In the Matter of: SeaHawkAir, Inc. UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS

WASHINGTON, D.C. 

# RECEIVED JUN 072016 

## HEARING DOCKET ) ) ) ) ) ) ) ) ) ) DocketNo. FAA-2014-0865 FAA Case No. 2011M730060

RESPONDENT'S RESPONSE TO ORDERTO SHOW CAUSE AND PROVISION OF REQUESTED LITIGATION SCHEDULES SeaHawkAir, Inc., Respondent, by its undersigned counsel hereby files this response to Your Honor's May 17th Order to Show Cause and Provide Requested Information and provides the following: The undersignedhadtwo initialtelephone conferences with Complainant's counsel in April, 2016 in an effort to comply with Your Honor's April 4th Order. During these telephone conferences, counsel discussed the substance ofthe underlying matter, exchanged settlement offers andbriefly discussed expectations for discovery. Theundersigned was out ofthe office traveling onMay 2nd, and was not available for Complainant's counsel's call. The undersigned then received Complainant's counsel's Response, filed withthis Court, onMay 3'd. The undersigned had some initial difficulty reaching Respondent after Your Honor's April 4th Order. This inability to confer withRespondent inhibited the ability to meaningfully confer with Complainant's counsel. However, the undersigned has nowreestablished contact withRespondent and meaningfully conferred with Complainant's counsel. After conferring with Complainant's counsel, the Parties agreed upon andjointly propose the following:

### • Counsel have privately conducted an informal conference and meaningfully discussedthe litigation issues and a proposed schedule. • The Parties agree that the proper venue is Anchorage, Alaska. • The Parties propose that all discovery be completed no later than August 31, 2016. • Neither Party is aware ofany pending motions. • Complainant's counsel is available for a prehearing conference on any date other than the following: o June 20-241\ o June 291\ or o July 13-16th. • Respondent's counsel is available for a prehearing conference on any date other thanthe following: 

### o June 9-101 h, o June 17th, or o August lOth. • The Parties propose that all pre-hearing motions be filed no later than September 30, 2016. • The Parties propose a hearing date ofDecember 7th, with alternate dates of November 1Oth, January 17th, and February 23'd.

Dated: June 1, 2016 Respectfully submitted, THE

### LAW OFFICE OF JoHN 

### L. WRIGHT, PC

L. Wright 11705 Airport Way, Suite 307 Broomfield, Colorado 80021 Telephone: (303) 747-4000 Facsimile: (303) 747-4001CERTIFICATE OF SERVICE I hereby certify that I have this date mailed, by facsimile and USPS Priority Mail service, an original and one copy ofthe foregoing Response to Order to Show Cause and Provision of Requested Litigation Schedules addressed to: Federal Aviation Administration Attention: Hearing Docket Clerk, AGC-430 Wilbur Wright Building- Room 2Wl000 800 Independence Ave. S.W. Washington, DC 20591 Facsimile: (202) 267-1293 And, further, I hereby certify that I have this date mailed, by facsimile and USPS Priority Mail service, one copy ofthe foregoing Response to Order to Show Cause and Provision of Requested Litigation Schedules addressedto: The Honorable Douglas M. Rawald, Administrative LawJudge Office ofHearings, M-20 U.S. Department ofTransportation 1200 NewJersey Avenue, S.E. (Ell-310) Washington, D.C. 20590 Facsimile: (202) 366-7536 Mr. Kyle Lomazow, Counsel for Complainant 222 West Seventh Avenue #14 Anchorage, Alaska 99513-7587 Facsimile: (907) 271-2800

THELAW OFFICE OF JOHNL. WRIGHT, PC

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Broomfield, Colorado 80021 Telephone: (303) 747-4000 Facsimile: (303) 747-4001