ALAN ARMSTRONG 

ATTORNEY AT LAW 

2900 CHAl>i:BLEEMTUCKER ROAD 

(770) 451-0313 

FAX (770) 451-0317 

Office of the Chief Counsel 

ATTN: FAA Part 16 Docket Clerk 

AGC-600 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

BUILDING 5, SUITE 350 

ATLANTA, GEORGIA 30341 

November 17,2014 

Re: Flightline Ground, Inc. v. Louisiana Department 

of Transportation and Development, et ai 

Docket No. 16-11-0 I 

Dear Sir/Madam: 

alan@alanarmstronglaw.com 

www.alanarmstronglaw.com 

Via FedEx 

Enclosed please find an original and four copies Complainant's Continuing and Restated 

Objection to Complete Due Process Breakdown at the FAA. Please file the document and return 

one copy stamped "filed" in the envelope provided. 

Thank you for your attention in this matter. 

AA/kjw 

Enclosures 

cc: Gerard Metzger, Esq. 

Brandon Brown, Esq. 

J.E. Murdock, III, Esq. 

Best regards, 
UNITED STATES OF AMERICA 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. 

FLIGHTLINE GROUND, INC., d/b/a 

FLIGHTLINE FIRST, 

Complainant, 

v. 

LOUISIANA DEPARTMENT OF 

TRANSPORTATION AND 

DEVELOPMENT, AS SUCCESSOR TO 

THE LOUISIANA DIVISION OF 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

ADMINISTRATION and THE BOARD OF ) 

COMMISSIONERS FOR THE MANAGEMENT) 

OF THE LAKEFRONT AIRPORT; ) 

NON-FLOOD PROTECTION ASSET ) 

MANAGEMENT AUTHORITY, AS ) 

SUCCESSOR TO THE BOARD OF ) 

COMMISSIONERS OF THE ORLEANS ) 

PARISH LEVEE DISTRICT and ORLEANS 

PARISH LEVEE DISTRICT, DIVISION OF 

NON-FLOOD ASSETS, 

Respondents. 

) 

) 

) 

) 

) 

DOCKET N0.16-ll-Ol· 

COMPLAINANT'S CONTINUING AND RESTATED OBJECTION TO COMPLETE 

DUE PROCESS BREAKDOWN AT THE FAA 

COMES NOW, Flightline Ground, Inc., d/b/a Flightline First (hereinafter "Flightline" or 

"Complainant"), Complainant in the above-captioned matter, pursuant to the Fifth Amendment to the 

Constitution of the United States of America, and 49 USC §4(/IIO(d), and objects to the FAA's failure, 

once again, to issue a fimll order; and in amplification of the foregoing, Complainant shows as follows: 

I. Complainant incorporates herein by this reference Complainant's Objection to Complete 

Breakdown of Due Process of the FAA- Death by Neglect, filed October 10,2014, as if each and 

every word in the foregoing Objection were set forth herein verbatim. 

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2. On October 10,2014, the same date of filing Respondent's last Objection, the Administrator 

declared: " ... pursuant to Part 16, Subpart B, the date by which the final Agency decision will be 

issued in this matter is hereby extended to November 7, 20 14." 

3. As of today, November 17, 2014, the Complainant has not received a fmal Agency decision. 

4. Complainant objects, on due process grounds, of this persistent and ongoing activity of the 

Administrator in failing to meet deadlines required by statute and regulation and in failing to meet 

the Administrator's own self-imposed deadlines. The Administrator's actions make a mockery of 

due process. 

Respectfully submitted this~ day of November, 2014. 

2900 Chamblee Tucker Road 

Building 5, Suite 350 

Atlanta, GA 30341 

P: 770-451-0313 

F: 770-451-0317 

alan@alanarmstronglaw.com 

Alan Armstr g / 

GA Bar No. 02207 _?/ 

Counsel for Complainant, Flight line 

Ground 

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CERTIFICATE OF SERVICE 

I, the undersigned, do hereby certify that I have this day served the Complainant in the 

foregoing matter with the foregoing COMPLAINANT'S CONTINUING AND RESTATED 

OBJECTION TO COMPLETE DUE PROCESS BREAKDOWN AT THE FAA via Federal 

Express to all counsel of record: 

Brandon Brown, Esq. 

Louisiana DOT 

1201 Capital Access Road 

Office S304/S305 

Baton Rouge, LA 70804 

Attorney for Louisiana Department of 

Transportation 

J.E. Murdock III, Esq. 

5034 Nebraska Avenue 

Washington, DC 20008 

Attorney for Non-Flood Protection 

Management Authority 

Gerard G. Metzger, Esq. 

Charles T. Curtis, Jr., Esq. 

Gerald G. Metzger APLC 

829 Baro:nne Street 

New Orleans, LA 70113 

Attorneys for Non-Flood Protection 

Management Authority 

Respectfully submitted this the 17'h day of November, 2014. 

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