mmi 

Michael Selig, MD, FACC, CFI-H 

2816 0refieldRoad 

Allentown, PA. 18104 ;D lOb 

RECEIVED 

MAR 1 5 20tl 

HEARING DOCKET 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON. D.C. 

Federal Aviation Administration 

Laura Ponto, Latonya Williams 

Complainants 

M & R Helicopters, LLC. 

Respondent 

Honorable Judge Ronnie Yoder 

Docket: 2010-1211 

PETITION FOR SPECIAL RELIEF 

JURISDICTION AND VENUE 

AND NOW, comes respondent, MICHAEL B. SELIG, MD, FACC, principle 

tor MR Helicopters, LLC, (MRH) (non-operational since 2007) whom avers and 

files the following Petition to establish all depositions, all pretrial conferences to 

be held in the Lehigh County and Hearings in the above cose, to be held at the 

US District Court located at 504 W. Hamilton Blvd. Allentown, PA, the place of 

origination and original Jurisdiction. 

1. Complainant's continual and ongoing quest is to unreasonably divert 

the location of depositions, pretrial hearings and hearing location to a remote 

-1 -
site for respondent who is a private practice cardiologist in the Lehigh County. 

Pa. 

2. Complainants continual and ongoing intent, at the taxpayers' 

expense, is to inconvenience the respondent, his schedule, the scheduling of his 

patients and to possibly effect this neutral party adversely, by interrupting 

continuity of care, and cardiology services he so renders and imposing risks. 

3. It is respondent's position that the most appropriate and reasonable 

hearing location is site where the violation was investigated, initiated and 

generated by Ms Williams coming to the Allentown location, requiring 2 visits 

(specifically to the joint cardiology/air charter office), the site of the alleged 

violation occurred in Allentown, would only follow suit that the hearing location 

should thereby also be held in the Allentown location, being the place of origin 

and original jurisdiction. 

4. The complainants ignored, evaded and circumvented in a 

malfeasant manner, in the past the main reason for requesting the Allentown 

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

respondents primary role in the Lehigh community as a solo, private practice 

cardiologist (for the last 23 years) with hospital and outpatient responsibilities. To 

leave the area would pose undue hardship to his patients. It is not reasonable 

or proper to burdened or inconvenience neutral party patients or a physician for 

a violation that he did not initiate, was an innocent bystander to and that 

appears to lack legal merit and stands at best on questionable grounds. 
as previously requested at the Gallagher Reporting site. 

2. That all Hearings be at the US District Court located at 504 W. Hamilton Blvd. 

Allentown, PA. 18103. 

Respectfully Submitted. 

Michael B. Selig, MD, FACC. 

Date 

4-
U.S. DEPARTMENT OF TRANSPORTATION 

Federal Aviation Administration 

Cynthia Dominik, Laura Ponto, 

Latonya Williams, Peter Lynch 

Complainants 

M & R Helicopters, LLC. 

Respondent 

IHonorable Judge Ronnie Yoder 

Doclcet: 2010-1211 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that I have this day served the foregoing entrie(s): 

PETITION FOR SPECIAL RELIEF 

JURISDICTION AND VENUE 

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

pursuant to 28 U. S. C. § 1746 . 

Service by first-class mail postage prepaid, addressed as follows: 

Federal Aviation Administration 

800 Independence Avenue, SW 

Wilbur Wright Avenue-Suite 2W1000 

Washington, D.C. 20591 

Att: Hearing Docket Clerk, AGC-430 

W A X 202 493 5142 

The Honorable Ronnie A. Yoder 

US Department of Transportation 

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

1200 New Jersey Avenue. S.E. 

Wpshington, DC 20590 

XX 202 366 7536 

Wp: 

OfXx 

Laura Ponto, Esq. 

Enforcement Division/AGC-300 

Office of the Chief Counsel 

FAA 

800 Independence Avenue, SW 

Washington, DC 20591 

•^A X 202 267 5106 

By: 

Michael B. Selig, MD, FACC. 

2816 Orefield Road 

Allentown, Pa. 18104 i \ 

610 360 3953 t^-Ao ^ 

Date: ^