SILVERBERG 

GOLDMAN& 

B IKO FF, L.L.P. 

ATTORNEYS AT LAW 

VL4FEDEX 

Federal Aviation Administration 

600 Independence Avenue, S.W. 

Wilbur Wright Building 

Suite 2Wl 000 

Washington, D.C. 20591 

CEORGETOWNPLACE • 5lllTEL?.Q • 110130THSTREET,NW • WASHINCTON,D.C 2000/ 

VOICE (202) 944-3300 • fACSIMILE (202) 944"3306 

May 14,2014 RECEI\l 

HEARING DOCK:I;T 

(Attention: Hearing Docket Clerk, AGC-430) 

Re: In the Matter of Airborne Maintenance and Engineering Services 

Docket: FAA-2013-0291 

FAA Case No.: 2011S0290032 

Dear Sir or Madam: 

Enclosed for filing in the above-referenced case please fmd an original and one copy of a 

Joint Motion to Suspend Litigation Dates. 

Also enclosed is an additional copy of the Joint Motion and a pre-addressed, postage paid 

envelope. Please date-stamp the additional copy and return it to our office in the enclosed 

envelope. 

Thank you for your assistance. Please call me at the telephone number listed above if 

you have any questions regarding this matter. 

cc: Christopher R. Stevenson, Esq. 

Very truly yours, 

SILVERBERG, GOLDMAN & BIKOFF, LLP 

Attorneys for 

AIRBORNE MAINTENANCE AND 

ENGINEERING SERVICES 

By: 
RECEiVED 

BEFORE THE 1 5 2014 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASIDNGTON, D.C. HEARING DOCKET 

In the matter of 

AIRBORNE MAINTENANCE AND 

ENGINEERING SERVICES 

Respondent 

Docket No. FAA-2013-0291 

Case No. 2011S0290032 

Administrative Law Judge 

J .E. Sullivan 

JOINT MOTION TO SUSPEND LITIGATION DATES 

Counsel for Respondent Airborne Maintenance and Engineering Services ("AMES") and 

Complainant Federal Aviation Administration ("FAA'') hereby request the temporary suspension 

of the litigation dates in the above-captioned matter. 

As Your Honor is aware, the end of the period for taking fact witness depositions in this 

case is currently set to end on May 31, 2014, and the deadline for completing general discovery 

in this case is June 6, 2014. See Order Granting Respondent's Motion to Enlarge Time to 

Complete Fact Witness Depositions, served April9, 2014, and Order Setting Litigation Dates 

and Procedures, served November 7, 2013. 

Recently, in an Order served May 2, 2014, Your Honor directed the FAA to respond fully 

to Respondent's Interrogatory No.9 and to provide an un-redacted copy of the Enforcement 

Investigative Report ("EIR") in this matter for in camera review by May 14, 2014. Your 

Honor's May 2"d Order also stated that a separate order will be issued after May 14, 2014 

addressing the potential disclosure ofthe redacted portions of the EIR. Counsel for Respondent 

would like the opportunity to review the FAA's full response to Interrogatory No. 9 and the 

additional portions, if any, of the EIR that Your Honor orders the FAA to produce before taking 
Joint Motion to Suspend Litigation Dates 

May 14, 2014 

Page2 

the depositions of FAA Inspector Frank Lipinski and other FAA representatives. In addition, the 

FAA has noticed the deposition of Mr. Jeff Becker, the AMES Director of Quality Assurance & 

Training, but the parties have been unable find a date before the end of May for Mr. Becker's 

deposition due to the incompatibility of Mr. Becker's schedule and FAA counsel's schedule. 

Thus, there is a need to extend the period for discovery in this case. However, because 

counsel for Respondent is uncertain as to his availability in June, it is not possible at this time to 

determine a proposed revised litigation schedule that would enable the parties to complete 

discovery as expeditiously as possible given the constraints on counsels' schedules. Counsel for 

Respondent may be available in June to participate in depositions in this case provided his trial in 

the U.S. District Court for the Western District of Virginia is rescheduled from its current June 

1 ih trial date. Opposing counsel in the U.S. District Court case has filed a motion to continue 

the June 17th trial date. Therefore, the parties would like to leave open the possibility of 

conducting depositions in this case in June, if possible, since counsel for the FAA has hearings in 

other matters and pre-existing personal commitments scheduled in July and August that would 

make it difficult to complete depositions during those two months. 

Counsel for Respondent expects to know in the next few weeks whether or not the June 

1 ih trial date in the U.S. District Court case will be rescheduled. At such time, assuming Your 

Honor grants this joint motion, counsel for Respondent and the FAA will then confer on a 

revised litigation schedule for this case to submit to Your Honor for approval. 
Joint Motion to Suspend Litigation Dates 

May !4, 2014 

\VHE.f-\EFORE< for the reasons set foril1 ht~t·cin, R(:~;spondcnt and Compluir:ant hereby 

jointly move for a temporary 

fwihet to r: report to Your Honor of rt:'solution of the conting,encies described 

<md filr such further and other relief as may be appropricltc. 

Christopher R. 

l?cdcral Aviation Administration 

the: Regional C_.:ounsel 

Southern Rt;gion 

P 0. !lox 20616 

At lama, GA 30320 

Tel: (404) 305-5200 

Fax: (404) 305<1223 

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RIJber1 P. . 

Silvcrtkrg. (;oldman & Btkoff LLP 

1101 J011 ',Strcct. N.W. 

Suite 120 

Washington., DC 20007 

lei: (202) 944-3304 

Fmc (202) 044-3306 

AmBOR:-.JE :VIi'dNTENANCE r\t'\D 

ENGINEERING SERVICES 
CERTIFICATE OF SERVICE 

I hereby certify that on this 141

h day of May 2014, I caused the foregoing Joint Motion to 

Suspend Litigation Dates to be served upon the following: 

Federal Aviation Administration 

600 Independence Avenue, S.W. 

Wilbur Wright Building 

Suite 2W1000 

Washington, D.C. 20591 

(Attention: Hearing Docket Clerk, AGC-430) 

Tel: (202) 385-8229 

(original and one copy by FedEx overnight delivery) 

The Hon. J.E. Sullivan 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

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

Washington, D.C. 20590 

Tel: (202) 366-2132 

Fax: (202) 366-7536 

(one copy by facsimile and First Class Mail)