U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of Renaissance Jet, Inc. 

Docket No. FAA-2013-1078 

Case No. 2012EA390030 

Judge Sullivan 

RECEIVED 

JUN 0 9 2014 

HEA-RING DOCKET 

AGENCY'S FIRST SET OF INTERROGATORIES, REQUEST FOR 

PRODUCTION OF DOCUMENTS, AND REQUESTS FOR ADMISSIONS 

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 

within thirty (30) days: 

INTERROGATORIES AND REQUEST FOR PRODUCTION 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 of this 

matter. 

2. Provide the substance of the testimony to be offered by each of said witnesses. 

3. With respect to each expert witness identified in response to request Nos. 1 and 2 

above: 

(a) identifY the subject matter on which the expert is expected to 

testifY; 
(b) list the substance of the facts and opinions to which the expert 

is expected to testifY; 

(c) provide a summary of the grounds for each opinion; 

(d) if the 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 of all documents that support the contention of Respondent 

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 "center malfunction display" as alleged in the Complaint. 
8. Produce copies of all documents that support the contention of Respondent 

that the aircraft contained no "center malfunction display" as alleged in the 

Complaint. 

9. State all facts to support the contention of Respondent 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 of Respondent 

that the "GPU start of the 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 of Respondent that "A ?P trims slow" 

is not a discrepancy, but a nonnal aircraft occurrence. 

12. Produce copies of all documents that support the contention of Respondent 

that "AlP trims slow"is not a discrepancy, but a normal 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 of Respondent 

that the "oxygen needs servicing" was not a discrepancy, and that the oxygen 

was within limits. 
REQUESTS FOR ADMISSIONS 

1. The copy of the Aircraft Discrepancy Record (attached herein as Exhibit A1) is genuine. 

2. The copy of the Aircraft Discrepancy Record (attached herein as Exhibit A-2) 

. . 1s genume. 

3. The copy of the Aircraft Discrepancy Record (attached herein as Exhibit A-3) 

. . 1s genume. 

4. The copy of the Aircraft Discrepancy Log and Historical Record (attached 

herein as Exhibit A-4) is genuine. 

5. The copy of the two-page excerpt from the General Operations Manual of 

Renaissance Jet, Inc. (GOM) (attached herein as Exhibit A-5) is genuine. 

6. The copy of the one-page excerpt from the GOM (attached herein as Exhibit 

A -6) is genuine. 

7. The copy of MEL page XI (attached herein as Exhibit A-7) is genuine. 

8. The copy of MEL page 34-7 (attached herein as Exhibit A-8) is genuine. 

9. The copy of MEL page 78-l (attached herein as Exhibit A-9) is genuine. 

10. The copy of the flight log (attached herein as Exhibit A-10) is genuine. 

11. At all times relevant to the Complaint in this matter, the document 

represented by Exhibit A-5 was in effect. 

12. At all times relevant to the Complaint m this matter, the docwnent 

represented by Exhibit A-6 was in effect. 
13. At all times relevant to the Complaint m this matter, the document 

represented by Exhibit A-7 was in effect. 

14. At all times re1evaut to the Complaint m this matter, the document 

represented by Exhibit A-8 was in effect. 

15. At all times relevant to the Complaint m this matter, the document · 

represented by Exhibit A-9 was in effect. 

Respectfully submitted, 

Alfred R. Johnson, Jr. 

Regional Counsel 

By Zachary M:Bnlim l\~ Attorney 

Federal Aviation Administration 

1 Aviation Plaza 

Jamaica, NY 11434 

718 553-3258 

718 995-5699 

Date: June 2, 2014