Todd C. Emerson, #8175 444 South River Road St. George, Utah, 84790 Telephone: (435) 634-3530 Facsimile: (435) 634-3505 Attorney for SkyWest Airlines, fuc. 

# RECFI\/ED SEP- 3 'c:G14 

## HEARING DOCKET

UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS

WASHINGTON, D.C.
illthe Matter of:

SkyWest Airlines, Inc. FAA Case No. 2012NM060030 FDMS No. FAA-2014-0322

Judge: Richard C. Goodwin

RESPONDENT'S INITIAL DISCOVERY REQUEST TO COMPLAINANT

INTERROGATORIES AND REQUESTS FORPRODUCTION futerrogatory No. 1: Identify byname, address and telephone number all persons whom you !mow to have personal knowledge ofthe matters alleged in the Complaint. futerrogatory No.2: Identifyby title, date, author, present custodian, and content, all documents, including correspondence, obtained by you or in your possession, relating to the assertions in the Complaint. REQUEST FOR PRODUCTION NO. 1: Provide a copy ofall documents referred to in your answer to the preceding interrogatory. InterrogatoryNo. 3: Identifyby name, address and telephone number, all persons whom youintend to have testify as a factual.Q! expert witness in your defense at the hearing in this matter, and for factual witnesses, provide a detailed summary ofeach persons anticipated testimony. Interrogatory No. 4: Identifybytitle, date, author, present custodian, and content, all documents which you anticipate offering into evidence at the hearing inthis matter, and through which witness or witnesses. REQUEST FORPRODUCTION NO. 2: Provide a copy ofall documents referred to in your answer to the preceding interrogatory. Interrogatory No. 5: With respect to each expert witness identified in response to Interrogatory No. 3, above, specifytheir specific area ofexpertise, and provide a synopsis oftheir credentials, background, training and experience. Interrogatory No. 6: With respect to each expert you expect to call as a witness, state the subject matter on which the expert is expected to testify, and state the substance ofthe facts and opinions to which the expert is expected to testify, and a sunnnary ofthe grounds for each such opinion. InterrogatoryNo. 7: Identify all persons involved in loading and counting bags at SMF for Flight 4743. InterrogatoryNo. 8: Identify the person at SMF who believed the bag count on Flight 4743 was incorrect. InterrogatoryNo. 9: Identifythe person at SMF who called SkyWest to report the alleged miscounted bags on Flight 4743. Interrogatory No. 10: Identify any witness in LAX who met Flight 4743 and verified the report that 3 9 valet bags were present inthe baggagehold but not accounted for inthe CLR or manifest. Interrogatory No. 11: Identify any witnesses that Inspector Stow, or any other FAA inspector, contacted in SMF or LAX to verifythere were 39 valet bags unaccounted for on Flight 4743. REQUEST FORPRODUCTIONNO. 3: Provide a copy ofall photographs depicting the bags present in the cargo hold for Flight 4743 or during loading orunloading ofthe same. REQUEST FORPRODUCTIONNO. 4: Provide a copy ofall eye-witness statements relating to the loading, unloading and counting ofbags for Flight 4743. REQUEST FORPRODUCTIONNO. 5: Provide a copy ofall Exhibits that youwill present during the hearing in this matter.

2REQUEST FORADMISSIONS
REQUEST FORADMISSIONNO. 1: Admit the FAA has not contacted or gathered any evidence from anywitness involved in the loading, unloading or counting ofbaggage on Flight 4743. REQUEST FOR ADMISSIONNO. 2: Admit the FAA has no photographs orpaperwork obtained at SMF or LAX to verify the alleged bag miscount on Flight 4743. REQUEST FOR ADMISSIONNO. 3: Admit the FAA has not obtained a copy ofthe cargo load report, in any iteration, for Flight 4 743. REQUEST FOR ADMISSIONNO. 4: Admit Sky West didnot conduct the ground handling for Flight 4743 in SMF. REQUEST FOR ADMISSION NO. 5: Admit the FAA is relying solely on an unverified, hearsay report receivedby SkyWest from a third-party vendor indicating that 39 valetbags may have been omitted from the CLR, flight manifest or weight andbalance calculations for Flight 4743.

DATED this 29th day ofAugust, 2014.

Attorney for SkyWestAirlines

3CERTIFICATE OF SERVICE The undersigned hereby certifies that onthis 29th day ofAugust, 2014, a true and correct copy ofthe foregoing RESPONDENT'S INITIAL DISCOVERY REQUEST TO COMPLAINANT was served as follows:
The Honorable Richard C. Goodwin Department ofTransportation Office ofHearings 1200 New Jersey Avenue, S.E. Ell-310 Washington, D.C. 20590 {FederalExpress} Federal Aviation Administration 800 Independence Avenue SW Washington, DC 20591 Attn: Hearing Docket Clerk, AGC-430 Wilbur Wright Building- Suite 2W1000 {Federal Express} Jeffrey Harper Federal AviationAdministration Northwest Mountain Region, ANM-7 1601 Lind Avenue S.W. Renton, Washington 98057 {E-mail andFederal Express}

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