From:BARHARD LAW GROUP To:12024935142 12/20/2013 04:00 11154 P.001/002 

UNITED STATES DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

Io the Matter of: 

v. 

Civll Penalty Action 

AVIATION ENGINEERING CONSULTANTS, INC., 

----------------------------~1 

Served: December 20,2013 

FDMS No. FAA-2013-0284 

Case No. 2012CE440003 

Judge: Hon. J.E. SULLIVAN 

MOTION TO WITHDRAW AS COUNSEL AND ABATE ACTION 

COMES NOW, the Wldersigned coWisel, DOUGLAS J. BARNARD, ESQUIRE, for the 

Defendant, AVIATION ENGINEERING CONSULT ANTS, INC., and hereby files this Motion to 

· Withdraw as CoWisel and as groWids therefore states: 

1. That the Widersigned is CoWISel for the Defendant, AVIATION ENGINEERING 

CONSULTANTS, INC., in this action, 

2. The Wldersigned, Douglas J. Barnard, Esq. has personal health issues that will preclude his from 

• 

continuing the representation of AVIATION ENGINEERING CONSULTANTS, INC. in this 

cause. 

3. Therefore, Douglas J. Barnard, Esq., the Widersigned, hereby requests to be withdrawn as coWISe! 

in this matter as of this date. 

4. The Wldersigned coWISel hils conferred with his client and opposing coWISe! regarding this matter 

and neither have any objection to the.Widersigned's withdrawal in this matter for the reasons set 

forth above. 

5. That CoWisel would request that any and all further pleadings and correspondence be sent directly 

to the Defendant as follows: 

AVIATION ENGINEERING CONSULTANTS, INC. 

C/0 Kamran Rouhani 

2159 McMullen Booth Road 

Clearwater, Florida 33759 

6, That CoWisel would also request that this court abate this action for thirty (30) days to allow 
From:BARHARD LAW GROUP To:12024935142 12/20/2013 04:00 11154 P.002/002 

Defendant to obtain new ~ounsel. 

WHEREFORE, based upon the foregoing, the undersigned counsel respectfully requests that this 

Court enter an Order allowing the undersigned attorney, DOUGLAS J. BARNARD, ESQ., and the firm 

of PLANE LAW, P.A. to withdraw as counsel for Defendant in this action and to be relieved of any 

further responsibility in this matter with respect to Defendant, abate this action thirty (30) days to allow 

Defendant to obtain new counsel and grant any further relief as this Honorable Court may deem just and 

proper. 

CERTIFICATE OF SERVICE 

· I hereby certify that a true and correct copy of the foregoing answer and affirmative 

. def~ses were served via confirmed facsimile and United States Postal Service on the 20th day 

of December, 2013, to: Mark Camacho, Esquire, Federal Aviation Administration, Office of the 

Regional Counsel, Central Region, 901 Locust , Room 506, Kansas City, MO 64106-2641, 

facsimile: (816) 329-3771, and that this pleading was filed this 20th Day of November, 2013, 

with the FAA hearing docket clerk, 800 Independence Ave. S.W., Attn: Hearing Docket Clerk, 

' 

AGC-430, Wilbur Wright Building, Room 2014, Washington, D.C. 20591, facsimile: (202) 493-

5142, and the Hon. J.E. Sullivan, Administrative Law Judge, Office of Hearings, U.S. 

Department of Transportation, 1200 New Jersey Ave. S.E. (Ell-310), Washington, D.C. 20590, 

facsimile: (202) 366-7536. 

Dou as J. Barnard, Esquire 

Fla. Bar No. 0928496 

Plane Law, P.A. 

13790 Roosevelt Boulevard 

Clearwater, Florida 33762 

Telephone: (727) 259-0224 

Fax: (727) 259-0223 

dougb@planelaw.com