# SILVERBERG 

# GoLDMAN& BIKOFF, L.L.P. CEORGETOWKPLACE • 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 ofAirborne 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 ofRespondent'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 ifyou 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. SilverbergBEFORE THE 

# RECEIVED U.S. DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS

WASHINGTON, D.C. 

## APR -4 

## 2014 HEARING 

## DOCKET Inthe matter of AIRBORNE MAINTENANCE AND ENGINEERING SERVICES Respondent Docket No. FAA-2013-0291 FAA Case No. 2011S0290032

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 oftime 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 bythe Complainant. As mightbe expected, the scheduling offact witness depositions is difficultbyvirtue of the fact that the FAA inspectors AMES has asked to appear at depositions have limitations on their availability. Further, Respondenthas held offfiling formal notices ofdeposition (although informal discussions between the parties have takenplace) until Your Honor rules on the pending motions to compel. Ifthe 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 ofdepositions ofthe FAA's fact witnesses. Scheduling depositions before Respondent knows ofthe ruling on its motion to compel andbefore the FAA produces any documents inresponse to the ruling (assuming Respondent's motion is granted), could necessitate second rounds ofdepositions therebyrequiring bothparties to incur considerableMotion to Enlarge Time April3, 2014 Page2 extra expense and time. Avoidance ofsuch can readilybe accomplishedbymoving the fact witness deposition deadlineuntil the end ofMay. Even though fact witness depositions may notbe completedbefore 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 onthe understanding that depositions, ifany are requested ofthe experts, can betaken prior to the end ofgeneral discovery on June 6, 2014. No other deadlines as set forth inthe Order Setting Litigation Dates and Procedures will be impactedbythe grant ofthis motion. Wherefore, for the reasons set forth herein, Respondentherebymoves for an enlargement oftime to complete fact witness depositions and for such further and other reliefas maybe 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.comCERTIFICATE OF SERVICE I hereby certifythat on this 3'd day ofApril2014, I caused a true copy ofthe foregoing Motion to Enlarge Time to Complete FactWitness Depositions to be served byFedEx overnight delivery addressed to: Federal Aviation Administration 600 Independence Avenue, S.W. Wilbur Wright Building Suite 2Wl000 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 ofHearings, M-20 U.S. Department ofTransportation 1200 New Jersey Avenue, S.E. (Ell-310) Washington, D.C. 20590 Tel: (202) 366-2132 Christopher R. Stevenson, Attorney Office ofthe Regional Counsel, AS0-7 Southern Region Federal Aviation Administration 1701 Columbia Avenue College Park, GA 30337 Tel: (404) 305-5200