U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

IN THE MA TIER OF: 

ROMNEY CYCLE CENTER 

Respondent. 

Docket No. FAA-20 15-0203 

Judge J.E. Sullivan 

FAA Case No. 2013S0700320 

JOINT PROPOSED RULE 26(0 SCHEDULING AND DISCOVERY PLAN 

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. At the teleconference, the parties discussed the nature and basis of 

each party's claims, the possibility of resolving all or part of the case, the scope and type of 

discovery and the place of the venue 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) by July 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 will 
be conducted in accordance with the Rules of Practice 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 party within two weeks of the discovery request. 

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 approximately two days. 

Respectfully submitted this ~ day of June 2015. 

Senior Attorney 

Office of the Regional Counsel 

BRIAN W. STOLARZ, Esq. 

Leclair Ryan 

Attorney for Respondent 

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CERTIFICATE OF SERVICE 

I hereby certify that a copy of the foregoing Rule 26(f) Report Submitted by Complainant FAA 

was mailed by facsimile and Federal Express to: 

The Honorable J .E. Sullivan 

DOT, Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor 

Room E12-320 

Washington, D.C. 20590 

(FAX) (202) 366-7536 

and via Federal Express to: 

Brian W. 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 copy via Federal Express to: 

Hearing Docket 

U.S. Department of Transportation 

Docket Operations, M-30 

West Building Ground Floor 

Room W12-140 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

~~fflT~~E~!~ Legal Assistant 

Of~}~ of t§e 2Qftfional Counsel 

Dated 

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