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Request to Compel Disclosure of Information

Motion raised to Administrative Review Board (ARB) of Department of Labor of United States of America.

This protected and lawful FAA whistleblower (Charles Shi) has been disclosing an extraordinary Boeing plane safety threat.

Some 500 Boeing planes were compromised due to knowingly installing counterfeit safety critical parts made in China.

Moog Aircraft top management committed a felony.

FAA massive cover-up

The worst of the scam is that the safety threat has not been removed so far, posing extreme risks to the life of flying public!

Moog Aircraft have been cheating everybody since day one of the scam. FAA was cheated, US DOL administrative law judge was cheated, journalists were cheated and flying public were also cheated, making the Boeing plane safety threat much more extraordinary and unprecedented.

Moog Aircraft willfully and knowingly concealed material fact of the fraud and crime, which I legally requested disclosure.

Below is the Motion raised to ARB of DOL 02/11/2017 which is not responded till this day.



Complainant (Petitioner), I (Charles Shi) ask leave for ARB order and compel Respondent to verify and disclose information on an extraordinary ground.

Respondent filed Opposition to my motion for compel disclosure dated 31/10/2017, refusing to verify citizenship of relevant Moog people and disclosure of critical information concerning the extraordinary air safety threat which was defrauded by Respondent, neglected by ALJ and gravely abused by FAA investigation process.

I ask for leave to compel disclosure, because:

1. Citizenship verification of Moog people

The request is raised only because ALJ made unfounded statement P. 29 “No Americans directed or effectuated his termination” in his dismissal Order, which is closing all ALJ process. Prior to that, there was no mention of citizenship of Moog people relevant and material to my AIR21 case either by ALJ or Respondent for such fact.
I had passport copies of all U.S. Moog Aircraft Group visitors to China between 2006-2015, just because I was the focal point of Moog Aircraft people applying Chinese visas. ALJ judge did not know this and that was why he made that unfounded statement to support his key reason for dismissal.

Pictures of US passports of Moog Aircraft people who are involved in the case — saved from public disclosure.

2. Critical information

The information sought is relevant material and extremely critical to determine the failure of FAA oversight and bigger fraud Moog willfully concealed during FAA investigation and ALJ discovery process. I was not aware of it before FAA reached violations of 2 out of 9 allegations substantiated on 4 November, 2016 and the report was not released to me until late December, 2016.

 According to ALJ, no more disclosure request could be granted, as the discovery was closed (See App Ex 12 ALJ order dated 10/01/2017). I had very detailed study of FAA 04/11/2016 report afterwards, only to realize the information I am requesting is critical and material on the failure of FAA oversight. 

For instance:

   One email, by SDE Ron Rong, contained very critical information regarding a list of NHJ outsourcing 11 Moog part numbers. This email is particularly sought, as it would rebut present Boeing misleading message to airlines' flying public that Moog "had already assessed these two issues and taken all necessary corrective actions" (per Reuter’s report). 

The fact is: 11 part numbers, thousands of piece parts of Suspected Unapproved Parts,many of them are safety sensitive were all on Boeing planes today.

The only necessary corrective action is to recall them all, because Moog and Boeing take flying public safety as their primary concern.

  Copies of following lot number GMT material certificates

  GMT lot number SE0583B3-12

  GMT lot number SD1850B2-10G

  GMT lot number SB2881C2-11

 GMT lot number SC282A5-10G

These GMT certificates would be evidence that there is no “accounting error” lied by Moog and accepted by FAA. The biggest violation I particularly paid attention to and requested of Moog, and Boeing as well, FAA also looked at closely. 

The violation was verified by my own investigation which badly was neglected and abused so far, but it is compromising some 500 Boeing B737 now in service.

GMT confirmation SC282A5-10G is not existent.

Exhibit now presented to ARB

Respondent acknowledged in its Opposition: ARB “can order an ALJ to reopen the record and receive evidence...” and Respondent knows exactly what I know, the information requested is relevant and material to the matter and case.

Therefore, I would appeal ARB grant my motion to compel disclosure for the sake of safety of all flying public, including our loved ones.
Yours sincerely,

Charles Shi (Chao-sheng)

Signed electronically by sending this file via email and EFSR.


I hereby certify that, on November 2, 2017, I electronically filed the motion via EFSR and send by email the foregoing motion to order and compel Ms. Donna M. Broome at [email protected], the paralegal specialist of DOL Administrative Judge Morris, and Respondent Moog counsel:

Jessica L. Copeland at [email protected]

No hard copy are mailed to Respondent, as its counsel agreed in an email dated 18/10/2017.

//s// Chaosheng Charles Shi

_____signed electronically_____


For more information, please contact:

[email protected]

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