MARK A 0 T T 0; J D ::r;, 7 t. !~' f (., lO J\D~:~f OTTO, JD LUCAS W OTTO, JD 

May 9, 2012 

,. i ~ ' . ' ' ., 

CERTIFIED MAIL-RETURN RECEIPT REQUESTED 

Certified Mail Receipt Nos. 70101670000189423825,70101670000189423818 and 70101670000189423788 

Hearing Docket 

Federal Aviation Administration 

800 Independence A venue SW 

Washington DC 20591 

AT1N: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building, Room Suite 2W1 000 

RE: In the Matter of Keystone Laboratories 

Case No. 2009CE700105 

Enclosed herewith please find the original and one copy of the Respondent's Answer to 

Complaint in the above-referenced proceeding. 

The Respondent requests that the hearing in this matter be held in Kansas City, Missouri. 

Sincerely, 

Adam D. Otto 

ADO/hm 

Eries. A ~.' ! : ,. 

Cc: Gayle E. Townsend, Complainant's Counsel 

Attorney, Office of Regional Counsel 

Central Region, ACE-7 

Federal Aviation Administration 

Room 506, DOT Building 

901 Locust 

Kansas City, MO 64106-2641 

RECEIVED 

MAY 1 7· 2012 

HEARING DOCKET 

W W W. 0 T T 0 LAWYERS. C 0 M 

P.O. BOX 1356 123 WEST SECOND STREET NORTH NEWTON, IOWA 50208 

P: 641.792.7000 F: 641.792.7001 
The Honorable Richard C. Goodwin, Administrative Law Judge 

Office ofHearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. (E11-310) 

Washington DC 20590 
RECEIVED 

U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION MAY f 7 2012 

HEARING DOCKET 

IN THE MATTER OF 

KEYSTONE LAB ORA TORIES 

FAA DOCKET NO. [TO BE ASSIGNED] 

FAA CASE NO. 2009CE700105 

FDMS NO. F AA-2012-0203 

JUDGE RICHARD C. GOODWIN 

ANSWER TO COMPLAINT 

Respondent Keystone Laboratories, by counsel, states the following in answer to the 

Complaint filed by the Agency: 

I. 

1. Keystone Laboratories ADMITS the allegations set forth in Paragraph 1 of this 

Section. 

II. 

1. Keystone Laboratories ADMITS the allegations set forth in Paragraph 1 of this 

Section. 

2. Keystone Laboratories DENIES the allegations set forth in Paragraphs 2 through 

4 of this Section. 

III. 

1. Keystone Laboratories DENIES the allegations set forth in Paragraphs 1 through 

3 of this Section. 

WHEREFORE, Respondent Keystone Laboratories, by counsel, respectfully requests that 

the Administrative Law Judge dismiss the Agency's complaint, with costs taxed to the Agency, 

and grant such other and further relief as maybe appropriate in the premises. 
Dated this 9th day of May, 2012. 

By: 

Respectfully submitted, 

Ad . Otto 

123 W 2nct St. N 

PO Box 1356 

Newton, IA 50208 

Phone: (641) 792-7000 

Fax: (641) 792-7001 

adam@ottolawyers.com 

Attorneys for Respondent 
Keystone Laboratories, FAA Case No. 2009CE700105 

CERTIFICATE OF SERVICE 

I hereby certify that I have this date placed in the United States mail, certified, return 

receipt requested, a copy of this Answer, addressed to: 

Gayle E. Townsend, Complainant's Counsel 

Attorney, Office of Regional Counsel 

Central Region, ACE-7 

Federal Aviation Administration 

Room 506, DOT Building 

901 Locust 

Kansas City, MO 64106-2641 

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 

In addition, I hereby certify that I have this date placed in the United States mail, 

certified, return receipt requested, the original and one copy, addressed to: 

Federal Aviation Administration 

800 Independence A venue, SW 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-401Wi30 

Wilbur Wright Building, Suite 2W1000 

\v ' ..... ' 

Adam D. Otto 

Attorney for Respondent 

Dated this 9th day ofMay, 2012.