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, Roorn E 12-320 

Washington, DC 20590 

Facsimile: 202-366-7536 

In addition, 1 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 

800 Independence Avenue, S.W. 

Washington, D.C. 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building - Suite 2W1000 

Dated: December 30, 2011