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# CapitalReportingCompany InRe: WorldwideAircraftServices, Inc. 06-06-2013 

# RECEl\'EC

DEPARTMENT OF TRANSPORTATION, OFFICE OF HEARINGS 

# JUN 2 120 3 

# HEARING DC 

# CKET

IN RE:
WORLDWIDE AIRCRAFT SERVICES, INC. FDMS NO. FAA-2013-0045

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## . . co Thursday, June 6, 2013

The following pages constitute the proceedings
held in the above-captioned matter before the
HONORABLE J.E. SULLIVAN, held at the Department of Transportation, Office of Hearings, 1200 New Jersey
Ave SE, Washington, D.C. before Roger Meyers of Capital Reporting Company, beginning at approximately
11:00 a.m
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# • InRe: WorldwideAircraftServices, Inc. 06-06-2013

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I APPEARANCES I Good morning to you alL Let's chatjust 2 2 very briefly about where we are in these proceedings. 3 On behalfofthe Complainant: 3 Essentially, as you both know, on March 28, 2013, an 4 MR. WILLIAM P. VINES, ESQUIRE 4 Order setting aRule 16 Litigation Scheduling 

### 5 Office ofthe Regional Counsel 5 Conference and Directing Rule 26(t) Planning and 6 Southern Region 6 Submission was filed. Andthen subsequently, the 7 Federal Aviation Administration 7 parties filed on May 30, 2013, a Joint Section 8 P.O. Box 20636 8 13.217/Rule 26(t)Report submitted by Complainant, 9 Atlanta, GA 30320 9 FAA. I have reviewed the material and I have only a 10 Tel: 404-305-5200 10 few questions to askboth ofyou as we formalize the 11 Fax: 404-305-5223 11 discovery and litigation schedule. I 12 12 And I am going to direct my questions first 13 On behalfofthe Respondent: 13 to you Mr. Vines since you are the complainant. In 14 Michael A. Honeycutt, President 14 this Rule 26(t) Report, you indicated that you would 15 Worldwide Aircraft Services, Inc. 15 be exchanging initial disclosures on orbefore June 16 c/o JET I.C.U. 16 28, 2013, and I'm happy to adopt that. 17 2561 Rescue Way 17 What I typically do in addition to setting 18 Brookville, FL 34604 18 some deadlines for completion is I also set some start 19 Tel: 325-796-2540 19 times in part because I have had some concernsby 20 Fax: 325-796-2549 20 litigants in the past about when they actually are 21 21 supposed to start exchanging information. So I don't 22 22 have any particular trouble with the deadline for 

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I PROCEEDINGS 1 finishing your initial discoveryrequest ofJuly 26, 2 THE COURT: We are on the record in the 2 2013. WhatI'm interested in really is setting a 3 matter ofWorldwide Aircraft Services, Inc. This is 3 starttime. Ifthe two ofyou finish exchanging the 4 DocketNumberFAA-2013-0045. Today is Thursday, June 4 initial disclosures on orbefore June 28, 2013, which 5 6, 2013. And the parties have convened for aRule I6 5 is aFriday, itprobably would make sense ifwe start 6 Litigation Scheduling Conference. 6 no laterthan July 12 with exchanging your additional 7 The FAA is represented by its attorney of 7 discovery requests. AndI looked atthe calendar, and 8 record, William P. Vines, who is appearing by 8 the firstFriday afterJune 28 is July 5, but it 9 telephone. 9 immediately follows the July 4th Federal Holiday and 10 The Respondent, Worldwide Aircraft Services, 10 many people like to take that long weekend**of1~** So I 11 Inc., is represented by Michael A. Honeycutt, who is 11 thought perhaps we could have the start date wherethe 12 the President ofthe company. 12 parties are directed to start no laterthan a due date 13 Mr. Honeycutt,just so that I know, are you 13 for discovery requests be on or before July 12, 2013. 14 an attorney as well as the President, or are you 14 Do you have any objection to that? 15 simply here as the President ofthe company? 15 MR. VINES: No, Judge, I do not. 16 MR. HONEYCUTT: I am strictly the President. 16 THE COURT: Okay. 17 I am not a lawyer. 17 Mr. Honeycutt, I am going to turn to you. 18 THE COURT: Okay. Thankyou. 18 Do you have any objection to having a start date of 19 Also present atthe Office ofHearings 19 July 12, 2013, for the additional general discovery 20 appearing as observers only is one ofourlaw student 20 requests? 21 interns, Mr. Andy Orr, as well as a legal assistant, 21 MR. HONEYCUTT: No, ma'am; I have no problem 22 Ms. LisaHarris. 22 with July 12. 

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1 THE COURT: Okay. When I say additional I answer; sending each other a notice ofdeposition 2 general discovery requests, do you know whatI'm 2 where you are going to actually depose awitness under 3 talking about, sir? 3 the rules for discoverypurposes; for requesting 4 MR. HONEYCUTT: I do believe that we 4 additional production ofdocuments; disclosing experts 

### 5 initially request disclosures and then ifwe feel that 

### 5 and expertreports; those kind ofthings that are much 6 we want to expand on it then thatwould be the 6 more specific are part and parcel ofthe general 7 additional request. 7 discovery that follows initial disclosure. 8 THE COURT: Yes. In general; the initial 8 So does that make sense so far to you, Mr. 9 disclosures that have aJune 28, 2013 deadline, those 9 Honeycutt? 10 are the very general disclosures thatyou will see in 10 MR. HONEYCUTT: Yes, ma'am, it does. And so 11 the Federal Rules underRule 26(a)(l)(A). And they 11 that pat1 ofthe request, the interrogatories and 12 basically are for your purposes exchanging the name 12 scheduling or at leastnaming ofpeople wanting to be 13 and ifknown the address and telephone number ofeach 13 deposed that would haveto be all in by the 26th 14 individual likely to have discoverable information 14 starting at least by the 12th ofJuly; is that 15 about the issues in dispute. 15 correct? 16 MR. HONEYCUTT: Okay. 16 THE COURT: Right. We are talking about 17 THE COURT: And essentially, you're going to 17 when you startto exchange. 18 be talking about whatyou may be using to support your 18 MR. HONEYCUTT: Okay. 19 claims or defenses unless the material is subjectto a 19 THE COURT: And according to my reviewof 20 privilege. So it is the beginning body ofinformation 20 yourRule 26(f), you didn't have any pat1icular start. 21 that you are providing to each other about who has 21 Many people don't. AndI have found though that it is 22 information and whattype ofinformation they have and 22 helpful for many ofthe litigants who appear before me 

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### I howthat opposing side can contact that person. 

### I for me to set a deadline to begin the exchange because 2 Then, secondly, under Civil Rule 26(a)(I)(A) 2 oftentimes in the past what I have seen is people wait 3 you also wantto exchange a copy or a description of 3 and then they find out that they don't have enough 4 the documents that you may have or othertangible 4 time afterthey serve the request to getthe answer. 5 items that you may have thatyou are potentially going 5 So I wantto make sure that everybody knows whattheir 6 to be using as evidence, documentary exhibits, 6 timeframe is. You can serve and requestgeneral 7 tangible exhibits thatyou think are helpful to your 7 discovery before July 12, 2013. What I'm doing is I 8 defense. 8 am setting a due date so that you knowthat you have 9 Those are the two primarythings in these 9 to start asking for some things at least by July 12, 10 types ofcases that are exchanged by the parties on or 10 2013, in orderto get done in time ifwe continue with 11 before the first deadline which is June 28, 2013. It 11 the scheduling order that you and Mr. Vines have 12 is the broadbrush overviewofdiscovery. 12 submitted to me; does that make sense? 13 Andthen as ofJuly 12, 2013, that's when 13 MR. HONEYCUTT: Yes, ma'am, it does. 14 you startexchanging more specificrequests for 14 THE COURT: Okay. Good. So is July 12, 15 information. And you don't have to wait until July 15 2013, acceptable to you, Mr. Honeycutt, as a start 16 12, 2013; you can do that ahead of.Tuly 12,2013. 16 time for the general discovery? 17 Iwill structure the Orderthat says on or 17 MR. HONEYCUTT: Yes, ma'am. 18 before July 12, 2013, the parties shall begin 18 THE COURT: Okay. Then I have in the Joint 19 exchanging or serving additional general discovery 19 Rule 26 Report from the parties that you also have 20 requests. And those types ofdiscovery requests would 20 agreed to have August 26, 2013 as the deadline for 21 be more specific. They could include things like 21 completing general discovery, and I'm happy to adopt 22 sending each other a tort and interrogatories to 22 that. 

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You also have indicated a follow-up 1 THE COURT: Okay. AndMr. Honeycutt, how supplemental discovery starttime for the request for 2 aboutyou; what is your vacation schedule orwork follow-up discoveryto be September 6, 2013; and I 3 schedule like around thatperiod oftime? will adopt that. 4 MR. HONEYCUTT: The I8th is mybirthday, so I'll also adoptthe September 30, 2013, 5 I won'tbe in; I will be out. The 19th wouldbe deadline for completing the exchange ofsupplemental 6 possible, butofcourse ifwe could do it, the 23rd discovery. 7 would workfor me. Youhave indicated some dispositive motion 8 THE COURT: Okay. Well, let me turn backto due dates, those being October 15, 2013, for filing 9 Mr. Vines, then. Mr. Vines, would the 23rd work as an dispositive motions, November 1, 2013, for filing 10 alternate date?

answers to the dispositive motions ifany; and then II MR. VINES: I don't have anything scheduled. November 15, 2013, for filing replies ifany. And I 12 My concern is it being that week ofChristmas, so
-- amhappy to adopt all ofthose dates. 13 THE COURT: No, I understand. I'mjustin a I do need to talkto you about scheduling an 14 little bit ofapinch because I am in trial the week oral argument for dispositive motions. And 

### Jwant to 15 immediately following the reply date that is due, and askyoubothto look at your calendars in November if 16 then I am going to be in a fairly lengthy trial you would be so kind. With aNovember 15, 2013, 17 beginning right after Thanksgiving. So letme see if deadline for filing a reply that puts me into the week 18 

### Jcan tweak this a little bit. Wemay end up going ofNovember 18 andNovember 25 for setting oral 19 into January, and ifwe do, I'm going to flush outthe argument potentially. I could go a little beyond that 20 dispositive motion time becausethere is no reason for too. I cannot set it for the week ofNovember 18, 21 you to whereyou have to get it all filed and then 2013, because I am going to be in trial that entire 22 have to wait. So let's take a look at afterthe

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week. I could set it ifyou like right before 1 Christmas holiday. Andjust so you know, I'm already Thanksgiving, ifyou both are available. 

### Jknowthat 2 scheduling trials in January. So I have to navigate many people like to takethat whole weekoffand if 3 between whenI am in trail those weeks. that is true for either oryou,justlet me know. So 4 How aboutthe week ofJanuary 6? Mr. Vines, I will start with you, Mr. Vines? 5 do you have vacation time scheduledthen, orwouldyou MR. VINES: Judge, I do plan to take that 6 be available any time that week? And this would be week off. 7 for one to one and a halfhour oral argumenttime. I THE COURT: Okay. 8 usually am able to hear oral argument fairly easily MR. VINES: Thanksgiving week, the week of 9 within one hour, butevery once in a while it goes November 22. 10 beyond into the nexthalfhour. THE COURT: Okay. Then whatI'm going to do 11 MR. VINES: Judge, to respond to your is I am going to tell you whenI'm available in 12 question, I am available the week ofJanuary 6. And December, and I have a fairly long trial set 13 also wanted to askyou: is it normal that in these immediately afterthe week ofThanksgiving, andI 14 types ofhearings thatyou do have oral arguments? should be backin the office byDecember 18, which is 15 THE COURT: I always schedule oral argument. right before Christmas. So ifyou are amenable to 16 Andthe reason I do is because I find it veryhelpful. oral argumentright before ChristmasI can either set 17 MR. VINES: Okay. And ofcourse thatis this matter for December 19, 2013, December 20, 2013, 18 based on ifanymotions are filed?

orperhaps even December 23, 2013. 19 THE COURT: And ifno motions are filed, I And I am going to turn again to you first, 20 convertit into a pre-hearing status conference. Mr. Vines. Do any ofthose dates workfor you? 21 MR. VINES: Okay. Thankyou. MR. VINES: Judge, December 19, Thursday. 22 THE COURT: You're welcome.


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Mr. Honeycutt, are you available the week of 1 MR. HONEYCUTT: I don't believe morethan a January 6, 2014? 2 day, Your Honor, either; maybe ahalfa day atthe MR. HONEYCUTT: Yes, ma'am. 3 very most on the outside

-- THE COURT: Do you have any blackout dates? 4 THE COURT: Okay. MR. HONEYCUTT: No, ma'am. 5 MR. HONEYCUTT:

-- a day and ahalf. THE COURT: Okay. Then Mr. Vines, turning 6 THE COURT: And I'm going to simply erron to you first, do you have any preferred date during 7 the side ofcaution atthis point and say one day. I the January 6, 2014 week? 8 find that it is very helpful ifwe have a little MR. VINES: The middle ofthe week is always 9 cushion oftime because things do come up that people preferable, so January 8 or 9? 10 don't anticipate, and it can be very uncomfortable if THE COURT: Okay. Mr. Honeycutt, do you 

### 11 you don't have the time to address those things. So have a preference, does January 8 orJanuary 9 work 12 let's say this is atwo-day trial. And according to for you? 13 yourRule 26(f) Report, it sounds like both parties MR. HONEYCUTT: Yes, ma'am; either day would 14 have agreed that Tampa, Florida is the preferred be fine with me. 15 venue; is that correct, Mr. Vines? THE COURT: Staying with you, Mr. Honeycutt, 16 MR. VINES: Yes, Judge. do you have apreference for morning or afternoon? 17 THE COURT: Okay. AndMr. Honeycutt? MR. HONEYCUTT: Eitherwould be fine. 18 MR. HONEYCUTT: Yes, ma'am. THE COURT: Mr. Vines, any preference 19 THE COURT: So let's do this. Let's look regardingtime during the day? 20 for atwo-day time period afterJanuary 8, 2014 and MR. VINES: No preference, Judge. 21 just so you know, I will be in trial the week of THE COURT: Let's do 10:30 a.m. on 22 January 13,2014. I'll be in trial againthe weekof

15 Wednesday, January 8, 2014. And I will schedule this 1 January 27, 2014, but I have the month ofFebruary from 10:30 to 11:30 a.m. Eastern time. I'll simply 2 available. So Mr. Vines, turning to you; do you have ask both ofyou to keep the halfhour immediately past 3 blackouttimes during the month ofFebruary that we that from 11 :30 to noon openjustin case we run over. 4 should not be looking at? And again, ifyou do not file dispositive motions, I 5 MR. VINES: Yes, Judge; let me confirmthat. will automatically keep this conference on my calendar 6 I believe it is February 12 through February 22, I and I will convert it into apre-hearing status 7 will be outofthe country, but let me confirm those conference so that ifthere are any matters that need 8 dates. to be addressed priorto hearing, we have gotthat 9 THE COURT: Okay. conference scheduled on that date. 10 MR. VINES: AndI don't havethis written in Then let's talk about howmany days if 

### 11 my calendarbecause my calendar stops on February 2. needed the hearing will be and Iwill stmiwith you 12 THE COURT: Okay. Are you looking, Mr. first, Mr. Vines; how long do you think itwould take 13 Vines, or should Ijusttake that as fact? you to put on aprima facie case for your client? 14 MR. VINES: I'm confirming that, Judge. I MR. VINES: Judge, probablyhaifa day to a 15 am having to pull up my itinerary here on myphone. full day. 16 THE COURT: Okay. THE COURT: Okay. I am going to err on the 17 MR. VINES: Yes, Judge, that's correct; side ofcaution sirjustfor now andjustnote that it 18 February 12 through 22. will be one day. 19 THE COURT: Mr. Honeycutt, let me turn to Mr. Honeycutt, turning to you how much time 20 you. Do you have blackout dates during the month of do you think it would take for you to put on a 21 February as well? responsive case ifthis case goes to hearing? 22 MR. HONEYCUTT: No, ma'am. I am free.


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THE COURT: Well, I'm going to suggestone 1 MR. VINES: It doesn't matter, Judge.
or two possibilities. Ifwe have a summaryjudgment 2 THE COURT: Let's setthis for February 5 motion heard on January 8, 2013, from10:30 to 11:30, 3 which is aWednesday through February 6, which is a I want to be sure that I have time to get out that 4 Thursday. We will have travel on Tuesday, February 4 motion, the ruling on the motion and because I am 5 and Friday, February 7potentially. And typically, I going to be in trial, I'm going tojustnote thatI 6 hold the hearings beginning at 9:00 a.m. running to should have that out on or before January 22, 2014, be 7 5:00 p.m. and those are the times that I will set. If in trial the next week, we could either do a short 8 we get done early, that is great, then we have had trial the first week ofFebruary, which is the week of 9 that cushion and we don't need it. Just so you know, February 3, 2014, or we're going to be looking at 10 I always take a lunch break ofone hour. Ifthere are doing atrial the weekofMarch 3, 2014, or shortly 11 restaurants that need to be walked to from the thereafter. 12 courthouse orwherever we end up holdingthe hearing Mr. Vines, what is your preference? 13 and we need a little extratime, I will add that in. MR. VINES: Judge, I can do either. I don't 14 We will also take a quick morning recess and afternoon have anything scheduled really in January orFebruary 15 recess so thatthe Court Reporters have abreak. But otherthan the trip. So ifwe like say getit set and 16 that's basically whatthe schedule will be. getthattried in February, I'm fine with the February 17 So since we are holding the hearing the 3 week. 18 first week ofFebruary, do you folks want to have a THE COURT: Mr. Honeycutt, do you have a 19 little bit ofmaneuvering room with the dispositive preference'l 20 motions or are you comfortable still with the October MR. HONEYCUTT: No, ma'am; February orMarch 21 15 and subsequent dates, starting with you, Mr. Vines? would either work fine for me. 22 MR. VINES: Judge, since we do have the

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THE COURT: Let's plan on the first week of 1 trial set for February, I would preferto move those February. Andthen I need to check in with both of 2 dates closerto the hearing, ifMr. Honeycutt agrees. you. 3 THE COURT: Mr. Honeycutt, do you want to Mr. Vines, you are located where? 4 expandthose dates a little bitto give yourselfa MR. VINES: Atlanta, Georgia. 5 little bit ofbreathing room? THE COURT: And Mr. Honeycutt, you are in 6 MR. HONEYCUTT: Yes, ma'am; I would. Brooksville, Florida? 7 THE COURT: Then Jet's talk about doing MR. HONEYCUTT: Yes, ma'am. 8 that. And I think what might work is ifwe schedule THE COURT: Howfar or how near is 9 maybe October 25 for the filing ofthe dispositive Brooksville, Florida to Tampa, Florida? 10 motion which is the lastFriday ofOctober. Andthen MR. HONEYCUTT: We are a 35 minute ride down 11 we can have November 8 as the deadline for filing an to Tampa. 12 answerto dispositive motions. Then we need to put THE COURT: Okay. So you have the shortest 13 how about-- I need to check my November calendar-- commute to the trial. 14 actually, we could sayNovember 15, 2013, for filing MR. HONEYCUTT: Yes, ma'am. 15 the answer; and then December 6 for filing the reply. THE COURT: Mr. Vines, I take it you might 16 And then I will have time priorto January 8, 2014, to be flying? 17 read all the material and then be prepared for that MR. VINES: Yes, Your Honor. 18 oral argument. THE COURT: And this Court will also be 19 Does thatwork for you, Mr. Vines? flying for the proceeding as well. 20 MR. VINES: Yes, Judge. Mr. Vines, do you have a preference for 21 THE COURT: And Mr. Honeycutt? flying on Monday orTuesday, do you care? 22 MR. HONEYCUTT: Yes, ma'am. Let me confirm;


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### I itwas file by October 28? I MR. VINES: That's fine, Judge. 2 THE COURT: I have file by October 25, 2013. 2 THE COURT: Mr. Honeycutt, how aboutyou; is 3 We could change that date a little bit ifthe parties 3 that acceptable? Doyou understand whatwe werejust 4 want. We could move that into November I; we can also 4 talking about? 5 switch the answer to a week later as well as the reply 5 MR. HONEYCUTT: Yes, ma'am, I do. Andthat 6 but itjust depends on whatyou wantto do? 6 will be fine with me. 7 MR. HONEYCUTT: I'm fine with the 25th. I 7 THE COURT: So let's do this. Let's switch 8 wasjustwanting to confirm and make sure the dates 8 those trail dates from February 5 and February 6to 9 were right. The 25th and then the response by the 9 March 5which is also aWednesday and March 6 which is 10 15th

-- 10 also a Thursday with travel on March 4 and March 7. 11 THE COURT: Right. 

### 11 And then whatwe can do is go to February 7 for the 12 MR. HONEYCUTT:

-- and reply by December 6. 12 exchange ofwitness lists and exhibits. 13 THE COURT: Correct. 13 And folks,just so that you know, I do ask 14 MR. HONEYCUTT: And I am fine with those 14 the parties to have an index cover sheet ofyour 15 dates. 15 exhibits so thatyou have Exhibit C-1, C-2, C-3, C-4, 16 THE COURT: AndMr. Vines, that is 16 or Exhibit R-1, R-2, R-3, R-4 identified in an index 17 acceptable to you, too? 17 cover sheet on top ofall ofyour exhibits. And I do 18 MR. VINES: Yes, Judge. 18 that in part because whenwe file the exhibits with 19 THE COURT: Then let's talk finally about 19 the hearing docketthey require us to have one. And 20 exchanging a list ofwitnesses and exhibits priorto 20 it is best ifyou identify them yourselfas you see 21 the Februaryhearing. 21 fit as opposed to having one ofmy clerks do it after 22 Mr. Vines, howmuch time prior to the 22 the fact. And I will putthat in the order. 

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1 hearing do you usually like to exchange those? I And then whatI am going to do also is 2 MR. VINES: Judge, in my other proceedings, 2 suggestthatyou have any and all witness stipulations 3 I believe it is usually at leastthree weeks, three 3 and/ormotions in limine filed on orbefore February 4 weeks to a month. 4 21,2014. Thatdoesn'tprecludeyou, ofcourse, from 5 THE COURT: Okay. Well, since I'mnot 5 engaging in further stipulations and presenting them 6 hearingthe summaryjudgment motion until January 8 6 orally to the Courtthe day ofthe hearing but it does 7 and I need time to issue the order, typicallywhatI 7 give you a deadline to look at and consider and try 8 do is I issue the summaryjudgmentorder and then I 8 and address those issues ahead oftime. 9 schedule a time for the parties to exchange the 9 So Mr. Vines, starting with you, are there 10 witness lists and exhibits. And ifthat-- ifyou are 10 any other procedural datesthat you would like to talk II looking for three weeks to a month then the February 3 11 about for your client today? 12 timeperiod doesn'tworkfor us. I don't have the 12 MR. VINES: I don't believe so, Judge. 13 ruling outuntil about January 22 in part because I am 13 THE COURT: Then Mr. Honeycutt, on behalfof 14 in trial the weekpreceding that date. Do you see 14 your client, any procedural matters or dates thatyou 15 whatI'm saying? So itmakes no sense for you to 15 would like to address today? 16 exchange witness lists and exhibits priorto the 16 MR. HONEYCUTT: No, ma'am. 17 ruling on the summaryjudgmentbecause that ruling 17 THE COURT: I'mjustgoing to briefly note 18 potentially can dramatically change orreduce the 18 that I will be sending out an order setting litigation 19 amount oftime the parties spend on trial. 19 dates and procedures that codifies whatwe talked 20 MR. VINES: Right. 20 about and agreedto today. This order will also 21 THE COURT: So do you want to move the trial 21 identify basic information that we have not talked 22 into that first weekofMarch, then? 22 about including howto request modification ofthe 

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1 litigation dates. We do have motions regarding 1 orderthat you get, I will have Mr. Cody L. Smith's 2 discovery, when to file them, howto file them. If 2 name and phone number included in the order. He is an 3 you want to set up additional conferences on my 3 attorney advisor in this office and he is available to 4 calendar between now and the hearing date; how to 4 answer any questions either ofyou might have about 5 contactthe office, who to contact, howto go about 5 what is contained in the order. 6 doing it. 6 So with that it looks like ourbusiness is 7 Mr. Honeycutt, ifyou decide to get counsel, 7 complete. 8 please let us know. The attorney will knowhowto 8 I thankyou very much both ofyou for being 9 file a notice ofrepresentation. Ifyou decide that 9 available today. We can go offthe record. And I 10 you are going to have somebody come in and replace you 10 wish you all a good day. Thank you verymuch. 11 for any reason, a lay person or an attorney, let us 11 MR. VINES: Thankyou. 12 know. 12 MR. HONEYCUTT: Thankyou. 13 And then I also have some information about 13 (Whereupon, at 11:39 a.m., the 14 howto mark exhibits in this order that essentially 14 scheduling conference in the matter ofWORLDWIDE 15 reiteratesthe index cover sheetrequirement and the 15 AIRCRAFT SERVICES, INC. was adjourned.) 16 pre-marking ofexhibits. 16 17 So with that, Mr. Vines, any questions or 17 18 any matters you would like to address before we close 18 19 today? 19 20 MR. VINES: No, Judge. 20 21 THE COURT: Okay. 21 22 Mr. Honeycutt, on your ownbehalf, any 22 

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1 questions thatyou have oranything else thatyou 1 CERTIFICATE OFNOTARYPUBLIC 2 would like to address today. AndI wouldbe happy to 2 I, ROGERMYERS, the officer before whom the foregoing 3 explain anything that we talked about ifforany 3 hearing was taken, do hereby certifY that the testimony 4 reason or any reason thatyou might have oryou are 4 appearing in the foregoing pages was recorded by me and 5 not quite sure whatwetalked about orwould like a 5 thereafterreduced to typewriting under my direction; 6 further explanation? 6 that said transcription is atrue record ofthe 7 testimony given by saidparties; that I am neither 7 MR. HONEYCUTT: No, ma'am, Your Honor; I 8 counsel for, related to, nor employed by any ofthe 8 appreciate it. I understand everything and

-- 9 parties to the action in which this hearing was taken; 9 THE COURT: I would simplynote, I should 10 and, further, thatI am not arelative or employee of 10 have mentioned this before; you folks are welcometo II any counsel or attorney employedby the parties hereto, II engage in settlement discussions as many people do 12 nor financially or otherwise interested in the outcome 12 throughout the litigation. I would simply remind you 13 ofthis action. 13 that ifyou are engaging in settlement negotiations, 14 14 that does not mean thatyoujustdrop all your 15 15 litigation work. You have to do both at the same 16 time. 16 ROGER MYERS 17 Settlementnegotiations are not permissible Digital Court Reporter 17 18 to be used as evidence in a trial so ifyou discuss 18 19 things that are specifically settlement-oriented, 19 20 those should be considered privileged and not subject 20 21 to disclosure during the trail. 21 22 Ifyou have any other questions about the 22 

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I CERTIFICATE OF TRANSCRIPTION 2 3 I, CHERYLLASELLE, hereby certifY thatI am 4 notthe CourtReporter who reported the proceeding 5 andthatI have typedthe transcript ofthe 6 proceedingusing the Court Reporter's notes and 7 recordings. TI1e foregoing/attached transcript 8 is a true, correct and completetranscription ofthe 9 proceedings. 

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1 CERTIFICATE OF NOTARY PUBLIC
2 I, ROGER MYERS, the officer before whom the foregoing
3 hearing was taken, do hereby certify that the testimony
4 appearing in the foregoing pages was recorded by me and
5 thereafter reduced to typewriting under my direction;
6 that said transcription is a true record of the
7 testimony given by said parties; that I am neither
8 counsel for, related to, nor employed by any of the
9 parties to the action in which this hearing was taken;
10 and, further, that I am not a relative or employee of
11 any counsel or attorney employed by the parties hereto,
12 nor financially or otherwise interested in the outcome
13 of this action.
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# Capital Reporting Company In Re: WorldwideAircraft Services, Inc. 06-06-2013

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## CERTIFICATE OF TRANSCRIPTION

2
3 I, CHERYL LASELLE, hereby certify that I am
4 not the Court Reporter who reported the proceeding
5 and that I have typed the transcript of the

6 proceeding using the Court Reporter's notes and

7 recordings. The foregoing/attached transcript
8 is a true, correct and complete transcription of the
9 proceedings.
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