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U,5. DEPARTMENT OF TRANSPoHEABING DOCt'^ET 

OFFICE OF HEARINGS 

WASHINGTON, DC 

In the .Matter of, 

Evergreen Helicopters of Alaska FAA pocket No. CP09AL0010 

DMS No. FAA-2009-084] 

EVERGREEN HELICOPTERS^ SECOND SET OF INTERROGATORIES AND 

REQUESTS FOR PRODUCTION 

Pursuant to 14 CFR § 13.220, Evergreen Helicopters 

ot Alaska request that the FAA answer the following 

interrogatories under oath and indentify and produce the 

requested documents for inspection and copying at the Offices 

of Richmond & Quinn, 360 K Street, Suite 200, Anchorage, AK 

99503 no later than 30.days from, the date pt this request. 

These requests '•'"are ' deemecJ' • continuing'/ '• •• and any 

information secured after answering or supplying the requested 

answers or documents/items is to be supplied by suppleinental 

production pursuant to § 13.220(i) of the Rules of Practice in 

FAA Civil Penalty Actions. 

1, Do you contend that FAA guidelines regarding 

HGNVO training programs required at least five flights of no 

less than one hour per flight of night vis.ion goggle Lraininq 

while employing n."ight vision goggles, for pilots Brabham and 
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Peabody? If so, please state all facts on which you are 

basing this contention. In addition, identify and produce a 

copy of each document that you believe support your 

contention. 

2. Do you contend that Evergreen Helicopters of 

Alaska's HGNVO approved training program, for in-house 

training, required at least five flights of no less than one 

hour per flight of night vision goggle training while 

employing night vision goggles, for pilots Brabham and 

Peabody? If so, please state all facts on which you are 

basing this contention. In addition, identify and produce a 

copy of each document that you believe support your 

contention. 

3. Regarding paragraph 11.11 of the complaint, do 

you contend that the flight in question was a helicopter night 

vision goggle operation? If so, then state all facts on which 

you are basing this contention, and identify and produce a 

copy of all documents and the substance of any oral i^tatements 

that you believe support your contention. 

Evergreen Helicopters' Second Set o£ Interrogatories and Reque.'Sl'..'? to r 

Production 

IN RE EVERGREEN HbLlCOPTF.RS OF ALASKA, INC., fAA Docker, CP09AL0010 

Page 3 
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4. Identify each person whom you intend to call as 

a witnes.s at the hearing in this matter, and for each such 

witness pro'^ide a summary of the expected testimony. 

5. For each person identif.ied in response to 

Request No. 4, identify and produce a copy of each and every 

statement made by that person in which the facts and 

circumstances of matters at issue in this case are referenced 

or discussed. 

6. Produce a complete copy of what you contend was 

Respondent's entire approved training program at the time of 

the events referenced in paragraph TI.6 of the complaint. 

7. To the extent not encompassed in your response 

to any of the foregoing items, identify and produce all 

documents upon which you expect to rely at the hearing or 

introduce as evidence in support of your position at the 

hearing in this matter. 

Evergreen Hel. •! <^opters' Second Set of Interrogator.! e.<5 and Requeau;^ for 

Production 

IN RE EVERGREEN HELICOPTERS OF ALASKA, INC, FAA Docket CP09AL0010 

Page 3 
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DATED this _/ / 

Anchorage, Alaska. 

day of December, 2009, at 

RICHMOND i QUINN 

Attorneys for Evergreen 

Helicopters of Alaska 

By: UJ 

Marc G, Wilhelm 

Alaska Bar No. 8406054 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY: that a true and 

correct copy of the foregoing was 

served by mail this /-^'^^day of 

December, 2009 on: 

Hearing Docket Clerk, AGC-430 

Wilbur Wright Building - Suite 2W1000 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, DC 20591 

Glenn H. Brown, Senior Attorney 

Office of the Regional Counsel, AAL-7 

Alaskan Region 

Federal Aviation Administration 

222 W. 7th Avenue #14 

Anchorage, Alaska 99513-7587 

:::i ^<^.y--v £i.. 

'^--RICHMOND ''& QUINN 

213e\010\DlSC\DiSC RESPS (2nd) 

Evergreen Helicoprsrs' Second Set of InrerrogaLorie.'s and Requcsta lor 

Production 

T.N RE EVERGREEN HELICOPTERS OF ALA-SKA, INC, FAA Docket CP09AL0010 

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