U.S. Department 

Of Transportation 

Federal Aviation 

Administration 

Office of Regional Counsel 

December 15, 2011 

Northwest Mountain Region 

Colorado, Idaho, Montana, 

Oregon, Utah, Washington, 

Wyoming 

1601 Lind Avenue S.W. 

Renton, Washington 98057 

Tel: (425) 227-2161 

Fax: (425) 227-1007 

JEFFREY.HARPER@FAA.GOV 

VIA FACSIMILE AND CERTIFIED MAIL- RETURN RECEIPT REQUESTED 

Attn: Hearing Docket Clerk, AGC-430 

Hearing Docket 

Federal Aviation Administration 

Wilbur Wright Bldg Room 2W1 000 

800 Independence A venue Southwest 

Washington, D.C. 20591 

Re: In the Matter of Cornerstone Aviation, Inc., FAA Case No. 2011NM070084 

Enclosed herewith please find a copy of a request for hearing and the original and one copy of the 

Complaint in the above-referenced proceeding. 

The Federal Aviation Administration (FAA) requests that the hearing in this matter be held in 

Salt Lake City, Utah and expects that the hearing .will last one (1) day. For scheduling purposes, 

counsel for the FAA anticipates being unavailable on the following dates in 2012 due to military 

reserve duty: January 6-9, February 10-13, March 16-19, March 30-31, April1-2, May 4-7, 

June 1-4, June 29-30, July 1-2, August 10-13, and September 7-10. Undersigned counsel also 

anticipates being unavailable at some point in June 2012 on the occasion of the birth of his third 

child. 

Please address all communications for the FAA to the undersigned at: 

Federal Aviation Administration 

Northwest Mountain Region, ANM -7 

1601 Lind A venue Southwest 

Renton, Washington 98057 

Telephone: (425) 227-2161 

FAX: ( 425) 227-1007 

Enclosures: Request for Hearing 

Complaint 
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JEFFREY M. HARPER 

FAA OFFICE OF REGIONAL COUNSEL 

1601 LIND AVE. SW. 

RENTON, WA 98057 

TELEPHONE: (425) 227-2161 

FACSIMILE: (425) 227-1007 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of: 

Cornerstone Aviation, Inc. 

IDDGE NOT ASSIGNED 

FAA DOCKET Not Assigned 

FAA Case No. 2011 NM070084 

Judge Not Assigned 

COMPLAINT 

The Federal Aviation Administration (FAA), by counsel, hereby files its Compliant, pursuant to 

Rule 208 of the Rules of Practice (14 C.F.R. § 13.208), and states as follows: 

I. 

35 On November 15, 2011, Cornerstone Aviation, Inc. (Cornerstone) was advised through a 

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Notice of Proposed Civil Penalty that the FAA proposed to assess a civil penalty in the 

amount of $5,000. On December 5, 2011, Cornerstone submitted a written request for a 

hearing. 

II. 

47 1. Cornerstone is now and was at all times material hereto the holder of Air Agency 

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4 9 Certificate No. QN7S767K, and conducts its operations pursuant to Part 141 of the 

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Federal Aviation Regulations. 

Complaint 

Cornerstone Aviation, Inc.- 2011NM070084 

Page 1 of5 

JEFFREY M. HARPER, F AAATTORNEY 

TEL: (425) 227-2161; FAX: (425) 227-1007 
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2. 

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Cornerstone's Authorized Courses of Training permits it to conduct training for the 

Private Pilot certificate. 

Cornerstone is authorized to provide the Private Pilot training referenced above using the 

Jeppesen Sanderson, Inc. "Guided Flight Discovery, Private Pilot Syllabus" (the syllabus) 

for both ground and flight training. 

On July 1, 2011, Mr. Richard Decker graduated from Cornerstone's Private Pilot Course 

of Training. 

Mr. Decker's graduation certificate does not contain a statement of the cross-country 

training Mr. Decker received in the course of training. 

Mr. Decker's training record was not certified upon his graduation from the Private 

Pilot course of training. 

III. 

By reason of the foregoing circumstances, Cornerstone violated the following sections 

of the Federal Aviation Regulations (14 C.F.R.): 

a. Section 141.95(b )(7), in that Cornerstone issued a graduation certificate that did 

not contain a statement of the cross-country training the student received in the 

course of training. 

b. Section 141.101(c), in that Cornerstone failed to certify a student's record upon 

termination of that student's training. 

Complaint 

Cornerstone Aviation, Inc. 2011NM070084 

Page 2 of5 

JEFFREY M. HARPER, FAA ATTORNEY 

TEL: (425) 227-2161; FAX: (425) 227-1007 
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3. 

Under 49 U.S.C. §§ 46301 (a) and (d), Cornerstone is liable for a civil penalty not to 

exceed $11,000 for each of the violations noted. 

Under the facts and circumstances of this case, a civil penalty of $5,000 is appropriate. 

WHEREFORE, the Agency, by counsel, respectfully requests that the Administrative 

Law Judge enter an order that Cornerstone Aviation, Inc. be assessed a civil penalty in the 

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amount of$5,000. 

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18 Respectfully submitted this 15th day ofDecember, 2011. 

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Complaint 

Cornerstone Aviation, Inc.- 2011NM070084 

Page 3 of5 

JEFFREY M. HARPER, FAA ATTORNEY 

TEL: (425) 227-2161; FAX: (425) 227-1007 
1 ANSWER 

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3 In accordance with section 13.209 of the Federal Aviation Regulations, Cornerstone Aviation, 

4 Inc. must answer this Complaint not later than thirty (30) days from the time it is served on it. 

5 Failure to file an Answer within 30 days without good cause shall be deemed an admission of the 

6 truth of each allegation contained in the Complaint (14-:-C.F.R. § 13.209(±)). 

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Complaint 

Cornerstone Aviation, Inc. 2011NM070084 

Page 4 of5 

JEFFREY M. HARPER, FAA ATTORNEY 

TEL: (425) 227-2161; FAX: (425) 227-1007 

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CERTIFICATE OF SERVICE 

I hereby certify that the foregoing Complaint has been served via facsimile and Certified Mail 

Return Receipt Requested this date, to the following: 

Federal Aviation Administration 

800 Independence Ave. SW. 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building Suite 2Wl 000 

Washington, DC 20591 

Fax: 202. 493.5142 

Susan Horstman 

Chief Executive Officer 

Cornerstone Aviation, Inc. 

337 North 2370 West #130 

Salt Lake City, UT 84116 

Fax: 801.355.2754 

Dated this 15th day ofDecerr1ber, 2011. 

Complaint 

Cornerstone Aviation, 'Inc. 2011NM070084 

Page 5 of5 

MOIFAIR CHIN 

Office ofRegional Counsel (ANM-7) 

Federal Aviation Administration 

1601 Lind Ave. SW. 

Renton, WA 98057 

(425) 227-2160 

JEFFRI!.tM. HARPER, FAAATTORNEY 

TEL: (425) 227-2161; FAX: (425) 227-1007