U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, DC 

In the Matter of: 

Facility Solutions, Inc. 

Respondent 

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Docket No. FAA-2013-0047 

Case No. 2012NE700128 

Judge J.E. Sullivan 

----------------------------------------------~' Roy J. Transit 

roytransit@comcast.net 

Attorney for Respondent: Facility Solutions, Inc. 

P.O. BOX 1578 

Royal Oak, MI 48068-1578 

586-491-6822 

Fax: 248-564-0940 

Brian K. Khan 

Federal Aviation Administration 

Office of Regional Counsel 

2300 East Devon Ave., AGL-7H 

Des Plains, Illinois 60018 

847-294-7652 

Fax: 847-294-7498 

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PARTIES PROPOSED DISCOVERY PLAN 

Federal Aviation Administration (FAA) Facility Solutions, lnc., and through their 

respective counsel, state as follows their Proposed Discovery Plan: 

The FAA filed this action against Facility Solutions for violation of the Hazardous 

Materials Regulation 49 CFR part 171 et. seq. because their employee, Jeffery Dwyer attempt to 

check baggage containing a can ofMAPP gas in his luggage. Facility Solutions, lnc., maintains 

that they are not responsible for the alleged violation made by JeffeRECETVE D 

outside the course and scope of his employment. MAY 2 8 2013 

HEARING DOCKET 
that they are not responsible for the alleged violation made by Jeffery Dwyer who was acting 

outside the course and scope of his employment. 

1. Rule 26 (a)(l) Disclosures: The parties shall exchange the disclosures required 

by Rule 26(a)( 1) on or before June 20,2013. 

2. Rule 26 (a)(2) Disclosures: The parties shall exchange initial expert disclosures 

(if any) required by .July 22, 2013. Rebuttal disclosures shall be served by 

August 6, 2013. 

3. Discovery Cut Off: All discovery shall be completed by September 20, 2013. 

4. Dispositive Motions: All dispositive motions shall be filed by and heard by 

November 20, 2013. 

5. Amendments to Pleadings: All amendments to pleadings must be sought by the 

discovery cut-off date of September 20, 2013. 

6. Final Settlement Conference: The parties, including counsel and those with 

authority to settle, shall meet January 13, 2014, at the FAA offices in the 

Chicago area for a final settlement conference. 

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Roy J. T· 1 sit 

Federal Aviation Administration 

Office of Regional Counsel 

2300 East Devon Ave., AGL-7H 

Des Plains. Illinois 60018 

847-294-7652 

Attorney f r Facility Solutions, Inc. 

P.O. Box 1578 

Royal Oak, MI 48068 

586-491-6822 
A copy of this: PARTIES PROPOSED DISCOVERY PLAN 

was served upon, 

Federal Aviation Administration 

600 Independence Ave., S.W. 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2Wl 000 

Judge J. E. Sullivan 

U.S. Adnllnistrative Law Judge 

Office of Hearing, M-20 

U.S. Department of Transportation 

1200NewJersey Ave, S.E. (Ell-310) 

Washington, DC 20590 

Brian K. Khan 

Federal Aviation Administration 

Office of Regional Counsel 

2300 East Devon Ave., AGL-7H 

Des Plains, Illinois 60018 

Roy J. Transit 

Attorney for Respondent: Facility Solutions, Inc. 

P.O. BOX 1578 

Royal Oak, MI 48068-1578 

On May 21, 2013, by US Mail, postage prepaid, by the undersigned. 

Dated: May 21, 2013 

Brian K. Khan