SILVERBERG 

GOLDMAN& 

B IKO FF, L.L.P. 

ATIORNEYS AT LAW 

VIAFEDEX 

Federal Aviation Administration 

600 Independence Avenue, S.W. 

Wilbur Wright Building 

Suite 2Wl000 

Washington, D.C. 20591 

GEORGETOWN PLACE • Surn120 • 1101 30TH STREET, NW • WASHINGTON, D.C. 20007 

VoiCE (202) 944-3300 • fACSIMILE (202) 944-3306 

June 16, 2014 RECEIVED 

JUN 1 7 2014 

HEARING DOCKET 

(Attention: Hearing Docket Clerk, AGC-430) 

Re: In the Matter of Airborne Maintenance and Engineering Services 

Docket: FAA-2013-0291 

FAA Case No.: 2011 S0290032 

Dear Sir or Madam: 

Enclosed for filing in the above-referenced case please fmd an original and one copy of a 

Revised Rule 26(t) Schedule/Discovery Plan. 

Also enclosed is an additional copy of the Revised Rule 26(t) Schedule/Discovery Plan 

and a pre-addressed, postage paid envelope. Please date-stamp the additional copy and return it 

to our office in the enclosed envelope. 

Thank you for your assistance. Please call me at the telephone number listed above if 

you have any questions regarding this matter. 

Very truly yours, 

SILVERBERG, GOLDMAN & BIKOFF, LLP 

Attorneys for 

AffiBORNE MAINTENANCE AND 

F.N<~G O'ERVICES 

By !.::,~~ 
BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the matter of 

AIRBORNE MAINTENANCE AND 

ENGINEERING SERVICES 

Respondent 

Docket No. FAA-2013-0291 

Case No. 2011S0290032 

Administrative Law Judge 

J.E. Sullivan 

REVISED RULE 26(() SCHEDULEIDISCOVERY PLAN 

Pursuant to ordering paragraph 2 of the Order Granting Joint Motion to Suspend 

Litigation Dates, served May 15,2014, counsel for Respondent Airborne Maintenance 

and Engineering Services and Complainant Federal Aviation Administration have 

consulted with each other and propose the following as the revised Rule 26(f) 

Schedule/Discovery Plan in the above-captioned matter. Counsel for the Federal 

Aviation Administration has authorized the undersigned to submit this proposed, revised 

Schedule/Discovery Plan on behalf of both parties. Counsel for Respondent has 

attempted to contact Mr. Cody Smith to schedule a telephone conference to discuss the 

revised schedule as required by Your Honor's May 151

h Order, but understands that Mr. 

Smith is out of the office until Tuesday, June 17, 2014. Counsel for Respondent will 

contact Mr. Smith upon his return to schedule the teleconference to the extent Your 

Honor deems it necessary to hold a conference call. 

August 25,2014- Resumption of Fact Witness Deposition Period 

September 30, 2014- End of Fact Witness Deposition Period 

October 14, 2014- Expert Disclosures Due 
November 4, 2014- Deadline for Completing General Discovery 

and Filing Rebuttal to Expert Reports 

November 18, 2014- Deadline for Filing Dispositive Motions 

December 9, 2014 - Deadline for Filing Answers to Dispositive Motions 

December 23, 2014- Deadline for Filing Replies to Dispositive Motions 

January 13, 2015 - Oral Argument on Dispositive Motions 

February 19,2015- List of Witnesses/Exchange of Exhibits Due Date 

March 12, 2015- Written Stipulations/Motions in Limine Due Date 

April21-24, 2015- Hearing (subject to Your Honor's schedule) 

Dated: June 16,2014 

Respectfully submitted, 

SILVERBERG, GOLDMAN & BIKOFF, L.L.P. 

Attorneys for 

AIRBORNE MAINTENANCE AND 

ENGINEERING SERVICES 

By:._2_.._R~o-=~~rt'----~.:_~~l/s;,;,r[£~er~~,~Es-~~- 1101 30'h Street, N.W. 

Suite 120 

Washington, D.C. 20007 

Tel: (202) 944-3304 

Fax: (202) 944-3306 

Email: rsilverberg@sgbdc.com 
CERTIFICATE OF SERVICE 

I hereby certify that on this 161

h day of June 2014, I caused the foregoing Revised Ru1e 

26(f) Schedu1e/Discovery Plan to be served upon the following: 

Federal Aviation Administration 

600 Independence Avenue, S.W. 

Wilbur Wright Building 

Suite 2W1000 

Washington, D.C. 20591 

(Attention: Hearing Docket Clerk, AGC-430) 

Tel: (202) 385-8227 

(original and one copy by FedEx overnight delivery) 

The Hon. J.E. Sullivan 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. (E11-310) 

Washington, D.C. 20590 

Tel: (202) 366-2132 

Fax: (202) 366-7536 

(one copy by facsimile and First Class Mail) 

Christopher R. Stevenson, Attorney 

Office of the Regional Counsel, AS0-7 

Southern Region 

Federal Aviation Administration 

P.O. Box 20636 

Atlanta, GA 30320 

Tel: (404) 305-5200 

Fax: (404) 305-5223 

(one copy by facsimile and First Class Mail)