UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

IN THE MATTER OF: 

PAZ AVIATION, INC. 

Respondent 

Tuesday, 

January 12, 2016 

FDMS No. 

FAA-2014-0807 

1 

The teleconference convened, pursuant 

to notice, at 10:00 a.m. 

BEFORE: 

THE HONORABLE J.E. SULLIVAN, 

Administrative Law Judge 

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; ,-

ORIGINAL 

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APPEARANCES: 

On Behalf of the Complainant: 

BRANDON C. GOLDBERG, ESQ. 

of: Office of the Chief Counsel 

Federal Aviation Administration 

1701 Columbia Avenue 

Suite 530 

College Park, Georgia 30337 

(404) 305-5200 

On Behalf of the Respondent: 

DAVID M. MCDONALD, ESQ. 

of: McLuskey, McDonald & Hughes, P.A. 

The Barrister Building 

8821 s.w. 69th Court 

Miami, Florida 33156 

(305) 662-6160 

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1 P-R-0-C-E-E-D-I-N-G-S 

2 (10:08 a.m.) 

3 JUDGE SULLIVAN: We're on the record in 

4 the matter of Paz Aviation, Inc. This is Docket 

5 No. FAA-2014-0807. 

6 Today is Tuesday, January 12, 2016, 

7 and the parties have convened by telephone for a 

8 Rule 16 schedule litigation scheduling 

9 conference. 

10 The Federal Aviation Administration, 

11 which I'll hereinafter refer to by its initials, 

12 the FAA, is represented by its attorney of 

13 record, Mr. Brandon C. Goldberg. 

14 The Respondent, Paz Aviation, Inc., is 

15 represented by its attorney of record, Mr. David 

16 M. McDonald. 

17 Good morning and happy New Year to you 

18 both. 

19 As you all are aware, on October 1, 

20 2015, an Order setting a Rule 16 litigation 

21 scheduling conference was filed, and on January 

22 4, 2016, the parties filed a joint proposed 

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1 scheduling plan, which I've had a chance to take 

2 a look at. And I wanted to ask you a couple 

3 questions about it, if I may. But I think the 

4 easiest thing to do is to just go through the 

5 plan, chronologically, as you have listed out 

6 your preferences, and then talk about the 

7 questions as they arise. 

8 So I had no problem adopting your 

9 February 5' 2016 deadline for initial 

10 disclosures, and I apologize, folks. I'm looking 

11 at page one of the two page joint proposed 

12 scheduling plan. I'm happy to adopt the February 

13 8, 2016 general discovery initiation date. 

14 I'm happy to adopt the March 25, 2016 

15 deadline for the exchange of initial expert 

16 reports. 

17 I do have a question about that. You 

18 had indicated that both of you would be 

19 exchanging reports simultaneously, and that's 

20 fine. You also indicated, a little further down 

21 the page, that July 22 was the deadline for the 

22 supplemental expert witness reports, which would 

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1 be workable. The question I have, however, is 

2 that if, after the period that you've identified 

3 for depositions of both experts, and non-experts, 

4 and typically what I see is the expert rebuttal 

5 report being exchanged prior to the deposition 

6 deadline being closed, in part, because if you 

7 get an expert rebuttal report and you don't have 

8 any questions, you generally don't depose that 

9 person. 

10 But I was wondering if there was a 

11 particular reason for this particular scheduling, 

12 and I'll start with the FAA attorney, Mr. 

13 Goldberg. Any thoughts about why you were doing 

14 it this way instead of the way the courts 

15 normally seem anyway. 

16 MR. GOLDBERG: There was no reason, 

17 Your Honor. Just as a, perhaps additional time 

18 for an expert to prepare a report. But if 

19 flipping those dates excuse me if 

20 flipping those dates makes more sense, we would 

21 have no objection to that. 

22 JUDGE SULLIVAN: Okay. And when you say 

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1 flipping the dates, you're talking about the July 

2 8 versus July 22 date? 

3 MR. GOLDBERG: Yes. That's correct. Or 

4 some other combination that allows for the 

5 supplemental reports to be submitted prior to the 

6 end of the deposition period. 

7 JUDGE SULLIVAN: Mr. McDonald, what are 

8 your thoughts about that? 

9 MR. MCDONALD: Well, as the court 

10 pointed out and, made a good point that, -- that 

11 we didn't catch. I am also fine with tending the 

12 dates, accordingly. 

13 JUDGE SULLIVAN: Okay. 

14 MR. MCDONALD: Probably ought to flip 

15 them around. 

16 JUDGE SULLIVAN: Okay. Why don't we do 

17 that. Why don't we send that -- say that the July 

18 8, 2016, is at least the deadline for exchanging 

19 expert rebuttal reports. 

20 MR. MCDONALD: Okay. 

21 JUDGE SULLIVAN: And that way --- and 

22 then we'll put July 22, 2016 for the end of the 

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1 deposition period. That will at least give both 

2 of you an opportunity to depose an expert, if you 

3 think it's needed before that deadline expires. 

4 So let's go back up where I left off, 

5 and then we can work our way down here. 

6 We had talked about March 25, 2016, 

7 for the mutual exchange of initial expert 

8 disclosures. I'm happy to adopt the March 28, 

9 2016 beginning of the deposition period. I'm 

10 happy to adopt the May 16, 2016 deadline for 

11 issuing deposition notices, and request for 

12 subpoenas for third party depositions. We'll 

13 then have the July 8, 2016 exchange of expert 

14 rebuttal reports, with a July 22, 2016 end of the 

15 deposition period. 

16 You had also indicated for a July 22, 

17 2016 date, the deadline to issue written 

18 discovery requests, and I'm happy to maintain 

19 that deadline, if that's acceptable. Mr. 

20 Goldberg? 

21 MR. GOLDBERG: Yes, Your Honor. That's 

22 fine. 

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1 JUDGE SULLIVAN: And Mr. McDonald? 

2 MR. MCDONALD: Yes, Your Honor. 

3 JUDGE SULLIVAN: Okay. I wanted to ask 

4 another question, and this is about the August 

5 26, 2016 close of general discovery. 

6 You had indicated that all discovery 

7 responses to be due by this date, except for 

8 discovery time available to resolve disputes on 

9 existing discovery. 

10 What were you thinking about in that 

11 regard, because I wasn't quite sure? Mr. 

12 Goldberg. 

13 MR. GOLDBERG: Your Honor, our hope 

14 there was to essentially allow a window, that if 

15 there had been some dispute, that we were able to 

16 either resolve amongst ourselves, or with the 

17 court's assistance, that we would still be able 

18 to --- we wouldn't cut ourself off, essentially, 

19 if we needed more time, although certainly if all 

20 the parties agreed and Your Honor agreed, I 

21 suppose we could alter the schedule at a future 

22 date, if necessary. 

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1 JUDGE SULLIVAN: And Mr. McDonald, what 

2 were your thoughts about this? 

3 MR. MCDONALD: Well, you know this was 

4 drafted by the FAA, and I went through it. I 

5 didn't have an objection to it. I understood what 

6 he meant with --- you know, I interpreted what he 

7 just said, which was that he intended to have an 

8 opportunity for us to resolve any disputes, and 

9 get a court order and discovery before the 

10 September 30 final close. 

11 JUDGE SULLIVAN: Okay. 

12 MR. MCDONALD: Which made sense to me. 

13 JUDGE SULLIVAN: Yeah. I actually will 

14 be giving you deadlines for filing motions, if 

15 there's discovery disputes, and in the past, what 

16 I've done is I've indicated, in my litigation 

17 order, is that there should be a filing, after a 

18 good-faith discussion, within ten to fifteen days 

19 of the dispute being noticed. And I 'm happy to 

20 be a little flexible with that particular 

21 turnaround time. 

22 But that way, if you see a problem, 

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1 then you address it immediately, and you address 

2 it within your discovery period. 

3 Typically, what happens then is that 

4 it's taken care of before your discovery closes. 

5 If, in the rare occasion when it's 

6 not, then we can discuss keeping the door open 

7 for any remaining discovery that needs to be 

8 addressed because that dispute intervened. 

9 So it would seem to me, perhaps, that 

10 we could simply adopt the September 30, 2016 date 

11 for final close of discovery, if the parties are 

12 aware --- and I'm trying to apprise you of that -

13 -- that you do have an ongoing obligation, under 

14 the litigation schedule that I'll be signing, to 

15 bring discovery disputes to the court's attention 

16 fairly quickly. Mr. Goldberg, would that work to 

17 your client's benefit, do you think? 

18 MR. GOLDBERG: That should be fine, 

19 Your Honor. Yes. 

20 JUDGE SULLIVAN: And Mr. McDonald, same 

21 question to you. 

22 MR. MCDONALD: Yes, Your Honor. I think 

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1 that's a fine way to resolve it. 

2 JUDGE SULLIVAN: Okay. Then what I will 

3 do in this proposed --- I have a draft in front 

4 of me right now--- litigation schedule, is I'll 

5 just note that motions for relief regarding 

6 discovery disputes should be made within 15 days 

7 after --

8 MR. MCDONALD: Become aware of the --

9 JUDGE SULLIVAN: Yeah, after becoming 

10 aware, essentially. And you'll see in my orders 

11 that there's a requirement for a good faith 

12 discussion, first, so that you can try and 

13 resolve it informally, and then if you can't, to 

14 submit a good faith declaration as part of the 

15 motion involving discovery. 

16 So let's strike the proposed August 

17 26, 2016 date, and that gives you both just an 

18 extra time for general discovery, with general 

19 discovery closing as of September 30, 2016. 

20 And then I'm happy to adopt, on the 

21 top of page two of your joint proposed scheduling 

22 plan, -- excuse me --- the -- let's see --August 

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1 -- I'm sorry, October 14, 2016 dispositive motion 

2 deadline, October 28, 2016 response to 

3 dispositive motion, and November 4, 2016 deadline 

4 for reply. 

5 My question to you is a the 

6 specific date for a motion conference, and we're 

7 going to looking for a 90 minute time period in 

8 early December 2016. I'll ask you both to take a 

9 look at your calendars, and once we look at that 

10 time period and codify a date, we may want to 

11 tweak a little bit, the proposals for the motion 

12 filings, if you would like. 

13 So Mr. Goldberg, starting with you, I 

14 actually have a trial already, the first week of 

15 December, so we're looking at the second week of 

16 December, which begins with Monday, December 12. 

17 In looking at your calendar, is there 

18 anything that would be a blackout time for the 

19 days of December 13, 14, or 15, to your 

20 knowledge? 

21 MR. GOLDBERG: No, Your Honor. Those 

22 days are all clear for me. 

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1 JUDGE SULLIVAN: And Mr. McDonald, same 

2 question to you, sir. 

3 MR. MCDONALD: I'm wide open, Your 

4 Honor. 

5 JUDGE SULLIVAN: Staying with you, Mr. 

6 McDonald, do you have any preference? 

7 MR. MCDONALD: The 14th. 

8 JUDGE SULLIVAN: Morning or afternoon. 

9 MR. MCDONALD: Nothing good happens on 

10 the 13th. 

11 JUDGE SULLIVAN: Always err on the side 

12 of caution. Do you have a morning or afternoon 

13 preference, sir. 

14 MR. MCDONALD: I would prefer after 

15 lunch, I think, Your Honor. 

16 JUDGE SULLIVAN: And where are you 

17 located? Miami. So Eastern you're at the 

18 Eastern --

19 MR. MCDONALD: Yes. 

20 JUDGE SULLIVAN: Period. And 

21 MR. MCDONALD: Yes, we're on the east. 

22 JUDGE SULLIVAN: Okay. We all are. 

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1 Mr. Goldberg, turning back to you, 

2 would Wednesday, December 14, 2016, in the 

3 afternoon, work for you? 

4 MR. GOLDBERG: Yes, Your Honor. 

5 JUDGE SULLIVAN: Okay. Then let's plan 

6 on December 14, 2016. Let's say 1:30 to 3:00 

7 p.m., to be on the safe side. You may find that 

8 once we get to that conference, it won't take 90 

9 minutes, but I've had enough of the summary 

10 judgment motion conferences run a little bit over 

11 one hour, so I'm scheduling them now for 90 

12 minutes, just so that everybody has that time 

13 calendared out. 

14 In the event neither party files any 

15 dispositive motions, keep this case conference on 

16 your calendar, because I'll use it as a 

17 prehearing status conference. 

18 MR. MCDONALD: Okay. 

19 JUDGE SULLIVAN: Now you had asked for 

20 a prehearing status conference shortly before the 

21 hearing date. We need to talk about the hearing 

22 date in spring of 2017. I'm going to ask you both 

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1 to take a look at your calendars in April 2017, 

2 and I'm wondering, starting with you, Mr. 

3 Goldberg, if the week of April 10, 2017, would be 

4 feasible. 

5 MR. GOLDBERG: The week of April lOth. 

6 That should be fine, Your Honor. I'm only looking 

7 because that's the week of the Passover holiday, 

8 although that should not interfere with this. 

9 10:19:29. 

10 JUDGE SULLIVAN: Okay. Well, let me 

11 take a look at some of my other timeframes. I 

12 can go in to March instead of April, if that 

13 would make things a little bit more comfortable. 

14 MR. GOLDBERG: If we were to do it on 

15 Monday, the lOth, that would actually be just 

16 before the holiday. That should be fine. 

17 JUDGE SULLIVAN: Well, how much time do 

18 you think this hearing will take? 

19 MR. GOLDBERG: To be honest, Your 

20 Honor, I don't know. I don't know at this stage. 

21 JUDGE SULLIVAN: So Mr. McDonald, I'll 

22 turn to you. Do you have any general estimate of 

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1 how much time the hearing would take? 

2 MR. MCDONALD: Assuming that the court 

3 works, you know, an eight hour day, I would think 

4 we would have no trouble concluding this in two 

5 and a half days. 

6 JUDGE SULLIVAN: Two and a half days? 

7 Okay. 

8 MR. GOLDBERG: In that instance, Your 

9 Honor, may looking for a different week would be 

10 better on my end, if that's all right. 

11 JUDGE SULLIVAN: Okay. And then where 

12 would the hearing be, preferably, for you, Mr. 

13 Goldberg? 

14 MR. GOLDBERG: Oh, we can hold that in 

15 a location that's convenient for Mr. McDonald and 

16 his clients, so --

17 JUDGE SULLIVAN: And Mr. McDonald, same 

18 question to you, sir. 

19 MR. MCDONALD: Miami's a lovely place 

20 that time of year. 

21 JUDGE SULLIVAN: Miami, Florida. Okay. 

22 Let's look at a week. Give me a minute 

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1 to look at my calendar. How about the week of 

2 March 13, Mr. Goldberg? 

3 MR. GOLDBERG: That should be fine, 

4 Your Honor. 

5 JUDGE SULLIVAN: And Mr. McDonald? 

6 MR. MCDONALD: Yeah. That's fine, 

7 Judge. 

8 JUDGE SULLIVAN: Okay. Let 1 s plan on 

9 March 13, 2017 as a travel day for those of us 

10 who may have to come in from out of town. We'll 

11 start the hearing on March 14, 2017, and we' 11 

12 continue on March 15, 2017, and we'll finish by 

13 the conclusion of March 16, 2017. Friday, of 

14 March 17, 2 017. Is March 17 is that St. 

15 Patrick's Day, by any chance? 

16 MR. MCDONALD: I believe. 

17 JUDGE SULLIVAN: I'm just wondering if 

18 that's going to be a problem for travel. 

19 Shouldn't be. Shouldn't be. March 17, 2017 is a 

2 o travel day, let's say. Okay. So that means a 

21 little bit about the final proposed day on page 

22 two of the parties' joint plan. 

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1 Mr. Goldberg, starting with you, you 

2 had indicated a deadline for exchange of witness 

3 lists and exhibits of March 3, 2017. we probably 

4 want to move that back a little bit. 

5 How much time do you usually prefer to 

6 have, prior to the hearing, to exchange that 

7 information with your friend across the aisle? 

8 MR. GOLDBERG: Oh, maybe several 

9 months. Certainly, moving it up back into January 

10 or February would be fine. We were, at that stage 

11 in the calendar, just making up dates based on a 

12 guesstimate of when the hearing would be. 

13 JUDGE SULLIVAN: Okay. Mr. McDonald, 

14 same question to you. 

15 MR. MCDONALD: Yeah. I think February's 

16 fine. 

17 JUDGE SULLIVAN: Okay. 

18 MR. MCDONALD: Maybe January. 

19 JUDGE SULLIVAN: Why don't we I'm 

20 looking --- I need to just double-check with the 

21 --- we've got a motion conference. Why don't we 

22 have the exchange of witness lists in February 

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1 2017, and why don't we just use that same date 

2 for the deadline to file any written stipulations 

3 or agreed motions in limine. 

4 And then that would bring us to a 

5 January or February 2017 prehearing conference. 

6 Why don't we do this. Since we've 

7 pushed this time period up a little bit, and 

8 we're going to have that conference in December 

9 2016, why don't we not schedule another 

10 conference the next month but wait until that 

11 December 2016 conference. If we find that we want 

12 to have another telephone conference prior to the 

13 hearing, sometime either in January or February, 

14 we can set that up on a short matter on my 

15 calendar. Unless the parties think that they'll 

16 be so booked up, that they won't be able to do 

17 that. 

18 Mr. Goldberg, what are your thoughts 

19 about that? 

20 MR. GOLDBERG: I think that would make 

21 sense, Your Honor. We should be able to find a 

22 time frame. 

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1 JUDGE SULLIVAN: Mr. McDonald, what are 

2 your thoughts? 

3 MR. MCDONALD: I agree. 

4 JUDGE SULLIVAN: Okay. Then let' s do 

5 that. Let me look at anything else I need to chat 

6 with the two of you about. 

7 MR. MCDONALD: Your Honor, the phone 

8 burped just a little bit and I didn't get the 

9 February date for the exchange of witnesses. 

10 JUDGE SULLIVAN: Okay. That would be 

11 February 10, 2017, which is a Friday. 

12 MR. MCDONALD: Thank you. 

13 JUDGE SULLIVAN: You're welcome. And I 

14 also had suggested February 10, 2017 for filing 

15 any written stipulations and/or agreed motions in 

16 limine. That doesn't prohibit you, obviously, 

17 from coming to the hearing and making a motion in 

18 limine orally, because things do happen. 

19 But if there are things that you can 

20 take off the plate, because witnesses can be --

21 eliminated because of a grievance, you know, 

22 that's better to do it, up front. 

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1 So then Mr. Goldberg, turning to you, 

2 anything else that you would like to address with 

3 the court, on behalf of your client, today, for 

4 litigation scheduling? 

5 MR. GOLDBERG: No, Your Honor. Thank 

6 you. 

7 JUDGE SULLIVAN: Okay. And Mr. 

8 McDonald, same question. 

9 MR. MCDONALD: Yes, Your Honor. Mr. 

10 Goldberg and I briefly discussed this previously, 

11 but unfortunately, the first of December, my 

12 client, the principal owner and an operator, has 

13 passed away. Had a sudden heart attack. 

14 And at this point the surviving family 

15 is trying to figure out how to take over and 

16 operate the business, and keep it going. 

17 I wanted the court to be aware of 

18 that. We've just recently had the probate estate 

19 opened, just before Christmas, and the personal 

20 representative has been appointed, and right now 

21 

22 

they're moving through the period, taking 

operational 

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1 Unfortunately, the owner, Mr. Joe Allen was ---

2 he had other employees, but from a management 

3 standpoint he was a one man band, and just the 

4 guy in charge, and signatory on bank accounts and 

5 things such as that. 

6 So we've been scrambling to address 

7 the need to handle simple things, such as 

8 payroll. 

9 I wanted the court to be aware of 

10 that. I briefly spoke with Mr. Goldberg about 

11 this in December, when it happened, and we were 

12 beginning to work on this proposed scheduling 

13 dates. 

14 And they were and I had both - -

15 once the family can get their hands wrapped 

16 around the business, you know, are certainly 

17 going to explore trying to resolve this amicably. 

18 JUDGE SULLIVAN: Would it be helpful to 

19 you to have a conference scheduled two or three 

20 months from now, just as a status conference? Or 

21 do you think you can address all the things that 

22 you need to without the court's oversight? 

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1 MR. MCDONALD: Unless the court's 

2 schedule is remarkably busy, and you're going to 

3 set time aside for such a thing, I don't have a 

4 problem with placing the burden upon me to give 

5 the court a status report, you know, like 

6 let's say mid-March. The ides of March. 

7 JUDGE SULLIVAN: Okay. 

8 MR. MCDONALD: And --

9 JUDGE SULLIVAN: Why don't we do that, 

10 just --

11 MR. MCDONALD: And then we can --

12 JUDGE SULLIVAN: Yeah. Just to have a 

13 brief written status report. That would be very 

14 helpful. And then I will of course certainly 

15 extend my sincere regrets to the family, the 

16 passing of Mr. Allen. As you have noted, that 

17 kind of makes it much more difficult for the 

18 family when it's entwined, not only with personal 

19 issues but business issues. 

20 MR. MCDONALD: Yes. 

21 JUDGE SULLIVAN: You 1 ll also note ---

22 I also have boilerplate in my litigation order 

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1 about attorney withdrawal, if at a certain point 

2 the family decides to not proceed with counsel. 

3 I'm not saying that that's a good idea, but I've 

4 had this happen in the past. It will give you 

5 very specific information about how to withdraw, 

6 so that Mr. Goldberg and the court have notice of 

7 who's taking your place. 

8 MR. MCDONALD: Okay. I don 1 t foresee 

9 that happening. 

10 JUDGE SULLIVAN: No, I would hope that 

11 it would not, but I'm just kind of trying to 

12 cover all the bases. 

13 So what time in --- when, in March, 

14 would you like to set up a written status report 

15 deadline for your client? 

16 MR. MCDONALD: Well, looking at the 

17 calendar, I see that March 15th is on a Tuesday. 

18 So why don't we just I'll have something 

19 submitted by Friday, the 18th. 

20 JUDGE SULLIVAN: Okay. Okay. That 

21 sounds great. And then anything else that you 

22 would like to address for your client, Mr. 

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1 McDonald? 

2 MR. MCDONALD: No, Your Honor. 

3 JUDGE SULLIVAN: Then it appears our 

4 business is complete, at least for now. I'll be 

5 issuing an order setting litigation dates and 

6 procedures, no later than tomorrow, and then I 

7 should have everybody's fax number, it looks like 

8 I do, and I'll also fax a courtesy copy to your 

9 offices, so that you have it forthwith. 

10 With that, I'll wish you all a very 

11 good day. Thank you very much for your time. We 

12 can go off the record. Thank you all. 

13 (Whereupon, the above-entitled matter 

14 went off the record at 10:31 a.m.) 

15 

16 

17 

18 

19 

20 

21 

22 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 (202) 234-4433 
A 

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Neal R. Gross and Co., Inc. 

Washington DC 

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Neal R. Gross and Co., Inc. 

Washington DC 

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

Washington DC www.nealrgross.com 
30 

C E R T I F I C A T E 

This is to certify that the foregoing transcript 

In the matter of: Paz Aviation 

Before: us DOT 

Date: 01-12-16 

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 

NEAL R. GROSS 

(202) 234-4433 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISUAND AVE, N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com