U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of Jet Logistics, Inc. 

F AA-2013-0290 

The Honorable J.E. Sullivan 

COMPLAINANT'S INITIAL DISCOVERY 

RECEIVED 

NOV 1 2 2013 

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 Administrative Law and the Respondent with its witness list. 

In addition to the witnesses listed by the Respondent, the Complainant may present 

at the hearing in this 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 

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4. Andy Albert Smith, Check Ainnan, Jet Logistics, 2913 Ravenwood Drive, Kinston, 

NC 28504-9137, (252) 521-5575 

5. Robin Scott Dill, 11271 Mac Nab 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 of Proposed Civil Penalty was issued. 

The following exhibits are specifically referenced: 

EXHIBITS 

1. Jet Logistics Air Carrier Certificate 

2. Excerpts of Jet Logistics Operations Specifications 

3. Records for Jet Logistics 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 Manifest Form 

8. Jet Logistics Contract Fuel Form 

9. Excerpts of Jet Logistics General Operations Manual (page 3, 4and 5) 

10.Flight Aware Print out for Jet Logistics flight to Hawaii on June 28, 2012 

and July 3, 2012 

11.Jet Logistics email and other correspondence requesting amendment ofB050 

12.Jet Logistics Operations Manual without pertinent excerpts of the Carriers 

Operations Specifications. 

13.Record of Telephone Call of July 25, 2012 

14.Jet Logistics Training Program Record 

15.Robin Dill's Training Record 

16.Luis Rios Training Record 

17.Letter of Surveillance dated July 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 

1 Aviation Plaza 

Jamaica, NY 11434 

Telephone: 718 553-3278 

Facsimile: (718) 995-5699 

Date: 

3 
CERTIFICATE 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 Law Judge 

Office of Hearings, M-20 

Room Ell-310 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Room 2014 

Washington, D.C. 20591 

Jet Logistics Inc. 

W. Ashley Smith, Jr. 

President 

5400 Airport Drive 

Charlotte, NC 28208 

/) 

s 

aralega Specialist 

Office of Regional Counsel 

1 Aviation Plaza 

Jamaica, NY 11434 

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