U.S. DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS

WASHINGTON, D.C.
Inthe Matter ofHortmanAviation Services, Inc. DocketNo. FAA-2016-0635 Case No. 2010EA170043 Administrative LawJudge J.E. Sullivan tJ I '
AGENCY'S PROPOSED SCHEDULING/DISCOVERYPLAN The Agency and Northeastem Aviation Corp., (Respondent) hereby propose the following schedule/discoveryplan: 1. January 4, 2016- deadline for filing general discovery requests, including but not limited to : taking depositions; serving and answering requests for production ofdocuments; interrogatories; requests for admissions; etc. 2. Motion to Limit Discovery upon Receipt of Discovery Request: A party served with a discovery request who seeks to limit discovery pursuant to 14 CFR Section 13.220(f)(g), and (h), shall file a Motion for relief within 10 days ofservice ofthe disputed discovery request. 3. Motionto Compel Discovery: A party seeking to compel discovery must file
a Motion to Compel within 10 days of receipt of service of a deficient response or afterthe response to the discovery is due, whichever occurs first. 4. March 4, 2016

- Expert witness disclosures (for any expert witness to be called at hearing), including the witness's resume or qualifications, and the witness's written report or statement ofopinion (including disclosure ofthe basis ofthe opinion).5. April 4, 2016- Deadline for Completing General Discovery- On or before April 4, 2016, the parties shall finish responding and serving answers to all general discovery requests pursuant to 14 CFR section 13.220. This includes the taking ofdepositions, pursuantto 14 CFR Section 13.2200). 6. May 4, 2016 -Deadlines for Filing Dispositive Motions. The last date for both parties to file any/all pre-hearing dispositive motions, including Default Motions and/or Summary JudgmentMotions.
a. May 25, 2016: Deadline for filing answers to dispositive motions. b. June 1, 2016: Deadline for filing Reply.
c. June 22, 2016- Oral argument on dispositivemotions. 7. August 1, 2016- Exchange oflist ofwitnesses and exhibits. 8. August 1, 2016 -Written Stipulations and/or agreed motions in Limine. On
or before August I, 2016, the parties shall file any written stipulations that
narrow the factual or legal issue, and that are agreed Motions inLimine.

29. September 13-15, 2016- Hearing in Philadelphia, PA. Respectfully submitted, PeterJ. Lynch Assistant ChiefCounsel

for Enforcement
By: Zachary Attorney FederalAviation Administration Office ofthe ChiefCounsel Enforcement Division, Northeast Team 1Aviation Plaza Jamaica, NY 11434 T: 718-553-3258 F: 718-995-5699 E: Zachary.Berman@FAA.GOV

3 Dated: November 12, 2015CERTIFICATE OF SERVICE I hereby certify that on this day copies of the foregoing Agency's Proposed Scheduling/DiscoveryPlan were sent first class mail and fax as follows: Judge J. E. Sullivan U.S. AdministrativeLawJudge Office ofHearings, M-20 U.S. Department ofTransportation 1200 NewJersey Avenue, S.E. (Ell-310) Washington, DC 20590 FAX: 202-366-7536 Mr. H.M. Hortman, President Hortman Aviation Services, Inc. 9800 Ashton Road Philadelphia, PA 19114 FAX: 215-677-6408 I hereby certifY that on this day copies of the foregoing Agency's Proposed Scheduling/DiscoveryPlanwere sent first class mail as follows: Federal AviationAdministration 800 IndependenceAvenue, S.W,. Washington, DC 20591 Attention: Hearing Docket Clerk, AGC-430 Wilbur Wright**Building~** Suite 2W1000

Date November 12,2015 

# !!jLi**~oks** Paralegal Specialist FederalAviation Administration 1AviationPlaza Jamaica, NY 11434

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