703 684 7085 LeClair Ryan 05:01:26 p.m. 03-23-2015 

UNITED STATES DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

FEDERAL AVIATION * ADMINISTRATION 

Complainant, * 

* FAA-2015-0203 

Vs. Judge J.E. Sullivan 

* ROMNEY CYCLE CENTER 

Respondent * 

ANSWER 

Romney Cycle Center ("Romney Cycle"), by counsel, hereby answers the Complaint 

filed by the Federal Aviation Administration pursuant to 14 C.F.R. § !3.209(a), and states as 

follows: 

Section I of Complaint 

!(!). Romney Cycle admits the jurisdictional statement in paragraph !(I) of the 

Complaint. 

Section II of Complaint 

II(2). Romney Cycle denies the allegations of Paragraph II(2) of the Complaint 

1!(3). Romney Cycle admits the allegations of Paragraph II(3) of the Complaint. 

ll(4). Romney Cycle denies the allegations of Paragraph Il(4) of the Complaint. 

ll(5). Romney Cycle is withont sufticient knowledge to admit or deny the allegations in 

Paragraph II(5) of the Complaint. 

11(6). Romney Cycle admits the allegations of Paragraph ll(6) of the Complaint. 

1!(7). Romney Cycle is without sufficient knowledge to admit or deny the allegations in 

Paragraph 11(7) of the Complaint. 

II(8) and (S)(b ). The allegations in Paragraphs Il(8) and (8)(b) of the Complaint 

contain recitation of legal citations and conclusions and therefore no response is required. To the 

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extent a response is required, Romney Cycle admits that the Complaint accurately cites the legal 

citations cited therein. 

II(9) through Il(9)(h): Romney Cycle denies the allegations of Paragraphs II(9) 

through (9)(h) of the Complaint. 

ll( I 0) through II(! 0)( c): Romney Cycle denies the allegations of Paragraphs II(l 0) 

through (1 0)( c) of the Complaint. 

II( 11) through II(!!)( d): Romney Cycle denies the allegations of Paragraphs II(!!) 

through ( 11 )(h) of the Complaint. 

II(l2): Romney Cycle denies the allegations of Paragraph ll(l2) of the Complaint. 

II(l3): Romney Cycle denies the allegations of Paragraph II(l3) of the Complaint. 

ll(l4): Romney Cycle denies the allegations of Paragraph ll(14) of the Complaint. 

ll(l5): Romney Cycle denies the allegations of Paragraph II( IS) of the Complaint. 

Il(l6): Romney Cycle denies the allegations of Paragraph II(l6) of the Complaint. 

II(l7): Romney Cycle denies the allegations of Paragraph II(l7) of the Complaint. 

II(l8): Romney Cycle denies the allegations of Paragraph ll(l8) of the Complaint. 

IJ(l9): Romney Cycle denies the allegations of Paragraph II(19) of the Complaint. 

II(20): Romney Cycle denies the allegations of Paragraph II(20) of the Complaint. 

Il(21): Romney Cycle denies the allegations of Paragraph Il(21) of the Complaint. 

II(22): Romney Cycle denies the allegations of Paragraph ll(22) of the Complaint. 

II(23): Romney Cycle denies the allegations of Paragraph ll(23) of the Complaint. 

Section III of Complaint 

III(24) through III(24)(ee): Romney Cycle denies the allegations of Paragraph II(24) 

through !II(24)(eee) ofthe Complaint. 

III(25): Paragraph III(25) is a request for relief and a statement of the relevant civil 

penalty provisions in this matter that do not require a response. To the extent a response is 

required, Romney Cycle denies the relief sought in this matter. 

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lll(26): Paragraph III(26) is a request for relief and a statement of the relevant fine 

provisions in this matter !hat do not require a response. To the extent a response is required, 

Romney Cycle denies the relief sought in this matter as Romney Cycles denies that it is subject 

to a civil penalty and denies that the civil penalty sought is appropriate. 

AFFIRMATIVE DEFENSES 

1. Respondent denies that the cited code sections were violated. 

2. Respondent respectfully states that to the extent there are any civil penalties to be 

assessed in this matter, there are significant mitigating factors that compel a lower civil penalty, 

including but not limited to the Respondent's prior history and corrective action taken. 

3. Respondent denies all allegations not otherwise admitted and denies liability. 

4. Respondent reserves the right to file additional affirmative defenses that result 

from discovery in this matter. 

WHEREFORE, Romney Cycles denies that the Complainant is entitled to the relief 

requested, and respectfi.tlly requests a hearing on the merits in this matter. 

Date: March 23,2015 

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Respectfully Submitted, 

Brian W. Stolarz 

LeClair Ryan 

2318 Mill Road 

Suite 1110 

Alexandria, Virginia 22314 

Telephone: (703) 647-5946 

Fax: (703) 647-5951 

brian.stolarz\aJ,leclairryan.com 

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703 684 7085 LeClair Ryan 

Service List: 

Original and One Copy bv Federal Express and by Facsimile 

Federal Aviation Administration 

600 Independence Avenue, S.W. 

Wilbur Wright Building 

Suite 2Wl 000 

Washington, D.C. 20591 

Attention: Hearing Docket Clerk 

Fax: (202) 267-1293 

One Copy by Facsimile and by Mail 

Judge J.E. Sullivan 

United States Administrative Law Judge 

Office of Hearings, M-20 

United States Department of Transportation 

1200 New Jersey Avenue, SE (Ell-31 0) 

Washington, D.C. 20590 

Fax: (202) 366-7537 

One Copy by Mail and bv Electronic Mail 

Rashwan Rich George 

Complainant's Counsel 

Federal Aviation Administration 

Office of the Regional Counsel 

AS0-7 

Southern Region 

170 I Columbia Avenue 

College Park, GA 30337 

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