Part 2, Singapore Airlines vs. Gladiator, case comes to abrupt end
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Part 2, Singapore Airlines vs. Gladiator, case comes to abrupt end
Part 1 showed the courts order after:
a)SIA served the defendant with a Summons .
b)The defendant presented answer and affirmative defences to complaint and counterclaim.
c)The plaintiff presented answer and affirmative defences to defendant's counterclaims.
(a,b,and c above in Part 3)
Part 2 is going to be the discovery material SIA was smart enough not to provide. Part 2 is going to be like a movie where the beginning starts with the end. SIA right from the beginning of the case had dodged and denied all the defendant's claims and counterclaims. It was only in the discovery phase of the case when SIA had no choice but to present documentation and answer to interrogatory questions.
Furthermore a meeting was held between the defendant, Ken T. representing CAAS and SIA and the FAA in Singapore in February 2000. The meeting was informal and not connected to the case directly. The topic of discission was FAA regulations and operation of SIA within US airspace while not in accordance with ICAO International minimum safety standards. The FAA representative was surprised by the material presented.
A double edge sword would best describe why the case came to an abrupt end. SIA finally came to the conclusion that if they were to continue with the case, by now in the discovery phase, they would no longer be able to deny every claim.
Discovery meant surrendering every document requested, answering every question in detail followed by deposition from Maurice DeV.
SIA's tactic was to break the defendant by high legal bills hoping to gain the upper hand. One thing SIA was not aware of, and probably SIA lawyers in Singapore have never heard of is the word 'PROBONO' (look it up folks).
SIA instead shafted itself by high legal bills.
Next the discovery material
a)SIA served the defendant with a Summons .
b)The defendant presented answer and affirmative defences to complaint and counterclaim.
c)The plaintiff presented answer and affirmative defences to defendant's counterclaims.
(a,b,and c above in Part 3)
Part 2 is going to be the discovery material SIA was smart enough not to provide. Part 2 is going to be like a movie where the beginning starts with the end. SIA right from the beginning of the case had dodged and denied all the defendant's claims and counterclaims. It was only in the discovery phase of the case when SIA had no choice but to present documentation and answer to interrogatory questions.
Furthermore a meeting was held between the defendant, Ken T. representing CAAS and SIA and the FAA in Singapore in February 2000. The meeting was informal and not connected to the case directly. The topic of discission was FAA regulations and operation of SIA within US airspace while not in accordance with ICAO International minimum safety standards. The FAA representative was surprised by the material presented.
A double edge sword would best describe why the case came to an abrupt end. SIA finally came to the conclusion that if they were to continue with the case, by now in the discovery phase, they would no longer be able to deny every claim.
Discovery meant surrendering every document requested, answering every question in detail followed by deposition from Maurice DeV.
SIA's tactic was to break the defendant by high legal bills hoping to gain the upper hand. One thing SIA was not aware of, and probably SIA lawyers in Singapore have never heard of is the word 'PROBONO' (look it up folks).
SIA instead shafted itself by high legal bills.
Next the discovery material
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Defendant's first set of discovery requests to plaintiff.
Interrogatory No. 1: Identify each person who participated in preparing SIA's answers to these interrogatories and equests for production, state his or her relationship to SIA, and state which answer(s) each prson participated is preparing.
Interrogatory No. 2: Identify each person known by SIA or its attorneys or representatives to possess information regarding the allegations or subject matter of SIA's complaint; Defendants Answer and Affirmative Defences to Plaintiff's Complaint, and Counterclaims ("Answer and Cou nterclaim"); ans/or SIA's Answer and Affirmative Defences to Counterclaim ("Answer to Counterclaim").
Interrogatory No. 3: Provide organizational charts or narrative statements which show SIA's corporate structure and its organization into divisions or other operating units as of January 1, 1991, together with charts or statements describing each organizational change between that date and the present date. for each division or other operating unit, identify its location and the person or persons with primary responsibility for management and supervision of the unit.
Interrogatory No. 4: Identify all employees of SIA with managerial or supervisory responsibility for the safety of flight operations during the period of 1991 to the present date. For each employee, state his position at SIA and precise role in each activity.
Interrogatory No. 5: Identify each person who was involved in or responsible for, on behalf of SIA, any negotiations, meetings, representations or communications with XXX relatind to his entry into training contracts with SIA. For each person, describe his or her precise role in such activity.
Interrogatory No. 6: Identify all oral and written communications and information furnished by SIA to XXX relating to his entry into training contracts with SIA.
Interrogatory No. 7: Identify all oral and written communications and information furnished by XXX to SIA relating to his entry into training contracts with SIA.
Interrogatory No. 8: State whether SIA granted credit to XXX for his employment as an airline pilot and commercial flying experience prior to 1991. If so, describe the credit provided, and identify all documents which discuss, relate or refer to the credit.
More to follow.
Interrogatory No. 1: Identify each person who participated in preparing SIA's answers to these interrogatories and equests for production, state his or her relationship to SIA, and state which answer(s) each prson participated is preparing.
Interrogatory No. 2: Identify each person known by SIA or its attorneys or representatives to possess information regarding the allegations or subject matter of SIA's complaint; Defendants Answer and Affirmative Defences to Plaintiff's Complaint, and Counterclaims ("Answer and Cou nterclaim"); ans/or SIA's Answer and Affirmative Defences to Counterclaim ("Answer to Counterclaim").
Interrogatory No. 3: Provide organizational charts or narrative statements which show SIA's corporate structure and its organization into divisions or other operating units as of January 1, 1991, together with charts or statements describing each organizational change between that date and the present date. for each division or other operating unit, identify its location and the person or persons with primary responsibility for management and supervision of the unit.
Interrogatory No. 4: Identify all employees of SIA with managerial or supervisory responsibility for the safety of flight operations during the period of 1991 to the present date. For each employee, state his position at SIA and precise role in each activity.
Interrogatory No. 5: Identify each person who was involved in or responsible for, on behalf of SIA, any negotiations, meetings, representations or communications with XXX relatind to his entry into training contracts with SIA. For each person, describe his or her precise role in such activity.
Interrogatory No. 6: Identify all oral and written communications and information furnished by SIA to XXX relating to his entry into training contracts with SIA.
Interrogatory No. 7: Identify all oral and written communications and information furnished by XXX to SIA relating to his entry into training contracts with SIA.
Interrogatory No. 8: State whether SIA granted credit to XXX for his employment as an airline pilot and commercial flying experience prior to 1991. If so, describe the credit provided, and identify all documents which discuss, relate or refer to the credit.
More to follow.
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Gee, all impressive stuff, Gladys.
But sooooo expensive, lah.
Why not save all the b.s., and admit that you never intended honoring your word from the outset. Declare mental instability, it would be easy to substantiate, just from the posts on PPRuNe, alone.
But sooooo expensive, lah.
Why not save all the b.s., and admit that you never intended honoring your word from the outset. Declare mental instability, it would be easy to substantiate, just from the posts on PPRuNe, alone.
Gladiator, I and others in the Fragrant harbour do find your story of great interest. Our company having started out as a small but ambitious airline has now grown into a headless turkey with management that continually lie, break contracts and misrepresent the true state of the company to the owners. It is encouraging to see that when finally forced to defend their position in court they quit.
KM, Slasher and Co. When I read your posts on other topics I usually agree with you but your blinkers when someone sticks up for himself does you no credit. You don't have to like someone to admit they have a case. If SIA grabbed the bull by the horns and dealt with their problems now instead of papering them over we would not be awaiting the SILKAIR verdict and discussing their actions.
KM, Slasher and Co. When I read your posts on other topics I usually agree with you but your blinkers when someone sticks up for himself does you no credit. You don't have to like someone to admit they have a case. If SIA grabbed the bull by the horns and dealt with their problems now instead of papering them over we would not be awaiting the SILKAIR verdict and discussing their actions.
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Interrogatory no. 9: State whether XXX at SIA was ever granted credit for "sectors" from commercial flying towards the total number of sectors requires at SIA to qualify for the rank of Captain. If so, describe the credit, and identify all documents which discuss, relate or refer to the credit.
Interrogatory No. 10: Describe in detail what is meant by the term "commuter airline pilot" (as opposed to "airline pilot")as stated in paragraph 4 of SIA's answer to Counterclaim.
Interrogatory No. 11: Describe the total flying hours and experience of an average cadet pilot employed by SIA from Singapore, Malaysia, or India (excluding any former member of armed forces).
Interrogatory No. 12: Describe the total flying hours and experience of all Singaporean, Malaysian, and Indian cadet pilots who trained with XXX on course 747, Type Conversion, No.48, commencing on July 18, 1991, and ending September 5, 1991.
Interrogatory No. 13: Identify all cadet pilots who trained on course 747, Type Conversion, No. 49, and describe their total flying hours and experience, rank and operating capacity as of January 1, 2000.
Interrogatory No. 14: Describe in detail what is meant by "to be rated" in the following excerpt from paragraph 5 of SIA's Answer to Counterclaims: "trained by SIA to a standard that would enable him to be rated on a particular aircraft type".
Interrogatory No. 15: State whether SIA or its SUBSIDIARY has ever recruited pilota at any level other than the levels of Captain and cadet pilot (including, without limitation, direct entry first officers). If so, identify all other levels of pilots rrecruited by SIA.
Interrogatory No. 16: State whether pilots recruited as Captain or any other capacity (including, direct entry first officers, but excluding cadet pilot) have ever been required to provide a surety, bank guarantee, bank bond, cash deposit, or other forms of monetary guarantee to SIA.
Interrogatory No. 17: Describe in detail the differences between SIA's type conversion training on B-747 and B747-400 aircraft (including aircraft systems training in a classroom or computer base training, safety equipment procedure training, cockpit procedure training and full flight simulator training) applicable to each of the following (a) a pilot that has previously flown a B-747 and /or B747-400, and (b) a pilot that has been employed by SIA for the purpose of placement on the B-747 and /or B747-400, but has never flown a B747 and /or B747-400.
Interrogatory No. 18: Decsribe in detail the difference between a "Restricted type rating" and a "Non-restricted type rating" with respect to service on SIA's B-747 and /or B747-400 aircraft.
Interrogatory No. 19: Describe in detail the difference between a type rating issued to a Commander (Captain), and a type rating issued to a CPL holder as a co-pilot of the B747 and /or B747-400 aircraft.
INterrogatory No. 20: Describe any and all differences between the training with respect to type rating provided by SIA to a Captain, and the training provided to a co-pilot holding a CPL, including, without limitation, training in the cockpit left-hand seat position, instrument approaches, maneuvers, and the ability to conduct AUTOLANDS on B-747 and /or B747-400.
Interrogatory No. 21: Describe in detail the requirements to qualify as a Captain on SIA's B-747 and /or B747-400 aircraft, including, without limitation, the required license, medical examination, years of experience, total flight hours, total flight hours with SIA, number of take-offs and landings, number of total sectors, number of total sectors as pilot flying, and whether any of the above criteria are limited to aircraft of above a certain weight.
Interrogatory No. 22: Describe in detail the requirements to qualify as a First Officer on SIA's B-747 and/or B747-400 aircraft, including, without limitaion, the required license, medical examinations, years of experience, total flight hours, total flight hours with SIA, number of take-offs and landings, number of total sectors, number of total sectors as pilot flying, and whether any of the above criteria are limited to aircraft of above a certain weight.
Iterrogatory No. 23: Describe in deatil the following "holder's operating capacity" designations issued and used at SIA: "P.1 Pilot in Charge", "P.1 u/s Pilot in Charge under supervision", "P.2 Second pilot exercising the privileges of this license as a required member of the operating crew", "P.3 Pupil pilot; and pilot under training" as in the "Personal Flying Log Book (Aircraft Operating Crew).
Interrogatory No. 24: State the dates when XXX, while a co-pilot with CPL on SIA's B-747 and B747-400 aircraft, acted in the operating capacity of (a) P.1; (b) P.1 u/s; (c) P.2, and/or P.3. For each date, identify the specific capacity in which XXX operated.
More to follow.
Interrogatory No. 10: Describe in detail what is meant by the term "commuter airline pilot" (as opposed to "airline pilot")as stated in paragraph 4 of SIA's answer to Counterclaim.
Interrogatory No. 11: Describe the total flying hours and experience of an average cadet pilot employed by SIA from Singapore, Malaysia, or India (excluding any former member of armed forces).
Interrogatory No. 12: Describe the total flying hours and experience of all Singaporean, Malaysian, and Indian cadet pilots who trained with XXX on course 747, Type Conversion, No.48, commencing on July 18, 1991, and ending September 5, 1991.
Interrogatory No. 13: Identify all cadet pilots who trained on course 747, Type Conversion, No. 49, and describe their total flying hours and experience, rank and operating capacity as of January 1, 2000.
Interrogatory No. 14: Describe in detail what is meant by "to be rated" in the following excerpt from paragraph 5 of SIA's Answer to Counterclaims: "trained by SIA to a standard that would enable him to be rated on a particular aircraft type".
Interrogatory No. 15: State whether SIA or its SUBSIDIARY has ever recruited pilota at any level other than the levels of Captain and cadet pilot (including, without limitation, direct entry first officers). If so, identify all other levels of pilots rrecruited by SIA.
Interrogatory No. 16: State whether pilots recruited as Captain or any other capacity (including, direct entry first officers, but excluding cadet pilot) have ever been required to provide a surety, bank guarantee, bank bond, cash deposit, or other forms of monetary guarantee to SIA.
Interrogatory No. 17: Describe in detail the differences between SIA's type conversion training on B-747 and B747-400 aircraft (including aircraft systems training in a classroom or computer base training, safety equipment procedure training, cockpit procedure training and full flight simulator training) applicable to each of the following (a) a pilot that has previously flown a B-747 and /or B747-400, and (b) a pilot that has been employed by SIA for the purpose of placement on the B-747 and /or B747-400, but has never flown a B747 and /or B747-400.
Interrogatory No. 18: Decsribe in detail the difference between a "Restricted type rating" and a "Non-restricted type rating" with respect to service on SIA's B-747 and /or B747-400 aircraft.
Interrogatory No. 19: Describe in detail the difference between a type rating issued to a Commander (Captain), and a type rating issued to a CPL holder as a co-pilot of the B747 and /or B747-400 aircraft.
INterrogatory No. 20: Describe any and all differences between the training with respect to type rating provided by SIA to a Captain, and the training provided to a co-pilot holding a CPL, including, without limitation, training in the cockpit left-hand seat position, instrument approaches, maneuvers, and the ability to conduct AUTOLANDS on B-747 and /or B747-400.
Interrogatory No. 21: Describe in detail the requirements to qualify as a Captain on SIA's B-747 and /or B747-400 aircraft, including, without limitation, the required license, medical examination, years of experience, total flight hours, total flight hours with SIA, number of take-offs and landings, number of total sectors, number of total sectors as pilot flying, and whether any of the above criteria are limited to aircraft of above a certain weight.
Interrogatory No. 22: Describe in detail the requirements to qualify as a First Officer on SIA's B-747 and/or B747-400 aircraft, including, without limitaion, the required license, medical examinations, years of experience, total flight hours, total flight hours with SIA, number of take-offs and landings, number of total sectors, number of total sectors as pilot flying, and whether any of the above criteria are limited to aircraft of above a certain weight.
Iterrogatory No. 23: Describe in deatil the following "holder's operating capacity" designations issued and used at SIA: "P.1 Pilot in Charge", "P.1 u/s Pilot in Charge under supervision", "P.2 Second pilot exercising the privileges of this license as a required member of the operating crew", "P.3 Pupil pilot; and pilot under training" as in the "Personal Flying Log Book (Aircraft Operating Crew).
Interrogatory No. 24: State the dates when XXX, while a co-pilot with CPL on SIA's B-747 and B747-400 aircraft, acted in the operating capacity of (a) P.1; (b) P.1 u/s; (c) P.2, and/or P.3. For each date, identify the specific capacity in which XXX operated.
More to follow.
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Interrogatory No. 25: Under SIA operating procedures with respect to 3-pilot crew operations on the B747-400 aircraft, during the time which the Captain takes in-flight relief as per SIA's Flight Administration Manual ("FAM"), page 3.39.1, 15 March 1998, describe in detail the operating capacity (P.1, P.1u/s, or P.2) of the co-pilot with CPL in the right-hand seat if the flight is initiated with him as "pilot flying".
Interrogatory No. 26: With respect to the same 3-pilot crew operations on B747-400 aircraft referenced in Interrogatory No. 25 above, describe in detail the operating capacity (P.1. P.1u/s, or P.2) of the third pilot (another co-pilot with CPL) in the left-hand seat.
Interrogatory no. 27: Under SIA's operating procedures for 3-pilot crew operations on B747-400 aircraft, during the time which the Captain takes inflight relief as per SIA's FAM page 3.39.1, 15 march 1998, describe in detail the operating capacity (P.1, P.1u/s, P.2) of the co-pilot with CPL in the right hand seat if the flight initiated with him as "pilot not flying".
Interrogatory No. 28: Under SIA's operating procedures for 3-pilot crew operations on the B747-400, while the Captain is taking inflight relief and two co-pilots with CPL are at the pilot duty stations as per SIA's FAM, page 3.39.1, March 1998, identify the pilot seat in which the Captain continues to perform his duty in the event the co-pilot in the right-hand seat becomes incapacitated.
Interrogatory No. 20: During the 3-pilot crew operations on the B747-400, while the Captain is taking in-flight relief and two co-pilots with CPL are at the pilot duty stations (as per SIA's FAM, page 3.39.1, 15 March 1998), state whether the co-pilot in the right-hand seat is permitted to leave his duty station for physiological needs under (a)SIA's policies and operating procedures and/or (b)CAAS regulations.
Interrogatory No. 30: Describe in detail the differences between a "2-pilot crew", "3-pilot crew", "augmented crew" and "double crew" with respect to SIA's B747-400 operations.
Interrogatory No. 31: Describe in detail the purpose of utilizing a crew that consists of two captains and one co-pilot, instead of one Captain and two co-pilots , on the B747-400 aircraft.
Interrogatory no. 32: Describe in detail the meaning of the phrase "taking in-flight relief" (as stated in the FAM, page 3.39.1, 15 march 1998), with respect to a 3-pilot crew operation on a B747-400. In your answer to this interrogatory, describe the limitations, if any, imposed upon the Captain during inflight relief, including, without limitation, absence from the cockpit while taking relief or rest in the crew bunkroom.
Interrogatory No. 33: During 3-pilot crew operations on the B747-400 aircraft (pursuant to the FAM, page 3.39.1, 15 March 1998), while the Captain is taking inflight relief, identify which of the two co-pilots behind the aircraft controls is in charge of the aircraft.
Interrogatory No. 34: Describe in detail the meaning, according to SIA's policies and operating procedures, of the term "designated first officer" with respect to 3-pilot crew operations on the B747-400 (as stated in the FAM, page 3.39.1, 15 march 1998).
Interrogatory No. 35: Describe in detail the meaning, according to SIA's policies and operating practices, of the phrase "in the event of an emergency" with respect to 3-pilot crew operations on the B747-400 (as stated in the FAM, page 3.39.1, 15 March 1998).
Interrogatory No. 36: State whether, according to SIA's policies and operating practices, the co-pilot in the left -hand seat during 3-pilot crew operations on B747-400 (as stated in the FAM, page 3.39.1, 15 March 1998) is trained to conduct emergency procedures from the left-hand seat.
Interrogatory No. 37: Describe in detail the meaning, according to SIA's policies and operating practices for B747-400 aircraft, of the phrase "the required operating crew memebers of the minimum crew complement shall be in their assigned seats" (as stated in SIA's FAM, page 3.39.1, 15 March 1998).
Interrogatory No. 38: Describe in detail the meaning, according to SIA's policies and operating practices for B747-400 aircraft, of the phrase "a crew memeber's absence is necessary for the performance of duties in connection with the operation of the flight" (as stated in the FAM, page 3.39.1, 15 march 1998).
Interrogatory No. 39: Describe in detail the meaning, according to SIA's policies and operating practices, of the phrase "a crew memeber's absence is in connection with physiological needs" (as stated in the SIA's FAM, page 3.39.1, 15 march 1998) with respect to the B747-400.
Interrogatory No. 40: State whether the Captain's absence from hid duty station during inflight relief on B747-400 aircraft is in compliance with the requirement, that acrew member's absence is (a) necessary for the performance of duties in connection with the operation of the flight; or (b) in connection with physiological needs (as stated in the FAM, page 3.39.1, 15 march 1998).
Interrogatory No. 41: State whether it violates SIA's policies or operating procedures and /or CAAS regulations if, during 3-pilot crew operations (one Captain, two co-pilots) on B747-400 aircraft, the Captain takes inflight relief in the passenger cabin or the bunkroom.
More to follow.
Interrogatory No. 26: With respect to the same 3-pilot crew operations on B747-400 aircraft referenced in Interrogatory No. 25 above, describe in detail the operating capacity (P.1. P.1u/s, or P.2) of the third pilot (another co-pilot with CPL) in the left-hand seat.
Interrogatory no. 27: Under SIA's operating procedures for 3-pilot crew operations on B747-400 aircraft, during the time which the Captain takes inflight relief as per SIA's FAM page 3.39.1, 15 march 1998, describe in detail the operating capacity (P.1, P.1u/s, P.2) of the co-pilot with CPL in the right hand seat if the flight initiated with him as "pilot not flying".
Interrogatory No. 28: Under SIA's operating procedures for 3-pilot crew operations on the B747-400, while the Captain is taking inflight relief and two co-pilots with CPL are at the pilot duty stations as per SIA's FAM, page 3.39.1, March 1998, identify the pilot seat in which the Captain continues to perform his duty in the event the co-pilot in the right-hand seat becomes incapacitated.
Interrogatory No. 20: During the 3-pilot crew operations on the B747-400, while the Captain is taking in-flight relief and two co-pilots with CPL are at the pilot duty stations (as per SIA's FAM, page 3.39.1, 15 March 1998), state whether the co-pilot in the right-hand seat is permitted to leave his duty station for physiological needs under (a)SIA's policies and operating procedures and/or (b)CAAS regulations.
Interrogatory No. 30: Describe in detail the differences between a "2-pilot crew", "3-pilot crew", "augmented crew" and "double crew" with respect to SIA's B747-400 operations.
Interrogatory No. 31: Describe in detail the purpose of utilizing a crew that consists of two captains and one co-pilot, instead of one Captain and two co-pilots , on the B747-400 aircraft.
Interrogatory no. 32: Describe in detail the meaning of the phrase "taking in-flight relief" (as stated in the FAM, page 3.39.1, 15 march 1998), with respect to a 3-pilot crew operation on a B747-400. In your answer to this interrogatory, describe the limitations, if any, imposed upon the Captain during inflight relief, including, without limitation, absence from the cockpit while taking relief or rest in the crew bunkroom.
Interrogatory No. 33: During 3-pilot crew operations on the B747-400 aircraft (pursuant to the FAM, page 3.39.1, 15 March 1998), while the Captain is taking inflight relief, identify which of the two co-pilots behind the aircraft controls is in charge of the aircraft.
Interrogatory No. 34: Describe in detail the meaning, according to SIA's policies and operating procedures, of the term "designated first officer" with respect to 3-pilot crew operations on the B747-400 (as stated in the FAM, page 3.39.1, 15 march 1998).
Interrogatory No. 35: Describe in detail the meaning, according to SIA's policies and operating practices, of the phrase "in the event of an emergency" with respect to 3-pilot crew operations on the B747-400 (as stated in the FAM, page 3.39.1, 15 March 1998).
Interrogatory No. 36: State whether, according to SIA's policies and operating practices, the co-pilot in the left -hand seat during 3-pilot crew operations on B747-400 (as stated in the FAM, page 3.39.1, 15 March 1998) is trained to conduct emergency procedures from the left-hand seat.
Interrogatory No. 37: Describe in detail the meaning, according to SIA's policies and operating practices for B747-400 aircraft, of the phrase "the required operating crew memebers of the minimum crew complement shall be in their assigned seats" (as stated in SIA's FAM, page 3.39.1, 15 March 1998).
Interrogatory No. 38: Describe in detail the meaning, according to SIA's policies and operating practices for B747-400 aircraft, of the phrase "a crew memeber's absence is necessary for the performance of duties in connection with the operation of the flight" (as stated in the FAM, page 3.39.1, 15 march 1998).
Interrogatory No. 39: Describe in detail the meaning, according to SIA's policies and operating practices, of the phrase "a crew memeber's absence is in connection with physiological needs" (as stated in the SIA's FAM, page 3.39.1, 15 march 1998) with respect to the B747-400.
Interrogatory No. 40: State whether the Captain's absence from hid duty station during inflight relief on B747-400 aircraft is in compliance with the requirement, that acrew member's absence is (a) necessary for the performance of duties in connection with the operation of the flight; or (b) in connection with physiological needs (as stated in the FAM, page 3.39.1, 15 march 1998).
Interrogatory No. 41: State whether it violates SIA's policies or operating procedures and /or CAAS regulations if, during 3-pilot crew operations (one Captain, two co-pilots) on B747-400 aircraft, the Captain takes inflight relief in the passenger cabin or the bunkroom.
More to follow.
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Interrogatory No. 42: State whether in airline operations involving commercial passenger aircraft such as the B-747 and B747-400, "non-compliance with procedures can have dire consequences and can expose the operation to grave risk, and that the only way an airline operation can be run safely and efficiently is for there to be strict compliance with standard operating procedures" (as stated in "From the DFO's Desk" memorandum dated December 8, 1999).
Interrogatory No. 43: Describe in detail SIA's policies and requirements for "flight crew members at duty stations" or "Pilots to remain at controls" with respect to B-747 and B747-400 operations.
Interrogatory No. 44: Describe in detail the CAAS legislated requirements for "flight crew members at duty stations" or "Pilots to remain at controls" with respect to B-747 ans B747-400 operations.
Interrogatory No. 45: State whether Singapore is an "ICAO member" and/ or"ICAO Contracting State". If the answer to this interrogatory is "no", state the reasons for your denial.
Interrogatory No. 46: Does SIA consider ICAO and the FAA to be "competent authorities". If the answer to this interrogatory is "no", state the reasons for youe denial.
Interrogatory No. 47: Describe in detail the obligation and responsibilities of ICAO Contracting States with regard to the "Standards" contained in Annex 1 (Personnel Licensing) and Annex 6 (Operation of aircraft), Part 1 (International Commercial Air Transport - Aeroplanes) to the Chicago Convention.
Interrogatory No. 48: Describe in detail the obligation and responsibilities of ICAO Contracting States with regard to giving notification to ICAO of differences in their operating practices from international standards under Article 38 of the Chicago Convention.
Interrogatory No. 49 : Describe in detail the obligation and responsibilities of ICAO Contracting States with regard to air regulations imposed by Article 12 of the Chicago Convention (rules in force over the high seas).
Interrogatory No. 50: Describe in detail ICAO's Standards with respect to "Flight crew members at duty stations" (as stated in Annex 6, Part 1 to the Chicago Convention).
Interrogatory No. 51: Describe in detail ICAO's Standards in Annex 1 (Personnel Licensing) to the Chicago Convention, with respect to a flight crew license to act as a flight crew member on an aircraft certificated for operation with a minimum crew of at least two pilots.
Interrogatory No. 52: Describe in detail the safety requirements imposed by the United States Department of Transportation ("DOT") upon the issuance of an "Air Caarrier Economic Authority" to an air carrier such as SIA for the purpose of conducting foreign air transport operations into the United States.
Interrogatory No. 53: Describe in detail the safety requirements imposed by the FAA regulations upon the issuance of "Part 129 Operations Specifications" to an air carrier such as SIA to conduct foreign air transport operations into the United States.
Interrogatory No. 54: Describe in detail the meaning of the aviation terms "unusual attitude" or "aircraft upset" with respect to commercial passenger aircraft such as B-747, B747-400, B-777, A310, A340.
Interrogatory No. 55: State whether SIA or the SUBSIDIARY (including, without limitation, any SIA Group aircraft type or entity for the purpose of flight training and or commercial passenger operations) has ever been involved in an "unusual attitude" and /or "aircraft upset" incident. If so, describe in detail the circumstances of each incident, including the date, location, and cause of the incident.
Interrogatory No. 56: If an unusual attitude or aircraft upset occurs on a B-747, B747-400, B-777, A310, or A340, state whether it would be possible for a pilot seated at the controls of the aircraft to exchange seats with another pilot during the incident.
Interrogatory No. 57: Describe in detail the difference between the flight crew oxygen system in the cockpit (not including the flight crew bunkroom), and the oxygen system in the passenger cabin in B-747 and B747-400 aircraft (including the flight crew bunkroom).
Interrogatory No. 58: Describe in detail the purpose of the smoke goggles at the pilot duty stations in the cockpit of B-747 and B747-400 aircraft, and state whether the same goggles are provided in the flight crew bunkroom of the B747-400.
Interrogatory No. 59: State whether during an emergency such as a "rapid or explosive decompression", the passenger oxygen system on the B-747 and B747-400 aircraft (including the oxygen available in the flight crew bunkroom of the B747-400) would be capable, in terms of volume and pressure, to deliver sufficient oxygen to enable a crew memeber to remain alert and carry out his pilot duties.
Interrogatory No. 60: State whether the B747-400 passenger aircraft is fitted with any intercom system or any other communication device in the flight crew bunkroom, to enable the two pilots seated at the pilot duty stations to establish communication with the crew member inside the flight crew bunkroom.
Interrogatory No. 61: State whether any SIA or the SUBSIDIARY (including without limitation any SIA Group aircraft type or entity for the purpose of flight training and or commercial passenger operations) has ever been involved in an accident resulting in an aircraft "hull loss". If so, describe in detail the circumstances of each incident, including the date, location, and cause.
Interrogatory No. 62: State whether any aircraft of SIA or the SUBSIDIARY (including without limitation any SIA Group aircraft type or entity for the purpose of flight training and or commercial passenger operations) has ever been involved in an incident or accident which resulted in fatalities. If so, describe in detail the circumstances of each incident or accident, including the date, location, and cause.
More to follow.
[This message has been edited by Gladiator (edited 19 June 2000).]
Interrogatory No. 43: Describe in detail SIA's policies and requirements for "flight crew members at duty stations" or "Pilots to remain at controls" with respect to B-747 and B747-400 operations.
Interrogatory No. 44: Describe in detail the CAAS legislated requirements for "flight crew members at duty stations" or "Pilots to remain at controls" with respect to B-747 ans B747-400 operations.
Interrogatory No. 45: State whether Singapore is an "ICAO member" and/ or"ICAO Contracting State". If the answer to this interrogatory is "no", state the reasons for your denial.
Interrogatory No. 46: Does SIA consider ICAO and the FAA to be "competent authorities". If the answer to this interrogatory is "no", state the reasons for youe denial.
Interrogatory No. 47: Describe in detail the obligation and responsibilities of ICAO Contracting States with regard to the "Standards" contained in Annex 1 (Personnel Licensing) and Annex 6 (Operation of aircraft), Part 1 (International Commercial Air Transport - Aeroplanes) to the Chicago Convention.
Interrogatory No. 48: Describe in detail the obligation and responsibilities of ICAO Contracting States with regard to giving notification to ICAO of differences in their operating practices from international standards under Article 38 of the Chicago Convention.
Interrogatory No. 49 : Describe in detail the obligation and responsibilities of ICAO Contracting States with regard to air regulations imposed by Article 12 of the Chicago Convention (rules in force over the high seas).
Interrogatory No. 50: Describe in detail ICAO's Standards with respect to "Flight crew members at duty stations" (as stated in Annex 6, Part 1 to the Chicago Convention).
Interrogatory No. 51: Describe in detail ICAO's Standards in Annex 1 (Personnel Licensing) to the Chicago Convention, with respect to a flight crew license to act as a flight crew member on an aircraft certificated for operation with a minimum crew of at least two pilots.
Interrogatory No. 52: Describe in detail the safety requirements imposed by the United States Department of Transportation ("DOT") upon the issuance of an "Air Caarrier Economic Authority" to an air carrier such as SIA for the purpose of conducting foreign air transport operations into the United States.
Interrogatory No. 53: Describe in detail the safety requirements imposed by the FAA regulations upon the issuance of "Part 129 Operations Specifications" to an air carrier such as SIA to conduct foreign air transport operations into the United States.
Interrogatory No. 54: Describe in detail the meaning of the aviation terms "unusual attitude" or "aircraft upset" with respect to commercial passenger aircraft such as B-747, B747-400, B-777, A310, A340.
Interrogatory No. 55: State whether SIA or the SUBSIDIARY (including, without limitation, any SIA Group aircraft type or entity for the purpose of flight training and or commercial passenger operations) has ever been involved in an "unusual attitude" and /or "aircraft upset" incident. If so, describe in detail the circumstances of each incident, including the date, location, and cause of the incident.
Interrogatory No. 56: If an unusual attitude or aircraft upset occurs on a B-747, B747-400, B-777, A310, or A340, state whether it would be possible for a pilot seated at the controls of the aircraft to exchange seats with another pilot during the incident.
Interrogatory No. 57: Describe in detail the difference between the flight crew oxygen system in the cockpit (not including the flight crew bunkroom), and the oxygen system in the passenger cabin in B-747 and B747-400 aircraft (including the flight crew bunkroom).
Interrogatory No. 58: Describe in detail the purpose of the smoke goggles at the pilot duty stations in the cockpit of B-747 and B747-400 aircraft, and state whether the same goggles are provided in the flight crew bunkroom of the B747-400.
Interrogatory No. 59: State whether during an emergency such as a "rapid or explosive decompression", the passenger oxygen system on the B-747 and B747-400 aircraft (including the oxygen available in the flight crew bunkroom of the B747-400) would be capable, in terms of volume and pressure, to deliver sufficient oxygen to enable a crew memeber to remain alert and carry out his pilot duties.
Interrogatory No. 60: State whether the B747-400 passenger aircraft is fitted with any intercom system or any other communication device in the flight crew bunkroom, to enable the two pilots seated at the pilot duty stations to establish communication with the crew member inside the flight crew bunkroom.
Interrogatory No. 61: State whether any SIA or the SUBSIDIARY (including without limitation any SIA Group aircraft type or entity for the purpose of flight training and or commercial passenger operations) has ever been involved in an accident resulting in an aircraft "hull loss". If so, describe in detail the circumstances of each incident, including the date, location, and cause.
Interrogatory No. 62: State whether any aircraft of SIA or the SUBSIDIARY (including without limitation any SIA Group aircraft type or entity for the purpose of flight training and or commercial passenger operations) has ever been involved in an incident or accident which resulted in fatalities. If so, describe in detail the circumstances of each incident or accident, including the date, location, and cause.
More to follow.
[This message has been edited by Gladiator (edited 19 June 2000).]
Guest
Posts: n/a
Interrogatory No. 63: State whether any flight of SIA or the SUBSIDIARY (including without limitation any SIA Group aircraft type or entity for the purpose of flight training and/or commercial passenger operations) has ever been involved in an incident of a cockpit crew member being incapacitated. If so, decribe in detail the circumstances of each incident including the date, location and cause of the incident.
Interrogatory No. 64: State whether, under SIA's policies and practices regarding salary and other monetary items, there is any difference on B747-400 aircraft between a co-pilot with CPL, and a co-pilot with CPL who passes or is granted exemption from the complete ATPL examination by CAAS. If so, describe in detail the difference in salary or other monetary items.
Interrogatory No. 65: State whether, according to SIA's policies and practices regarding salary and other monetary items, there is any difference between a Captain and a co-pilot with CPL but (without the demonstrated knowledge, at the airline transport pilot license level, as determined by CAAS) on the B747-400 aircraft.
Interrogatory No. 66: State whether any Captain on B747-400 aircraft has ever complained to SIA management (by formal or informal letter, comment during B747-400 fleet meetings, or other means) regarding the lack of clean bed sheets, and pillow covers, or blankets while operating as the Captain of a 3-pilot crew operation. If so, describe in detail the circumstances of the complaint, including the date, person complaining, and nature of the complaint.
Interrogatory No. 67: Describe in detail all statements or comments relating to the subjects of 3-pilot crew operations and inflight relief or rest during B747-400 fleet meetings, including the dates thereof, the persons making the statements or comments, the substance of the statements, and an identification of all documents relating to the statements or comments.
Interrogatory No. 68: State whether XXX was adequately trained to perform assigned duties in non-normal and or emergency procedures from the left-hand seat of the B-747 and B747-400, and describe the nature and extent of the training provided.
Interrogatory No. 69: State whether XXX was trained in all types of emergency or abnormal situation or procedure caused by powerplants, airframe or systems malfunctions, fire or other abnormalities from the left-hand seat of the B-747 and B747-400 aircraft, and describe the nature and extent of the training provided.
Interrogatory No. 70: Describe in detail the procedure utilized by SIA to ensure that XXX piloting technique and ability to execute emergency procedures was checked so as to demonstrate his competence from the left-hand seat of the B-747 and B747-400 aircraft.
Interrogatory No. 71: State whether SIA has ever provided or considered providing any training for First Officers/ and or Senior First Officers in the left-hand seat of the B747-400 aircraft. If so, describe in detail the nature and extent of training SIA provided, or considered providing, to First Officers.
Interrogatory No. 72: State whether the subject of providing training for First Officers and/or Senior First Officers in the left-hand seat of the B747-400 aircraft has been discussed at any B747-400 fleet meetings. If so, state the date of the meeting, identify the persons participating in the discussion, state the substance of the discussion, and identify all documents relating to the discussion.
Interrogatory No. 73: State whether SIA has ever been involved in an incident involving a "hijacking". If so, describe in detail the circumstances of each incident, including the date, location, and events relating to the incident.
Interrogatory No. 74: State whether SIA has ever had an incident where an unruly passenger required intervention of law enforcement upon arrival at the destination. If so, describe in detail the circumstances of each incident including, the date, location, and events relating to the incident.
Interrogatory No. 75: State whether on SIA's commercial passenger flight, the cockpit door is normally locked or unlocked during flight time, including during the critical phase, take-off and landing.
Interrogatory No. 76: Describe in detail the regulations, policies, and practices of SIA and CAAS with regard to the cockpit door being unlocked during flight time.
Interrogatory No. 77: State whether the locks on the cockpit door of B747-400 aircraft have been modified in any way from their original configuration at the time of the aircaft's certification, and state whether the cockpit door has the capability of being locked from the inside.
Interrogatory No. 78: State whether curtains or any other kinds of separating barriers exist between the upper passenger compartment and the cockpit door of B747-300 and B747-400 aircraft.
Interrogatory No. 79: Describe in detail the regulations, policies, and practices of SIA and CAAS relating to allowing passengers to enter the cockpit during flight time, including the critical phase, takeoff and landing.
Interrogatory No. 80: State the reasons why the Singapore CAAS was assessed by the FAA under the International Aviation Safety Program.
Interrogatory No. 81: State the basis for SIA's affirmative defence of waiver.
Interrogatory No. 82: State the basis for SIA's affirmative defense of laches.
Interrogatory No. 83: State the basis for SIA's affirmative defence of unclean hands.
Interrogatory No. 84: State the basis for SIA's affirmative defence that XXX counterclaims are reckless and negligent.
Interrogatory No. 85: Identify each expert retained by SIA or its attorneys or representatives for purpose of this litigation. With repect to each such expert expected to testify at trial as an expert witness, provide the following information:
a) Name and address;
b) Occupation and qualifications of the expert;
c) The subject matter on which the expert is expected to testify;
d) The substance of the facts and opinions to which the expert is expected to testify; and
e) A summary of the grounds for each opinion.
Interrogatory No. 86: Identify all statements obtained from any other person regarding the allegations or subject matter of SIA's Complaint, Defendant's Answer and Counterclaims, and/or SIA's Answer to Counterclaim.
End of Interrogatories. Next will be 'Request for Production of Documents' followed by 'SIA to Admit'.
Interrogatory No. 64: State whether, under SIA's policies and practices regarding salary and other monetary items, there is any difference on B747-400 aircraft between a co-pilot with CPL, and a co-pilot with CPL who passes or is granted exemption from the complete ATPL examination by CAAS. If so, describe in detail the difference in salary or other monetary items.
Interrogatory No. 65: State whether, according to SIA's policies and practices regarding salary and other monetary items, there is any difference between a Captain and a co-pilot with CPL but (without the demonstrated knowledge, at the airline transport pilot license level, as determined by CAAS) on the B747-400 aircraft.
Interrogatory No. 66: State whether any Captain on B747-400 aircraft has ever complained to SIA management (by formal or informal letter, comment during B747-400 fleet meetings, or other means) regarding the lack of clean bed sheets, and pillow covers, or blankets while operating as the Captain of a 3-pilot crew operation. If so, describe in detail the circumstances of the complaint, including the date, person complaining, and nature of the complaint.
Interrogatory No. 67: Describe in detail all statements or comments relating to the subjects of 3-pilot crew operations and inflight relief or rest during B747-400 fleet meetings, including the dates thereof, the persons making the statements or comments, the substance of the statements, and an identification of all documents relating to the statements or comments.
Interrogatory No. 68: State whether XXX was adequately trained to perform assigned duties in non-normal and or emergency procedures from the left-hand seat of the B-747 and B747-400, and describe the nature and extent of the training provided.
Interrogatory No. 69: State whether XXX was trained in all types of emergency or abnormal situation or procedure caused by powerplants, airframe or systems malfunctions, fire or other abnormalities from the left-hand seat of the B-747 and B747-400 aircraft, and describe the nature and extent of the training provided.
Interrogatory No. 70: Describe in detail the procedure utilized by SIA to ensure that XXX piloting technique and ability to execute emergency procedures was checked so as to demonstrate his competence from the left-hand seat of the B-747 and B747-400 aircraft.
Interrogatory No. 71: State whether SIA has ever provided or considered providing any training for First Officers/ and or Senior First Officers in the left-hand seat of the B747-400 aircraft. If so, describe in detail the nature and extent of training SIA provided, or considered providing, to First Officers.
Interrogatory No. 72: State whether the subject of providing training for First Officers and/or Senior First Officers in the left-hand seat of the B747-400 aircraft has been discussed at any B747-400 fleet meetings. If so, state the date of the meeting, identify the persons participating in the discussion, state the substance of the discussion, and identify all documents relating to the discussion.
Interrogatory No. 73: State whether SIA has ever been involved in an incident involving a "hijacking". If so, describe in detail the circumstances of each incident, including the date, location, and events relating to the incident.
Interrogatory No. 74: State whether SIA has ever had an incident where an unruly passenger required intervention of law enforcement upon arrival at the destination. If so, describe in detail the circumstances of each incident including, the date, location, and events relating to the incident.
Interrogatory No. 75: State whether on SIA's commercial passenger flight, the cockpit door is normally locked or unlocked during flight time, including during the critical phase, take-off and landing.
Interrogatory No. 76: Describe in detail the regulations, policies, and practices of SIA and CAAS with regard to the cockpit door being unlocked during flight time.
Interrogatory No. 77: State whether the locks on the cockpit door of B747-400 aircraft have been modified in any way from their original configuration at the time of the aircaft's certification, and state whether the cockpit door has the capability of being locked from the inside.
Interrogatory No. 78: State whether curtains or any other kinds of separating barriers exist between the upper passenger compartment and the cockpit door of B747-300 and B747-400 aircraft.
Interrogatory No. 79: Describe in detail the regulations, policies, and practices of SIA and CAAS relating to allowing passengers to enter the cockpit during flight time, including the critical phase, takeoff and landing.
Interrogatory No. 80: State the reasons why the Singapore CAAS was assessed by the FAA under the International Aviation Safety Program.
Interrogatory No. 81: State the basis for SIA's affirmative defence of waiver.
Interrogatory No. 82: State the basis for SIA's affirmative defense of laches.
Interrogatory No. 83: State the basis for SIA's affirmative defence of unclean hands.
Interrogatory No. 84: State the basis for SIA's affirmative defence that XXX counterclaims are reckless and negligent.
Interrogatory No. 85: Identify each expert retained by SIA or its attorneys or representatives for purpose of this litigation. With repect to each such expert expected to testify at trial as an expert witness, provide the following information:
a) Name and address;
b) Occupation and qualifications of the expert;
c) The subject matter on which the expert is expected to testify;
d) The substance of the facts and opinions to which the expert is expected to testify; and
e) A summary of the grounds for each opinion.
Interrogatory No. 86: Identify all statements obtained from any other person regarding the allegations or subject matter of SIA's Complaint, Defendant's Answer and Counterclaims, and/or SIA's Answer to Counterclaim.
End of Interrogatories. Next will be 'Request for Production of Documents' followed by 'SIA to Admit'.
Guest
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REQUESTS FOR PRODUCTION OF DOCUMENTS.
Request No. 1: All documents which discuss, relate or refer to XXX.
Request No. 2: All contracts or agreements between XXX and SIA.
Request No. 3: All correspondence, notes, memoranda and other documents relating to meetings, communication, and conversation between XXX and SIA personnel.
Request No. 4: All documents evidencing XXX's total flight hours and sectors at SIA, and his opereations in the left-hand seat and right-hand seats on SIA aircraft.
Request No. 5: All documents provided by SIA to XXX relating to his crew license.
Request No. 6: All of XXX's pay slips from November, 1996 to October, 1997.
Request No. 7: All documents showing XXX's "Technical Crew Hours (LCREWHRS)" through October 27, 1997.
Request No. 8: All records of XXX's check rides (base checks) at SIA.
Request No. 9: All documents which discuss, relate or refer to XXX's requests to take annual vacation for the purpose of taking the ATPL examinations.
Request No. 10: All documents which discuss relate or refer to international safety atandards adopted or implemented by ICAO, including, without limitation, the standards contained in Annex 1 (Personnel licensing) and Annex 6, Part 1 to the chicago Convention.
Request No. 11: All documents which discuss, relate or refer to the status of SIA as a Contracting State of ICAO.
Request No. 12: All documents which discuss, relate or refer to any notification of SIA's departure from ICAO safety standards pursuant to Article 38 of the Chicago Convention.
Request No. 13: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to licensing requirements for SIA pilots operating B-747 and B747-400 aircraft.
Request No. 14: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to restricted type ratings with respect to operations on B-747 and B747-400 aircraft.
Request No. 15: All policy manuals, circulars, bulletins, memeoranda and other documents which discuss, relate or refer to any of the following "holder's operating capacity": (a) P.1 Pilot in charge; (b) P.1u/s Pilot in Charge under supervision (each entry must be countersigned by the Captain); (c) P.2 Second pilot exercising the privileges of license as a required member of ther operating crew; (d) P.3 Pupil pilot; (e) pilot under training, as set forth in the Personal Flying Log Book (Aircraft Operating Crew) issued by SIA to XXX and other pilots.
Request No. 16: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to the policies and procedures of SIA and/or CAAS relating to the training of SIA cadet pilots on B-747 and B747-400 aircraft, including, without limitation, training in the left-hand seats and training in non-normal and emergency procedures.
Request No. 17: All documents which discuss, relate or refer to the costs of training cadet pilots at SIA.
Request No. 18: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to the policies and procedures of SIA and/or CAAS relating to the training of Captains, First Officers, and Second Officers for operations on B-747 and B747-400 aircraft, including, without limitation, training in the left-hand and right-hand seats, and training in non-normal and emergency procedures.
Request No. 19: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to the policies and procedures of SIA and/or CAAS relating to pilots holding ATPL or passing ATPL exams for service on B-747 and B747-400 aircraft.
Request No. 20: All policy manuals manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to policies and procedures of SIA and/or CAAS designated to protect against two new First Officers with minimal experience being paired together in 3-pilot crew operations.
Request No. 21: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to the policies and procedures of SIA and/or CAAS with respect to 3-pilot crews.
Request No. 22: All documents which discuss, relate or refer to authorization from CAAS to perform 3-pilot crew operations.
Request No. 23: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to the policies and procedures of SIA and/or CAAS relating to inflight relief or rest taken by the Captain.
Request No. 24: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to the policies and procedures of SIA and/or CAAS relating to the absence of the Captain from his duty station for any reason.
More to follow.
Request No. 1: All documents which discuss, relate or refer to XXX.
Request No. 2: All contracts or agreements between XXX and SIA.
Request No. 3: All correspondence, notes, memoranda and other documents relating to meetings, communication, and conversation between XXX and SIA personnel.
Request No. 4: All documents evidencing XXX's total flight hours and sectors at SIA, and his opereations in the left-hand seat and right-hand seats on SIA aircraft.
Request No. 5: All documents provided by SIA to XXX relating to his crew license.
Request No. 6: All of XXX's pay slips from November, 1996 to October, 1997.
Request No. 7: All documents showing XXX's "Technical Crew Hours (LCREWHRS)" through October 27, 1997.
Request No. 8: All records of XXX's check rides (base checks) at SIA.
Request No. 9: All documents which discuss, relate or refer to XXX's requests to take annual vacation for the purpose of taking the ATPL examinations.
Request No. 10: All documents which discuss relate or refer to international safety atandards adopted or implemented by ICAO, including, without limitation, the standards contained in Annex 1 (Personnel licensing) and Annex 6, Part 1 to the chicago Convention.
Request No. 11: All documents which discuss, relate or refer to the status of SIA as a Contracting State of ICAO.
Request No. 12: All documents which discuss, relate or refer to any notification of SIA's departure from ICAO safety standards pursuant to Article 38 of the Chicago Convention.
Request No. 13: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to licensing requirements for SIA pilots operating B-747 and B747-400 aircraft.
Request No. 14: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to restricted type ratings with respect to operations on B-747 and B747-400 aircraft.
Request No. 15: All policy manuals, circulars, bulletins, memeoranda and other documents which discuss, relate or refer to any of the following "holder's operating capacity": (a) P.1 Pilot in charge; (b) P.1u/s Pilot in Charge under supervision (each entry must be countersigned by the Captain); (c) P.2 Second pilot exercising the privileges of license as a required member of ther operating crew; (d) P.3 Pupil pilot; (e) pilot under training, as set forth in the Personal Flying Log Book (Aircraft Operating Crew) issued by SIA to XXX and other pilots.
Request No. 16: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to the policies and procedures of SIA and/or CAAS relating to the training of SIA cadet pilots on B-747 and B747-400 aircraft, including, without limitation, training in the left-hand seats and training in non-normal and emergency procedures.
Request No. 17: All documents which discuss, relate or refer to the costs of training cadet pilots at SIA.
Request No. 18: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to the policies and procedures of SIA and/or CAAS relating to the training of Captains, First Officers, and Second Officers for operations on B-747 and B747-400 aircraft, including, without limitation, training in the left-hand and right-hand seats, and training in non-normal and emergency procedures.
Request No. 19: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to the policies and procedures of SIA and/or CAAS relating to pilots holding ATPL or passing ATPL exams for service on B-747 and B747-400 aircraft.
Request No. 20: All policy manuals manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to policies and procedures of SIA and/or CAAS designated to protect against two new First Officers with minimal experience being paired together in 3-pilot crew operations.
Request No. 21: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to the policies and procedures of SIA and/or CAAS with respect to 3-pilot crews.
Request No. 22: All documents which discuss, relate or refer to authorization from CAAS to perform 3-pilot crew operations.
Request No. 23: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to the policies and procedures of SIA and/or CAAS relating to inflight relief or rest taken by the Captain.
Request No. 24: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to the policies and procedures of SIA and/or CAAS relating to the absence of the Captain from his duty station for any reason.
More to follow.
Guest
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So your lawyer will then receive this information, and spend the next 6 months wading through it, making notations, and filing it, while he charges YOU a couple of hundred bucks an hour.
Looks like a good tactic, Glad................for building up the lawyer's bank account!!!
Looks like a good tactic, Glad................for building up the lawyer's bank account!!!
Guest
Posts: n/a
Request No. 25: All policy manuals, circulars, bulletins, memoranda or other documents concerning whether inflight relief must occur in any particular order or phase of cruise. (See FAM, page 3.39.1, march 15, 1998).
Request No. 26: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to the policies and procedures of SIA and/or CAAS relating to co-pilots operating in the laft-hand seat of B-747 and B747-400 aircraft.
Request No. 27: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to pilot incapacitation training provided by SIA.
Request No. 28: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to the policies and procedures of SIA and/or CAAS relating to checks for pilot training, including non-normal and emergency operations.
Request No. 29: All documents provided to SIA and/or CAAS by a competent authority of any Contracting State other than Singapore Iincluding without limitation, competent authorities of the United States), relating to the granting of permission to the holder of a Singapore license to o[perate aircraft and the conditions thereto.
Request No. 30: All minutes, notes, memoranda and other documents which discuss, relate or refer to fleet meetings attended by SIA pilots during the period of January 1, 1995 to the present date.
Request No. 31: All SIA Operation Manuals pursuant to Part V, Chapters 25 and 26, Air Navigation Act (Chapter 6), Air Navigation Order.
Request No. 32: All FAA Part 129 Operations Specifications issued to SIA.
Request No. 33: All FAMs, including all revisions and amendments thereto.
Request No. 34: The 1995 ALPA-S Agreement, and any subsequent agreements or amendments between SIA and ALPA-S.
Request No. 35: All documents which discuss, relate or refer to requirements for cleaning crews to dress the flight crew bunkroom for 2-pilot and 3-pilot crew flights.
Request No. 36: All specifications applicable to the flight crew oxygen systems located in the cockpit, passenger cabin, and flight crew bunkroom on the B-747 and B747-400 aircraft.
Request No. 37: All policy manuals, circulars, bulletins, memoranda, and other documents which discuss, relate or refer to the policies and procedures of SIA and/or CAAS regarding passengers entering the cockpit during takeoff and landing.
Request No. 38: Lists of all 3-pilot crew operation sector on A-340 and B747-400 aircraft in the SIA system.
Request No. 39: The passenger manifest of the flight carrying Captain XXX and his son.
Request No. 40: The voyage record of the flight when XXX was injured.
Request No. 41: All service bulletins and other documents relating to cockpit door lock modifications on SIA B747-400 aircraft.
Request No. 42: Advisory Circular AC-FO 3/96, dated September 1996, referred to in Advisory Circular AC-FO 1/99.
Request No. 43: All documents which discuss, relate or refer to the grandfather clause and ICAO Annex 1 license issue as discussed by Captain Maurice DVz in his memorandum entitled "From Desk of DFO".
Request No. 44: Lists of all pilots on A-340 and B747-400 aircraft who hold CPL only, without demonstrated knowledge of ATPL.
Request No. 45: The voyage record of XXX's flight with XXX and XXX.
Request No. 46: All documents which discuss, relate or refer to XXX request for leave in a handwritten note to Tony T.
Request No, 47: A copy of FAM, Page 3.39.1 existing before the March 15, 1998 revision.
Request No. 48: All records of route checks performed on SIA aircraft by CAAS.
Request No. 49: SIA records showing the date the last B-747 aircraft left SIA line operations.
Request No. 50: All documents which discuss, relate or refer to the "unusual attitude" incident involving an SIA A-310 aircraft in 1994, including technical log entries upon arrival at the destination, records of maintenance inspection of the A-310, and the date when the incident was reported.
Request No. 51: All documents which discuss, relate or refer to any incident involving a cockpit crewmember being incapacitated on SIA aircraft.
Request No. 52: All documents which discuss, relate or refer to any incidents resulting in a "Hull loss" of SIA or the SUBSIDIARY aircraft.
Request No. 53: All documents which discuss, relate or refer to the experience level and flight hours of the co-pilot on the SIA Lear Jet that crashed in August 1997.
Request No. 54: All documents which reflect the name and address of flight engineer(s) on the following SIA flights: 9V-SQQ on April 12, 1993, SIN to MEL, 9V-SQT on April 14, 1993, MEL to SIN.
Request No. 55: Pages 5.36 and 5.37 of the SIA Boeing B747-400 Flight Crew Training manual, Full Flight Simulator.
Request No. 56: All documents provided by ICAO or any Contracting State (including, without limitation, the United States), indicating or granting permission to the holder of a Singapore license to operate aircraft without staisfying relevany international standards.
Request No. 57: All statements regarding the allegations or subject matter of SIA's Complaint; Defendant's Answer and Counterclaims; and/or SIA's Answer to Counterclaims in this action.
Request No. 58: All other documents which discuss, relate oe refer to the claims or defences to counterclaims asserted by SIA in this action.
Request No. 59: All documents identified by SIA in its answer to Defendant's interrogatories.
End of request for production of documents. next will be "SIA to Admit".
Request No. 26: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to the policies and procedures of SIA and/or CAAS relating to co-pilots operating in the laft-hand seat of B-747 and B747-400 aircraft.
Request No. 27: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to pilot incapacitation training provided by SIA.
Request No. 28: All policy manuals, circulars, bulletins, memoranda and other documents which discuss, relate or refer to the policies and procedures of SIA and/or CAAS relating to checks for pilot training, including non-normal and emergency operations.
Request No. 29: All documents provided to SIA and/or CAAS by a competent authority of any Contracting State other than Singapore Iincluding without limitation, competent authorities of the United States), relating to the granting of permission to the holder of a Singapore license to o[perate aircraft and the conditions thereto.
Request No. 30: All minutes, notes, memoranda and other documents which discuss, relate or refer to fleet meetings attended by SIA pilots during the period of January 1, 1995 to the present date.
Request No. 31: All SIA Operation Manuals pursuant to Part V, Chapters 25 and 26, Air Navigation Act (Chapter 6), Air Navigation Order.
Request No. 32: All FAA Part 129 Operations Specifications issued to SIA.
Request No. 33: All FAMs, including all revisions and amendments thereto.
Request No. 34: The 1995 ALPA-S Agreement, and any subsequent agreements or amendments between SIA and ALPA-S.
Request No. 35: All documents which discuss, relate or refer to requirements for cleaning crews to dress the flight crew bunkroom for 2-pilot and 3-pilot crew flights.
Request No. 36: All specifications applicable to the flight crew oxygen systems located in the cockpit, passenger cabin, and flight crew bunkroom on the B-747 and B747-400 aircraft.
Request No. 37: All policy manuals, circulars, bulletins, memoranda, and other documents which discuss, relate or refer to the policies and procedures of SIA and/or CAAS regarding passengers entering the cockpit during takeoff and landing.
Request No. 38: Lists of all 3-pilot crew operation sector on A-340 and B747-400 aircraft in the SIA system.
Request No. 39: The passenger manifest of the flight carrying Captain XXX and his son.
Request No. 40: The voyage record of the flight when XXX was injured.
Request No. 41: All service bulletins and other documents relating to cockpit door lock modifications on SIA B747-400 aircraft.
Request No. 42: Advisory Circular AC-FO 3/96, dated September 1996, referred to in Advisory Circular AC-FO 1/99.
Request No. 43: All documents which discuss, relate or refer to the grandfather clause and ICAO Annex 1 license issue as discussed by Captain Maurice DVz in his memorandum entitled "From Desk of DFO".
Request No. 44: Lists of all pilots on A-340 and B747-400 aircraft who hold CPL only, without demonstrated knowledge of ATPL.
Request No. 45: The voyage record of XXX's flight with XXX and XXX.
Request No. 46: All documents which discuss, relate or refer to XXX request for leave in a handwritten note to Tony T.
Request No, 47: A copy of FAM, Page 3.39.1 existing before the March 15, 1998 revision.
Request No. 48: All records of route checks performed on SIA aircraft by CAAS.
Request No. 49: SIA records showing the date the last B-747 aircraft left SIA line operations.
Request No. 50: All documents which discuss, relate or refer to the "unusual attitude" incident involving an SIA A-310 aircraft in 1994, including technical log entries upon arrival at the destination, records of maintenance inspection of the A-310, and the date when the incident was reported.
Request No. 51: All documents which discuss, relate or refer to any incident involving a cockpit crewmember being incapacitated on SIA aircraft.
Request No. 52: All documents which discuss, relate or refer to any incidents resulting in a "Hull loss" of SIA or the SUBSIDIARY aircraft.
Request No. 53: All documents which discuss, relate or refer to the experience level and flight hours of the co-pilot on the SIA Lear Jet that crashed in August 1997.
Request No. 54: All documents which reflect the name and address of flight engineer(s) on the following SIA flights: 9V-SQQ on April 12, 1993, SIN to MEL, 9V-SQT on April 14, 1993, MEL to SIN.
Request No. 55: Pages 5.36 and 5.37 of the SIA Boeing B747-400 Flight Crew Training manual, Full Flight Simulator.
Request No. 56: All documents provided by ICAO or any Contracting State (including, without limitation, the United States), indicating or granting permission to the holder of a Singapore license to operate aircraft without staisfying relevany international standards.
Request No. 57: All statements regarding the allegations or subject matter of SIA's Complaint; Defendant's Answer and Counterclaims; and/or SIA's Answer to Counterclaims in this action.
Request No. 58: All other documents which discuss, relate oe refer to the claims or defences to counterclaims asserted by SIA in this action.
Request No. 59: All documents identified by SIA in its answer to Defendant's interrogatories.
End of request for production of documents. next will be "SIA to Admit".
Guest
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Everyone else noticed how these non-achievers - Glad, Titan, and the host of other names they use - continually make peurile postings, to keep their sad, whinging stories at the top.
Singapore Airlines got to their "Number One" position, BECAUSE they weeded out non-performers, such as you moaners.
Singapore Airlines got to their "Number One" position, BECAUSE they weeded out non-performers, such as you moaners.
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SIA to Admit
Request No. 1: Admit that the SIA documents attached as exhibit 1 are true and correct copies of XXX’s pay slips during his employment with SIA, showing XXX’s take home pay of $91,822.24 Singapore dollars for the 12-month period of November, 1996 through October, 1997.
Request No. 2: Admit that $1200 per month was deducted for deposit in XXX’s provident fund, and that SIA made a matching contribution of $1200 Singapore dollars per month to XXX’s provident fund.
Request No. 3: Admit that SIA pays a 13th month salary to XXX and other pilots each year.
Request No. 4: Admit that the total of XXX’s take home pay, XXX’s provident fund contribution, and SIA’s provident fund matching contributed averaged $10,051.85 Singapore dollars income per month ($6,282.40 US Dollars per month at 96/97 exchange rate of 1 US Dollar to 1.6 Singapore dollar).
Request No. 5: Admit that the documents attached as exhibit 2 are true and correct copies of the 1990 edition of Singapore’s Subsidiary Legislation, the Air Navigation Act (1990) (also known as “Air Navigation Order"), Chapter 6, Section 19.
Request No 6: Admit that SIA operates flights into the United States and to he following destinations: Los Angeles, San Francisco, Achorage, Chicago, New York.
Request No. 7: Admit that the international cicvil aviation marking “9V’ designates “Singapore aircraft”, an aircraft which is registered in the Republic of Singapore.
Request No. 8: Admit that CAAS is a civil aviation authority which regulates SIA’s flight operations.
Request No. 9: Admit that Singapore is a “Contracting State” which is a party to the Convention on International Civil Aviation (the “Chicago Convention").
Request No. 10: Admit that according to Singapore’s Air Navigation Order, the term “competent authority” means, in relation to Singapore, the minister, and, in relation to any other country, the authority responsible under the law of that country for promoting the safety of civil avaition.
Request No. 11: Admit that ICAO is the only internationally recognized aviation standards-setting body and is a “competent authority” within the meaning of the Air Navigation Order.
Request No. 12: Admit that the FAA is a “competent authority” responsible for promoting the safety of civil aviation under the laws of the United States.
Request No. 13: Admit that the document attached as exhibit 3 is a true and correct copy of the Chicago Convention.
Request No. 14: Admit that the document attached as exhibit 4, is a true and correct copy of International Standards and Recommended Practices, Personnel Licensing, Annex 1, to the Chicago Convention (Eighth edition; July 1988), applicable November 16, 1989.
Request No. 15: Admit that pursuant to Annex 1 to the Chicago Convention, a flight crew member of an aircraft is required to hold a valid license showing compliance with the specifications of Annex 1 and appropriate to the duties performed by that person.
Request No. 16: Admit that the attached as exhibit 5 is a true and correct copy of International Standards and Recommended Pracices, Operation od Aircraft, Annex 6, Part 1 (International Commercial Air Transport – Aeroplanes) to the Chicago Convention.
Request No. 17: Admit that a Contracting State such as Singapore is prohibited from permitting the holder of a license to exercise privileges other than those granted by that license.
Request No. 18: Admit that under Annex 1 to the Chicago Convention, a Contracting State shall not permit the holder of a license to act as pilot-in-command or co-pilot of an aeroplane certified for operation with a minimum crew of at least two pilots, unless he is authorized by a type rating in which the applicant demonstrated a level of knowledge appropriate to the privileges granted to the holder of an ATPL (Airline Transport Pilot License).
Request No. 19: Admit that the Boeing B747-400 aircraft is certified for operation with a minimum crew of at least two pilots.
Request No. 20: Admit that the document attached as exhibit 6 is a true and correct copy of the Commercial Pilot License (“CPL")issued to XXX by the CAAS on November 1, 1991, in accordance with the Air navigation Act (CAP 87) and Annex 1 to the Chicago Convention.
Request No. 21: Admit that SIA and/or CAAS did not accept XXX’s Airline Transport Pilot license (“ATP”
issued by FAA.
Request No. 22: Admit that during XXX’s employment at SIA, XXX did not demonstrate a level of knowledge granted to a holder of an ATPL by passing the ATPL examination as administered or accepted by CAAS.
Request No. 23: Admit that XXX and other co-pilots on the B747-400 never received training in recovery from unusual attitudes from the left-hand seat in the B-747 or B747-400 aircraft.
Request No.24: Admit that under XXX’s CPL (exhibit6), Aircraft Ratings (Aeroplanes), Part II Co-pilot, XXX was entitled to exercise the privileges of a co-pilot (P2) on the following aircraft: B-747 (date and stamp on CPL: November 1, 1991) and B747-400 aircraft (date and stamp on CPL: January 13, 1995).
Request No. 25: Admit that all of XXX’s flying check (Base checks) were administered for co-pilot (P2) capacity.
Request No. 26: Admit that XXX’s CPL does not contain any endorsements for Captain (pilot-in-command).
Request No. 27: Admit that in XXX’s CPL (exhibit 6), Aircraft Ratings (Aeroplanes), Part 1, Pilot-in-command, no aeroplanes are specified for his exercise of the privilege of a pilot-in-command (P1).
Request No. 28: Admit that pursuant to Annex 1 to the Chicago Convention, a co-pilot operating Singapore registered B-747 or B747-400 aircraft and holding a CPL, but not holding an ATPL, cannot act as a crewmember under the capacity of P1 for the purpose of public transport.
Request No. 29: Admit that the document attached as exhibit 7 is a true and correct copy of Instructions for use, Personal Flying Log Book (Aircraft Operating Crew) issued to XXX by SIA.
More to follow.
[This message has been edited by Gladiator (edited 22 June 2000).]
[This message has been edited by Gladiator (edited 22 June 2000).]
Request No. 1: Admit that the SIA documents attached as exhibit 1 are true and correct copies of XXX’s pay slips during his employment with SIA, showing XXX’s take home pay of $91,822.24 Singapore dollars for the 12-month period of November, 1996 through October, 1997.
Request No. 2: Admit that $1200 per month was deducted for deposit in XXX’s provident fund, and that SIA made a matching contribution of $1200 Singapore dollars per month to XXX’s provident fund.
Request No. 3: Admit that SIA pays a 13th month salary to XXX and other pilots each year.
Request No. 4: Admit that the total of XXX’s take home pay, XXX’s provident fund contribution, and SIA’s provident fund matching contributed averaged $10,051.85 Singapore dollars income per month ($6,282.40 US Dollars per month at 96/97 exchange rate of 1 US Dollar to 1.6 Singapore dollar).
Request No. 5: Admit that the documents attached as exhibit 2 are true and correct copies of the 1990 edition of Singapore’s Subsidiary Legislation, the Air Navigation Act (1990) (also known as “Air Navigation Order"), Chapter 6, Section 19.
Request No 6: Admit that SIA operates flights into the United States and to he following destinations: Los Angeles, San Francisco, Achorage, Chicago, New York.
Request No. 7: Admit that the international cicvil aviation marking “9V’ designates “Singapore aircraft”, an aircraft which is registered in the Republic of Singapore.
Request No. 8: Admit that CAAS is a civil aviation authority which regulates SIA’s flight operations.
Request No. 9: Admit that Singapore is a “Contracting State” which is a party to the Convention on International Civil Aviation (the “Chicago Convention").
Request No. 10: Admit that according to Singapore’s Air Navigation Order, the term “competent authority” means, in relation to Singapore, the minister, and, in relation to any other country, the authority responsible under the law of that country for promoting the safety of civil avaition.
Request No. 11: Admit that ICAO is the only internationally recognized aviation standards-setting body and is a “competent authority” within the meaning of the Air Navigation Order.
Request No. 12: Admit that the FAA is a “competent authority” responsible for promoting the safety of civil aviation under the laws of the United States.
Request No. 13: Admit that the document attached as exhibit 3 is a true and correct copy of the Chicago Convention.
Request No. 14: Admit that the document attached as exhibit 4, is a true and correct copy of International Standards and Recommended Practices, Personnel Licensing, Annex 1, to the Chicago Convention (Eighth edition; July 1988), applicable November 16, 1989.
Request No. 15: Admit that pursuant to Annex 1 to the Chicago Convention, a flight crew member of an aircraft is required to hold a valid license showing compliance with the specifications of Annex 1 and appropriate to the duties performed by that person.
Request No. 16: Admit that the attached as exhibit 5 is a true and correct copy of International Standards and Recommended Pracices, Operation od Aircraft, Annex 6, Part 1 (International Commercial Air Transport – Aeroplanes) to the Chicago Convention.
Request No. 17: Admit that a Contracting State such as Singapore is prohibited from permitting the holder of a license to exercise privileges other than those granted by that license.
Request No. 18: Admit that under Annex 1 to the Chicago Convention, a Contracting State shall not permit the holder of a license to act as pilot-in-command or co-pilot of an aeroplane certified for operation with a minimum crew of at least two pilots, unless he is authorized by a type rating in which the applicant demonstrated a level of knowledge appropriate to the privileges granted to the holder of an ATPL (Airline Transport Pilot License).
Request No. 19: Admit that the Boeing B747-400 aircraft is certified for operation with a minimum crew of at least two pilots.
Request No. 20: Admit that the document attached as exhibit 6 is a true and correct copy of the Commercial Pilot License (“CPL")issued to XXX by the CAAS on November 1, 1991, in accordance with the Air navigation Act (CAP 87) and Annex 1 to the Chicago Convention.
Request No. 21: Admit that SIA and/or CAAS did not accept XXX’s Airline Transport Pilot license (“ATP”
issued by FAA.Request No. 22: Admit that during XXX’s employment at SIA, XXX did not demonstrate a level of knowledge granted to a holder of an ATPL by passing the ATPL examination as administered or accepted by CAAS.
Request No. 23: Admit that XXX and other co-pilots on the B747-400 never received training in recovery from unusual attitudes from the left-hand seat in the B-747 or B747-400 aircraft.
Request No.24: Admit that under XXX’s CPL (exhibit6), Aircraft Ratings (Aeroplanes), Part II Co-pilot, XXX was entitled to exercise the privileges of a co-pilot (P2) on the following aircraft: B-747 (date and stamp on CPL: November 1, 1991) and B747-400 aircraft (date and stamp on CPL: January 13, 1995).
Request No. 25: Admit that all of XXX’s flying check (Base checks) were administered for co-pilot (P2) capacity.
Request No. 26: Admit that XXX’s CPL does not contain any endorsements for Captain (pilot-in-command).
Request No. 27: Admit that in XXX’s CPL (exhibit 6), Aircraft Ratings (Aeroplanes), Part 1, Pilot-in-command, no aeroplanes are specified for his exercise of the privilege of a pilot-in-command (P1).
Request No. 28: Admit that pursuant to Annex 1 to the Chicago Convention, a co-pilot operating Singapore registered B-747 or B747-400 aircraft and holding a CPL, but not holding an ATPL, cannot act as a crewmember under the capacity of P1 for the purpose of public transport.
Request No. 29: Admit that the document attached as exhibit 7 is a true and correct copy of Instructions for use, Personal Flying Log Book (Aircraft Operating Crew) issued to XXX by SIA.
More to follow.
[This message has been edited by Gladiator (edited 22 June 2000).]
[This message has been edited by Gladiator (edited 22 June 2000).]
Guest
Posts: n/a
Request No. 30: Admit that according to the SIA document attached as exhibit 8, "P1" means "pilot in charge", "P2" means "second pilot exercising the privileges of his license as a required member of the operating crew, "P1u/s" means "pilot in charge under supervision."
Request No. 31: Admit that a co-pilot operating in the capacity of "P2" or "P1u/s" is under the supervision of the Captain, and "P3" is a pupil pilot (also known a spilot under training).
Request No. 32: Admit that the document attached as exhibit 8 is a true copy of the FAM, page 2.19.4, Logging of Hours/Sectors, 1 march 1990.
Request No. 33: Admit that according to CFR 129.15, Flight crewmember certificates, a flight crewmember is required to hold a current certificate or license issued or validated by the country in which that aircraft is registered, showing his ability to perform his duties connected with operating that aircraft.
Request No. 34: Admit that the document attached as exhibit 9 is a true and correct copy of the FAM, Line Operations, Cockpit seats/A340 crew rest Facility, page 3.39.1, 15 march 1998.
Request No. 35: Admit that under the provisions of FAM, page 3.40.1, First Officer Route Flying, 15 December 1995 (attached as exhibit 10), during 3-pilot crew operations, the Commander is not allowed to take inflight relief in the passenger cabin or the flight crew rest facility bunkroom.
Request No. 36: Admit that during XXX's employment at SIA, there was no provision in the FAM requiring XXX or other First Officers to occupy the left-hand seat of the B-747.
Request No. 37: Admit that according to the SIA reports regarding Technical Crew Hours attached as exhibit 11, XXX had "P1: 530, P2: 544, HRS: 806" from commercial flying experience previous to employment at SIA.
Request No. 38: Admit that the document attached as exhibit 12 are true and correct copies of the FAM, Minimum Qualifications for Promotions, pages 2.19.1 and 2.19.2, 15 January 1999.
Request No. 39: Admit that according to exhibit 12, a number of sectors and/or hours in exhibit 11 was credited to XXX for commercial flying experience previous to his employment at SIA.
Request No 40: Admit that the document attached as exhibit 13 is a true and correct copy of an SIA form entitled "Non-SIA flying hours and sectors", in which XXX was requested by SIA to verify P1u/s sectors by providing a letter from his previous employer confirming that XXX had flown the number of handling sectors under supervision.
Request No. 41: Admit that the document attached as exhibit 14 is a true and correct copy of the FAM, Line Operations, Cockpit visits, page 3.30.1, march 15, 1998.
Request No. 42: Admit that the document attached as exhibit 15 is a true and correct copy of the FAM, Security, page 4B.1.7, 15 January 1999.
Request No. 43: Admit that the photograph attached as exhibit 16 accurately depicts a typical cockpit door lock on any of SIA's B747-400.
Request No. 44: Admit that the SIA document attached as exhibit 17 is true and correct copy of a B744 Megaflash 21, page 8 of 10, April 1999, relating to Improved Flight Deck Door Lock (B).
Request No. 45: Admit that the photograph attached as exhibit 18 accurately depicts the compartment holding oxygen masks in the flight crew bunkroom of SIA's B747-400, and admit that the oxygen compartment illustrated in the photograph is not a "quick doning" type oxygen mask.
Request No. 46: Admit that the document attached as exhibit 19 through 21, respectively, are true and correct copies of SIA Boeing 747-400 Operations manual, Oxygen systems, Page 11.20.04, September 2, 1993; SIA Boeing 747-400 operations manual, Oxygen systems diagram, page 11.20.05, October 3, 1994; and SIA Boeing 747-400 Operations Manual, Emergency Equipment Location (Flight/Upper Deck and Overhead crew Rest), page 11.20.09, October 1, 1996.
Request No. 47: Admit that the document attached as exhibits 22and 23, respectively, are true copies of SIA's Boeing 747-400 Operations manual, Standby bus, page 10.20.06, April 3, 1995; and SIA's Boeing 747-400 Operations manual, Standby bus, page 10.30.02, may 6, 1994.
Request no. 48: Admit that the document attached as exhibit 24 is a true and correct copy of SIA's June 18, 1992 letter to XXX, offereing XXX employment with the airline.
Request No. 49: Admit that upon successful completion of XXX's probation, and confirmation of his appoinment, his general conditions of service were as set out in the 1988 ALPA-S Agreement, and any succeeding agreement thereto.
Request No. 50: Admit that the document attached as exhibit 25 is a true and correct copy of the 1995 ALPA-S Agreement.
Request No. 51: Admit that under the 1995 ALPA-S Agreement, a First Officer who passed or was granted exemption from complete ATPL examination was to be granted a salary increase of $150 by SIA.
Request No. 52: Admit that SIA did not pay and additional $150 to XXX in salary and other monetary items (including, without limitation, 13th month salary or annual bonuses) payable to a First Officer who passes or is granted exemption from the complete ATPL examination.
Request No. 53: Admit that the SIA document attached as exhibit 26 is a true and correct copy of document no. 000381 produced by SIA in the case of Singapore Airlines Limited v. Michael John DeMarco, (No. C96-5858FDB), in which B-747 Conversion Training is listed as "(restricted)".
More to follow.
Request No. 31: Admit that a co-pilot operating in the capacity of "P2" or "P1u/s" is under the supervision of the Captain, and "P3" is a pupil pilot (also known a spilot under training).
Request No. 32: Admit that the document attached as exhibit 8 is a true copy of the FAM, page 2.19.4, Logging of Hours/Sectors, 1 march 1990.
Request No. 33: Admit that according to CFR 129.15, Flight crewmember certificates, a flight crewmember is required to hold a current certificate or license issued or validated by the country in which that aircraft is registered, showing his ability to perform his duties connected with operating that aircraft.
Request No. 34: Admit that the document attached as exhibit 9 is a true and correct copy of the FAM, Line Operations, Cockpit seats/A340 crew rest Facility, page 3.39.1, 15 march 1998.
Request No. 35: Admit that under the provisions of FAM, page 3.40.1, First Officer Route Flying, 15 December 1995 (attached as exhibit 10), during 3-pilot crew operations, the Commander is not allowed to take inflight relief in the passenger cabin or the flight crew rest facility bunkroom.
Request No. 36: Admit that during XXX's employment at SIA, there was no provision in the FAM requiring XXX or other First Officers to occupy the left-hand seat of the B-747.
Request No. 37: Admit that according to the SIA reports regarding Technical Crew Hours attached as exhibit 11, XXX had "P1: 530, P2: 544, HRS: 806" from commercial flying experience previous to employment at SIA.
Request No. 38: Admit that the document attached as exhibit 12 are true and correct copies of the FAM, Minimum Qualifications for Promotions, pages 2.19.1 and 2.19.2, 15 January 1999.
Request No. 39: Admit that according to exhibit 12, a number of sectors and/or hours in exhibit 11 was credited to XXX for commercial flying experience previous to his employment at SIA.
Request No 40: Admit that the document attached as exhibit 13 is a true and correct copy of an SIA form entitled "Non-SIA flying hours and sectors", in which XXX was requested by SIA to verify P1u/s sectors by providing a letter from his previous employer confirming that XXX had flown the number of handling sectors under supervision.
Request No. 41: Admit that the document attached as exhibit 14 is a true and correct copy of the FAM, Line Operations, Cockpit visits, page 3.30.1, march 15, 1998.
Request No. 42: Admit that the document attached as exhibit 15 is a true and correct copy of the FAM, Security, page 4B.1.7, 15 January 1999.
Request No. 43: Admit that the photograph attached as exhibit 16 accurately depicts a typical cockpit door lock on any of SIA's B747-400.
Request No. 44: Admit that the SIA document attached as exhibit 17 is true and correct copy of a B744 Megaflash 21, page 8 of 10, April 1999, relating to Improved Flight Deck Door Lock (B).
Request No. 45: Admit that the photograph attached as exhibit 18 accurately depicts the compartment holding oxygen masks in the flight crew bunkroom of SIA's B747-400, and admit that the oxygen compartment illustrated in the photograph is not a "quick doning" type oxygen mask.
Request No. 46: Admit that the document attached as exhibit 19 through 21, respectively, are true and correct copies of SIA Boeing 747-400 Operations manual, Oxygen systems, Page 11.20.04, September 2, 1993; SIA Boeing 747-400 operations manual, Oxygen systems diagram, page 11.20.05, October 3, 1994; and SIA Boeing 747-400 Operations Manual, Emergency Equipment Location (Flight/Upper Deck and Overhead crew Rest), page 11.20.09, October 1, 1996.
Request No. 47: Admit that the document attached as exhibits 22and 23, respectively, are true copies of SIA's Boeing 747-400 Operations manual, Standby bus, page 10.20.06, April 3, 1995; and SIA's Boeing 747-400 Operations manual, Standby bus, page 10.30.02, may 6, 1994.
Request no. 48: Admit that the document attached as exhibit 24 is a true and correct copy of SIA's June 18, 1992 letter to XXX, offereing XXX employment with the airline.
Request No. 49: Admit that upon successful completion of XXX's probation, and confirmation of his appoinment, his general conditions of service were as set out in the 1988 ALPA-S Agreement, and any succeeding agreement thereto.
Request No. 50: Admit that the document attached as exhibit 25 is a true and correct copy of the 1995 ALPA-S Agreement.
Request No. 51: Admit that under the 1995 ALPA-S Agreement, a First Officer who passed or was granted exemption from complete ATPL examination was to be granted a salary increase of $150 by SIA.
Request No. 52: Admit that SIA did not pay and additional $150 to XXX in salary and other monetary items (including, without limitation, 13th month salary or annual bonuses) payable to a First Officer who passes or is granted exemption from the complete ATPL examination.
Request No. 53: Admit that the SIA document attached as exhibit 26 is a true and correct copy of document no. 000381 produced by SIA in the case of Singapore Airlines Limited v. Michael John DeMarco, (No. C96-5858FDB), in which B-747 Conversion Training is listed as "(restricted)".
More to follow.