U.S. DEPARTMENT OF TRANSPORTATION 

Office of Hearings 

Washington, D. C. RECEIVED 

JUL 2 5 2012 

The Liberty Foundation, Inc. HEARING DOCKET 

FAA DOCKET NO. CP *not yet assigned* 

(EIR 2011-GL-03-0070) 

(Civil Penalty Action) 

FDMS No. FAA-2012-0477 

The Honorable J. E. Sullivan, Administrative Law Judge 

RESPONDENT'S REPLY TO THE ADMINISTRATION'S OPPOSITION 

TO RESPONDENT'S SUGGESTION OF HEARING LOCATION 

At best, the FAA's basis for its opposition to having the hearing in the Atlanta, 

Georgia, area as requested by Respondent, is that the FAA has witnesses and lawyers 

located where it wants the hearing. The FAA does not challenge or dispute any of the 

reasons or facts supporting Respondent's request. 

As a matter of fairness, it is both harsh and heavy-handed for the FAA to suggest 

Respondent, a charitable foundation with very limited resources, should incur the 

expenses associated with the travel and housing of its witnesses and counsel, but to 

suggest the FAA, with its considerable resources, should be relieved of that burden. 

Between the two parties, the FAA is far better able to afford the cost burden of the case 

it has initiated. 

The FAA has not asserted it would be prejudiced in any way if the hearing is held 

in the Atlanta, Georgia area, whereas Respondent has stated it would be prejudiced by 

the costs associated with a hearing in the Chicago area. Nothing in Respondent's 

Suggestion is for the purpose of the FAA changing counsel. In fact, Respondent would 

STUART A. GOLDSTEIN, P. A. 

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

T: (305) 670-1222 F: (305} 670-7065 STIIARTGOI DSTE!NpACiilATTNEI 
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be shocked if the FAA changed counsel merely because its attorneys had to travel the 

approximate 500 miles (90 minute flight) from Chicago to Atlanta. 

Respectfully submitted, 

Stuart A. Goldstein, P. A. 

9350 South Dixie Highway, 10th Floor 

Miami, Florida 33156 

Tel: (305) 670-1222 

Fax: (305) 670-7065 

Email: stuartgoldsteinpa@att.net 

By:---1--U-l-l~~tL Stuart A. Goldstein J!p=--u~~- Attorney for The Liberty Foundation 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on the 18th day of July, 2012, this document was 

served on the persons/entities on the Service List below in the manner set forth thereon. 

By: lrffifffA 

Stuart A. Goldstein 

~~~ 

STUART A. GOLDSTEIN, P. A. 

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

T: (305) 670-1222 F: (305) 670-7065 SI\ IARTGOI DSTE!NpA®AIINET 
Original and One Copy to: 

Federal Aviation Administration 

600 Independence Avenue, S. W. 

Washington, D. C. 20591 

SERVICE LIST 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building, Suite 2W1000 

One Copy to: 

The Honorable J. E. Sullivan, Administrative Law Judge 

Office of Hearings, M-20 

U. S. Department of Transportation 

1200 New Jersey Avenue, S. E. (E11-310) 

Washington, D. C. 20590 

By Facsimile (202) 366-2132 

and regular U. S. Mail 

and 

Adrianne Wojcik, Esq. 

Office of the Regional Counsel 

Great Lakes Region, AGL-7 

Federal Aviation Administration 

2300 East Devon Avenue 

Des Plaines, IL 60018-4696 

By Facsimile (847) 294-7498 

and regular U. S. Mail 

STUART A. GOLDSTEIN, P. A. 

9350 SOUTH DIXIE HIGHWAY, 1OTH FLOOR, MIAMI, FL 33156 

T: (305) 670-1222 F: (305) 670-7065 SIIJARTGOI QSTEINPACWAUNFT 

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