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'V-pARTMENTOF 

• MICHAEL B. SEUG, M.D„ RA.CC. ;McPO[TfAT!qN ^ 

LifeLine Cardiolog y -i 0:--j;i'AT!0^':; '^X 

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01 

Federal Docket 20?0-]2M 

FAA File 2009SO950434 

M & R Helicopters 

2816 0refielci Road 

Allentown, PA. 18104 

January 6, 2011 

The Honorable Ronnie A. Yoder 

US Department of Transportation 

Office of Hearings, M-20, Room El2-320 

1200 New Jersey Avenue. S.E. 

Washiingfon, DC 20590 

FAX 202 366 7536 

Re: Deposition of Latonya Williams and Federal Hearing Location 

Dear Judge Yoder; 

This letter is in response to Ms Ponto's correspondence dated December 

30, 2010. in her letter she made several misrepresentations that I would like to 

correct of this time. At no time did I request or agree to a hearing location in 

Philadelphia, PA or Washington DC. In fact, during the informal hearing of 

October 1, 2010, Ms Ponto stated that there was a court location in Ailentown 

PA, which was confirmed to as an option and jointly agreed to. 

Ms Ponto also evaded and circumvented the main reason for requesting 

the Ailentown location, as stated in my letter of November 24, 2010, namely my 

role in the community os a solo, private practice cardiologist (for the last 23 

years) with hospital and outpatient responsibilities. To leave the area would be 

a hardship to my patients and myself. Nevertheless, it was in her letter of 

November 17, 2010 that she on her own accord, requested the Philadelphia 

hearing location. 

Ms Ponto mentioned that Philadelphia is only 1 hour and 15 minutes away, 

which is also incorrect, as it closer 2 hours at off hours, but can be several hours 

of hold up time during business hours due to the insurmountable traffic on the 

Schuylkill Expressway and in the downtown area. There is as well heavy air 

traffic and continuous delays in Philadelphia o% compared to the easy access to 

Ailentown both in air and ground traffic. 

It is as well, appropriate, proper and follows suit that since the violation 

Gateway Fmfessionsl Center » 2045 Westgate DrivB, Suite 205 • Bethlehem, Pennsylvania 18017-7474 

VolceAi'M 610-868-6200 • Fax 610-868-1489 • Education Sen/Ice 610-068-6203 • B-Mall llfeDnecard^verlzon.net 
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010002/0006 

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was investigated, Initiated and generated by Ms Williams coming to the 

Ailentown location requiring 2 visits (specifically to my joint cardiology/air charter 

office), then it would only follow suite that under the circumstances, the hearing 

should thereby be held in the Ailentown location as to not in addition, 

inconvenience my patients, disrupt the continuity of core, put them at risk or 

add additional liability or malpractice, 

Ms Ponto agreed to a deposition of Ms Williams and cited erred dates for 

pre-trial deposition of Ms Williams in her response dated December 20, 2010 of 

"January 28, 2010. February 1-4, 2010, February 8-11, 2010 or February 15-17, 

2010". Respondent does agree to these dates except as the dates apply to the 

year 2011 at 10 am, as fitting to Ms Williams schedule In the Ailentown, location 

namely at; 

Gallagher Reporting and Video, LLC, 

1600 Lehigh Parkway East, Suite 1H 

Ailentown, PA 18103. 

Once I am notified of the date that best suits Ms Williams schedule for the 

pre-trial deposition, I can firm up the other details. I will of course cover the costs 

pertaining to the room and court reporter, 

I am led to believe that your office would need to set up the hearing at 

the US District Court located at 504 Hamilton Street, Ailentown, PA. 18101, in the 

event that you believe this cose should proceed. 

I am hopeful that this court will find: 

1. The conduct by Ms Williams and Ms Ponto to be procedural and prosecutorial 

overreaching. 

2. That the complainants are trying to hold the respondent to a higher standard 

than their own officials in regard to regulations that were not evident or known. 

3. Issues of judicial estoppels, legal inconsistency and procedural defects, 

4. That inappropriate action has been taken against a small single pilot 

operation that has had negative cash flow and had long stopped operating in 

due diligence, good judgment and good faith due to human factors of a tragic 

divorce case scenario in order to not expose the public to undue risk, 

5. Rapidly initiated the appropriate changes once respondent became aware, 

despite not performing operations. 

6. That precious scarce judicial resources are being squandered on a case that 

appears frivolous, trivial, without merit, while representing an aggressive 

prosecutorial pursuit that lacks proper perspective or good judgment. 

Thank you for your kind considerations. 
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Yours Sincerely, 

Michael Selig, MD, FACC. CFI-H \ 

cc. Hearing Docket, Clerk 
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FAA + DMS 2)004/00 6 

1210004/0005 

M & R Helicopters, LLC. 

2816 OrefieldRoad 

Ailentown, PA. 18104 

November 24, 2010 

Please fiio a wi'iiien 

ro-sponse Lo the enclosod 

document within (20) days 

of service. 

D O T Docket No. TBA 

FAA Case No. 2009SO950434 

Laura Ponto, Esq 

Enforcement Division/AGC-300 

Office of the Chief Counst:! 

Federal Aviation Administration 

800 Independence Avenue, yW, 

Washington, DC 20591. 

Sen t by PAX 202.267-510 6 

Re: Ailentown DOT Hearing/ OutBtandlng Diacovery 

Dear Ms Ponto: 

Pursuant to your correspondence dated November 17, 2010, telephone 

communication on October 1, 2010 and my letter of October 27, 2010, please 

be advised that MR Helicopters is requesting a venue change to Ailentown^ PA 

DOT court. This topic was discussed during our most recent conversation, 

wherein you stated and confirmed that Ailentown DOT court was available. 

Accordingly, I ask tha t we move the hearing from Philadelphia to Ailentown, PA 

since it would be a hardship on my schedule a s a solo private practice 

cardiologist. 

In addition there were several items in my October 27, 2010 letter which 

were not addressed including the following; 

1. Full and complete copies of eveiy regulation referenced as a violation, 

inclusive of all adoption dates, as I have found them difficult to access on the 

FAA website or using several search engines. You have been exti'emely kind 

providing 3 copies of the penalty proceedings regulations, however to date 1 

have not received copies of referenced regulaiions that you claim are in 

violation. 

2. While portions of the investigation report were provided to me, a complete 

report is needed at this time. There was one page that was deducted and 

spoliated, please provide the complete unaltered document. The other 

documents given were already in my records, Omitted was the reference for 
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case Jordon v Department of Justice, as well as the specific regulation 

regarding the allowance of your disclosure restriction. 

Thank you for your kind considerations. 

Yours Sincerely > "^ 

Michael Selig, MD, FACC, CFI-H 

cc. 

Federal Aviation Administration 

600 Independence Avenue, SW 

Wilbur Wright Avenuc-Suite 2W1000 

Washington, D.C. 20S91 

Att: Hearing Docket Clerk, AGC-430 
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FAA -> DM S IgOOG/OOe 

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U.S. DEPARTMENT OF TRANSPORTATION 

Federal Aviation Administration 

Cynthia Dominik, Laura Ponto, 

Latonya Wlllioms 

Complolnants 

M & R Hellcopteis, LLC. 

Respondent 

Honorable Judge Ronnie Yoder 

Docker: 2070-1211 

CERTIFICATE OF SERVICE 

( HEREBY CERTIFy that 1 have this aay served the foregoing entrie(s): 

Deposinon of Latonya Williams and Federal Hearing Location 

(Letter) 

upon all parties of record in ihis proceeding, in accordance with the requirements ot Rule 29 

pursuant to 28 U. S. C. § 1746 . 

Service by first-class mail,postaae prepaid, addressed astollows: 

Federal Aviation Administration 

000 Independence Avenue, SW 

Wilbur Wright Avenue-Suite 2W1CIO0 

Washington, D.C. 20591 

Att; Hearing Docket Clerk, AOC-430 

FAX 202 493 5142 

Laura Ponto, Esq. 

Enforcement Division/AGC-SOO 

Office of Ihe Chief Counsel 

FAA 

800 Independence Avenue, SW 

WasNngton, DC 20591 

FAX 202 267 5106 

By: 

Michael B. Selig, MD, FACC. 

2816 OrefieldRoad 

Ailentown, Pa. 18104 

610 360 3953 

Date; 

^ 

^ ^ 

V -^^ \ 

The Honorable Ronnie A. Yoder 

US Department of Transportation 

Office of Hearings, M-20, Room El 2^20 

1200 New Jersey Avenue. S.E. 

Washington, DC 20590 

FAX 202 366 7536