LAW OFFICES OF RICHARD G. NOVAK



### FederalAviationAdministration 800 Independence Avenue, S.W. Washington, DC 20591 June 3, 2015

ATTN: Hearing Docket Clerk, AGC-430 WilburWrightBuilding, Suite 2W1000 Lierre Green, Esq. Office ofRegional Counsel, A WP-7.3 Western-Pacific Region FederalAviationAdministration P.O. Box 92007 LosAngeles, CA 90009-2007 Hon. Richard C. Goodwin, Administrative LawJudge Office ofHearings, M-20 U.S. DepartmentofTransportation 1200 NewJerseyAvenue, S.E. (E11-310) Washington,DC 

### 20590 StefanEric Sacks, Esq. 1901 Avenue ofthe Stars, Suite 200
. LosAngles, CA 90067 Re: Arash Durrani- DocketNo. FAA 2015 -0209 DearJudge Goodwin, Ms. Green, and Mr. Sacks, 65 N. Raymond Ave., Suite 320 Pasadena, CA 91 I03 

# RECEIVED JUN 092015 

## HEARING DOCKET

I write in response to Mr. Sacks' letter dated May 25, 2015 concerning the abovecaptioned matter. Mr. Sacks' letter was accompanied by an 

### Order to Show Cause issued by Judge Goodwin. Wh1le the 

### Order to Show Cause 1s not dated, it app<Oar""'s--- that it was served on the parties and counsel of record m th1s actwn on

**7\p"'r>liil-,.,2'77~,**

### --- 2015. The 

### Orderto Show Causerequired Mr. Durrani to take certain actions by May 8, 2015. I have notpreviously s.een this

### Order. • Mr. Sacks' letter represents that I am Mr. Durrani's attorney in this action. This is not correct. While I did substitute for Mr. Sacks in a separate federal criminal proceeding, I have 11ever entered an appearance in this action. I have never informed Mr. Sacks that I would enter. an .appearance in this matter. Nor did Mr. Durrani retain me to representhim in thismatter. Mr. Durraniretained me to representhim only in· post-conviction proceedings in a federal criminal matter in the Central DistrictofCalifornia, and for no otherpurpose.

626-578-1175 (Phone) - 626-685-2562 (Fax) - richard@rgnlaw.com

# .A~ LAW OFFICES OF


# ., 1 r



# ~ RICHARD G. NOVAK 65 N. Raymond Ave., Suite 320 Pasadena, CA 91103


### If he had retained me to represent him in this proceeding, I would have personally notified Mr. Sacks of that, I would have prepared a substitution of attorney for this action as well, I would have as.ked Mr. Sacks to sign it and I would have filed it with the Office ofHearings. Ofcourse, I would have then timely responded to the 

### Orderto Show Cause. 

### I did receive a telephone call from Ms. Green a number ofweeks ago after Mr. Sacks made the same misrepresentations to her thathe has made in his letter ofMay 25. I explained to her that I was not retained by Mr. Durrani to represent him in this action. Shortlythereafter, Mr. Sacks sentme, unsolicited, what appears to be his file concerning this matter. · With this letter, I am returning those documents to him so that he can continue to represent Mr. Durrani in this matter or take whatever actions are necessary in order to be relieved as counsel, if that is appropriate. A copy of Mr. Durrani's retainer agreement with my office is also enclosed. I hope that this letter resolves any confusion createdbyMr. Sacks'misrepresentations. Respectfully submitted,

Richard G. Novak

cc: Arash Durrani

626-5y8-n75 (Phone) - 626-685-2562 (Fax) - richard@rgnlaw.comLAW OFFICES OF RICHARD G. NOVAK

Mr. Arash Durrani cfo Ash@webpr.com DearMr. Durrani, March 20, 2015 65 N. Raymond Ave., Suite 320 Pasadena, CA 91 I03

We (the Firm) have prepared this Engagement Letter to set forth the terms under which you (the Client) would engage us to represent you in a federal post-conviction criminal proceeding currently pending in the United States District Court, United States v. Arash Durrani, Case No. SA CR 12-242- DOC. Thankyou foryourtrust and confidence. Legal Fees and Retainer For this matter, the Firm will charge an hourly rate for the services of senior attorney Richard Novak at $500 per hour, billed in 1/10 of an hour allotments. We require payment of a refundable $5,000 retainer deposit, which shall be held in trust, as a condition ofproceeding with this agreement. The client agrees to restore the trust balance to $5,000 at the end of each monthlybilling cycle. Disbursements In addition to fees for services rendered, our Firm may incur or advance out-of-pocket costs that we believe are reasonably necessary for the proper handling of the matters for which we are engaged. Such costs may include photocopying, electronic transmission and long distance telephone charges, airfreight charges, title and recording fees, courtreporting charges, and travel expenses. The Client agrees to beresponsible for these costs.
nvmces Invoices for costs incurred and services rendered by our Firm will be submitted to the Client on a monthly basis (unless the amount ofthe invoice would be so small that we decide to defer billing it, or we have agreed to an alternate billing arrangement). All payments are due upon receipt of our invoices. In the absence ofanywritten objection to an invoicewithin 72 hours after receipt, the Clientwillbe deemed to have accepted and acknowledgedthe invoice as correctfor theperiod coveredbythatinvoice.

626-syS-nys (Phone)
- 626-685-2562 (Fax)
- richard@rgnlaw.comLAW OFFICES OF RICHARD G. NOVAK

Confidentiality; Other Ethical Obligations 65 N. Raymond Ave., Suite 320 Pasadena, CA 91 I03

This Firm takes very seriously all of its ethical obligations under the ethics rules of California and the otherjurisdictions in which we practice law. These obligations include the Firm's ethical duty to maintain the confidential nature ofits clients'activities. Conflict ofInterest Ourrepresentation ofyou in anymattermust be conditionedupon there beingno existing conflict ofinterest with any partyhaving an adverse interest, unless, under certain circumstances, the parties that are the basis for such conflict of interest are willing to give their informed written consent to our representation despite the existence of such conflict, and to waive, in writing, any actual or potential conflict of interest arising as a result of our representation in those matters. Neither the Firm nor the Client is aware of any suchparty. Rights to Terminate You have the right, at any time, for any reason or no reason at all, to terminate our services. The law provides that the Firm may terminate our services under certain circumstances. For instance, we shall have the rightto terminate your engagement of our Firm if our invoices for services rendered are not paid in a reasonably prompt manner. Prior to terminating your engagement ofour Firm, we shall give you not less than 15 days' prior notice. In the event of any termination, all sums owing by you to the Firm shall be then due andpayable. Disputes Under California law you have the right, if you desire, to request arbitration of any fee dispute befgre JlJl arbitrator

## _ox. panel of arbitrators selected by a local bar association or the State Bar (the "Bar Arbitration") and a trial de novo in court if dissatisfied with the result. Ifyou do request a Bar Arbitration, the law provides that evidence of any claim of malpractice or professional misconduct is admissible only concerning the fees or costs in dispute and that the Bar Arbitrators shall not award any affirmative reliefin the form ofdamages, offset or otherwise on account of such claim. By signing this Agreement, you agree that if a Bar Arbitration is conducted, that Bar Arbitration or any trial de novo in Court thereafter shall only determine the issue ofthe amount offees properlychargeable toyou, ifany.

626-578-1175 (Phone)

- 626-685-2562 (Fax)

- richard@rgnlaw.comLAW OFFICES OF RICHARD G. NOVAK

Disclaimer ofGuarantee 65 N. Raymond Ave., Suite 320 Pasadena, CA 91 I03

Nothing in this Agreement should be construed as a promise or guarantee about the outcome of any matter, which we are handling on your behalf. Our comments about the outcome ofyour matter are expressions of opinion only. Ifwe should provide you with an estimate ofthe fees and costs which may be incurred in connection with our representation of you, it is important that you understand and acknowledge that any such estimate is merely an estimate based on numerous assumptions which may or may not prove to be correct and that any estimate is not a guarantee or agreement of whatthe maximum amount offees and/or costs will be. FutureMatters Unless otherwise agreedinwritingbetweenus, all other mattersreferred to us for representation shallbe governedbythe terms ofthisAgreement. Client The Firm's clientfor the purpose ofourrepresentation is onlythe person or entity identified in this Agreement. Unless expressly agreed, we are not undertakingthe representation ofanyrelated or affiliatedperson or entity, nor anyoftheir shareholders, partners, officers, directors, agents, or employees. Miscellaneous This letter is the entire agreement between the Client and the Firm and may be amended only in a writing signed by the party to be charged with the amendment. Thank you again for choosing our Firm to represent and advise you. Please be assured that we will extend every effort to handle each matter forwhichwe are engaged in a responsive and efficientmanner.

By LAW OFFICES OF RICHARD G. NOVAK Digitallysignedby Richard Novak ON:cn=Richard Novak,o, ou=lawOfficesofRichard G. Novak,ema!t=rlchard.rgnlaw@gmall.com,c=US Richard G. Novak Theundersignedunderstands and agrees to the terms ofthe engagement set forth in this letter and agrees to beboundby suchterms. Dated: _______ _ Arash Durrani
626-578-1175 (Phone)
- 626-685-2562 (Fax)
- richard@rgnlaw.com