UNITEDSTATESOFAMERICA RECEIVEr) 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS JUN 0 I 2014 

WASHINGTON, D.C. HEARING DOCKET 

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In the Matter of Ridan Investments, 

Inc. 

Respondent. 

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FAA Docket No.: TO BE ASSIGNED 

FDMS No.: FAA-2013-1082 

FAA Case No.: 2012S0700133 

FAA Region: Western-Pacific 

Judge: Hon. Richard C. Goodwin 

SUPPLEMENT TO COMPLAINANT'S 

MOTION TO COMPEL, OR, IN THE 

ALTERNATIVE, MOTION TO EXTEND 

TIME TO CONDUCT DISCOVERY 

To: Administrative Law Judge (ALJ) Richard C. Goodwin, and Respondent: 

Complainant hereby supplements its May 23, 2014 Motion to Compel, Or, 1n the 

Alternative, Motion to Extend Time to Conduct Discovery, in order to add the following 

information: 

Complainant's argument that good cause exists for issuance of an Order compelling 

Respondent to answer Complainant's First Set of Discovery (Discovery Requests) based 

upon the fact that Respondent was not prejudiced by the alleged one (1) business day delay in 

receiving the discovery requests. 

Complainant served the Discovery Requests upon Respondent via United States Mail, 

certified mail, return-receipt requested. 1 The certified mail, return receipt card was received 

in this office and shows it was signed by "Griselda B." "Griselda B." appears to be Griselda 

Bastian, the same person who signed the Certificate of Service on Respondent's Answer and 

Respondent's Response to the discovery requests? The "Date of Delivery Box" on the 

1 See Exhibit H (Declaration of Antonia Garcia). 2 See Exhibit H, Exhibit C (Respondent's Answer) and Exhibit F (Respondent's Response). 
Certified Mail Receipt was left blank.3 A review of the United States Postal Service's 

Tracking Information website reveals that Respondent received the discovery requests on 

May 9, 2014.4 This further shows that Respondent was not prejudiced, and indeed, could 

have answered the discovery requests within 30 days. 

Therefore, Complainant respectfully requests that the ALJ issue an Order compelling 

Respondent to answer Complainant's discovery requests, or, in the alternative, grant a motion 

extending time to conduct discovery. 

Respectfully submitted, 

NAOMI TSUDA 

Regional Counsel 

By: $,-h---~ General Attorney 

Dated: May 27,2014 

CBAx7128/05-23-14/L:ADOLPH/Civ A vEnf/CivPenalties/Hazmat!Ridan 

Investmentslnc/Supplement to Motion to Compel.doc 

3 See Exhibit H, and Exhibit E, second page (Certified Mail Receipt card, Discovery Requests). 4 See Exhibit I (USPS Trackiog Information sheet). 

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Exhibit 

"H" 
DECLARATION OF ANTIONA GARCIA 

I, ANTONIA GARCIA, declare as follows: 

All matters stated herein are within my own personal knowledge, and if called as a 

witness, I could and would competently testify as follows: 

1. I am a Paralegal in the Office of the Regional Counsel, Federal Aviation Administration, 

Western-Pacific Region. 

2. On April 7, 2014, I mailed Complainant's First Set of Discovery, Ridan Investments, 

Inc., FDMS No. 2013-1082, FAA Case No.2012S0700133, by certified mail, retnrn receipt 

requested [tracking number 7011 2210 0002 6550 7200], and by regular first class mail at 

Respondent's counsel's address of record at 550 North Parkcenter Drive, Suite 204, Santa Ana, 

California 92705. A true and correct copy of the Certified Mail Receipt card is attached to the 

original May 23, 2014 Motion as Exhibit "E", second page. 

3. The certified mail, return receipt card was received in this office and shows it was signed 

by "Griselda B." The "Date of Delivery Box" on the Certified Mail Receipt was left blank. I d. 

4. I am informed and believe that "Griselda B." is Griselda Bastian, the same person who 

signed the Certificate of Service on Respondent's Answer and Respondent's Response to the 

discovery requests. A true and correct copy of Respondent's Answer and of Respondent's 

Response are attached to the original May 23, 2014 Motion as Exhibits "C" and "F." 

5. On May 27, 2014, I entered the tracking number identified in paragraph 2 above. The 

United States Postal Service tracking information reveals that the discovery requests were 

delivered by the United States Postal Service on April 9, 2014, at 11:19 a.m. A true and correct 

copy of the USPS Tracking information sheet is attached as Exhibit "I." 
I declare under penalty of perjury under the laws of the United States of America that the 

foregoing is true and correct. 

Signed this 271

h day of May 2014, in Hawthorne, CA. 

~ON~clA ' 
Exhibit 

"I" 
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USPS Tracking TM 

Tracking Number: 70122210000265507200 

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April 9, 2014, 

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Delivered 

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SANTA ANA, CA 92705 

Your item was delivered at 11:19 am on April9, 2014 in SANTA ANA, CA 

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CERTIFICATE OF SERVICE 

I hereby certify that on this date I have placed in the United States mail, postage 

prepaid, the executed original, and one copy of the SUPPLEMENT TO 

COMPLAINANT'S MOTION TO COMPEL, OR, IN THE ALTERNATIVE, MOTION 

TO EXTEND TIME TO CONDUCT DISCOVERY, addressed as follows: 

Hearing Docket 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, D.C. 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building-Suite 2Wl 000 

I further certify that on this date I have placed in the United States mail, postage 

prepaid, and sent via e-mail, a copy of the above, addressed as follows: 

The Honorable Richard C. Goodwin 

U.S. Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Ave., S.E. (Ell-310) 

Washington, D.C. 20590 

Attn.: Patricia Matthews, Staff Assistant 

E-mail: Patricia.Matthews@dot.gov 

And by United States mail, postage prepaid, and sent via e-mail, a copy of the above, 

addressed as follows: 

Lawrence M. Burek (Counsel for Respondent) 

550 North Parkcenter Drive, Suite 204 

Santa Ana, CA 92705 

lburek@lsblawyers.com 

Dated: MAY 2 '7 2014 

{f2t;;£L Antonia L. Garcia, Paralegal 

Office of the Regional Counsel 

Federal Aviation Administration 

Western-Pacific Region 

Lawndale, California 

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