03/11/2011 14 16 FAX 2024935142 

07/21/3011 6 15AK FAX 

FAA - OMS 21001/00 5 

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U.S. DE 

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Federal Aviation AdmlnljIratJon 

Charles Rate/, Cynthia Dominlk. Loura Ponfo, 

Peier Lynch, Lotonyo Wiiijams 

Complainants 

M 8. R HelicopteTS, LLC. 

Respondem 

Honorable Judge RIchaid Goodwin 

Docket : 2010-1211 

CERTIFICATE Or SERVICE 

I HEREBY CERTIFY that I have this day served the foregoing entrie(s}: 

MOTION FOR APPEAL AND RECONSIDERATION OF THE ORDER DENYING 

DEPOSITION OF LAURA PONTO AND 

LATONYA WILLIAMS 

upon all parties of record \r\ Ihis proceeding, in accordance wi^h the requirerr,ervls of Rv.ile 19 

pursuant to 28 U. S. C, § 1746 . 

Service by tirsf-class mail. DOs^aQe prepQid. addressed as follows: 

Pederai Aviation Administration 

800 Independence Avenue. SW 

Wilbur Wrighl Avenue-Suite 2W1000 

Washington, D.C, 20591 

Alt: Hearing Docket Clerlt. AGC-d30 

ly^FAX 202 493 5142 

Charles Rciiey 

Enforcement Divislon/AGC-SOO 

Office of the Chief Counsel 

FA A 

80Q independence Avenue, SW 

Washington, DC 20591 

^^A X 202 267 5106 

The Honorable f^Jichard C. Goodwin 

US Deportment of Transportation 

Office of Hearings. M-20, Room El 2-320 

1200 New Jersey Avenue. S.E. 

Washington, DC 20590 

^^A X 202 366 7536 

Michael B.^ellg, MD, FAC C 

2816 Orefield Road 

Allentown. Pa. 1810-^ 

610 360 3953 — ^ ,_ j i 

Dote: l^ri-\rr\\ 
08/11/2011 14 17 FAX 2024935142 

07/21/201 1 8- 15AM FAX 

FAA - DHS @|OO2/0O5 

§10002/0005 

Michael Selig, MD, FACC. CFI-H 

2816 Orefield Road 

Allentown, PA, 19104 

July 21 , 20 n 

U.S . DEPARTMEN T O F TRANSPORTATIO N 

OFFIC E O F HEARING S 

WASHINGTON , D.C. 

Federa l Aviation Administration 

Charles Raley, Laura Ponto, 

Latonya Williams 

Complainants 

V. 

M & R Helicopters, LLC. 

Respondent 

The Honorable Richard Ooodwin 

Dockets 2010.121 1 

MOTION FOR APPEAL AND RECOiySlDERATlON OF THE ORDER 

DENYING DEPOSITION OF LAURA PONTO AND 

LATONYA WILLIAMS 

AND NOW, comes respondent. MICHAEL B. SELIG, MD, FACC. 

CFT-H, principle for MR Helicopters, LLC, (MRH) (non-operational, at 

financial loss since 2007. regulation violations pursued rescinded 1 year 

prior to issuance of the civil penalty) whom avers and rcspectfvilly files 

the tbllowing Motion for Appeul and Reconsideration for Deposition of 

Laura Ponto and Latonya Williams under Rule s §13.22 5 and §13.234 in 

the place of venue. 

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1. On July 6, 2011, respondent emailed Mr Raley to determine if he was 

willing to close the case completely instead of incurring additional 

financial costs and addition transportation burden on the tax payers. 

2. This attempt to close the case as advised by the Honorable Judge 

Yoder was made in good faith, in addition to all the other arguments 

(non-operaiional, no income) against a reasonable, viable case other than 

a remote violation in theory, on the part of the agency. 

3. In addition it was further discovered that the 2 regulations that the 

agency was violating the respondent for: 135.251 and 135.255, were so 

confusing, inconsistent, contradictory and problematic that the FAA rule 

makers removed and rescinded these regulations on July 13. 2009. one 

year prior to complainants even filing their complaint against 

respondent, perhaps unbeknownst by the complainants {did not research 

the currency of the regulations cited) or lacking candor to the tribunal, in 

attempts to impair the dignity of the court. Since complainants arc not 

interested in closing this case the following persons are requested for 

depositions. 

4. On July 15. 2011, respondent Motioned for the Deposition of Latonya 

Williams and Laura Ponto. 

5. The Motions for Deposition as part of the courts requested entry of 

discovery, was Denied. 

6. The respondent requests that the Honorable Richard C. Goodwin 

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consider the following concerning Latonya Williams: 

a) ]t was Latonya Williams who traveled to the place of venue and 

jurisdiction to seek out tiic violation. 

b) It was solely based on Latonya Williaiins investigative work and 

other factors, that the violation theory was created. 

c) The sole correspondence for the first year wa s with Latonya 

Williams and shifting context and changing character of that 

violation. 

d) There arc questions concerning tht* credibility of Latonya Williams 

that may be essential to the case, 

c) Therefore, it is essential to respondent's defense to take testimony 

of Latonya Williams in order to establish and confirm the proper 

Fact Findings. 

7. The respondent requests that the Honorable Richard C. Goodwin 

consider the following concerning the deposition of Laura Ponto: 

a) In year 2010, most all the correspondence and documents was 

created and generated by Ms Ponto. 

b) There appeared to be mistruths by her to the court, perhaps 

lacking candor to the tribunal. 

c) Therefore, it is essential for respondent's defense to take direct 

testimony of Laura Ponio in order to establish and confirm the 

proper Fact Findmgs, 

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8. It is respondent's position that these employees as representatives of 

the FAA, should be held accountable and responsible fur their decisions 

impacting the agency and the allocation of taxpayers funds, therein ful! 

disclosure is proper and reasonable. 

9. It was only at a late date in the tag team of agency attorneys did Mr. 

Raley come into the case. 

10. It is respondent's position that a fair trial in a fair tribunal cannot . 

occur unless the most active and knowing paxticlpants in this case be 

available for close examination. 

WHEREFORE, the respondent prays that the Honorable Judge Richard 

C. Goodwin will reconsider the depositions of Latonya Williams and 

Laura Ponto in Allentown, PA, the originating jurisdiction and venue of 

the alleged theoretical violations as these two individuals are essential to 

the case or in the alternative for the Honorable Judge Richard C. 

Goodwin to completely dismiss with prejudice this case. 

Respectfully Submitted, 

Michael B. Selig, MD. FACC, CFl-H \\ 

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