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•^•-PARTMENTOF 

•iANSPORT/VflON 

December 6,2010 .-^ET OPERATIONS 

CERTIFIED MAIL-RETURN RECEIPT REQUESTF.D 'CiO TEC H P 12^ UU 

Federal Aviaiion Administration 

800 Independence Avenue, S.W. 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 '7A/A — 1)1 llO -

Wilbur Wright Building-Suite 2wl 000 C^OlU "*^<^ T 

RE: In the Matter of Samuel Joseph Latham; Case No. 201 OWPl 50016 

1. In response to your letter dated November 10,2010. The order granting complaintajit s 

motion. 1 did file an answer on October 14,2010. A copy is enclosed for your review. 

Why was I deemed to have admitted to each statement in Complainant's Request For 

Admission if I filed my answer as stated above. 

2. As far as the request for discovery 1 would like to file a motion for protective order on 

the grounds that it would cause embarrassment and undue expense, 

3. At this time Re.spondent pursuant to Section 13.220 of the Rules of Practice in FAA 

Civil Penalty Actions, requests the Complainant please respond to Jhc following 

Discovery Reque<>ts separately and fiilly within 30 days of the date of service. We would 

like copies of all reports taken in the alleged incidents by the airline, FAA and any other 

agencies that took reports. We would like copies of all the statements taken £rom 

passengers, crcwmembers and any other witnesses that you may have. Please identify by 

name, address, and telephone number all persons whom you intend to testily. 

Your consideration in this matter is greatly appreciated. 

Respectfully submitted, 

Samuel Latham, Respondent 
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CERTIFICATE OF SERVICE 

I, Samuel Latham, hereby certify that on December 6, 20101 served copies of my 

respt^nse to the Complainants request for discovery on the following parties by way of 

certified mail- return receipt. 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, DC 20591 

Attention; Hearing Docket Clerk, AGC-4.'iO 

Wilbur Wright Building- Suite 2W1000 

TEL: 202-385-8229 and 202-385-8230 

FAX: 202-493-5123 and 202^93-5020 

Lierre Green, Complainant's Counsel 

Otticc of the Regional Counsel 

Western-Pacific Region, AWP-7 

Federal Aviation Administration 

P.O. Box 92007 

Los Angeles, CA 90009-2007 

TEL: 310-725-7117 

FAX: 310-725-6816 

The Honorable Richard C. Goodwin, Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor, Room £12-320 

Washington, DC 20590 

I'HL: Attorney-Advisor 202-566-2139 

Legal Assistant 202-366-5121 

FAX: 202-366-7536 

Date Signature 
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-. - -, • c^fi 

CERTfflCATE OF SERVICE 

I, Samuel Latham, hereby certify that on October 15,2010,1 served copies of my answer 

to the Complaint on the following parties by way of certified mail- return receipt 

requested as well via fax: 

Federal Aviation Administration 

800 IndependeDce Avenue, S.W. 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

WUbur Wright Building- Suite 2W1000 

TEL: 202-385-8229 and 202-385-8230 

FAX: 202-493-5123 and 202-493-5020 

Liene Gzeen, Complainant's Counsel 

Office of the Regional Counsel 

Western-Pacific Region, AWP-7 

Federal Aviation Adminislzation 

P.O. Box 92007 

Los Angeles. CA 90009-2007 

TEL: 310-725-7117 

FAX: 310-725-6816 

The Honorable Richard C. Goodwin, Administrative Law Judge 

OfBce of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avaiue, S.E. 

East Building Grouol Floor, Room El 2-320 

Washington, DC 20S90 

TEL: Attorney-Advisor 202-366-2139 

Legal Assistant 202-366-5121 

FAX: 202-366-7536 

Date Signature 
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P?i 

October 14,2010 

CERTIFIED MAIL-RETURN RECEIPT REQUESTED 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washin^n, DC 20591 

Attention: Hearing Docket Qerk, AGC-430 

Wilbur Wright Building-Suite 2wl000 

RE: In the Matter of Samuel Joseph Ladiam; Case No. 2010WP150016 

In response to your letter dated September 30,2010 and the pmvisions of Section 13.209 

(a) Of The lovestigative and Enforoement Procedures. I am filing my answ»- to the 

Complaint as required. 

I did file a motion to dismiss instead of an answer on August 20,2010 as pursuant to 

Section 13.208 (F). 

Paragraph 1 of the Comphiitt. Admit 

Paragraph 2 of the Complaint: Admit 

Paiagrai^ 3 of the Complaint do not have sufficient infoanation to admit or deny 

Pacagrqih 4 of the Complaint do not have sufficient infomaation to admit or deny 

Paragrqjfa 5 of die Complaint: do not have suffident information to admit or deny 

Paragraph 6 of the Complaint: do not have sufficient infoonanon to admit or deny 

Paragnpb 7 of the Complaint do not have sufficient information to admit or deny 

I do not recall any of the inradents of the evidence in tins matter. Therefore, I have no 

knowledge in my memory of the incidents. I could not have koowm^Y committed diese 

violations. As stated in Section 13.14 (b) Any person wh<$]^iowingly commits an act in 

violation of 49 U.S.C. chapter 51 or a regulation prescribed or oi^teflssued under that 

chafnter, is subject to a civil penalty under 49U.S.C. 5123. 

Your oonadeiation in this matter is greatly appreciated. 

RespectfiiUy submitted, 

Spmjuel Latham, Respondent 

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