### UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION OFFICEOFHEARINGS 

# RECE\VE·o·

WASHINGTON, D.C. 

# MAY 2**~** 

## 20\3 

## HEARING DOCKET ******************************************* Inthe Matter of:
Southwest Airlines Co. 

## * * * * FAA CaseNo. 2010SW290189 

## * * 

# * * * * Docket CPNo.

- To Be Assigned FDMS No. FAA 2013-0050 Judge Richard C. Goodwin


### ******************************************* 

### 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 PartI ofthe Complaint. 

### ANSWER TOP ART II I. Southwest admits the allegations contained in Paragraph 1 ofPart II ofthe Complaint.2. Southwest admits the allegations contained in Paragraph 2 ofPart II ofthe Complaint. 3. Southwest admits the allegations contained in Paragraph 3 ofPart II ofthe Complaint. 4. Southwest admits the allegations contained in Paragraph 4 ofPart II ofthe Complaint. 5. Southwest admits the allegations contained in Paragraph 5 ofPart II ofthe Complaint. 6. Southwest admits the allegations contained in Paragraph 6 ofPart II ofthe Complaint. 7. Southwest admits the allegations contained in Paragraph 7 ofPart II ofthe Complaint. 8. Southwest admits the allegations contained in Paragraph 8 ofPart II ofthe Complaint. 9. In response to the allegations contained in Paragraph 9 ofPartII ofthe Complaint, Southwest admits onlythat Figure 2, Step 18, Note (x) ofBoeing Service Bulletin (SB) 737-32A1355, Revision 2, March 5, 2008, states as follows: "To getthe 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 ofPart II ofthe Complaint, Southwest admits only that CMM 32-16-31, at Page 2, states as follows: "Make oversize bushings perFig. 1A." 11. Southwest admits the allegations contained in Paragraph 11 ofPart II ofthe Complaint. 12. Southwest denies the allegations contained in Paragraph 12 ofPart II ofthe Complaint. 13. Southwest denies the allegations contained in Paragraph 13 ofPartII ofthe Complaint. 14. Southwest admits the allegations contained in Paragraph 14 ofPart II ofthe Complaint. 15. Southwest admits the allegations contained in Paragraph 15 ofPart II ofthe Complaint. 16. Southwest denies the allegations contained in Paragraph 16 ofPart II ofthe Complaint. 17. Southwest denies the allegations contained inParagraph 17 ofPart II ofthe Complaint. 18. Southwest denies the allegations contained in Paragraph 18 ofPart II ofthe Complaint. 19. Southwest denies the allegations contained in Paragraph 19 ofPart II ofthe Complaint. 20. Southwest denies the allegations contained in Paragraph 20 ofPart II ofthe Complaint. 21. Southwest denies the allegations contained in Paragraph 21 ofPart II ofthe Complaint, including all subparts.



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### ANSWER TOP ART III
1. Southwest denies the allegations contained in Paragraph I ofPart III ofthe Complaint. 2. Southwest denies the allegations contained in Paragraph 2 ofPart 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 bythe 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 ofMay, 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 ofthe foregoing Answer to Complaint on the following party's counsel or designated representative, at the address indicated, by UPS overnight delivery: Yolanda AyalaBernal, 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 ofthe foregoing Answer to Complaint onthe following, at the address indicated, byUPS overnight delivery: Hearing Docket Federal Aviation Administration 600 Independence Avenue, S.W. Wilbur Wright Building- Suite 2W1000 Washington, DC 20591 Attention: Hearing Docket Clerk, AGC-430 Fax: 202-493-5142 I also certify that I have this day served a copy ofthe foregoing Answer to Complaint on the following, atthe address indicated, by UPS overnight delivery: The Honorable Richard C. Goodwin, Administrative Law Judge Office ofHearings, M-20 U.S. Department ofTransportation 1200 NewJersey Avenue, S.E. (Ell-310) Washington, DC 20590
Dated this 23rd day ofMay, 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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