U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of Hortman Aviation Services, Inc. 

Docket No. FAA-2016-0635 

Case No. 2010EA170043 

Administrative Law Judge J.E. Sullivan 

tJ 

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AGENCY'S PROPOSED SCHEDULING/DISCOVERY PLAN 

The Agency and Northeastem Aviation Corp., (Respondent) hereby propose the 

following schedule/discovery plan: 

1. January 4, 2016- deadline for filing general discovery requests, including but 

not limited to : taking depositions; serving and answering requests for 

production of documents; 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 of service of the disputed discovery request. 

3. Motion to 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 after the 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 of opinion (including disclosure of the 

basis of the 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 of depositions, pursuant to 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 Judgment Motions. 

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 dispositive motions. 

7. August 1, 2016- Exchange oflist of witnesses 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 in Limine. 

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9. September 13-15, 2016- Hearing in Philadelphia, PA. 

Respectfully submitted, 

Peter J. Lynch 

Assistant Chief Counsel 

for Enforcement 

By: 

Zachary 

Attorney 

Federal Aviation Administration 

Office of the Chief Counsel 

Enforcement Division, Northeast Team 

1 Aviation Plaza 

Jamaica, NY 11434 

T: 718-553-3258 

F: 718-995-5699 

E: Zachary.Berman@F AA.GOV 

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Dated: November 12, 2015 
CERTIFICATE OF SERVICE 

I hereby certify that on this day copies of the foregoing Agency's Proposed 

Scheduling/Discovery Plan were sent first class mail and fax as follows: 

Judge J. E. Sullivan 

U.S. Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey 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, P A 19114 

FAX: 215-677-6408 

I hereby certifY that on this day copies of the foregoing Agency's Proposed 

Scheduling/Discovery Plan were sent first class mail as follows: 

Federal Aviation Administration 

800 Independence Avenue, S.W,. 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building~ Suite 2W1000 

Date November 12,2015 !!jLi 

~oks Paralegal Specialist 

Federal Aviation Administration 

1 Aviation Plaza 

Jamaica, NY 11434 

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