UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICEOFHEARINGS RECE\VE·o· WASHINGTON, D.C. 

MAY 2 ~ 20\3 

HEARING DOCKET 

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In the Matter of: 

Southwest Airlines Co. 

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* * FAA Case No. 2010SW290189 

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Docket CP No. - To Be Assigned 

FDMS No. FAA 2013-0050 

Judge Richard C. Goodwin 

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ANSWER TO COMPLAINT 

COMES NOW Respondent Southwest Airlines Co. ("Southwest"), through counsel, and answers 

the Complaint against it as follows: 

GENERAL DENIAL 

Except to the extent specifically and unequivocally admitted herein, all allegations contained in 

the Complaint are denied. 

ANSWER TOP ART I 

Southwest admits the allegations contained in Part I of the Complaint. 

ANSWER TOP ART II 

I. Southwest admits the allegations contained in Paragraph 1 ofPart II of the Complaint. 
2. Southwest admits the allegations contained in Paragraph 2 of Part II of the Complaint. 

3. Southwest admits the allegations contained in Paragraph 3 of Part II ofthe Complaint. 

4. Southwest admits the allegations contained in Paragraph 4 of Part II of the Complaint. 

5. Southwest admits the allegations contained in Paragraph 5 of Part II of the Complaint. 

6. Southwest admits the allegations contained in Paragraph 6 of Part II of the Complaint. 

7. Southwest admits the allegations contained in Paragraph 7 of Part II of the Complaint. 

8. Southwest admits the allegations contained in Paragraph 8 of Part II of the Complaint. 

9. In response to the allegations contained in Paragraph 9 of Part II of the Complaint, Southwest 

admits only that Figure 2, Step 18, Note (x) of Boeing Service Bulletin (SB) 737-32A1355, 

Revision 2, March 5, 2008, states as follows: "To get the necessary interference fit, it can be 

necessary to fabricate oversize bushings. CMM 32-16-31 gives data for fabrication of 

oversize bushings." 

10. In response to the allegations contained in Paragraph 10 of Part II of the Complaint, 

Southwest admits only that CMM 32-16-31, at Page 2, states as follows: "Make oversize 

bushings per Fig. 1A." 

11. Southwest admits the allegations contained in Paragraph 11 of Part II of the Complaint. 

12. Southwest denies the allegations contained in Paragraph 12 of Part II of the Complaint. 

13. Southwest denies the allegations contained in Paragraph 13 of Part II of the Complaint. 

14. Southwest admits the allegations contained in Paragraph 14 of Part II of the Complaint. 

15. Southwest admits the allegations contained in Paragraph 15 of Part II of the Complaint. 

16. Southwest denies the allegations contained in Paragraph 16 of Part II of the Complaint. 

17. Southwest denies the allegations contained in Paragraph 17 of Part II of the Complaint. 

18. Southwest denies the allegations contained in Paragraph 18 of Part II of the Complaint. 

19. Southwest denies the allegations contained in Paragraph 19 of Part II of the Complaint. 

20. Southwest denies the allegations contained in Paragraph 20 of Part II of the Complaint. 

21. Southwest denies the allegations contained in Paragraph 21 of Part II of the Complaint, 

including all subparts. 

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ANSWER TOP ART III 

1. Southwest denies the allegations contained in Paragraph I of Part III of the Complaint. 

2. Southwest denies the allegations contained in Paragraph 2 of Part Ill ofthe Complaint. 

WHEREFORE, Respondent Southwest Airlines Co., through counsel, requests that the 

Administrative Law Judge enter an order finding that Respondent Southwest Airlines Co. did not 

violate any ofthe Federal Aviation Regulations as alleged by the Federal Aviation 

Administration in this matter, and further requests that the Complaint be dismissed and that no 

civil penalty be assessed against it. 

Respectfully submitted this 23rd day of May, 2013. 

Dane B. Jaques, Esq. 

McKenna Long & Aldridge LLP 

1676 International Drive, Penthouse 

McLean, VA 22102 

Tel: 703-336-8800 

Fax: 703-336-8750 

djaques\a)mckennalong.com 

Counsel for Respondent Southwest Airlines Co. 

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CERTIFICATE OF SERVICE 

I hereby certify that I have this day served a copy of the foregoing Answer to Complaint 

on the following party's counsel or designated representative, at the address indicated, by UPS 

overnight delivery: 

Yolanda Ayala Bernal, ASW -7E2 

Federal Aviation Administration 

Southwest Region 

2601 Meacham Blvd., Room 663 

Fort Worth, TX 76137 

Fax: 817-222-5945 or 5092 

I also certify that I have this day served the original and one copy of the foregoing 

Answer to Complaint on the following, at the address indicated, by UPS overnight delivery: 

Hearing Docket 

Federal Aviation Administration 

600 Independence Avenue, S.W. 

Wilbur Wright Building- Suite 2W1 000 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

Fax: 202-493-5142 

I also certify that I have this day served a copy of the foregoing Answer to Complaint on 

the following, at the address indicated, by UPS overnight delivery: 

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 

Dated this 23rd day of May, 2013. 

Fax: 202-366-7536 

A. Eastwood 

Me e Long & Aldridge LLP 

1676 International Drive, Penthouse 

McLean, VA 22102 

Tel: 703-336-8800 

Fax: 703-336-8750 

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