U.S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATIONADMINISTRATION OFFICE OF HEARINGS

WASHINGTON, D.C.
Inthe Matter ofJet Logistics, Inc. FAA-2013-0290 TheHonorable J.E. Sullivan
COMPLAINANT'S INITIAL DISCOVERY 

# RECEIVED NOV 1 22013 

## HEARING DOCKET

COMES NOW the Complainant, by and through it designated representative, the Regional Counsel for the Eastern Region and his designated and authorized agents, and provides the AdministrativeLaw andthe Respondentwith its witness list.

In addition to the witnesses listed by the Respondent, the Complainant may present at the hearing inthis matter the following witnesses:

I. Todd Kuhn, Aviation Safety Inspector, Federal Aviation Administration, 3800 Arco Corporate Drive, Suite 233, Charlotte, NC 28273, (704) 319-7048

2. Lewis Sain, Aviation Safety Inspector, Federal Aviation Administration, 3800 Arco Corporate Drive, Suite 233, Charlotte, NC 28273, (704) 319-7048
3. Kevin Richard Bryan, Check Airman, Jet Logistics, 7536 Newt Country Lane, Fuquay Varina, NC 27526-5405, (919) 805-0307 14. Andy Albert Smith, Check Ainnan, Jet Logistics, 2913 Ravenwood Drive, Kinston, NC 28504-9137, (252) 521-5575
5. Robin ScottDill, 11271 MacNab Street, Garden Grove, CA 92841-1622, (714) 225- 7370
6. Luis Alberto Rios, 2110 Vaquero Avenue, La Habra, CA 90631-4253, (562) 652- 3273 Complainant reserves the right to supplement and/or amend its witness list prior to July 18th, 2014 pursuant the Order Setting Litigation Dates and Procedures dated October 30,2013. The Complainant anticipates referring to specific exhibits from its Enforcement Investigative Report; the Answer produced by Respondent to the Complainant in response to the Agency's Complaint, and other documents provided by the Respondent to the Complaint after the Notice ofProposed Civil Penalty was issued. The following exhibits are specifically referenced:
EXHIBITS 1. JetLogistics Air Carrier Certificate 2. Excerpts ofJetLogistics Operations Specifications 3. Records for JetLogistics flight to Hawaii on June 28, 2012 and July 3, 2012 4. Trip Data Sheet Flight# 22726 5. Trip Data Sheet for flight# 22729 6. Validate Certificate for Flight# 22729
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### 7. Jet Logistics Passenger ManifestForm 8. JetLogistics ContractFuel Form 9. Excerpts ofJet Logistics General Operations Manual (page 3, 4and 5) 10.Flight Aware Print out for JetLogistics flight to Hawaii onJune 28, 2012 and July 3, 2012 11.JetLogistics email and other correspondence requesting amendment ofB050 12.JetLogistics Operations Manual withoutpertinent excerpts ofthe Carriers Operations Specifications. 13.Record ofTelephone Call ofJuly 25, 2012 14.Jet Logistics TrainingProgram Record 15.Robin Dill's Training Record 16.Luis Rios TrainingRecord 17.Letter of Surveillance datedJuly 26, 2012 18.Letter oflnvestigation dated August 2, 2012 Respectfully submitted,

Alfred R. Johnson, Jr. Regional Counsel ) /:J / B

# :~·""-;~,<~:((~Gv~**~**.../1?seL. Nieves (/Attorney Federal Aviation Administration 1Aviation Plaza Jamaica, NY 11434 Telephone: 718 553-3278 Facsimile: (718) 995-5699 Date:

3CERTIFICATE OF SERVICE I hereby certify that on this day copies of the foregoing Complainant's Witness List and Exhibit List were placed in the United States mail, postage prepaid, Certified Mail

- Return Receipt Requested addressed as follows: The Honorable J.E. Sullivan Administrative LawJudge Office ofHearings, M-20 RoomEll-310 U.S. Department ofTransportation 1200 New Jersey Avenue, S.E. Washington, D.C. 20590 FederalAviation Administration 800 Independence Avenue, S.W. Attn: Hearing Docket Clerk, AGC-430 WilburWrightBuilding- Room 2014 Washington, D.C. 20591 JetLogistics Inc. W. Ashley Smith, Jr. President 5400 Airport Drive Charlotte, NC 28208
/)



### s aralega Specialist Office ofRegional Counsel 1Aviation Plaza Jamaica, NY 11434

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