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- O ^^—'—)»*•,» ) 

nor, 

U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

RECEIVED 

JUN 2 5 2010 

HEARING DOCKHT 

) 

In the Matter of Wisconsin Aviation, Inc. ) Judge Richard C. Goodwin 

) 

) FAA. Docket No. 2007SW910050 

) DMS No. 2010-0542 

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 

Priiclice in FAA Civil Penalty Actions (14 CF.R. 13.220), the Federal Aviation 

Administration ("PAA'"') 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 rccjuest for Respondent to provide all updated or 

new records or information, as itemized in diis document, through the dale of the hearing. 

DEFINITIONS 

1. Unle.ss 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. fhc pronouns "yc>"" ^"<1 "yf>^irs" 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 wiih 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 
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address, addresses of all persons to whom copies of the document were or have been sent, 

and the organization, firm or agency with whicli all such persons were connected as of 

the date of the document, and state whether you arc in possession of the original or copy, 

and/or fiirni.'ih 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 relerring 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 ol" 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 

infomiaiion capable of being read or viewed. 

7. For all intenrogalorics to vchich the responding individual has an objection, slate 

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. dale 

b. title 

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

d. Subject matter (without revealing the information a-s to which privilege or 

statutoiy 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 

irSTERKOCA I CRY 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 witness identified in Interrogatory No. 1. 
I 

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

a witness in tliis 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 and any and all documents in your possession 

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

INTERROGATORY NO. 5 State whether or not between September 25, 2005, and 

December 31, 2006 any of the same aircraft were used in both Part 91 and Part 135 

operations. If so, identify the aircraft number and the dates those aircraft were operated 

in Part 135 operations. 

INTERROGATORY NO. 6 State whether or not any of the persons identified in the 

complaint performed maintenance or preventive maintenance on any of the aircraft used 

in both Part 91 and Part 135 operations prior to that person obtaining a drug test and prior 

to Wisconsin Aviation receiving a negative drug test for that individual. 

INTERROGATORY NO. 7 List all objective criteria that Wisconsin Aviation used to 

determine that a mechanic who performed maintenance or preventive maintenance on a 

Part 91 aircraft was eligible to work on a Pan 135 aircraft. Identify any and all vvritten 

policy or procedures that stated the above-referenced criteria. 
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REQUEST FOR PRODUCTION OF DOCUMENTS 

DOCUIVlKNT REOUEST NO. 1: Copies of current curricula vitae for each expert 

witness you identified in Interrogatory No. 3. 

DOCUMENT REOUEST NO. 2: Copies of any statements made by witnesses 

identified in Interrogatories No. 1 and 3, concerning, referring to, or involving the 

circum.stances set forth in the Complaint. 

DOCUMENT REOUEST NO. 3: Copies ol' all documents that you intend to introduce 

into evidence. 

DOCUMENT REOUEST NO. 4: Copies of al 1 documents that you identified m 

Interrogatory No. 4. 

Peter J Lynch 

Assistant Chief Counsel 

for Enforcement 

. ..'-'^ 

Au^^n Killingham 

Office of the Chief Counsel 

(202) 267-7728 
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'^"'^ * DMS 12005/005 

CERTIFICATE OF SERVICE 

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

Production of Documents, in the matter of "Wisconsin Aviation, Inc. FAA Case No. 

2007SW910050 has been mailed this date by Certified Mail-Return Receipt Requested 

and to: 

.Teffrcy D, Baum 

Prcsident/CLO 

Wisconsin Aviation, Inc. 

1741 River Drive 

Watertown, "Wl 53094 

Honorable Richard C. Goodwin 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE. 

East Building, Ground Floor, Room E12-320 

Washington, D.C. 20590 

I'he original and one copy was also hand delivered to the Hearing Docket at: 

Hearing Docket, Room 2014, AGC-430, 

Federal Aviation Administration 

600 Independence Avenue, S.W. 

Washington, D.C. 20591 

|riWjyv?L Q)a^(^ 

June 24, 2010