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U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

OFFICE OF HEARINGS 

WASHINGTON D.C. 

In the Matter of Maria Tavcras 

2008SW210198 

CP10SW0005 

The Honorable Isaac D. Benkin 

AGENCY'S MOTION FOR PROTECTIVE ORDER 

COMES NOW the Agency, by and through its designated representative tlie 

Regional Counsel for the Eastern Region, and his designated and authorized agents, and 

moves, pursuant to 14 CFR 13.220(h) and (g), for an Order to preclude the personal 

medical information of •witness Julia Sasson, contained in the Agency's Responses to tlie 

Respondent's Discovery Requests, dated July 1, 2010 (enclosed herein) from becoming 

part of the public record. 

The Agency respectfully submits that maintaining Ms. Julia Sasson's medical 

information in the public record would unnecessarily invade Ms. Sjisson's jiersonal 

privacy. The requested records are confidential documents, the release of which could 

result in violations of the subject's personal privacy. Also, Respondent will not be 

prejudiced in any way by protecting Ms. Sasson's personal medical information. Tlie 

Agency is producing the records to Respondent subject to a confidentiality agreement, 

entered on behalf of Respondent by her attorneys. 

While the Agency concedes that some of the information contained in these 

documents, such as description of the witness's injuries are relevant to ihe proceedings, 

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they contain the personal information of the witness and should not be available for 

public disclosure, as they would be if made part of the public docket and transcript. Tlie 

Agency is not seeking to preclude presentation of evidence ivith respect to the witness's 

injuries, it is merely seeldng to prevent the invasion of the witness's personal privacy by 

having her medical records placed in the public docket. 

Pursuant to 14 C.F.R. 13.220(g), the Administrative Law Judge is empowered to 

enter an order protecting the confidentiality of a person, including providing 

"[p]rocedures for excluding the information from the record." 14 CF.R, 13.220(g)(4)(ii). 

WHEREFORE, the Complainant respectfully requests that this Motion be granted in all 

respects. 

Respectfully submitted, 

Alfred R. Johnson, Jr. 

Regional Counsel 

By: 

Leonid Talisman 

Attorney 

Office of Regional Counsel, AEA-7 

One Aviation Plaza 

Jamaica, NY 11434 

718-553-3403 

718-995-5699 (fax) 

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CERTIFICATE OF SERVICE 

I hereby certify that a copy of the Agency's Motion for a Protective Order was served by 

facsimile and Certified Mail - Return Receipt Requested, on this day to the following; 

Administrative Law Judge Honorable Isaak D. Benkin 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

Fax: (202) 366-7536 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, D.C 20591 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building - Suite 2WI000 

Fax:(202)493-5142 

Alexei Schacht, Esq. 

Nalven & Schacht 

Attorneys at Law 

350 Fifth Avenue, Suite 4022 

New York, NY 10118 

Fax: (212) 616-5543 

IMM ^ ''QruZ^^ 

Leonid Talisman 

Attorney 

1 Aviation Plaza, Room 561 

Jamaica, NY 11434 

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