U.S. DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS WASHINGTON, de
FEDERALAVIATION ADMINSTRATON ) ) ) ) ) ) ) ) Complainant, FELTS FIELDAVIATION Respondent.



### ~-----------------------) Docket No. FAA-2015-3307 Case No. 2015WP910090 Hon. J.E. Sullivan

JOINT PROPOSED SCHEDULING AND DISCOVERY PLAN Pursuant to the Court's Order of February 24, 2016, and Civ. 

### R. 26(f), Respondent's counsel, Mark J. Conlin, and FAA Counsel, Robert Spitzer, conferred on April 1, 2016. The parties, through their respective counsel, jointly proposeto the following scheduling and discoveryorderagreed upon bythe Parties.
In accordance with Civ. R. 26(f)(2), the parties have considered the nature and basis of their claims and defenses and the possibilities for promptly settling or resolving the case. Arrangements for the disclosures required by Rule 26(a)(1) will be outlined below. There are no issues about preserving discoverable information. The proposed discoveryplan is:
1. May 31, 2016- deadline for filing general discovery requests, including but not limited to: taking depositions; serving and answer requests for production of documents; interrogatories; requests foradmissions; etc.2. June 15, 2016 - Expert witness disclosures (for any expertwitness to be called at hearing), including the witness's resume or qualifications, and the witness's written report or statement of opinion (including disclosure of the basis of the opinion).
3. June30, 2016- Deadlinefor Completing General Discovery- On or before June 10, 2016, the parties shall finish responding and serving answers to all general requests pursuant to 14 CFR Section 13.220. This includes the taking of depositions, pursuantto 14 CFR Section 13.2200)-

4. July 31, 2016- Deadlines for Filing Dispositive Motions. The last date for both parties to file any/all pre-hearing dispositive motions, including Default Motions and/orSummaryJudgmentMotions.

a. August 15, 2016: Deadlineforfiling answersto dispositive motions. b. August31, 2016: Deadlineforfiling Reply. c. September 15, 2016: Oral argumenton dispositive motions.

5. September2, 2016- Exchange ofJist ofwitnesses and exhibits.

6. September 2, 2016 -Written Stipulations and/or agreed motions in Limine. On
or before September 30, 2016, the parties shall file any written stipulations that narrowthefactual or legal issues, and thatare agreed Motions in Limine.

27. February21, 2017- Hearing in Spokane, Washington.
In accordance with Civ. R. 26(f)(3)(A), the parties do not contemplate any changes to Civ. R. 26(a) otherthanthose indicated above.
In accordance with Civ. R. 26(f)(3)(B), discovery should be limited to subjects related to the issue at hand, the FAA's complaint. Discovery should be complete as indicated above.
In accordance with Civ. R. 26(f)(3)(C), Motions to Limit or Compel Discovery are discussed below. Electronically stored information should "saved" as appropriate and produced in a "searchable" format such as aword document (.doc) or a searchable .pdf document(.pdf).
1. Motion to Limit Discovery upon Receipt of Discovery upon Receipt of Discovery Request: A party served with a discovery request who seeks to limit discovery pursuant to 14 CFR Section 13.220(f)(g), and (h), shall file a Motion for relief within 10 days ofservice ofthe disputed discovery request.
2. Motion to Compel Discovery: A party seeking to compel discovery must file a Motion to Compel within 10 days of receipt ofservice of a deficient response or afterthe response to the discovery is due, whicheveroccursfirst.

3In accordance with Civ. R. 26(f)(3)(D), the parties do not anticipate and any issues about claims of privilege or of protection as trial-preparation materials. If issue arise, they will addressed with Motions to Limit or Compel Discovery. The parties do not request that this agreement be included in an order under Federal Rule of Evidence 502.
In accordance with Civ. R. 26(f)(3)(E), changes in the limitations on discovery imposed under these rules or by local rule are outlined above. No other limitations should be imposed.
In accordancewith Civ. R. 26(f)(3)(F), the partiesdo not requestthatthe court issue any otherorders under Rule 26(c) or under Rule 16(b) and (c). Respectfully submitted this4th dayofApril, 2016.

Conlin, Maloney

### &Miller 421 

### W_ Riverside Ave., Suite 911 Spokane, VVA 99201 Attorneyfor Respondent Felts Field Aviation, Inc. 14 East MainAve. Spokane, VVA 99201-0405 Respondent TelephonicallyApproved Robert Spitzer Northwest Mountain Region. ANM-7 FederalAviationAdministration 1601 Lind Ave., S.W Renton, VVA 98057 AttorneyforComplainant

4CERTIFICATE OF SERVICE I hereby certify that on this day copies ofthe foregoing Joint Proposed Scheduling and Discovery Plan were sentfirst class mail and fax asfollows: JudgeJ.E. Sullivan U.S. Administrative LawJudge Office ofHearings, M-20 U.S. DepartmentofTransportation 1200 NewJerseyAvenue, S.E. (E11-310) Washington, DC 20590 (Fax) 202-366-7536 Mr. Robert Spitzer Northwest Mountain Region, ANM-7 Federal Aviation Administration 1601 Lind Ave. S.W Renton, WA 98057 (Fax) 425-227-1007 I hereby certify that on this day copies of the foregoing Joint Proposed Scheduling and Discovery Plan were sentfirst class mail as follows: FederalAviation Administration ATTN: Hearing Docket Clerk, AGC-430 WilburWright Building- Suite2W1000 800 IndependenceAvenue S.W. Washington, DC 20591 Date: April4, 2016



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