12/30/201 0 12:3 9 FAX 2024935142 FAA * DMS 121001/017 

-^FPARTMENT OF 

Michael Selig, MD, FACC, CFI-H p ;;;HU^u!^A''^'^^' ..^ .....';''^- ' '' 

^^CBIVBO 

2816 Orefield Roaid ' ' ^^-^RIN G n^OU'tr- v 

Allentown. PA. 18104 " • 0 '•' ^-' - ^ ^''VC T 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

Federal Aviation Administration 

Laura Ponto, Cynthia Dominik, 

Latonya Williams 

Complainants 

M & R Helicopters, LLC. 

Respondent 

Docket: 2010-1211 

RESPONDENT'S REPLY TO THE AMENDED COMPLAINT 

AND NOW, comes respondent, MICHAEL B. SELIG, MD, FACC, principle 

for MR Helicopters, LLC, (MRH) whom avers and files the following Reply In demurrer 

to the Amended Complaint in accordance to §13.2Q8(d) submitted by the Federal 

Aviation Administration associate Laura Ponto, Esq. hereby asserting that the 

allegations made in the complaint are erred, not proper or reasonable represents 

malicious, frivolous and prosecutorial overreaching, and thereby the complaint should 

be stricken and dismissed. 

Count I. 

Constitutes conclusions of law to which no answer is required pursuant to 

the federal rules of court. 

Page 1 of 6 
12/30/201 0 12:4 0 FAX 2024935142 FAA •» DMS @|002/017 

Count II 

1. Agreed in part. MRH has not been able to carry on part 135 operations 

since August 2007, on account of the single pilot operator has either been unavailable 

to pass or take his flight exam for personal reasons {protracted divorce, liability issues) 

or the Inspector was unavailable to perform a flight exam (medical leave). MRH has 

since ceased operating under the name and under the certificate number, ownership of 

helicopter has changed, financials have been closed, the company no longer has any 

assets, thereby rendering the complaint moot. 

2. Denied. The operation specifications were signed off in 2004 (Exhibit 1). 

The exhibit came redacted by Ms Pontes and by way of her investigation file. 

Respondent did not deny signing the document, but since the time of sign off, the 

regulation now finding MRH In violation had been changed without notification. 

By way of further answer 14 C.F.R. part 121, Appendix I and J and 49 C.F.R. 

part 40 are not disclosed, clearly delineated or spelled out in the compliance statement, 

operational specifications, not readily available in the Federal Aviation Regulations 

/Airman Information Manual (FAR/AIM) and thereby one can assume are less Important 

than other regulations that are clearly disclosed in the signed operational specifications. 

These regulations were thereby hidden and concealed. By way of judicial estoppels, 

respondent was already released of the hidden appendices by act of Ms Williams, 

Ponto releasing the other mechanic of all violations. 

3. Denied. Regulations 135.251 and 135.255 as written in the compliance 

statement and confirmed by the respondent does not inherently state that MRH must 

Page 2 of 6 
12/30/201 0 12:4 0 FAX 2024835142 FAA * DMS 0003/01 7 

directly test each employee who performs a safety sensitive function (Exhibit 2) but 

empirically states that any contractor be covered by an FAA approved drug and alcohol 

testing program. These individual referred to, did comply with mandatory drug and 

alcohol testing regulations by way of their full time employers. 

In administrative law "In the interpretation of the language of regulations, where 

doubt exists as to the intent of the meaning of the language written and enacted by a 

governing body, the language shall be interpreted in favor of the operator and against 

any implied extension of the restriction". 

4. Denied. All individuals performing safety sensitive functions on MRH aircraft 

were at all times subject to random drug and alcohol testing programs and have never 

had a history of a positive testing result over the last 10 known year period. Safety 

sensitive functions are neither specific to either pilot or mechanic tasks, but are inclusive 

thereof. 

5. Denied. All individuals performing safety sensitive functions on MRH aircraft 

at all times have been subject to alcohol testing under the alcohol misuse program and 

have never tested positive. 

6. Denied. At all times was the individual performing safety sensitive functions 

was subject to DOT required random drug testing or have ever tested positive. 

7. Denied. At all times were individuals performing safety sensitive functions 

were subject to DOT required random alcohol testing. 

8. Agreed. 

9. Denied. Mr Baker at all times was in a random pool for DOT required drug 

and alcohol testing at the time of performing safety sensitive functions, which includes 

Page 3 of 6 
12/30/201 0 12:4 0 FAX 2024935142 FAA - DMS 0004/01 7 

his mechanic tasks, in paragraph 8 and clearly within the known regulations clearly 

pursuant to the operational specifications, the compliance statement and the standard 

FAR/AIM. 

By way of further answer, a regulation change occurred in February 2004, no 

notification procedure was in place to infomn the operator of this change, contrary to the 

routine protocol followed by all other operation specification chapters which included a 

regular notification procedure, written operational specification revisions, replaced 

pages and subsequent re-signoff and confirmation of the new pages that the operator is 

aware and agrees. It is therefore not reasonable, proper to hold MRH responsible for 

changes he was not formally or othenwise notified of This lacking procedure only 

encourages violation rather the spirit of compliance and safety. 

In addition, MRH was inspected by Vincent Roots of the FAA's own drug 

abatement program in April of 2004 (Exhibit 3) and found compliant with the regulations, 

even though a regulation change had occurred in February of 2004. Therefore the 

FAA's own drug abatement officer was also not informed of the regulation change just 

as MRH was not. It is therefore not proper or reasonable to hold the operator to a 

standard higher than their own drug inspection officers who themselves did not know or 

informed in good faith MRH of the regulation changes in his one on one meetings. 

Furthermore, MRH maintenance inspector, Gerry Henninger, MRH operation 

inspector, Frank Alotta, the Allentown FSDO manager, Mr Wadsworth, also were not 

aware of the regulation change. The Allentown FSDO is located across the street from 

the MRH aircraft and it's officer's inspected frequently during their daily activities at the 

Lehigh Valley International Airport (ABE) where the aircraft has been hangared for over 

Page 4 of 6 
12/30/201 0 12:4 0 FAX 2024935142 FAA + DMS 01005/01 7 

10 years, never to find MRH in violation of FAA regulations. 

10. Denied. Mr Baker was in a random pool for DOT required drug and alcohol 

testing at all times under ERA Med and Air Methods Corporation including the time of 

performing referenced safety sensitive functions on MRH aircraft (Exhibit 4). 

Performing safety sensitive functions is inclusive of pilot and mechanic functions, for 

there is no different process for compliance for either function. Mr Baker performs 

independent maintenance under his Airframe/Power Plant certification and independent 

of his place of employment in compliance to FAA regulations. 

11. Denied. There is all reason to believe and in good faith, that under the 

stated circumstances that MRH operated in due diligence and in accordance to the 

knowledge sets of the Allentown FSDO, its inspectors and the regulations that were 

clearly set forth, written and described in the compliance statement, the operational 

specifications and the FAR/AIM. 

By way of further answer, it is not proper or reasonable to expect an operator to 

randomly find and hunt for regulations, not clearly written, spelled out in the compliance 

statement, operation specifications and not even listed in the standard Federal Aviation 

Regulations /Airman Information Manual, or to be required to review hundreds of pages 

of text at a remote site, to focus, find, comprehend and determine if a random regulation 

change had occurred. It is not clearly stated where the exact source location of these 

unidentified and hidden (fine print) regulations are to be located or at what frequency or 

on what time interval to complete this tedious hit or miss search procedure that is prone 

to misinterpretation and error, therefore, it is impossible to ever be thoroughly compliant 

at any point in time, if a regulation change or update randomly occurs. It is also 

Page 5 of 6 
12/30/201 0 12:4 0 FAX 2024935142 FAA * DMS 0OOG/O17 

impossible to do this time consuming, random search on a regular basis and is more 

prone to mistake and entrapment than a forthright notification procedure, that is 

consistent and already in place for procedures pertaining to the other chapters in the 

operational specifications. The current system only encourages violations, rather than a 

transparent method that would encourage compliance and safety as is in place by the 

operation specifications. 

Once MRH was made aware of the regulations that had changed without the 

Drug abatement officer Vincent Roots, the respondent, the FAA operational and 

maintenance inspectors and the Allentown FSDO being alerted, the two part-time A/P 

mechanics were immediately enjoined to MRH's own, independent long existing drug 

and alcohol program. 

Count III. 

1. Denied. 

2. Denied. 

WHEREFORE, The respondent prays to this Honorable Court that the proposed 

violation, consisting of a judgment against MRH, (which currently does not exist, with no 

financial assets) and the recently lowered fine of $4400 (forty-four hundred dollars) be 

immediately STRICKEN and DISMISSED. 

Respectfully Submitted, ^ Xvl ^ 

Michael B. Selig, MD, FACC, CFI-H^ r^ ^A' ^ 

Page 6 of 6 
12/30/2010 12:40 FAX 2024935142 FAA DMS 21007/017 

' , •*- ... i TTT -

U.S. DepartmeiH 

of Transportation 

Federal Aviation 

Aclniinistratian 

Operations Specifications 

A*49. .A.ntirirug and Alcah<?l Misuse Prevention Program HQ Control: \ 01/27/04 ^ 

HQ Revision: 000 ^ 

3, The ccnifitate holdei' who operates utidcv Title 14 Code of Federal Reguktions (CFR) Part 135 

cetTifies thst it will i;omply with the requirements of 14 CFK Pari 121 Appendices I and J and 

49 CFJ^ fftiT 40 for its Anlidi'ug and Alcohol Misuse Prevention ProBi'am. 

b. Ainidruc and Alcohol Misu.se Prevcniion Pi'ogrdm records are maintained and availalile for iii.'ipf.ction 

by the FAA's DxTig Abaicmenl CoaipUance and Eiil~orccment Inspectors a.i the location listed in Table 1 

below; 

Table 1 

Address: 

AdJresS! 

City: 

Stale: 

Location of Antidrug sind Alcohol MlMisc 

_ Prevention Pro|^r)tm^tcor(l<; 

_2045_Weslgate_Dnv£_ 

Telcphnne Number: 

r-f-A .,r-.= 

(c;io)7fi9-70on 

Bethltheni 

PA 

1.8017 

c. Limitaiions and Provisions. 

'D AmidriiR and Alcohol Misuse Prevention Program infiijociions and eiilorcemcnl iictiviiy wjll be 

conducted exclusively by the Di-ug Abilomeni Division. All questions regarding ihisi program 

should b« directed to tiic Drug Afciitcmcni Division. 

(2) Thi c<iiLiiicate holder must irnplemeritits Antidrug and Alcohol Misuse Prevention Programs fully 

111 accordance with 14 CFH Pan 121, Appendices I and J, and 49 C:FR P:m 40. 

(3) The ceitificate holiicr is responsible for wisurtng that its contractor.* who pcrfonii safcty-scnsiuvc 

work for the ccrtitlcate holder arc subject to Antidrug and Alcohol Misuse Prevention Programs. 

(4) The certificate holder is respon.sible for updating this operations sptcificarion when any changes 

occur in the follovving: ,.•.. . 

(&) I -ocation or phone number where tlie Antidrug and Alcohol Mi.'^usc Prevention Records ai'e 

kept (im listed in Tabic 1 above). 

Cb) 1 rthe certificate holder's numbci' of .=ia.fcty-sr,nsitivc employees goes to 30 and above, or falls 

billow 50 saft;ty-sersiiivc employees. 

(5) The certificate holder with .50 oi more employees performing a safety-sensiiivc funciion on 

.fanuary 1 oKthe calendar ycur must subinii an annual vepon to the .Drug Abatement Division of the 

FAA. The certificate holder with fewer than 50 employees performing a sateiy-sensiiivc -fonciion 

on Jajiuary 1 of any calendar year must submit an annual report upon request of the Adrtiinistrator, 

as specified In the regulations. 

'J'hc cerLificaU: holder has fe.vcr ".hf.;-. ;C' sz'.'f-.-si-.-.i::::':: •j".:-::'.y--:2^ 

Print Date; 8/15/2005 A449-1 

M A"ND 1^ llELTCOPTHR,? LLC 

Ccnifioate No.: MR3AU20K 

FOR OFFiCIAL ilSE ONLY 

PublJe avollabiliiy fo be deternilned under 5 USC152 

FfluHr 
12/30/2010 12:40 FAX 2024935142 

FAA 

DMS l ^ UOD/ f V I I 

US, Department 

of Transportation 

Fedisral Aviation 

Aciminlstraiion 

tS3C 

Opei'alions Specifications 

\. Issued by the Federal Aviation Administration. 

2. These Operations Specifications arc approved by direction ofthe Admini.e;trator, 

yVLOTTA, I'RANK Principn.1 Opcratious Inspector I^A05 

3. 1^ate Approval is effective; 2/4/04 Ainendnienthlumbcr: 0 

4. 1 hereby accept and reeuive the Operations Specifications in this paragrnph. 

SeliR, Michael B. Agent for Service Date; 2/4/04 

Print Date: 8/15/2005 .A44.0-2 

M AMD R HEf.lCOPTHRS LL(.: 

CtriificateNo.: MR3A020K 

fOi?OFHCIAlUSf.« 

Public ovailab!l!t\f lo be dstermlnsd under 5 l)SC 552 
12/30/2010 12:41 FAX 2024935142 ^^^ 

. DMS i009/01 7 

NOTE: Whenever a compliance statement directs M & R Helicopters, LLC. to 

mail or deliver documents to the Allentown, PA, FSDO, the following address will 

be used: 

Federal Aviation Administration 

Flight Standards District Office 

961 Marcon Boulevard, Suite 1'! 1 

Allentown, Pennsylvania 1S103 

REGULATiOisi COMPLIANCE FAA USF. 

SUJi£ABX,,^-.;:;-Sm&BAL 

135."; The regulations governing air carrier operations i:ha^ ai'e 

contained in FAR part 135, as amended, apply to M & R 

Helicopters, LLC, and will be complied with as shown below. 

(a)(l)M & R Helicopters, LLC, will conduct on-demand 

operations as a holder of an Air Carrier Certificate 

under Part 11 9 of this chapter, 

(a)(2) M& R Helicopters, LLC. will insure that all 

contractors, employees, and persons performing 

maintenance, preventive maintenance, and/or 

alterations of its aircraft will comply with the 

applicable rules of this part. 

(a)(3)M & R Helicopters, LLC, will not transport mail. 

(a)(4)Not applicable. M & R Helicopters, LLC. will not 

apply for provisional approval of an advanced 

Qualification Program curriculum, curriculum 

segment, or portion of a curriculum segment under 

SFAR No. 58. 

(s)(!-3) Any i-ionstop sightseeing flights conducted iDy 

M & R Helicopters, LLC. for compensation or hire 

within 2-5 statute miles of an airport wilt be conducted 

under the provisions of this Part; however, except for 

operations conducted under SFAR 50--2, these operations, 

when conducted tor compensation or hire, will comply 

only with 135,249, 135.251. 135.253, 135.255, and 

135.353. 

C ''^ib.ki 
_, OMS @1010/017 

12/30/2010 12:41 FAX 2024935142 FAA 

135.251 M & R Helicopters, LLC. will be a member of an FAAapprovedConsortium, or will have its own approved 

program, wit.h membership initiated at the time ATCO 

certificate is issued. Consortium membership will in^^ure 

compliance m\.\\ Appendices I of FAR Part 121, 

M & R Helicopters, LLC. will insure that any contractor 

who performs maintenance on its aircraft: is covered by 

an FAA-Approved drug-testing program. 

135.253(a) M & R Helicopters^ LLC, will comply with the provisions of 

FAR Part 135.253, in regard to employees who perform 

a function listed in Appendix J to Part 121 of this chapter, 

as set forth below. 

135.253(b) M & R Helicopters, LLC, will allow no covered employee, as 

described in Appendix i of FAR Part 121., to report for 

duty or to remain on duty, and no covered employes shall 

report for duty for any covered position, if that person 

has an alcohol concentration of 0.04 or greater,. 

135.253(c) M fli R Helicopters, LLC. will not permit the use of, and no 

covered employee of M & R Helicopters, LLC, will use, 

alcohol while performing any safety-sensitive function. 

135.253(d) M & R Helicopters, LLC, will not allow, nor will any covered 

employee perform, any flight crewmember duties within 8 

hours of using alcohol. M & R Helicopters, I..LC does not have 

any covered employees other than flight crewmembers. 

135.253(e) No M fii R Helicopters, LLC covered employee will use alcohol 

for 8 hours following an fjccident involving an aircraft for 

which that employee has performed a safety-sensitive 

function, unless and until he has been given a post-accident 

alcohol test, or unless M & R Helicopters, LLC has determined 

that the employee's performance could not have contributed 

to the accident. 

38 
12/30/201 0 12:4 1 FAX 2024935142 FAA * DMS glOn/01 7 

Office of Aviation Madicine 800 Independence Ave., S.W. 

U.S, Department Washington, D.C. 20591 

of Transportation 

Federal Aviation 

Administration 

APR 2 2004 

On-. 

Certified-Returrt Receipt 

File Number: 2004EA910073 

Dr. Michael Selig, CEO 

M and R Helicopters I..LC 

2045 Westgate Drive, Suite 101 

Bethieliem, PA 18017 

Dear Dr. Selig 

On March 3, 2004, you were informed that the Federal Aviation Administration (FAA) was 

investigating alleged violations of 49 CFR Part 40 and 14 CFR Part 121, Appendices 1 and J. 

After reviewing tlie evidence compiled during the inspection of M and R Helicopters LLC on 

February 26, 2004 and the docunnentation submitted in your response dated 

IVlarch 18, 2004, it appears that M and R Helicopters LLC did not comply vi^ith all provisions of 

the Antidrug and Alcohol Misuse Prevention Programs as detailed below: 

1. M and R Helicopters LLC's specimen collection procedures do not meet the 

requirements of 49 CFIR Part 40. Specifically: 

M and R Helicopters LL.C's collector (Denese Miller/CHS 02) failed to complete Step 1 

item E, Test to Be l^erformed, on the Federal Drug Testing Custody and Control Form. 

Corrective Action: At the inspection outbriefing, M and R Helicopters LLC agreed to ensure the 

collector would complete Step 1 on the Federal Drug Testing Custody and Control Form. In the 

response dated March 18, 2004, M and R Helicopters LLC submitted a copy of an Error 

Correction Training Checklist from Clinical Laboratories, Inc. documenting training for Denese 

Miller, 

2. M and R Hftlicopters i.,LC's breath alcohol testing procedures do not meet the 

requirements of 49 CFR "ari: 40, Specifically: 

M and R Helicopters LLC's Breath Alcohol Technician (Denese Milier/CHS 02) failed to 

complete Step 1 itern C, the Designated Employer Representative, on the Department of 

Transportation Alcohol Testing Form. 

Corrective Action: At the inspection outbriefing, M and R Helicopters LLC agreed to 

immediately ensure that the Breath Alcohol Technician would complete Step 1 of the Alcohol 

Testing Form. In the response dated March 18, 2004, iVl and R Helicopters LLC submitted a 

copy of an Error Correction Training Checklist from Clinical Laboratories, Inc. documenting 

training for Denese Miller. 

c'7K)i.>r'* '•= 
12/30/2010 12:41 FAX 2024835142 FAA 

^ °MS 21012/017 

3. Wl and R Helicopters LLC failed to maintain records as required by 49 CFR Part 40. 

Specifically: 

M and R Helicopters LLC's laboratory failed transmit the employer specific aggregate 

statistical summary for 2003 to the employer on a semi-annual basis. 

Corrective Action: At the inspection outbriefing, M and R Helicopters LLC agreed to 

immediately ensure the lab will send statistical summaries for 2003. In the response dated 

March 18, 2004, IVI and R Helicopters LLC submitted a copies of aggregate statistical 

summaries for 2003 from LabCorp. 

This is to confirm that you have satisfactorily corrected the above issues. We have given 

consideration to all available facts and concluded that these issues do not v/arrant legal 

enforcement action. In lieu of such action, we are issuing this letter, which will be made a 

matter of record. We expect that in the future IVI and R Helicopters LLC's Antidrug and Alcohol 

Misuse Prevention Programs wf|| be in compliance with applicable regulations. 

Sincerely, 

Vincent 0. Roots 

Inspector, Compliance and Enforcement 
12/30/2010 12:41 FAX 2024935142 FAA * DMS 0013/01 7 

-• Earhart Drive • Suiie 11 • Coatesville, PA 19320 • 484-288-2600 

www ersmcdllc.corr, 

Wednesday, Wf5V0r:^.bei' 'U.. 'A(y\^ 

Eawardl Baliec 

5 Sarafi'te Lasie 

Eas^ Strour^sbuii-cj, Pk 'i8502 

Dear Ed, 

This iisiicr SG b<?!ncj wfittGd'i to verify thai; i^'-cft/varcJ B,-aker was incSLfcSed in S-iraliHJr'l'.Fs dti^iicj 

firogram disntug liis rtstes of employsrneri'i: 3--1-?,003 ic '1 i-A-POOy 

if you have aiiy question-s or corrcerns pfeass; contaci :-.iie aiyotii- co.nvsnienci8. 

Thanks, 

Rilelissa Rodrigue?'. 

.ii^ccour?^;ing iiiianager 

mrodn0ue;:i@era?jiedI!c. COP":. 

f~/',vi''>'! ^ 
c ^ DMS 121014/017 

12/30/2010 12:41 FAX 2024935142 FAA 

PaRC 1 of 2 

m^elig 

From: "Ed BaRer" <ebaker@airmethods.com> 

To: <m5elig@ptd.net> 

Sent: Sunday. November 28, 2010 10:41 PM 

Subject: FW: Edward L. Baker III 

Mike, below is the letter from our Drug program manager to the FAA, 

Base Lead l^ilot 

East Sfroudsburg Base 

Air Methods Corporation 

(570) 476-2129 phor^e 

(570) 476-2128 fax 

;57'j; 730-3131 cell 

(•;bai«-;i ;y!airn'iotl'ic;d'.,c 'orn 

From: John Hargleroad 

Sent: Mon ll/lS/2010 11:40 AM 

To: Ed 13aker 

Subject:: FW: Edward L. Baker IK 

Ed, 

Here is a copy of the email that I sent Chet Stevenson with FAA drug abatement. Please feel free to call me if 

you need anything. 

Regards, 

.John Hargleioad 

Anli-i'^rug and Alcohol Progr;;im l\/i;iii;jqor 

PRIA Manager 

Pilot Records Supervisor 

7;i01 S. I^eoria St. 

l.-il(.|lov,/ood, CO a0112 

o'!- :i03V49-i:r/3 

,-:y ''0:3 7'it). v.);-;;^ 

jnL.ri:.)n;i-oaa((^,airmPthod;"i.c;om 

From: John Hargleroad 

Sent: Thursday, October 14, 2010 9:45 Ai^ 

To: chet.stevenson@faa.gov 

Subject: Edward L. Baker III 

Chet, 

Edward L Baker III, SSN 158545206, has been continually in the Air Methods DOT Anti-Drug and Alcohol 

program since ll/S/7.007. He is a pilot who also holds a A8iP certificate, however he is under our master 

1 1 i''^ f i 1 ^ r'' 1 '••1 
12/30/201 0 12:4 1 FAX 2024935142 FAA * DMS 0015/01 7 

Page2or2 

certificate QiVlLA253U and does not perform any maintenance under our repair station certificate QMLR253U, 

and is not authcized or contracted by Air Methods to do any outside maintenance for M&R Helicopters or any 

other operator. 

Please reply to let me know that you have .'-eceived this email. 

Regards, 

.lohn l-larglcroad 

Anti-Drug and Alcohol Program ManwgKr 

PRIA Manager 

Pilot Rucordii Supervisor 

.•\ir Method s Cuy\> 

7301 M. Pftoria St. 

lioqtewood, coijoii;- ' 

Off- 303-749--i:.r/'3 

Coil- 3l4-/'j3-?4ft? 

ihr")i"C|lc;i'Ofjd(aJii!rirmtl K.)di:i.c;(;n i 
12/30/2010 12:41 FAX 2024935142 FAA . OUS ^016/017 

Employee Nam©^ . "c'rA fxA^-("'\/ 

Date: H-'-\--'?<:>cR 

49 CFR 40.25 requires DOT regulated companies to check the drug and alcohol testing record of new 

employees who were previously employed by a DOT regulated employer. 

1. Have you been employed by any DOT regulated company within the last 24 rnonttis? (check one) 

\/\ YES [ J NO 

If YES, please provide the name, address and phone number of the facility. (If more than one, list names, 

addresses, phone on the back of this form.) 

/\l/' A{iytCj^^J Co^q/) 

3(y i -7V'-7'-j^'?3' 

2. Have you ever tested positive or refused to test on any pre-employment drug or alcohol test 

administered by an employer to which you applied for, but did not obtain, safety-sensitive work covered 

by DOT drug and alcohol testing rules during the past two years? (check one) 

U YES {)2( NO 

S.g ^ 
12/30/2010 12:42 FAX 2024935142 FAA ^ DMS 12017/017 

U.S. DEPARTMENT OF TRANSPORTATION 

Federal Aviation Administration 

Cynthio Dominik, Laura Ponto, Latonya Williams 

Complainants 

FAA Case 2009SO9S0434 

V. 

M & R Helicopters, LLC. 

___Respqndent . 

CERTIFICATE OF SERVICE 

1 HEREBY CERTIFY Ihat 1 have tlnis day served tine foregoing entrie(s): 

RESPONDENT'S REPLY TO THE AMENDED COMPLAINT 

upon all parties of record in this proceeding, in accordance with the requirements of Rule 29 

pu^uant to 26 U. S. C. § 1746 . 

Service by first-class mail, postooe orGpaid, addressed o.^ follows: 

Federol Aviation Administration 

800 Independence Avenue, SW 

Wilbur Wright Avenue-.9Ljite 2W1000 

Washington, D.C. 20591 

t: Heoring Docket Clerk, AGC-43 0 

FAX 202 493 5142 

The Honorable Ronnie A. Yoder 

US Deparlmeni of Transportation 

Office of Hearings, M-20, Room El 2-320 

]200 New Jersey Avenue. S.E, 

woshington, DC 20590 

Cynthia Dominik, Esq. 

Enforcement Division/AGC-300 

Office of the Chief Counsel 

FAA 

800 independence Avenue. SW 

V FAX 202267 5106 K.\(?^X] Kf By; 

Michael B. Selig, MD, FACC. V 

2616 Orefield i?oad r ^ f ' ^ 

Allenlown, Pa. 18104 \" \ 

6)0360 3953 ^<' 

Date: