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

UNITED STATES DEPARTMENT OFTRANSPORTATION FEDERAL AVIATION ADMINISTRATION
Iothe Matter of: 

### v. CivllPenaltyAction

AVIATION ENGINEERING CONSULTANTS, INC.,

## ----------------------------~1 Served: December 20,2013 FDMS No. FAA-2013-0284 Case No. 2012CE440003 Judge: Hon. J.E. SULLIVAN



### MOTION TO WITHDRAWAS COUNSEL AND ABATEACTION 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., inthis action, 2. TheWldersigned, 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 Therefore, Douglas J. Barnard, Esq., the Widersigned, herebyrequests to be withdrawn as coWISe! inthis matter as ofthis date. 4. TheWldersigned coWISel hils conferred withhis client and opposingcoWISe! regardingthis matter andneitherhave any objectionto the.Widersigned's withdrawal inthis matter for the reasons set forth above. 5. That CoWisel wouldrequestthat any and all further pleadings and correspondencebe sent directly to the Defendant as follows: AVIATIONENGINEERING CONSULTANTS, INC. C/0 Kamran Rouhani 2159 McMullenBoothRoad

Clearwater, Florida 33759 6, That CoWisel would also request thatthis 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 obtainnew**~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 reliefas this Honorable Court may deemjust and proper. 

### CERTIFICATE OF SERVICE



### ·I hereby certify thata 

### 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 ofDecember, 2013, to: Mark Camacho, Esquire, Federal Aviation Administration, Office ofthe 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, WilburWright 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 ofTransportation, 1200 New JerseyAve. S.E. (Ell-310), Washington, D.C. 20590, facsimile: (202) 366-7536.

Dou as J. Barnard, Esquire Fla. BarNo. 0928496 Plane Law, P.A. 13790 Roosevelt Boulevard Clearwater, Florida33762 Telephone: (727) 259-0224 Fax: (727) 259-0223 dougb@planelaw.com