U. S. Depar1ment ofTransportation 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 2Wl000 Re: Inthe Matter ofRedemption Inc. Case No. 2013AL030106 Dear Sir or Madam: 222 W. 7th Avenne #14 Anchorage, Alaska 99513-7587 

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OnAprill6, 2014, we were notified that Redemption Inc. requested a hearing in the abovereferenced case. Enclosed are the original and one copy ofthe Complaint in the above-referenced proceeding as required by§ 13.208(a) ofthe Rules ofPractice in FAA Civil Penalty Actions, 14 C.F.R. Part 13, Subpart G. By copy ofthis letter, a copy ofthe Complaint is being served on Respondent as required by§ 13.208(b). The FAArequests 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: BrentR. Cole, Esq. (with copy ofFAR 13.16 and Subpart G ofPart 13)Inthe Matter of:
Redemption Inc. Judge Not Assigned U.S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION 

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FAA Docket No. Unassigned

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COMPLAINT The Federal Aviation Administration (FAA), by counsel, hereby files its Complaint, pursuant to Rule 208 ofthe Ruies ofPractice (14 C.F.R. § 13.208), and states as follows:
I. On February 14, 2014, Respondent was advised through a Notice ofProposed 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 ofProposed Civil Penalty in the amount of$11,000 was issued. OnApril 15, 2014, Respondent submitted a written request for a hearing.
II. 1. At all times mentioned herein, Respondent was the holder ofAir Carrier Certificate No. RI9A557W and appropriate operations specifications authorizing it to conduct ondemand and commuter operations underpart 135 ofthe Federal Regulations (Title 14, Code ofFederal Regulations) using the business names of"Island Air" and "Island Air Service."
12. 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 ofoperations at 1**~20** Airport Way, Kodiak, Alaska.

3. The purpose ofMs. Bryant's visitto Respondent was to conduct a quick, five-minute follow-up records inspection ofRespondent's load manifests per an ongoing FAA investigation so as to ensure that Respondent was complying with Title 49 ofthe United States Code, applicable regulations, Respondent's certificate, and Respondent's operation specifications.

4. Upon identifying herselfand stating the nature ofher visit, Ms. Bryant was greeted by Robert G. Stanford, the President and Director ofOperations for Respondent.

5. Ms. Bryant asked Mr. Stanford to allowher 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

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

8. Upon finding Ms. Bryant approximately two minutes later, Mr. Stanford confronted her about her inspectionrequest, aggressively told Ms. Bryantto 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 infear from Mr. Stanford's display, Mr. Stanford then moved toward her as ifto physically force her from the building.

10. Ms. Bryantmanaged to avoid physical contact withMr. Stanfordby quickly exiting the opened door.

11. As she exited, and with Mr. Stanford continuing to make physical gesture for herto leave, Mr. Stanford yelled at herto "get offmy danmproperty, you are notfucking 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 herthat he "neverwants to see [her] on [his] property again," that she "is not welcome here," and how "sick [his] wife is and [howMs. Bryant] could give a shit about her."

313. Immediately after that incident, Mr. Stanford entered a red truck withtan trim.

14. While entering the truck's driver's seat, Mr. Stanford yelled at the retreating Ms. Bryant to "stay out ofhis aircraft," slamming the truck's door for emphasis.

15. Once seated inthe truck, Mr. Stanfordreversed the truck, tires screeching, and drove directly towards Ms. Bryant, causing her tojump with fear.

16. Mr. Stanfordthen abruptly stopped the truck and, in an angry and unrestrained voice, told Ms. Bryantthat there wouldbe no manifest inspectionbefore her flight to Anchorage.

17. Immediately thereafter, Ms. Bryant proceededto the safety ofnearby the Alaska Airlines' terminal at Kodiak Airport.

18. Through the hostile and intimidating actions ofMr. Stanford towards Ms. Bryant, Respondent effectivelyrefused to allow the Administrator to perform an inspection.



### III. 1. By reason ofthe foregoing facts and circumstances, Respondent violated Section 119.59(b)(2) ofthe Federal Aviation Regulations (FAR) inthat Respondent failed to allow the Administrator to determine Respondent's compliance with Title 49 ofthe United States Code, applicable regulations, Respondent's certificate, and Respondent's operations specifications.

42. 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 ofthe FAR.
3. Under the facts and circumstances ofthis case, a civil penalty of$11,000 is appropriate. WHEREFORE, the Federal Aviation Administration, by counsel, respectfully requests that the administrative lawjudge enter an order that Respondent be assessed a civil penalty inthe amount of$11,000. RESPECTFULLY SUBMITTED this

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## ;20/1-). HOWARD L. MARTIN, JR. Regional CounselCERTIFICATE OF SERVICE Re: Redemption Inc. FAA Case No. 2013AL030106 FAA DocketNo. To Be Assigned I hereby certify that on this date I served a copy ofthe FAA's Complaint and a copy ofthe foregoing letter byplacing them inthe U11ited States Mail, postage-prepaid, certified mail, return receipt requested, addressed as follows: Brent R. Cole Law Office ofBrent R. Cole, P.C. 821 N Street, Suite 208 Anchorage, AK 99501 I further certify that on this date I have served the original ofthe foregoing letter and the original and one copy ofthe FAA's Complaintby postage-prepaid, certified mail, return receipt requested, addressed as follows: Federal AviationAdministration 800 Independence Avenue, SW Washington, DC 20591 ATTN: Hearing Docket Clerk, AGC-430 Wilbur Wright Building- Suite 2Wl000

Office ofthe Regional Counsel 222 West 7th Avenue #14 Anchorage, Alaska 99513-7587

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### Brent R. Cole Law Office ofBrent R. Cole, P.C. 821 N Street, Suite 208 Anchorage, AK 99501 (907) 277-8001 Attorneys for Redemption Air, Inc. 

# RECEIVED APR 2 22014 

## HEARING DOCKET

UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION NATIONAL TRANSPORTATION SAFETY BOARD In the matter of: )

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### ______ ) FAA Case No. 20 13AL030106 

### REQUEST FOR HEARING Redemption Air, Inc., by and through its attorneys ofrecord, Law Office ofBrent • 

### R. Cole, P.C., pursuant to Subpart G of Part 13 of the Federal Aviation Regulations, requests a hearing in this matterto be held in Anchorage, Alaska. 

## -tL DATED this 

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### -day ofApril, 2014, at Anchorage, Alaska.

Request for Hearing 

### LAW OFFICE OF BRENT R. COLE, P.C. Attorneys for Redemption Air, Inc.

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# c \.**By:~** -- Brent

### R. Cole AK State BarNo. 8606074

In re: RedemptionAir. Inc., FAA Case No. 2013AL030106 Page I of2

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### D Faxed to the following: Original and one copy: Attention: Hearing Docket Clerk, AGC-430 Wilbur Wright Building-Suite 2Wl000 Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591 One copy: Craig Wrn. Black, Esq. Office ofthe Regional Counsel 222 West 7th Avenue, # 14 Anchorage, AK 99513-7587 Fax: 271-28//
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Request for Hearing In re: RedemptionAir, Inc., FAA Case No. 2013AL030106 Page 2 of2