SILVERBERG 

GoLDMAN& 

BIKOFF, L.L.P. CEORGETOWK PLACE • Surnl20 • 1101 30TH STREET, NW • WASHINGTON, D.C. 20007 

VorcE (?02) 944-3300 • fACSIMILE (202) 944-3306 

ATTORNEYS AT LAW 

VIAFEDEX 

Federal Aviation Administration 

600 Independence Avenue, S.W. 

Wilbur Wright Building 

Suite 2W1000 

Washington, D.C. 20591 

April3, 2014 

.~~ECEIVED 

APR -4 2014 

HEARING DOCKET 

(Attention: Hearing Docket Clerk, AGC-430) 

Re: In the Matter of Airborne Maintenance and Engineering Services 

Docket: FAA-2013-0291 

FAA Case No.: 2011S0290032 

Dear Sir or Madam: 

Enclosed for filing in the above-referenced case please find an original and one 

copy of Respondent's Motion to Enlarge Time to Complete Fact Witness Depositions. 

Also enclosed is an additional copy of the Motion and a pre-addressed, postage 

paid envelope. Please date-stamp the additional copy and return it to our office in the 

enclosed envelope. 

Thank you for your assistance. Please call me at the telephone number listed 

above if you have any questions regarding this matter. 

Enclosures 

Very truly yours, 

SILVERBERG, GOLDMAN & BIKOFF, LLP 

Attorneys for 

AIRBORNE MAINTENANCE AND 

ENGINEERING SERVICES 

By zi-~-1\e~ Robert P. Silverberg 
BEFORE THE RECEIVED 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

APR -4 2014 

HEARING DOCKET 

In the matter of 

AIRBORNE MAINTENANCE AND 

ENGINEERING SERVICES 

Respondent 

Docket No. FAA-2013-0291 

FAA Case No. 2011 S0290032 

Administrative Law Judge 

J.E. Sullivan 

MOTION TO ENLARGE TIME TO COMPLETE FACT WITNESS DEPOSITIONS 

Respondent, Airborne Maintenance and Engineering Services ("Respondent" or 

"AMES") herby moves for an enlargement of time to complete fact witness depositions until 

May 30,2014. Counsel for the Complainant has authorized the undersigned to state that the 

requested extension is not objected to by the Complainant. 

As might be expected, the scheduling of fact witness depositions is difficult by virtue of 

the fact that the FAA inspectors AMES has asked to appear at depositions have limitations on 

their availability. Further, Respondent has held off filing formal notices of deposition (although 

informal discussions between the parties have taken place) until Your Honor rules on the 

pending motions to compel. If the Respondent's motion is granted andthe Complainant is 

required to answer the objected to interrogatories and produce the documents which thus far the 

Complainant has refused to produce, the resulting discovery responses will be needed and used 

in connection with the taking of depositions of the FAA's fact witnesses. Scheduling depositions 

before Respondent knows of the ruling on its motion to compel and before the FAA produces 

any documents in response to the ruling (assuming Respondent's motion is granted), could 

necessitate second rounds of depositions thereby requiring both parties to incur considerable 
Motion to Enlarge Time 

April3, 2014 

Page2 

extra expense and time. A voidance of such can readily be accomplished by moving the fact 

witness deposition deadline until the end of May. 

Even though fact witness depositions may not be completed before the May 2, 2014 

deadline for initial expert disclosures and/or the May 16,2014 deadline for expert rebuttal 

disclosures, Respondent is not suggesting any change in these deadlines based on the 

understanding that depositions, if any are requested of the experts, can be taken prior to the end 

of general discovery on June 6, 2014. No other deadlines as set forth in the Order Setting 

Litigation Dates and Procedures will be impacted by the grant of this motion. 

Wherefore, for the reasons set forth herein, Respondent hereby moves for an enlargement 

of time to complete fact witness depositions and for such further and other relief as may be 

appropriate. 

Dated: April3, 2014 

Respectfully submitted, 

SILVERBERG, GOLDMAN & BIKOFF, L.L.P. 

Attorneys for 

AIRBORNE MAINTENANCE AND 

ENGINEERING SERVICES 

By: ----:':2::-"o':'i!bert!!O-."':"f""'. s-=~=-/-erb.;:-.!1.~ e""'rg""', E'-"~-'~.'-""-.:....~=1-- 1101 30th Street, N.W. 

Suite 120 

Washington, D.C. 20007 

Tel: (202) 944-3304 

Fax: (202) 944-3306 

Email: rsilverberg@sgbdc.com 
CERTIFICATE OF SERVICE 

I hereby certify that on this 3'd day of April2014, I caused a true copy of the foregoing 

Motion to Enlarge Time to Complete Fact Witness Depositions to be served by FedEx overnight 

delivery addressed to: 

Federal Aviation Administration 

600 Independence Avenue, S.W. 

Wilbur Wright Building 

Suite 2Wl 000 

Washington, D.C. 20591 

(Attention: Hearing Docket Clerk, AGC-430) 

Tel: (202) 385-8229 

(original and one copy) 

The Hon. J.E. Sullivan 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

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

Washington, D.C. 20590 

Tel: (202) 366-2132 

Christopher R. Stevenson, Attorney 

Office of the Regional Counsel, AS0-7 

Southern Region 

Federal Aviation Administration 

1701 Columbia Avenue 

College Park, GA 30337 

Tel: ( 404) 305-5200