06/12/2014 14:51 :49 (Eastern) From: Pillsbury Winthrop- 202.663.8007 Page 3 of 5 

BEFORE THE UNITED STATES 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRA TJON 

HEAFUNG DOCKET 

In the Matter 

ofLEARJET, 

INC. 

Docket No. FAA-2014-0113 

FAA Case No. 2012CE430011 

The Honorable Richard C. Goodwin 

LEARJET, INC.'S UNOPPOSED MOTION TO EXTEND DISCOVERY 

DEADLINE 

Pursuant to 14 C.F .R. §§ 13.213, 13.218 and the Procedural Order in this matter, 

Respondent Learjet, Inc., by co1msel, respectfully moves the Administrative Law Judge for an 

extension of the discovery deadline f\·om July 7, 2014, to September 8, 2014, stating as follows: 

1. Couru;el for Complainant does not object to this extension. 

2. Lemjet served its discovery requests on the Complainant on April24, 2014, to 

allow for sufficient time for review of the Complainant's responses in advance of depositions 

m1d to allow for service of m1y follow-up discovery before the July 7, 2014 deadline. Pursuant to 

the Rules of Practice in FAA Civil Penalty Actions, the latest possible date by which the 

Complainant had to respond to Learjet's discovery was June 2, 2014. 

3. On June 2, 2014, counsel for the Complainant informed cotmsel for Learjet, in 

response to an inquiry as to the status of the discovery responses, that Lcarjet could expect a 

response within seven days. Counsel for the Complainant served his written responses via email 

on JLme 5, 2014, and served the requested docmnentation via certified mail on June 6, 2014, 

which Lemjet received on June 9, 2014. 

4. To provide Learjet with adequate time to review Complainm1t's discovery 

response prior to depositions in this matter, and to avoid the costs and burdens associated with 

L[mecessary discovery that would result from serving additional discovery prior to reviewing 

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06/12/2014 14:52:02 (Eastern) From: Pillsbury Winthrop- 202.663.8007 

Complainant's response, Leatjet requests that the discovery deadline be postponed, as set forth 

below. 

5. In addition, lead counsel for Leat"jet is not only facing a rigorous work schedule 

this summer, but also has been asked to facilitate a retreat for the ICAO CoLmcil and pal'ticipate 

in the ALP aJJ.d then EASA-FAA safety gatherings in June. One co-counsel for Learjct is 

currently prepming for a trial to be held from JLme 16- hme 20, 2014 that will req nire post-trial 

briefing. Learj et also faces a difficult schedule in June. 

6. A two-month extension will permit both parties sufficient time to complete the 

discovery required to prepare for the hearing in tl1is matter. 

WHEREFORE, Lemj et respectfully requests that the discovery deadline be extended 

from July 7, 2014, to September 8, 20'1 4. 

Dated: hme 12, 2014 

2 

501355173vl 

By: J~, • ~-~:£__~)~ K~P~~uinn 1 

PILLSBURY \VINTHROP SI-IA W 

PITTMANLLP 

2300 N Street, NW 

Washington, DC 20037-1122 

(202) 663-8898 

Fax: (202) 663-8007 

Counsel for Learjet, Inc. 

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06/12/2014 14:52:10 (Eastern> From: Pillsbury Winthrop- 202.663.8007 

CERTIFICATE OF SERVICE 

I hereby certify that the foregoing Motion has been sent via facsimile and U.S. First Class mail, 

Return Receipt Requested to the following recipients: 

The Honorable Richard C. Goodwin 

U.S. Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

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

Washington, DC 20590 

Attn: Patricia Matthews 

FAX: 202-366-7536 

David Kesslcr 

Federal Aviation Administration 

901 Locust Street, Room 506 

Kansas City, MO 64106 

(816) 329-3763; Fax (816) 329-3771 

Counsel for Complainant 

I fmther certify that the original Motion, and one copy thereof~ was sent by U.S. First Class mail, 

Retum Receipt Requested and one copy by facsimile to the following recipient: 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Attention: Hearing Docket Clerlc, AGC-430 

Wilbur Wright Building, Suite 2W1000 

FAX: 202-493-5142 

Dated this 12th day ofJune, 2014 

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