From:BARHARD LAW GROUP To: 12024935142 01/14/2014 00:33 

UNITED STA:_:rES DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

Civil Penalty Action 

11159 P.002/003 

In the Matter of: 

v. 

Served: January 14,2014 

FDMS No. FAA-2013-0284 

Case No. 2012CE440003 

AVIATION ENGINEERING CONSULTANTS, INC., 

Judge: Hon. J.E. SULLIVAN 

I 

NOTICE OF PENDING SETTLEMENT AND UNNOPOSED MOTION TO CONTINUE 

COMES NOW, the undersigned counsel, DOUGLAS J. BARNARD, ESQUIRE, for the 

Respondent, AVIATION ENGINEERING CONSULTANTS, INC., and hereby files this Notice of 

. ·Pending-Settlement and Motion to Continue (the "Motion") and as grounds therefore states: 

1. That the undersigned is Counsel for the Respondent, AVIATION ENGINEERING 

CONSULTANTS, INC., in this action. 

2. The undersigned, Douglas J. Barnard, Esq. has previously filed a Motion to Withdraw as Counsel 

and Abate this action based upon personal health issues that will preclude his from continuing the 

representation of AVIATION ENGINEERING CONSULT ANTS, INC. in this cause. This Conrt 

has reserved ruling on the undersigned's Motion to Withdraw. 

3. However, on January 10, 2014, the parties mutually agreed to the terms of settlement in this 

action with a payment dne date ofJanuary 31, 2014 to the FAA from the Respondent. 

4. The undersigned counsel has conferred with opposing counsel (Mark Camacho, Esq.), the 

Respondent (Aviation Engineering Consultants, Inc.) regarding this Motion and propose that 

the current deadline contained in this conrt's Ru1e 16 Order served November 19, 2013 be 

continued as follows: 

a. The Ru1e 26(f) planning meeting and associated proposed schedu1ing/discovery plan 

shall be completed and filed by Wednesday, February 05, 2014; and 
From:BARHARD LAW GROUP To: 12024935142 01/14/2014 00:33 11159 P.003/003 

b. The Rule 16 litigation Scheduling conference shall occur on Wednesday, February 

12, 2014 at 1:30 p.m. EST. 

5. None of the parties to this action have any objection to this Motion or the proposed dates/times 

which have been pre-cleared with Attorney/ Advisor Cody L. Smith, Esq. 

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

Court enter an Order continuing the deadline for the Rule 26(f) planning meeting and associated proposed 

scheduling/discovery plan and continue the date of the Rule 16 litigation Scheduling conference to allow 

the settlement reached between the parties to become fmal. 

CERTIFICATE OF SERVICE 

. . I hereby certifY that a true and correct copy of the foregoing answer and affirmative 

defenses were served via confirmed facsimile and United States Postal Service on the 14th day 

of January, 2014, 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 AVIATION ENGINEERING CONSULTANTS, INC. (C/0 Kamran 

Rouhani, 2159 McMullen Booth Road, Clearwater, Florida 33759/fax: (727) 723-1333, and that this 

pleading was filed this 14th day of January, 2014, with the FAA hearing docket clerk, 800 

Independence Ave. S.W., Attn: Hearitig 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 ofHearings, U.S. Department ofTransportation, 1200 New 

Jersey Ave. S.E. (E11-310), Washington, D.C. 20590, facsimile: (202) 366-7536 with copies to 

CodyL. Smith, Esq via fax to (202)366-7536. 

&fA 

Douglas J. Barnard, Esquire 

Fla. Bar No. 0928496 

Plane Law, P .A. 

13790 Roosevelt Boulevard, Suite A 

Clearwater, Florida 33762 

Telephone: (727) 259-0224 

Fax: (727) 259-0223 

dougb@olanelaw.com 
From:BARHARD LAW fiROUP To:12024935142 01/14/2014 00:33 11159 P.001/003 

Plane Law in Plain English ... 

FAX======== 

TO: FAA Docket Clerk FROM: Douglas J. Barnard, Esq. 

FAX: (202) 493-5142 PAGES: 3 (Including Cover) 

PHONE: (202)385-8229 DATE: January 14,2014 

RE: In Re: Aviation Consultants, Inc. CC: Hon. J.E. Sullivan/Mark Camacho. Esq 

X Urgent X ForReview 0 Please Comment 0 Please Reply 0 Please Recycle 

Madam Clerk, 

Please refer to our enclosed pleading of even date for your recordation. 

A hard copy will follow via USPS. 

Tlianli you for your attention to tliis urnent rnatter. 

1Jouai£Ls J. 'Barnard; 'Esq. 

NOTICE TO RECiPIENT 

ALL THE PAGES WHICH CONSTITUTE THIS FACSIMILE TRANSMISSION CONTAIN INFORMATION WHICH IS CONFIDENTIAL AND COVERED BY 

ATTORNEY-CLIENT PRIVILEGE. 

The infonnation herein is intended solely for the use of the person to whom it is addressed or directed. If the reader of this notice is not listed above, or if the reader is not 

an employee or agent responsible for delivering the :fucsimile transmission to the addressee, then you are hereby notified that any dissenrination. distribution or 

reproduction of any or a.Il of these pages is strictly prohibited. If you have received this fucsimile tmnsmission in error, please notify us immediately and retwn the 

· original fucsiinile transmission to us via the postal service. We will reimburse you for the postage. Thank you. 

Douglas J. Barnard, Esq."' 

"'Also admitted to the District of Columbia 

AFFILIATES WORLDWIDE 

13790 Roosevelt Boulevard 

Clearwater, Florida 33762 

Email: dougb@olanelaw.com 

Phone: (727) 259-0224 

Facsimile: (727) 259-0223