U.S. DEPARTMENT OFTRANSPORTATION OFFICE OFHEARINGS

WASHINGTON, D.C.

IN THE MATIEROF: ROMNEY CYCLE CENTER Respondent. DocketNo. FAA-2015-0203 Judge J.E. Sullivan
FAA Case No. 2013S0700320

JOINTPROPOSED RULE 26(0 SCHEDULING AND DISCOVERYPLAN The parties, pursuant to §13.217 ofthe Rules of Practice (14 C.P.R. 13.217), Federal Rules of Civil Procedure Rule 26(t) and the Order Setting Rule 16 Litigation Scheduling Conference and Directing Rule 26(t) Planning and Submission, hereby files its Rule 26(t) Report, Complainant states the following: I. Pursuant to 14 C.P.R. § 13.217 and Fed.R.Civ.P. 26(t), a teleconference was held with Respondent on June 4, 2015. Atthe teleconference, the parties discussed the nature and basis of each party's claims, the possibility of resolving all or part ofthe case, the scope and type of discovery and the place ofthevenue for the hearing in this matter. 2. The Complainant initiated settlement discussions on August 6, 2014. 3. The parties propose that the parties will exchange the discovery disclosures required by Rule 26(a)(1) byJuly 16, 2015. 4. The parties propose that initial discovery requests will be made by July 31,2015. The parties will have until August 31, 2015, to respond to initial discovery requests. Discovery willbe conducted in accordance with the Rules ofPractice in FAA Civil Penalty Actions, 14 C.F.R. §13.220. 5. The parties propose that the deadline to disclose experts will be August 7, 2015 and the deadline to submit expert rebuttal reports will be August 14, 2015. 6. The parties propose that the parties serve any follow-up discovery requests by August 10, 2015. The parties will have until September 10, 2015, to respond to follow-up discovery requests. 7. The parties propose that any objections to discovery requests must be made to the requesting partywithin two weeks ofthe discoveryrequest. 8. The parties propose that all dispositive motions must be filed by September 30, 2015. 9. The parties propose that a trial the week ofNovember 16, 2015, in the Washington, D.C.
area would be best. The parties expect the hearing to take approximatelytwo days. Respectfully submitted this



# ~ day ofJune 2015.

SeniorAttorney Office ofthe Regional Counsel BRIAN W. STOLARZ, Esq. Leclair Ryan Attorney for Respondent

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### CERTIFICATE OF SERVICE I hereby certify that a copy ofthe foregoing Rule 26(f) Report Submitted by Complainant FAA was mailedbyfacsimile and Federal Express to: The Honorable J.E. Sullivan DOT, Administrative Law Judge Office ofHearings, M-20 U.S. Department ofTransportation 1200NewJerseyAvenue, S.E. EastBuilding GroundFloor Room E12-320 Washington, D.C. 20590 (FAX) (202) 366-7536 and viaFederal Express to: BrianW. Stolarz, Esq. Respondent's Counsel Leclair Ryan 2318 Mill Road, Suite 1100 Alexandria, VA 22314 (FAX) (703) 684-8075 and Romney Cycle Center Attn: President 51 Industrial Park Romney, WV 26757 and the original and one copyviaFederal Express to: Hearing Docket U.S. Department ofTransportation Docket Operations, M-30 WestBuilding Ground Floor Room W12-140 1200 NewJerseyAvenue, S.E. Washington, D.C. 20590

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### oft§e2Qftfional Counsel Dated
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