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'"l .. 1',_.,:\ • .:f\t~~~ \,..,.1 f'"' " OFF SPORTATION ICE OF HEARINGS SEP 1 7 2012 

ZD IZ 2 5 /-\ 10: 0 3 WASHINGTON, D.C. 

IN THE MATTER OF, 

LEADING EDGE AVIATION, INC., 

) 

) 

) 

) 

) 

) Respondent. 

HEARING DOCKET 

No. FAA Case No. 2011 NM 070089 

DMS No.: FAA-2012-0783 

Honorable Richard C. Goodwin 

MOTION TO SET HEARING DATE AND LOCATION 

NOW COMES Leading Edge Aviation, Inc. ("Leading Edge"), by and through its 

counsel, for its Motion to Set Hearing Date and Location states as follows: 

1. The FAA has not yet produced all responsive documents to the Freedom of 

Information Act request submitted by Leading Edge's counsel on July 18,2012. 

2. The FAA has not yet produced its items of proof ("lOP") to Leading Edge that 

were requested by Leading Edge's counsel on July 24, 2012. 

3. Leading Edge issued interrogatories, requests for production, and requests to 

admit to the FAA on September 7, 2012. 

4. Counsel for the FAA has indicated that the FAA plans to issue interrogatories, 

requests for production and requests to admit to Leading Edge. 

5. Leading Edge plans to conduct at least two depositions in this case. 

6. Leading Edge anticipates that it will likely retain an expert witness to testify at the 

hearing of this case. 

1891871\1\22816\49252 
'\ _,/ 

1 .¢.-

~ 7. Given the aforesaid facts, Leading Edge respectfully requests that the hearing of 

this matter be set at least 180 days from now (after March 10, 2013) to allow Leading Edge 

sufficient time to prepare for the hearing. 

8. Leading Edge's counsel are in Chicago, Illinois. Leading Edge respectfully 

requests that the hearing of this matter be set to proceed in Chicago, Illinois, which would be 

much more cost efficient for Leading Edge than the FAA's selected forum for the hearing in 

Bend, Oregon. Alternatively, if the Administrative Law Judge is not agreeable to scheduling the 

hearing for Chicago, Illinois than Leading Edge requests that the hearing proceed in Washington, 

D.C. rather than Bend, Oregon It would be very costly for Leading Edge to have its counsel 

travel from Chicago, Illinois to Bend, Oregon as there are no direct commercial flights available. 

Wherefore, Leading Edge respectfully requests that the Administrative Law Judge set the 

hearing of this matter after March 10, 2013 and schedule the hearing to occur in Chicago, 

Illinois, or alternatively, in Washington, D.C. 

Fred C. Begy 

Carri A. Conlon 

CHUHAK & TECSON, P.C. 

30 S. Wacker Drive 

Suite 2600 

Chicago, IL 60606 

(312) 444-9300 

1891871\1\22816\49252 

LEADING EDGE AVIATION, INC. 

By: & ~J. ~~-" One of Its Attorneys 

-2 $ 
/ .~ 

'~~-~ CERTIFICATE OF SERVICE 

The undersigned, being first duly sworn on oath, certifies that a true and correct copy of this 

Respondent's Motion to Set Hearing Date and Location was served upon counsel-of-record as 

indicated above by depositing same, proper postage prepaid, in the U.S. mailbox located at 30 

South Wacker Drive, Chicago, Illinois 60606 at or about 5:00p.m. this lOth day of September, 

2012. 

1891871\1\22816\49252 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, D.C. 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2W1 000 

(Original and copy) 

The Honorable Richard C. Goodwin 

Office of Hearings, M-20 

1200 New Jersey Avenue, S.E. (E-11-310) 

Washington, D.C. 20590 

202-366-7536 

(Sent via U.S. Mail and Facsimile) 

Jeffrey M. Harper, FAA Attorney 

Dana Stephenson, FAA Attorney 

Natalie Morrell, FAA Attorney 

FAA Office of Regional Counsel 

Federal Aviation Administration 

Northwest Mountain Region, ANM-7 

1601 Lind Ave. SW 

Renton, W A 98057 

425-227-1007 

(Sent via~.S. M · an.d Facsimile) 

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Counsel for 

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