o 

U.S. Department 

Of Transportation 

Federal Aviation 

Administration 

Office of Regional Counsel 

Northwest Mountain Region 

Colorado, Idaho, Montana, 

Oregon, Utah, Washington, 

Wyoming 

1601 Lind Avenue S.W. 

Renton, Washington 98057 

Tel: (425) 227-2161 

Fax:(425)227-1007 

JEFFREY.HARPER@FAA.GOV 

May 26, 2011 

VIA FACSIMILE AND CERTIFIED MAIL - RETURN RECEIPT REQUESTED 

: O C 

Attn: Hearing Docket Clerk, AGC-430 

Hearing Docket 

Federal Aviation Administration 

Wilbur Wright Bldg - Room 2W1000 -:: 

800 Independence Avenue Southwest '-' ^• 

Washington, D.C. 20591 

Re: In the Matter of Cornerstone Aviation, Inc., Case No. 2011NM070021 /'^' ^ P^t^f^'CfP' /StV 

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

Complaint in the above-referenced proceeding. 

The FAA requests that the hearing in this matter be held in Salt Lake City, Utah and expects that 

the hearing will last one (1) day. Unavailability dates for the undersigned in 2011 for military duty 

are: May 20 through 23, June 23 through 27, July 8 through 11, August 5 through 8, and 

September 9 through 12. 

Please address all communications for the FAA to the undersigned at: 

Federal Aviation Administration 

Northwest Mountain Region, ANM-7 

1601 Lind Avenue Southwest 

Renton, Washington 98057 

Telephone: (425)227-2161 

FAX: (425)227-1007 

Sincerely, 

Jefjp-eviM. Harper 

FAA Attorney 

Enclosures: Request for Hearing 

Complaint 

^^CEIV£{} 

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JEFFREY M. HARPER 

FAA OFFICE OF REGIONAL COUNSEL 

1601 LIND AVE. SW. 

RENTON, WA 98057 

TELEPHONE: (425)227-2161 

FACSIMILE: (425) 227-1007 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of: 

Cornerstone Aviation, Inc. 

FAA DOCKET Not Assigned 

FAA Case No. 2011NM070021 

Judge Not Assigned 

JUDGE NOT ASSIGNED 

COMPLAINT 

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

pursuant to Rule 208 of the Rules of Practice (14 C.F.R. § 13.208), and states as follows: 

I. 

On May 13, 2011, Cornerstone Aviation, Inc. was advised through a Final Notice of 

Proposed Civil Penalty that the FAA proposed to assess a civil penalty in the amount of 

$5,000. On May 18, 2011, Cornerstone Aviation, Inc. submitted a written request for a 

hearing. 

II. 

1. Cornerstone Aviation, Inc. (Cornerstone) is now and was at all times material hereto the 

holder of Air Agency Certificate No. QN7S767K, and conducts its operations pursuant to 

Part 141 of the Federal Aviation Regulations (FAR). 

2. Cornerstone's Authorized Courses of Training record permits it to conduct training for 

the Instrument - Airplane rating. 

Complaint 

Cornerstone Aviation, Inc. • 

Page 1 of 5 

20nNM070021 

JEFFREY M. HARPER, FAA ATTORNEY 

TEL: (425) 227-2161; FAX: (425) 227-1007 
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Cornerstone is authorized to provide training referenced above, using the Jeppesen 

Sanderson, Inc. Instrument / Commercial Course Syllabus (the syllabus). 

4. The syllabus requires students to complete 30.0 hours of ground training. 

5. Ms. Haley A. Wilson was enrolled in the Instrument - Airplane rating course of training 

on June 10, 2010. She did not receive credit for any prior instrument airplane rating 

ground training. 

Ms. Wilson's logbook does not show that she received any ground training 

required by the syllabus. 

Ms. Wilson's Cornerstone Part 141 records do not show that she received any 

ground training required by the syllabus. 

Cornerstone issued Ms. Wilson a graduation certificate on November 17, 2010, 

certifying that she had completed all course requirements for the Instrument - Airplane 

course of training. 

III. 

By reason of the foregoing circumstance(s). Cornerstone violated the following 

Sections of the Federal Aviation Regulations (14 C.F.R.): 

a. Section 141.77(a)(1), in that it issued a graduation certificate to a student who had 

not completed the training specified in its course of training. 

b. Section 141.77(b), in that it graduated a student who had not completed all of the 

curriculum requirements. 

c. Section 141.83(a)(1), in that it did not comply with its approved training course. 

d. Section 141.101 (a), in that it did not maintain current and accurate records of the 

participation of a student enrolled in an approved course of training. 

2. Under 49 U.S.C. §§ 46301 (a) and (d). Cornerstone Aviation, Inc. is liable for a civil 

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

3. Under the facts and circumstances of this case, a civil penalty of $5,000 is appropriate. 

Complaint 

Cornerstone Aviation, Inc. - 2011NM070021 

Page 2 of 5 

JEFFREY M. HARPER, FAA ATTORNEY 

TEL: (425) 227-2161; FAX: (425) 227-1007 
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WHEREFORE, the Agency, by counsel, respectfully requests that the Administrative 

Law Judge enter an order that Cornerstone Aviation, Inc. be assessed a civil penalty in the 

amount of $5,000. 

Respectfully submitted this 26th day of May, 2011. 

Complaint 

Cornerstone Aviation, Inc. - 2011NM070021 

Page 3 of 5 

JEFFREY M. HARPER, FAA ATTORNEY 

TEL: (425) 227-2161; FAX: (425) 227-1007 
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ANSWER 

In accordance with Section 13.209 of the Federal Aviation Regulations, Cornerstone Aviation, 

Inc. must answer this Complaint not later than 30 days from the time it is served on it. Failure to 

file an Answer within 30 days without good cause shall be deemed an admission of the truth of 

each allegation contained in the Complaint (14.C.F.R. § 13.209(f)). 

Complaint 

Cornerstone Aviation, Inc. - 2011NM070021 

Page 4 of 5 

JEFFREY M. HARPER, FAA ATTORNEY 

TEL: (425)227-2161; FAX: (425)227-1007 
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CERTIFICATE OF SERVICE 

I hereby certify that the foregoing Complaint has been served via facsimile and certified mail 

Return Receipt Requested this date, to the following: 

Federal Aviation Administration 

800 Independence Ave. SW. 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building - Suite 2W1000 

Fax: 202. 493.5142 

I also certify that the foregoing Complaint has been served via Regular and Certified Mail -

Return Receipt Requested this date, to the following: 

Susan Horstman 

Chief Executive Officer 

Cornerstone Aviation, Inc. 

337 North 2370 West #130 

Salt Lake City, UT 84116 

TEL: (801)355-2244 

Dated this 26th day of May, 2011. 

MOIFAIR CHIN 

Office of Regional Counsel (ANM-7) 

Federal Aviation Administration 

1601 Lind Ave. SW. 

Renton, WA 98057 

(425)227-2160 

Complaint 

Cornerstone Aviation, Inc. - 2011NM070021 

Page 5 of5 

JEFFREY M. HARPER, FAA ATTORNEY 

TEL: (425) 227-2161; FAX: (425) 227-1007 
CORNERSTON E AVIATION 

FLIGH T SCHOOL S 

May 18,2011 

Federal Aviation Administration 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building - suite 2W1000 

800 Independence Avenue Southwest 

Washington, DC 20591 

To Whom It May Concern: 

I am requesting a hearing on a Civil Penalty matter, FAA Case No. 20nNM070021 along with the 

already requested hearing for another Civil Penalty matter, FAA Case No. 2011NM070022. I did not 

realize I had to identify both case numbers separately when I submitted the first request for a hearing. 

Please advise as to what are the next steps in this matter. 

Sincerely, 

Susan J. Horstman 

CEO 

Cornerstone Aviation 

shorstman(aicomerstoneaviation.com 

801-355-2244 

^ECEW/BD 

M : - ? 20)1 

f-fEARING DOCKET