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UNITED STATl~S OF AMERICA 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE m· HEARINGS 

WASHINGTON, D.C. 

) 

liN THE MATTER OF CHEMSYSTEMS, INC., ) 

) 

RESPONDENT ) 

) 

) 

) 

) 

) 

) 

FAA DOCKET NO.: TBA 

DMS FAA-20120911 

October 1, 2013 

AGENCY'S MOTION TO STAY OEADLINES DUE TO 

GOVERNMENT SHUTDOWN 

COMES NOW the Federal Aviation Administration (Complainant), by and through 

!{/] 002/004 

counsel, pursuant to Rules l3.37(h), G) and (k), and l3.44(b) of the Office of Bearings' Rules of 

Practice for FAA Hearings, to request the deadlines in the above-captioned case be s1:ayed in the 

t'Vent of a shutdown of the Federal Government on October I, 2013. See 14 C.F.R. §§ 13.37 and 

I 3.44. 

Should the Federal Government shut down, Agency Counsel will be placed in furlough 

status and, by law, forbidden to work in his capacity as a government employee. As the 

Administrative Law Judge (ALJ) and other individuals associated with this Complaint will likely 

also have been affected by the shutdown, a stay of deadlines equal to the number of clays of 

sb.utdown would be in the interest of both equity and practicality for all parties involved. 

In the event of a shutdown furlough, Agency counsel will have approximately four hours 

on October I, 2013 to perfonn necessary and criT:ical shutdown operations. Because of the 
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limited time for Agency coWlsel to respond to all pending matters before being placed in a 

furlough status and the proposed relief sought herein will affect all parties equally, the Agency 

has not contacted the Respondent regarding this Motion. 

For good cause having been shown, Complainant's CoWlsel therefore requests that 

deadlines, specifically regarding discovery, be stayed by the number of days the Federal 

Government is in "shutdown" status. 

Respectfully submitted, 
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CERTIFICATE OF SERVICE 

I hereby certify that on this date I sent via facsimile, of the COMPLAINANT'S 

II{QTION TO STAY, addressed as follows: 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGG430 

Wilbur Wright Building-Suite 2W I 000 

Facsimile: (202) 493-5142 

And by facsimile only to: 

Hon. Richard C. Goodwin 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Ave., S.E. 

East Building Ground Floor, Room El2-230 

Washington, D.C. 20590 

Facsimile: (202) 366-7536 

And by facsimile only t: 

Dated: October 1, 20 13 

ChemSystems, Inc. 

c/o Robert Fling, Esq. 

S. Robert Fling, PLLC 

P.O. Box 411, Katy, TX 77492f s 

Facsimile: (281) 727-0082 

C :ourtne Adolph, General Attorney 

Office of the Regional Counsel 

Federal Aviation Administration 

Western-Pacific Region 

Lawndale, California 

141004/004 
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Federal Aviation 

Administration 

l4l 001/004 

To: 

Company: 

Hen. Richard C. Goodwin 

Office of Hearings, M-20, US DOT 

Office of the Regional Counsel, A WP-7.4 

PO Bol< 92007 

Phone: 

Fax; 

From: 

Title: 

Date: 

Description of 

item being 

transmitted: 

(202) 366-7536 

Courtney Adolph 

Attorney 

10/01/13 

Complamt ' s Motion For Stay, 

FDMS No. FAA-2012-0911, 

FAA Docket No. unassigned 

Los Angeles, CA 90009-2007 

Telephone; (31 0) 725-7128 

Facsimile: (310) 725-6816 

Email: Courtney.Adolph@faa.gov 

Facsimile 

Total Number of pages including the 

cover page: 4 

0 PER YOUR REQUEST x FOR YOUR REVIEW 0 PLEASE COMMENT 

0 FOR COORDINATION 0 HARD COPY TO FOLLOW VIA US MAIL 

NOTES/COMMENTS: 

cc: Hearing Docket Cle.:k, AGC-430 (via facsimile only) 

(202) 493-5142 

Robert Fling, Esq. (Respondent's Counsel) (vi<t facsllnilc only) 

(281) 727-0082 

0 U.S. Oep;.nment ofTrons"Of'tlllj""