U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

) 

In the Matter of Arctic Air Alaska, Inc. ) FDMSNo.FAA2014-0316 

) FAACaseNo.2012WP910268 

____________________________ ) 

Judge Richard C. Goodwin 

AGENCY'S FIRST INTERROGATORIES 

AND REQUEST FOR PRODUCTION OF DOCUMENTS 

Pursuant to the discovery guidelines set forth in Section 13 .220 of the Rules of Practice in 

FAA Civil Penalty Actions (14 C.F.R. 13.220), the Federal Aviation Administration ("FAA'') 

hereby requests that Respondent within thirty (30) days of service, provide to counsel for the 

Administrator the information described and requested below. Moreover, this is a continuing 

request for Respondent to provide all updated or new records or information, as itemized in this 

document, through the date of the hearing. 

DEFINITIONS 

1. Unless otherwise indicated, these Interrogatories and Requests for Documents refer to 

the time, place and circumstances of the occurrence mentioned or complained of in the 

Compliant. 

2. Where knowledge or information or a document possessed by a party is requested, that 

request includes knowledge of the party's representatives, agent and, unless privileged, 

attorneys. 

3. The pronouns "you" and "yours" refer to the party to whom or which these 

Interrogatories and Requests for Productions are addressed, and the persons mentioned in 

paragraph B. supra. 

4. When used with respect to a documents, "identify" means to furnish the document 

itself, or in lieu thereof, the name and date of the document, the name and address, addresses of 

all persons to whom copies of the document were or have been sent, and the organization, firm 

or agency with which all such persons were connected as of the date of the document, and state 

whether you are in possession of the original or copy, and/or furnish the name and address of a 

person whom you believe is in possession of the original or a copy of such document. 
5. The term "identify" when referring to a person, means to identify the person by name, 

occupation(s), and business address. 

6. The terms "document" and "statement" mean without limitation, the following items, 

whether printed or recorded or reproduced by any other mechanical process or written or 

produced by hand: agreements, communications, correspondence, telegraphs, memoranda, 

electronic messages, court or legal documents, summaries or recordings of telephone 

conversations, summaries or records of personal conversations or interview, summaries or 

reports of investigations, opinions or reports of consultants, diaries, graphs, reports, notebooks, 

note charts, plans drawings, sketches, maps, photographs, motion picture films, brochures, 

pamphlets, advertisements, circulars, press releases, drafts, letters, and marginal comments 

appearing on any documents, and all other tangible information capable of being read or viewed. 

7. For all interrogatories to which the responding individual has an objection, state the 

factual and legal basis for the claimed privilege, or any other authority that provides the claimed 

basis for the objection. 

8. All documents requested as to which the responding individual claims privilege or any 

other objection as a ground for non-production shall be identified chronologically as follows: 

a. date 

b. title 

c. type of document (e.g., memorandum, report, chart, etc.) 

d. subject matter (without revealing the information as to which privilege or statutory 

authority is claimed), and 

e. factual and legal basis for the claimed privilege, or any other authority that provides 

the claimed ground for non-productivity 

INTERROGATORY NO. 1: Identify, by providing the name, occupation, and business 

address, of each person you intend to call as a witness in this proceeding. 

INTERROGATORY No.2 Provide the substance of the testimony to be offered by each of the 

wituess identified in Interrogatory No. 1. 

INTERRROGATORY NO.3 With respect to each expert witness you intend to call as a 

witness in this proceeding, set forth the subject matter upon which each expert witness is 
expected to testifY, the facts and opinions composing the testimony of each expert witness, and a 

summary of the grounds for each opinion. 

INTERROGATORY NO. 4 Identify any and all documents in your possession that concern, 

refer to, or involve the circumstances set forth in the Complaint. 

REQUEST FOR PRODUCTION OF DOCUMENTS 

DOCUMENT REQUEST NO. 1: Copies of current curricula vitae for each expert witness 

you identified in Interrogatory No.3. 

DOCUMENT REQUEST NO.2: Copies of any statements made by witnesses identified in 

Interrogatories No. 1 and 3, concerning, referring to, or involving the circumstances set forth in 

the Complaint. 

DOCUMENT REQUEST NO.3: Copies of all documents that you intend to introduce into 

evidence. 

DOCUMENT REQUEST NO.4: Copies of all documents that you identified in Interrogatory 

No.4. 

Peter J Lynch 

Assistant Chi 

for Enfl c 

Ki ingharn 

E orcement Division 

ffice of the Chief Counsel 

(202) 267-7728 
CERTIFICATE OF SERVICE 

I hereby certify that the foregoing Agency's First Interrogatories and Request for Production of 

Documents, In the Matter of Arctic Air Alaska, Inc., FDMS No. 2014-0316, has been mailed this 

date by regular and Certified Mail to: 

James I. Hamilton 

President/CEO 

Arctic Air Alaska, Inc. 

3540 University Ave. South 

Fairbanks, AK 99709 

I further certify that the foregoing document has been sent via facsimile and mailed this date by 

Certified Mail to: 

The Honorable Richard C. Goodwin 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. (E-11-310) 

Washington, DC 20590 

The original and a copy was also personally delivered to: 

Hearing Docket (Original and 1 copy) 

Federal Aviation Administration 

600 Independence Avenue, S.W. 

Room 2W1000-AGC-430 

Washington, DC 20591 

November 6, 2014