UNITED STATES OF AMERICA 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of 

TANGO AIR, INC., d/b/a SCHUBACH AVIATION 

(CIVIL PENALTY ACTION) 

FDMS NO. FAA-2015-3317 

JUDGE: THE HONORABLE J.E. SULLIVAN 

JOINT STATUS REPORT PURSUANT TO ORDER SETTING 

LITIGATION SCHEDULING CONFERENCE 

AND DIRECTING PARTIES TO FILE PROPOSED DISCOVERY PLAN 

TO THE HONORABLE J.E. SULLIVAN, ADMINISTRATIVE LAW JUDGE: 

Pursuant to the Order Setting a Ru1e 16 Litigation Scheduling Conference and Directing 

the Parties to Confer and File a Rule 26(f) Proposed Discovery Plan, the parties respectfully 

submit this Joint Status Report. 

I. 

VENUE 

Inasmuch as this case arose in Carlsbad, California, and the majority of percipient 

witnesses reside and/or work in the greater San Diego, California area, the parties request that 

the hearing in the matter be scheduled for San Diego, California after completion of discovery. 

Given the complexity of the issues, it is anticipated that the hearing may take 2-3 days. 

II. 

DISCOVERY 

TANGO AIR, INC., d/b/a SCHUBACH AVIATION ('TANGO") has initiated discovery, 
serving its First Discovery Request upon Complainant on February 19, 2016. 

Complainant also intends to initiate discovery. 

Predicated upon the contents of the parties' respective discovery responses, the parties 

may take depositions of those persons whom have been identified as percipient witnesses, 

experts or hearing witnesses. It is anticipated that any such depositions will have been taken and 

concluded and discovery will have been concluded by November 30, 2016. 

Ill. 

DATES UPON WHICH THE PARTIES AND/OR TIDER COUNSEL AND WITNESSES 

WILL NOT BE AVAILABLE FOR HEARING 

April27-May 2, 2016; 

May 5, 2016; 

May 10-13, 2016; 

May 25-June 2, 2016; 

August 25-September 10, 2016; and 

October 31-November 4, 2016. 

The foregoing reflects the parties' and their respective counsels' current calendars, and the 

parties reserve the right to supplement this information from time to time. 

It is respectfully requested that the hearing be scheduled so as not to conflict with these 

dates of unavailability and that the Administrative Law Judge provide not less than ninety (90) 

days notice prior to hearing. 

IV. 

STATUS OF SETTLEMENT EFFORTS 

Although the parties have discussed settlement, they have not been able to resolve this 
matter. The parties anticipate that settlement discussion will likely continue during the pendency 

of this litigation. 

In addition, the parties would have no objection to participating in a settlement 

conference or participating in alternative dispute resolution. 

Respectfully submitted. 

Dated: April 4, 2016 

'!Jp}) 

Dated: M!mili __ _,2016 

ROBERT SiirTZER 

Attorney, Enforcement Division, Western Team 

Federal Aviation Administration 

1601 Lind Avenue, SW 

Renton, W A 98057 

Telephone: (425) 227-1417 

FAX: (425) 227-1007 

Email: robert.spitxer@faa.gov 

Attorney for Complainant, 

FEDERAL AVIATION ADMINISTRATION 

I' 

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~Ml~C=H=A~E='L~L~_~D~W~O~R=K~IN~--------­

MICHAEL L. DWORKIN and ASSOCIATES 

465 California Street, Suite 210 

San Francisco, CA 94104 

Telephone: (415) 421-2500 

FAX: (415) 421-2560 

Email: 1aw@avialex.com 

Attorney for TANGO AIR, INC., 

d/b/a SCHUBACH AVIATION 
CERTIFICATE OF SERVICE 

I hereby certify that on this 4th day of April, 2016, a true and correct copy of the 

foregoing TANGO AIR, INC., d/b/a SCHUBACH AVIATION'S JOINT STATUS 

REPORT was served as follows: 

The Honorable J.E. Sullivan 

Office of Hearings, M-20 

1200 New Jersey Avenue, S.W. 

Room El2-320 

Washington, D.C. 20590 

Fax: (202) 366-7536 

(One copy via FAX) 

Federal Aviation Administration 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Bldg-Ste. 2W1000 

800 Independence Avenue SW 

Washington, D.C. 20591 

(Original plus one copy via FED EX) 

Robert Spitzer, Esq. 

Enforcement Division-Western Team 

Federal Aviation Administration 

1601 Lind Avenue, SW 

Renton, WA 98057 

Fax: (425) 227-1007 

(One copy each via FAX)