# SILVERBERG GOLDMAN& 

# BIKOFF, L.L.P. ATTORNEYS AT LAW

VL4FEDEX Federal Aviation Administration 600 Independence Avenue, S.W. Wilbur Wright Building Suite 2Wl000 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: Inthe Matter ofAirborne 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 ofa Joint Motion to Suspend Litigation Dates. Also enclosed is an additional copy ofthe 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 52014 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 ofthe litigation dates inthe above-captioned matter. As Your Honor is aware, the end oftheperiod for taking fact witness depositions inthis
case is currently set to end on May 31, 2014, and the deadline for completing general discovery inthis case is June 6, 2014. See 

### Order Granting Respondent's Motionto Enlarge Time to Complete Fact Witness Depositions, served April9, 2014, and Order Setting Litigation Dates and Procedures, servedNovember 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 ofthe 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 oftheredacted portions ofthe EIR. Counsel for Respondent would like the opportunity to reviewthe FAA's full response to Interrogatory No. 9 and the additional portions, ifany, ofthe EIRthat Your Honor orders the FAAto produce before takingJoint Motion to Suspend Litigation Dates May 14, 2014 Page2 the depositions ofFAA InspectorFrank Lipinski and other FAArepresentatives. In addition, the FAAhas noticed the deposition ofMr. JeffBecker, the AMES Director ofQuality Assurance & Training, but the parties have beenunable find a date before the end ofMay for Mr. Becker's deposition due to the incompatibility ofMr. Becker's schedule and FAA counsel's schedule. Thus, there is a needto extendthe period for discovery in this case. However, because counsel for Respondent is uncertain as to his availability in June, itis notpossible 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 oncounsels' schedules. Counsel for Respondent may be available in June to participate in depositions inthis case providedhis trial in the U.S. District Court for the Western District ofVirginia is rescheduled from its current June 1

## ih trial date. Opposing counsel in the U.S. District Court case has filed a motionto continue the June 17th trial date. Therefore, the parties would like to leave openthe possibility of conducting depositions inthis case in June, ifpossible, since counsel for the FAAhas hearings in other matters andpre-existing personal commitments scheduled in July and Augustthat would make it difficult to complete depositions during those two months. Counsel for Respondent expects to knowinthe next few weeks whether ornot the June 1



## ih trial date inthe U.S. District Court case will be rescheduled. At suchtime, assuming Your Honor grants thisjointmotion, counsel for Respondent and the FAA willthen 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 ofthe conting,encies described <md filr such further and other reliefas may be appropricltc.

Christopher R. l?cdcral Aviation Administration the: Regional C_.:ounsel Southern Rt;gion P0. !lox 20616 Atlama, GA 30320 Tel: (404) 305-5200 Fax: (404) 305<1223

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. 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 certifythat onthis 141 h 

### day ofMay 2014, I caused the foregoing JointMotion to SuspendLitigation 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 ofHearings, M-20 U.S. Department ofTransportation 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)