03/30/2011 07:28 FAX 2024935142 FAA * DMS 0001/00 5 

Michael Selig. MD. FACC, CFl-H 

2816 0refield Road 

Allentown, PA. 18104 

RECEIVED 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

r";. 

>, ZTJ K~' ~-^' 

C/1 

Federal Aviation Administration 

Cynthia Dominik, Laura Ponto, 

Latonya Williams 

Complainants 

M & R Helicopters, LLC. 

Respondent 

Honorable Judge Ronnie Voder 

NderaJ Docket. No: 2010^1211 

PETITION FOR EMERGENCY INJUNCTIVE AND DECLARATORY RELIEF AND 

CASE DISMISSAL 

AND NOW, comes respondent. MICHAEL B. SELIG, MD, FACC, 

CFI-H, principle for M & R Helicopters, LLC,j(MRH} (non-operational since 

2007) whom avers and files the following Petition for Emergency Relief. 

1. Complainants have continued to hold steadfast to their 

alleged violation despite multiple procedural defects and nonresponsiveness as listed in the Motion for Sanctions and the Counter 

Complaint. 

-1 
03/30/201 1 07:2 8 FAX 2024935142 FAA * DMS gl002/005 

2. Complainonts have filed lateiresponses to motions past the 

10 day deadline period under § Rule 13.2^8(d). 

3. Complainants have failed to respond to the Motion for 

Special Relief and Sanctions against Complainants-Prosecutorial 

Indiscretion filed on 2-26-2011. 

4. By ignoring and falling to respond, complainants have 

agreed to admissions of truth to those statements in those documents to 

be held as correct findings of fact. 

5. Complainants have refused to respond to the Petition for 

Disclosure of Ms Pontos attorney ID number and all other inquiries to this 

subject matter. j 

6. Complainant's have held corjisistent with their statements 

I 

I 

made in the Notice of Continual Objectiohs that they oppose all future 

j 

pleadings without hearing or knowing the content of these pleadings, 

choosing to leave themselves open to further procedural defects that 

currently exist. 

7. It is respondents request that since complainants have 

chosen to step out of the litigation and become non-responsive, have a 

long list of complaint and procedural defects, that the telephone hearing 

of March 25, 2011 should be cancelled, j 

8. It is respondents request that since complainants have 

chosen to step out of the litigation, have a long list of complaint and 
03/30/201 1 07:2 8 FAX 2024935142 FAA ^ DMS ^003/00 5 

procedural defects, that the connplaint be immediately dismissed, that 

i 

Injunctive and Declaratory Relief be granted and only the counter 

complaint be addressed at this time and sanctions be applied as 

deemed appropriate to defer similar future wrongful conduct. 

9. It is respondent's request thatisince complainants have 

chosen to step out of the litigation, have d long list of complaint and 

procedural defects, have squandered and dissipated governmental 

funding beyond any potential fee recovery, even though the complaint 

i 

appears non-meritorious, that the case be immediately quashed and 

peer review be conducted on the involved parties. 

10. It appears that the complainanis have engaged in Malicious 

Prosecution with the motive to extort monies from respondent and 

financially harm his business. j 

11. It appears that the complaindints have failed to apply valid 

arguments concerning the subject matter jurisdiction, failed to apply 

proper principles of law, failed to base its ({allegations on proper 

procedural grounds, abuse its discretion ih making findings of fact, 

thereby committing errors of law and abujed its discretion in reaching its 

conclusions of law. ' 

3-
03/30/201 1 07:2 8 FAX 2024935142 FAA + DMS gl004/00 5 

WHEREFORE, the respondent prays that this Honorable Court will: 

1. Grant the following: 

a. Dismissing the case /or i 

b. Issue a protective order to Freeze the case to the original 

complaint/and ! 

c. Award punitive damages to thej respondent at the courts 

i 

discretion /and 

d. Report the complainonts to theiOpproprlate disciplinary 

board/and i 

e. Hold complainants liable and not shielded under the witness 

immunity doctrine. ; 

Respectfully Submitted, 

Michael B. Selig, MD, FACC , CFl-H ^ 

Dat e ^• 

- 4 -
03/30/2011 07:28 FAX 2024935142 FAA * DMS 21005/005 

'• \ iU^ % ^ 

U.S. DEPARTMENT OF TRANSPORTATION 

EIVED 

) ^' 2011 

EARING DOCKET 

Federal Aviation Administration 

Cynthia Dominik, Laura Ponto, 

Latonya Williams. Peter Lynch 

Complainants 

M & R Helicopters, LLC. 

Respondent 

Honorable Judge Ronnie Yoder 

Docket: 2010-1211 

CERTIFICATE OF SERVICE 

1 HEREBY CERTIFY that I have this day served the foregoing entrie(s); 

PETITION FOR EMERGENCY INJUNCTIVE AND DECLARATORY RELIEF AND CASE 

DISMISSAL 

upon all parties of record in this proceeding, in accordance with the requirements of Rule 29 

pursuant to 28 U. S. C. § 1746 . 

Service by first-class mail, postage prepaid, addressed as follows: 

Federal Aviation Administration 

800 Independence Avenue, SW 

Wilbur Wright Avenue-Suite 2W]000 

Washington, D.C. 20591 

Att: Hearing Docket Cleric, AGC-43 0 

FAX 202 493 5142 

The Honorable Ronnie A. Yoder 

US Department of Transportation 

Office of Hearings, M-20, Room El 2-320 

1200 New Jersey Avenue. S.E. 

Washington, DC 20590 

FAX 202 366 7536 

Laura Ponto, Esq. 

Enforcement Division/AGC-300 

Office of the Chief Counsel 

FAA 

800 independence Avenue, SW 

Washington, DC 20591 

FAX 202 267 5106 

^ \ By: 

Michoel B. Selig, MD. FAtC. 

2816 Orefield Road 

Allentown, Pa. 18104 

610 360 3953 -^/\V^^ ^ 

Date: 

^^v -