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U.S.DEPARTMENTOFTRANSPORTATIONRECEIVEO 

FEDERAL AVIATION ADMINISTRATION 

JUN- ~ -2012 

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HEARING DOCKET 

In the matter of: 

BADGER HELICOPTERS, INC. 

FAA Docket No. CP-2012-0201 

Case No. 2011AL910019 

Judge Richard C. Goodwin 

COMPLAINT ANT'S MOTION TO EXTEND DISCOVERY DEADLINE 

Pursuant to Section 13.218(a) of the Rules of Practice in FAA Civil Penalty Actions, 

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14 C.P.R.§ 13.208(a), the Complainant hereby files this motion to extend the discovery deadline 

in the above-captioned matter, and in support of this motion states as follows: 

1. On June 1, 2012, U.S. Administrative Law Judge Richard C. Goodwin issued ari 

Order (hereinafter "ALJ's Order") denying Complainant's May 9, 2012 motion to deem the 

allegations in the complaint admitted and accepting Respondent's May 31, 2012 answer to the 

complaint. In so ruling, the ALJ noted that Respondent's May 31, 2012 answer was 

accompanied by a letter from its President (who is also its representative in this matter) stating 

that Respondent had misunderstood the requirement to file an answer, which the ALJ found 

adequately explained Respondent's failure to timely answer the complaint in this matter.1 ALJ 

Order at 1. The ALJ thus accepted Respondent's answer, denied Complainant's motion, and 

informed the parties that "[t]he matter will proceed." ALJ Order at 2. 

2. Discovery in this matter was scheduled to close in the ordinary course of this 

proceeding on June 1, 2012. See ALJ's Procedural Order dated April12, 2012. However, 

Respondent's answer to the complaint, which is essential to ascertaining what is in dispute in this 

matter and was originally due on April19, 2012, was not submitted by Respondent until May 31, 

1 Undersigned counsel for Complainant was not served with a copy of Respondent's letter of explanation referenced 

in the ALI's Order. 
2012 and not accepted for filing until June 1, 2012 (the same date the ALJ's Procedural Order 

provides as the discovery deadline in this case). 

3. Given the circumstances as described above, Complainant requests that the 

June 1, 2012 discovery deadline set forth in the ALJ's Procedural Order be extended until 

July 13, 2012, in order to allow the parties a reasonable opportunity for discovery in this matter. 

WHEREFORE, the Complainant respectfully requests that the June 1, 2012 discovery 

deadline be extended until July 13, 2012. 

Dated: June 2, 2012 

Respectfully submitted, 

Peter J. Lynch 

Assistant Chief Counsel 

Enforcement Division, AGC-300 

~1f~ffL6 Senior Attorney 

Enforcement Division, AGC-300 

Federal Aviation Administration 

Office of the Chief Counsel 

800 Independence Ave., S.W. 

Washington, D.C. 20591 

Telephone: (202) 267-7268 

Facsimile: (202) 267-5106 

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CERTIFICATE OF SERVICE 

I hereby certify that on this date, I have sent by U.S. certified mail, a copy of the 

foregoing Motion to Extend Discovery Deadline in the matter of Badger Helicopters, Inc., 

FAA Docket No. CP-2012-0201, Case No. 2011AL910019, to: 

Michael Jacob, President 

Badger Helicopters, Inc., Respondent 

24564 Hwy 16/385 

Custer, SD 57730 

AND 

The Honorable Richard C. Goodwin, Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200New Jersey Ave., S.E., RoomEll-310 

Washington, DC 20590 

In addition, I hereby certify that on this date, I have sent by U.S. certified mail the 

original and one copy of the foregoing document to: 

Hearing Docket 

Federal Aviation Administration 

Orville Wright Building 

800 Independence A venue, SW 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building - Suite 2W1 000 

Date: June 2, 2012 

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