u.s. DEPARTMENT OF TRANSPORTATION REcEIvED 

OFFICE OF HEARINGS 

WASHINGTON, DC FEB 2 7 2014 

HEARING DOCKET 

IN THE MATTER OF DENNIS J. MCGLYNN 

RESPONDENT 

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FAA DOCKET No: TBA 

FAA Region : Western-Pacific 

Judge: Honorable Richard C. Goodwin 

OMS No. FAA-2013-0615 

MOTION FOR CHA~t:>E OF LOCATION OF HEARINI3 

Now comes, Dennis McGlynn by his attorney Fred Morelli Jr. and respectfully requests 

that the hearing on this matter be changed to either Sacramento, California or in the 

alternative to Oakland, California. In support of this motion he states as follows: 

1. The incident complained of was a tandem skydive which took place at a sport 

parachute drop zone located at Lodi California. 

2. I contest the allegations of the complaint filed in this cause. 

3. A hearing on the complaint and my denial of any wrongdoing has been scheduled for 

May 14th and May 151

h, 2014 at the Glenn M. Anderson Federal Building located in 

Long Beach, California. 

4. I live in Auburn, California. The distance from Auburn California to Long Beach is 

480 miles and would take about 7.6 hours to drive. 

5. I have fourteen potential witnesses, their names and addresses are attached and 

marked as Exhibit A. 

6. I am without funds to transport my self and my witnesses from the Auburn and 

Sacramento, California area to Long Beach, California. Having no funds for 

transport, I likewise have no funds to house my witnesses in the Long Beach area. 

7. I anticipate one of my primary witnesses will be Laverne Everett who was my 

tandem passenger. 

1 2/14/14 2:35PM 
8. Laverne Everett was approximately 80 years old at the time of the jump and is now 

approximately 83 years old. The trip to Long Beach, CA would be an undue hardship 

on her. 

9. I am aware that there is an FAA facility in Sacramento, California and another in 

Oakland California. Both locations are significantly closer to the location of the 

incident and the homes of the witnesses. 

10. To require my witnesses to travel to Long Beach, California would be a hardship on 

them of a magnitude that they may refuse to attend. 

11. I am aware of no government witnesses who live or are based in the Long Beach 

area. 

12. The requirement that the hearing be held in Long Beach, California would have the 

practical effect of denying me the right to present witnesses on my behalf and 

therefore to a fair hearing in this cause. 

13. Wherefore, Dennis McGlynn respectfully requests that the hearing location be 

changed from Long Beach, California to either Sacramento, California or Long 

Beach, California. 

Prepared by: 

Fred M. Morelli, Jr. 

IL Atty No. #1957139 

P.O. Box 1416 

Aurora, Illinois 60507-1416 

(630) 892-6665 

2 2/14114 2:35PM 

Fred Morelli 

Attorney for Dennis McGlynn 
Bill Dause 2359 north hwy 99 acampo ,ca 95220 

1. Thomas Whitman 13540 marengo rd, galt, ca 

2. Chris Conkright 2359 north hwy 99 acampo ,ca 95220 

3. · Mike Spugen Lodi, CA 

4. Roger Hoffman 2359 north hwy 99 acampo ,ca 95220 

5. Jay Berg 2359 north hwy 99 acampo ,ca 95220 

6. Mark Hewitt 34163 OLIVE GROVE RD wildomar; CA 92595 

7. Steven Jester sacramento, CA 

8. Will Dasilva 13540 Marengo Rd Galt, CA 

9. Rob Pooly 986 park terrace dr. galt ca 

10. Mike Knight Watsonville, ca 

11. Jauneen Wyman P.O. box 272 Middletown, Ca 

12. Laverne Everett 411 F St Oakdale, CA 95361 (209)847-9375 

i4 robin hied perris valley ca 
Certificate of Service 

I hereby certify that on this date I have placed in the United States mail, 

postage pre-paid, via regular USPS the executed original and one copy of the 

Motion to Change Venue and attached exhibit addressed as follows: 

Federal Aviation Administration 

800 Independence Ave, SW 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building - Suite 2W1 000 

Facsimile: (202) 493-5142 

I further certify that on this date I have placed in the United States mail, 

postage pre-paid, via regular USPS, a true copy of the Motion to Change Venue 

and attached exhibit addressed as follows: 

The Honorable Richard C. Goodwin, Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. (E-11-310) 

Washington D.C. 20590 

TEL 202-366-2139 Attorney-Advisor 

202-366-5121 Legal Assistant 

FAX 202-366-7536 

Dennis McGlynn Respondent 

659 Dorothy Way 

Auburn, CA 95603-3862 
I also further certify that on this date I have placed in the United States 

mail, postage prepaid via overnight mail, a true copy of the Motion to Change 

Venue and attached exhibit addressed as follows: 

Christopher Merrill, Complainant's Counsel 

Attorney, Office of the Regional Counsel, AWP-7.3 

Western-Pacific Region 

Federal Aviation Administration 

P.O. Box 92007 

Los Angeles CA 90009-2007 

TEL 310-725-7105 

FAX 310-725-6816 

I also further certify that on this date I have sent via email a true copy of the 

Motion to Change Venue and attached exhibit addressed as follows: 

PATRICIA MATTHEWS STAFF ASSISTANT (202) 366 5251 

(PATRICIA.MA TTHEWS@ DOT.GOV) 

Dated: -;;:,._ .._ \ Lj--. ( f 

Mel Morelli Adminl trative Assistant 

Law Offices of Morelli & Raval 

P.O. Box 1416 

Aurora IL 60507 
FDMS NO. FAA 2013-0615 

(Civil Penalty Action) 

SERVICE LIST- BY U.S. MAIL 

ORIGINAL AND ONE COPY -VIA US MAIL 

Federal Aviation Administration 

800 Independence Ave, S.W. 

Washington, D.C. 20591 

Attention : Hearing Docket Clerk , AGC-430 

Wilbur Wright Building -Suite 2W1 000 

ONE COPY -VIA US MAIL 

Christopher Merrill, Complainant's Counsel 

Attorney, Office of the Regional Counsel, AWP-7.3 

Western-Pacific Region 

Federal Aviation Administration 

P.O. Box 92007 

Los Angeles CA 90009-2007 

TEL 310-725-7105 

FAX 310-725-6816 

Dennis McGlynn Respondent 

659 Dorothy Way 

Auburn, CA 95603-3862 

The Honorable Richard C. Goodwin, Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. (E-11-310) 

Washington D.C. 20590 

TEL 202-366-2139 Attorney-Advisor 

202-366-5121 Legal Assistant 

FAX 202-366-7536 

ONE COPY- VIA EMAIL 

PATRICIA MATTHEWS STAFF ASSISTANT (202) 366 5251 

(PATRICIA.MATTHEWS@DOT.GOV)