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UNITED STATES OF AMERICAJiEM:;I G 

U.S. DEPARTMENT OF TRANSPORTATION •n "·· 

FEDERAL AVIATION ADMINISTRATION 

IN THE MATTER ) 

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DOCKET NO.: FAA-2015-0643 

OF 

MACH 1 AIR CHARTERS, INC. 

ASSIGNED TO 

DOUGLAS M. REWALD, ALJ 

FIRST AMENDED ANSWER TO 

COMPLAINT BY RESPONDENT 

______________________) 

COMES NOW the Respondent MACH 1 AIR CHARTERS, INC., individually, 

in answer to the complaint of the Administrator on file herein, for itself alone, and 

pursuant to 14 CFR §§13.16 AND 13.201 et seq. of the Rules of Practice, denies 

and alleges as follows: 

ALLEGATION I. 

This answering Respondent admits the allegations contained in Allegation 

of the complaint on file herein. 

ALLEGATION II. 

I. This answering Respondent admits the allegations contained in 

paragraph I, 2, 3 and 10 of the complaint on file herein. 

2. With respect to paragraph 9 Respondent admits that it operated an 

aircraft on May 12, 2014 but denies the wording "after the events referenced above" 

and by its admission does not admit the substance of the other allegations 

Pa e 1 

FIRST AMENDED ANSWER TO COMPLAINT 
incorporated in the wording by the Administrator and therefore specifically denies 

any facts incorporated by the wording set forth_ 

3. This answering Respondent denies the allegations of paragraphs 4, 

5, 6, 7, 8, 12 and 13, both generally and specifically, whether the allegation be 

express or implied. 

4_ This answering Respondent alleges that the allegations contained in 

paragraph 11 are ambiguous, incomplete confusing and therefore has insufficient 

information to either admit or deny the allegation_ On that basis, this answering 

Respondent must therefor deny the allegations, both generally and specifically, 

whether the allegation be express or implied_ 

ALLEGATION Ill. 

1_ This answering Respondent denies the allegations contained in 

paragraph I, 2, and 3 of Allegation IlL of the complaint on file herein, both generally 

and specifically, whether the allegation be express or implied, and further denies 

that this answering Respondent violated any Federal Aviation Regulation(s). 

FIRST AFFIRMATIVE DEFENSE 

This answering Respondent is informed and believes and thereon alleges 

that the complaint, and that each purported cause of action stated therein, fails to 

state facts sufficient to constitute a cause of action against this answering 

Respondent 

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FIRST AMENDED ANSWER TO COMPLAINT 
SECOND AFFIRMATIVE DEFENSE 

This answering Respondent is informed and believes and thereon alleges 

that safety in air commerce and the public interest do not require the imposition of 

a civil penalty against this certificate holder. 

THIRD AFFIRMATIVE DEFENSE 

This answering Respondent is informed and believes and thereon alleges 

that the pleading is uncertain, ambiguous and unintelligible. 

FOURTH AFFIRMATIVE DEFENSE 

This answering Respondent is informed and believes and thereon alleges 

that the appropriate Federal Aviation Regulations authorize the actions of the 

Respondent as set forth herein. 

FIFTH AFFIRMATIVE DEFENSE 

This answering Respondent is informed and believes and thereon alleges 

that there were no airworthy issues involving the aircraft and that the aircraft was 

operated in an airworthy condition at all time. 

WHEREFORE, Respondent prays that the Administrator take nothing by its 

complaint, that the same be dismissed, that Respondent be awarded his attorney's fees 

and costs and for such other relief as the Administrative Law Judge of the Office of 

Hearings deems proper. 

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FIRST AMENDED ANSWER TO COMPLAINT 
DATED: September 28, 2016 

STEVEN L. GRAFF, INC. 

A Professional Law Corporation 

by~~1-Jl STEVEN L. GRAFF v \j J 

43399 Cal]g~!ardo 

Temecula, CA'-92092 

(951) 303-6400 tel 

aviationcounsel@aol.com 

Attorney for Respondent 

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FIRST AMENDED ANSWER TO COMPLAINT 
CERTIFICATE OF SERVICE 

I hereby certify that I have this day, placed in the United States mail, postage prepaid, 

the original and copy of the FIRST AMENDED ANSWER TO COMPLAINT addressed 

to: 

FEDERAL AVIATION ADMINISTRATION 

The Hearing Docket, AGC-430 

Wilber Wright Building - Room 2W1 000 

800 Independence Avenue, S.W. 

Washington, D.C. 20591 

I further certify that I have this day, placed in the United States mail, postage prepaid, 

a copy of the FIRST AMENDED ANSWER TO COMPLAINT addressed to: 

GLENN H. BROWN, ESQ. 

Office of the Regional Counsel 

FEDERAL AVIATION ADMINISTRATION 

222 W. 7TH Avenue #14 

Anchorage, Alaska 99513-7586 

Pa e 5 

FIRST AMENDED ANSWER TO COMPLAINT 
September 28, 2016 

43399 Calle De Velardo 

Temecula, CA 92592 

(951) 303-6400 tel. - (951) 303-0723 fax 

Aviationcounsel@aol.com 

FEDERAL AVIATION ADMINISTRATION 

The Hearing Docket, AGC-430 

Wilber Wright Building - Room 2W1 000 

800 Independence Avenue, S.W. 

Washington, D.C. 20591 

Re: FAA adv. MACH ONE AIR CHARTERS, INC. 

FDMS NO.: FAA-2015-0643 

TRANSMITTAL COVER SHEET 

The enclosed documents are for your file and/or appropriate action.