I. Glossary 

ASI 

C.P.R. 

FAA 

FAA# 

FAR 

FSDO 

Grace 

HNL 

KOA 

Monfort 

NPCP 

OGG 

OpSpecs 

SERVED: August 31,2015 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, DC 

·' ·.:·;.i.' 

IN THE1MATTER OF 

SCHUMAN AVIATION COMPANY, LTD. 

FAA DOCKET NO. [TO BE ASSIGNED] 

(Civil Penalty Action) 

FDMS NO. FAA 2013- 1080 

INITIAL DECISION OF ADMINISTRATIVE LAW JUDGE 

Aviation Safety Inspector 

Code ofFederal Regulations 

Federal Aviation Administration 

0 0 j ~~-~ • 

FAA Ex1¥b1t, ~~ ,, "i ... , , 

Federal Aviation Regulation 

Flight Standards District Office 

Darryl Grace, Director of Operations for Mokulele Airlines 

Honolulu, HI 

Kailua-Kana International Airport, Kona, HI 

Joseph Monfort 

Notice of Proposed Civil Penalty 

Kahului, Maui 

Operations Specifications 
f:O·;· 

r~ .. \· · i., 

S# Schuman Exhibit 

U.S.C. United States Code 

II. Introductory Comment 

Between September 8, 2012, and September 13,2008, Schuman Aviation Company, Ltd. 

(hereinafter "Schuman") operated out of Kailua-Kana International Airport, Kona, Hawaii 

(hereinafter "KOA"), an airport it was not authorized for scheduled operations by Schuman's 

OpSpecs C070-2. 

On or about September 1 7, 2012, the FAA requested to inspect Schuman's records 

regarding the above flights. Schuman initialJy refu§ed to make any records available, but \. 

,;.-

informed the FAA approximately two (2) hours later that Schuman would comply with the 

request. 

III. Procedural History 

The Federal Aviation Administration (hereinafter "FAA") advised the Respondent, 

Schuman Aviation Company, Ltd. (hereinafter "Schuman"") through a Notice of Proposed Civil 

Penalty and Final Notice of Proposed Civil Penalty that the FAA proposed to assess a civil 

penalty in the amount of $28,000.00. 

On February 5, 2014, Schuman submitted a written request for a hearing. 

The FAA filed its Complaint on February 12, 2014. 

Schuman answered the FAA's Conipll;lint,p:A'February 26,2014. 

IV. Hearing 

A hearing was held on December 4, 2014, in Honolulu, HI. 

The FAA was represented by Don Bobertz, Esq., FAA, Western-Pacific Region, Office 

of Regional Counsel, Los Angeles, CA. 

2 
Schuman was represented by Christopher D. Ferrara, Esq., Honolulu, HI. 

Post hearing briefs were filed by both parties. 

The matter is now ready for decision. 

V. Jurisdiction 

Schuman was at all times mentioned herein, the holder of Air Carrier Certificate No. 

MKHA108K, and authorized to conduct scheduled air carrier service under Part 135 of the 

Federal Aviation Regulations (hereinafter "FAR"s) and was subject to those regulations. 

VI. Burden of Proof 

The FAA was the petitioning party with the initial burden of proof (14 C.F.R. § 13.224). 

VII. Allegations 

A. FAA's recitation of facts 

1. Schuman was the holder of Air Carrier Certificate No. MKHA108K, authorized to 

conduct scheduled air carrier service under part 13 5 of the F ARs. 

2. Schuman's Operations Specificatiom{(liereHidfter "OpSpecs") C070, "Airports 

Authorized for Scheduled Operations" stated that Schuman was "authorized to conduct 

scheduled passenger and cargo operations between the regular, refueling, and provisional 

airports" only at the airports listed on C070-2. 

3. At all relevant times, Kailua-Kana International Airport, Kona, Hawaii (hereinafter 

"KOA"), was not an airport authorized for scheduled operations by Schuman's OpSpecs 

C070-2. 

4. Between September 8, 2012, and September 13, 2008, Schuman operated civil aircrafts 

N687MA and N865MA, both Cessna 208B aircraft on approximately twenty-four (24) 

round trip flights to KOA. 

3 
1 • 

. 5. On or about September 17, 2012, the FAA requested to inspect Schuman's records 

regarding the above flights. 

6. Schuman initially refused to make any records available, but informed the FAA 

approximately two (2) hours later that Schuman would comply with the request. 

7. On or about September 21, 2012, Shuman provided the requested records to the FAA. 

The FAA alleged by reason of the foregoing facts and circumstances, Schuman violated 

the following Sections of the F ARs (Title 14, Code of Federal Regulations (hereinafter "CFR"): 

14 C.FR. 119.5(g), which states that "[n]o person may operate as a direct air carrier or as 

a commercial operator without, or in violation of, an appropriate certificate and 

appropriate operations specifications." 

14 C.FR. 135.73, which states: :"Each.Ret1i5.Cifte holder and each person employed by the 

certificate holder shall allow the Administrator, at any time or place, to make inspections 

or tests (including en route inspections) to detemline the holder's compliance with the 

Federal Aviation Act of 1958, applicable regulations, and the certificate holder's 

operating certificate, and operations specifications." 

The FAA alleged, pursuant to Title 49 US. C. Section 46301, Respondent was subject to a 

civil penalty not to exceed $11,000.00 for each of the violations alleged. 

The FAA alleged, under the facts and circumstances of this case, a civil penalty of 

$28,000.00 was appropriate. 

B. Schuman's recitation of facts 

Schuman Answered: 

FIRST DEFENSE 

1. The Administrator's Complaint failed; tb~:sf~~~(;a cause of action upon which relief could 

be granted. 

SECOND DEFENSE 

2. Respondent admitted the allegations in paragraphs I; II, 1, 2, 3, 4 and 7 of the 

FAA's Complaint. 

4 
3. Respondent averred it was without knowledge of the actual date in the allegation 

contained in paragraph II, 5 of the FAA's Complaint, and therefore denied the same. 

4. Respondent denied the allegation contained in paragraph II, 6 ofthe FAA's Complaint. 

5. Respondent denied the applicability of:par~£_bph III, a and b and paragraph IV, 1 and 2 ' •. ..• { 

of the FAA's Complaint. 

THIRD DEFENSE 

6. Schuman intended to rely on any and all Affirmative Defenses that were available, the 

applicability of which might be determined and/or disclosed by investigation and/or 

discovery. 

VIII. Issues 

Did Schuman violate 14 C.FR. 119.5(g), and 14 C.FR. 135.73 ofthe FARs. 

If Schuman violated the above provisions ofthe C.F.Rs. was a fine of$28,000.00 

appropriate under the circumstances. .• 

,i, ' C:{:,,,r\~r.: 

IX. Summary of Testimony and Evidence J ·; 

All admitted testimonial and documentary evidence was reviewed and considered. Only 

brief highlights are summarized herein. 

A. FAA's Case 

Joseph Monfort1 

Joseph Monfort (hereinafter "Monfort") was employed by the FAA at the Honolulu 

(hereinafter ",HNL") Flight Standards District Office (hereinafter "FSDO") as an Aviation Safety 

Inspector (hereinafter "ASI") at the time of the alleged violations. He had been employed 

approximately five '(5) years. He had primary oversight of general aviation in the islands. 

. . . ~~- r~Y\-.··f~:.;·\' . . •. ... 

1 Tr. p. 9, I. 11 top. 32, I. 20 

5 
He was the principal operations inspector for Schuman and routinely conducted 

surveillance of all Part 13 5 operations. 

He was notified in September 2012 there were commuter operations conducted by 

Schuman at Kona airport. He reviewed the files for Schuman, verified that he did not have the 

operation specifications, "Charlie 070" (hereinafter "C070") to conduct commuter operations in 

to Kona, so he and Bartler2 went over to Schuman's office to find out what was going on. 

At the interview, when Monfort inquired about the operations, Schuman denied doing 

commuter operations. Schuman said he was doing "on-demand charter", and he could do as 

many as he wanted, as often as he want~d. Monfort reviewed C070, which was issued to 

Schuman as ofthe date of September 17,2012 (FAA# 1). Monfort pointed out that under 

operation specification C070, page two, there was a list of airport cities where Schuman was 

authorized to conduct commuter operations and Kona was not listed on that page. 

During the interview, when Monfort and Bartler mentioned that Schuman could not 

conduct commuter operations into Kona, Schuman disagreed, so Monfort and Bartler asked to 

see his maintenance logs, daily flight logs. At that point in time, Mr. Schuman said, no, I don't 

think so. Monfort testified he and Bartler said: 

... are you sure that's what you want to do? He says: Yeah, I don't think so, and he backed 

away from his desk. At that point in time, we got up and we walked out of the office. It 

was a very short meeting ... 

f ' \ • .,:· 

Monfort testified Schuman was under the impression he could do on-demand operations 

or charter operations from Mokulele Airlines and he believed that he could do that as often as he 

liked. 

Monfort testified, two hours later, Schuman called me, after contacting his lawyer, and he 

said the records would be made available to us. Schuman delivered the records to the FSDO 

2 Kyle Bartler, see ID below. 

6 
sometime later. 

Monfort reviewed FAA# 2 and 3. FAA# 2 was his statement, which was given limited 

weight because it was cumulative to the live testimony at the hearing. 

,, 

FAA# 3 was the daily flight logs or run sheets for the Cessna Caravan. The document 

showed the actual commuter flights that were conducted for Mokulele by Schuman with this 

aircraft. There were two (2) flights that day on the page one of eight, and it had the time periods, 

the actual aircraft hours, when they took off, when they landed, how much time was accumulated 

between each flight. These notations recurred on multiple pages. On page three of eight, it 

showed Kahului, Maui (hereinafter "OGG"), KOA, KOA, OGG. OGG. The records indicated 

operations between Kona and Maui. There were two different aircraft used 687 Mike Alpha and 

65 Mike Alpha. 

Once the FAA identified that the actual flights to Kona were done from Mokulele, the 

FAA requested records from Mokulele Airlines,3 to give the FAA their published schedule and 

which flights Schuman flew those published schedules for. The FAA received a document 

Darryl Grace4 (hereinafter "Grace") showing the actual commuter scheduled airline operations. 

FAA# 5 showed the flights were scheduled operations, which was the basis for a commuter 

airline. In other words, a ticket was sold for a certain time, from a certain airport to a certain 

place, just like you would go to an airline. When this operation was conducted on these days, it 

was a scheduled commuter operation. The flights that went between Kona and OGG were preplanned flights by Mokulele, which were conducted by Schuman Aviation. On page four of six, 

were the actual logs by the flight-locating system for Mokulele, and with the estimated time of 

departures and their estimated time of arrivals, and their actual times, inputted by an individual, 

' '· -- ) ~~ 

3 FAA# 4, Ltr. to Darryl Grace, Director of Operations for Mokulele 

4 FAA# 5. 

7 
when they landed and when they took off. The first two pages were the flights conducted by 

Schuman for Mokulele, and the pilot's name that conducted those flights from Schuman. 

Cross5 

Monfort had not been involved in management in prior employment. He was a line pilot. 

Schuman told Monfort he had amended the OpSpecs about four months prior to the 

inspection allowing Schuman to operate into Lahaina and Lanai. Schuman told Monfort he had 

been in the commuter business for over a year, a year and a half at the time, and he had 

previously amended the OpSpecs. Schuman principally operated from Mokulele into Lanai 

and Lahaina. Kalaupapa was a very small airport that was difficult to fly in, but the same 

requirements for the commuter operation existed at Kona as they did at Kalaupapa. The 

weather at Lanai was pretty much island weather, the same as everywhere. Kona was a 

single, very long runway airpprt. Monfort testified Schuman ultimately applied for and 

received OpSpecs allowing him to operate out of Kona. 

Schuman had asked to do on-demand operations for Mokulele in the past, and 

Monfort informed him that he had to have same operation specifications at Mokulele to 

support Mokulele commuter operations. Had Schuman asked me for the Kona route, 

Monfort would have gone through the catygori~al exclusion, requested an amendment to 

his operation specifications, and would have gone through the proper procedure to 

authorize him to conduct Kona operations, just like we did Lahaina and Lanai City. Had 

Monfort known that he was requesting to go to Kona, he would have started the process 

to issue him and go through the requirements to issue C070 into Kona. 

5 Tr. p. 34, 1. 5 top. 60, 1. 7. 

8 
On the date in question, when Monfort requested records, and he was denied 

access. Schuman immediately pulled the aircraft out ofKona and brought it back to 

Honolulu. 

There was no requirement for the FAA to notify the operator prior to an 

inspection. The FAA normally employed two inspectors when it conducted an 

investigation. In accordance with the 135 rules and regulations, an inspector can inspect 

at any time and any place, and all the records that are available should be made available 

to us. 

Monfort did not know Schuman was conducting Kona operations. Early in the 

morning of the 17th, Monfort was told there was a possibility that Schuman was 

conducting commuter operations out ofKona. Monfort talked to his front-line manager, ·~ '/· ,..;;:. ·iy~;l 

and then he and Bartler proceeded over to Schuman's office. Schuman kept a copy of 

logs file in his maintenance records downstairs in his office. Plus he had an All Pro 

System that identified where the aircraft go and come from. 

When Mr. Schuman called Monfort two, two and a half hours later, there was no 

question that he was going to deliver the records. After his initial denial, he said he 

wanted to talk to his lawyer before he gave us the records. Had he told us the records 

were not there, this would be a non-issue. It's the initial-- that he denied it, that we were 

shocked. 

Redirect6 

... -. .. ::· 

6 Tr. p. 60, I. 10 top. 61, I. 7. 

9 
To get an amendment to OpSpecs, an operator normally provided the FAA a letter 

saying where he wanted to go - start from and go to - and provided a list of altitudes that 

he'd be at where the single engine aircraft could make easy glide, or in the event of 

engine failure, could land on land. It was a seven page, eight page document. That 

document was signed by the operator and then finalized and issued by the FAA. 

Recross7 

Because Schuman did not have faciJJties,:1to operate, or handle passengers out of 

Kona, except for the ones that Mokulele would provide, Monfort just needed to see the 

agreement. Eight (8) days later it was issued to him through the proper requests. 

Kyle Bartler8 

Kyle Bartler (hereinafter "Bartler") corroborated the testimony of Monfort. 

Evidence 

The following FAA exhibits were admitted: FAA# 1, FAA# 2, FAA# 3, FAA# 4, FAA# 

5, FAA# 6, FAA# 8, FAA# 9 

We took judicial notice of FAA# 7, FAA Order 2150.3B, consistent with past practices of 

this court. 

B. Schuman's Case 

Gustav R. Scbuman9 

Schuman testified he owned Schuman. In the summer of 2012 Mokulele contacted 

Schuman about supporting Mokulele to with their commuter scheduled operations from Oahu to 

Molokai, Molokai to Maui that may include Lanai and Kapalua. Schuman believed at that time, 

7 Tr. p. 61, l. 13 top. 65, l. 22. 8 Tr. p. 65, 1. II top. 74, 1. 1. 9 Tr. p. 83, 1. 9 top. I32, 1. 6. 

10. 
that he could comply with Mr. Grace's requests because they were an authorized Part 13 5 ·ondemand carrier. Schuman attempted to· contact. the~FAA but was unsuccessful. Schuman 

believed the flights were legal. 

When the FAA informed Schuman he was not authorized to perform the missions, they 

immediately ceased the operations. 

Schuman admitted denying the FAA access to his records. Schuman admitted that two 

hours later he called the FAA and offered to produce the records. 

C. Credibility determinations 

All witnesses were found to be credible. 

X. Analysis of Evidence and Testimony 

FAA's case 

A. 14 C.F.R. 119.5(g) provides: 

No person may operate as a direct air carrier or as a commercial operator without, or in 

violation of, an appropriate certificate and appropriate operations specifications. No 

person may operate as a direct air carrier or as a commercial operator in violation of any 

deviation or exemption authority, if issued to that person or that person's representative. 

B. 14 C.F.R. 135.73 provides:· 

Each certificate holder and each person employed by the certificate holder shall allow the 

Administrator, at any time or place, to make inspections or tests (including en route 

inspections) to determine the holder's compliance with the Federal Aviation Act of 1958, 

applicable regulations, and the certificate holder's operating certificate, and operations 

specifications. 

XI. Law 

A. The FAA has the burden of proof, except for affirmative defenses 14 C.F.R. 

§§ 13.224(a) and (c). The standard is aprep'ondenh~ce ofreliable, probative, and substantial 

evidence 14 C.F.R. § 13.223. 

11 
B. 49 US. C. §§ 46301 (a) and (d) (Transportation) provides for the imposition of civil 

penalties in FAA cases. 

A person is liable to the United States Government for a civil penalty of not more than 

$25,000 for violating ... (B) a regulation prescribed or order issued under any provision to 

which clause (A) of this paragraph applies." The authority for issuing Parts 119 and 121 

of 14 C.P.R. includes 49 U.S.C. Chapters 401, 441, and 447- all of which are covered 

by clause (A). 49 USC.§ 46301(a)(1)(A), 14 C.F.R. Parts 119 and 121 (Preamble). 

C. 14 C.F.R. 119.5(g) provides: 

No person may operate as a direct air carrier or as a commercial operator without, or in 

violation of, an appropriate cert~ficate~p~ ~ppropriate operations specifications. No 

person may operate as a direct air carrier or as a commercial operator in violation of any 

deviation or exemption authority, if issued to that person or that person's representative. 

D. 14 C.F.R. 135.73 provides: 

Each certificate holder and each person employed by the certificate holder shall allow the 

Administrator, at any time or place, to make inspections or tests (including en route 

inspections) to determine the holder's compliance with the Federal Aviation Act of 1958, 

applicable regulations; and the certificate holder's operating certificate, and operations 

specifications. 

XII. Findings of Fact 

We find that the evidentiary facts, by a preponderance of the evidence standard, do 

support a findings that the following violations occurred: 

A. 14 C.F.R. 119.5(g) provides: 

No person may operate as a dirJet air,6'krrX~~gr as a commercial operator without, or in 

violation of, an appropriate certificate and appropriate operations specifications. No 

person may operate as a direct air carrier or as a commercial operator in violation of any 

deviation or exemption authority, if issued to that person or that person's representative. 

B. 14 C.F.R. 135.73 provides: 

Each certificate holder and each person employed by the certificate holder shall allow the 

Administrator, at any time or place, to make inspections or tests (including en route 

inspections) to determine the holder's compliance with the Federal Aviation Act of 1958, 

applicable regulations, and the certificate holder's operating certificate, and operations 

specifications. 

12 
XIII. Conclusions 

We find that the evidentiary facts, by a preponderance of the evidence standard, support a l I·' r~·· , pf}'f 

;1 · 1 'i+r"'[C· r · · 

finding that Schuman violated 14 C.F.R. J19:5(g)'in'that Schuman operated as a direct air carrier 

or as a commercial operator in violation of a deviation or exemption authority. 

We find that the evidentiary facts, by a preponderance of the evidence standard, support a 

finding that Schuman violated 14 C.F.R. 135.73 in that Schuman denied the Administrator to 

make inspections or tests (including en route inspections) to determine the holder's compliance 

with the Federal Aviation Act of 1958, applicable regulations, and the certificate holder's 

operating certificate, and operations specifications. 

XIV. Penalty and Mitigation Considerations 

Schuman subsequently allowed the FAA to inspect its records. 

Schuman immediately ceased operation&.,)Vh,eU;..informed it was in violation of the F ARs. ~t f { i·~:··to-! i:' .... 

We found the violations alleged. 

Schuman was not initially cooperative and responsive to FAA concerns. 

Once notified of the discrepancies/violations, Schuman took swift, comprehensive 

corrective action. 

Schuman presented testimony that the penalty requested would severe impact its 

operations. 

The FAA failed to prove by testimony and/or evidence ofhow it arrived at the figure of 

$11,000 for each violation. We are left to speculate how the figures of $11,000 and $28,000 

were determined. ,, 

While a penalty calculated in a&ordcirlet~ wi¥rf the FAA's policy guidance should stand, 

absent a showing of the Schuman's inability to pay, the evidence and testimony did not support 

13 
the penalty requested. While the FAA was entitled to substantial deference in establishing an 

appropriate civil penalty, we cannot ignore our role to evaluate the testimony and evidence. 

A. Sanctions guidance 

FAA Order 2150.3B Appendix C sets forth the penalty policy of the FAA. 10 As a general 

matter, a sanction should be imposed that is a sufficient deterrent but not excessive, in order to 

comply with the underlying purposes of the Federal hazardous material transportation law and 

. :~. }.>:;!:~~· f:.Ji~:>;~ 

HMR. The FAA considers a variety of factors wheri determining an appropriate civil penalty, 

including: (1) the nature and circumstances of the violation; (2) the extent and gravity of the 

violation; (3) the person's degree of culpability; (4) the person's history of prior violations, if 

any; (5) the per!:!on's ability to pay the civil p.enalty; (6) the effect on the person's ability to stay 

in.business; and (7) other matters as justice may require. 11 

Any determination of penalty should weigh whether the violation was inadvertent or 

deliberate, the private or public character of the violation, andthe attitude of the violator. 

The agency should also consider the respondent's size, particularly in determining the 

offender's ability to absorb the sanction. An appropriate civil penalty must reflect the totality 

of the circumstances surrounding the violati0ns, ~q$tern Air Center, Inc., FAA Order No. j;.~ ' '. ~:;'".:) '"~-,.,· .• 1 ~ .. ~ 

2008-3 (January 28, 2008). Finally, the civil penalty should provide sufficient incentive to 

deter the respondent and similarly-situated entities from future violations. Folsom's Air 

Service, Inc., Id, p. 20. 

The FAA has the burden of justifying the amount of civil penalty sought. 12 The FAA's 

1

° Folsom's Air Service, Inc., FAA Order No. 2008-11, 2008 WL 4948488 (November 6, 2008). 11 Id. See also Eastern Air Center, Inc., FAA Order No. 2008-3, 2008 WL 345386 (2008). 12 In The Matter of' Phyllis Jones Luxemburg, 1994 WL 899676 (1994), citing In the Matter of Northwest Airlines, 

FAA Order No. 90-37 at 7 (November 7, 1990). 

14 

,. 

,\ ,, 'G<~t 

'I;,•. I~.', ,: lo• ' 
proposed sanction is no more than a proposal or a recommendation to the ALJ .

13 The FAA must .. ~ ~. ~:r~~ ~ 

. ··~~ ~ : 

prove to the ALJ how it used the sanction guidance to arrive at its proposal. 14 The FAA must 

also prove the existence of aggravating factors and must show how it used aggravating or 

mitigating factors to adjust the suggested sanction. Evid~nce of swift comprehensive corrective 

. action must be considered as a mitigating factor. Significant weight has been given to 

respondent's efforts to ensure that a violation will not reoccur. 15 

B. Analysis 

Schuman violated two (2) provisions of the F ARs as set forth above. 

The FAA presented no evidence that it considered the nature and circumstances of the 

violations, the extent in gravity related to the violations, any mitigating or aggravating 

circumstances, or whether Regent's ability to .nay v¥'as taken into account. 

The FAA failed to prove to the ALJ how it used the sanction guidance to arrive at its 

proposal. 

The FAA failed to prove the existence of aggravating factors and failed to show how it 

used aggravating or mitigating factors to adjust the suggested sanction. 

Taking the totality of the facts and circumstances into account, we conclude a fine of 

$5,000 for each ofthe two (2) violations is appropriate, for a total fine of$10,000. 

WHEREFORE, evidence and testimony having been heard and considered it be and is 

hereby ORDERED as follows: 

a. We find the FAA proved Schuman violated 14 C.F.R. 119.5(g) and 14 C.F.R. 

135. 73; and 

13 In the Matter of Eastern Air Center, Inc., FAA Order No. 2008-3, 2008 WL 345386 (2008). 

14 In the Matter ofWarbelow's Air Ventures, Inc., FAA Order 2000-3, 2000 WL 298578 (2000). 15 In the Matter of American Air Network, Inc., FAA Order No. 2006-5, 2006 WL 465369 (2006). See also In the 

Matter of Airtran Airways, Inc., Docket No. FAA- 2010-0193, Initial Decision (June 23, 2010). 

15 
b. Schuman be and is hereby assessed fines of $5,000 for each of the two (2) 

violations for a total fine of$10,000. 

Richard C. Goodwin 

U.S. Administrative Law Judge 

Attachment- Service List 

,, . · ..l~'; \{{.~.; 

16 

'. ~· -. 
SERVICE LIST 

ORIGINAL & ONE COPY 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building-Suite 2W1 0001 

ONE COPY 

Gustav Richard Schuman, President 

Schuman Aviation Company, Ltd., Respondent 

130 Iolana Place 

Honolulu, HI 96819 

TEL: NOT PROVIDED 

FAX: NOT PROVIDED 

Christopher D. Ferrara, Respondent's Counsel 

3555 Harding Avenue, Suite 2F 

Honolulu, HI 96816 

TEL: 808-522-1660 

FAX: 808-522-1661 

EMAIL: chris@ferraralawhawaii.com 

Don Bobertz, Complainant's Counsel 

Office of the Regional Counsel, Western Pacific Region, A WP-7 

Federal Aviation Administration 

P.O. Box 92007 

Los Angeles, CA 90009-2007 

TEL: 310-725-3454 

FAX: 310-725-6816 

The Honorable Richard C. Goodwin, Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

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

Washington, DC 20590 

TEL: 202-366-5121 Staff Assistant 

FAX: 202-366-7536 

FDMS No. FAA-2013-1080 

(Civil Penalty Action) 

1 Service was by U.S. Mail. For service in person or by expedited courier, use the following address: Federal 

Aviation Administration, 600 Independence Avenue, S.W., Wilbur Wright Building-Suite 2Wl000, Washington, 

DC 20591; Attention: Hearing Docket Clerk, AGC-430. 

17