'\ ,-' ;,..., ,..**,~** ...**'"'!·f·:,;\~RTI·v·1ENT** OF -, -,;,:'-**t\I~:I)ClRTATION** -.. '.It \I:f**~)** .....,.-c'"\ ""----....,**.·,r/r~r ()f)ER·~·\TI** **)N~ DEP':=i~~**  AMERICARECE 'VED '"l..1 ',_.,:\ •**.:f\t~~~** \,..,.1 f'"' " OFF SPORTATION ICE OF HEARINGS SEP 1 7 2012 ZDIZ 25/-\10:03 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 tothe 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 atthe

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 setat 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 setto 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, ifthe 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. ConlonCHUHAK & TECSON, P.C. 30S. Wacker Drive Suite 2600Chicago, IL 60606 (312) 444-9300 1891871\1\22816\49252

LEADING EDGE AVIATION, INC.**~J.** By:&**~~-"** One ofIts Attorneys -2 $/**.~ '~~-~**  CERTIFICATE OF SERVICE The undersigned, being first duly sworn on oath, certifies thata 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 at30 South Wacker Drive, Chicago, Illinois 60606 ator 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 98057425-227-1007(Sent**via~.S.** M·an.d Facsimile)·P _i?p__._**~** Counsel for**~nt**-3-

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