1 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS

IN THE MATTER OF: FELTS FIELD AVIATION, INC., Respondent
Tuesday, February 9, 2016 Docket No. FAA-2015-3307

The teleconference convened, pursuant to notice, at 1:30 p.m.
BEFORE: THE HONORABLE J.E. SULLIVAN, Administrative Law Judge

(202) 234-4433 

## ORIGINAL

NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RHODE ISLANDAVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433APPEARANCES: On Behalf of the Complainant: CODY SMITH, ESQ. Attorney-Advisor Office of Hearings, M-20 US Department of Transportation 1200 New Jersey Ave., SE (E-11-310) Washington, DC 20590 Phone: 202-366-6941 cody.smith@dot.gov On Behalf of the Respondent: MARK J. CONLIN, ESQ. BENJAMIN WYBORNEY, ESQ. of: Conlin, Maloney & Miller 421 W. Riverside Ave. Suite 911 Spokane, WA 99201 (509) 624-3020 mconlin@aviation-law.com
Also Present: RACHAEL BROWN, Staff Assistant

(202) 234-4433 NEAL R. GROSS COURT REPORTERS ANO TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 2

(202) 234-44333

1 P-R-0-C-E-E-D-I-N-G-S 2 1:41 p.m. 3 JUDGE SULLIVAN: We're on the record in 4 the matter of Felts Field Aviation. This is 5 Docket Number FAA-2015-3307. 6 Today is Tuesday, February 9, 2016, 7 and the parties have convened by telephone for a 8 court-ordered Rule 16 Litigation Scheduling 9 Conference. 10 The Complainant, Federal Aviation 11 Administration, which I'll herein after refer to 12 as a FAA is represented by its attorney of 13 record, Mr. Robert Spitzer. Mr. Spitzer is not 14 present at this time and there's no explanation 15 for his absence. 16 The Respondent, Felts Field Aviation, 17 is represented by its lead counsel, Mr. Mark J. 18 Conlin. Also present with Mr. Conlin is his 19 co-counsel, Mr. Benjamin Wyborney. 20 In addition, sitting in as observers 21 today at the Office of Hearings in Washington, 22 D.C. is Mr. Cody Smith, an Attorney Advisor with

(202) 234-4433 NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RHODE ISLANDAVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-44334 1 this office and Mrs. Rachael Brown, a Staff 2 Assistant. So, good afternoon to you all. 3 MR. CONLIN: Thank you, Your Honor. 4 JUDGE SULLIVAN: Before we jump into 5 litigation scheduling I '11 simply note for the 6 record that the last Court order was issued on 7 December 1, 2

### o15, in this case. This was an 8 order setting a Rule 16 Litigation Scheduling 9 Conference and directing the parties to confer 10 and file a Rule 26F Proposed Discovery Plan. 11 That Discovery Plan was due on or before Tuesday, 12 February 2, 2016. I'll note that on that date, 13 February 2nd, 2016, the parties filed a Joint 14 Proposed Scheduling and Discovery Plan which I 15 have before me and I'm going to be talking with 16 you about today. 17 Since this plan was recently filed and 18 it was filed as a joint plan by both the 19 Respondent and the FAA, Mr. Conlin, do you by any 20 chance have any information about why Mr. Spitzer 21 has not appeared this afternoon 22 conference?

(202) 234-4433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 for this

(202) 234-44335

1 MR. CONLIN: No, I don't, Your Honor. 2 I had a little trouble communicating with him as 3 far as putting the Schedule and Discovery Plan 4 together. I drafted a Respondent's proposed 5 scheduling order, sent it over to Mr. Spitzer and 6 he said just to go ahead and add his name 7 telephonically and then I converted it over to a 8 Joint Proposed Scheduling and Discovery Plan. 9 And I'm not sure what happened concerning today's 10 hearing, Your Honor. 11 JUDGE SULLIVAN: Okay. I will note 12 that the December 1, 2015, Order that set up 13 today's date and time and provided information to 14 both Mr. Spitzer and to Mr. Conlin about filing 15 the Rule 26F planning submission and also 16 appearing for today was not returned as 17 undeliverable and it was served upon Mr. Spitzer 18 at his address of record which is 1601 Lind 19 Avenue, Southwest, Renton, Washington 98057. 20 That service occurred by 

### u.s. Mail. In addition, 21 it was also served as a courtesy by fax and that 22 fax was sent on Tuesday, December 1st, 2015, to

(202)234-4433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-44336 1 Mr. Spitzer's fax number which is 425-227-1007. 2 We received a fax transmission log indicating 3 that all four pages of the Order were served on 4 that fax address. 5 So, Mr. Conlin, we have two options 6 for you to consider today, you and I. I'm happy 7 to go forward at this point and set up the 8 litigation scheduling just with you and at your 9 calendar convenience. If I do that and I'm happy 10 to do that, I'm basically waiving Mr. Spitzer's 11 participation and any objection he might have. 12 MR. CONLIN: Well, at this point I have 13 not heard back. I don't know if it would just be 14 appropriate to move to dismissal on this matter 15 for the failure to reply. 16 JUDGE SULLIVAN: When you say failure 17 to reply are you talking about his failure to 18 reply to the plan which he said you could put his 19 name on? 20 MR. CONLIN: Failure to respond to the 21 Court order to appear as ordered on today's 22 telephonic hearing, Your Honor.

(202) 234·4433 NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RHODE ISLAND AVE., NW. WASHINGTON, D.C. 20005·3701 (202) 234·44337 1 JUDGE SULLIVAN: I do not have in my 2 orders currently a warning of that nature in part 3 because sometimes people have problems and they 4 can tell us about them. So, if you both had 5 failed to appear I certainly would be issuing an 6 Order to Show Cause noting that if the FAA who is 7 the Complainant party fails to show good cause 8 for its non-appearance, the Court will dismiss
9 the action. I can do that in this case as well 10 if you would like because Mr. Spitzer on behalf 11 of the FAA was supposed to appear today and 12 participate in this conference. 13 MR. CONLIN: And I guess that would be 14 on point, Your Honor. We both had obligations in 15 this matter and both of us are aware of what the 16 Court had said and ordered and is clear. And at 17 this point it seems like the Respondent, Felts 18 Field, has put together the order and although he 19 telephonically agreed to it, we both know what 20 our obligations are and I would just request this 21 matter just be dismissed at his point for failure 22 to show up for an order that's been ordered by

(202) 234-4433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-44338 1 this Court. 2 JUDGE SULLIVAN: Then I will defer a 3 scheduling conference at this point, Mr. Conlin, 4 and I will send out an Order to Show Cause and 5 see if the FAA plans to pursue action on this 6 case. 7 MR. CONLIN: All right. Thank you, 8 Your Honor. 9 JUDGE SULLIVAN: If the FAA responds 10 and shows good cause I' 11 be setting up a new 11 conference time and then if I do that, I'm going 12 to just highlight for you a couple of concerns I 13 have now just so that you know and you don't 14 repeat them if, in fact, there's a second 15 conference. 16 MR. CONLIN: All right. Thank you, 17 Your Honor. 18 JUDGE SULLIVAN: Yes. If you would 19 look with me on Page 1 of the four-page Joint 20 Proposed Schedule

-- 21 MR. CONLIN: Yes, Your Honor. 22 it ln front of me.

(202) 234-4433 NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RHODE ISLAND AVE., NW. WASHINGTON, D.C. 20005-3701 I have

(202) 234-44339
1 JUDGE SULLIVAN: Thank you. On Page 2 1, Paragraph 1, which is at the bottom of the 3 first page, there is a March 11, 2016, deadline 4 for filing general discovery requests and also 5 serving answers to requests for production of 6 documents, interrogatories and so forth which is 7 virtually impossible to meet for the parties if, 8 in fact, you serve your opponent with requests 9 for admission on March 11, 2016, for 10 interrogatories and so forth. So, I would simply 11 note for you that if you want to have a deadline 12 for starting general discovery that makes sense. 13 It doesn't quite make sense to give yourself less 14 than 30 days to both serve discovery and serve 15 answers to it. 16 MR. CONLIN: That's a good point, Your 17 Honor. What we may do at the Court's discretion 18 over on page 2, tie it into the June lOth, 2016, 19 deadline for completing general discovery. 20 21 more sense. 22

(202) 234-4433 JUDGE SULLIVAN: Yes, that would make

I'll also note that on Page 2,

NEALR. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RHODE ISLANDAVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-443310
1 Paragraph 4, there's a July 11, 2016, deadline 2 for filing dispositive motions and then directly 3 beneath that in Paragraph 4(a) there's a July 12, 4 2016, deadline for filing answers to dispositive 5 motions. And it would seem to me to be a 6 terrible disadvantage to the responding party to 7 have less than 24 hours to answer a Summary 8 Judgment Motion. So, you might want to tweak 9 that a little bit before we convene again if, in 10 fact, we do.
11 MR. CONLIN: I appreciate that, Your 12 Honor. 13 JUDGE SULLIVAN: In addition, and I'm 14 still on Paragraph 4, Page 2, Paragraph 4(c) has 15 an August 31, 2016, date for oral argument. If 16 you look directly below that Paragraph 5 has a 17 September 2nd, 2016, date for exchanging witness 18 lists and exhibits. I, again, applaud your 19 ambition but essentially you provided no time for 20 the Court to issue a ruling on Summary Judgment 21 between August 31, 2016, and September 2, 2016, 22 which would allow the parties an opportunity to

(202) 234·4433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLAND AVE., NW. WASHINGTON, D.C. 20005·3701 (202) 234·443311

l carve out who they actually want to testify and 2 what exhibits they want after Summary Judgment 3 Decision has been rendered. 4 So, typically, just so you know, I 5 typically put about two months of time between 6 the date of your oral argument and the date that 7 the parties are going to exchange witness lists 8 and exhibits. That gives the Court time to issue 9 a ruling that hopefully will be reasoned and lO understandable to the parties and it will give ll the parties enough time to look at that ruling l2 and say, okay, how did this change my case, if at l3 all. So, just a heads up for you there. l4 MR. CONLIN: Yes, I appreciate that, l5 Your Honor. l6 JUDGE SULLIVAN: Okay. Just so that l7 you know in terms of where I'm calendaring right lS now and that will be a little fluid depending on l9 if we ever come back to talk about this. I'm 20 calendaring around March or April of 20l7 at this 2l point. So, again, I appreciate the ambitious 22 schedule of October 20l6 for hearing, but you'll

(202) 234-4433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-443312 1 probably see it set out beyond that. So, you'll 2 have a little bit of time to provide some margin 3 of comfort for you and your colleague if he does, 4 in fact, show up. 5 So, with that, any questions before we 6 conclude today? 7 MR. CONLIN: No, Your Honor. I 8 appreciate the feedback on this discovery plan 9 and we'll certainly take that into consideration. 10 JUDGE SULLIVAN: Okay. Then what 11 you'll find is that I will be sending out 12 hopefully either let's see, it's almost 2:00 13 here. Probably tomorrow which would be February 14 10, 2016, an Order to Show Cause giving the FAA 15 attorney approximately two weeks to file a Show 16 Cause Statement to say why the case should not be 17 dismissed. And then I'll keep track of it from 18 there. If a Show Cause statement is filed and 19 accepted then I'll reset this matter for a later 20 time and ask you to, again, confer with your 21 friend across the aisle about these matters. 22

(202) 234-4433 MR. CONLIN: Very good.

NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RHODE ISLANDAVE., NW. WASHINGTON, D.C. 20005-3701 I appreciate

(202) 234-4433l3 1 it. 2 JUDGE SULLIVAN: Thank you. 3 With that, it appears our business is 4 complete. Thank you again, sir, for your work so 5 far. And I look forward to either working with 6 you on this case or some other case in the 7 future. 8 We can go off the record and I will 9 you all a good day. 10 Thank you. 11 MR. CONLIN: Thank you, Your Honor. 12 JUDGE SULLIVAN: You're welcome. 13 (Whereupon, the above-entitled matter 14 was concluded at 1:55 p.m.) 15 16 17 18 19 20 21 22

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-- Neal R. Gross and Co., Inc. (202) 234-4433 Washington DC www.nealrgross.com17

This is to certify that the foregoing transcript

In the matter of: Felts Field Aviation

Before: US DOT/OH

Date: 02-09-16

Place: teleconference

was duly recorded and accurately transcribed under my direction; further, that said transcript is a true and accurate record of the proceedings.

Court Reporter

{202)2344433 NEAL R. GROSS COURTREPORTERSANDTRANSCRIBERS 1323RHODE ISLANDAVE., N.W. WASHINGTON,D.C. 20005·3701 www.nealrgross.com