U.S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION ) Inthe Matter ofArctic Air Alaska, Inc. ) FDMSNo.FAA2014-0316 ) FAACaseNo.2012WP910268



## ____________________________) Judge Richard C. Goodwin AGENCY'S FIRST INTERROGATORIES AND REQUEST FORPRODUCTION OF DOCUMENTS Pursuant to the discovery guidelines set forth in Section 13 .220 ofthe Rules ofPractice in FAA Civil Penalty Actions (14 C.F.R. 13.220), the Federal Aviation Administration ("FAA'') herebyrequests that Respondent within thirty (30) days ofservice, 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 newrecords or information, as itemized inthis document, through the date ofthe hearing. DEFINITIONS 1. Unless otherwise indicated, these Interrogatories and Requests for Documents refer to the time, place and circumstances ofthe occurrence mentioned or complained ofinthe Compliant. 2. Where knowledge or information or a document possessed by a party is requested, that request includes knowledge ofthe party's representatives, agent and, unless privileged, attorneys. 3. The pronouns "you" and "yours" refer to the party to whom orwhichthese Interrogatories and Requests for Productions are addressed, and the persons mentioned in paragraphB. supra. 4. When used withrespect to a documents, "identify" means to furnish the document itself, or in lieu thereof, the name and date ofthe document, the name and address, addresses of all persons to whom copies ofthe document were orhave been sent, and the organization, firm or agency with which all such persons were connected as ofthe date ofthe document, and state whether you are inpossession ofthe original or copy, and/or furnish the name and address ofa person whom youbelieve is inpossession ofthe original or a copyofsuch document.5. The term "identify" when referring to a person, means to identify thepersonbyname, occupation(s), and business address. 6. The terms "document" and "statement" mean without limitation, the following items, whetherprinted orrecorded orreproduced by any other mechanical process orwritten or produced by hand: agreements, communications, correspondence, telegraphs, memoranda, electronic messages, court or legal documents, summaries or recordings oftelephone conversations, summaries orrecords ofpersonal conversations or interview, summaries or reports ofinvestigations, opinions or reports ofconsultants, 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 ofbeingread orviewed. 7. For all interrogatories to which the responding individual has an objection, state the factual and legal basis for the claimedprivilege, or any other authority that provides the claimed basis for the objection. 8. All documents requested as to whichthe 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 ofdocument (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 legalbasis for the claimedprivilege, or any other authority thatprovides the claimed ground for non-productivity



### INTERROGATORYNO. 1: Identify, by providing the name, occupation, and business address, ofeachperson you intend to call as a witness in this proceeding.



### INTERROGATORY No.2 Provide the substance ofthe testimony to be offered by each ofthe 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 isexpected to testifY, the facts and opinions composing the testimony ofeach expert witness, and a summary ofthe grounds for each opinion.

INTERROGATORY NO. 4 Identify any and all documents inyour possession that concern, refer to, or involvethe circumstances set forth inthe Complaint. REQUEST FOR PRODUCTION OF DOCUMENTS DOCUMENT REQUEST NO. 1: Copies ofcurrent curricula vitae for each expert witness you identified in Interrogatory No.3.

DOCUMENT REQUEST NO.2: Copies ofany 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 ofall documents that you intend to introduce into evidence.

DOCUMENT REQUEST NO.4: Copies ofall documents that you identified inInterrogatory No.4. Peter 

### J Lynch Assistant Chi for Enfl c

Ki ingharn E orcement Division

ffice ofthe ChiefCounsel (202) 267-7728CERTIFICATE OF SERVICE I hereby certify that the foregoing Agency's First Interrogatories and Request for Production of Documents, In the Matter of ArcticAirAlaska, Inc., FDMS No. 2014-0316, has beenmailed 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 LawJudge Office ofHearings, M-20 U.S. Department ofTransportation 1200NewJersey 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