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 

MAY 2 8 2014 

HEARING DOCKET 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

In the matter of: 

Redemption Air, Inc. 

WASHINGTON, DC 

) 

) FAA Case No. 20 13AL030 106 

) Docket No. FAA-2014-0115 

______________ ) (Civil Penalty Action) 

ANSWER 

Redemption, Inc. ("Respondent"), by and through counsel Law Office of Brent R. 

Cole P.C., answers the FAA's Notice of Proposed Civil Penalty ("complaint") as follows: 

1. The Respondent admits the allegations contained in paragraph 1 of the 

FAA's complaint. 

2. The Respondent admits that Inspector Christina Bryant came to 1420 

Airport Way, Kodiak, Alaska, on or about August 15, 2013, but lacks knowledge 

regarding the remaining allegations contained in paragraph 2 ofF AA's complaint, and 

therefore denies the same. 

3. The Respondent lacks infonrtation as the truth or falsity of the allegations 

contained in paragraphs 3, 9, 20, 21, and 22 of the FAA's complaint and therefore denies 

the same. 

Answer 

lnre: Redemption Air, Inc., Docket No. FAA-2014-0115 

Page 1 of 4 
4. The Respondent denies the allegations contained in paragraphs 4, 5, 6, 7, 8, 

10, 11, 12, 13, 14, 15, 17, 18, 19,23,24,25,26,27,28,and29oftheFAA'scomplaint. 

5. As to paragraph 16, the Respondent admits that he drove away in a red 

truck with tan trim, but denies the remaining allegations in the paragraph. 

6. The Respondent denies it violated Section 119 .59(b )(2). 

GENERAL DENIAL 

The Respondent denies each and every allegation not specifically admitted herein. 

AFFIRMATIVE DEFENSES 

1. The penalty sought for the violation alleged is inappropriate and in contrast 

to penalties sought from similarly situated individuals. 

2. Mr. Stanford's wife had a medical emergency; he informed Ms. Bryant of 

the emergency and requested she come back after 2:00. 

3. The requested records were made available for Ms. Bryant's review. 

4. Respondent reserves the right to assert additional affirmative defenses as 

become apparent during the course of discovery in this matter. 

WHEREFORE, having answered the FAA's complaint fully, Respondent requests 

the following relief: 

1. That the FAA's complaint be dismissed with prejudice. 

2. That appropriate findings be made to support an Equal Access To Justice 

Act Request. 

Answer 

In re: Redemption Air, Inc., Docket No. FAA-2014-0115 

Page 2 of4 
DATED this fl!ntday ofMay, 2014, at Anchorage, Alaska. 

CERTIFICATE OF SERVICE 

This is to certify that on this~ day of May, 2014, a 

true and correct copy of the foregoing document was 

[;5. Mailed 

0 Hand-delivered 

0 Faxed 

to the following: 

Original and one copy: 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building-Suite 2W1 000 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

One copy: 

Craig Wm. Black, Esq. 

Office of the Regional Counsel 

222 West 7th A venue, # 14 

Anchorage, AK 99513-7587 

Craig.Biack(alfaa.gov 

Fax: 271-2800 

The Honorable Richard C. Goodwin, Administrative Law 

Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. (Ell-310) 

Washington, DC 20590 

Richard. Goodwin a 

Answer 

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

Attorneys for Redemption Air, Inc. 

B~h-> CL 

Brent R. Cole 

AK State Bar No. 8606074 

In re: Redemption Air, Inc., Docket No. FAA-2014-0115 

Page 3 of3