UNITED STATES OF AMERICA:

 IN THE UNITED STATES

 DEPARTMENT OF TRANSPORTATION

 OFFICE OF HEARINGS

FEDERAL AVIATION ADMINISTRATION,

 COMPLAINANT,

VS. CASE NO. FAA-2015-0203

ROMNEY CYCLE CENTER, INC.,

 RESPONDENT.

_____________________________________________________

 HEARING BEFORE

 THE HONORABLE J.E. SULLIVAN

 THURSDAY, JUNE 18, 2015

 1:31 P.M.

 HISTORIC JORDAN SPRINGS

 1160 JORDAN SPRINGS ROAD

 STEPHENSON, VIRGINIA 22656
IN THE MATTER OF ROMNEY CYCLE CENTER June 18, 2015 VR # 2407-1 Page 2

1 APPEARANCES

2 ON BEHALF OF THE COMPLAINANT,

3 FEDERAL AVIATION ADMINISTRATION:

4 RASHAWN RICH GEORGE, ESQUIRE

5 OFFICE OF THE REGIONAL COUNSEL

6 ASO-7, SOUTHERN REGION

7 1701 COLUMBIA AVENUE

8 COLLEGE PARK, GEORGIA 30337

9 TELEPHONE: 404.305.5200

10 FACSIMILE: 404.305.5223

11

12 ON BEHALF OF THE RESPONDENT,

13 ROMNEY CYCLE CENTER:

14 BRIAN W. STOLARZ, ESQUIRE

15 LECLAIR RYAN

16 2318 MILL ROAD, SUITE 1100

17 ALEXANDRIA, VIRGINIA 22314

18 TELEPHONE: 703.684.8007

19 FACSIMILE: 703.684-8075

20 EMAIL: BRIAN.STOLARZ@LECLAIRRYAN.COM

21

22

23

24

25
IN THE MATTER OF ROMNEY CYCLE CENTER June 18, 2015 VR # 2407-1 Page 3

1 HEARING

2 THURSDAY, JUNE 18, 2015

3 1:31 P.M.

4 THE COURT: We're on the record, in the

5 matter of Romney Cycle Center. This is Docket number

6 FAA-2015-0203. Today is Thursday, June 18, 2015, and

7 the parties have convened by telephone for a

8 litigation scheduling conference. The FAA is

9 represented by its attorney of record, Ms. Rashawn

10 Rich George. The respondent, Romney Cycle Center, is

11 represented by its attorney of record, Mr. Brian W.

12 Stolarz. Also present at the Office of Hearing

13 location is Mr. Spencer P. Williams, a law student

14 judicial intern, who is also sitting in as an observer

15 only. So good afternoon to you all. Folks, what I'm

16 going to do first and foremost, is just outline why

17 we're here. Essentially, as you all know, on April

18 15, 2015, an Order setting Rule 16, Litigation

19 Scheduling Conference and Directing Rule 26, Planning

20 and Submission was filed. On June 8, 2015, the

21 parties filed a joint proposed Rule 26F Scheduling and

22 Discovery Plan. And this conference follows, so that

23 we can talk about that joint plan, and set up the

24 litigation for this particular case.

25 I've had a chance to review the two-page
IN THE MATTER OF ROMNEY CYCLE CENTER June 18, 2015 VR # 2407-1 Page 4

1 document that you filed on June 8, 2015, and I do have

2 a couple questions. But I think our conference is

3 probably going to go pretty quickly. Just in terms of

4 the initial disclosures and the initial discovery

5 request, I wanted to check in with you. There's a

6 difference between initial disclosures under Rule 26A,

7 and general discovery. And so it looked to me, as

8 though you might have been talking about starting

9 general discovery, on or before July 16, 2015. And I

10 wasn't sure about that. So I'm going to talk to Ms.

11 George first, since she's the prosecuting agency, and

12 then I'll turn to the Respondent's attorney.

13 Ms. George, can you tell me a little bit

14 about the July 16, July 31 dates, that you proposed on

15 page one of your two-page plan?

16 MS. GEORGE: Yes, Your Honor, the initial

17 disclosures as I understood them, would be disclosures

18 by the parties and individuals, who were potential

19 witnesses, documents that we had under Rule 26(a)(1).

20 The discovery ... my understanding would be that that

21 would be our interrogatories, document requests for

22 production, and our ... I'm sorry. It's been a long

23 day. Our submissions ...

24 THE COURT: Okay, a general discovery.

25 MS. GEORGE: Yes.
IN THE MATTER OF ROMNEY CYCLE CENTER June 18, 2015 VR # 2407-1 Page 5

1 THE COURT: The reason I ask is because it

2 appeared to me that there's too short of a time. And

3 I say that because I look at paragraph four, on page

4 one, and it says that you're going to start

5 essentially your general discovery request on or

6 before July 31, 2015, and then have exactly 30 days to

7 respond. And within that period of time, essentially

8 seven days after July 31, 2015, you're going to

9 mutually disclose expert witnesses, and then one week

10 later, have your experts' rebuttal reports exchanged,

11 as well as any follow-up discovery, prior to that

12 time, or in the middle of that time. And it may be

13 that you both are super lawyers and this will be easy

14 for you to do. But if it were me, and I was trying

15 more than one case, I would find this quite daunting.

16 So I wanted to check in with you about that,

17 particularly because I won't be able to accommodate

18 your request for a November 16, 2015, hearing.

19 Currently, I am scheduling hearings in late June and

20 early July of 2016. So the push to get everything

21 done before November, isn't necessary.

22 MS. GEORGE: Okay.

23 THE COURT: So if that's the case, and the

24 parties don't feel the need to do this really fast,

25 I'm going to suggest that we flush out or push out
IN THE MATTER OF ROMNEY CYCLE CENTER June 18, 2015 VR # 2407-1 Page 6

1 some of these dates, to give you a little bit more of

2 a comfort zone. Now we don't have to do that. We can

3 talk about getting everything done right away, so it

4 frees you up for other cases. It's up to the two of

5 you. But I'm just telling you that if you do that,

6 then you're going to be hurrying up, only to wait.

7 Because we're not going to be scheduling this before

8 mid-to-late June of 2016.

9 MR.STOLARZ: Thank you, Your Honor, this is

10 Brian Stolarz. I have no problem with spacing out the

11 time. Honestly, as we all have other matters, I will

12 defer to the Court. And because of the scheduling

13 issues that you've noted about the date, makes

14 complete sense to space out the discovery. So I'm

15 fine with that, if that's fine with the government.

16 THE COURT: Ms. George, what's your position

17 on that?

18 MS. GEORGE: No objection to changing the

19 time as well.

20 THE COURT: Then let's talk a little bit,

21 first and foremost, about how much time you're going

22 to need for the hearing. I want to just double-check

23 with you about that. Currently, on page two of your

24 two-page document, you indicate in paragraph nine,

25 that it's going to take approximately two days. And
IN THE MATTER OF ROMNEY CYCLE CENTER June 18, 2015 VR # 2407-1 Page 7

1 I'm happy to just schedule a two-day trial, if you're

2 both comfortable that you have plenty of time within

3 that framework to get all your witnesses, all your

4 arguments, and any motions in limine and so forth,

5 taken care of within that time. So starting with you,

6 Ms. George, is two days plenty of time?

7 MS. GEORGE: I believe so, Your Honor, yes.

8 THE COURT: And Mr. Stolarz?

9 MR.STOLARZ: Yes, I believe two days will be

10 sufficient, Your Honor. Thank you.

11 THE COURT: Then let's look first and

12 foremost at a potential hearing date in Washington,

13 D.C., for a two-day period of time. Then I'm going to

14 backtrack, and I'll make some suggestions to you both,

15 about how to set this up, so that you slowly and

16 comfortably drive into the first day of the hearing.

17 So I'm going to take a look at my 2016 calendar, and

18 I'll ask both of you to do the same. We're going to

19 be looking around May and June. What do I have here?

20 I have the week of May 15th through May 21 open.

21 Would that work for either of you? Ms. George?

22 MS. GEORGE: At this time, I don't have

23 anything scheduled for that time.

24 THE COURT: Okay, and Mr. Stolarz, how about

25 you?
IN THE MATTER OF ROMNEY CYCLE CENTER June 18, 2015 VR # 2407-1 Page 8

1 MR.STOLARZ: Both of those weeks are fine,

2 so I defer to the Court's calendar.

3 THE COURT: Why don't we do this? Why don't

4 we plan on the week of May 16th. Do either of you

5 have a preference for starting on either Tuesday or

6 Wednesday? Ms. George?

7 MS. GEORGE: I would prefer a Tuesday, Your

8 Honor.

9 THE COURT: I'm sorry. I didn't hear you.

10 MS. GEORGE: I would prefer Tuesday, May

11 17th.

12 THE COURT: Okay. A Tuesday, Wednesday time

13 period. Ms. George?

14 MS. GEORGE: Yes, Your Honor, I'm sorry. It

15 appears that my phone is acting up.

16 THE COURT: Mr. Stolarz, how about you?

17 Does that work for you as well?

18 MR.STOLARZ: Yes, Your Honor, I defer to Ms.

19 George, since she will be the one traveling to the

20 hearing. So whatever accommodates her schedule is

21 fine by me, because I'm local to D.C.

22 THE COURT: Then what we'll do, is we'll set

23 this matter for Tuesday, May 17, 2016, and Wednesday,

24 May 18, 2016, for a hearing in Washington, D.C. And

25 we'll utilize May 16, which is a Monday, and May 19,
IN THE MATTER OF ROMNEY CYCLE CENTER June 18, 2015 VR # 2407-1 Page 9

1 which is a Thursday, as travel days for anyone who

2 needs to come in from out of town.

3 So let's then talk a little bit about how to

4 push your current schedule out, so that it fits more

5 comfortably within that envelope of time. And I'm

6 going to look at my calendar, and as I do, I'm going

7 to suggest some dates to you. If you'd be so kind as

8 to just jot them down. And then we can look at them

9 as a whole. That would be great. With a May 2016

10 hearing date, it would seem to me to have perhaps this

11 type of schedule. We could keep July 16, 2015, as the

12 deadline for initial disclosures, as you have

13 indicated. We could also have July 20th, which is the

14 Monday following, for the beginning of the general

15 discovery, where you initiate on or before July 20th,

16 2015. You could then have August 7th, if you want,

17 for either mutually exchanged expert witness

18 disclosures, or we could set this up, so that the FAA

19 disclosure is first, the Respondent discloses, and

20 then you both have a time to talk to your experts and

21 get expert rebuttals back. If we did that, and I'm

22 just going to suggest a couple dates, you could have

23 the FAA disclose on August 7th, the Respondent

24 disclose on August 21. You could have expert rebuttal

25 disclosed on or before, say September 11th. At that
IN THE MATTER OF ROMNEY CYCLE CENTER June 18, 2015 VR # 2407-1 Page 10

1 point, you're still in your general discovery phase.

2 You could disclose general discovery say

3 around early November. And I'm just going to pick a

4 date out of a hat, say November 13, 2015, which is

5 shortly before Thanksgiving. Dispositive motions

6 could be filed after that, let's say filing a

7 dispositive motion ... all dispositive motions filed

8 no later than December 4, 2015. Answers due probably

9 early January, say January 8th, 2016. That way you

10 can file the motions before all the holidays start,

11 and then respond to the motions after the holidays are

12 over. Let's say a filing of reply is January 22,

13 2016. We'd need to set up a telephone motion

14 conference, and I would suggest ... I'm going to take

15 a look at my February calendar. Say the first week of

16 February. Let's just say February 4, 2016, sometime

17 during that day. And then when I give myself enough

18 time to issue any kind of summary judgment decision,

19 before you have to file any kind of list of witnesses

20 or exchange Exhibits, because as you know, summary

21 judgment motion prevails, even in part can change how

22 the parties try the case. So assuming someone is

23 successful in their summary judgment, not completely,

24 but partially, you want to get that decision before

25 you start creating a book of Exhibits. So how about
IN THE MATTER OF ROMNEY CYCLE CENTER June 18, 2015 VR # 2407-1 Page 11

1 the last week of March, or perhaps the first week of

2 April for the exchange of Exhibits and list of

3 witnesses, for any kind of motions in limine, and that

4 puts you right into a mid-May 2016 trial.

5 I know I went through that fairly quickly,

6 but Ms. George, what are your thoughts about that?

7 Did anything strike you as being a little too short,

8 or a little too long in nature?

9 MS. GEORGE: Your Honor, I don't have any

10 objections to any of the proposed dates. I did have a

11 question about the date for the exchange of witnesses

12 and Exhibits.

13 THE COURT: Please feel free to ask it now.

14 MS. GEORGE: My question is ... I think when

15 you were speaking, you said it could be in early April

16 or in ... excuse me, in late April or early May, but

17 we didn't have a definitive date, so we would just

18 decide what date?

19 THE COURT: We would talk about it now. I'm

20 just kind of giving you an idea of what I think might

21 work, that would be comfortable for you.

22 MS. GEORGE: I like the framework. I do.

23 THE COURT: The date could be either late

24 March 2016 or early April 2016. And just so that we

25 have a date and time, let's just April 8th for a
IN THE MATTER OF ROMNEY CYCLE CENTER June 18, 2015 VR # 2407-1 Page 12

1 working date for the time being. Mr. Stolarz, what's

2 your perception of this? Any comment, any concern,

3 any suggested changes?

4 MR.STOLARZ: Your Honor, I have no questions

5 or concerns about this. It looks like you have done a

6 great job in mapping out the calendar. I have jotted

7 down the dates as you were going, and they look like

8 they make intuitive sense and calendar sense, so I'm

9 fine to proceed with how you've laid it out.

10 THE COURT: Okay. Well then let's just

11 double-check and make sure that we have firm dates

12 before we close. As I understand it from the parties,

13 it would be July 16, 2015, for a deadline for

14 exchanging initial voluntary disclosures. You would

15 start general discovery shortly thereafter, on or

16 before July 20, 2015. General discovery would

17 continue until approximately November 13, 2015.

18 Within that general discovery time on August 7, 2015,

19 the FAA would disclose its experts. On August 21,

20 2015, the Respondent would disclose its experts. And

21 on September 11, 2015, the parties would exchange

22 expert rebuttal reports. And you can do it ahead of

23 time. These are simply the deadlines for the

24 discovery process.

25 I've jotted down December 4, 2015, for the
IN THE MATTER OF ROMNEY CYCLE CENTER June 18, 2015 VR # 2407-1 Page 13

1 deadline for filing dispositive motions. Answer date

2 for response to such motions would be January 8, 2016,

3 with reply due on or before January 22, 2016.

4 Let's talk about scheduling a motion

5 conference. I'm looking at my first week of February,

6 which is the week starting with Monday, February 1,

7 running to Friday, February 5. Ms. George, I don't

8 know if we talked about this. We may have. But do

9 you have any preferred date or time within that

10 particular week that works well for you?

11 MS. GEORGE: I only have two conflicts that

12 week. On February 2nd, at 10 o'clock, from 10 to 11,

13 I have a conflict. And on February 3rd, from 1 to 2

14 p.m., I have a conflict. Other than that, I am open.

15 THE COURT: Okay, Mr. Stolarz, same question

16 to you.

17 MR.STOLARZ: Yes, Your Honor, I've just

18 reviewed my calendar, as you were mentioning those

19 dates. I am free for those dates at this time.

20 THE COURT: Would Thursday, February 4,

21 work? And Ms. George, I apologize if I'm dovetailing

22 into one of your conflicts. If so, stop me right now.

23 MS. GEORGE: No, the conflict was on

24 Wednesday the 3rd.

25 THE COURT: Okay.
IN THE MATTER OF ROMNEY CYCLE CENTER June 18, 2015 VR # 2407-1 Page 14

1 MS. GEORGE: February 4th is clear, thank

2 you.

3 THE COURT: How about February 4, 2016 from

4 10:30 to noon, eastern time?

5 MS. GEORGE: And I am clear.

6 THE COURT: I'm going to ask the parties to

7 make sure that you get that calendar now. If you

8 don't file dispositive motions, we'll still hold that

9 conference, but it will be automatically converted to

10 a prehearing status conference, so that we can get

11 together at least once before the hearing, and check

12 in and find out what the status of the case is, and if

13 there are any matters or concerns that need to be

14 addressed. I have April 8, 2016, as the exchange of

15 Exhibits and witness lists. That's the same date,

16 April 8, 2016, for filing any written stipulations or

17 agreed motions in limine, and then that takes us right

18 into the week of May 16, 2016, with a hearing date

19 beginning on Tuesday, May 17, 2016, and concluding at

20 the end of the day on Wednesday, May 18, 2016.

21 And just so that you know, in case you

22 don't, I usually start the hearing at 9, to conclude

23 by 5. I take a lunch break, typically as close as I

24 can to a break in a witness' testimony, somewhere

25 between 11:30 and noon, and the break is usually an
IN THE MATTER OF ROMNEY CYCLE CENTER June 18, 2015 VR # 2407-1 Page 15

1 hour and 15 minutes, so that people can actually leave

2 the courthouse and go somewhere to grab some

3 sustenance. We'll also take a very brief break in the

4 morning, and then again, another break in the

5 afternoon, just so that everybody can stretch and make

6 a phone call, or do whatever else they need to do.

7 I should also mention, and you probably know

8 this already, I will send out an order setting

9 litigation dates and procedures that codify in

10 writing, all of these dates that we've talked about

11 briefly. This particular order will also talk about

12 how to mark Exhibits, how to withdraw, if Mr. Stolarz,

13 for some unknown reason in the future, you need to

14 leave the case, there will be instructions on how to

15 do it, and do it well. There will be information

16 about filing Exhibits with the hearing docket, and

17 also, I think most importantly, how to schedule any

18 other motions or conferences on my calendar, between

19 now and the trial date, if you need to. So this would

20 be on page four, paragraph D. Essentially, what you

21 want to do, is contact your friend across the aisle,

22 get some mutually agreed dates that you can propose to

23 the Court, and then call my office and talk to the

24 attorney advisor, who is assigned to this case. His

25 name is Mr. Smith. You may have talked to him
IN THE MATTER OF ROMNEY CYCLE CENTER June 18, 2015 VR # 2407-1 Page 16

1 briefly, earlier today, when you called into the

2 conference. He has access to my calendar. He can

3 give you information immediately about which of your

4 dates would work. He can reserve that time on my

5 calendar, and that way you get that scheduled on my

6 calendar, and you can file the motions or request for

7 relief immediately thereafter, knowing that you've got

8 that time slot reserved. So with that, Ms. George, is

9 there anything else that we can address on behalf of

10 your client today, or any matters that need to be

11 raised?

12 MS. GEORGE: No, Your Honor.

13 THE COURT: Okay, Mr. Stolarz, same question

14 to you, sir.

15 MR.STOLARZ: No, Your Honor, very thorough.

16 Thank you.

17 THE COURT: Then I'm going to thank you both

18 very much for your help in this matter today. I wish

19 you good luck in your discovery exchanges. I'll be

20 sending out this litigation order probably tomorrow

21 morning at the latest. With that, we can go off the

22 record.

23 (WHEREUPON, the hearing was concluded at 1:55 p.m.)

24

25
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1 STIPULATION

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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, Andrea F. Mikus, 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 

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Court Reporter

SIGNATURE AND DELIVERY OF CERTIFIED TRANSCRIPT

 signed and securely delivered through our encryption

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IN WITNESS HEREOF, I have here unto set my hand 

 this day of , .

Andrea F. Mikus

25th June 2015
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