U.S. Department 

of Transportation 

Federal Aviation 

Administration 

Southern Region 

Office of the Regional Counsel 

CERTIFIED- RETURN RECEIPT REQUESTED 

Hearing Docket Clerk 

FAA, AGC-430, Suite 2Wl 000 

Wilbur Wright Building 

800 Independence Avenue, SW 

Washington, DC 20591 

Re: In the Matter of Professional Flight Transport Inc. 

FAA Case No. 2014S0190149 

P.O. Box 20636 

Atlanta, Georgia 30320 

(404) 305-5200 

(404) 305-5223 FAX 

RECEIVED 

MAY 11 2015 

HEARING DOCKET 

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 the Miami Florida area, and expects 

that the hearing will last two days. 

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

Federal Aviation Administration 

Office of the Regional Counsel, AS0-7 

Southern Region 

1701 Columbia Avenue 

College Park, GA 30337 

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

DEL TRICK H JOHNSON 

Attorney 

Office of the Regional Counsel 

Enclosures 
U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

FEDERAL AVIATION ADMINISTRATION, 

Complainant, 

vs. 

Professional Flight Transport, Inc. 

Respondent. 

JUDGE NOT YET ASSIGNED 

FAA Docket No. 

Judge 

COMPLAINT 

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

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

I. 

1. On April!, 2015, Respondent, Professional Flight Transport, Inc. d/b/a Windsor Jet 

Management (Windsor) was advised through a Final Notice of Proposed Civil Penalty 

that the FAA proposed to assess a civil penalty in the amount of$11,000. On April22, 

2015, the Agency Attorney received a written request for a hearing from the Respondent. 

II. 

2. At all times material herein Respondent, Professional Flight Transport Inc., doing 

business as, Windsor Jet Management (Windsor) was and is now the holder of Air 

Carrier Certificate No. XPTA138K. 

3. At all times material herein, Windsor's Operations Specifications authorized Windsor to 

conduct flights under Part 135 of the Federal Aviation Regulations. 

4. On or about March 10,2014, Windsor operated N962SS, Gulfstream G-IV. 

5. The above-described flight consisted of the following segments: 

a. Opa-Locka Executive Airport (KOPF) to St. John's International Airport 

(CYYT); and, 
b. St. John's International Airport (CYYT) to Bucharest Aurel Vlaicu International 

Airport (LRBS). 

6. The above-described flight consisted of a flight crew of two pilots. 

7. Per the definition of "Flight Time" in 14 CPR § 1.1, flight time means pilot time 

that commences when an aircraft moves under its own power for the purpose of flight 

and ends when the aircraft comes to a rest after landing. 

8. According to the flight log for the above-described flight, the KOPF to CYYT 

flight segment consisted of 4.2 flight hours. 

9. According to the flight log for the above-described flight, the CYYT to LRBS 

flight segment consisted of 7.4 flight hours. 

10. According to the flight log for the above-described flight, Windsor operated 

N962SS a total for 11.6 flight hours. 

11. The above-described 11.6 flight hours occurred during a consecutive 24-hour time 

period. 

12. Prior to departure of CYYT, Windsor knew that the flight from CYYT to LRBS 

would be more than 5.8 flight hours. 

13. Windsor's operation of N962SS on a Part 135 on-demand passenger flight in 

excess of flight duty limits was careless or reckless so as to endanger the life or property 

of another. 

III. 

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

following sections of the Federal Aviation Regulations: 

a. Section 91.13(a) in that no person may operate an aircraft in a careless or 

reckless manner so as to endanger the life or property of another. 

b. Section 135.267(b)(2) in that except as provided in paragraph (c) of this 

section, during any 24 consecutive hours the total flight time of the assigned 

flight when added to any other commercial flying by that flight crewmember 

may not exceed 10 hours for a flight crew consisting of two pilots qualified 

under this Part for the operation being conducted. 
c. Section 135.267(e) in that when a flight crewmember has exceeded the daily 

flight time limitations in this section, because of circumstances beyond the 

control of the certificate holder or flight crewmember (such as adverse 

weather conditions), that flight crewmember must have a rest period before 

being assigned or accepting an assignment for flight time of at least- (1) 11 

consecutive hours of rest if the flight time limitation is exceeded by not more 

than 30 minutes; (2) 12 consecutive hours of rest if the flight time limitation is 

exceeded by more than 30 minutes, but not more than 60 minutes; and (3) 16 

consecutive hours of rest if the flight time limitation is exceeded by more than 

60 minutes. 

Pursuant to 49 U.S.C. Sections 46301(a)-(d), Respondent is subject to a civil penalty not to 

exceed $1,100 for each of the violations alleged. 

Under the facts and circumstances of this case, a civil penalty of $11,000 is appropriate. 

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

Judge enter an order that Respondent be assessed a civil penalty in the amount of $11,000. 

Respectfully submitted this 5 day of May, 2015. 

DE~ 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. 
CERTIFICATE OF SERVICE 

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

Mail, Return Receipt Requested, to the following: 

Professional Flight Transport, Inc. 

DBA Windsor Jet Management 

Lilley James, Agent for Service 

Executive Airport Business Center 

1835 S. Perimeter Rd. Suite 120 

Ft. Lauderdale, FL 33309 

Hearing Docket Clerk 

FAA, AGC-430, Suite 2W1000 

Wilbur Wright Building 

800 Independence Avenue, SW 

Washington, DC 20591 

Mark Goldstein, P.A. 

2700 N. Military Trail, Suite 130 

Boca Raton, FL 33431 

l(rrororu 

DONNA E. STANLEY 

~·~ Legal Assistant 'J 

~ J 

Dated 

(original + 1 copy) 
U.S. Department 

of Transportation 

Federal Aviation 

Administration 

April 22, 2015 

Mark B. Goldstein, P.A. 

2700 N. Military Trail 

Suite 130 

Boca Raton, Florida 334 31 

Office of the Chief Cou:1se! eoo Independence Ave., S.W. 

Washington, D.C. 20591 

Re: In the Matter of Professional Flight Transport, Inc .. FDMS No. FAA-2015-0638 

Dear Mr. Goldstein: 

The Hearing Docket has received your request for h,~aring in FAA Case No. 2014S0190149. 

We have assigned the above-referenced Federal Docket lv1anagemenl System (FDMS) number to 

this matter. Please include this FDMS number on a!l correspondence and on each document that 

you file with the Hearing Docket in this proceeding. No other docket number will be assigned. 

You will receive a letter from the Office of Hcanngs Gnce an administrative law judge is 

assigned to this case. 

FAA civil penalty actions are governed by the Rules of Practice, 14 C.F.R. §§ 13.16 and 13.201-

13.235. The Rules of Practice, as well as other useful intc>nnation about civil penalty 

proceedings and indexes of decisions issued by the Administrator, may be found at: 

http ://wv-.w .faa. gov I about/office org/h eadq ua 1.1!' rs _o li I cesiall c/ poI ad judi cation/ ag c400/ 

civil penalty/. 

Be advised that documents filed with the Hearing Docket will be available publicly through the 

following Internet website: http://www.reguLaliouguv[. if you plan to file a document 

containing information that should not be made publicly available, you should file a motion 

under 14 C.F.R. § 13.226. 

If you have any questions, please contact the Hearing Docket at (202) 267-0377. 

Sincerely, 

~~Q~ Hearing Docket Clerk, AGC-430 

"· . ;>\ 

\ \\\ 

. ' j \ 

Cc: Deitrick Johnson, FAA 
Mark B. Goldstein, P.A. 

ATTORNEY AT LAW 

April 9, 2015 

RECEIVED 

APR 14 2015 

HEARING DOCKET 

VIA U.S. CERTiFIED MAIL RETURN RECEIPT REQUESTED 

FEDERAL AVIATION ADMINISTRATION 

600 INDEPENDENCE A VENUE SW 

WILBUR WRIGHT BUILDING, SUITE 2W1000 

WASHINGTON, DC 20591 

ATTENTION HEARING DOCKET CLERK, AGC 430 

Re: 2014S0190149-Professional Flight Transport, Inc. 

Gentlemen: 

We represent Professional Flight Transport, Inc. 

Request is hereby made for a hearing concerning the above-referenced matter. 

If you should have any questions or comments concerning the foregoing, please feel free to contact 

me so that we may :discuss same. 

MBG:agw 

· Cc: Deitrick Johnson, Esquire (via electronic mail) 

Client (via electronic mail) 

2700 N. MILITARY TRAIL, Sum 130 • BOCA RATON, FLORIDA 33431 • TELEPHONE (561) 989-9955 'FACSIMILE (561) 989-9966 

mbg@bizavlaw.com • www.bizavlaw.com