U.S. DEPARTMENT OFTRANSPORTATION OFFICE OF HEARINGS WASHINGTON, DC 

# RECElVED NOV 2 723\3 

## HEARING DOCKET IN THE MATTER OF DENNIS J. MCGLYNN
RESPONDENT 

### ) ) ) 

### ) ) ) FAA DOCKET No: TBA FAA Region :Western-Pacific Judge: Honorable Richard C. Goodwin OMS No. FAA-2013-0615



### AFFIDAVIT & 

### REQUEST FOR AN EXTENSION OF**TIM~** NOW COMES, Fred M. Morelli, Jr., Counsel for Dennis McGlynn and respectfully requests an extension of time in which to respond to the Government's Discovery Request and an extension oftime in which to submit myown discovery requestto the government. In support of this motion I state as follows:

1. Iam counsel for Dennis McGlynn. 2. Iwas out of the countryfrom October 15, 2013 until November 10, 2013. 3. Ido not know what daythe government's discovery request arrived but it
was on my desk upon my return. Upon my return, I experienced some health issues and was in the hospital three days. 4. The government's discovery request consists oftwenty-seven requests to admit, twenty-two interrogatories, and fourteen requests for production of documents. 5. My office is located in Aurora, ILand Dennis McGlynn resides in California. It is an impossibility to complywith the government's discovery requests within 30 days.6. This request is not made to delaythe case, but merelyto insure that I am able to respond to the government's discovery request and that Iam able to submitdiscoveryto the government on Dennis McGlynn, and that he therefore have a fair hearing.
Wherefore, on behalf of myself, and Dennis McGlynn, I respectfully request that I be granted a minimum offorty-five daysto comply with the government's discovery requests and to submit myown to the government.

STATE OF ILLINOIS COUNTYOF 

# ¥**1\~** ) 

# )ss Fred M. Morelli Jr.


### ) Fred M. Morelli Jr., being first duly sworn on oath, deposes and states that he signed the foregoing statement; that he understandsthe contents thereof and thatthe same are true and correct in substance and in fact, to the best of his knowledge.

Prepared by: Fred M. Morelli, Jr. IL A

### tty No. #1957139 P.O. Box 1416 Aurora, Illinois 60507-1416 (630) 892-6665 Fred M. Morelli Jr.

### Certificate of Service
I hereby certify that on this date I have placed in the United States mail, postage pre-paid, the executed original and one copy ofthe Affidavit & Request For an Extension ofTime addressed as follows:
Federal Aviation Administration 800 IndependenceAve, SW Washington, DC 20591 Attn: Hearing Docket Clerk, AGC-430 Wilbur Wright Building - Suite 2W1 000 Facsimile: (202) 493-5142
Ifurther certify that on this date I have placed in the United States mail, postage pre-paid, a true copy of the Affidavit 

### &Requestfor an extension of time addressed as follows:
The Honorable Richard C. Goodwin, Administrative Law Judge Office of Hearings, M-20 U.S. DepartmentofTransportation 1200 NewJerseyAvenue, S.E. (E-11-310) Washington D.C. 20590 TEL 202-366-2139 Attorney-Advisor 202-366-5121 Legal Assistant FAX 202-366-7536
I also further certifythat on this date I have placed in the United States mail, postage prepaid via regular mail, a true copy ofthe Affidavit 

### &Request For An Extension ofTime addressed as follows:FDMS NO. FAA 2013-0615 (Civil Penalty Action)


### SERVICE LIST- BY U.S. MAIL

ORIGINAL AND ONE COPY Federal Aviation Administration 800 Independence Ave, S.W. Washington, D.C. 20591 Attention : Hearing DocketClerk ,AGC-430 Wilbur Wright Building -suite 2W1000


### ONE COPY Christopher Merrill, Complainant's Counsel Attorney, Office ofthe Regional Counsel, AWP-7.3 Western-Pacific Region Federal Aviation Administration P.O. Box 92007 Los Angeles CA 90009-2007 TEL310-725-7105 FAX 310-725-6816 Dennis McGlynn Respondent 659 Dorothy Way Auburn, CA95603-3862 The Honorable Richard C. Goodwin, Administrative Law Judge Office of Hearings, M-20 U.S. DepartmentofTransportation 1200 NewJerseyAvenue, S.E. (E-11-310) Washington D.C. 20590 TEL202-366·2139 Attorney-Advisor 202-366-5121 Legal Assistant FAX 202-366-7536Christopher Merrill, Complainant's Counsel Attorney, Office ofthe Regional Counsel, AWP-7.3 Western-Pacific Region Federal Aviation Administration P.O. Box 92007 Los Angeles CA 90009-2007 TEL310-725-7105 FAX 310-725-6816
Dennis McGlynn Respondent 659 Dorothy Way Auburn, CA 95603-3862
Ialso certify that on this date, I have emailed a true copy of the Affidavit 

### & Request For An Extension OfTime to Patricia Matthews, StaffAssistant:
Patrica Matthews, Staff Assistant (202) 366-521**(ES!tri<::ia.I\IISJ.tth~ws(§ldo_tgov)**

Dated:

# ~~"&\\~

Mel Morelli Adminis rative Assistant Law Offices of Morelli & Raval P.O. Box 1416 Aurora IL 60507