From: Robert Fling Fax: (281) 727-0082 To: +12024935142 Fax: +12024935142 Page 3 of 5 2/4/2014 6:04 

U.S. DEPARTMENT OF TRANSPORTATION 

OFI<'ICE OF HEARINGS 

WASHINGTON, DC 

In the Matter of: ChemSystems, Inc., ) 

Chemsystems, Inc. ) 

) 

) 

Respondent ) 

FAA DOCKET No: TBD 

FDMS No: FAA-2012-0911 

FAA Region: '"estern Pacific 

Judge: Richard C. Goodwill 

RESPONDENT'S AVAILABILITY FOR HEARING AND OPPOSITION TO 

COMPLAINANT'S MOTION FOR CHANGE I"! VENUE 

To: Honorable Richard C. Goodwin, Administrative Law Judge, and through its attorney, 

Courtney Adolph, United States Federal Aviation Administration. 

Chemsystems, Inc. ("Respondent"), by and thlough counsel, pursuant to 

Administrative Law Judge Goodwin's October 22, 2013 Amended Procedural Order 

provides the below response for hearing date availability. 

Respondent respectfully requests that the hearing date be scheduled according the 

Administrative Law Judge's order on or after March 1, 2014. 

Chemsystems, Inc. anticipates calling the accountant of Chemsystems to testify 

regarding Chemsystems, Inc.'s financial standing. Due to the Federal Income Tax filing 

deadline on April 15, 2014, the accountant's availability may be limited during the month 

of April. 

Consequently, Complainant respectihlly requests that the hearing 111 this matter be 

scheduled for March 1, 2014 or later. 

In addition, Respondent is opposed to any transfer of Venue from Houston, Texas. 

Chemsystems, Inc. is a small company, a transfer of Venue from Houston, Texas would cause 

Respondent to incur unreasonable costs associated with travel, lodging, meals and incidentals. 
From: Robert Fling Fax: (281) 727-0082 To: +12024935142 Fax: +12024935142 Page 4 of 5 2/4/2014 6:04 

Any witness or Chems;1ems, Inc. employee expected to appear in the hearing would have to 

travel to Califomia. In addition, a transfer of venue would force Respondent to incur extensive 

costs associated with legal representation as they would have to pay their current Houston based 

attomey to travel or retain new counsel in California. 

For these reasons, Respondent, Chemsystems,Inc. respectfully requests that the hearing 

in this matter be scheduled for March 1, 2014 or later. Fllliher Respondent respectfully requests 

that venue for the hearing remain in Houston, Texas. 

DATED: February 4, 2014 

Respectfully submitted, 

S. ROBERT FLING, 

ATTORNEY AT LAW, PLLC. 

!S! SR~~ 

S. ROBERT FLING 

TBA 24043660 

P.O. Box 411 

Katy, Texas 77492 

(281) 391-2003 Telephone 

(281) 727-0082 Facsimile 

Attomey for Defendant, 

Chemsystems, Inc. 
From: Robert Fling Fax: (281) 727-0082 To: +12024935142 Fax: +12024935142 Page 5 of 5 2/4/2014 6:04 

CERTIFICATE OF SERVICE 

I further certify that on this date I sent via facsimile and placed in the United States mail, 

postage prepaid, certified mail, the executed original and one copy of RESPONDENT'S 

AVAILABILITY FOR HEARING AND OPPOSITION TO COMPLAINANT'S MOTION FOR 

CHANGE IN VENUE, addressed as follows: 

Federal Aviation Administration, 

800 Independence Avenue, SW 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building-Suite 2WIOOO 

Facsimile: (202) 493-5142 

And by facsimile only to: 

Hon. Richard C. Goodwin 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Ave., S.E. 

East Building Ground Floor, Room El2-230 

Washington, D.C. 20590 

Facsimile: (202) 366-7536 

I fi.uiher certify that on this date I sent via facsimile and certified mail, postage prepaid, a true 

copy of the RESPONDENT'S AVAILABILITY FOR HEARING AND OPPOSITION TO 

COMPLAINANT'S MOTION FOR CHANGE IN VENUE, addressed as follows: 

Courtney Adoph 

General Attorney 

Oflice of the Regional Counsel 

Federal Aviation Administration 

Western-Pacific Region 

Lawndale, California 

Facsimile: (310) 725-6816 

Dated: February 4, 2014 

/S/ S. Ro-betr~ 

S. Robert Fling, 

S. Robert Fling, Attomey at Law, PLLC. 

Attorney for Chemsystems, Inc. 
From: Robert Fling Fax: (281) 727-0082 To: +12024935142 Fax: +12024935142 Page 1 of 5 2/4/2014 6:04 

I FAX I Date: 12/4/2014 

I Pages including cover sheet: J5 

To: +12024935142 From: Robert Fling 

S. Robert Fling, Attorney at 

P.O. Box 411 

Katy 

TX 77492 

Phone Phone +1 (281) 391-2003 

Fax Number +12024935142 Fax Number (281) 727-0082 

NOTE: 

FAA Docket: TBD; 

ChemSystems, Inc.; 

FAA Case No. 2011WP700181; In the Matter of 

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From: Robert Fling Fax: (281) 727-0082 To: +12024935142 Fax: +12024935142 

S. ROBERT FLING, PLLC. 

ATTORNEY AT LAW 

TELEPHONE (281) 391-2003 

FACSIMILE (281) 727-0082 

Physical Address: 

5518 Fifth Street, Suite C 

Katy, Texas 77493 

Federal Aviation Administration, 

800 Independence Avenue, SW 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wdght Building-Suite 2WIOOO 

Facsimile: (202) 493-5142 

l-Ion. Richard C. Goodwin 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Ave., S.E. 

East Building Ground Floor, Room E12-230 

Washington, D.C. 20590 

Facsimile: (202) 366-7536 

Courtney Adoph 

General Attomey 

Office of the Regional Counsel 

Federal Aviation Administration 

W estem-Pacific Region 

Lawndale, Califomia 

Facsin1ile: (310) 725-6816 

Febmary 4, 2014 

Page 2 of 5 2/4/2014 6:04 

Mailing Address: 

P.O. Box 411 

Kaiy, Texas 77 4 92 

Re:; FAA Dodcet: TBD; FAA Case No. 2011WP700181; In the ivlatter of 

ChemSystems, Inc.; 

All, 

Please see attached Respondent's Respondent's Availability For Hearing _And 

Opposition To Complainant's Motion For Change In Venue. 

Sincerely, 

IS/ S J?(Jbert-~--­

S. Robert Fling