+ 

f:) 

U.S. Department 

of Transportation 

Federal Aviation 

Ad~~~i~~v 

Eastern Region 

Regional Counsel 

Telephone: 718 553-3258 

Facsimile: 718 995-5699 

FIRST CLASS MAil AND FACSIMILE 202-366-7536 

Judge J.E. Sullivan. 

U.S. Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. (EE11-310) 

Washington, DC 20590 

FAX: 202-366-7536 

1 Aviation Plaza 

Jamaica, NY 11434 

RECE\VED 

SEP 2 9 2014 

HEARING DOCKET 

RE: In the matter of Global Aircraft Interiors, Inc., Docket No. 

FAA-2014-0324, Case No. 2011EA110043 

Dear Judge Sullivan: 

Enclosed herein is the Agency's proposed Scheduling Discovery Plan. Agency 

counsel earlier contacted Respondent's counsel to see if the latter would concur, but 

Respondent's counsel has not responded. 

Sincerely, ·· 

Alfred R. Johnson, Jr. 

Regional Counsel 

By: Zachary:nerm:an ~ 

Attorney 

Sande E. Lichtenstein, Esq. 

Lichtenstein & Schindel 

158 West Boston Post Road 

P.O. Box 787 

Mamaroneck, NY 10543 

FAX: 914-698-3478 

Enclosure 
U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

Ht:CEIVED 

SEP 2 9 20!4 -------------------------------------------------

In the Matter of Global Aircraft Interiors, Inc. 

Docket No. FAA-2014-0324 

Case No. 2011EA110043 

Administrative Law Judge J.E. Sullivan 

HEARING DOCKET 

AGENCY'S PROPOSED SCHEDULING/DISCOVERY PLAN 

The Agency hereby proposes the following schedule/discovery plan: 

l. November 3, 2014- deadline for filing general discovery requests, including but not 

limited to : taking depositions; serving and answering requests for production of 

documents; interrogatories; requests for admissions; etc. 

2. Motion to Limit Discovery upon Receipt of Discovery Request: A party served with 

a discovery request who seeks to limit discovery pursuant to 14 CFR Section 

l3.220(f)(g), and (h), shall file a Motion for relief within 10 days of service of the 

disputed discovery request. 

3. Motion to Compel Discovery: A party seeking to compel discovery must file a 

Motion to Compel within 10 days of receipt of service of a deficient response or after 

the response to the discovery is due, whichever occurs first. 

4. December 21, 2014- Expert witness disclosures (for any expert witness to be called 

at hearing), including the witness's resume or qualifications, and the witness's 

written report or statement of opinion (including disclosure of the basis of the 

opinion). 
5. January 15, 2015- Deadline for Completing General Discovery - On or before 

January 15, 2015, the parties shall finish responding and serving answers to all 

general discovery requests pursuant to 14 CFR section 13.220. This includes the 

taking of depositions, pursuant to 14 CFR Section 13 .2200). 

6. February 5, 2015 -Deadlines for Filing Dispositive Motion9s). The last date for 

both parties to file any/all pre-hearing dispositive motions, including Default 

Motions and/or Summary Judgment Motions. 

a. February 25, 2015: Deadline for filing answers to dispositive motions. 

b. March 11, 2015 -Deadline for filing Reply. 

7. March 25, 20 15 - Exchange of list of witnesses and exhibits. 

K March 25, 2015 -Written Stipulations and/or agreed motions in Limine. On or 

before February 11, 2015, the parties shall file any written stipulations that narrow 

the factual or legal issue, and that are agreed Motions in Limine. 

2 
9. April28-29, 2015 ~Hearing in New York, NY 

Respectfully submitted, 

Alfred R. Johnson, Jr. 

Regional Counsel 

Ry Zachary~ 

Attorney 

~ 

Federal Aviation Administration 

1 Aviation Plaza 

Jamaica, NY 11434 

TEL:718 553-3258 

FAX: 718 995-5699 

Date: September 23, 2014 

3 
CERTIFICATE OF SERVICE 

I hereby certifY that the foregoing Agency's Proposed Scheduling/Discovery Plan has been 

sent via facsimile and first class mail to: 

Sande E. Lichtenstein, Esq. 

Lichtenstein & Schindel 

158 West Boston Post Road 

P.O. Box 787 

Mamaroneck, NY 10543 

FAX: 914-698-3478 

Judge J.E. Sullivan. 

U.S. Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. (EEll-310) 

Washington, DC 20590 

FAX: 202-366-7536 

I hereby certifY that the foregoing Agency's Proposed Scheduling/Discovery Plan has been 

sent via first class mail to: 

Federal Aviation Administration (Original and one copy) 

800 Independence Avenue, S.W. 

Washington, D.C. 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Room 2014 

SEP 2 3 1014 

Date: ______ _ 

Paralegal Specialist 

Federal Aviation Administration 

Office of Regional Counsel 

l Aviation Plaza 

Jamaica, NY 11434 

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