# RECEIVED FEB 1 8 2014 

## u.s. DEPARTMENTOF TRANSPORTATION 

## HEARlNG DOCKET FEDERAL AVIATION ADMINISTRATION OFFICE OF HEARINGS

WASHINGTON, D.C.

In the MatterofWings Air, LLC DocketNo. F M-2013-0849 Case No. 2012EA110052 Judge Sullivan

JOINTPROPOSED PROCEDURAL SCHEDULE The Federal Aviation Administration (FAA), by counsel, and Wings Air, LLC, jointly file this proposed procedural schedule in accordance with the Order Setting Rule 16 Litigation Scheduling Conference. I. April I, 2014: General Discovery Start Date. On or before April 1, 2014, the parties shall begin exchanging or serving additional general discovery requests pursuant to CR 26- CR 36 and 14 C.F.R. §l3.220(b) and (e). This includes but is not limited to: notices ofdeposition; subpoena duces tecum; propounding inten·ogatories; request forproduction ofdocuments, etc. 2. Objections to, and Motions Regarding, Interrogatories. Pursuant to 14 C.F.R. §13.220(k), any objection(s) to inten·ogatones shall be nled within twenty (20) days after receipt of the interrogatories. Pursuant to 14 C.F.R. §l3.220(m) and Paragraph D herein, any motions to compel for deficientinterrogatory response(s) shall be filed within twenty (20) days afterreceipt of the objection ordeficient answer. 3. May 21, 2014; Deadline for Completing General Discovery. The last date for both parties to t1nish responding and serving answers to all additional general discovery requests pursuant to CR 26- CR 36 and 14 C.F.R. §13.220(b) and (e). This includes but is not limited to, the taking ofdepositions and serving responses to all Requests for Discovery. 4. May 28, 2014, Supplemental Discovery Request Deadline. The last date for both parties to complete exchange of all supplemental discovery requests based on the general discovery exchange, including but not limited to the notices ofsupplemental depositions, and other requests. 

### 5. June 12, 2014: Deadline for both parties to finish taking supplemental depositions, and responding to and serving answers to all supplemental discovery requests pursuantto CR 26- CR36 and 14 C.F.R. §13.220(i). 6. June 17,2014. Deadlines for Filing Dispositive Motion(s). The last date for both parties to tile any/all pre-hearing dispositive motions, including Default Motions and/or Summary JudgmentMotions. a) August 18,.2014: Deadline for filing Answer to Dispositive Motion(s); b) September!,2014- Deadline for filing Reply (ifany). 7. October l, 2014: List ofWitness Exchange ofExhibits due date. The last date for each party to serve and file the following:a) A list orthewitnesses the party intends to call; b) A short statement ofthe testimony expected from each such witness; c) The resume ofeach witness who will be oJJ'ered as an expert; and d) The documents the party intends tooffer in evidence. 8. October 15, 2014: Written Stipulations and/or Motions in Limine due date. The deadline for tiling written stipulations and/or written Motions in Limine. 9. November4-6,2014- Hearing in New York, 

### NY. Respectfully submitted, Alfred 

### R. Johnson, Jr. Regional Counsel

By:----+-+---"-- Zachary Attorney Federal Aviation Administration I Aviation Plaza Jamaica, NY 11434 TEL: 718-553-3258 FAX: 718- 995-5699 By:**~m.** 

# hJIAtN ed M. Allen, Esq
.

. espondent's Counsel The Aviation Law Finn One Research Court, Suite 450 Rockville, MD 20850 TEL: 301-294-8550 FAX: 301-294-2525

### CERTIFICATE OF SERVICE I hereby certify that the foregoing JointProposedProcedural Schedule has been sent this date via first class mail and viafacsimile to the following:

JaredM. Allen, Esq. Respondent's Counsel The Aviation LawFirm One Research Court, Suite450 Rockville, MD 20850 TEL: 301-294-8550 FAX: 301-294-2525 Judge J.E. Sullivan U.S. Administrative law Judge Office ofHearings, M-20 U.S. Department ofTransportation 1200 New Jersey Avenue, SE (Ell-310) Washington, DC 20590 FAX: 202-366-7536 

# FiECEIVED FEB I8 2014 HEARING DOCKET

Ihereby certify that the foregoing Joint ProposedProcedural Schedule has been sent this date viafirst class mail to the following:
Federal AviationAdministration (Original and one copy) 800 Independence Avenue, S.W. Washington, D.C. 20591 Attn: HearingDocket Clerk, AGC-430 Wilbur Wright**Building~**

### Room 2014


### FEB - 7"1014 Date:.

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# ~**\fo~k** L; aHooks Paralegal Specialist FederalAviation Administration Office ofRegional Counsel 1AviationPlaza Jamaica, NY 11434