~ 1llsour~ Pillsbury Winthrop Shaw Pittman LLP 

2300 N Stree-t, NW 1 W~shington, DC 20037-1122 I tel202.663.8000 I fax 202.663.8007 

September 4, 2014 

VIA FEDERAL EXPRESS AND FACSIMILE 

Hearing Docket 

Federal Aviation Administration 

Attn: Hearing Docket Clerk, AGC~430 

Wilbur Wright Building, Suite 2W1 000 

800 Independence Avenue, SW 

Washington, DC 20591 

FAJ<: 202-493-5142 

Rebecca Carr Rizzo 

tel202.663.9143 

rebecca.rizzo@pillsburylaw.com 

Re: Respondent's Motion to Extend Discovery Deadline 

FAA Case No. 2012CE430011 

To Hearing Docket Clerk: 

Enclosed herein please find the original and one copy of Respondent Learjct, Inc.'s 

Motion to Extend Discovery Deadline in the above-referenced proceeding. The 

Administrator has taken no position on this Motion. 

wvvw.pillsburylaw.com 501447148v1 
UNITED STATES DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASIIINGTON, DC 

IN THE MATTER OF 

Served: September 4, 2014 

FAADocketNo. CP10CE0003 

DMS No. FAA-2014-0113 

FAA Case No. 2012CE430011 

LEARJET, INC. 

Judge: Richard C. Goodwin 

LEARJET, INC.'S MOTION TO EXTEND DISCOVERY DEADLINE 

Pursuant to 14 C.P.R. §§ 13.213, 13.218 and the Amended Procedmal Order in this 

matter, Respondent Learjet, Inc. ("Lcarjct"), by counsel, respectfblly moves the Administrative 

Law Judge for an extension of the discovery deadline from September 26,2014, to October 24, 

2014, stating as follows: 

1. Learjet previously requested, a11d the Administrative Law Judge granted, an 

extension of the discovery deadline in this case to September 26, 2014, to penni! tht; patiies 

sufficient time to complete and review the written discovery prior to the depositions in this case. 

2. After receipt of the Amended Procedural Order on June 25, 2014, counsel for 

Learjet worked with co1.msei for Complainant to :find mutually-agreeable deposition dates. On 

July 16,2014, Learjet noticed the depositions in this matter for August 25-27, 2014, after 

learning that earlier proposed dates were difficult for one of the Complainant's witnesses. 

3. Within several weeks, however, Learjet's lead counsel, Kenneth Quim1, 

encountered three unavoidable conflicts with these August deposition dates. First, in his 

capacity as General Com1sel of the Flight Safety Foundation ("FSF"), on August 1, 2014, he was 

appointed to the International Civil Aviation Organization ("ICAO") Task Force on Regional 

Conflict Zones, now chaired by his client, FSF Chainnan David McMillan. Supporting this effort 

5014469llvl 
and travelling to/from Montreal in August consumed significant time. Second, on August 6, 

2014, Mr. Quinn was called upon to go to Tokyo and Kyoto from August 19 to 25,2014, for 

meetings with his client GS Yuasa, the battery manufactmer, in connection with the final reports 

of the JTSB and NTSB on the B787 incidents and grounding. Third, on August 14,2014, Mr. 

Quinn was appointed to an Experts Committee for the new Shanghai lntemational Aviation 

Court of Arbitration, and asked to attend its inaugural ceremony and first meeting in Shanghai on 

August 27-28, 2014, which directly conflicted with tl1e deposition dates. In light oftl1ese 

conflicts, Leatjet was forced to cancel the August depositions. 

4. On August 7, 2014, Leatjet's counsel reached out to counsel for Complainant to 

advise him oftl1ese conflicts and to request, for the first time, that the depositions be 

rescheduled. On August 29, 2014, Learjet re-noticed tl1e depositions for September 10-12,2014. 

However, on September 2, 2014, com1sel for the Complainunt notifted counsel for Lealjet that he 

atld two of the deponents were unavailable on those dates. 

5. Despite their best efforis, the parties have been unable to find mutually-agreeable 

alternative dates for the depositions plior to tl1e September 26,2014 discovery deadline, Learjet, 

however, has been able to confirm that the parties, ccunscl, and the deponents are all available 

for depositions on October 6-8, 2014. 

6, To provide Lcatjct the opportunity take tl1e depositions ofthe three witnesses 

identified by the Complainant in advance of the healing on dates agreeable to both the pariies 

and the deponents themselves and to provide two additional weeks of discovery in the event that 

any discovery issues arise at the depositions, Learjet requests that the discovery deadline be 

postponed by four weeks. 

2 

501446911 vl 
WHEREFORE, Learjet respectfully requests that the discovery deadline be extended 

from September 26,2014, to October 24,2014, 

Dated: September 4, 2014 

3 

5014469llvl 

By:l~J-~- PILLSBURY WINTHROP SHAW 

P!TTMANLLP 

2300 N Street, NW 

Washington, DC 20037-1122 

(202) 663-8898 

Fax: (202) 663-8007 

Counsel fi;r Lemjet, Inc, 
CERTIFICATE OF SERVICE 

I hereby cettify that the foregoing Motion has been sent via facsimile and Federal Express to the 

following recipients: 

The Honorable Richard C. Goodwin 

U.S. Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Je1·sey Avenue, S.E. (Ell-31 0) 

Washington, DC 20590 

Attn: Patricia Matthews 

FAX: 202-366-7536 

David Kessler 

Federal Aviation Administration 

901 Locust Street, Room 506 

Kansas City, MO 64106 

(816) 329-3763; Fax (816) 329-3771 

Counsel for Complainant 

I fmther certify that the original Motion, and one copy thereof, was sent by Federal Express and 

one copy by facsimile to the following recipient: 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Attention: Heming Docket Clerk, AGC-430 

Wilbur Wright Building, Suite 2Wl 000 

FAX: 202-493-5142 

Dated this 4th day of September, 2014 

50l4469l!vl 

4 
Pillsbury Winthrop Shaw Pittman LLP 

2300 N Street. NW 1 Washington. DC 20037-11221 tel 202.663.8000 I fax 202.663.8007 

Date: 

To: 

From: 

Subj: 

Total 

September 04, 07:04:07 PM EDT 

12024935142 

kathleen.husoskey@pil1sburylaw.com 

Fax for Hearing Docket Clerk, AGC 

pages: 7 

430 

FACSIMILE 

Attached please find a fax from Rebecca Carr Rizzo in connection with FAA Case No. 2012CE430011. 

Kathleen A. Husoskey I Pillsbury Winthrop Shaw Pittman LLP 

Legal Secretary 

2300 N Street, NW 1 washington, DC 20037-1122 

t 202.663.8175 1 f 202 sn azs3 

kathleen.husoskey@pillsburylaw.com I pillsburylaw.com 

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Total Pages (Including cover): 6 

Date: September 4, 2014 Must Be Sent By: 

To: Hearing Docket Clerk, AGC Fax No 

430 

Company: FAA Phone No: 

Confirm: Confirmed By: 

From: Rebecca Carr Rizzo Phone No: 

Email: rebecca.rizzo@pillsbur~ylaw.com Fax No: 

User No: 54632 CIM No: 

Comments: See attached Updated Deposition Notices 

Re: FAA Case No. 2012CE43001 l 

202-493-5142 

202.663.9143 

202.663.8007 

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