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RECEIVED 

U.S. DEPARTMENT OF 1RANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of Endless Mountains Air, Inc. 

Docket No. PAA-2013-0848 

Case No. 2012EA050008 

Judge Sullivan 

JOJNT PROPOSED PROCEDURAL SCHEDULE 

. ,' ' ~ ' 

MAR 1 9 2014 

HEARING DOCKET 

The Fed~ral.A.yig~,tion Admini&tr.ati.on .. (FAA), by.. counsel,. and Endles.s Mountains. 

Air, Inc., jointly file this proposed procedural schedule in accordance with the Order 

Setting Rule 16 Litigation Scheduling Conference. 

1. April1, 2014: General Discovery Start Date. On or before April 1, 2014, 

the parties shall begin exchanging or serving additional general discovery 

requests pursuant to CR26- CR 36 and 14 C.P.R. §13.220(b) and (e). This 

includes but is not limited to: notices of deposition; subpoena duces tecum; 

propounding interrogatories; request for production of documents, etc. 

2. Objections to, and Motions Regarding, Interrogatories. Pursuant to 14 C.F.R. 

§13.220(k), any objection(s) to interrogatories shall be filed within ten (10) 

days after receipt of the interrogatories. Pursuant to 14 C.P.R. §13.220(m) 

and Paragraph D herein, any motions to compel for deficient interrogatory 
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___ .,. ___ , ____ , .. 

response(s) shall be filed within ten (10) days after receipt of the objection or 

deficient answer. 

3. May 21, 2014; Deadline for Completing General Discovery. The last date for 

both parties to finish 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 of depositions and serving 

responses to all Requests for Discovery. 

4. May 28, 2014, Supplemental Discovery Request Deadline. The last date for 

. botll partj.es_.to. complete ... exchange of.all supplemental discovery-requests 

based on the general discovery exchange, including but not limited to the 

notices of supplemental 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 pursuant to CR26- CR 36 and 14 C.F.R. §13.220(i). 

6. July 17, 2014. Deadlines for Filing Dispositive Motion(s). The last date for 

both parties to file any/all pre-hearing dispositive motiol'..s, including Default 

Motions and/or Summary Judgment Motions. 

a) August 1, 2014: Deadline for filing Answer to Dispositive Motion(s); 

b) August 8, 2014 -Deadline for filing Reply (if any). 

7. September 2, 2014: List of Witness Exchange of Exhibits due date. The last 

date for each party to serve and file 1he following: 

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a) A list of the witnesses the party intends to call; 

b) A short statement of the testinlony expected from each such witness; 

c) The resume of each witness who will be offered as an expert; and 

d) The documents the party intends to offer in evidence. 

8. August 15, 2014: Written Stipulations and/or Motions in Limine due date. 

The deadline for filing written stipulations and/or written Motions in Limine. 

9. October 21-22,2014-- Hearing in Allentown, PA 

Respectfully submitted, 

. AlfredR.Johnson,..IL.. . . 

Regional Counsel 

By: 0~~ Zach~. Berman 

Attorney 

Federal Aviation A on 

1 Aviation Pla.~0v 

PAGE 04/04 
CERTIFICATE OF SERVICE 

I hereby certifY that the foregoing Jointly Proposed Procedural Schedule has been sent by first class mail 

and by facsimile addressed as follows: 

William J. Dobitsch, Jr. 

Endless Mountains Air, Inc. 

Seamans Airport 

727 Windsock Lane 

Factoryville, PA 18419 

FAX: (570)945-7222 

The Honorable J.E. Sullivan, Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, DC 20590 

FAX: (202)366-7536 

I hereby certify that the foregoing Jointly Proposed Procedural Schedule has been sent by first class mail 

addressed as follows: 

Federal Aviation Administration (Original and one copy) 

800 Independence Avenue, S.W. 

Washington, D.C. 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Room 2014 

Date: MAR 11 Z014 ------

Paralegal Specialist 

Federal Aviation Administration 

Office of Regional Counsel 

Aviation Plaza 

Jamaica, NY 11434