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### BEFORE THE UNITED STATES DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATJON 

# HEAFUNG DOCKET
In the Matter ofLEARJET, INC. DocketNo. 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 ofthe discovery deadline f\·om July 7, 2014, to September 8, 2014, stating as follows: 1. Couru;el for Complainant does not objectto this extension. 2. Lemjet served its discovery requests on the Complainant on April24, 2014, to allow for sufficient time for review ofthe Complainant's responses in advance ofdepositions m1d to allow for service ofm1y follow-up discoverybefore the July 7, 2014 deadline. Pursuant to the Rules ofPractice in FAA Civil PenaltyActions, the latest possible datebywhich 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 ofthe 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 therequested docmnentation via certified mail on June 6, 2014, which Lemjet received on June 9, 2014. 4. To provide Learjet with adequate timeto review Complainm1t's discovery response prior to depositions in

### this matter, and to avoid the costs and burdens associated with L[mecessary discoverythat would result from serving additional discoverypriorto reviewing

501355173vl06/12/2014 14:52:02 (Eastern) From: Pillsbury Winthrop- 202.663.8007

Complainant's response, Leatjetrequests that the discovery deadline bepostponed, 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 inJune. One co-counsel for Learjct 

### is currentlyprepmingfor a trial to be held from JLme 

### 16- hme 

### 20, 2014 that will reqnire post-trial briefing. Learjet also faces a difficult schedule in June. 

### 6. A two-month extension will permitbothparties sufficient time to complete the discoveryrequired to prepare for thehearing in tl1is matter. WHEREFORE, Lemjetrespectfullyrequests thatthe 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-IAW PITTMANLLP 

### 2300 N Street, NW Washington, DC 

### 20037-1122 (202) 663-8898 Fax: (202) 663-8007 Counsel forLearjet, Inc. Page 4 of 506/12/2014 14:52:10 (Eastern> From: Pillsbury Winthrop- 202.663.8007



### CERTIFICATE OF SERVICE I hereby certifythatthe foregoing Motion has been sentvia 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 ofHearings, M-20 U.S. Department ofTransportation 1200 New JerseyAvenue, 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 certifythat the original Motion, and one copy**thereof~** was sent byU.S. First Class mail, Retum Receipt Requested and one copybyfacsimile 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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