In the Matter of: 

ECEIVED 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS MAY- 1 2015 

FEDERAL AVIATION ADMINISTRATIONCiL.nhiNG DOCKET 

Served: April27, 2015 

Docket No. FAA-2015-0636 

FAA Case No. 2014CE070023 

Triumph Accessory Services 

The Honorable Richard C. Goodwin, 

Administrative Law Judge 

NOTICE OF APPEARANCE AND RESPONDENT'S ANSWER TO COMPLAINT 

Pursuant to 14 CPR§ 13.204, MarshallS. Filler of the law firm ofObadal, Filler, MacLeod & 

Klein, P.L.C. hereby enters his appearance as counsel for Respondent in this matter. 

Additionally, pursuant to 14 CPR§ 13.209, Respondent hereby answers the Complaint of the 

Federal Aviation Administration ("FAA'') as follows: 

ANSWER TO COMPLAINT 

I. 

1. Respondent admits receiving a Notice of Proposed Civil Penalty dated December 5, 

2014. Respondent admits to making a written request for a hearing on March 17,2015. 

II. 

1. Respondent admits to holding Air Agency Certificate Number OB2R051L. 

2. Respondent admits that on or about December 17, 2012, VAS Aero Systems, LLC (VAS) 

sent to Respondent a LG Truck Positioner Assembly, part number 273T61 01-9, serial 

number 024 for overhaul. Respondent lacks sufficient facts to admit or deny the 

remaining allegations in this paragraph. 

3. Respondent denies the allegations in paragraph 3. 

4. Respondent admits that the repair order cited in this paragraph instructed Respondent to 

perform an overhaul "I/A/W the latest OEM CMM instructions." 

5. Respondent admits that on January 22,2013 it issued FAA Form 8130-3 stating that it 

overhauled the LG Truck Positioner Assembly in question and returned it to VAS. 

Respondent denies the remaining allegations in paragraph 5. 

6. Respondent denies the allegations in paragraph 6. 

7. Respondent denies the allegations in paragraph 7. 

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8. Respondent denies the allegations in paragraph 8. 

9. Respondent denies the allegations in paragraph 9. 

10. Respondent denies the allegations in paragraph 10. 

11. Respondent denies the allegations in paragraph 11. 

12. Respondent denies the allegations in paragraph 12. 

13. Respondent denies the allegations in paragraph 13. 

14. Respondent denies each of the allegations described in paragraph 14 in their entirety. 

a. Respondent denies the allegations in subparagraph (a). 

b. Respondent denies the allegations in subparagraph (b). 

c. Respondent denies the allegations in subparagraph (c). 

d. Respondent denies the allegations in subparagraph (d). 

III. 

1. Respondent denies each of the allegations described in paragraph 1. 

a. Respondent denies the allegations in subparagraph (a). 

b. Respondent denies the allegations in subparagraph (b). 

c. Respondent denies the allegations in subparagraph (c). 

d. Respondent denies the allegations in subparagraph (d). 

e. Respondent denies the allegations in subparagraph (e). 

f. Respondent denies the allegations in subparagraph (f). 

2. Respondent denies that it is subject to a civil penalty in any amount. 

3. Respondent denies that a civil penalty is appropriate. 

WHEREFORE, Respondent requests that the FAA's claims against it be dismissed with 

prejudice. 

Dated at Alexandria, VA, this 27th day of April, 2015. 

Respectfully submitted, 

Marshall S. Filler 

Counsel for Triumph Group Operations, Inc. 

d/b/a Triumph Accessory Services 

Obadal, Filler, MacLeod & Klein, P.L.C. 

117 North Henry Street 

Alexandria, VA 22314-2903 

Telephone: (703) 299-0784 

Facsimile: (703) 299-0254 

E-Mail: marshall.filler@potomac-law.com 

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CERTIFICATE OF SERVICE 

I, Ebony Evans, hereby certify that I have on this date sent by U.S. Mail, postage prepaid, 

certified return-receipt requested, the original and one copy of the foregoing Notice of 

Appearance and Respondent's Answer to Complaint, addressed to: 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building-Suite 2W1 000 

In addition, I hereby certify that I have on this date sent by U.S. Mail, postage prepaid, 

certified return-receipt requested, one copy of the foregoing document to the following 

addressees: 

Jeffrey D. Frisbee, Respondent 

President and CEO 

Triumph Group Operations, Inc. dfb/a Triumph Accessories Services 

899 Cassatt Road, Suite 210 

Berwyn, PA 19312 

Mark G. Camacho, Complainant's Counsel 

Federal Aviation Administration 

Office of Regional Counsel, Central Region, ACE-7 

901 Locust, Room 506 

Kansas City, MO 64106-2641 

TEL: 816-329-3765 

The Honorable Richard C. Goodwin, Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. (Ell-310) 

Washington, DC 20590 

TEL: 202-366-5121 Staff Assistant 

FAX: 202-366-7536 

Dated: April27, 2015 

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