U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In The Matter Of: 

PROFESSIONAL FLIGHT TRANSPORT, INC. 

Respondent. 

Docket No. F AA-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/discovery plan: 

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 of Deposition 

November 27, 2015: Deadline for initial expert disclosures 

December 1, 2015: Beginning of deposition period (expert or non-expert) 

January 15, 2016: Deadline to issue deposition notices and/or request subpoenas for 

third-party depositions 

March 11, 2016: End of deposition period (expert or non-expert) 

March 25,2016: Deadline to issue written discovery requests; deadline for supplemental 

expert witness reports 

1 The FAA acknowledges the preference for a joint proposed discovery plan. However, Respondent has declined to 

discuss such a submission. See Attachment A. 

D 
April29, 2016: Close of general 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 of Discovery 

June 24, 2016: Dispositive Motion Deadline 

July 8, 2015: Deadline to Respond to Dispositive Motions 

July 22, 2016: Deadline for Replies in Support of Dispositive Motions 

Early August 2016 (or other such date as may be 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 of Witness Lists and Exhibits 

September 21,2016: Deadline to file written stipulations and/or motions in limine 

October 2016 (or other such time as may be suitable for the Judge's schedule): Hearing 

Respectfully submitted this l ~ay of September, 2015, 

0 

Christop er R. Stevenson 

Attorney 

Office of the Chief Counsel, Enforcement Division~ Southern Team 
CERTIFICATE OF SERVICE 

I hereby certify that the foregoing Proposed Schedule was sent: 

original and one copy via Federal Express to: 

Federal Aviation Administration 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2Wl 000 

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 of Hearings, M-20 

U.S. Department of Transportation 

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 

Boca Raton, FL 33431 

facsimile: (561) 989-9966 

e-mail: mbg@bizavlaw.com 

Dated 
u.s. Department 

of Transportation 

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 

Boca Raton, FL 33431 

facsimile: (561) 989-9966 

mbgralbizavlaw .com 

Re: Proftssional Flight 11-<msport, Docket No. 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 a joint 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 

possible joint 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: General Discovery Begins; parties may initiate written discovery; 

parties may issue Notice of Deposition 

November 27, 2015: Deadline for initial expert disclosures 

December 1. 2015: Beginning of deposition period (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 of deposition period (expe11 or non-expert) 

March 2 5, 2016: Deadline to issue written discovery requests; deadline for supplemental 

expcri witness reports 

Apri.I 29, 2016: Close of general 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 of Discovery 

June 24,2016: Dispositive Motion Deadline 

July 8, 2015: Deadline to Respond to Dispositive Motions 

GOVERNMENT 

EXAlT 
July 22, 2016: Deadline for Replies in Support of Dispositive Motions 

Early August 2016: Motion Conference on Dispositive Motions (to be converted to pre~ 

hearing conference if no dispositive motions fi.led) 

September 1, 2016: Deadline for exchange of Witness Lists and Exhibits 

September 21, 2016: Deadline to tile written stipnlations and! or motions in limine 

October 20 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 out of the office on Friday, September II, 20!5. 

Christopher R. ~~·~~~·-~ Attorney 

Office of the Chief Counsel, Enforcement Division- Southern Team