' 02/17/201 1 G:48AM FAX 1^000 vy g I ( 

Michael Selig< MD, FACC, CFI-H 

2816 0refield Road 

Allentown, PA. 18]04 

^mRTMENTOF 

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U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON. D.C. 

Federal Aviation Adminlstrofion 

Laura Ponto, Latonya Willianns 

Complainants 

M & R Helicopters, LLC. 

Respondent 

Honorable Judge Ronnie Yoder 

Docket: 2010-1211 

MOTION FOR MORE DEFINITE STATEMENT 

TRAVEL LOG FOR LATONYA WILLIAMS 

AND NOW, comes respondent, MICHAEL B. SELIG, MD, FACC, 

principle for MR Helicopters, LLC, (MRH) (non-existent since 2007) whom files the 

following MOTION for More Definite Statement pertaining to Latonya Williams 

travel operations. 

1. Respondent has requested pre-trial meetings to be held in 

Allentown, PA, the place of original jurisdiction and for reasons given in other 

pleadings. 

2. Complainants stated that to conne to Allentown "would be a 

tremendous inconvenience and expense". 

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7. It was not a tremendous inconvenience and expense for Ms Williams 

to come to Allentown to initiate, find and impose a frivolous alleged civil 

penalty, impeding Dr Selia's patient time at his private cardiology practice for 

several hours, however now it is an inconvenience to appear to substantiate 

and defend several positions, under due process, in the place of Jurisdiction 

where the alleged civil penalty took place. 

3. The Federal Register (under the DOT) made public that the FAA has a 

$181 million dollar budget for 2011 travel, inclusive of enforcement activities. 

http://v^/ww.faa.qov/about/budqet/ 

http://www.dot.aov/budaet/2011 /budaetestimates/index.htm 

4. Ms Williams stated to the respondent that she "travels all over as part of 

her job" and also mentioned the reason she was delayed in some of the follow-up 

documentation, was because she was traveling. 

5. Ms Ponto stated in her pleading of December 29, 2010, that Ms Williams 

does not regulariy travel to Allentown, even though Ms Williams indeed did come 

to Allentown apparently from Miami, Florida, her place of residence to seek and 

impose the civil penalty. 

6. Ms Ponto stated in her document draft dated February 9, 2011, Certified 

Mgil signed received 2-14-2011, that was in response to the document, Motion for 

Travel Log for Latonya Williams, that this information is irrelevant. 

7. It is respondents averment that this is appropriately requested due to the 

circumstances, particularly relevant to the complainants avoidance of having Ms 

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02/17/201 1 G:48AM FAX ^ 

Williams return to the jurisdictional location where the inspection she conducted 

the investigation and where the alleged violation occurred. 

8. It is respondent's averment that this is appropriately requested and 

relevant since the complainants repetitiously evaded and circumvented the 

main reason for respondents request for the Allentown location, as stated in his 

letter of November 24, 2010, namely the respondent's primary role in the Lehigh 

Community as a solo, private practice cardiologist (for the lost 23 years) with 

hospital and outpatient responsibilities. To leave the area would pose undue 

hardship to his patients. It would be improper and unreasonable to burden and 

inconvenience neutral party patients and a physician for an alleged violation 

that he did not initiate, has caused no harm, and lacks legal merit, 

9. It is respondent's averment that the travel log history is appropriately 

requested and relevant since it addresses a robust budget that is available to 

Ms. Ponto's Department. It would be inappropriate, unreasonable, morally and 

ethically insensitive to compromise a physician's clinical responsibilities in his 

office or in the hospital in a manner that would delay and interrupt continuity of 

care or compromise patient care and potentially increase liabilities or risk to him 

or his patients in his role of providing emergent, acute and chronic public heath 

cardiac care services to the community. 

10. It is respondent's averment that the travel log history is appropriately 

requested and relevant because it demonstrates Ms Williams regular and 

frequent travel history, confirmatory to Ms. William's previous statements made 

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02/17/201 1 6:48AM FAX 

directly to respondent. 

11. The respondent, thereby requests, a definite statement as to why this 

logic is unreasonable, specifically addressing the irrelevancy of the travel log, 

since it appears that complainants are trying to impede respondent's 

cardiology practice and impose hardships on his patients by attempting to 

remove him from his cardiology practice location. 

12. Respondent merely requested, as should be made publicly available 

under the |gw, to provide her unaltered or redacted work and travel log for 2009 

and 2010, inclusive of work schedule and cities traveled to. 

WHEREFORE, the respondent prays that this Honorable Court will direct the 

complainants to make a more definite statement as to how this is not directly 

appropriate or reasonable. 

Respectfully Submitted, 

Michael B. Selig, MD, FACC. 

Date 

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