10/09/2012 11:54 4252271007 ANM7 PAGE 02/07 

JEFFREY HARPER 

FAA OFFICE OF REGIONAL COUNSEL 

1601 LIND AVENUE SOUTHWEST 

RENTON, WASHINGTON 98057 

TELEPHONE: (425) 227-2161 

FACSIMILE: (425) 227-1007 

~~]!1 iY'T • r· r) ry. 01 £, '· \)i, t ,J j·- t.. ,::. () 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF' HEARINGS 

WASHINGTON, D.C. 

In the Matters· of: 

Leading Edge Aviation, Inc. 

To: Leading Edge Aviation~ Inc. 

FAA Case No. 2011NM070089 

DMS No. FAA·2012-0783 

Honorable Richard C. Goodwi.n 

Complainant's Responses to 

Respondent's Requests to Admit 

Pursuant to 14 C.P.R.§ 13.220, and consistent with Fed.R.Civ.Pro. 26, and 36~ Complainant 

responds to Respondent's Requests to Admit served September 7, 2012. Complainant is 

aware of and understands the contin:uh1.g !lature of its discovery obligation! and reserves the 

right to supplement this response a.s necessary. Where an objection is noted, but a substantive 

response is provided, the substantive l'esponse is provided without waiving the objection. 

Reques~ to Admit No. 1: Leading Edge corrected the typographical error on its Capability List 

of '

1

Bell 206 AJB series'1 to "Be11206 series". 

Answer: Objection, argwnentative, to the exten:t the requested admission assumes the 

CapabilitY List had a typographical error. Deny with respect to the characterization of 

the Capability List as having l~d a typographical error. Admit that Leading Edge's 

Capability List currently lists ~·Bell 206 series" aircraft. 

Request to Admit No. 2: Leading Edge corrected the typogri3:phical error on its Capability List 

stated in request to admit # 1 at the direction of and to the satisfaction ofF AA PMI Curt 

Cowley. 

Answer: Objection, argumentative, to the extent the request admission assum.es the 

Capability List had a typographical error. Objection, compound question. Deny with 

respect to the characterization of the Capability List as having had a typographical 
10/09/2012 11:54 4252271007 ANM7 PAGE 03/07 

error. Admit that Leading Edge's Capa.bili.ty List citrrently lists ''Bell 206 series" 

aircraft. Deny that the addition. of "Bell 206 series" aircraft was at the direction of 

FAA PMI Curt Cowley; the addition of a capability to tbe capabilities list is the 

responsibility of Leading Edge. See Produced Documents Bates No. 000133--000134. 

Request to Admit No.3: No additional housing~ facilities, equipment, materials, data, 

knowledge, or experience are needed for the Bell 206 series versus the Bell 206 AfB se:des. 

Answer: Deny. By way of example, and not limitation, the da.ta are different as the 

Bell 206 AlB series uses a different maintenance m.anual than the 206L series. By 

way of example, an.d not Hmitation, the materials are different~ as part numbers vary 

between the two series. 

Request to Admit No. 4: The logbook entries for the Aircraft dated July 7, 2011 were not 

made by Leading Edge·. 

Answer: Admit. 

Request to Admit No. 5: The logbook entries for the Aircraft dated July 7~ 2011 were m.ade 

by a service provider who is a competitor to Leading Edge. 

Answer: Objection, argumentative~ to the extent the requested admission assumes the 

service provider is a competitor to Leading Edge. Deny, Complainant is without 

sufficient infonnation or knowledge of Leading Edge's business or the business of the 

service provider making the July 7l 2011 logbook e11trl.es to detenni.ne whether the 

service provider is or is n.ot a competitor to Leading Edge. · · 

Request to Admit No. 6: The FAA. did n.ot independently c:onfinn the accuracy of the 

purported discrepancies noted in the Aircraft's logbook dated. July 7, 2011. 

Answer: Deny. 

Request to Admit No. 7: Tile FAA l.s seeking violations and penalties against Leading Edge 

premised upon a competing service provider's Jog book entries for the Aircraft dated July 7) 

2011. 

Answer: Objection, argumentative to the extent the requested admi~sion assumes the 

service provider is a competitor to Leading Edge. Denyl Com:plai.nant is without · 

sufficient information or knowledge of Leading Edge's business or the business of the 

service provider making the July 7, 20lllog book entries to detennine whether the · 

service provider is or is not a competitor. Admit that the violations are based, in part, 

on log book entries for the Air~raft dated July 7, 2011. 

Request to Admit No. 8: Bell Helicopter's guidelines did not require a hidden damage 

inspection of the Aircraft at the time Leading Edge performed its 100 hour inspection on or 

about February 17. 20 11. 

Complainant's Responses to Respondent's Requests to Admit 

Leading: Edge Aviation, Jnc. 

DMS Nos. FN\.·2012·0783 

Page2 of5 

JEFFREY M. HARPER, FAA A:r.roR~'i' 

TEL: 425.227.1417~ FAX: 425.227.1007 
10/09/2012 11:54 4252271007 ANM7 

Answer: Admit. 

Request to Admit No. 9: An air conditioning leak is not required to be repaired in connection 

with a 100 hour inspection by manufacturer Bell Hell. copter. 

Answer: Deny. 

Request to Admit No. 10: The Aircraft's air conditioning leak reflected on Leading's [sic] 

Edges 100 hour inspection completed on February 17, 2011 had no bearing on the 

airworthiness of the Aircraft. 

Answer: Deny. 

Request to Admit No. 11: The purported "discrepancy" in paragraph 16(a) of the FAA 

Complaint is incottect because the ~ircraft•s latch engaged appropriately during Leading 

Edge's 100 hour inspection completed on February 17. 2011. 

Answer: Deny. 

Request to Admit No. 12: Leading Edge did not perform. the work referenced in paragraph 

16(b) of the FAA's Complaint and Leading Edge had no obligation to inspect this part of the 

Aircraft during its 100 hour inspection completed on. Febroary 17, 2011. 

PAGE 04/07 

Answer: Deny Leading Edge had no obligation to inspect the part referenced in 

paragraph 16(b) of the Amended Complaint. Admit that Leading Edge did not in.spect 

the part referenced in paragraph 16(b) of the Amended Compl ain.t. 

Request to 'Admit No. 13: The purported ~'discrepancy" in paragraph 16(e) of the FAA's 

Complaint was not present when Leading Edge completed its 100 hour inspection of the 

Aircraft on or about February J 7, 2011. 

Answer: Deny. 

Request to Admit No .. 14: The purported '~discrepancy" in paragraph 16(f) ofthe FAA's 

Complaint did not exist on or about February 17, 201 L The screws are not too long or 

bottoming on nut plates. 

Answer: Deny the discrepancy did not exist on or about February 17, 2011. Deny the 

screws are not too long or bottoming on nut plates. 

Request to Admit No. 15: The purported '~discrepancy" in paragraph 16(g) of the FAA's 

Complaint did not exist when Leading Edge completed its 100 hour inspection. ofthe Aircraft 

on or about February 17,2011. 

Answer; Deny. 

Request to Admit No. 16: "Working" rivets are not required to be corrected per Bell 

Helicopter's inspection checklist. 

CornplainBilt's Responses to Respondent's Requests to Admi.t 

J .. e:adln.g Edge Aviation, Inc. 

DMS Nos. FAA·2012·0783 

Page 3 of6 

JEFFR.F.Y M. BARPr~. FMArrORNEY 

TEL: 425.227.1417; FAX: 425.227.1007 
10/09/2012 11:54 4252271007 ANM7 PAGE 05/07 

Answer: Deny. 

Request to Admit No. 17: The purported "discrepancy', in paragraph 16(h) of the F AA1s 

Complaint did not exist when. Leading Edge completed its 100 hour inspection of the Aircraft 

on February 17,2011. 

Answer: Deny. 

Request to Admit No. 18: If the fin damage to the Aircraft alleged in paragraph 16(h) of the 

FAA's Complaint was caused during an accident that occurred in t~e year 2000 as speculated 

by the FAA, the fm damage to the Aircraft was visjble t9 the F M during its confonni.ty 

inspection. 

Answer: Admit, with the caveat that conformity j.nspecti.on.s are the responsibility of 

the operator, not the FAA, and do not have the same scope as a 1 00 hour inspection. 

See FAA Order 8900.1, Volume 4, Chapter 16, ~ 4-1671.C. 

Request to Admit No. 19: Leading Edge did n.ot rem.ove or install the fin referenced in 

paragraph 16(h) ofthe FAA's Complaint. 

Answer: Complainant is without sufficient information or knowledge to determine if 

Leading Edge did not remove or install the fin. reference in paragraph 16(h) of the 

Amended Compliant. Admit tl1.at the logbook for the Aircraft does not indicate the fin 

was removed or installed. 

Request to Admit No. 20: The fin is not required to be inspected during the 100 hour 

inspection per the Bell Helicopter checklist. 

Answer: Deny. 

Request to Admit No. 21: The purported discrepancy in paragraph 16(i) ofthe FAA's 

Complaint does not exist. The Aircraftls hardware installation is correct per the instructions 

for. the STC to allow proper clearance of the compressor drive pulley. 

Answer: Complainant is without sufficient information or knowledge to determine 

the current status of.tb.e discrepan.cy described in paragraph 16(i) of the Amended 

Complaint as the aircraft is not in Complainant's possession, and therefore deny. 

Deny the discrepancy described in paragraph 16(i) of the Amended Complaint did .not 

exist at the time Leading Edge completed its 100 hour inspection of the Aircraft on 

February 17, 2011. Complainant is without sufficient information or knowledge to 

determine the current status of the hardware installation, and therefore deny. Deny 

that the hardware installation was correct at the time Leading Edge completed its 

100 hour inspection of the Aircraft on February 17, 2011. 

Complainant's Responses to Respondent's Requests to Admit 

Leading Edge Aviation, Inc. 

DMS Nos. FAA-2012-0783 

Page 4 of6 

JEFFREYM. H.Aru>ER, FAAAitOT{NlaY 

TEL; 425.227.1417: FAX: 425.227.1007 
il' 10/09/2012 11:54 4252271007 ANM7 

Request to Admit No. 22: The purported discrepancy in paragraph 16(j) of the FAA's 

Complaint does not exist. Th.e Aircraft's system is operational and was checked during the 

post 100 hou:r nm up. 

Answer: Complainant i.s without sufficient information or knowledge to determin.e 

the current status of the discrepancy d.escribed in paragraph 16G) of the Amended 

Complaint as the aircraft is not in Complainant's possession, and therefore deny. 

Deny the discrepancy described in paragraph 16G) of the Amended Complaint did not 

exist a.t the time Leadin.g Edge completed its 100 hour inspection of the Aircraft on 

February 17, 2011. 

Respectfull.y submitted this 9th day of October, 20 1.2. 

-t~~ FAA Attorney 

JMH/ds 

Complainant's Responses to Respondent's Requests to Admit 

Leading Edge Aviati(ln, lno. 

DMS Nos. FAA-2012·0783 

PageS of6 

JEFl!RliY M. HA:RPER, FAA ATT.OMEY 

TEL: 425.227.1417; FAX: 425.227.1007 

PAGE 05/07 
~ 10/09/2012 11:54 4252271007 ANM7 PAGE 07/07 

CERTIFICATE OF SERVICE 

I hereby certify that the foregoing Complainant's Responses to Respondent's Requests to 

Admit has been served via facsimile and Certified Mail- Return Receipt Requested this date, 

to the following: 

The Hon.ora.ble Richard. C. Goodwin 

Office of Hearings, M-20 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor, Rm. El2~320 

Washington, D.C. 20590 

TEL: (202) 366-2139 

FAX: (202) 366"7536 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building - Suite 2WI 000 

Federal Aviation Administration. 

800 Independence Ave. SW. 

Washington, DC 20591 

FAX: (202) 493MS142 

Fred C. Begy~ Esq. 

Chuhak. & Tecson 

30 South Wacker Drive, Suite 2600 

Chicago, JL · 60606 

Tel: (312) 855-5442 

Fax: (312) 444·9027 

DATED this 9th day of October, 2012. 

Te i irk 

0 1 e of Regional Co nsel (ANM-7) 

Federal Aviation Administration 

1601 LindAve. SW 

Renton, WA 98057 

(425) 227-21.60 

Complainant's .Responsl!ls to Rcspon.<lont's Reque~ts to Admit 

T~eading Edge Aviation, Inc. J.~~y M.l'::l.AR.PER, fAAAITORNEY 

TEL: 425.227.1417; PAX: 425 . .2Z7.1007 DMS Nos. FAAft2012-0783 

Page 6 of6