### FILED

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA

FLIGHT TEST AVIATION, INC., 5175 Parkstone Drive, Suite 150 Chantilly, Virginia 20151 Plaintiff,

v. SCOTT A. BEALE, 

### c/o ADI Shuttle Group, LLC 6544 Highland Drive Waterford, Michigan 48327

Defendant. Alexandria Division

C.A.No.: 2013 FEB-I A <* 05
CLERK US DISTRICT COURT

ALEXANDRIA. VIRGINIA


# l:m\/H^Mmf^

JURY DEMAND

COMPLAINT 

### Flight Test Aviation, Inc. ("FTA") hereby files its Complaint against Scott A. Beale and alleges as follows.

PARTIES 

### 1. Plaintiff, FlightTest Aviation, Inc. ("FTA") is a Delaware corporation whose 

### principal place of business is at 5175 Parkstone Drive, Suite 150, Chantilly, Virginia 20151. 2. Aerodynamics, Inc. ("ADI") is a Michigan corporation whose principle place of business is at 6544 Highland Road, Waterford, Michigan. 3. Defendant, Scott A. Beale ("Beale"), is an individual whose is a citizen of the 

### stateof Georgia, and whose last known address was c/o ADI Shuttle Group, LLC, 6544 Highland Road, Waterford, Michigan 48327. Beale was at all times relevant thereto was the

Chief Executive Officer of ADI. 

### Case 1:13-cv-00145-AJT-JFA Document 1 Filed 02/01/13 Page 1 of 8 PageID# 1

### Case 1:13-cv-00145-AJT-JFA Document 1 Filed 02/01/13 Page 2 of 8 PageID# 2

### Case 1:13-cv-00145-AJT-JFA Document 1 Filed 02/01/13 Page 3 of 8 PageID# 3

### Case 1:13-cv-00145-AJT-JFA Document 1 Filed 02/01/13 Page 4 of 8 PageID# 4

### Case 1:13-cv-00145-AJT-JFA Document 1 Filed 02/01/13 Page 5 of 8 PageID# 5

### Case 1:13-cv-00145-AJT-JFA Document 1 Filed 02/01/13 Page 6 of 8 PageID# 6

### Case 1:13-cv-00145-AJT-JFA Document 1 Filed 02/01/13 Page 7 of 8 PageID# 7

### Case 1:13-cv-00145-AJT-JFA Document 1 Filed 02/01/13 Page 8 of 8 PageID# 8Bankof America Section l:-Req"uistor/6rlElnato'r-fnforniation" Requestor Name JAMES WILLIAM PAQUETTE Business Name (if applicable) FLIGHT TEST AVIATION, INC Address 5175 PARKSTONE DR STE 170 Customer ID T>pc I VADL ID# T63858365 ID# Funds Transfer Request and Authorization (FTRA)

• •.- k- *;-:.x ' • ."..X^'a. " '••',*:•>

City CHANTILLY .,•',' • Dale Wire lo be Sent 4/25/2012 Telephone #

Slate VA Zip 20151 Issue State/Country VA/USA Issue Dale 03/23/2010 Expiration Date 01/14/2013 Issue State/Counlry Issue Date Expiration Date 09/2015 Customer ID Type 2 BOA BUSI DEBIT CK CARD Section It: Assuctate Accenting AVI f

- •>: ,v- "' ,-.'- •,•;••>;';••

. #L

- - J>"&J&.;'' ,•'>.••••' •-•... Time 111:33 AM Associate Name MARIA ANDRADE Phone and Fax U 703-331-3050 Callback Required if Phone. Fax or Letter • Yes BIN/A Call Back Completed by: / 571-292-8037 UnitCo((/CC# 295 /1011571 Name/Number of Person Contacted Date 4/25/2012 Date/Time

Section III: Domestic Payment Instructions

• • ' - .'-./'.. Source 0OTC D Fax D Phone • Letter Amount of Wire 100,000.00 Account Debit 435026703493 Account Title FLIGHT TEST AVIATFQN, INC, Overdraft Amount Debit Account Type (check one) gJcHKG DSAV DlCA D GL
Stile VA Serial B (For ICA'GL) or Repetitive IDS

Available Balance s 5321,327.93

Overdraft Approved by (Name & Signature) Date Wire Fee S 25.00 -S- ,';SectjonIV:' International Payincnl^iStfuctlons •,ej|gc^licrejf funUifiuu'st be.sen.fln'tIS dollars." r."., : .• : - B£»-4V USD Amount of Wire
s Country Role Foreign Currency Code Foreign Currency Amount

Debit Account Type (check one) D CIIKG D SAV D 1CA D GL Account Debit Serial # (For 1CA/GL) or Repetitive ID#

Stale FX Reference ID (If applicable)

Available Balance S Source D OTC D Fax D Phone Q Letter

Account Title

Overdraft Amount Overdraft Approved by (Name & Signature) Date Wire Fee s_ •££

Section V: WfoTnfnrmatioii/V'frff* • Beneficiarv Name AERODYNAMICS, INC W--' rmmje^t'^-M ,-•-.:• - *••< .«•••• v.' ;<fc.V -'.WyiC Beneficiarv Account fl or IBAN (if BAN. no further BeneficiaryBank information is requited) 3852546525 Beneficiary Address: Street 

### Mtt&lffllftlNUL BANK Bcxft^ir; Bi-i Mirat Street City NEW YORK

Citv NEW YORK Additional Instructions (Attention To. Phone Advise. Customer Reference. Contact Upon Arrival)
Send Thru Bank/IBK(if available) State NY Country

ABA it or Swift or National ID 026007773 Slate NY Country

ABA H or Swift or National ID Zip

Zip

bena I hrubanx Address htrcet City Slate Country Zip jifpHrm VI; f^istoMicrAnproVnl'fPrintfofmtn'obtaincusionW^sighiiittrflV'•' •v-j..- ::v/-:-Vtraiafo.l"--#3lty^>'- • ^'WMI authorize Bank of America to transfer my funds as set forth in the instructions noted herein (including dchitinp mv account ifennlirahWt nnrl utri- ih»t aguan »lt v.»>H)mcrrtnnrovaHrnmiormtOQi>tamcuslolncr^sii^mrey<' "•• i •-•• uriiara'--- •*.m V **••- -•• •• ~."'.>K[&£ • • •» I authorize Bank of America to transfer my funds as set forth in the inslructions noted herein (including debiting my account if applicable), and agree lhat such transfer of

funds is subject to the Bank of America standard transfer agreement (see page 2of this form) and applicable fees. If this isa foreign currency wire transfer, I accept the conversion rate provided in Section IV. or,if norateis entered, the rate provided by Bank of America at the time the wire transfer is sent. Cuslome* SiTMal..r«- Dale of Request: / / \,

'Section vn;"Approval andWlre-S\itcfo^ • M.*'., '• ~ v,-y;,'

•••• ••, •••-.....,, I-,., • nM.Mr.nmaiiTiii i miiwiiwii iwynwrntv mmiyaim ~ — • - -",.»,» .-. . • -...—_-- Signature Verification: Type oraccount: 0T3usiness (Required for all) Q Personal (Required ifSlO.OOO or more unless customer is well-known) Indicate Method of Signature Verification: Q-Signalure Card D Business Resolution • Posted Check U •m,

Approval (required field) BAT Approval Authorization It (if applicable/attach approval) Wire Entered by. Name/Signature (aliach BFTscreen prints) Print: VlG^, ^^A^A. Signature: BFT System Time BFT Scoucncc B
Date of Entry and Verification / / •A. VerifiedBy (Namc/SignatureT(Atiach Verification ScreenPrint) Pnnl Signature: Note: Purpose of Wire must be disclosedif sent to an OFAC blockedcountry - SecOFAC In PRO 95-14-0237NSBW CM-20II BFT System Time 

### Case 1:13-cv-00145-AJT-JFA Document 1-4 Filed 02/01/13 Page 1 of 1 PageID# 12•UfiOOYXAMICS l»C


### April 30th, 2012

Mr. Jim Paquette President Flight Test Partners, LLC 5175 Parkstone Drive Suite 150 Chantilly,VA 20151

Joint Venture Agreement between Aerodynamics Inc. and Flight Test Partners. LLC on N359AD Embraer 145 Regional Jet

Dear Jim: As a follow up to our recent communication and review of ADI's proposal for the Embraer 145 

### Regional Jet Joint Venture Project dated April 18th, 2012, please accept the enclosed agreement terms outlining the key points of our mutual agreement.

Background on Aerodynamics and the Regional Jet J45 Aerodynamics Inc. and its subsidiary Air Shuttle Group, LLC is a leading charter management Company headquartered in Waterford, MI with multiple operating basis throughout the United States. ADI is a 53 year old Company proud of its heritage and its flawless safety record since inception. It's the only certified FAA Air Carrier (Parts 135, 125, 121 and 145) in existence that has an incident and accident free record meeting the highest industry standards and the recipient of various third party best practice audits and certifications. These include the following: Aviation Research Group (ARG/US) Platinum operator for which there are only 93 in the world out of 2,200 plus certified Air Carriers; Department of Defense (DoD) certification - pending final review; ISBAO Stage 1 certificated; and a Netjets, a Berkshire Hathaway Company, approved and preferred vendor. ADI is a qualified operator in this Joint Venture for the following reasons:

• Impeccable reputation in the industry with a perfect track record in all areas. Flight Test JV Partner can be confident that their clients will be in good hands with a top tier Company. • As a Part 121/135/125 Air Carrier, ADI has a robust infrastructure and management team required by the FAR's. As such ADI currently has over twenty dedicated professionals in the management of our operations department, not including our Technical Services 

### Case 1:13-cv-00145-AJT-JFA Document 1-5 Filed 02/01/13 Page 1 of 4 PageID# 13

### Case 1:13-cv-00145-AJT-JFA Document 1-5 Filed 02/01/13 Page 2 of 4 PageID# 14

### Case 1:13-cv-00145-AJT-JFA Document 1-5 Filed 02/01/13 Page 3 of 4 PageID# 15

### Case 1:13-cv-00145-AJT-JFA Document 1-5 Filed 02/01/13 Page 4 of 4 PageID# 16

### The Fauquier Bank Page 1of2

Wire Transfer | International Services | Security Admin | Help | Logoff | WlreXchange® Tammy Lo«Bwi« ' 5 SL-SLlfe 11*3/12 0*54 AM 

# = IT s^ The Fauquier Bank Banking and Wealth Management Services 

### Outgoing Wire Detail

General Information Wire Sequence Number 7366 Type of Wire: New Wire

Wire Status: Complete OFAC Status: OF AC Passed

Audit Trail Information Entered: 05/29/12 10:11 AM by ASHLEY STANTON NO CALLBACK NECESSARY. WIRE AGREEMENT ON FILE AS 5005 EXT 10279 Verified: 05/29/12 01:40 PM by Linda Sullivan Posted: 05/29/12 01:46 PM by Linda Sullivan Posted: 05/29/12 01:46 PM by System Forwarded to Fed: 05/29/12 01:46 PM by System Completed: 05/29/12 01:47 PM by System Basic Settlement Information Effective Date: 05/29/12 IMAD: 20120529GMQFMP01006977 OMAD:20120529B6B7IM1C00022705291447FT03 Amount S400.000.00 Wire Fee: $20.00

- DDA-wire transfer fee Fee Account: Checking 108326701 Sending Financial Institution: 051402259 The Fauquier Bank Receiving Financial Institution: 026007773 STERLING NYC Business Function Code: CTR-Customer Transfer Type Code: 1000-Basic Funds Transfer Originator Information Originating Fl Name: Originator: FLIGHT TEST AVIATION INC Originator Account 0108326701 Originator Address: 5175 PARKSTONE DRIVE ST 170 CHANTILLYVA 20151 Originator Country: United States Beneficiary Information Beneficiary Fl Name: Beneficiary Fl Account

https://wirexchange.goxroads.contfwx/wreAvp^^ 1402259&wire_... 11 /5/2012

EXHIBIT 

### Case 1:13-cv-00145-AJT-JFA Document 1-6 Filed 02/01/13 Page 1 of 1 PageID# 17

### Case 1:13-cv-00145-AJT-JFA Document 44 Filed 05/28/13 Page 1 of 10 PageID# 404

### Case 1:13-cv-00145-AJT-JFA Document 44 Filed 05/28/13 Page 2 of 10 PageID# 405

### Case 1:13-cv-00145-AJT-JFA Document 44 Filed 05/28/13 Page 3 of 10 PageID# 406

### Case 1:13-cv-00145-AJT-JFA Document 44 Filed 05/28/13 Page 4 of 10 PageID# 407

### Case 1:13-cv-00145-AJT-JFA Document 44 Filed 05/28/13 Page 5 of 10 PageID# 408

### Case 1:13-cv-00145-AJT-JFA Document 44 Filed 05/28/13 Page 6 of 10 PageID# 409

### Case 1:13-cv-00145-AJT-JFA Document 44 Filed 05/28/13 Page 7 of 10 PageID# 410

### Case 1:13-cv-00145-AJT-JFA Document 44 Filed 05/28/13 Page 8 of 10 PageID# 411

### Case 1:13-cv-00145-AJT-JFA Document 44 Filed 05/28/13 Page 9 of 10 PageID# 412

### Case 1:13-cv-00145-AJT-JFA Document 44 Filed 05/28/13 Page 10 of 10 PageID# 413

### Case 1:13-cv-00145-AJT-JFA Document 44-1 Filed 05/28/13 Page 1 of 1 PageID# 414

### Case 1:13-cv-00145-AJT-JFA Document 44-2 Filed 05/28/13 Page 1 of 4 PageID# 415

### Case 1:13-cv-00145-AJT-JFA Document 44-2 Filed 05/28/13 Page 2 of 4 PageID# 416

### Case 1:13-cv-00145-AJT-JFA Document 44-2 Filed 05/28/13 Page 3 of 4 PageID# 417

### Case 1:13-cv-00145-AJT-JFA Document 44-2 Filed 05/28/13 Page 4 of 4 PageID# 418

### Case 1:13-cv-00145-AJT-JFA Document 44-3 Filed 05/28/13 Page 1 of 1 PageID# 419

### IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA

ALEXANDRIA DIVISION
Flight Test Aviation, Inc. , ) ) Plaintiff, ) ) v. ) Case No.: 1:13

- cv - 145

- AJT/FJA ) Scott A. Beale. ) ) Defendant

. )

ANSWER TO AMENDED COMPLAINT COMES NOW Defendant, Scott Beale, by counsel, and for his Answer to the Complaint filed herein states as follows:
1. Defendant is without information as to Paragraph One.
2. Defendant admits that ADI is a Michigan corporation, but denies all other allegations in Paragraph Two that are not expressly admitted.
3. Paragraph Three is denied in part and admitted in part. Defendant is not a citizen of Georgia and the address listed is not his address. Defendant admits that he was the CEO of ADI at all times relevant thereto, but notes that he was asked to step down by the ADI Board in October

– November 2012 , but has since resumed that position

. 4. Defendant denies Paragraph Four.
5. Defendant denies Paragraph Five, as previously reflected in his Motion to Dismiss

. 6. Defendant is without information as to Paragraph Six.
7. Upon information and belief, Paragraph Seven is admitted , but it is denied that
D efendant Beale “acquired” ADI

. Case 1:13-cv-00145-AJT-JFA Document 47 Filed 06/10/13 Page 1 of 8 PageID# 432

### 2

8. Paragraph Eight is denied in part and admitted in part. Defendant admits the approximat e date of the initial conversation with Paquette, but denies the nature of the request. Defendant also denies that he stated that any requested cash would be returned in 60 days. Defendant admits that an investor dropped out of the EMB

- 145 project and that on behalf of ADI he approached Paquette about partnering with ADI i n the prior investor’s place, and further that this discussion included the offer of participation in the EMB

- 145 effort in exchange for $500,000.
9. The first three sentences of Paragraph N ine are denied except that Defendant admits that FTA was told that it would not incur, or need to pay, any additional costs or expenses. Sentence four is denied in that ADI did have a contract that it was negotiating with Rectrix, all of the terms of which were agreed upon, contingent upon the securing of a LaGuardia landing slot. Sentence five is denied, but a similar package was prepared. Finally, sentence six is denied.
10. Defendant admits that wire transfer of $100,000 was made, before Exhibit 2 was produced, but denies the remaining allegations in Para graph Ten.
11. Paragraph Eleven is admitted in part, in that the proposed joint venture agreement was not executed by either party. However, Defendant denies all other allegations in Pa ragraph Eleven that were not expressly admitted.
12. Defendant denies making any oral representations, and denies generally the first sentence of Paragraph Twelve. As to the proposed agreement, the document speaks for itself. Defendant admits that he had conv ersations with Paquette between April 30, 2012 and May 15, 2012, but denies the substance as alleged. Moreover, Defendant asserts that most of these conversations, if not all, dealt with the Embraer certification process. Case 1:13-cv-00145-AJT-JFA Document 47 Filed 06/10/13 Page 2 of 8 PageID# 433

### 3

13. Defendant admits the provision of funds, as alleged in Paragraph Thirteen , but denies all other allegations not expressly admitted.
14. Defendant denies the first sentence of Paragraph Fourteen, as phrased, as Rectrix had indicated that it was prepared to move forward with ADI, and was only a waiting the Embraer certification and resolution of other minor topics, as is commonly done in that industry, but then later reversed its position. Defendant denies sentence two. Sentence three is admitted in part and denied in part in that ADI was promise d the contract by Rich Cawley of Rectrix, but he ultimately reversed his position. 15. Defendant denies Paragraph Fifteen.
16. Paragraph Sixteen is denied , although Plaintiff’s counsel did make one demand for the return of the money.
17. Paragraph Seventeen is denie d.
18. Paragraph Eighteen is admitted. 19. As to Paragraph Nineteen , Defendant restates his responses to Paragraphs 1

- 18.
20. Paragraph Twenty is denied

. 21. Paragraph Twenty

- One is denied; the Code section speaks for itself.
22. Paragraph Twenty

- Two is denied; the Code section s speak for themselves

. 23. Paragraph Twenty

- Three is denied; the Code section s speak for themselves

. 24. Paragraph Twenty

- Four is denied.
25. As to Paragraph Twenty

- Five , Defendant restates his responses to Paragraphs 1

- 18.
26. Paragraph Twenty

- Six is denied.
27. Paragraph Twenty

- Seven is denied; the Code section speaks for itself. Case 1:13-cv-00145-AJT-JFA Document 47 Filed 06/10/13 Page 3 of 8 PageID# 434

### 4

28. Paragraph Twenty

- Eight is denied; the Code section speaks for itself. 29. Paragraph Twenty

- Nine is denied; the Code section speaks for itself.
30. Paragraph Thirty is denied.
31. Paragraph Thirty

- O ne simply realleges Paragraphs 1

- 18.
32. Paragraph Thirty

- Two is denied.
33. Defendant denies Paragraph Thirty

- Three and demands strict proof thereof

. 34. Paragraph Thirty

- Four is denied.
35. Paragraph Thirty

- Five is denied.
36. Def

endant denies Paragraph Thirty

- Six and demands strict proof thereof.
37. Defenda nt denies Paragraph Thirty

- Seven . In fact, when Rectrix began to back away from the ADI deal, Paquette was advised and sought other parties to work with on the
EMB

- 145 project, such as Easy Jet.
38. Paragraph Thirty

- Ei ght is denied. 39. Paragraph Thirty

- Nine is denied and Defendant demands strict proof thereof. Specifically as to sentence two, Defendant notes that industry custom and usage allows for agreements to be made and negotiated and then signed later. Furthermore, Paquette was kept apprised of the status of the Rectrix negotiations and contract at all times. Additionally, as to sentence five, Defendant notes that a copy of the redline contract was, indeed, sent to Paquette.
40. Paragraph Forty introduces this new Count and contains no substantive allegations

. 41. As to Paragraph Forty

- One , Defendant restates his responses to Paragraphs 1

- 18.
42. Defendant denies Paragraph Forty

- Two. 43. Defendant denies Paragraph Forty

- Three. Case 1:13-cv-00145-AJT-JFA Document 47 Filed 06/10/13 Page 4 of 8 PageID# 435

### 5

44. Paragraph Forty

- Four is denied.
45. Paragraph Forty

- Five is denied.
46. Paragraph Forty

- Six is denied.
47. Paragraph Forty

- Seven is denied. In fact, when Rectrix began to back away from the ADI deal, Paquette was advised and sought other parties to work with on the EMB

- 145 project, such as Easy Jet.
48. Paragraph Forty

- Eight is denied. GROUNDS OF DEFENSE 49. Defendant incorporates all of the above denials as recited in the Answer. 50. Defendant asserts as a defense the bankruptcy of Ae r o dynamics, Inc. (hereinafter “ADI”).
51. Defendant herein asserts as a defense that at all times he was operating as a corporate officer, and Plaintiff seeks to make him responsible, individually, for the acts of a corporation, now bankrupt. As Plaintiff has not sought to pierce the corporate veil, Beale therefore cannot be held liable for his work performe d on behalf of ADI , his principal and employer

. 52. Defendant asserts as a defense that at all times, Plaintiff, and its principal, James Paquette (“Paquette”) was aware and knew of the allegations that he now asserts constitute the actions complained of in th e Complaint, to the extent that Paquette was aware of the nature of any relationship and proposed contract with Retrix, and participated in seeking alternative uses for the aircraft, subject to the instant Complaint. 53. Paquette and FTA, as participants in t he aviation industry, were well aware of the fact that it is industry custom to discuss and negotiate all of the clauses of a contract, but then Case 1:13-cv-00145-AJT-JFA Document 47 Filed 06/10/13 Page 5 of 8 PageID# 436

### 6

have the same signed later, when the aircraft in question is certified and prepared for use. This is exactly wh at happened in the present situation. 54. Defendant further asserts that as to the allegations made under the Virginia Securities Act, that the document advanced as a security by the Plaintiff is not a security under Virginia Code § 13.1

- 501, that the acts complained of do not constitute any viol ation of the referenced A ct, and that the losses sustained were not a result of any alleged violation of the A ct as well as that the statements made were not statements of material fact, and the actual facts in this case were well known to the Plai ntiff, a nd its principal, Paquette. 55. Defendant further asserts as defenses under the Michigan Uniform Securities Act that the document advanced as a security by the Plaintiff is not a security und er MCLA § 440.8102, that the acts complained of do not constitute an y violation of the instant A ct, and that the losses sustained were not a result of any violation of the A ct as well as that the statements made were not statements of material fact, and the actual facts in this case were well known to the Plai ntiff, and it s principal, Paquette

. 56. Defendant further asserts as a defense herein that no fraud was perpetrated upon the Plaintiff herein, and, in fact, the principal of Plaintiff, Paquette, was aware at all times of the facts of which he now complains

. 57. Defendant furth er asserts that the damages herein are not the result of those acts recited in the Complaint.
58. Defendant further asserts that an indispensible party, the bankrupt corporation, ADI, is a necessary party to this action, in that Plaintiff seeks discovery again st ADI, and seeks to substitute Defendant Beale for the liability of that properly incorporated entity. 59. Defendant asserts as a defense unclean hands. Case 1:13-cv-00145-AJT-JFA Document 47 Filed 06/10/13 Page 6 of 8 PageID# 437

### 7

60. Defendant further alleges defenses of waiver, estoppel , latches, and the active participation of the Plaintiff, and its principal, in the acts recited within the Complaint. WHEREFORE Defendant , by Counsel, prays that the Plaintiff be denied the relief prayed for in its Complaint, that said Complaint be dismissed with prejudice, that Defendant be award his attorney’s fees and costs herein, and that he be awarded such further relief as this Court deems proper and just

. Respectfully submitted, Scott A. Beale, by Counsel

______________

_/s/__________________ Jonathan S. Gelber, Esq. Virginia Bar Number #23992 Attorney for Scott A. Beale Law Offices of Jonathan Gelber, PLLC 100 North Washington Street, Suite 402 Falls Church, Virginia 22046 Phone: 703.237.1200 Fax: 703.237.2775 Case 1:13-cv-00145-AJT-JFA Document 47 Filed 06/10/13 Page 7 of 8 PageID# 438

### 8 CERTIFICATE OF SERVICE I hereby certify that on this 10 th 

### day of June , 2013, I will electronically file the foregoing with the Clerk of Court using the CM/ECF system, which will then send a notification of such filing (NEF) to the following: Joseph S. Luchini , Esq. Virginia Bar No. 13566 Counsel for Flight Test Aviation, Inc. Reed Smith LLP 3110 Fairview Park Drive, Suite 1400 Falls Church, Virginia 22042 Gregory J. Sagstetter , Esq. Virginia Bar No. 82598 Counsel for Flight Test Aviation, Inc. Reed Smith LLP 3110 Fairfview Park Drive, Suite 1400 Falls Church, Virginia 22042

___________/s/____________________ Jonathan S. Gelber, Esq. Virginia Bar Number #23922 Attorney for Scott A. Beale Law Offices of Jonathan Gelber, PLLC 100 North Washington Street, Suite 402 Falls Church, Virginia 22046 Phone: 703.237.1200 Fax: 703.237.2775 Case 1:13-cv-00145-AJT-JFA Document 47 Filed 06/10/13 Page 8 of 8 PageID# 439