u. s. DEPARTMENT oF TRANSPORTATimR E C E IV ED 

FEDERAL AVIATION ADMINISTRATION 

OFFICE OF HEARINGS 

WASHINGTON, DC 

FEB 2 6 2013 

HEARING DOCKET 

In the Matter of: 

Martinaire Aviation, LLC 

Respondent 

JUDGE GOODWIN 

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FAA DOCKET No. FAA-2013-0040 

FAA Case No.2011SW700189 

(Civil Penalty Action) 

FDMS No. FAA-2013-0040 

JOINT MOTION TO EXTEND TIME FOR DISCOVERY 

NOW COMES the Federal Aviation Administration (hereinafter 

"FAA") and Martinaire Aviation, LLC pursuant to Rule 217 of the 

Rules of Practice in FAA Civil Penalty Actions, 14 C.F.R. § 217, 

Joint Procedural or Discovery Schedule and hereby request the 

Administrative Law Judge to extend the discovery deadline to 

June 5, 2013. In support of this joint motion the parties state 

the following: 

1. Under Judge Goodwin's Procedural Order discovery closes on 

April 5, 2013. The agency attorney, James Archier, and counsel 

for the Respondent held a telephone conference on February 25, 

2013 to discuss various discovery issues. The parties agreed 

that additional time is necessary to reschedule complainant's 

pending depositions and to complete other discovery, including 

interrogatories, request to produce and request to admit facts. 

2. The parties request a new discovery closure date of June 5, 

2013. Repondent's attorney, his client and witnesses will not 

be available on the following dates: 

March 20-April 15, 2013 

April 29-May 3, 2013 

June 5-15, 2013 

July 3-7, 2013 

August 1,-September 5, 2013 

September 23-28, 2013 

October 30-November 3, 2013 
3. On February 14, 2013, the FAA noticed the depositions of 

Cory Smith and Michael Bates for March 7, 2013 and March a, 

2013. The witnesses are unavailable on these dates and the 

alternative dates respondent proposed are not convenient for the 

FAA attorney because of scheduled preparations for witnesses in 

upcoming depositions during the month of March. 

4. A discovery closure date of April 5, 2013 would create 

hardship for the clients of both attorneys. 

WHEREFORE, the attorney for the Federal Aviation Administration 

and the attorney for Martinaire jointly request that the 

Administrative Law Judge enter an Order extending the discovery 

closure date to June s, 2013. 

Respectfully submitted this 25~ day of February, 2013. 

ERIC E. ANDERSON 

Regional Counsel 

Southwest Region 

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Aviation, LLC 

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CERTIFICATE OF SERVICE 

Re: Martinaire Aviation, LLC, FAA Case No. 2011SW700189 

I hereby certify that on this date, I have sent via Federal 

Express an executed original and one copy of the Joint Motion to 

Extend Time for Discovery, addressed as follows: 

Federal Aviation Administration 

Attention: Hearing Docket, AGC 430 

600 Independence Avenue, SW 

Washington DC 20591 

Wilbur Wright Building-Suite 2W1000 

Washington, DC 20591 

(original plus one copy) 

(Federal Express) 

I further certify that on this date, I have sent via 

Federal Express a true copy of the Joint Motion to Extend Time 

for Discovery, addressed as follows: 

The Honorable Richard C. Goodwin 

Administrative Law Judge 

Office of Hearings, M-20 

Department of Transportation 

1200 New Jersey Avenue, S.W. 

Washington, DC 20590 

FAX: (202) 366-7536 

(FAX and Federal Express) 

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I further certify that on this date, I have sent via 

Federal Express a true copy of the Joint Motion to Extend Time 

for Discovery addressed as follows: 

Mr. Michael L. Dworkin and Associates 

Law Offices 

465 California Street, Suite 210 

San Francisco, California 94104-1808 

(Federal Express) 

ERIC E. ANDERSON 

Regional Counsel 

Southwest Region 

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Dated February 25, 2013