# FlECEIVED AUG 03 2015 

## I IEARING DOCKET Mink & 

### Duke, PLLC

Honorable Judge J.E. Sullivan Office ofHearing M-20 US Department ofTransportation July 28, 2015

1200 New JerseyAvenue S.E. (E-11-310) Washington, D.C. 20590 Federal Aviation Administration Attention Hearing Docket Clerk, AGC-430 Wilbur Wright Building- Suite 2Wl000 800 Independence Avenue, S.W. Washington, D.C. 20591

DearJudge Sullivan: RE: SmyrnaAir Center-FAA Issues DocketNo. 2011CE190020 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 providingherewith, for filing, an Agreed Written Request Amending Scheduling Order Dates. I amalso enclosing a copy ofthisAgreed Written Request, which Iwould appreciate you stamping "filed" andreturning in the enclosed, self-addressed, stamped envelope. In addition, I am providing herewith, for filing, the OrderAmendingLitigation Dates. As with the Request, I am enclosing an extra copy of this Order, which I would appreciate you stamping "filed" andreturning in like fashion. Bycopy ofthis letter, I am advising FAA counsel, Ryan Landers, ofthe actions taken. If youhave any questions regarding myrequest, please do not hesitate to give me a call.

Nashville • LawrenceburgJuly 28, 2015 

### P" g e 

### 12

With kindestregards, I remain

WML/cp Cc: Ryan Landers Very truly yours, MINK & DUKE, PLLC

# By:~· William M. Leech

Nashville • LawrenceburgU.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 inthis 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 completedby November 6, 2015. 3. Dispositive Motions- November 16'h will be deadline for the filing ofdispositive motions, ifany, with all responses due by November 24'11• ifany. Replybriefs, ifany, shall be due no later than November 30'h.

14. All other dates and schedules will remain unaffected by entry ofthis Order.
WHEREFORE, PREMISES CONSIDERED, the pru1ies pray that this Court approve for entrythe 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

2CERTIFICATE 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 ofRegional Counsel, AS0-7 Southern Region1701 Columbia Avenue College Park, GA 30337 Hon. J.E. Sullivan, Administrative Law Judge Office ofHearings, 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-Suite2Wl000 800 Independence Avenue, S.W. Washington, DC 20591 Onthe.t'J'r'ayof

# J~ ,2015.

# h/~4;'-~A_ Thomas F. Mink, II ' Charles M. Duke William M. Leech, III



### 3FEDERALAVIATION ADMINISTRATION, Complainant, 

### v. U.S. DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS FEDERAL AVIATION ADMINISTRATION

FAA Docket No. 2014-0685 JudgeJ.E. Sullivan SMYRNA AIR CENTER ) ) ) ) ) ) ) ) ) Respondent
ORDER AMENDING LITIGATION DATES Theparties, after

**confen~ng** andjointlyrequesting that this Court adjust the litigation dates finds the Motion well taken. Itis 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 ofdispositive motions with all responses due by November 24'11• Anyreplies shall be due no laterthan 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