UNITED STATES OF AMERICA

 UNITED STATES OF AMERICA

 DEPARTMENT OF TRANSPORTATION

 OFFICE OF HEARINGS

IN THE MATTER OF:

MIAMI TECH AIRCRAFT DOCKET NO. FAA-2014-0682

MAINTENANCE, INC.

RESPONDENT.

_____________________________________________________

 TELECONFERENCE HEARING BEFORE

 THE HONORABLE J.E. SULLIVAN

 THURSDAY, JANUARY 15, 2015

 9:56 A.M.

 HISTORIC JORDAN SPRINGS

 1160 JORDAN SPRINGS ROAD

 STEPHENSON, VIRGINIA 22656
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 2

1 APPEARANCES

2 ON BEHALF OF THE UNITED STATES OF AMERICA,

3 DEPARTMENT OF TRANSPORTATION:

4 WILLIAM VINES, ESQUIRE

5 FEDERAL AVIATION ADMINISTRATION, SOUTHERN REGION

6 1701 COLUMBIA AVENUE

7 COLLEGE PARK, GEORGIA 30337

8 TELEPHONE: 404.305.5200

9 FACSIMILE: 404.305.5223

10 EMAIL: WILLIAM.VINES@FAA.GOV

11

12 ON BEHALF OF THE RESPONDENT,

13 MIAMI TECH AIRCRAFT MAINTENANCE, INC.:

14 JUAN R. SERRANO, ESQUIRE

15 GRIFFIN & SERRANO, P.A.

16 BLACKSTONE BUILDING, 6TH FLOOR

17 707 SOUTHEAST 3RD AVENUE

18 FORT LAUDERDALE, FLORIDA 33316

19 TELEPHONE: 954.462.4002

20 FACSIMILE: 954.462.4009

21

22 ALSO PRESENT:

23 CODY L. SMITH

24

25
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 3

1 INDEX

2 Page

3

4 (NONE EXAMINED)

5

6

7 EXHIBITS

8 Exhibit Page

9

10 (NONE MARKED)

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 4

1 TELECONFERENCE HEARING

2 THURSDAY, JANUARY 15, 2015

3 9:56 A.M.

4 THE COURT: Good morning. This is

5 Judge Sullivan. Do I have Mr. Vines on the line?

6 MR. VINES: Yes, Judge.

7 THE COURT: And do I also have Mr.

8 Serrano on the line?

9 MR. SERRANO: Yes. Good morning,

10 Judge.

11 THE COURT: Good morning. And I should

12 also have Dakota Swafford, the court reporter from the

13 court reporting company?

14 COURT REPORTER: Yes, ma'am.

15 THE COURT: And Mr. Swafford, are you

16 ready to proceed?

17 COURT REPORTER: Yes, ma'am.

18 THE COURT: We're on the record in the

19 matter of Miami Tech Aircraft Maintenance, Inc. This

20 is docket number FAA-2014-0682. Today is Thursday,

21 January 15, 2015 and the parties have convened by

22 telephone for a litigation scheduling conference. The

23 Federal Aviation Administration, which I'll

24 hereinafter refer to as the FAA, is represented by its

25 attorney of record, Mr. William Vines. The
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 5

1 respondent, Miami Tech Aircraft Maintenance, Inc., is

2 represented by its attorney of record, Mr. Juan

3 Serrano. Good morning to you both, counsel.

4 MR. VINES: Good morning.

5 MR. SERRANO: Good morning.

6 THE COURT: I will note that on October

7 24, 2014, an order setting Rule 16 litigation

8 scheduling conference and directing Rule 26F, planning

9 and submission was filed. On January 7, 2015, the

10 parties filed a joint Section 13.217/Rule 26(f) Report

11 and the parties have convened today to discuss that.

12 So, let's start off with a little bit

13 of discussion about your Rule 26(f) Report. There

14 appears to be a rush to trial in this report since it

15 looks like you're suggesting that we have the trial

16 sometime in June or shortly thereafter. Mr. Vines,

17 was that your party's hope in putting this schedule

18 together?

19 MR. VINES: I'll speak for myself, that

20 was not my, that was not intended by this report, no,

21 Judge.

22 THE COURT: Okay. Mr. Serrano, how

23 about you. Was that your client's hope?

24 MR. SERRANO: No, Your Honor. We're in

25 no hurry to get the matter resolved. It was just,
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 6

1 just that we had, those were dates that would work but

2 we don't, we don't need to rush the trial.

3 THE COURT: Okay. Then I won't, didn't

4 want to disappoint either of your clients. My trial

5 schedule is such that I'm setting in early 2016 at

6 this point. So, I can certainly adopt some of the

7 short abbreviated times but it wouldn't make sense.

8 Particularly since if we set the trial in 2016, as I

9 hope that we can, you would be sitting with six months

10 of dead time and we might as well give you and your

11 clients a little bit of room and breathing room for

12 discovery and depositions if the trial is not going to

13 be heard until early next year.

14 So, maybe what we can do is talk a

15 little bit first about how long the trial will take,

16 assuming that no issues are resolved by a pretrial

17 discussion or motion and where that trial would be.

18 You indicate in the Miramar, Miami area. We want to

19 chat about that a little bit. And then once we talk

20 about those issues and get some dates tentatively set

21 on our calendar, we can backtrack and give you some

22 periods of time for each phase of discovery. Would

23 that work for you, Mr. Vines?

24 MR. VINES: Yes, Judge.

25 THE COURT: And Mr. Serrano?
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 7

1 MR. SERRANO: Yes, Your Honor.

2 THE COURT: So, Mr. Vines, let's start

3 with you. How long do you think this hearing would

4 take if all issues remained on the table for the trial

5 itself?

6 MR. VINES: Judge, I would estimate two

7 to three days.

8 THE COURT: And Mr. Serrano, would you

9 agree with that general estimate?

10 MR. SERRANO: Yes, Your Honor. I think

11 we could present our defenses in two days or less.

12 So, we might extend that to four but I think two to

13 three is a fair estimate.

14 THE COURT: Well, lets err on the side

15 of caution because I have found that no matter how

16 experienced the lawyer, there are things that do come

17 up in trial that no one thought about a month or three

18 months ahead of time. So, lets assume four days for

19 the sake of argument at this point.

20 In terms of the Miramar, Miami area, can you

21 tell me, Mr. Vines, about Miramar because I'm not

22 familiar with that. Is that a suburb of Miami or is

23 it another city?

24 MR. VINES: Mr. Serrano may be better

25 inclined to discuss that issue, Judge. It's my
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 8

1 understanding it is, I think, southwest of Fort

2 Lauderdale and northwest of Miami.

3 THE COURT: Mr. Serrano, is that

4 accurate or does there need to be more discussion

5 about that?

6 MR. SERRANO: No, that's accurate.

7 It's probably halfway between Miami International and

8 Fort Lauderdale. And you know, Your Honor, down here

9 it's, it's concrete all along so that the lines of

10 demarcation between city and city are hard to tell.

11 It's just all one big blur. But I think Miramar,

12 technically, is a different city.

13 THE COURT: I've had the chance

14 recently to talk to a federal judge who sits in Miami

15 and he was telling me that a new federal district

16 courthouse has opened recently in or around the Fort

17 Lauderdale area. Are you aware of that?

18 MR. SERRANO: I don't know that it's

19 open yet. I can certainly find out. I thought it was

20 maybe a month or two away still. Certainly it would

21 be open by 2016.

22 THE COURT: According to him, and I

23 spoke with him in October of 2014, it was already

24 open. And there was one sitting judge and some empty

25 courtrooms there. So I'm wondering if the Fort
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 9

1 Lauderdale area is encompassed in the Miramar/Miami

2 area because if it is, we may be able to easily find

3 courtroom space at that newest district court. Mr.

4 Serrano, do you ...

5 MR. SERRANO: I'm sorry, Judge.

6 THE COURT: ... yes, do you have an

7 opinion about that?

8 MR. SERRANO: I think that would be a

9 great venue. Absolutely. I mean, there certainly is a

10 federal courthouse in Fort Lauderdale.

11 THE COURT: Yes.

12 MR. SERRANO: If there is a new one

13 that's opened up, that would be great. My office is

14 in Fort Lauderdale so it would be terribly convenient

15 for me.

16 THE COURT: And is there, in terms of

17 Fort Lauderdale facilities, does it have an airport,

18 does it have hotel facilities, I mean, how

19 sophisticated and independent is it as a city from

20 Miami?

21 MR. SERRANO: It is absolutely

22 sophisticated, independent, you know, well, you know,

23 versed in the sense of, you know, hotels, restaurants,

24 it's a big city.

25 THE COURT: Does it have an airport?
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 10

1 MR. SERRANO: It does.

2 THE COURT: Okay.

3 MR. SERRANO: Several.

4 THE COURT: Mr. Vines, would it be

5 acceptable to focus in on Fort Lauderdale for our

6 purposes and then if for some reason we, we can't get

7 a courthouse there, move into the Miami/Miramar

8 greater area?

9 MR. VINES: I have no objections to

10 that plan, Judge.

11 THE COURT: Well, let's plan on that.

12 Okay. So let's talk next about trial time and let's

13 all look at our calendars. And that gets, I think I

14 need to take a look, open up my calendar. Give me a

15 moment to do that, please. And my first opening is

16 February of 2016. So, Mr. Vines, once you get your

17 February of 2016 calendar open, let's talk a little

18 bit about your dates of availability and then I'll

19 turn to Mr. Serrano.

20 MR. VINES: Judge, other than the, I

21 think the federal holiday that lies in February, I

22 have, I'm wide open.

23 THE COURT: Mr. Serrano, how about you?

24 MR. SERRANO: I am too, Your Honor.

25 Wide open.
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 11

1 THE COURT: Why don't we, I think that

2 federal holiday is probably going to land on the 15th

3 or the 22nd and I don't know for sure so I'm going to

4 double check that right now while you're both on the

5 phone. Here it is. That doesn't tell me. Let me see

6 if I can go to another website and find out.

7 MR. SERRANO: Judge, my research, I'm

8 online, I'm in OPM.gov and it's saying that Monday,

9 February 15th is Washington's birthday.

10 THE COURT: Thank you. Thank you.

11 Well, let's try for the week following that, February

12 22nd, 2016, through February 26th, 2016. And Mr.

13 Vines, do you prefer to travel on a Sunday or a

14 Monday? Do you care?

15 MR. VINES: Judge, I'll prefer to

16 travel on a workday.

17 THE COURT: Okay. Then let's plan on

18 Monday, February 22nd, 2016, as our travel day to

19 Florida with the hearing itself starting on February

20 23rd, 2016. And to err on the side of caution, we'll

21 take through February 26th, 2016, with the last travel

22 day being on a Saturday, February 27, 2016.

23 Now, obviously as we get closer to the

24 hearing, if the parties have resolved some issues, we

25 can tighten up that trial schedule. But for now I
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 12

1 think that it's best to err on the side of caution and

2 set 4 days so that we have plenty of muscle room to

3 utilize the, for the hearing itself. Mr. Vines, is

4 that, is that an acceptable time period for your

5 client?

6 MR. VINES: Yes, Judge.

7 THE COURT: And Mr. Serrano, how about

8 for your client?

9 MR. SERRANO: Yes, it is, Judge.

10 THE COURT: So having said that, let's

11 talk a little bit about the discovery period, the

12 exchange of information, the setting of a dispositive

13 motion for any kind of summary judgements and so

14 forth.

15 Typically, one of the last things that

16 I do with the parties is hold a telephone conference

17 for hearing pretrial dispositive motions. And that's

18 usually done between two and three months before the

19 hearing starts. In part to give me time to get

20 through all of the evidence and make a ruling so that

21 the parties don't have to put together evidence and

22 witness lists on matters that have actually already

23 been resolved by pretrial motion.

24 So if our hearing date begins on

25 February 23rd, 2016, we're talking about having a
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 13

1 summary judgement motion most likely in late November,

2 early December of 2015. So, I'm going to take a look

3 at my calendar and suggest a date, some dates to you.

4 How about the week of November 1st for a 90 minute

5 pre-hearing conference for summary judgement purposes.

6 Mr. Vines, do you have calendar availability that

7 week?

8 MR. VINES: Yes, Judge, I'm wide open.

9 THE COURT: And Mr. Serrano, how about

10 you?

11 MR. SERRANO: The Tuesday and the

12 Thursday mornings are taken but other than that it's

13 wide open.

14 THE COURT: And so why don't we talk

15 about November 4, which is a Wednesday in the year

16 2015, and Mr. Vines, do you have a preference for

17 morning or afternoon?

18 MR. VINES: Either is fine, Judge.

19 THE COURT: Mr. Serrano, same question?

20 MR. SERRANO: Either one is fine.

21 THE COURT: Why don't we plan then for

22 a 10:30 a.m. telephone conference for 90 minutes which

23 would run us to noon p.m., eastern time, and that will

24 be for any kind of summary judgement oral argument.

25 If for some reason the parties don't file any motions
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 14

1 for summary judgement or for partial disposition of

2 the case, keep this on your calendar because I use it

3 for a pretrial status conference. So this conference

4 will be heard. It may not run 90 minutes if there are

5 no motions to address but we will have it on the

6 calendar.

7 So having said that, let me take a look

8 at the calendar preceding that date and come up with

9 suggestions for you both about filing motions,

10 responses and the like. And I'm going to be double

11 checking my calendar first, quietly to myself to make

12 sure I'm in the office to read the material that you

13 file, so.

14 Okay, how about this. We could have

15 the motion due date on or about August 27, 2015. The

16 response on or about September 24, 2015 and the reply

17 on or about October 15, 2015. Those dates work for,

18 would you like to do something a little bit different?

19 Mr. Vines, and I know you want to take a look at your

20 calendar first.

21 MR. VINES: Judge, I've got the first

22 date, the August 27th date. Would you kindly repeat

23 the other 2 dates?

24 THE COURT: Of course. The response

25 date I propose is September 24, 2015. The reply date,
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 15

1 October 15, 2015.

2 MR. VINES: Thank you, Judge. Standby

3 for me.

4 THE COURT: Sure.

5 MR. VINES: Judge, I have no objection

6 to that schedule.

7 THE COURT: Mr. Serrano, how about you?

8 MR. SERRANO: No objection, Judge.

9 THE COURT: Then let's adopt that as it

10 is and then let's talk a little bit about some of

11 these other dates. And essentially, you've already

12 provided a due date for initial discovery disclosures

13 of January 30, 2015, which I'm happy to adopt.

14 Typically then I start the general discovery process

15 on or before the same date as the deadline for initial

16 disclosures. And given the little extra time that we

17 have because of our hearing date, let's do that in

18 this case. Or let's start out with that suggestion.

19 And say that on or before January 30, 2015, general

20 discovery is initiated.

21 And then we want to talk about expert

22 witness disclosures. You've indicated in your Rule

23 26(f) Report, initial discovery request with response

24 dates. I'm going to presume that you both know that

25 response to initial discovery requests and other
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 16

1 discovery requests is typically 30 days unless the

2 parties agree otherwise. And so, I don't necessarily

3 need to have that particular deadline, it's already in

4 the rules for the rules of practice outlined in the

5 litigation order.

6 What I do need to have, I think, and I

7 found it helpful for the parties, is to have some

8 other deadlines provided such as a deadline for

9 motions that need to be filed if discovery, if a party

10 seeks to limit discovery. When a party should file a

11 motion to compel. And then when parties should start

12 exchanging expert witness disclosures. And that would

13 be expert witness disclosures or reports, rebuttal

14 reports. And then that timeframe where people might

15 want to depose an expert before general discovery is

16 closed.

17 So, essentially with my litigation

18 schedule I typically will ask parties to serve a

19 motion for relief from a discovery request within 10

20 days after service. And then I'll have information in

21 the litigation order about the good faith declaration

22 that should accompany such a motion and when to

23 respond to that motion. Which should be no later than

24 10 days after service of the motion. The same would

25 be true, essentially, for a motion to compel if you
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 17

1 have troubles with discovery.

2 Mr. Vines, do you have any difficulty

3 with those general dates in a litigation order?

4 MR. VINES: No, Judge, I do not.

5 THE COURT: Mr. Serrano, how about you?

6 MR. SERRANO: I'm fine with those,

7 Judge.

8 THE COURT: Let's talk about expert

9 witness disclosures. If we're having a motion for

10 summary judgement deadline of August 27, 2015,

11 generally you'd want to have all discovery closed, if

12 you can, about a month prior to that. So let's assume

13 just for the sake of argument this morning, that we're

14 going to set July 31, which is the last weekday of

15 July 2015, as the deadline for all general discovery

16 to be done. If we do that, then we want to set some

17 time limits prior to that for expert witness

18 disclosures, reports and depositions.

19 And so I'm going to look at my

20 calendar. I'm going to suggest some things and then

21 see what you think. And give me a minute to do that.

22 Okay, how about this. How about having your expert

23 disclosure deadline, you can disclose them now if you

24 want, but how about having the deadline be around June

25 19, 2015. Expert rebuttal by July 10, 2015, and the
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 18

1 close of all discovery by July 31, 2015. That gives

2 you just a window of about 3 weeks to set up

3 depositions and take them, of any experts that you,

4 you chose to depose. So, it's a very short window of

5 time but if you want to have a longer window of time,

6 that's fine. I'm just giving you some ideas of what

7 might work.

8 Mr. Vines, what's your thought about

9 that?

10 MR. VINES: I'm sorry, Judge. I keep

11 putting my phone on mute and so you don't hear paper

12 shuffling in the background and then when I, when it's

13 my turn to talk, I forget it's activated. I'm, Judge,

14 I have no objection to that timeline.

15 THE COURT: And Mr. Serrano, how about

16 you?

17 MR. SERRANO: That schedule works fine,

18 Judge. The only request I was going to make was that

19 we stagger the experts but I think in your rebuttal

20 deadline, that takes care of that.

21 THE COURT: We can stagger if you want.

22 I've done it both ways.

23 MR. SERRANO: I think it's fine. So

24 long as, you know, I have an opportunity to evaluate

25 the FFA's experts and have some window to determine
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 19

1 whether I need a rebuttal expert then retain one and,

2 and do those things. I think three weeks is enough.

3 THE COURT: Okay. Very good. Then

4 let's adopt those time periods. That means

5 essentially that you would have from January 30th,

6 which is the beginning of the initial discovery,

7 formal discovery phase, until July 31. And some of

8 these due dates, obviously, tucked in to that

9 discovery period. There's obviously a duty to amend or

10 supplement any discovery request as soon as the

11 information is known and that will be contained in the

12 litigation order.

13 What I also generally do is set a date

14 for change of witnesses and exhibits and since we have

15 a summary judgement oral argument on November 4, 2015,

16 I'm going to hope I get that order out before

17 Christmas. And I need to look at my July, my January

18 2016. How about setting the list of witnesses and

19 exchange of exhibits for January 12th, 2016. Would

20 that work for you, Mr. Vines? Or do you want it a

21 little sooner than that?

22 MR. VINES: Judge, that's fine with the

23 FAA.

24 THE COURT: And Mr. Serrano, is that

25 acceptable?
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 20

1 MR. SERRANO: It is acceptable, Judge.

2 THE COURT: And I'm going to also ask

3 you folks to adopt a date for filing any kind of

4 written stipulations or agreed motions in limine prior

5 to the hearing. Obviously you can make oral motions

6 in limine on the day of the hearing but the more you

7 talk about and agree to ahead of time and let me know,

8 the easier it is for all of us to hone in on what's

9 really tugging at the dispute.

10 So, let's talk about a date for that.

11 How about February 9th, 2015, '16, excuse me, for the

12 deadline for filing any written stipulations or agreed

13 motions in limine regarding the hearing procedure

14 itself. Mr. Vines, is that acceptable to you?

15 MR. VINES: Yes, Judge.

16 THE COURT: And Mr. Serrano?

17 MR. SERRANO: Yes, Judge.

18 THE COURT: Okay. Then let me go

19 through my, my notes and see if there's anything else

20 we need to address today. I do have some information

21 in my litigation order about how to prepare and mark

22 exhibits and bring exhibits to the hearing. In

23 essence, you want to bring 3 copies of any documents

24 you wish to offer to the hearing itself even though

25 you've filed exhibits ahead of time. And part of the
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 21

1 reason for that is because people change their minds

2 about things, first and foremost. And also because we

3 have a hired court reporter who will need to take 2

4 copies of those exhibits that are actually moved for

5 admissions and then file 1 with the transcript which

6 would then be filed with the hearing docket as well.

7 So, there will be information about that.

8 If there's anything in the procedural

9 order that is confusing or you think is in error,

10 please call my office and speak to the attorney

11 advisor who works with me. His name is Mr. Smith. I

12 believe you talked with him briefly this morning when

13 the call was being set up. And he will promptly

14 address any concerns you have.

15 Is there anything else that we need to

16 talk about today then, on behalf of the FAA, Mr.

17 Vines?

18 MR. VINES: Not that I'm aware of,

19 Judge.

20 THE COURT: Okay. And Mr. Serrano,

21 anything that we need to address on behalf of your

22 clients?

23 MR. SERRANO: I don't think so, Judge.

24 I think we covered it.

25 THE COURT: Okay. Then I thank you
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 22

1 both very much for your time and your work today. I

2 will be sending out a litigation order no later than

3 tomorrow in this case. It will contain all the dates

4 that we've talked about and I will look forward to

5 talking with you later this year at a pre-hearing

6 conference. Either for summary judgement purposes or

7 otherwise.

8 I, we should also note though, that if

9 there are, if there's anything that you need in terms

10 of other conference dates be set on my calendar, the

11 easiest way to do that is to talk amongst yourselves,

12 come up with 3 alternative dates that work for both of

13 you and then call Mr. Smith and tell him that you want

14 to get on my calendar and that these are the 3 dates

15 that you're thinking about. And he can check with my

16 calendar. He has access to it. And then tell you if

17 any of those dates work and if not, what other dates

18 might be available so that you can get on the calendar

19 quickly and address any concerns that have arisen that

20 we didn't talk about today.

21 So, with that, I will thank you both

22 very much for your presence today. Wish you both a

23 happy new year. We can go off the record and I wish

24 you all a good day. Thank you.

25 MR. VINES: Thank you, Judge.
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 23

1 MR. SERRANO: Thank you as well.

2 THE COURT: Bye-bye.

3 (WHEREUPON, the Teleconference Hearing was concluded

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REPORTERS 

855.667.0077 

VETERANREPORTERS.COM 
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 24

1 STIPULATION

2

3 The foregoing matter was taken on the date, and at

4 the time and place set out on the title page hereof.

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6 It was requested that the matter be taken by the

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CERTIFICATE OF REPORTER AND SECURE ENCRYPTED

 I, Dakota W. Swafford, do hereby certify that

 the foregoing matter was reported by stenographic and/or 

 mechanical means, that same was reduced to written form,

 that the transcript prepared by me or under my direction, 

 is a true and accurate record of same to the best of my 

 This transcript and certificate have been digitally

 the action filed or its outcome.

 knowledge and ability; that there is no relation nor 

 parties hereto, nor financial or otherwise interest in

 employment by any attorney or counsel employed by the

SIGNATURE AND DELIVERY OF CERTIFIED TRANSCRIPT

 signed and securely delivered through our encryption

 server.

 IN WITNESS HEREOF, I have here unto set my hand 

 this day of , .

My Commission Expires: 

Notary Registration Number: 7609015

Court Reporter / Notary

Dakota W. Swafford

20th January 2015

12/31/2018
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 26

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19 17:25

1st 13:4

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13:24 17:13

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assume 7:18
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 27

17:12

assuming 6:16

attorney 4:25

5:2 21:10

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14:15 14:22

17:10

availability

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22:18

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17:8

18:15 18:21

19:3

19:24

20:2

20:16 20:18

21:3

21:20 21:25

23:2
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 28

courthouse

8:16 9:10

10:7

courtroom 9:3

courtrooms

8:25

covered 21:24

D

Dakota 4:12

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15:15

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16:8

December 13:2

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16:21

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8:10

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16:15 18:4

depositions

6:12

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18:25

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8:12 14:18

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17:2

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6:4

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17:23

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17:23

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15:12 15:16

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20:23

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18:24

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12:20 12:21

exchange

12:12 19:19

exchanging

16:12

excuse 20:11

exhibits

19:14 19:19

20:22 20:22

20:25 21:4
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 29

experienced

7:16

expert

15:21 16:12

16:13 16:15

17:8

17:17 17:22

17:25 19:1

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18:3

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F

FAA 4:24

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9:17 9:18

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10:16 10:17

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11:18 11:19

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4:23 8:14

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13:20

17:6 18:6

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18:6

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Inc 4:19 5:1

inclined 7:25

independent

9:19 9:22
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 30

indicate 6:18

indicated

15:22

information

12:12 16:20

19:11 20:20

21:7

initial 15:12

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12:13

July 17:14

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19:17

June 5:16

17:24

K

kindly 14:22

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L

land 11:2

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10:17 11:11

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line 4:5 4:8

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4:22 5:7

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17:3

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22:2

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14:18 15:10

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long 6:15 7:3

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M

ma'am 4:14

4:17

Maintenance

4:19 5:1

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14:12

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may 7:24

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8:20

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Miami 4:19

5:1 6:18

7:20 7:22

8:2 8:7

8:14 9:20

Miami/Miramar

10:7

minds 21:1

minute 13:4

17:21
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 31

minutes 13:22

14:4

Miramar

6:18 7:20

7:21 8:11

Miramar/Miami

9:1

moment 10:15

Monday 11:8

11:14 11:18

month 7:17

8:20 17:12

months 6:9

7:18 12:18

morning 4:4

4:9 4:11

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21:12

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13:25

14:5 14:9

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myself 5:19

14:11

N

necessarily

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November 13:1

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11:23

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10:14 10:17

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18:24

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16:2 22:7

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16:3

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4:21 5:10

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16:2 16:7

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16:14 21:1

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periods

6:22 19:4

phase 6:22

19:7

phone 11:5

18:11

plan 10:10

10:11 11:17

13:21

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please

10:15 21:10

plenty 12:2

point 6:6

7:19

practice 16:4

preceding

14:8

prefer

11:13 11:15

preference

13:16

pre-hearing
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 32

13:5 22:5

prepare 20:21

presence

22:22

present 7:11

presume 15:24

pretrial 6:16

12:17 12:23

14:3

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8:7 11:2

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21:8

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20:13

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process 15:14

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21:13

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15:12 16:8

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5:17 18:11

Q

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13:19

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quietly 14:11

R

ready 4:16

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reason 10:6

13:25 21:1

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16:13 17:25

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recently 8:14

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4:25 5:2

22:23

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20:13

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remained 7:4

repeat 14:22

reply 14:16

14:25

report 5:10

5:13 5:14

5:20 15:23

reporter 4:12

4:14 4:17

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reporting

4:13

reports 16:13

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4:24 5:2

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16:19 18:18

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requests

15:25 16:1

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resolved 5:25

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respondent

5:1

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14:16 14:24

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14:10

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9:23

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room 6:11

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Rule 5:7

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15:22

rules 16:4

16:4

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S

sake 7:19

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11:22

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sense 6:7

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September

14:16 14:25

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5:22 5:24

6:25 7:1

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11:7 12:7

12:9 13:9

13:11 13:19

13:20

15:7 15:8

17:5 17:6

18:15 18:17

18:23 19:24

20:1

20:16 20:17

21:20 21:23

23:1

serve 16:18

service 16:20

16:24

setting 5:7

6:5 12:12
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 33

19:18

Several 10:3

short 6:7

18:4

shortly 5:16

shuffling

18:12

sits 8:14

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22:13

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9:19 9:22

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18:10

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18:21

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start 5:12

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15:18 16:11

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11:19

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status 14:3

stipulations

20:4 20:12

submission

5:9

suburb 7:22

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13:3 17:20

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5:15

suggestion

15:18

suggestions

14:9

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summary 12:13

13:1 13:5

13:24

14:1

17:10 19:15

22:6

Sunday 11:13

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19:10

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14:12 15:4

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T

table 7:4

talk 6:14

6:19 8:14

10:12 10:17

12:11 13:14

15:10 15:21

17:8 18:13

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22:11 22:20

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21:12 22:4

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8:12

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4:22

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6:20

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9:16 22:9

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11:10

15:2

21:25 22:21

22:24 22:25

23:1

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5:16

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19:9

20:19

21:8 22:9

Thursday

4:2 4:20

13:12

tighten 11:25

timeframe

16:14

timeline

18:14

today 4:20

5:11

20:20 21:16

22:1

22:20 22:22

tomorrow 22:3

transcript

21:5

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11:13 11:16

11:18 11:21

trial 5:14

5:15 6:2

6:4 6:8

6:12 6:15

6:17 7:4

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10:12 11:25

troubles 17:1

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Tuesday 13:11

tugging 20:9

turn 10:19

18:13

typically

12:15 15:14

16:1 16:18

U

understanding

8:1
F.A.A. vs Miami Tech Aircraft Maintenance, Inc. January 15, 2015 VR # 1820-1 Page 34

unless 16:1

usually 12:18

utilize 12:3

V

venue 9:9

versed 9:23

Vines 4:5 4:6

4:25 5:4

5:16 5:19

6:23 6:24

7:2 7:6

7:21 7:24

10:4 10:9

10:16 10:20

11:13 11:15

12:3 12:6

13:6 13:8

13:16 13:18

14:19 14:21

15:2 15:5

17:2 17:4

18:8

18:10 19:20

19:22 20:14

20:15 21:17

21:18 22:25

W

Washington's

11:9

ways 18:22

website 11:6

Wednesday

13:15

week 11:11

13:4 13:7

weekday 17:14

weeks 18:2

19:2

we'll 11:20

we're 4:18

5:24

12:25

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we've 22:4

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23:3

whether 19:1

wide 10:22

10:25

13:8 13:13

William 4:25

window 18:2

18:4 18:5

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wish 20:24

22:22 22:23

witness 12:22

15:22 16:12

16:13

17:9 17:17

witnesses

19:14 19:18

wondering

8:25

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14:17

18:7

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22:1

22:12 22:17

workday 11:16

works 18:17

21:11

written

20:4 20:12

Y

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yourselves

22:11

you've

15:11 15:22

20:25