LAW OFFICES OF 

RICHARD G. NOVAK 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, DC 20591 

June 3, 2015 

ATTN: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building, Suite 2W1000 

Lierre Green, Esq. 

Office of Regional Counsel, A WP-7 .3 

Western-Pacific Region 

Federal Aviation Administration 

P.O. Box 92007 

Los Angeles, CA 90009-2007 

Hon. Richard C. Goodwin, Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. (E11-310) 

Washington, DC 20590 

Stefan Eric Sacks, Esq. 

1901 Avenue of the Stars, Suite 200 . 

Los Angles, CA 90067 

Re: Arash Durrani- Docket No. FAA 2015 -0209 

Dear Judge Goodwin, Ms. Green, and Mr. Sacks, 

65 N. Raymond Ave., Suite 320 

Pasadena, CA 91 I 03 

RECEIVED 

JUN 0 9 2015 

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 Order to Show Cause required Mr. Durrani to take certain actions by May 

8, 2015. I have not previously 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 represent him in this matter. Mr. Durrani retained me to represent him 

only in· post-conviction proceedings in a federal criminal matter in the Central 

District of California, and for no other purpose. 

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 911 03 

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 of Hearings. Of course, I would have then timely responded to the Order to 

Show Cause. 

I did receive a telephone call from Ms. Green a number of weeks ago after Mr. Sacks 

made the same misrepresentations to her that he has made in his letter of May 25. I 

explained to her that I was not retained by Mr. Durrani to represent him in this 

action. Shortly thereafter, Mr. Sacks sent me, 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 created by Mr. Sacks' misrepresentations. 

Respectfully submitted, 

Richard G. Novak 

cc: Arash Durrani 

626-5y8-n75 (Phone) - 626-685-2562 (Fax) - richard@rgnlaw.com 
LAW OFFICES OF 

RICHARD G. NOVAK 

Mr. Arash Durrani 

cfo Ash@webpr.com 

Dear Mr. Durrani, 

March 20, 2015 

65 N. Raymond Ave., Suite 320 

Pasadena, CA 91 I 03 

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. Thank you for your trust 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 of proceeding with this agreement. 

The client agrees to restore the trust balance to $5,000 at the end of each 

monthly billing 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, court reporting charges, and travel 

expenses. The Client agrees to be responsible 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 of the 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 of any written objection to an invoice within 72 hours 

after receipt, the Client will be deemed to have accepted and acknowledged the 

invoice as correct for the period covered by that invoice. 

626-syS-nys (Phone) - 626-685-2562 (Fax) - richard@rgnlaw.com 
LAW OFFICES OF 

RICHARD G. NOVAK 

Confidentiality; Other Ethical Obligations 

65 N. Raymond Ave., Suite 320 

Pasadena, CA 91 I 03 

This Firm takes very seriously all of its ethical obligations under the 

ethics rules of California and the other jurisdictions in which we practice law. 

These obligations include the Firm's ethical duty to maintain the confidential 

nature of its clients' activities. 

Conflict of Interest 

Our representation of you in any matter must be conditioned upon there 

being no existing conflict of interest with any party having 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 such party. 

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 right to 

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 of our 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 and payable. 

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. If you 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 relief in 

the form of damages, 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 of the amount of fees properly chargeable to you, if any. 

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

RICHARD G. NOVAK 

Disclaimer of Guarantee 

65 N. Raymond Ave., Suite 320 

Pasadena, CA 91 I 03 

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 of your matter are expressions of 

opinion only. If we should provide you with an estimate of the 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 

what the maximum amount of fees and/ or costs will be. 

Future Matters 

Unless otherwise agreed in writing between us, all other matters referred 

to us for representation shall be governed by the terms of this Agreement. 

Client 

The Firm's client for the purpose of our representation is only the person 

or entity identified in this Agreement. Unless expressly agreed, we are not 

undertaking the representation of any related or affiliated person or entity, nor 

any of their 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 

for which we are engaged in a responsive and efficient manner. 

By 

LAW OFFICES OF RICHARD G. NOVAK 

Digitally signed by Richard Novak 

ON: cn=Richard Novak, o, ou=law Offices of Richard 

G. Novak, ema!t=rlchard.rgnlaw@gmall.com, c=US 

Richard G. Novak 

The undersigned understands and agrees to the terms of the engagement set 

forth in this letter and agrees to be bound by such terms. 

Dated: _______ _ 

Arash Durrani 

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