U.S. DEPARTMENT OF TRANSPORTATION 

Office of Hearings 

Washington, D. C. 

1 of 3 

--------~-R-Ho...FCEIVED The Liberty Foundation, Inc. 

FAA DOCKET NO. 2012-0477 

(EIR 2011-GL-03-0070) 

(Civil Penalty Action) 

Hon. J. E. Sullivan, Administrative Law Judge 

JAN 2 8 2014 

HEARING DOCKET 

RESPONDENT'S MOTION TO FOR ENLARGEMENT OF TIME OF 

ONE WEEK TO RESPOND TO ORDER RESERVING RULING ON 

MOTION TO CONTINUE. ETC. 

Respondent, The Liberty Foundation (TLF), by and through its undersigned 

attorney, respectfully moves the Court for the entry of an order enlarging the time within 

which it may respond to the Court's January 14, 2014 Order Reserving Ruling On 

Motion To Continue And Directing The Parties To File Supplemental Materials ("The 

Order"). In support of its Motion, TLF states: 

The Order was received in undersigned counsel's office yesterday, January 21, 

2014, despite the fact it is dated a week earlier on January 14, 2014. The reason for 

the late arrival of The Order is that it was both faxed to undersigned counsel's old fax 

number and mailed to undersigned counsel's old address, as can be seen on the 

Service List. Undersigned counsel previously filed a Notice of Address Change on 

August 23, 2013. A copy of that Notice is attached hereto as Exhibit A. Further, the 

Court's office has previously faxed and mailed orders to undersigned counsel at his new 

STUART A. GOLDSTEIN, P. A. 

7300 North Kendall Drive, Suite 380, Miam~FL 33156 

T: {305) 670·12.22 F: (305) 400-0685 EMAIL: SJJJABIG.QI.DSIE!NEA.@AIL.NEI 
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address and fax number. Undersigned counsel's address and phone/fax number 

appear at the bottom of every page of the Motion To Continue. 

The inadvertent error in the Court's office shortened by one week TLF's response 

time. It appears from The Order the intent was to allow the parties 15 days to respond 

to The Order. 

Undersigned counsel conferred with counsel for the Administrator regarding this 

Motion. Administrator's counsel could not say if he will oppose this Motion. 

WHEREFORE, TLF respectfully requests an enlargement of time of one week, to 

and including February 5, 2014 to respond to The Order. 

Respectfully submitted, 

STUART A. GOLDSTEIN, P. A. 

7300 North Kendall Drive, Suite 380 

Miami, FL 33156 

Tel: (305) 670-1222 

Fax: (305) 670-7065 

Email: stuartgoldsteinpa@att.net 

STUART A. GOLDSTEIN, P. A. 

7300 North Kendall Drive, Suite 380, Miam~FL 33156 

T: (305) 670-1222 F: (305)400-0685 EMAIL: SI.UABIG.QLJ:!SI_f!NfA_@.AILJ:IlEI 
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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that the foregoing has been served on this 22nd day of 

January, 2014, as set forth below: 

Christopher R. Stevenson, Esq. 

Office of the Regional Counsel 

Federal Aviation Administration 

P. 0. Box 20636 

Atlanta, GA 30320 

By Facsimile (404) 305-5223 

and regular U. S. Mail 

and that an original and one copy was served upon: 

Hearing Docket Clerk, AGC-430 

Wilbur Wright Building, Suite 2W1000 

Federal Aviation Administration 

800 Independence Avenue, S. W. 

Washington, D. C. 20591 

and that a copy was served upon: 

Honorable J. E. Sullivan 

Office of Hearings, M-20 

S. Department of Transportation 

1200 New Jersey Avenue, S. E. (E11-31 0) 

Washington, D. C. 20590 

By Facsimile: (202) 366-7536 

and regular U. S. Mail h. A " 

,~i-.~~-:~-~,-1 ... \ i' f fl~ ·;·.)}:r t:rBy: rs :\70-.f:pu C\ . x.':rtli wY U r---= 

Stuart A. Goldstein 

STUART A. GOLDSTEIN, P. A. 

7300 North Kendall Drive, Suite 380, Miami,FL 33156 

T: (305) 670·1222 F: (305) 400·0685 EMAIL: S.I!JARTGO! QSIE!NpA®AU NET 
U.S. DEPARTMENT OF TRANSPORTATION 

Office of Hearings 

Washington, D. C. 

The Liberty Foundation, Inc. 

FAA DOCKET NO. 2012-0477 

(EIR 2011-GL-03-0070) 

(Civil Penalty Action) 

Hon. J. E. Sullivan, Administrative Law Judge 

RESPONDENT'S COUNSEL'S NOTICE OF ADDRESS CHANGE 

Respondent's undersigned counsel herewith notifies the Court, the Clerk, and 

opposing counsel of his new address, effective as of September 2, 2013, as follows: 

7300 North Kendall Drive, Suite 380 

Miami, FL 33156 

Undersigned counsel's telephone number will remain the same, but his facsimile 

number will change to: (305) 400-0685. 

Respectfully submitted, 

STUART A. GOLDSTEIN, P. A. 

9350 South Dixie Highway, 10th Floor 

Miami, FL 33156 

Tel: (305) 670-1222 

Fax: (305) 670-7065 

Email: stuartgoldsteinpa@ alt. net 

STUART A. GOLDSTEIN, P A 

9350 SOU!'H DIXIE HIGHWAY, 10TH I'LOOR, MIAMI, FL 33156 

T: (305) 670-1222 F: (305)670·7065 EMAIL: SJl..A!ll:\.i_QW281Ht:lf..6..@LAll['Jll 

A 
CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that the foregoing has been served on this 23rd day of 

August, 2013, as set forth below: 

Christopher R. Stevenson, Esq. 

Office of the Regional Counsel 

Federal Aviation Administration 

P. 0. Box 20636 

Atlanta, GA 30320 

By Facsimile (404) 305-5223 

and regular U. S. Mail 

and that an original and one copy was served upon: 

Hearing Docket Clerk, AGC-430 

Wilbur Wright Building, Suite 2W1000 

Federal Aviation Administration 

800 Independence Avenue, S. W. 

Washington, D. C. 20591 

and that a copy was served upon: 

Honorable J. E. Sullivan 

Office of Hearings, M-20 

U. S. Department of Transportation 

1200 New Jersey Avenue, S. E. (E11-31 0) 

Washington, D. C. 20590 

By Facsimile: (202) 366-7536 

and regular U. S. Mail 

/\ 

By: lc~N;G$1 //. vlitlf)i~-~ Stuart A. Goldstein 

STUAf!T A. GOLDSTEIN, P. A. 

9350 SOUTH DIXIE HIGHWAY, 10TH FLOOR, MIAMI, Fl 33156 

T: {305\ 670..1222 F: (305) 570-7065 EMAIL: SHMRTGOI DSIE!NP;\<alf\TT.NFT