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BAIRD, WILLIAMS & GREER, L.L.P. 

6225 NORTH 24"' STREET, SUITE 125 

PHOENIX, ARIZONA 85016 

TELEPHONE (602) 256-9400 

Daryl M. Williams (004631) 

6 darylwilliatnslalbwj:law.net Attorneys for Solid Edge ~viation 

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In the matter of: 

Solid Edge Aviation, Inc. 

IV ED 

1 8 2015 

HEARING DOCKET 

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FAA Case No. 2015WP910067 

Answer 

(Assigned to the Honorable Richard C. 

) Goodwin) 

12 Solid Edge Aviation, by counsel, answers the allegations of the FAA's complaints as 

13 follows: 

14 I. 

15 The allegations of this part of plaintiff's complaint are admitted. 

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1. 

2. 

3. 

4. 

5. 

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7. 

II. 

Admit. 

Admit 

Admit. 

Admit. 

Admit. 

Admit. 

With regard to Eric Brunner: 

a. Deny. 

b. Admit. 

c. Admit. 

d. Admit. 

e. Admit. 
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10. 

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1. 

2. 

With regard to Robert Grenga: 

a. Admit. 

b. 

c. 

Admit. 

Admit. 

d. Solid Edge admits that it did not obtain information from Era Helicopters 

until September 10,2014, but denies that it did not make a good faith effort 

to obtain this information. 

With regard to Henry Kowalski: 

a. Admit. 

b. Admit. 

c. Admit. 

d. Deny. 

With regard to Josh Mock: 

a. Admit. 

b. Admit. 

c. Admit. 

With regard to Charles Rush: 

a. Admit. 

b. Admit. 

c. Admit. 

III. 

The alleged facts and circumstances do in some instances show a violation 

of: 

a. 

b. 

Deny. 

Deny. 

As to the violations alleged in this paragraph: 

a. 

b. 

c. 

Admit that in some instances it had not obtained information from prior 

employees, but deny the balance of this paragraph. 

Deny. 

Deny. 

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Deny. 

Deny. 

AFFIRMATIVE DEFENSES 

Solid Edge Aviation is a small, family-owned business; and the founder and 

former head of this entity, Larry Brunner, recently diea. 

Solid Edge Aviation does not have the financial resources to pay the penalty 

proposed by the FAA; indeed, there is a high likliehood that assessment of 

this penalty would put Solid Edge out of business. 

a. 

b. 

c. 

The ordinary business income for Solid Edge Aviation is shown on its 2011 

tax return, was $24,956.00. 

Ordinary income in 2012 was $45,513.00. 

In 2013, it was $36,489.00. 

Solid Edge is entitled to relief under the Small Business Regulatory 

Enforcement Fairness Act of 1996. 

Solid Edge is a compliant operator that conducts safe operations. Violations 

have been unwitting, not willful, and corrections have fieen made so that 

Solid Edge will be compliant in the future. 

Solid Edge reasonably and in good faith believed its random drug pools 

were being populated with new hires by its employee security screening 

service, which maintains the random pool. 

Respectfully submitted this 5th day of August 2 

22 ORIGINAL mailed this 5th day 

of August 2015, to: 

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24 Federal Aviation Administration 

800 Independence Ave. Southwest 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

26 Wilbur Wright Building, Suite 2W1 000 

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COPY mailed/emailed this same day to: 

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1 The Honorable Richard C. Goodwin 

Office of Hearings, M-20 

2 US Department of Transportation 

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

3 Washington, DC, 20590 

Administrative Law Judge 

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J. M. Harper 

5 Federal Aviation Administration 

Office of Regional Counsel- ANM-7 

6 Northwest Mountain Region 

160 1 Lind A venue, Southwest 

7 Renton, WA 98057 

ieffrey.harperlalfaa.g:ov 

: CoTJ1Goud? Of&JJ 

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Business • T riols 

Aviation 

BAIRD WILLIAMS 

& GREERLLP 

Attorneys at Law 

Daryl M. Williams 

Darv!Wil/iams@bwqlaw.net 

Federal Aviation Administration 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building 

800 Independence A venue, Southwest 

Washington, DC 20591 

August 5, 2015 

6225 N. 24th Street, Suite 125 

Phoenix, Arizona 85016 

Toll Free: (800)251-8243 

Local: (602)256-9400 

Fox: (602)271-9308 

www.bwglaw.net 

600 Cameron Street, Suite 416 

Alexandria, Virginia 22314 

Toll Free: (800)251-8243 

Local: (703)217-9825 

Fax: (703)340-1642 

www.bwglaw.nel 

AUG 1 8 2015 

HEARING DOCKET 

Re: In the matter of Solid Edge Aviation, LLC, FAA Case No. 2015WP910067 

Enclosed find the original and one copy of our answer in this proceeding. 

Solid Edge Aviation requests that the hearing in this matter be held in Phoenix, Arizona, and 

expects the hearing will last one day. For scheduling purposes, Mr. Brunner of Solid Edge Aviation, 

LLC and his counsel, Daryl Williams, are generally available for the next year. However, Mr. 

Williams's calendar fills up quickly as the dates approach. The only blackout dates are for federal 

holidays and the dates below: 

DMW/dlc 

Enclosures 

August 26-September 4, 2015 

September 25-29,2015 

Aprill8-22, 2016 

cc: J.M. Harper