U. S. Depar1ment 

of Transportation 

Federal Aviation 

Administration 

Alaskan Region 

PH: (907) 271-5269 

FAX: (907) 271-2800 

CERTIFIED MAIL-RETURN RECEIPT REQUESTED 

APR 17 2014 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

ATTN: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2Wl 000 

Re: In the Matter of Redemption Inc. 

Case No. 2013AL030106 

Dear Sir or Madam: 

222 W. 7th A venne # 14 

Anchorage, Alaska 

99513-7587 

RECEIVED 

APR 2 2 2014 

HEARING DOCKET 

J)o ex e.-1-=* 

do1l.t- 0\\12) 

On Aprill6, 2014, we were notified that Redemption Inc. requested a hearing in the abovereferenced case. 

Enclosed are the original and one copy of the Complaint in the above-referenced proceeding as 

required by§ 13.208(a) of the Rules of Practice in FAA Civil Penalty Actions, 14 C.F.R. Part 13, 

Subpart G. By copy of this letter, a copy of the Complaint is being served on Respondent as 

required by§ 13.208(b). 

The FAA requests that the hearing in this matter be held in Anchorage, Alaska, and expects that 

the hearing will last one day. 

HOWARD L. MARTIN, JR. 

Regional Counsel 

By: 

Enclosures 

cc: Brent R. Cole, Esq. 

(with copy of FAR 13.16 and Subpart G of Part 13) 
In the Matter of: 

Redemption Inc. 

Judge Not Assigned 

U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

.RECEIVED 

APR 2 2 2014 

HEARING DOCKET 

FAA Docket No. Unassigned - dOl Lt . O I IS 

COMPLAINT 

The Federal Aviation Administration (FAA), by counsel, hereby files its Complaint, 

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

I. 

On February 14, 2014, Respondent was advised through a Notice of Proposed Civil 

Penalty that the FAA proposed to assess a civil penalty against Respondent in the amount of 

$11,000. On April4, 2014, a Final Notice of Proposed Civil Penalty in the amount of$11,000 

was issued. On April 15, 2014, Respondent submitted a written request for a hearing. 

II. 

1. At all times mentioned herein, Respondent was the holder of Air Carrier Certificate No. 

RI9A557W and appropriate operations specifications authorizing it to conduct ondemand and commuter operations under part 135 of the Federal Regulations (Title 14, 

Code of Federal Regulations) using the business names of"Island Air" and "Island Air 

Service." 

1 
2. After flying in that morning from Anchorage, Alaska, on Augnst 15, 2013, at 

approximately 12:35 p.m. Alaska Time, FAA Aviation Safety Inspector Christine Bryant 

visited Respondent's main base of operations at 1 ~20 Airport Way, Kodiak, Alaska. 

3. The purpose of Ms. Bryant's visit to Respondent was to conduct a quick, five-minute 

follow-up records inspection of Respondent's load manifests per an ongoing FAA 

investigation so as to ensure that Respondent was complying with Title 49 of the United 

States Code, applicable regulations, Respondent's certificate, and Respondent's operation 

specifications. 

4. Upon identifying herself and stating the nature of her visit, Ms. Bryant was greeted by 

Robert G. Stanford, the President and Director of Operations for Respondent. 

5. Ms. Bryant asked Mr. Stanford to allow her five minutes to quickly inspect Respondent's 

manifests, noting that she was scheduled to depart Kodiak on a flight from the nearby 

airport terminal at 3:00p.m. 

6. Mr. Stanford refused to allow Ms. Bryant to inspect the manifests. 

7. In refusing to allow Ms. Bryant her requested five minutes to inspect the manifests, and 

without any provocation, Mr. Stanford was loud, was visibly agitated, slammed his fist 

onto a desk and yelled angry obscenities towards Ms. Bryant, causing Ms. Bryant to 

2 
retreat to another area within Respondent's main base so as to find safety away from Mr. 

Stanford. 

8. Upon finding Ms. Bryant approximately two minutes later, Mr. Stanford confronted her 

about her inspection request, aggressively told Ms. Bryant to leave, violently swung an 

exterior door open, yelled that she was not welcome there, and gestured for her to exit 

using rapid forceful motions. 

9. With Ms. Bryant frozen in fear from Mr. Stanford's display, Mr. Stanford then moved 

toward her as if to physically force her from the building. 

10. Ms. Bryant managed to avoid physical contact with Mr. Stanford by quickly exiting the 

opened door. 

11. As she exited, and with Mr. Stanford continuing to make physical gesture for her to 

leave, Mr. Stanford yelled at her to "get off my danm property, you are not fucking 

welcome here, you don't give a damn about people." 

12. Once Ms. Bryant was outside the building, Mr. St8nford scrambled forward, blocked her 

pat further away from the building, and yelled at her that he "never wants to see [her] on 

[his] property again," that she "is not welcome here," and how "sick [his] wife is and 

[how Ms. Bryant] could give a shit about her." 

3 
13. Immediately after that incident, Mr. Stanford entered a red truck with tan trim. 

14. While entering the truck's driver's seat, Mr. Stanford yelled at the retreating Ms. Bryant 

to "stay out of his aircraft," slamming the truck's door for emphasis. 

15. Once seated in the truck, Mr. Stanford reversed the truck, tires screeching, and drove 

directly towards Ms. Bryant, causing her to jump with fear. 

16. Mr. Stanford then abruptly stopped the truck and, in an angry and unrestrained voice, told 

Ms. Bryant that there would be no manifest inspection before her flight to Anchorage. 

17. Immediately thereafter, Ms. Bryant proceeded to the safety of nearby the Alaska Airlines' 

terminal at Kodiak Airport. 

18. Through the hostile and intimidating actions of Mr. Stanford towards Ms. Bryant, 

Respondent effectively refused to allow the Administrator to perform an inspection. 

III. 

1. By reason of the foregoing facts and circumstances, Respondent violated Section 

119.59(b)(2) of the Federal Aviation Regulations (FAR) in that Respondent failed to 

allow the Administrator to determine Respondent's compliance with Title 49 of the 

United States Code, applicable regulations, Respondent's certificate, and Respondent's 

operations specifications. 

4 
2. Pursuant to 49 U.S. C.§ 46301(a) and 14 C.F.R. § 13.305(d), Respondent is subject to 

a civil penalty of $11,000 for this violation of the FAR. 

3. Under the facts and circumstances of this case, a civil penalty of$11,000 is 

appropriate. 

WHEREFORE, the Federal Aviation Administration, by counsel, respectfully requests 

that the administrative law judge enter an order that Respondent be assessed a civil penalty in the 

amount of$11,000. 

RESPECTFULLY SUBMITTED this 

5 

;20/1-). 

HOWARD L. MARTIN, JR. 

Regional Counsel 
CERTIFICATE OF SERVICE 

Re: Redemption Inc. 

FAA Case No. 2013AL030106 

FAA Docket No. To Be Assigned 

I hereby certify that on this date I served a copy of the FAA's Complaint and a copy of the 

foregoing letter by placing them in the U11ited States Mail, postage-prepaid, certified mail, return 

receipt requested, addressed as follows: 

Brent R. Cole 

Law Office of Brent R. Cole, P.C. 

821 N Street, Suite 208 

Anchorage, AK 99501 

I further certify that on this date I have served the original of the foregoing letter and the original 

and one copy of the FAA's Complaint by postage-prepaid, certified mail, return receipt 

requested, addressed as follows: 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

ATTN: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2Wl 000 

Office ofthe Regional Counsel 

222 West 7th Avenue #14 

Anchorage, Alaska 99513-7587 

6 

~L I~ ;20/.!f Date 
Brent R. Cole 

Law Office of Brent R. Cole, P.C. 

821 N Street, Suite 208 

Anchorage, AK 99501 

(907) 277-8001 

Attorneys for Redemption Air, Inc. 

RECEIVED 

APR 2 2 2014 

HEARING DOCKET 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

NATIONAL TRANSPORTATION SAFETY BOARD 

In the matter of: ) 

~ d-o1<4- 0\\S ~R~e~de:::.:m=:pct:.::io:::n:.cAc..:I~· r,~I~n.:::c·:..._ ______ ) FAA Case No. 20 13AL030 106 

REQUEST FOR HEARING 

Redemption Air, Inc., by and through its attorneys of record, Law Office of Brent 

• 

R. Cole, P.C., pursuant to Subpart G of Part 13 of the Federal Aviation Regulations, 

requests a hearing in this matter to be held in Anchorage, Alaska. 

-tL 

DATED this l ~ -day of April, 2014, at Anchorage, Alaska. 

Request for Hearing 

LAW OFFICE OF BRENT R. COLE, P.C. 

Attorneys for Redemption Air, Inc. 

~c::,_._ c \. By:~ --

Brent R. Cole 

AK State Bar No. 8606074 

In re: Redemption Air. Inc., FAA Case No. 2013AL030106 

Page I of2 
u 

r;l, 

~· 

.....:! 

0 

u co -

0 

~ 0 .,., >< N 0\ <..::1 E-< Q) 0\ 

.t:: ro -

0 

~ ;:>-"' 0 N 

r:/1 gj co 0 

' 0 

·- r-- co -Q) <r--· ~ Q) .,N ~ .;; 

I,I.,r:/1 ~r::.'N 

oz roo,.--, 

'-<Q\t'-

0'--'0 

~ - ~ 0\ 

u N ~ '--' >--< co 

!.I. 

!.I. 

0 

~ 

~ 

.....:! 

CERTIFICATE OF SERVICE 

This is to certify that on this J..5i1t day of April, 2014, a 

true and correct copy of the foregoing document was 

~ Mailed 

0 Hand-delivered 

D Faxed 

to the following: 

Original and one copy: 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building-Suite 2Wl 000 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

One copy: 

Craig Wrn. Black, Esq. 

Office of the Regional Counsel 

222 West 7th A venue, # 14 

Anchorage, AK 99513-7587 

Fax: 271-28// 

/ 

Request for Hearing 

In re: Redemption Air, Inc., FAA Case No. 2013AL030106 

Page 2 of2