04/21/2011 11:14 FAX 2024935142 FAA + DMS 0001/007 

O 

U.S. Department Southern Region P.O. Sox 20636 

of Transportation Office of the Regional Counsei Atlanta, Georgia 30320 

Federal Aviation (404) 305-5200 

Adminislration (404) 305-5223 FAX 

- a MAR 2 9 2011 " J 

CERTIFIED - RETURN RECEIPT REOUHS TRP '^^ '^^,Oi^ 

Hearing Docket Clerk "^J ^S" * 

FAA, AGC.430, Suite 2WiO00 ro O^* ? 

Wilbur Wright Building CD V^ 

SCO Independence Avenue, SW "" 

Re: In the Matter of Dean Tniemational, lac. i—-N n r ^/\}i ht^i G 

FAACaseNo.2010SOl90256,2010SO190260 pOW S ' <:^0n^yO^ J 

Enclosed herewith please find a copy of a request for hearing and the original and one copy of 

the Complaint m. the above-referenced proceeding. 

The FAA requests that the iiearing in this matter be held in the Miami, Florida area, and expects 

that the hearing will last one day. 

Please address all conuBunicalions for the FAA to tlie undersigned, ai; 

Federal Aviation Administration 

Office of the Regional Counsel, ASO-7 

Southern Region 

P.O. Box 20636 

Atlanta, Georgia 30320 

Telephone: (404) 305-5200, facsimile (404) 305-5223. 

Sincerely, 

CHl^lSTOPHER R.^TEVENSON 

Attorney 

Office of the Regional Counsel 

Enclosures APR " [i 201J 

HEARING DOCKET 
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U.S. DEPARTMENT OF TRANSPORTATION 

OFFICK OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

FEDERAL AVIATION ADMINISTRATION, 

Complainant, 

vs. 

Dean IntemationaJ, Lie. 

Respondent. 

FAA Docket No. 

Judge 

JUDGE NOT YET ASSIGNED 

COMPLAINT 

The Federal Aviation Administration (FAA)» by counsel, hereby files its Complaint, 

pursuant to Rule 208 of the Rules of Practice (14 CF.R. 13.208), and slates as follows: 

I. 

1. On March 15, 2011, Respondent, Dean International, Inc. was advised through a 

Final Notice of Proposed Civil Penalty ihat the FAA proposed to assess a civil penalty in the 

amount of S21,450. On March 24, the Agency Attorney received a written request for a hcarinj^ 

from ihc Respondent. 

II. 

2. AL all times material herein Dean International was and is now the holder of Air^ 

Agency (Flight School) Certificate No. D4R$706K. 

3. a. On or about February 28, 2010, Dean International operated civil aircraft 

N6348B,aCE-152. 

b. Dean International also operated N6348B on March 1, 2010 

c. Dean International also operated N634B on April 22, 2010. 

4. FUglit instruction was given during each of these operations of N6348B. 
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5. At the time of these operation, neither an aimual nor 100-hour mspecLion had been 

completed on N6348B within the proceeding 100 hours of lime in service. 

6. a. Airworthiness Directive (AD) 87-20-03 R2 is applicable to N6348B. 

b. AD 87-20-03 R2 requires an inspection every 100 hours of time in service. 

c. At the time of the abovc^rcferenced operations, the inspection required by 

AD 87-20-03 R2 had not been performed on N6348B in the proceeding 

100 hours. 

d. At the time of the operation on May 8, 2010, N634SB was noi in 

airworthy condition by reason of Jion-complianee with the AD. 

7. On or about May 8 2010, Dean International operated civil aircraft N527f)M, a 

CE-152. 

8. Flight instruction was given during this operation of N5276M. 

9. At the time of this operation, neither an annual nor 100-hour inspection had been 

completed on N527ftM within the proceeding 100 hours of time in service. 

10. a. Airworthiness Directive (AD) 87-20-03 R2 is applicable to N5276M. 

b. AD 87-20-03 R2 requires an inspection every 100 hours of time in service. 

c. At the time of the above-referenced operation, the inspection required by 

AD 87-20-03 R2 had not been perfonmed on N5276M in Lhe proceeding 

100 hours. 

d. At the time of the operation on May 8, 2010, N5276M was not in an 

airworthy condition by reason of non-compliance with the AD. 

m. 

11. By reason of the foregoing facts and circumstances, Respondent violated the 

tbllowing sections of the Federal Aviation Regulations: 

a. Section 38.7 in that no person may operate a product that does not meet 

the requirements of an applicable airworthiness directive. 

b. Section 91.7(a) in that no person may operate a civil aircraft unless it is in 

an airworthy condition. 
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c. Section 91.409(b) m that except as provided in paragraph (c) of this 

section, no person may operate an aircraft carrying any person (other than a crewmembcr) for 

hire, and no person may give flight instruction for hire in an aircraft which tliat person provides, 

unless within the preceding 100 hours of time in service the aircraft has received an annual or 

100-hour inspection and been approved for return to service in accordance with part 43 of this 

chapter or has received an inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter. 

12. Pursuant to 49 DS C Sections 46301 (a)-(d), Restiondent is subject to a civil 

penalty not to exceed $11,000 for each of the violations alleged. 

13. Under the facts and circumstances of this case, a civil penalty of $21,450 is 

appropriate. 

WHEREFORE, the Agency, by counsel respectfully requests that Oic Administrative Law 

Judge enter an order that Respondent be assessed a civil penalty in the amount of $21,450. 

Respectfully submitted this ^ "^ day of March, 2011. 

CHRISTOPHER R. STEVENSON 

Attorney 

Office of the Regional Counsel 

PLEASE NOTE: 

Pursuant to Title 14 CFR Section 13.209(a), you are required to file a written answer to this 

Complaint, or a written Motion to Dismiss if appropriate* not later than 30 days after the date 

shown on the Certificate of Service which follows. 
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CERTTFTCATE OF SERVICE 

1 hereby certify that a copy of the foregoing Complaint has been mailed this date by Certified 

Mail, Return Receipt Requested, to the following: 

Stuart A. Goldstein, Esq. 

Goldstein 6c Sordo 

9350 South Dixie Highway 

Tenth Floor 

Miami. FL 33156 

Hearing Docket Clerk (original + 1 copy) 

FAA, AGC-430, Suite 2W1000 

Wilbur Wright Building 

800 Independence Avenue, SW 

Washington, DC 20591 

__JWL 2 9JSa 

Dated 
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^^ ^ 120002/0003 

03/24/JiOll H^dT FAX .-1056707055 ^ 

UNITED STATES OF AMERICA 

FEDERAL AVIATION ADMINISTRATION 

J. RANDOLPH BABBITT, ADMINISTRATOR 

FEDERAL AVIATION ADMINISTRATION. 

Complainant, FAA Case Nos: 

201 OSOl 90256 

V 2010SO190260 

DEAN INTERNATIONAL. INC., 

Respondent. 

RESPQNDEWrS HFAR[NG REQUEST 

Respondent, DEAN INTERNATIONAL, INC., ("Dean"), by and through Ks 

uodersigned attorneys, pursuant to 14 CFR §13.16 and 14 CFR §13.210, herewith 

requests a hearing on the Administrator's Final Notice of Proposed Civil Penalty dated 

March 15,2011. 

CERTIFlCATF^FffF"V'<^P 

I HEREBY CERTIFY, that on this 24th day of March, 20ii . the original and one 

copy of this Request was served via Federal Express on: Federal Aviation 

Administration. Hearing Docket. 600 Independence Avenue, S.W., Wilbur Wright 

Building, Suite 2W1000, Washington, D. C, 2059L attention Hearing Docket Cl^rk, 

AGC-430, and that a copy was served via facsimile (404) 305-5223 and regular U. S. 

Mail upon Christopher R. Stevenson, Esq., Office of the Regional Counsel, P. O. Box 

20636, Atlanta, GA 30320. 

LAW Office s OF QOLDSTtIN i SOflDO 

MSO SOUTH OiXIE mQHW*.Y. lOTH PLOOB. MIAMI. R, 33156 

T: (305)570-1222 F. (y>S) 670-7O6S 
04/21/2011 11:15 FAX 2024935142 

03/24/2011 14:47 FAX 305«707065 

FAA DMS @]007/007 

@10003/t)003 

Stuart A. Goldstein 

Law Offices of Gofdstein & Sordo 

9350 South Dixie Highway. 10th Floor 

Miami, FL 33156 

Tel: (305)670-1222 

Fax: (305) 670-7065 

Email: sQoldst219@aol.cQm 

Anorney for Respondent 

BV-JjJ^dJtM^ 

Stuarf A. Goldstein 

LAW OFFICES OF GOLDSfTFIN A SOflOO 

9350 SOUTH ow e HIGHWAY; lOTH FLOOfl. MIAMI, FL 331SS 

r I305)6TO-I2a2 F: (305) 670'toe5