Todd C. Emerson, #8175 

444 South River Road 

St. George, Utah, 84 790 

Telephone: ( 435) 634-3530 

Facsimile: (435) 634-3505 

Attorney for SkyW est Airlines, fuc. 

RECFI\/ED 

SEP- 3 'c:G14 

HEARING DOCKET 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

ill the 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 FOR PRODUCTION 

futerrogatory No. 1: Identify by name, address and telephone number all persons whom you 

!mow to have personal knowledge of the matters alleged in the Complaint. 

futerrogatory No.2: Identify by 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 of all documents referred to in your 

answer to the preceding interrogatory. 

Interrogatory No. 3: Identify by name, address and telephone number, all persons whom you 
intend 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 of each persons anticipated testimony. 

Interrogatory No. 4: Identify by title, date, author, present custodian, and content, all documents 

which you anticipate offering into evidence at the hearing in this matter, and through which 

witness or witnesses. 

REQUEST FOR PRODUCTION NO. 2: Provide a copy of all 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, specify their specific area of expertise, and provide a synopsis of their 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 of the facts and opinions 

to which the expert is expected to testify, and a sunnnary of the grounds for each such opinion. 

Interrogatory No. 7: Identify all persons involved in loading and counting bags at SMF for 

Flight 4743. 

Interrogatory No. 8: Identify the person at SMF who believed the bag count on Flight 4743 was 

incorrect. 

Interrogatory No. 9: Identify the 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 in the baggage hold but not accounted for in the CLR or manifest. 

Interrogatory No. 11: Identify any witnesses that Inspector Stow, or any other FAA inspector, 

contacted in SMF or LAX to verify there were 39 valet bags unaccounted for on Flight 4743. 

REQUEST FOR PRODUCTION NO. 3: Provide a copy of all photographs depicting the bags 

present in the cargo hold for Flight 4743 or during loading or unloading of the same. 

REQUEST FOR PRODUCTION NO. 4: Provide a copy of all eye-witness statements relating to 

the loading, unloading and counting of bags for Flight 4743. 

REQUEST FOR PRODUCTION NO. 5: Provide a copy of all Exhibits that you will present 

during the hearing in this matter. 

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REQUEST FOR ADMISSIONS 

REQUEST FOR ADMISSION NO. 1: Admit the FAA has not contacted or gathered any 

evidence from any witness involved in the loading, unloading or counting of baggage on Flight 

4743. 

REQUEST FOR ADMISSION NO. 2: Admit the FAA has no photographs or paperwork 

obtained at SMF or LAX to verify the alleged bag miscount on Flight 4743. 

REQUEST FOR ADMISSION NO. 3: Admit the FAA has not obtained a copy of the cargo load 

report, in any iteration, for Flight 4 7 43. 

REQUEST FOR ADMISSION NO. 4: Admit Sky West did not 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 received by SkyWest from a third-party vendor indicating that 39 valet bags may 

have been omitted from the CLR, flight manifest or weight and balance calculations for Flight 

4743. 

DATED this 29th day of August, 2014. 

Attorney for Sky West Airlines 

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CERTIFICATE OF SERVICE 

The undersigned hereby certifies that on this 29th day of August, 2014, a true and correct 

copy of the foregoing RESPONDENT'S INITIAL DISCOVERY REQUEST TO 

COMPLAINANT was served as follows: 

The Honorable Richard C. Goodwin 

Department of Transportation 

Office of Hearings 

1200 New Jersey Avenue, S.E. 

Ell-310 

Washington, D.C. 20590 

{Federal Express} 

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 Aviation Administration 

Northwest Mountain Region, ANM-7 

1601 Lind Avenue S.W. 

Renton, Washington 98057 

{E-mail and Federal Express} 

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