FlECEIVED 

AUG 0 3 2015 

I IEARING DOCKET 

Mink & Duke, PLLC 

Honorable Judge J.E. Sullivan 

Office of Hearing M-20 

US Department of Transportation 

July 28, 2015 

1200 New Jersey Avenue S.E. (E-11-310) 

Washington, D.C. 20590 

Federal Aviation Administration 

Attention Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2Wl 000 

800 Independence Avenue, S.W. 

Washington, D.C. 20591 

Dear Judge Sullivan: 

RE: Smyrna Air Center-FAA Issues 

Docket No. 2011 CE190020 

Our File No: SAC-2404 

William M. Leech 

P.O. Box 198742 

219 Second Avenue North, Suite 400 

Nashville, TN 372!9~8742 

Phone: (615)256-0138 

Fax: (615) 730-5997 

\dC-CCll@Iiih1kdukehm·.conJ 

As you know, we are representing the Respondent, Smyrna Air Center, in this matter. I 

am providing herewith, for filing, an Agreed Written Request Amending Scheduling Order Dates. 

I am also enclosing a copy ofthis Agreed Written Request, which I would appreciate you stamping 

"filed" and returning in the enclosed, self-addressed, stamped envelope. 

In addition, I am providing herewith, for filing, the Order Amending Litigation Dates. As 

with the Request, I am enclosing an extra copy of this Order, which I would appreciate you 

stamping "filed" and returning in like fashion. 

By copy of this letter, I am advising FAA counsel, Ryan Landers, of the actions taken. If 

you have any questions regarding my request, please do not hesitate to give me a call. 

Nashville • Lawrenceburg 
July 28, 2015 

P" g e 12 

With kindest regards, I remain 

WML/cp 

Cc: Ryan Landers 

Very truly yours, 

MINK & DUKE, PLLC 

By:~· 

William M. Leech 

Nashville • Lawrenceburg 
U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

FEDERAL AVIATION 

ADMINISTRATION, 

) 

) 

) 

) 

) 

) 

) 

) 

) 

Complainant, 

v. 

FAADocketNo. 2014-0685 

Judge J .E. Sullivan 

SMYRNA AIR CENTER 

Respondent 

AGREED WRITTEN REQUEST AMENDING SCHEDULING ORDER DATES 

Comes now the respondent in the matter, Smyrna Air Center, by and through undersigned 

counsel and states unto the Court, that the parties have conferred in this matter and have agreed 

to adjust the litigation dates as follows: 

1. Expert Disclosure dates- Complainant will disclose their expert no later than 

October 1, 2015 and respondent shall disclose their expert on October 9, 2015. 

2. Deposition dates- All fact witnesses' depositions and expert deposition shall be 

completed by November 6, 2015. 

3. Dispositive Motions- November 16'h will be deadline for the filing of dispositive 

motions, if any, with all responses due by November 24'11 • if any. Reply briefs, if any, shall be 

due no later than November 30'h. 

1 
4. All other dates and schedules will remain unaffected by entry of this Order. 

WHEREFORE, PREMISES CONSIDERED, the pru1ies pray that this Court approve for 

entry the attached order amending the litigation dates in this matter. 

Respectfully submitted, 

MINK & DUKE, PLLC 

~~~~ Thomas F. Mink, II, BPR 006067 

Charles M. Duke, BPR # 23607 

William M. Leech, III, BPR# 30515 

P.O. Box 198742 

Nashville, Tennessee 37219-8742 

(615) 256-0138 

. (615) 730-5997 Fax 

tmink@minkdukelaw.com 

mduke@minkdukelaw .com 

wleech@minkdukelaw.com 

2 
CERTIFICATE OF SERVICE 

The undersigned certifies that the foregoing motion was sent via U.S. Mail and electronic 

mail to the following: 

Mr. Ryan M. Landers, Complaint's Counsel 

Federal Aviation Administration, 

Office of Regional Counsel, AS0-7 

Southern Region 1701 Columbia A venue 

College Park, GA 30337 

Hon. J.E. Sullivan, Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department ofTranspotiation 

1200 New Jersey Avenue, S.E. (E-11-310) 

Washington, DC 20590 

Federal Aviation Administration 

Attention Hearing Docket Clerk, AGC-430 

Wilbur Wright Building-Suite 2Wl 000 

800 Independence Avenue, S.W. 

Washington, DC 20591 

Onthe.t'J'r'ayof J~ ,2015. 

Thomas 

h/~4;'-~A_ F. Mink, II ' 

Charles M. Duke 

William M. Leech, III 

3 
FEDERAL AVIATION 

ADMINISTRATION, 

Complainant, 

v. 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

FAA Docket No. 2014-0685 

Judge J.E. Sullivan 

SMYRNA AIR CENTER 

) 

) 

) 

) 

) 

) 

) 

) 

Respondent ) 

ORDER AMENDING LITIGATION DATES 

The parties, after confen~ng and jointly requesting that this Court adjust the litigation 

dates finds the Motion well taken. 

It is hereby ORDER, ADJUDGED, and DECREED that the Order settling litigation dates and 

procedures is hereby amended such that: 

1. Expert Disclosqre dates - Complainant will disclose their expert no later than 

October I, 2015 and respondent shall follow with October 9, 2015 as their expert disclosure 

deadline. 

2. Deposition dates- All fact witnesses' depositions and expert deposition shall be 

completed by November 6, 2015. 

3. Dispositive Motions- November 16tl' will be deadline for the filing of dispositive 

motions with all responses due by November 24'11 • Any replies shall be due no later than 

November 30'h. 
4. All other dates and schedules will remain unaffected by entry of this Order. 

Entered this, the-~· day of~-----' 2015. 

JUDGE J.E. SULLIVAN 

US Administrative Law Judge