U.S. DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS WASHINGTON, D.C.

Inthe Matter ofRenaissance Jet, Inc. Docket No. FAA-2013-1078 CaseNo. 2012EA390030 Judge Sullivan 

# RECEIVED JUN 09 2014 

## HEA-RING DOCKET

AGENCY'S FIRST SET OF INTERROGATORIES, REQUEST FOR PRODUCTIONOF DOCUMENTS, ANDREQUESTS FORADMISSIONS COMES NOW the Agency, by and through its designated representative, the Regional Counsel for the Eastern Region and his duly designated agents, and requests that Respondent, Renaissance Jet, Inc., respond to the following discovery withinthirty (30) days: INTERROGATORIES AND REQUEST FORPRODUCTION OF DOCUMENTS 1. IdentifY the names, titles, business or home addresses and telephone numbers of each person whom the Respondent intends to call as a witness at the hearing ofthis matter. 2. Providethe substance ofthetestimonyto be offeredby each ofsaidwitnesses. 3. With respect to each expert witness identified in response to request Nos. 1and 2 above: (a) identifY the subject matter on which the expert is expected to testifY;

### (b) list the substance ofthe facts and opinions to which the expert is expectedto testifY; (c) provide a summary ofthe grounds for each opinion; (d) ifthe Respondent intends to introduce into evidence or otherwise rely upon a written curriculum vitae or other written document listing the expert's professional qualifications, identity and attach copies of all such documents. 4. Identity and produce copies of any and all documents or other tangible exhibits on which the Respondent anticipates relying, or will rely, in support of the case it will present at the hearing in this matter, including but not limited to documents or other tangible exhibits it intends to introduce into evidence. 5. State all facts to support the contention of Respondent that the Flight Management System (FMS) referred to in the Complaint was never inoperative. 6. Produce copies ofall documents that support the contention ofRespondent that the Flight Management System (FMS) referred to in the Complaint was

never inoperative. 7. State all facts to support the contention of Respondent that the aircraft contained no "centermalfunction display" as alleged in the Complaint.8. Produce copies of all documents that support the contention ofRespondent that the aircraft contained no "center malfunction display" as alleged in the Complaint. 9. State all facts to support the contention ofRespondent that the "GPU start of the left engine bogs down right engine while starting" is not a discrepancy, but a normal aircraft occurrence. 10. Produce copies of all documents that support the contention ofRespondent that the "GPU start ofthe left engine bogs down right engine while starting" is not a discrepancy, but a nonnal aircraft occurrence. 11. State all facts to support the contention ofRespondent that "A?P trims slow" is not a discrepancy, but a nonnal aircraft occurrence. 12. Produce copies of all documents that support the contention ofRespondent that 

### "AlP trims slow"is not a discrepancy, but anormal aircraft occurrence. 13. State all facts to support the contention of Respondent that the condition "oxygen needs serving" was not a discrepancy, and that the oxygen was within limits. 14. Produce copies of all documents that support the contention ofRespondent that the "oxygen needs servicing" was not a discrepancy, and that the oxygen

was within limits.REQUESTS FORADMISSIONS 1. The copy ofthe Aircraft Discrepancy Record (attached herein as Exhibit A1) is genuine. 2. The copy ofthe AircraftDiscrepancy Record (attached herein as Exhibit A-2)



### . . 1s genume. 3. The copy ofthe Aircraft DiscrepancyRecord (attached herein as Exhibit A-3)



### . . 1s genume. 4. The copy of the Aircraft Discrepancy Log and Historical Record (attached herein as ExhibitA-4) is genuine. 5. The copy ofthe two-page excerpt from the General Operations Manual of Renaissance Jet, Inc. (GOM) (attached herein as ExhibitA-5) is genuine. 6. The copy ofthe one-page excerpt from the GOM (attached herein as Exhibit A-6) is genuine. 7. The copyofMELpage XI (attachedherein as ExhibitA-7) is genuine. 8. The copy ofMEL page 34-7 (attached herein as ExhibitA-8) is genuine. 9. The copy ofMEL page 78-l (attachedherein as Exhibit A-9) is genuine. 10. The copy ofthe flight log (attachedherein as Exhibit A-10) is genuine. 11.At all times relevant to the Complaint in this matter, the document represented byExhibitA-5 was in effect. 12.At all times relevant to the Complaint m this matter, the docwnent represented byExhibit A-6 was ineffect.13.At all times relevant to the Complaint m this matter, the document represented by ExhibitA-7 was in effect. 14.At all times re1evaut to the Complaint m this matter, the document represented byExhibitA-8 was in effect. 15. At all times relevant to the Complaint m this matter, the document · representedbyExhibitA-9 was in effect. Respectfully submitted, Alfred R. Johnson, Jr. Regional Counsel



### By

# l\~ Zachary

# M:Bnlim Attorney Federal AviationAdministration 1Aviation Plaza Jamaica, NY 11434 718 553-3258 718 995-5699 Date: June 2, 2014