U.S. DEPARTMENT OF TRANSPORTATION APR " 6 2012 

FEDERAL AVIATION ADMINISTRATIOMp A OlIlBi^ r> ^ 

OFFICE OF HEARINGS ''^CMftllMG DOCKE T 

WASHINGTON, D.C. 

In the Matter of Ivy Enterprises, Inc. 

Docket No. FAA-2011-1116 

CaseNo.20l0SO700376 

Judge J.E. Sullivan 

JOINT PROPOSED SCHEDULING/DISCOVERY PLAN 

Pursuant to §13.217 of the Rules of Practice for FAA Civil Penalty Actions (14 C.F.R. 

§13.217), and Civ. R 26(f) and further to the Second Order Setting Rule 16 Litigation 

Scheduling Conference, and Directing Rule 26(f) Planning and Submission, dated March 1, 

2012, the parties in this action hereby submit the following proposed scheduling/discovery 

plan: 

I 

Initial requests for discovery will be servedby June 15, 2012. Responses thereto will be 

served within 30 days of service of initial requests for discovery. [14 C.F.R. §13.220(d)]. 

(i.e. Not later than July 16, 2012). 

Any additional requests for discovery shall be served within 10 days of a parties' receipt of 

responses to its initial discovery requests. Objections or responses thereto will be served 

within 30 days of service of any additional requests for discovery. [14 C.F.R. §13.220(d)]. 

(i.e. Not later than August 27, 2012). 

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Exchange of exhibits to be introduced al the hearing and exchange of witness lists shall be 

concluded within 30 days of receipt of responses to any additional discovery requests (i.e., 

Not laterthan September 26, 2012.) The witness lists shall contain a summary of the topics 

of their testimony offered in live or written format. 

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S:;bmission of prehearing motions shall be concluded within 15 days of the parties' 

exchange of exhibits (i.e. by October 11,2012) with responses thereto to be submitted within 

10 days of service of such motion October 22, 2012. [14 C.F.R. §13.218(d); 14 C.F.R. 

§13.212(0)]. 

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The parties request that the hearing take place in the New York City or Ix)ng Island area, 

within 30 days ofcompletion of prehearing motions [14 C.F.R. § 13.218(c)]. 

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The parties have discussed settlement and will continue to explore the possibility of 

settlement, but at this time prospects of settlement are unknown. 

A^e d to: 

For Complainant: (y[yJSoir^''= ^ Date; 3 (9-'^[^Z. ^ 

Jwanine C. Gotimcr 

Attorney 

For Respondent: Date: ^/id^ 
CERTIFICATE OF SERVICE 

1 hereby certify that the foregoing Joint Proposed Scheduling/Discovery Plan has been 

placed this date in the United States mail, postage prepaid, as follows: 

Via Facsimile 

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, D.C. 20590 

FAX (202) 366-7536 

Via First Class Mail 

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 - Suite 2W1000 

Alexander G. Bateman, Jr. Esq. 

Ruskin Moscou Faltischek P.C. 

1425 RexCorp Plaza 

East Tower - 15th Floor 

UniondaJe,NY11556 

(FAX) 516-663-6601 

Date: MAR 2 9 2012 Jim, •"^w^-^L ^ <?A i .\^, ' 

Marianna Perero 

Paralegal Specialist 

Federal Aviation Administration 

OfSce of Regional Counsel 

1 Aviation Plaza 

Room 561 

Jamaica, NYl 1434