U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF BEARINGS 

WASHINGTON, D.C. 

RECEIVED 

OCT 1 2 2016 

HEARING DOCKET 

In th~ matter of: 

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FAA DocketNo. FAA•20B-1086 

CaseNo. 201\S0\90\81 

PUERTO RICO POLICE DEPT. 

Judge J.E. Sulllvan 

Respondent 

JOINT PROPOSED SCHEDU,Yil 

Pursuant to the Judge's Order, (he parties hereby submit the folloWing proposed 

scheduling/discovery plan: 

October 13, 2016: Rule 16 Litigation Scheduling Couference 

October 25,2016: Deadline for Initial Disclosures 

- November l, 20\6: Oeneral Discovery Begins; parties may initiate written discovery; 

parties may issue Notices of Deposition 

December 8, 2016: Deadline. for initial expert disclosures 

J~nuary 15, 2017: Beginning ofdeposition period (expert or non-expert) 

'.,, '.' -,•- ' ' ,_ ' ' ' ·- ' ' 

Januar)' 31, 2017: Deadline to issue deposition notices and/o~ request subpoenador.• , 

third-party depositions 

March 2, 2017: End of deposition period (expett or non-expert) 

March 16, 2017: Deadline to issue written discovery requests; deadline for supplemental 

expert witness reports 

April 21, 2017: Deadline for responding to discovery; all discQvery responses due l)y this 

date; remaining discovery time to available only to resolve disputes on existing discovery 

May 23, 2017: Final Close of Discovery 

July 11, 2017: Dispositive Motion Deadline 

Angus~ 1, 2017: Deadline to Respond to Dispositive Motions 
- August 25, 2017: Deadline for Replies in Support of Dispositive Motions 

September 2017 (or other such date as may be suitable for the Judge's schedule): Motion 

Conference·on Dispositive Motions (to be converted to pre-hearing conference if no 

dispositive motions filed) 

January \7, 201 S: Deadline fur exchange of Witness .Lists and Exhibits 

January 31,2018: Deadline to file written stipulations aod/o.r motio.ns in liliiin~ 

February 2018 (or other .such time as may be suitahle for the Judge's schedule): Hearing 

Tile above-referenced schedule is based on the presumption that the hearing time frame listed 

will be available in the Judge's schedule, al)d that the Judge is unlikely to be available in 201.7. 

The time frames listed above can be extended if the Judge does not have a hearingavailabi!ity in 

early 2018, or reduced if the Judge has. at) earlier hearing availability . . )IV\ 

Respectfully submitted this L day of October, 2()16, 

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~" ~~ L~~"~"~-~-­ &7 -:~ ci;;;stopher R. Stevenson 

FAA Office of the Chief Counsel 

Bnforcement Division 

~,~ ~ulra an Soler 

PuertO Rico Po bee Department 

Office ofLegal Affairs 
CERTIFICATE OF SERVICE 

I hereby certify that a copy of the foregoing Joint Proposed Scheduling/Discovery Plan has been 

sent this date by the following methods: 

original and one copy via certified mail: 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2Wl 000 

Washington, D.C. 20591 

one copy via Federal Express and facsimile: 

Nazihra M. Abdulrahman Soler 

Office of Legal Affairs 

Puerto Rico Police Department 

P.O. Box 71200 

San Juan, PR 00936 

fax: (787) 781-7993 

Honorable Judge J.E. Sullivan 

Office of Hearings, M-20 

U.S. Department of Transportation 

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

Washington, DC 20590 

fax: (202) 366-7536 

~~ Program Analyst 

[[C!, k~ii6 2016~ 

Dated