UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

IN THE MATTER OF: 

PUERTO RICO POLICE 

DEPARTMENT, 

FDMS Nos. 

FAA-2013-1086 

Respondent. 

Wednesday, 

Jul 23 2014 

The teleconference 

pursuant to notice, at 10:00 a.m. 

BEFORE: 

THE HONORABLE J.E. SULLIVAN, 

Administrative Law Judge 

convened, 

1 

RECEIVED 

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HEARING DOCKET 

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APPEARANCES: 

On Behalf of the Complainant: 

CHRISTOPHER H. STEVENSON, ESQ. 

of: Federal Aviation Administration 

Office of Regional Counsel, AS0-7 

Southern Region 

P.O. Box 20636 

Atlanta, GA 30320 

(404) 305-5200 

( 4 04) 3 05-5223 (fax) 

On Behalf of the Respondent: 

NAZIHRAM. ABDULRAHMAN-SOLER, ESQ. 

BETMAR LOPEZ, ESQ. 

Office of Legal Affairs 

P.O. Box 70166 

San Juan, P.R. 00936-8166 

(787) 793-1234 ext. 3067 

Also Present: 

Cody L. Smith, Office of Hearings 

Irene Nemesio, Intern 

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1 P-R-0-C-E-E-D-I-N-G-S 

2 10:08 a.m. 

3 ADMIN. JUDGE SULLIVAN: Okay, 

4 we're on the record in the matter of the FAA 

5 versus Puerto Rico Police Department. This is 

6 Docket Number FAA-2013-01086. 

7 Today is Wednesday, July 23, 2014. 

8 And the parties have appeared by telephone 

10 Scheduling Conference. 

11 The Federal Aviation 

12 Administration, which I'll hereinafter refer 

13 to as the FAA, is represented by its attorney 

14 of record Mr. Christopher R. Stevenson. The 

15 Respondent, Puerto Rico Police Department, is 

16 represented by its lead attorney, Ms. Nazihra 

17 M. Abdulrahman-Soler. Alsoappearingwithher 

18 is her co-counsel, Ms. Betmar Lopez. 

19 In addition appearing at the 

20 Office of Hearings as an observer only, is Ms. 

21 Irene Nemesio, a law student intern with this 

22 office. 

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1 Good morning everybody. Folks we 

2 have a couple of procedural matters to deal 

3 with. And I'll just basically identify what's 

4 happened so far in the litigation. On June 

5 23, 2014, an Order continuir:g the Rule 16 

6 Litigations Scheduling Conference was filed. 

7 On July 16, 2014, the FAA on 

8 behalf of both parties, filed a jointly 

9 

10 2014, the FAA filed a Motion to Deem Admitted, 

11 asserting that the Respondent had failed to 

12 file a timely Answer to the FAA's March 19, 

13 2014 Complaint. 

14 I'll note that this morning, Ms. 

15 Nemesio brought into me a multi-page document 

16 that the Respondent had emailed to her, that's 

17 entitled Answer to the Complaint and/or Motion 

18 to Dismiss and Opposition to Motion to Deem 

19 Admitted. I'll note first and foremost that 

20 this office does not have email filing. 

21 So I certainly have this document 

22 in front of me, but it has not been properly 

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1 filed with this office. The document 

2 indicates that there was a fax service, or 

3 filing with this office yesterday on July 22, 

4 2014, and that actually did not occur. The 

5 document also states under the Certificate of 

6 Service that it was mailed by certified mail 

7 this morning. 

8 So I need to clear up a little 

9 snafu about the method of service u on thi 

10 office. And I will do that right now. 

11 Ms. Abdulrahman-Soler, we do not 

12 have email filings with this office. So this 

13 document, although it is in my hands, has not 

14 been properly filed. 

15 I will accept it for today, but I 

16 will tell you that we do not accept email 

17 filings. And so filing something or sending 

18 something by email to one of my staff members, 

19 is not an acceptable way of filing. 

20 Ms. Nemesio had advised me that 

21 you were having some trouble trying to fax 

22 something to our office yesterday, is that 

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1 correct? 

2 MS. ABDULRAHMAN-SOLER: Yes, 

3 that's correct. 

4 ADMIN. JUDGE SULLIVAN: Okay. 

5 What kind of trouble were you having? 

6 MS. ABDULRAHMAN-SOLER: Well, we 

7 are sending the fax to the number 202-366-

8 2131, three times yesterday and one time today 

9 in mornin And 

10 for that reason we send a motion and send it 

11 by email today. 

12 ADMIN. JUDGE SULLIVAN: Well, 

13 first of all that's not our fax number, which 

14 is possibly why it wasn't coming through. 

15 MS. ABDULRAHMAN-SOLER: Okay, can 

16 -- can we have the right number of fax? 

17 ADMIN. JUDGE SULLIVAN: Sure. If 

18 you look at the Order that I have sent out to 

19 you, the fax number for our office and for me 

20 is identified clearly under my name. Do you 

21 have for example the Order Continuing Rule 16 

22 Litigation Scheduling Conference before you? 

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1 MS. ABDULRAHMAN-SOLER: Urn-hum. 

2 ADMIN. JUDGE SULLIVAN: When you 

3 say Urn-hum, does that mean yes? 

4 MS. ABDULRAHMAN-SOLER: Yes. The 

5 Order of Continuing as sent to us on the date 

6 I think in June, I don't see a date. But I 

7 have the number and I called today is 202-493-

8 2343 and then the number three. 

9 We have anoth r 

10 clarification in order our question with 

11 regard to the procedures to be followed in 

12 this case. And the number is 202-366-6941. 

13 ADMIN. JUDGE SULLIVAN: Okay. 

14 Let's start again. Do you have a copy of the 

15 Order Continuing Rule 16 Litigation Scheduling 

16 

17 MS. ABDULRAHMAN-SOLER: Yes. 

18 ADMIN. JUDGE SULLIVAN: Conference 

19 before you? 

20 MS. ABDULRAHMAN-SOLER: Yes, yes. 

21 ADMIN. JUDGE SULLIVAN: Okay. I 

22 want you to look at the third page of that 

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1 Order, which is the service list. 

2 MS. ABDULRAHMAN-SOLER: 202-366-

3 7536 is the fax. 

4 ADMIN. JUDGE SULLIVAN: Are you 

5 looking at the third page of the three page 

6 Order that I just referred to you? 

7 MS. ABDULRAHMAN-SOLER: Yes, Your 

8 Honor. 

10 now want you to look at the bottom of the page 

11 where it starts with my name, Judge J.E. 

12 Sullivan. Do you see that section? 

13 MS. ABDULRAHMAN-SOLER: Yes. 

14 ADMIN. JUDGE SULLIVAN: Good. 

15 Under my name there is a fax number. Do you 

16 see that fax number? 

17 MS. ABDULRAHMAN-SOLER: Yes. 

18 ADMIN. JUDGE SULLIVAN: That fax 

19 number is the number that you need to use to 

20 fax things to me and to my office. 

21 MS. ABDULRAHMAN-SOLER: Okay, they 

22 have it. 

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1 ADMIN. JUDGE SULLIVAN: That 

2 number is 202-366-7536. That is our official 

3 fax number. And it's the only one you should 

4 be using. Now if you look at page two of that 

5 three page Order. 

6 MS. ABDULRAHMAN-SOLER: Okay. 

7 ADMIN. JUDGE SULLIVAN: Paragraph 

8 three. 

9 

10 ADMIN. JUDGE SULLIVAN: Yes? 

11 MS. ABDULRAHMAN-SOLER: Yes. 

12 ADMIN. JUDGE SULLIVAN: Okay, 

13 thank you. That particular paragraph 

14 identifies Mr. Smith by name. He is the 

15 attorney that works with me on these cases. 

16 The number that you see associated 

17 with his name on page two, paragraph three of 

18 the June 23, 2014 Order, is his telephone 

19 number. It is not a fax number. 

20 MS. ABDULRAH~-SOLER: It's 

21 perfect, I get it. 

22 ADMIN. JUDGE SULLIVAN: Okay. So 

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1 in the future when you are trying to fax 

2 documents to this office, you fax them to the 

3 number that's provided under my name, which I 

4 showed you. And then if you have problems 

5 faxing anything to the office, you can call 

6 Mr. Smith for assistance. And that should 

7 clear up any future problem. 

8 MS. ABDULRAHMAN-SOLER: Okay, 

9 

10 ADMIN. JUDGE SULLIVAN: You're 

11 welcome. All right, let's talk with Mr. 

12 Stevenson briefly. Have you received a copy 

13 of the Respondent's Answer to the Complaint 

14 and Opposition to your Motion that this Court 

15 received today by email? 

16 MR. STEVENSON: Yes Your Honor, we 

17 received a facsimile copy last night. So I 

18 saw it this morning. 

19 ADMIN. JUDGE SULLIVAN: Okay, 

20 thank you. Folks what we need to do then is 

21 set up a reply time for the FAA, and we also 

22 need to talk a little bit about -- about good 

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1 cause. 

2 And it may be that I need to set 

3 up an additional response time for the 

4 Respondent as well. Let me ask a second 

5 question to you, excuse me, Ms. Abdulrahman6 Soler. 

7 In your service list and in your 

8 materials that you submitted to Ms. Nemesio 

9 this mornin ou identif ourself and Ms. 

10 Lopez as legal advisors. Does that mean that 

11 you're both attorneys? 

12 MS. ABDULRAHMAN-SOLER: Yes. 

13 ADMIN. JUDGE SULLIVAN: Okay. Is 

14 there some reason that you're not identifying 

15 yourself as attorneys? Is this a practice 

16 issue or a preference where you practice? 

17 (No Response.) 

18 ADMIN. JUDGE SULLIVAN: Ms. 

19 Abdualrahman-Soler, did you hear the question? 

20 MS. ABDULRAHMAN- S~ER: Can you 

21 repeat the question please? 

22 ADMIN. JUDGE SULLIVAN: Is there 

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1 some reason why you have not identified 

2 yourself as an attorney, and instead listing 

3 -- because you've listed yourself as a legal 

4 advisor. And so I'm wondering why you have 

5 not identified yourself as an attorney? Is 

6 there some reason for that? 

7 MS. ABDULRAHMAN-SOLER: No, no. 

8 No reason. 

9 ADMIN. JUDGE 

10 normally list yourself as a legal advisor when 

11 you're appearing as an attorney representative 

12 in Puerto Rico? 

13 MS. ABDULRAHMAN-SOLER: Yes. 

14 ADMIN. JUDGE SULLIVAN: Okay. Are 

15 you currently licensed as an attorney? 

16 MS. ABDULRAHMAN-SOLER: Yes. 

17 ADMIN. JUDGE SULLIVAN: Okay. And 

18 is Ms. Lopez also licensed as an attorney? 

19 MS. ABDULRAHMAN-SOLER: Yes. 

20 ADMIN. JUDGE SULLIVAN: Okay. Are 

21 you working within the Puerto Rico Police 

22 Department, is that why you use the title of 

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1 legal advisor instead of attorney? 

2 MS. ABDULRAHMAN-SOLER: Yes. 

3 ADMIN. JUDGE SULLIVAN: Okay. 

4 That's helpful. What I'm going to ask you to 

5 do in the future is simply to put the word 

6 attorney/legal advisor below your name for 

7 purposes of this litigation. 

8 MS. ABDULRAHMAN-SOLER: Okay. 

9 ADMIN. JUDGE SULLIVAN: Th 

10 I ask you to do that is because there are 

11 people who call themselves legal advisors that 

12 are not attorneys. And I need to know for 

13 purposes of your case, where you fall. 

14 And if you're an attorney, that 

15 means that I don't have to explain lots of 

16 things to you. It's presumed that you're 

17 going to know certain things because of your 

18 legal education and background. 

19 Now that doesn't mean you can't 

20 always ask me questions. You're welcome to 

21 ask questions at any time. But this way we 

22 have a record that you are of counsel as 

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1 opposed to simply a lay representative giving 

2 some advice. 

3 Okay, so in terms of your 

4 Response, in these types of cases, when you 

5 fail to comply with the regulatory time period 

6 for filing an Answer, you are subject to 

7 potential dismissal of your request for 

8 hearing. Unless you do certain things, such 

9 as file an Answ 

10 what good cause factors prevented you from 

11 filing a timely Answer. 

12 You have to make a showing of good 

13 cause to be allowed to go forward. On page 

14 three of your four-page Answer that you filed 

15 this morning by email with Ms. Nemesio, you 

16 have a very short paragraph at the bottom of 

17 page three entitled Opposition to Motion to 

18 Deem Admitted. 

19 And in this paragraph you say that 

20 the Motion is not filed with the intention of 

21 delaying the administrative proceeding, but 

22 "because responsibly was not possible to file 

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1 an Answer to Complaint until Respondent 

2 finished its internal adjudicative procedures 

3 against the concerning parties." Now I think 

4 you need to expand a little bit about that 

5 because I'm not quite sure what that means. 

6 MS. ABDULRAHMAN-SOLER: Okay. 

7 ADMIN. JUDGE SULLIVAN: And so I'm 

8 going to give you a deadline for filing a Good 

10 different way of saying that. 

11 You obviously have filed a Motion 

12 or an opposition to Mr. Stevenson's Motion, 

13 and you've filed an Answer to the Complaint. 

14 It does not appear that you were aware of your 

15 requirement to address good cause factors. 

16 So I'm going to give you a chance 

17 to do that. There are many different 

18 decisions that the FAA Administrator and the 

19 Judges in this office have issued regarding 

20 what is and is not good cause. And I would 

21 highly recommend that you and your colleague, 

22 Ms. Lopez, read some of those decisions so 

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1 that you are more familiar with that body of 

2 work. 

3 So let's look at our calendars. 

4 We'll talk about giving you a time to file a 

5 Supplemental Answer to the Motion addressing 

6 any good cause factors that you would like to 

7 raise. And then we'll talk about getting Mr. 

8 Stevenson a right of final reply. 

9 I'll then rule on that Motion 

10 before we continue with any further 

11 proceedings in this matter. I don't know what 

12 your other case load work is like. So I'm 

13 going to ask you a question or two about it. 

14 How often, if at all, do you 

15 practice before the Office of Hearings in 

16 these types of cases? 

17 MS. ABDULRAHMAN-SOLER: This is 

18 the first time. 

19 ADMIN. JUDGE SULLIVAN: Okay. 

20 MS. ABDULRAHMAN-SOLER: For me. 

21 ADMIN. JUDGE SULLIVAN: Sure. Are 

22 you familiar with the database or the websites 

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1 that you would need to access in order to look 

2 up case law or case decisions? 

3 MS. ABDULRAHMAN-SOLER: No. 

4 ADMIN. JUDGE SULLIVAN: Okay. All 

5 right. How often, if at all, do you do any 

6 kind of practice in the U.S. District Court in 

7 Puerto Rico? 

8 MS. ABDULRAHMAN-SOLER: Never. 

9 It's the first tim . 

10 ADMIN. JUDGE SULLIVAN: Okay. How 

11 often, if ever, do you do litigation in any 

12 court in Puerto Rico? 

13 MS. ABDULRAHMAN-SOLER: I do 

14 mostly in administrative, the CIPA proceeding 

15 procedures. 

16 ADMIN. JUDGE SULLIVAN: Okay. And 

17 for whom would you be doing those? I mean, 

18 what administrative body are you appearing? 

19 MS. ABDULRAHMAN-SOLER: It's 

20 called CIPA. It's the Commission for 

21 Investigation and Proceedings. For this is 

22 how we -- this is how we administer to the 

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1 police officers. 

2 ADMIN. JUDGE SULLIVAN: Okay. 

3 That's helpful. And then when you are 

4 appearing before that particular decision 

5 making body, are you appearing before Judges, 

6 are you appearing before administrative 

7 decision makers, are you appearing before 

8 mediators or arbitrators? 

9 MS. ABDULRAHMAN SOLER: 

10 administrative judge. 

11 ADMIN. JUDGE SULLIVAN: Okay and 

12 are these Federal Administrative Law Judges, 

13 or some other type of judge? 

14 MS. ABDULRAHMAN-SOLER: Not 

15 federal. It's state it's state 

16 administrative judge. 

17 ADMIN. JUDGE SULLIVAN: Okay. 

18 That's helpful. And-- okay, that's helpful. 

19 I think that gives me a good idea. All right. 

20 Let's talk about a time period for 

21 you to file a Supplemental Answer to the 

22 Motion. And to do that, I need to talk to Mr. 

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1 Stevenson for just a minute, because he has 

2 appeared before me recently on several other 

3 cases. And I have a dim memory of some of his 

4 August schedule. 

5 MS. ABDULRAHMAN-SOLER: Okay. 

6 ADMIN. JUDGE SULLIVAN: So Mr. 

7 Stevenson, I recall dimly that you have some 

8 things going on in August that take you out of 

9 the office. And the rea 

10 that I want to give a due date to the 

11 Respondent in this case for filing something 

12 so that you're in the office when you get it 

13 and you have the time to respond to it. 

14 As opposed to giving the 

15 Respondent a deadline in August where you're 

16 not there and it's just going to sit on your 

17 desk. That doesn't make sense to me. I might 

18 as well give the Respondent some additional 

19 time if you aren't available until X date. 

20 So can you give me a sense of time 

21 periods that would work for you in terms of 

22 getting a supplemental answer from the 

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1 Respondent and then replying? 

2 MR. STEVENSON: Yes, Your Honor. 

3 Your dim recollection is correct. After this 

4 week, every single week for the next four 

5 weeks, I am out of the office for some or all 

6 of the week with travel. I anticipate of 

7 being back in the office after all of that on 

8 August 19 or 20. 

10 right. So Ms. Abdulrahman-Soler, let's talk 

11 about the week of August 25. Would it be 

12 possible for you to do some research and then 

13 write a Supplemental Answer and have it filed 

14 on or about the week of August 25? Or do you 

15 have some things going on in your calendar 

16 that make that difficult? 

17 MS. ABDULRAHMAN-SOLER: Yes. Yes, 

18 I can do that. 

19 ADMIN. JUDGE SULLIVAN: Okay. Do 

20 you have a preference as to a day? 

21 MS. ABDULRAHMAN-SOLER: 27th of 

22 August, a Wednesday. 

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1 ADMIN. JUDGE SULLIVAN: Okay. Why 

2 don't we set your deadline then for August 2 7, 

3 2014 for a Supplemental Answer to the FAA's 

4 Motion to Deem Admitted. And then Mr. 

5 Stevenson, I'm going to turn back to you. 

6 Looking at your calendar, what --

7 how much time would you need to comfortably 

8 file a reply once you receive that document? 

MR. STEVEN ON: I -- I believe I 

10 could file a reply within a week or five 

11 business days of when I receive it. 

12 ADMIN. JUDGE SULLIVAN: Okay. And 

13 just so that you know, because this will make 

14 a difference potentially for you, I will be 

15 out of the office from September 8 through 

16 about September 21. 

17 So if you want to file something 

18 on or before say September 22, that would 

19 probably make more sense for my calendar. 

20 MR. STEVENSON: I can I'm 

21 fairly certain I can craft something by 

22 September 22. 

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1 ADMIN. JUDGE SULLIVAN: Okay. 

2 Excellent. Then what I'm going to do, is I'm 

3 going to reserve any further discussion on the 

4 Rule 16 issues until after I receive both the 

5 Supplemental Answer and the reply and either 

6 grant or deny the Motion. 

7 So what's going to happen is I'm 

8 going to take a look at the materials after 

9 s 

10 Motion. You can still during that time 

11 period, talk to each other about any kinds of 

12 settlement. If you want to do that, it 

13 doesn't prohibit you from doing that. 

14 But I think given the fact that 

15 this is a Motion for essentially, to deem 

16 material admitted, there's no purpose in 

17 proceeding with a Rule 16 if in fact it's 

18 possible that the case wouldn't go forward. 

19 So Ms. Abdulrahman-Soler, let's 

20 talk about, a little bit about resources. 

21 There are a variety of different ways that you 

22 can find case decisions by the FAA Assistant 

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1 Administrator, or by Judges in this office on 

2 the issue of good cause. 

3 You can go to Westlaw. You have 

4 access to Westlaw? You can go to 

5 MS . ABDULRAHMAN- SOLER: I have 

6 access to Microjuris. 

7 ADMIN. JUDGE SULLIVAN: To what? 

8 MS. ABDULRAHMAN-SOLER: 

9 

10 ADMIN. JUDGE SULLIVAN: I don't 

11 know what that is. 

12 MS. ABDULRAHMAN-SOLER: It's like 

13 Westlaw, but it's more kind of a state's laws. 

14 We have also federal laws here. 

15 ADMIN. JUDGE SULLIVAN: Well this 

16 is all federal. It won't be in any state law 

17 banks that you may have. 

18 MS. ABDULRAHMAN-SOLER: Okay. 

19 ADMIN. JUDGE SULLIVAN: It's all 

20 federal. Your prosecuting agent is an 

21 attorney representing a Federal Administrative 

2 2 Agency, the FAA. You're appearing before the 

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1 Office of Hearings, which is part of the 

2 Secretary's Department in the U.S. Department 

3 of Transportation. 

4 And I'm an Administrative 

5 Federal Administrative Law Judge operating 

6 under the authority of the Administrative 

7 Procedures Act, which is a Federal Statute. 

8 This is all federal. 

10 ADMIN. JUDGE SULLIVAN: Okay? 

11 MS . ABDULRAHMAN- SOLER: We can 

12 look for Westlaw also. 

13 ADMIN. JUDGE SULLIVAN: Well, I'm 

14 just telling you that there are many different 

15 databases that are available to you so that 

16 you can quickly become familiar and 

17 knowledgeable about the good cause standard. 

18 But Westlaw is one of them. 

19 LexisNexis is another database 

20 that's commonly used that has many of our 

21 decisions posted. You can also go to another 

22 website. And I'm going to pull that up on my 

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1 computer right now, so that I have a copy 

2 available to talk about with you. 

3 MS. ABDULRAHMAN-SOLER: Okay. 

4 ADMIN. JUDGE SULLIVAN: This is a 

5 Federal Docket Management System website. And 

6 this has all of the FAA decisions on it. So 

7 it's www.F as in Frank, D as in David, Mas in 

8 Mary, S as in Sam, . gov. 

9 

10 into the website, but that should be fairly 

11 easy for you. Once you get into the website, 

12 you can go and look for all the FAA decisions 

13 by the Administrator, or all the decisions by 

14 Judges in this office about good cause. 

15 If you have trouble accessing the 

16 website, there is a contact menu item, where 

17 you can contact the people who take care of 

18 that tech support. And they're available 

19 Monday through Friday, 9:00 to 5:00 p.m. 

20 Eastern time. 

21 I've also had people tell me that 

22 they just put in a Google search and gotten 

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COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISlAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 (202) 234-4433 
26 

1 information. That's not quite ideal, because 

2 Google covers lots of different things. But 

3 that's also a possibility. 

4 But I would highly encourage you 

5 to read some of these decisions about what is 

6 and is not considered good cause. So that if 

7 you have good cause factors, you can present 

8 them appropriately. 

10 ADMIN. JUDGE SULLIVAN: So and I 

11 will be sending out an Order identifying these 

12 two deadlines, the August 27, 2014 deadline 

13 for the Respondent to file a Supplemental 

14 Answer, as well as the deadline of September 

15 22, 2014 for the FAA to file a reply. 

16 What might be helpful, and I will 

17 leave it to the parties, I'll ask you both 

18 what you think. I can set up a new telephone 

19 conference date about a month after the 

20 September 22 date, in the event that we need 

21 to reconvene and talk further. 

22 Or I can simply set a blind date 

NEAL R. GROSS 

(202) 234-4433 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005·3701 (202) 234-4433 
27 

1 if in fact we need to have a new conference 

2 and proceed with a Rule 16 conference. Mr. 

3 Stevenson, do you have a preference? 

4 MR. STEVENSON: I think my 

5 preference would be one that I think Your 

6 Honor has expressed elsewhere, to go ahead and 

7 set a date just so that I have that in my 

8 calendar and I can make sure to plan around 

10 ADMIN. JUDGE SULLIVAN: Ms. 

11 Abdulrahman-Soler, is that acceptable to you 

12 as well? 

13 MS. ABDULRAHMAN-SOLER: Yes. 

14 ADMIN. JUDGE SULLIVAN: Okay. 

15 Then let's talk about a date in and around 

16 October. And I can tell you that my first 

17 three weeks -- actually, something cleared up, 

18 excuse me. How about the week of October 2 0, 

19 or the week of October 26? 

20 Mr. Stevenson, do you have a 

21 preference? 

22 MR. STEVENSON: The week of 

NEAL R. GROSS 

(202) 234-4433 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 (202) 234-4433 
28 

1 October 20 would be my preference. 

2 ADMIN. JUDGE SULLIVAN: And Ms. 

3 Abdulrahman-Soler is that acceptable to you? 

4 MS. ABDULRAHMAN-SOLER: Yes. 

5 ADMIN. JUDGE SULLIVAN: Okay. 

6 Then why don't we plan for October 22, 2014 at 

7 10:00 a.m. in the morning. And this will be 

8 for a Rule 16 conference unless the Court 

9 issu 

10 Admitted and cancels the conference. 

11 Mr. Stevenson, let me ask you a 

12 question about your Motion. It was my 

13 understanding in reading the Motion that it 

14 was for all the allegations in the Complaint, 

15 is that correct? 

16 MR. STEVENSON: Yes Your Honor. 

17 ADMIN. JUDGE SULLIVAN: Okay. All 

18 right. So I' 11 issue an Order that identifies 

19 those three dates, August27, 2014, September 

20 22, 2014 and October 22, 2014. I'll also re21 identify Mr. Smith as the contact person with 

22 his telephone number for any questions that 

NEAL R. GROSS 

(202) 234-4433 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 (202) 234-4433 
29 

1 either party may have. 

2 If there is a need for some reason 

3 by either party because of an unexpected 

4 conflict to move for a change in these dates, 

5 I'll have a little paragraph about how you can 

6 do that, if it's absolutely necessary. 

7 And then Ms. Abdulrahman-Sola:, 

8 I'll ask you to take a look at some of these 

9 websites and see if ou can' 

10 soon as possible about the good cause standard 

11 and some of the things that you may want to be 

12 considering in talking about why your Answer 

13 was late. 

14 It doesn't appear that anyone 

15 disagrees at this point that the Answer was 

16 due on or before April 23, 2014. And it was 

17 not filed at that time. 

18 So with that, on behalf of the 

19 FAA, Mr. Stevenson, is there anything else 

20 that we need to address for your client today? 

21 MR. STEVENSON: No, Your Honor. 

22 ADMIN. JUDGE SULLIVAN: Okay. Ms . 

NEAL R. GROSS 

(202) 234-4433 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 (202) 234-4433 
30 

1 Abdu1rahman-Soler, is there any question you 

2 might have, or anything else we need to 

3 address for your client before we close today? 

4 MS. ABDULRAHMAN-SOLER: No, Your 

5 Honor. 

6 ADMIN. JUDGE SULLIVAN: Okay. 

7 Then I will thank all of you very much for 

8 your presence today and for your 

9 

10 Respondent's Supplemental Answer as well as 

11 the FAA's reply. 

12 I look forward to getting all 

13 those materials and I'll issue an Order as 

14 soon as possible thereafter. With that, we 

15 can go off the record, and I wish you all a 

16 good day. Thank you. 

17 MS . ABDULRAHMAN- SOLER : Thank you . 

18 MR. STEVENSON: Thank you, Your 

19 Honor. 

20 ADMIN. JUDGE SULLIVAN: Good bye. 

21 (Whereupon, the above-entitled 

22 matter went off the record at 10:41 a.m.) 

NEAL R. GROSS 

(202) 234-4433 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 (202) 234-4433 
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29:20 30:3,8 

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24:3 

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trouble 5:21 6:5 

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Neal R. Gross and Co., Inc. 

Washington DC 

Page 34 

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202-234-4433 

Page 35 

Neal R. Gross and Co., Inc. 

Washington DC www.nealrgross.com 
36 

C E R T I F I C A T E 

This is to certify that the foregoing transcript 

In the matter of: Puerto Rico Police Department 

Before: US DOT/FAA 

Date: 07-23-14 

ace: teleconference 

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

(202) 234-4433 

Court Reporter 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005·3701 www .nealrgross.com