01/14/2015 11:35 FAX 3107256816 AWP-7 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C . 

• 

In the Matter of Juan Marquez Jr * FDMS No. FAA-2014,0862 

* 

Respondent. • FAA Region: Western,Pacific 

* 

• Judge: Unassigned 

• 

* 

*********~*****~********************~******* 

MOTION TO DEEM ALLEGATIONS ADMITTED 

AND TO lSSUE ORDER ASSESSING CIVIL PENALTY 

To: Hearing Docket Clerk and Respondent acting in pro per: 

141002 

COMES NOW, the Regional Counsel of the Western-Pacific Regi'"' c>f the 

Federal Aviation Administration (FAA), by and through his counseL and files this 

Motion to Deem Allegations Admitted and to Issue Order Assessing Civil Penalty. or in 

the altemative. to deem aJiegations admitted and to limit the hearing to the amount of the 

sanction pursuant to Section l3218(a) and 13.209(f) of the Rules of Practice. This 

motion is based on the fact that no answer has been filed by Respondent. 

Section !3.209(f) of the Rules of Practice [14 C.F.R- Section 13.209(1)1 slates, "A 

person's failure to file an answer without good cause shaH be deemed an admission to the 

tmth of each allegation contained in the complaint." The complaint in this case was 

served on November 6, 2014. (See attached declaration of Jeff Kamberg). The 

Complaint was served by certified mai.l, return receipt reguested, and tracking 

infonnation fmm the United States Postal Service indicates it was deli··,-ered on 
01/14/2015 11:35 FAX 3107256816 A\VP-7 141003 

November 8, 2014. (A copy of the tracking confinnation is attached hereto as Exhibit 

"A" and incorporated herein by this reference.) On November 12, 2014, th~ Agency 

received PS Fom1 3 811 signed by "Yesenia Gonzalez'' as having received the Complaint. 

although indicating that the date of receipt was November 8, 2014. (A copy ofthc green 

card is attached hereto as Exhibit "B" and incoported herein by this reference.) Pursuant 

to Rule 13.211 (!4 C.F.R. § 13.211), the date of service is the date on the proof of 

service, and after service by mail, an additional 5 days is added to the prescribed period 

for a response. Accordingly, an answer was due on or before December 11, :2014. To 

date, no answer has been received by Complainant trom Respondent. 

Respondent was iidvised of the requirement to file an answer in the cover letter 

which accompanied the complaint. In specific, the one-page cover letter included the 

following paragraph: 

"NOTE TO RESPONDENT: SECTION 13.209 OF TI-lE CP RULES OF 

PRACTICE REQUIRE THAT A WRITTEN ANSWER TO THE COMPLAINT BE 

FILED NOT LATER THAN 30 DAYS AFTER SERVlCE OF THE COMPLi\lNT. AS 

AN ALTERNATIVE TO FILING AN ANSWER, A MOTION MAY Bi~ FILED 

PURSUANT TO SECTION J3.208(D) OR SECTION 13218(F)(l-4) OF TI-m RULES 

OF PRACTICE." (See Exhibit "C" attached hereto and incorporated by this rekrcncc). 

Moreover, in accordance with established office procedure, a copy of the Rules of 

Practice applicable in these cases was enclosed with the Notice of Proposed Civil Penalty 

served June !9, 2014. (See attached declaration ofJeff Krunberg.) 

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In view of the above, Complainant moves that the allegations in the con1plaint be 

deemed admitted, and an Order Assessing Civil Penalty be issued in the amount of 

$20,000.00. Alternatively, it is moved thar the allegations be deemed admitted and the 

hearing be limited to the issue of the amount of the sanction. 

Respectfully submitted, 

Naomi Tsuda 

Regional Counstj 

,/)/ 

Dated: JI\N '14 2Di5 

3 
01/14/2015 11:35 FAX 3107256816 AWP-7 

CERTlFICATE OF SERVICE 

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

postage prepaid, certified mail, the executed original of the MOTION TO DEEM 

ALLEGATIONS ADMJTTED AND TO ISSUE ORDER ASSESSING CIVIL 

:PENALTY, addressed as follows: 

federal Aviation Administration 

800 Independence Avbenue, S,W, 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2Wl 000 

FAX (202) 493-5020 

141005 

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

prepa:id, certified mail - retum receipt requested, and by regular mail, a true copy of the 

MOTION TO DEEM ALLEGATIONS ADMITTED AND TO ISSUE ORDER 

ASSESSING CIVIL PENALTY, addressed as follows: 

Juan Antonio Marquez Jr. 

717 Crawford StTeet 

Bakersfield, CA 93305 

Dated: .January 14,2015 

di#:~ JeffKamberg 

Legal Technician 

~ Office of the Regional Counsel 

Federal Aviation Administration 

Western-Pacific Region 

Hawthorne, California 

4 
01/14/2015 11:35 FAX 3107256816 AWP-7 141006 

DECLARATJON OF .JEFF KAMBERG 

I. Jeff Kamberg, declare as follows: 

All martel's stated herein are within my own personal knowledge, and if called as a witness. 1 

could, and would competently testify thereto, except for those matters stated upon infom1ation and belief. 

md as w those mat1ers, I hclieve them to be true: 

L i am a legal technician in the Office of the Regional Counsel, Federal Aviation 

Administration, Westem-l'acific Region. 

7 On November 6, 2014, the original Complaint was served on Juan Antonro Marquez k. 

818 Crawford St1·eet, Bakersfield, CA 93305 by certified mail, retui'I1 receipt requested (70 14 

0 I 50 0000 II 02 5043). The Complaint was deLivered on November &, 20 I 4. A true copy of 

the tr~.cking printout fi'om the USPS website is attached as Exhibit "A'' 

3. On Novcmbe1· 12, 2014, the Agency received the signed PS Form 381 I (green card) 

signed by "Yesenia Gonzalez." A true copy of the front and back of PS Form 3R I I are attached 

as Exhibit "B." 

3. It is established office procedure tc· enclose a copy of the Rules of Practice applicable in 

these cases to the Respondent with the Notice of Proposed Civil Penalty. 

4. On June 19, 2014, the Respo11dent wa,~ served with the Notice of Proposed Civil Penalty, 

and a copy of the Rules of Practice for Civil Penalty cases. 

I declare under penalty of perjury under the laws of the United States of America that the 

foregoing is ttue and correct. 

Signed this 14'" day of January, 20 I 5, in Lawndale, CA. 

-, 

~--- / // 

JEFF KAMBJ~RG 

J~/C~~ . !J 
01/14/2015 11:35 FAX 3107256816 AlVP-7 lill 007 

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November 8, 2014 , 1,:55 am BAKERSFIELD, CA 93305 

November 8, 201.:1 , 4:•i.O a.m DepatlM USPS Faci1ity BAKERSF!C.LD. CA 93380 

Arrived at USPS Facility BAKERSFIELD, CA 93380 

Noveinbe;G, 201.<1. ~:11 prn Arrived ~l USPS Facilit.y LOS ANGt::Ll::s. c,~ 90052 

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01/14/2015 11:35 FAX 3107256816 AWP-7 ~008 

! First .... Class Mail : .l Postaae & Fees PRid' ' 

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~ Perm!t !\!o, ·G-10 

dd . ' 7"P jC® ' "I . I • * S6!nder.: Please print your na.rne, a res~~ ane: ~l +..... rn ~'.IS oox 

U.S. Department of Transportation 

Federal Aviation Administration 

P. 0. Box 92007, AWP-7.6 

Los Angeles, CA 90009-2007 , '' ',".· 

• Complete- it9me l, 2, and s.' Also bomplete 

1terri 4 lf .Restricted Delivery is dGalred. 

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• Attach thiS card to thB ba~k of the maUplee:e, 

or on th@ fl:ont if spac;:e Perinlts. 

1. Article Addressed to: 

JuanAntonioMarquezJr. 

717 Cra',:vfotd Street · · 

Bakersfidd,CA 93305 

A Slgnatur'@t ... 

. · C"'·· ·~Agent · / .' /"~ :.' C•o-t. ,, ?"-f': .. .' .1(0.._ (.:C"' .,-,,~ ..-'\r!i ~Ac;itl~., 

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0. Is delfvary address different from item 1? D Yes 

tt Yes, anter c!~:llvery addres.<:~ below: I:1 No 

3 • .E7'ice l)tpe 

~ _ Gertlflad Mallw D Pr!Or'lty Mall Expre"sa'" 

D Registered D Return Receipt for Marchand I~ 

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2. Article 'NUmber · 7014 0150 DODO 1~02 ED43 

PS Form 

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-- . 
01/14/2015 11:35 FAX 3107256816 AWP-7 141009 

US. Department Western"Pacific Region P.O. Box 92007 

·of Transportation Office of the Regional Counsel Los Angeles, CA 90009-2007 

Federal Aviation 

Admlnisltratiof! 

Telephone: (310) 725-7117 

Facsimile: (31 0) 725-6816 

CERTIFIED MAIL- RETURN RECEIPT REQUESTED and FACSIMIU' 

federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building-- Suite 2Wl 000 

Re: In the Malter ofJuan Antonio Marquez k; FAA Case No. 20!4WP 1 70021 

Enclosed is a copy of a request for hearing, postmarked October 22, 2014, recdvcd by our 

office on October 27, 2014, and the original and one copy ofthe Complaint in the above" 

referenced proceeding. 

I request that the hearing in this matter be held in the Los Angeles, Califomia aret-t, and 

expect that the hearing \:villlast one (l) day. 

Please address all communi. cations for the Regional Counsel of the Westcrn-Paciiic Region, 

to the undersigned, at: Office of the RegionaJ Counsel, A WP-7.6, Federal Aviation 

Administration, Western" Pacific Region, P. 0. Box 92007, Los Angeles, CA 90009-2007, 

Telephone: (310) 725-7117, FAX: (310) 725-6816. 

Sincerely, 

NAOMI TSUDA 

Regional Cmms~h 

r--, / J 

I !

1 I 

By: , , !)i ..Si=.'' 

( 

Lierry Green 

Atto,rnev 

Enclo~ R~quest for Hearing; Complaint; Certificate of Service 

NOTE TO RESPONDENT; SECTION 13.209 OF THE CP kULES OF PR.A.CTICE 

REQUIRE THAT A WRITTEN ANSWER TO THE COMPLAINT BE FILED NGT 

LATER THAN 30 DAYS AFTER SERVICE OF THE COMPLAINT. AS AN 

ALTERNATIVE TO FIL!NG AN ANSWER. A MOTION MAY BE FILED PURSUANT 

TO SECTION !3.208(D) OR SECTION !3.218(F)(H) OF THE ROLES OF PR?.CT!CE. 

~ ,_, 1 

. \ '\ - ~ 1--Jy,..:ol!, 
01/14/2015 12:18 FAX 3107256816 AWP-7 141001 

Federal Aviation 

Administration 

~ Hearing Docket Clerk, AGC-430 Office of the Regional Counsel, AWP-7 

PO Box92007 -

Phone: . 

~:- (20~) 267-1293 

From:: Lierre Green ,, 

Title: FAA Attorney, AWP-7.6 .. 

~-- January 14, 2015 

15 

Pages w/cover: 

0 Per your Request 

0 For Coordination 

NOTES/COMMENTS: 

l.os Angeles, CA 90009-2007 

Telephone: (310) 725-7117 

Facsimile: (310) 725-6816 

Email: 

Facsimile 

Description of item being transmitted: 

MTC Answers to Comp's First Disc Req 

0 For Review 0 Please Comment 

~- Hard Copy to Follow via US MAIL 

RE: Administrator, FAA v. Joseph Terrell Brown, FDMS No. FAA-2014-0690 

The information contained in this facsimile message is intended for the use of the designated addressee only. 

The information transmitted may be subject to the attorney-client privilege or may be prote<;ted under the Privacy 

Act. li' you are not the designated addressee and you receive this document through inadvertent error, any further 

review, dissemination, distribution or copying of this communication is strictly prohibited. IF YOU RECEIVE THIS 

COMMUNICATION IN ERROR, PLEASE NOTIFY THE SENDER IMMEDIATELY BY TELEPHOI~ING (310) 725-

7100 AND DESTROY THE ORIGINAL OF THIS COMMUNICATION. Thank You. 

0 U.S. Dl':p;~~!mr,ml of Transportation 
01/14/2015 12:18 FAX 3107256816 AWP-7 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C . 

In the Matter of Joseph T. Brown 

Respondent. 

• 

* 

* 

• 

• 

* 

* 

* ****~~*******•~••*********••****************** 

FDMS No. FAA-2014-0690 

FAA Region: Western-Pacific 

Judge: Richard C. Goodwin 

MOTION TO COMPEL ANSWERS TO COMPLAINANT'S FIRST 

DISCOVERY REQUEST 

141002 

COMES NOW, the Regional Counsel o:f the Westem-Pacific Region of the 

Federal Aviation Administration (FAA), by counsel, and files this Motion 10 Compel 

Answers to Complainru1t's First Set of Discovery, pursuant to Section 13.220(m) of the 

Rules o:f Practice. This motion is based on the fact that Respondent has failed to t1le a 

response to Complainant's First Set of Discovery. 

FACTS 

1. On December 2, 2014, Complainant served his First Set o:f Discovery to 

Respondent ("Discovery Requests") seeking information regarding the identity of 

witnesses, testimony, documents and other evidence to be presented by Respondent at 

the hearing in this case. (A true copy of said discovery is attached hereto as E>:hibit 

"A.") 

2. The Discovery was served on Respondent and his representative, Ancesah 

Cleveland, at 3370 Adriatic Avenue #2A, Long Beach, CA 90810 by ce11itled mail. 
01/14/2015 12:18 FAX 3107256816 AlVP-7 I(!] 003 

return receipt requested [tracking number 7014 0150 0000 1102 5763 and 70i4 0150 

0000 1 102 5760 respcctivelyl This is the address that Respondent and his 

representative have regularly received previous filings in this case. 

3. On December 3, 2014, the Respondent and his representative each recdved the 

discovery request. The certified mail receipts were each sig11ed by Respondent' s 

representative, but not dated. (A tJue and correct copy of signed certii1ed nwil receipts 

and printouts downloaded from the Uni:ed States Post Office indicating when the 

requests were delivered. arc attached as Exhibit "B.") 

4. To date, Respondent has failed to respond to the propounded discovery, nor has 

he requested an extension of time in which to respond. 

ARGUMENT 

Section 13.220(m) of the Rules of Practice states: "A party may make a motion to 

compel discovery if a person refuses to answer a question during a dcposititlr,, a party 

fails or refuses to answer an interrogatory, if a person gives an evasive or incomplete 

answer during a deposition or when responding to an interrogatory, or a pati)' fails or 

refuses to produce documents or tangible: items." Here, Complainant's Discovery 

Requests were sent to Respondent and his representative on December 2, 2014, and 

Respondent was requested to respond to the Intenogatories and Requests for Ptoduction 

of Documents, separately and fully under oath, within thirty (30) days of the date of 

service. Pursuant to section 13.211 of the Rules of Practice, the date of service is the 

mailing date shown on the certificate of senrice, and after service by maiL an additional 

five (5) days is added to the prescribed period for a response. Accordingly, Respondent's 

response to Complainant's Discovery Requests was due on or before January 6, 2015. To 
01/14/2015 12:18 FAX 3107256816 AWP-7 141004 

date, Respondent has failed to respond to Complainant's Discovery Requests, nor has he 

requested an <::xtension of time in which to submit his response. 

Without responses to the propounded discovery, Complainant will be hampered in 

its ability to prepare for a heming in this matter. Therefore, Complainant requests that 

the Administrative Law Judge issue·an Order compelling Respondent to provide separate 

and complete answers to each of the pending discovery requests served December 2. 

2014, and that said responses be ordered served so that they are received by Coa1piainant 

no later than February 10, 2015. In the event Respondent fails to comply with the Order 

to Compel, Complainant requests the Administrative Law Judge issue an Order making 

negative i.nferences against Respondent relative to the matters sought and not provided, a 

preclusion order, dismissal, or other relief deemed appropriate by the court. 

Respectfully submitted, 

Federal Aviation Administntion 

Westem,Pacific Region 

Lawndale, California 

Naomi. Tsuda 

Regional Cotmsel /'I 

By / :J/!li2 I . IJieTTe·M. Green I / 

tl!J:ofney 

Date: 

JAN 14 2015 

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01/14/2015 12:18 FAX 3107256816 AWP-7 141005 

CERTIFICATE OF SERVICE 

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

postage prepaid, certifred mail, the executed original of the COMPLArNANT'S 

MOTION TO COMPEL RESPONSES TO DlSCOVERY REQUESTS, acldressccl as 

follows; 

Federal. Aviation Administration 

800 Independence Avbenue, S.W. 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2Wl000 

FAX (202) 267-1293 

The Honorable Richard C. Goodwin 

Administrative Law J\ldge 

Office of Hearings, M-20 

U.S. Department of Transportation 

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

Washington, DC 20590 

VIA FACSIMILE: (202) 366-7536 

I i'lrrther certif'y that on this date I have placed in the United States maiL postage 

prepaid, certified mail -· retmn receipt requested, and by regular mail, a true copy o:F the 

COMPLAINANT'S MOTION TO COMPEL RESPONSES TO DISCOVERY 

:REQUESTS, addressed as follows: 

Joseph Terrel Brown, Respondent 

3370 Adriatic Avenue #2A 

Long Beach, CA 9081 0 

Aneesah Cleveland, Resondent's Representative 

3370 Aclriatic Avenue #2A 

Long Beach, CA 90810 

Dated: January 14,2015 

fYC(tl(~' ~;r '7 

JeffKamberg ' 

Legal Technician 

Office of the Regional Counsel 

Federal Aviation Aclmi.nistration 

Western-Pacific Region 

Hawthorne, California 

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01/14/2015 12:18 FAX 3107256816 AWP-7 141006 

DECLARATION OF JEFF KAMBERG 

I, JeffKamberg, declare as follows: 

All matters stated herein are within my own personal knowledge, and if called ;;s a witness, i 

< ould, and would competently testifY thereto, except for those matters stated upon infonnation a11d belie( 

el!ld as to those matters, I believe them to be true: 

1. I am a legal technician in the Office of the Regional CounseL Federal Aviation 

Administration, Western-Pacific Region. 

2. On December 2, 2014, the Complainant's First Set of Discovery to Respondent was 

served on Joseph Terrell Brown, and Aneesah Cleveland, Respondent's Representative at 3370 

Adriatic Avenue #2A, l"ong Beach CA 90810 by ce1tified mail, return receipt re.:.ll!ested (7014 

0150 0000 I !02 5760 and 7014 0150 0000 I !02 5753). A copy of the Discover·y Requests is 

attached as Exhibit "A." 

3, On December 3, the Complainant and his Rep•·esentative each received I he Discovery 

Requests. in that Respondent's Representative signed both PS Form 38lls (green cards). A copy 

of the f-ront and back of each PS Form 381:, along with the pl'intouts from WI\!.\V.LI}llS.c:Q!.J' arc 

attached as Exhibit "B." 

_,_ To date, this office has not received a response to Complainant's outstanding discovery 

request. 

I declare under penalty of perjury under tl1e laws of the United States of America that the 

foregoing is true and conect 

Sig11ed this 14"' day of January, 2015 in Law,,dale, California 
01/14/2015 12:19 FAX 3107256816 AWP-7 

UNITED STATt=S OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

**********~*****************~******~******~** 

• 

In the Matter of Joseph T. Brown * FDMS No. FAA-2014-0690 

* 

Respondent. • FAA Region: Western-Pacific 

* 

* Judge: Richard C. Goodwin 

• 

• 

COMPLAINANT'S FIRST SET OF 

DISCOVERY TO RESPONDENT 

To: Respondent and Respondent's Representative: 

~007 

Complainant, by and through counsel, pursuant tO Section 13.220 oflhe Rvlcs of 

Practice in FAA Civil Penalty Actions, requests the Respondent please respond to the 

following Interrogatories and Requests for Production of Documents, separately and fully 

under oath, within thirty (30) days of the date of service. 

These discovery requests are intended to be continuing in nature and any 

infom1ation which may be discovered by you subsequent to the service and filing of your 

answers must be brought to the attention of the. Complainant's attomey through 

sctpplemental answers when it becomes available to you, and in a reasonable time prior to 

the hearing in this matter. If there are any additions, deletions or changes in the answers 

or infom1ation provided at any time prior to hearing, the Respondent is specifically 

requested to so immediately infom1 Complainant's attomey. If such informa·jon is not 
01/14/2015 12:19 FAX 3107256816 AWP-7 141008 

furnished, iil the time of the hearing, the attorney for Complainant may mo\ e to exclude 

from evidence such information requested and not furnished. 

IL in responding to, or failing to respond to these requests for discovery you 

invoke or rely Ltpon any privilege of any kind, state specifically the nature of the 

privilege, the basis upon which you invoke, rely upon or claim it, including 2tny statutory 

or decisional reference, and identify all documents or other information, including 

contacts and communications which you believe to be embraced by the privilege 

invoked_ 

lNTERROGATORIES: 

l _ Identify by name, address and telephone number all person:\ v,;ho have 

personal knowledge of the incidents alleged in the complaint. 

2_ Identify by nan1e, address and telephone number all person'; vcho have 

personal knowledge of your affmnative defenses alleged in your answer. 

3. Identify by title, date 7 author, present custodian, and content, all 

documents obtained by you or in your possession relating to the assertwns in the 

complaint and your answer, including affilmative defenses. 

4. Identify by name, address and telephone number, all persons whom you 

intend to have testify as a factual witness i.n your defense at the hearing in this matter, and 

provide a detailed summary of each person's anticipated testimony. 

5. Identify by name, address and telephone number, all persons whom you 

intend to have testify as an expert witnes8 in your defense at the hearing in 1.l1i~ matter, 

and provide a detailed swnmary of each expert's anticipated testimony. 

6. Identify by title, date, author, present custodian, and cont<;lll, which 

documents you anticipate offering into evidence at the hearing in this nJattcr, 2nd through 

which witness or witJJesses_ 

2 
01/14/2015 12:19 FAX 3107256816 AWP-7 141009 

7. Wirh respect to each expen witness identified in response to interrogatory 

No. 5, above, specifY their area of expertise, and provide a synopsis of their credentials, 

background, training and experience_ 

8_ Do you contend that the FAA's proposed civil penalty should be ;·educed? 

9. If you answered "yes" to InteJTogatory 8., please identify all facts !.lpon which 

you base your contention. 

1 Q_ Identify all individuals by name, address, and telephone number who hav0 

knowledge of the facts which support your contention that the FAA's prcposed civi.l 

penalty sho1Jld be- reduced. 

1.1. State all facts to support your contention that you were "founci completely 

innocent of all charges against you," as yo)l contend in your request for hearing dated 

September 23,2014. 

REQUESTS FQRPRODUCTION OF DOCUMENTS: 

I. Provide a copy of all written statements/affidavits/declarations of 

individuals identified in response to inten·ogatory number 1, on the previous page. 

2_ Provide a copy of all documents identified in interrogatory number 2, on 

the previous page_ 

3. Provide a copy of all doeuments in support of any and all of your 

atlirmative defenses plead in your answer. 

4. Provide a copy of the curre:nt cuniculum vitae tor each and every expert 

you intend to have testify in your defense at the hearing in this matter. 

5. Provide a copy of any and all recorded statements of any w~tnesses 

having personal knowledge of the incidents alleged in the complaint and your ecffim1ative 

defenses alleged in your answer includiog but not limited 10 tape recordings and 

lramcriptions of the tape recordings. 

6. Provide any and all documents your expe1is will be relying upon to testify 

in your defense at the hearing on tllis matter. 

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01/14/2015 12:19 FAX 3107256816 AWP-7 141010 

7. Provid8 a copy of any and all reports, notes, charts, diagramo. ·\light ·olots 

or other wrirten documentation prepared by your expert(s) whicl1 will be testifying in 

your defense at the hearing on this matter. 

8. Provide a copy of any and all docw11ents which supports your co mention that 

the FAA's proposed civil penalty should be reduced. 

9. Provide a copy of any and all documents, repo1ts, notes, court orders, minute 

orders, a11d any other writings which o:upport your COIJtention that you were found 

"completely im1ocent of all charges against you" by a Judge as detailed in your ietter 

dated September 23, 2014. 

Respectfully submitted, 

Naomi Tsuda 

Regional Counsel 

1\ 

/ j 

~;/ / / / 

i /T'·I .... . / '/ ' 

By: 1/~~­ Llerfe" Green 

(JAttomey 

Dated: November 26,201.4 

4 
01/14/2015 12:19 FAX 3107256816 AWP-7 141 011 

CERTIFICATE OF SERVICE 

I hereby cenify that on this date I have placed in the United States mail, pas-cage prepaid, 

cer:ified 

COMPLAINANT'S 

mail, retum receipt requested, md via regular mail, the executed original c)f the 

FIRST SET OF DISCOVERY TO RESPONDENT, addressed 

as follows: 

Joseph TeEell Brown, Respondent 

3 3 70 Adriatic Avenue #2A 

Long Beach, CA 90810 

and 

Aneesah Cleveland, Respondent's Representative 

3370 Adriatic Avenue #2A 

Long Beach, CA 90810 

Dated: December 2, 2014 

~~- JeffKan1b 

Office of the Regional Counsel 

Federal Aviation Administration 

Western-Pacific Region 

Hawthome, California 

5 
01;14/2015 12:19 FAX 3107256816 AWP-7 141012 

:·U.S. Postal Service,,., 

·'CERTIFIED MAIL.:,. RECEIPT CJ 

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Hearing DocKet Clerk, AGC-430 

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120;2\:4>83-5 141"" ;{ fc7 -12f2, 

: Lierre Green 

FAA Attorney, AWP"7_6 

January 14, 2015 

Date ... , 

9 

Page$ w/cover. 

D Per your Request 

D For Coordination 

NOTES/COMMENTS: 

~ 

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