### U.S. DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS

WASHINGTON, D.C.



### InThe Matter Of: PROFESSIONAL FLIGHT TRANSPORT, INC. Respondent. DocketNo. FAA-2015-0638 Judge J.E. Sullivan

FAA Case No. 2014S0190149

FAA'S PROPOSED SCHEDULE 

### Pursuant to the Judge's July 6, 2015, Order, the FAA1 

### hereby submits the following proposed scheduling/discoveryplan: September 22, 2015: Rule 16 Litigation Scheduling Conference October 8, 2015: Deadline for Initial Disclosures October 13, 2015: General Discovery Begins; parties may initiate written discovery; parties may issue Notice ofDeposition November 27, 2015: Deadline for initial expert disclosures December 1, 2015: Beginning ofdeposition period (expert ornon-expert) January 15, 2016: Deadline to issue depositionnotices and/or request subpoenas for third-party depositions March 11, 2016: End ofdepositionperiod (expert ornon-expert) March 25,2016: Deadline to issue written discovery requests; deadline for supplemental expert witness reports

1The FAA acknowledges the preference for ajointproposeddiscovery plan. However, Respondent has declinedto discuss such asubmission. See AttachmentA. 

# D

### April29, 2016: Close ofgeneral discovery; all discovery responses due by this date; remaining discovery time to available only to resolve disputes on existing discovery May 27, 2016: Final Close ofDiscovery June 24, 2016: Dispositive Motion Deadline July 8, 2015: Deadline to Respond to Dispositive Motions July 22, 2016: Deadline for Replies in Support ofDispositive Motions Early August 2016 (or other such date as maybe suitable for the Judge's schedule): Motion Conference on Dispositive Motions (to be converted to pre-hearing conference if

no dispositive motions filed) September 1, 2016: Deadline for exchange ofWitness Lists and Exhibits September 21,2016: Deadline to file written stipulations and/or motions in limine 

### October 2016 (or other such time as maybe suitable for the Judge's schedule): Hearing Respectfully submittedthis 

# l

# ~ay ofSeptember, 2015, 

# 0 Christop er R. Stevenson Attorney Office ofthe ChiefCounsel, Enforcement**Division~** 

### Southern Team

### CERTIFICATE OF SERVICE I hereby certify that the foregoing Proposed Schedule was sent: original and one copy viaFederal Express to: Federal Aviation Administration Attention: Hearing Docket Clerk, AGC-430 WilburWright Building- Suite 2Wl000 800 Independence Avenue, S.W. Washington, D.C. 20591

one copy via federal express, facsimile, and e-mail to: The Honorable J.E. Sullivan Administrative Law Judge Office ofHearings, M-20 U.S. Department ofTransportation 1200 New Jersey Avenue, SE (Ell-310) Washington, DC 20590 facsimile: (202) 366-7536 e-mail: cody.smith@dot.gov Mark B. Goldstein, Esq. 2700 N. Military Trail, Suite 130 BocaRaton, FL 33431 facsimile: (561) 989-9966 e-mail: mbg@bizavlaw.com

Dated

## u.s. Department ofTransportation Federal Aviation Administration Office of the Chief Counsel Enforcement Division Southern T earn 1701 Columbia Avenue College Park, GA 30337 

## LSEe

**~La.** 

## 2015, VIA E-MAIL ONLY Mark B. Goldstein, Esq. 2700 N. Military Trail, Suite 130 BocaRaton, FL 33431 facsimile: 

### (561) 989-9966 mbgralbizavlaw.com Re: 

### ProftssionalFlight 11-<msport, DocketNo. FAA-2015-0638, EIR 2014S0!90149 Mr. Goldstein: I am writing to present 

### a proposed scheduling plan 

### in the above-reference matter. As you are aware, we must submit a scheduling plan (preferably ajoint plan) by September 15, 2015, one week 

### betare the scheduled Rule 16 conference. I have attempted to telephonically contact you several times to discuss a possible schedule and whether your client had accepted by settlement offer, but 

### my calls have not been returned. Accordingly, 

### J am presenting tbis plan to you 

### as a possiblejoint submission. 

### lfi do not receive a response, 

### I 

### will fi.le something along 

### these lines 

### as the FAA's proposed schedule. Based on a recent re-scheduling in another case before Judge Sullivan, the Judge will not be available for 

### a hearing until 

### in or after late September 2016. 

### I am basing this suggested schedule around a possible hearing date in October 2016. September 22,2015: Rule 16 Litigation Scheduling Conference October 8, 2015: Deadline for Initial Disclosures October 

### 13, 20

### 15: GeneralDiscovery Begins; parties may initiate written discovery; parties may issue Notice ofDeposition November27, 2015: Deadline for initial expert disclosures December 

### 1. 2015: Beginning ofdepositionperiod (expert or non-expert) January 

### J

### 5, 2016: Deadline to issue deposition notices and/or request subpoenas for third-party depositions March 11, 20!6: End ofdepositionperiod(expe11 ornon-expert) March 25, 2016: Deadlineto issue written discovery requests; deadline for supplemental expcri witness reports Apri.I 29, 2016: Closeofgeneral discovery; all discoveryresponses dueby this date; remaining discovery time to available only to resolve disputes on existing discovery May 27, 2016: Final Close ofDiscovery June

### 24,2016: Dispositive Motion Deadline July 8, 2015: Deadline to Respond to Dispositive Motions

GOVERNMENT EXAlTJuly 22, 2016: Deadline for Replies in Support ofDispositive Motions Early August 2016: Motion Conference on Dispositive Motions (to be converted to**pre~** hearing conference ifno dispositive motions fi.led) September 1, 2016: Deadline 

### for exchange ofWitness Lists andExhibits September 21, 2016: Deadlineto tile written stipnlations and! or motions in 

### limine October20 16: Hearing As noted above, we are required to make a scheduling submission so that 

### it is received by the Judge by September 15.2015. lfyou. wish to discuss the possible schedule for this case,**plc~L~c** contact me so that we can conclude that discussion and still provide a timely submission to the Judge. Please note that I will he outofthe office on Friday, September II, 20!5.

Christopher R.

## ~~·~~~·-~ Attorney Office ofthe ChiefCounsel, EnforcementDivision- Southern Team