.v 

IN THE MATTER OF, 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

LEADING EDGE' AVIATION, INC., 

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No. FAA Case No. 2011 NM 070089 

OMS No.: FAA-2012-0783 

Respondent. Honorable Richard C. Goodwin 

RESPONDENT'S MOTION TO SET EXPERT DISCLOSURE DEADLINE 

NOW COMES Respondent Leading Edge Aviation, Inc. ("Leading Edge"), by and 

through its counsel, and for its captioned motion states as follows: 

1. Discovery in this matter is currently set to close on February 28, 2013. 

2. No deadline has been set to disclose experts nor has a hearing date been set. 

3. Leading Edge may retain an expert in this case. However, written discovery and 

key depositions must first be completed to evaluate that issue. Leading Edge will be unduly 

prejudiced if it does not have adequate time to conduct fact discovery and potentially retain and 

disclose an expert. Further, if the FAA discloses an expert, Leading Edge needs sufficient time 

to depose such expert prior to the hearing. 

WHEREFORE, Leading Edge requests that the administrative law judge enter the 

following order (a proposed order is attached hereto): 

1. The February 28, 2013 discovery deadline is modified as follows: all parties shall 

disclose any expert witnesses by February 21, 2013, with expert depositions to be conducted 

within 30 days thereafter. 

LEADING EDGE AVIATION, INC. 

1919982\1\22816\49252 
Fred C. Begy 

Cani A. Conlon 

CHUHAK & TECSON, P.C. 

30 S. Wacker Drive, Suite 2600 

Chicago, IL 60606 

(312) 444-9300 

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·~· ... 

By: 

One of 

e-~~ Its Attorneys 

CERTIFICATE OF SERVICE 

The undersigned, being first duly sworn on oath, certifies that a true and correct copy of this 

Respondent's Motion to Set Expert Disclosure Deadline was served upon the persons below as 

indicated by either facsimile, Federal Express, or depositing same, proper postage prepaid, in the 

U.S. mailbox located at 30 South Wacker Drive, Chicago, Illinois 60606 by 5:00p.m. on this 

16th dayofNovember, 2012, as reflected below. 

Federal Aviation Administration 

800 Independence Avenue SW Washington, D.C. 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2W1 000 

(Original and copy) (Via Federal Express) 

The Honorable Richard C. Goodwin 

Office of Hearings, M-20 

1200 New Jersey Avenue, S.E. (E-11-310) 

Washington, D.C. 20590 

Fax: 202-366-7536 

(Sent via Federal Express and Facsimile) 

Jeffrey M. Harper, FAA Attorney 

FAA Office of Regional Counsel 

Federal Aviation Administration 

Northwest Mountain Region, ANM-7 

1601 Lind Ave. SW 

Renton, W A 98057 

Fax: 425-227-1007 

(Sent via Facsimile and U.S. Mail) 

Counsel ~~ for Respondent 

19 I 9982\ I \228 I 6\49252 -2-
UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

IN THE MATTER OF, ) 

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LEADING EDGE AVIATION, INC., 

Respondent. 

ORDER 

No. FAA Case No. 2011 NM 070089 

DMS No.: FAA-2012-0783 

Honorable Richard C. Goodwin 

NOW COMES Administrative Law Judge Court Goodwin on Respondent's 

Motion to Set Expert Disclosure Deadline and orders: 

The February 28, 2013 discovery deadline is modified as follows: all parties shall 

disclose any expert witnesses by February 21, 2013, with expert depositions to be 

conducted within 30 days thereafter. 

1920848\1\22816\49252 

DATED: ----------------------

Richard C. Goodwin 

Administrative Law Judge