William A. Curtright Respondent PO Box 1350 Jefferson, OR 97352 Telephone: (503) 209-7388 Fax: (503) 485-0812

In The Matter of: WILLIAM A. CURTRIGHT, Respondent 

### UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS WASHINGTON, D.C.

Docket No. FAA-2015-1319 Case No. 2014NM090046 Judge J.E. Sullivan

RESPONDENT'S MOTION FOR DISMISSAL i'; ""1**~~.** ,.I:

Respondent, William A. Curtright, DBA respectfully files and submits this Motion to Dismiss the Complaint of FAA Administrator Michael P. Huerta, Administrator, Federal Aviation Administration (the "Administrator" or "Complainant") in its entirety, pursuant to 49 C.F.R. 

### § 821.17 

### (a).l Respondent, Dr. Wm. Ames Curtright, DBA files this Motion For Dismissal and would show the court the following: We were served with the Complaint, on or about May 19, 2015. (Attached hereto as Exhibit 1). 1. The complaint by the FAA states that Respondent allegedly violated Section 91.417 (c) ofthe Federal Aviation regulations (14 Code of Federal regulations (C.F.R.) in that he failed to make all maintenance records required to be kept by this section available for inspection by the Administrator.

RESPONDENT'S MOTION TO DISMISS Docket No. FAA-201S-1319 Case No. 2014NM0046 William A. Curtright Respondent Telephone: (S03)209-7388 Fax (S03)48S-08122. Respondent would show this court that on or about August 13, 2015 Federal Aviation Administration, Curt Cowley and Terry Juan inspected the aircraft maintenance records of Supercub N949JP owned by Respondent. They were allowed unrestricted access to the aircraft logbooks without distraction, and found the records were well organized and complete, back to the birth ofthe aircraft. The records did not appear to be altered or edited in any way. No discrepancies were noted, and the aircraft appeared to be airworthy at the time ofthe accident. (Attached hereto is Exhibit 2 An Email from David F. Shayne to Ames Research, dated October 14, 2015 with confirmation that the records have been produced and examined to satisfaction by Billy J. McKibbon, Portland Flight Standards FAA with attached Speed Memo EIR NO. 2014NM090046, Lost Logs.) 3. In addition, Respondent would show this court that on or about August 9, 2016 there was a litigation scheduled conference via telephone in the above-entitled matter and commenced on August 9, 2016 at 1:34 p.m. before The Honorable J.E. Sullivan U.S. Administrative Law Judge. On page 14 ofthe transcript ofthis telephone conference The Honorable J.E. Sullivan U.S. Administrative Law Judge addresses the FAA attorney David Shayne to identify the actual date that the allegation commences as a single violation with a date of on or about in the Initial Disclosure Statement that was served on or about August 11, 2016. (Attached hereto as Exhibit 3 is page 14 Lines 8-25 and page 15, lines 1-2 ofthe transcript ofthe telephone conference of August 9, 2016 before the HonorableJ.E. Sullivan U.S. Administrative law Judge.) Respondent would show the court that the FAA's Initial Disclosure filed on or about August 10, 2016 does
not identify the actual date ofthe alleged violation by Respondent and would further request that this action be dismissed. (Attached hereto as Exhibit 4 Complainant's initial Disclosure Pursuant to the AU's Order ofAugust 10, 2016 and FRCP 26 (1(a).)

RESPONDENT'S MOTION TO DISMISS Docket No. FAA-2015-1319 Case No. 2014NM0046 William A. Curtright Respondent Telephone: (503) 209-7388 Fax (503)485-08124. Respondent would show the court that the FAA has not provided Respondent with the Enforcement Investigation Report that The Honorable J.E. Sullivan U.S. Administrative Law Judge addressed with the FAA Attorney David Shayne on August 9, 2016 during the telephone conference and would show the court that FAA attorney David Shayne answered the court that "it was no problem" to provide the Enforcement Investigation Report to Respondent. Respondent would request the court to dismiss the above referenced matterfor lack of providing Respondent with the Enforcement Investigation Report by the FAA. (Attached hereto

as Exhibit 5 is page 48 lines 22-25 and page 49 lines 1-3 ofthe transcript ofthe telephone conference ofAugust 9, 2016 before the Honorable J.E. Sullivan U.S. Administrative law Judge.) 5. Respondent would show the court that the FAA has never given an explanation ofwhy they are proposing an $11,000.00 fine as the penalty, and what forms the basis for the maximum amount allowed. Respondent would request the court to dismiss the above referenced matter for lack of explanation and basis ofthe maximum amount allowed. (Attached hereto as Exhibit 6 is page 32 Lines 18-21 ofthe transcript ofthe telephone conference ofAugust 9, 2016 before the Honorable J.E. Sullivan U.S. Administrative law Judge.) 6. Respondent would show the court that the FAA has not met the burden of proof as the moving party bringing this action before the court against Respondent because of lack of proving that the imposed fine of $11,000.00 truly reflects the magnitude and scope oftime period where the records were lost and not available to the FAA for inspection. Respondent would show the
court that in Complainant's Initial Disclosures Pursuant to the AU's Order ofAugust 10, 2016 and FRCP 26(1(a) that document 2014NM090046 clearly states that on July 7, 2014 and August 28, 2014 Respondent sent copies ofthe documents that were requested of him to the FAA. (Attached hereto as Exhibit 7 is document 2014NM090046 with lines f, and h, j.) Respondent

RESPONDENT'S MOTION TO DISMISS Docket No. FAA-201S-1319 Case No. 2014NM0046 William A. Curtright Respondent Telephone: {S03)209-7388 Fax {S03)48S-0812would request the court to dismiss the above referenced matter because Respondent did provided the FAA with the documentation that they requested within 6 days ofthe requested materials as requested in the letter dated July 1, 2014 to William Ames Curtright from Martin G. Conroy Aviation Safety Inspector. (Attached hereto as Exhibit 8 is the letter from Martin G. Conroy Aviation Safety Inspector to William Ames Curtright, dated July 1 2014.) 7. Respondent would show the court that the FAA hindered this case by not disclosing to Martin G. Conroy that the documents were produced on July 7, 2014 as stated in the letterfrom Dr. W. Ames Curtright to Martin G. Conroy, dated September 9, 2014 RE: EIR Number 2014NM090046 with attachments. (Attached hereto as Exhibit 9 is the letter from Dr. W. Ames Curtright to Martin G. Conroy, dated September 9, 2014 with attached documents: Oregon Aircraft Registration Certificate, and Memorandum from Ben W. Davidson to William Ames Curtright, dated 8/26/2014.) Respondent would request that this court dismiss this action for lack of evidence that Respondent did not provided the documentation that was requested of Respondent. 8. Respondent would show the court that the FAA Complaint states that Respondent violated Section 91.417 (c) ofthe Federal Aviation regulations 14 Code of Federal Regulations (C.F.R.) which the section reads as follows: Respondent would show the court that the records themselves do not need to, and arguably should not be, stored on the aircraft, but must be produced for inspection in 

### a reasonable amountof time when requested by the FAA, NTSB or law enforcement. See 14 C.F.R. 91.417(c): The owner or operator shall make all maintenance required to be kept by this section available for inspection by the Administrator or any authorized representative ofthe National Transportation Safety Board (NTSB).

RESPONDENT'S MOTION TO DISMISS Docket No. FAA-2015-1319 Case No. 2014NM0046 William A. Curtright Respondent Telephone: (503) 209-7388 Fax (503)485-0812

### WHEREFORE, Respondent respectfully requests and prays that the Administrative Law Judge
enter an Order dismissing the Complaint against Respondent with prejudice.

Respectfully submitted this \

## "\~ay of September 2016



### Dr. WmAmes Curtright

RESPONDENT'S MOTION TO DISMISS Docket No. FAA-2015-1319 Case No. 2014NM0046 William A. Curtright Respondent Telephone: {503) 209-7388 Fax {503)485-0812In The Matter of: 

### UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS WASHINGTON, D.C.

Docket No. FAA-2015-1319 WILLIAM A. CURTRIGHT, Case No. 2014NM090046 Respondent Judge J.E. Sullivan

ORDER GRANTING RESPONDENT'S MOTION TO DISMISS IT IS HEREBY ORDERED: That Respondents Motion To Dismiss is herein granted in its entirety, with prejudice.

I, Judge J.E. Sullivan, grant this Motion To Dismiss in its entirety, with prejudice.

dated this

__day**of-------~** 2016.

Judge J.E. Sullivan U.S. Administrative Law Judge

Attachment: Service List RESPONDENT'S MOTION TO DISMISS Docket No. FAA-2015-1319 Case No. 2014NM0046 William A. Curtright Respondent Telephone: {503)209-7388 Fax {503)485-0812

### SERVICE LIST- BY U.S. MAIL ORIGINAL & ONE COPY Federal Aviation Administration (Fax and Certified First Class Mail) 800 Independence Avenue SW Washington, DC 20591 Attn: Hearing Docket Clerk, AGC-430 Wilbur Wright Building, Suite 2W1000 Fax: (202) 267-1293 ONE COPY Judge J.E. Sullivan (Fax and Certified First Class Mail) U.S. Administrative Law Judge Office of Hearings, M-20 U.S. Department ofTransportation 1200 New Jersey Avenue, SE (E11-310) Washington, DC 20590 TEL: 202-366-6941 FAX: 202-366-7536 David F. Shayne, FAA Attorney (Certified First Class Mail) Complainant's Counsel Northwest Mountain Region, ANM-7 Federal Aviation Administration 1601 Lind Ave. SW Renton, WA 98057 TEL: 425-227-1847

RESPONDENT'S MOTION TO DISMISS Docket No. FAA-2015-1319 Case No. 2014NM0046 

### Docket No. FAA-2015-1319 (Civil Penalty Action)

William A. Curtright Respondent Telephone: {503) 209-7388 Fax {503)485-0812RESPONDENT'S MOTION TO DISMISS Docket No. FAA-2015-1319 Case No. 2014NM0046 William A. Curtright Respondent Telephone: (503) 209-7388 Fax (503)485-0812DAVID F. SHAYNE FAA OFFICE OF REGIONAL COUNSEL 1601 LIND AVE., SW RENTON, WASHINGTON 98057 TELEPHONE: (425) 227-2165 FACSIMILE: (425) 227-1007 

## UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS

WASHINGTON, D.C.

In the Matter of: William A. Curtright FAA Case No. 2014NM090046 Judge Not Assigned

JUDGE NOT ASSIGNED: COMPLAINT 

### The Federal Aviation Administration (FAA), by counsel, hereby files its Complaint, pursuant to Rule 208 ofthe Rules ofPractice (14 Code ofFederal Regulations (C.F.R.) Section 13.208), and states as follows: I. 

### On May 6, 2015, William A. 

### Curtiight was advised through a Final Notice ofProposed Civil Penalty that the FAA proposed to assess a civil penalty in thearnount of$11,000. On May 11, 2015, Mr. Curtright submitted awritten request for a hearing. II. 

### 1. William A. 

### Curttight was and at all times material hereto was the owner and/or operator ofaPiper Model PA-18135, a U.S. registered civil aircraft, N949JP. 2. On or about July 1, 2014, an Aviation Safety Inspector (AS!) from the Portland Flight Standards District Office wrote Mr. Cmtright a letterdemanding that he provide
COMPLAINT DAVID F. SHAYNE, FAAATTORNEY TEL: (425) 227·2165: FAX: (425) 227-I 007 FAA v. William A. Curtright FAA Case No. 2014NM090046 Page 2 ofS Resp. Reply to Order Setting Deadlines 

### Exhibit 1, 

# io?

### aircraft weight and balance, and aircraft and engine maintenance logbooks for N949JP. 3. Mr. Curtright sent two emails and a letter acknowledging that he was aware ofthe demand. 4. As ofthis time, Mr. Curtright has failed to provide the maintenance records referenced above.
lll. 

### I. By reason ofthe foregoing facts and circumstances, 

### Mr. Curtright violated Section 91.417 (c) ofthe Federal Aviation Regulations (14 Code ofFederalRegulations (C.F.R.)) inthat he owned or operated an aircraft for which he failed to 

### make all maintenance records required to be kept 

### by this section available for inspection by the Administrator.
2. 

### In accordance with Sections 4630J(a) and (d) ofTitle 49 ofthe United States Code (U.S.C.) (Transportation) [49 U.S.C. Sections 4630J(a) and(d)], Mr. Curtright is liable for a civil penalty not to exceed $11,000 for each ofthe violations noted. 3. Under the facts and circumstances ofthis case, acivil penalty of$11,000 is appropriate. WHEREFORE, the Agency, by counsel, respectfully requests that the Administrative Law Judge enter an Order that William A. Curtright be assessed 

### aci

### vi! penalty in the amount of $11,000.
Respectfully submitted this 19th day ofMay 2015.

COMPLAINT FAA v. William A. Cunright FAA Case No. 2014NM090046 Page 3 of5 DAVID F. SHAYNE, FAAATTORNEY TEL: (425) 227·2165: FAX: (425) 227·1007 Resp. Reply to Order Setting Deadlines 

### Exhibit 

## 1,

### ANSWER In accordance with Section 13.209 ofthe Federal Aviation Regulations, William A. Curtright,

**~** 

### must answer this Complaint not later than thirty (30) days from thetime it is served. Failure to file an Answer within thirty (30) days without good cause shall be deemed an admission ofthe truth ofeach allegation contained in the Complaint [14.C.F.R. § 13.209(f)].

COMPLAINT FAA v. William A Curtright F M Case No. 20 14NM090046 Page 4of5 DAVID F. SHAYNE, FAA ATTORNEY TEL: (425) 227·2165: FAX: (425) 227-1007 Resp. Reply to Order Setting Deadlines

# --·· William Ames Curtright From: Sent: 

### To: Subject: Attachments: David.F.Shayne@faa.gov Wednesday, October 14,2015 2:15PM ames@amesresearch.com RE: Docket No. FAA-2015-1319, Curtright document2015-08-16-071730.pdf

Here is acopy ofthe email! received and the memo Sorry David, This is to confirm the records have now been provided and examined to our satisfactiort. Mtached is aspeed memo from inspector Cowley regarding his examination of the records. Best regards, Billy J. McKibbon Front Line Manager- Heavy Helicopter Unit Portland Flight Standards Federal Aviation Administration (5031615-3235

.vevalue your feedback. Flight Standards Service Quality Management System {QMS) Feedback: Form:http://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afs/qms/

From: William Ames Curtright [mailto:ames@amesresearch.com] 

### Sent: Wednesday, October 14, 2015 1:58PM 

### To: Shayne, David F(FAA) 

### Subject: Docket No. FAA-2015-1319, Curtright David, I note that this matter is still before the courts. Ialso note the Order for Reassigning the proceedings to anewJudge. Thus I note that this matter isn't dismissed as ofyet. ICould you send me acopy ofyour last letterto the court requesting the Dropping and closure ofthis matter. As you know Curt Cowleyvisited our offices and reviewed all documentation ofthe lostdocuments from Portland, Oregon

Or. Wm. Ames Curtright, BS, DBA

**~EO/President** Ames Research Laboratories, Inc. ames@amesresearch.com Phone: 503-588-7000 

### Exhibit 

# 8)

# In the Matter 

# of: 

# William A. Curtright, DBA August 9, 2016

Condensed Transcriptwith Word Index



# For The Record, Inc. (301) 870-8025
- www.ftrinc.net- (800) 921-5555

## William 

## A. Curtright, DBA 

## 8/9/2016

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### 24 25 case. And not taking into account inflation, the answer is yes. JUDGE SULLIVAN: Okay. Thank you. So in staying with the complaint for just a moment, and I'm on the first page, which is identified as page 2 at the bottom of the page, and it asserts that the allegation arose out ofa July 

### I, 2014 demand from the FAA for certain documentation and logbooks, and as a result the continuing violation or the violation was initiated as ofJuly I, 

### 2014 or some other date? MR. SHAYNE: I hadn't thought about that, frankly, because as I said before, although we could have treated it as a continuing violation, you know, we decided to treat it as a single unitary violation. But in terms ofthe commencement, you know, when did the violation occur is when Mr. Curtright was served either actually constructively with the letterthat was sent out on July !st. You know, there is a-- I think the law provides for afive-day, you know, assumption that a letter is delivered within five days. So when I was going back

and reading the file, I don't remember whether there was any issue aboutit being delivered. Although as you can see from allegation number three, we have evidence that Mr. Curtright was well aware ofthe FSDO

-- I'm sorry, that's Flight Standard District Office. We often use the term shorthand FSDO. JUDGE SULLIV1\N: Okay. Well, let me go back to you, Mr. Shayne. What I'd like to have you do is in your initial disclosure status is to identify the actual date that the allegation commences as a single violation if it's-- ifyou want to confirm that it's on or about July I, 

### 2014 or you want to identify it on or about July 6, 

### 2014. Ifyou would just nail that down for all ofus. MR. SHAYNE: At this moment or later? JUDGE SULLIVAN: No, as part ofyour initial disclosures. MR. SHAYNE: Later. JUDGE SULLIVAN: Yes. We'll talk about the date or deadline for initial 

### disclosures in amoment. Now, l'mjust ask!ng you to be sure that you perfect your complaining record so that we all knovv· and 13

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### 24 25 it's clearly eslablished by esrly in the action. So Jet's talk a little bit more about your July22nd, 

### 2016 proposed schedule. You had talked about initial written discovery requests to be served with some response time and so forth. About bowmuch

-- assuming for the sake ofargument that there's no resolution to any issues that are currently on the table, either by agreement or by dispositive motion, how much hearing time do you think this case would take and \vhere do you think it should be held? MR. SHAYNE: First ofall, in all deference and clue respect, Your Honor, it's difficult for me lo say with any exactitude what-- how long it would take to try a hearing, as I have not had the-- I have not had the privilege oftrying a case before Your Honor. And it's been my experience as a litigator for 26 years, everyjudge is different and two judges can have the same case and, you know, give very different

results. The other part ofthat, ofcourse, at this point in time I have no idea what Mr. Curtrightis going to present for a defense. What I can say is with fair certainty I don't think my case will take more than two hours at mostto present my case-in-chief barring anything unusual or unforeseen. JUDGESULLIVAN: Sure. MR. SHAYNE: As far as venue is concerned, we didn't-- usually those things get resolved earlier on. I didn't realize that was an open question. My witnesses are FAA employees, so venue is less 

### of' an important issue to us and 

### I don't remember where 

### Mr. Curtright lives. But ifhe has 

### a request for venue, we could in all likelihood agree to what is reasonable. JUDGESULLIVAN: Okay. You're currently located in Renton, Washington. MR. SHAYNE: Yeah, I am. The inspectors 

### are in Portland, Oregon. JUDGESULLIVAN: Okay. And Mr. Curtright is ·-has an address in Jefferson, Oregon. So it's likely that we're


### 4 (Pages 13 to 16) 

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16

# ..

DAVID F. SHAYNE FAAOFFICE OFREGIONAL COUNSEL 

### 1601 LINDAVE., SW RENTON, WASHINGTON

### 98057 TELEPHONE: 

### (425)227-2165 FACSIMILE: 

### (425) 227-1007

\ 

## UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS

WASHINGTON, D.C.

In the Matter of: · William A. 

### Curtright DocketNo. FAA-2015-1319 

### FAA CaseNo. 2014NM090046 

### Judge J. E. Sullivan



## TO RESPONQENT: 1. Includedherewithplease find copies all ofthe documents in Complainant's possession relating to the above-captionedmatterthatmay be offeredinto evidence.
2. 

### Atthis time, Complainant anticipates as calling as its solewitness Marty

### Comoy, FAA 

### Aviation Safety Inspector. He maybe reachedthroughthe undersigned. Respectfully submittedthis August 11, 2016

------ ·**--FAA-v,-WU!iam-A~Gat'!rigllt·** - DocketNo. FAA-2015-1319 FAA CaseNo. 2014NM090046 ---DAVIDF. SHAYNE, EAAATIORNEY-........ TEL (425}227'2165; FAX: (425) 227·1007

# In the Matter 

# of: 

# William A. Curtright, DBA August9, 2016

Condensed Transcript with Word Index



# For The Record, Inc. (301) 870-8025- www.ftrinc.net- (800) 921-5555

### William 

## A. Curtright, DBA 

## 8/9/2016

I 2 3 4 5 6 7 8 9 lO II 

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### 16 17 18 19 

### 20 21 22 23 24 25

I 2 3 4 5 6 7 8 9 

### 10 II 

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### 16 17 18 19 

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### 24 25 Mr. Curtright, is two primary concerns and I want you to correct me if! get these wrong. Number one, you think that the prosecutor should not have charged you with this incident and, number two, ifthe prosecutor had used his discretion, that the charge is accompanied with an inappropriately high fine. Would those be your two primary issues? MR. CURTRIGHT: Inappropriately high fine would be one and wrongful prosecution as one that concerns me in reference to going after other pilots that might have the same problems and then will have attorneys that supply them with, you know, stufflike that. I see this. This is the principle ofthe thing, Your Honor. JUDGE SULL!VAN: I actually had that pm1icular defense raised before. Someone else has come. Interestingly enough someone else who was a Vietnam veteran raising the defense that because he thought other people had committed the same violation and hadn't been charged, that he should not have been charged, that it was wrong. And it is creative and I tip my hat to

you. It's a creative argument, but I don't believe there's legal authority to support it because

-- and I'm going to give you another roadside analogy. A police officer who's sitting in his cruiser on the side ofthe road may not be able to stop everybody who is speeding past him. But when he does stop a car and he stops them because they were speeding and he has the ability to prove that, they have to defend that allegation, against that allegation, and the defense that there were other people who were speeding and who did not get stopped doesn't have legal authority to support a dismissal. Ifyou can find legal authority at this particular arena, you're welcome to look. I certainly have addressed this before and the parties who were appearing before me were not able to find anything nor was I, but you're certainly welcome to look independently. Typically the law finds for the prosecutor's discretion to charge and the prosecutor may charge or may not charge and it's a discretionary call that cannot be 45

46 I 2 3 4 5 6 7 8 9 

### 10 ]] 

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### 2 3 4 5 6 7 8 9 

### 10 11 

### 12 13 14 15 

### 16 17 18 

### 19 20 21 22 23 24 25 second guessed by this Court. But I'm going to suggest to you that you look intothat particular prong of-- since it is ofinteres! to and what we should probably do is JUSt do an initial disclosure exchange and then have a second conference to talk about the specifics ofthe rest ofthe discovery schedule because we're running out oftime. And I am going to also suggest that it is impot1ant to remember that in litigation you have to wear several hats, especially when you represent yourself, and one ofyour hats is a litigation hat where you're preparing for litigation and one ofyour hats is always a settlementhat where you're also looking at 

### how to reso1ve issues. Ifyou were, Mr. Curtright, represented 

### by counsel, your counsel certainly would be addressing both simultaneously. That's good litigation practice. So you 

### want to look at Mr. Shayne and not only yourhonored opponent and the litigation itself, but also as your friend across the aisle for any settlement

discussions that you might privately want to have with him about money issues in particular. And setllement discussions may occur at any time and I never need to know about them, but it behooves you to always keep that door open orat least ajar as we talk about these other issues at the same time. So, Mr. CuJtright, you have wanted an extension farbeyond August 

### 19, 2016 for the exchange of**:~itial** disclosures. Since you're going to be doing 

### alittle research at the same time, 

### why don't we do this andjust say initial disclosLJ.res should be exchanged no later than September 

### 9, 

### 2016. That is the name, address, phone number, ifyou have it, ofai!lyone you know that might have information that's helpful to the charge orto the proposed fine and the identity or the actual copy ofthe document, ofany documents that you think migl:Jt be helpful And, Mr. Shayne, since Mr. Cmtright never retained ALtorney Flaherty, I'm going to ask you to di:ectly send to Mr. Curtright the enfOrcemf,ntinvestigative report that you -- 

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## William A. 

## Curtright, DBA 

## 8/9/2016

I 

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### 4 5 6 

### 7 8 9 10 II 12 13 14 15 16 17 18 19 20 21 

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### 24 25 MR. SHAYNE: Your Honor, it's no problem. JUDGE SULLIVAN. Okay. Thank you. Now, Mr. Shayne, for your private discussion and exchanges, do you want to use E-mail or would you prefer to have U.S. mailing or fax? MR. SHAYNE: Well, we have no objection to using E-mail. We can I guess -- I'm sorry, let me ask for clarification of that. Is Your Honor talking about communications with the Court or communications between the parties? JUDGE SULLIVAN: No. For your private communication with Mr. Curtright when you exchange discovery. Do you have a preference so that everybody knows? This Court cannot accept any kind ofE-mail filings. We don't have any E-mail server. MR. SHAYNE: Understood, Your Honor. I'm aware ofthat. E-mail is fine for me. JUDGE SULLIVAN: Mr. Cmiright

-- MR. SHAYNE: Whatever Mr. Cmiright wants. JUDGE SULLIVAN: Okay. Mr. CUitright,

what's your preference? MR. CURTRIGHT: Oh, Ithink I've had difficulties on the E-mails going back and forth with Mr. Shane because he's out ofthe office a lot. Anyway, I'm out guite a bit this next month, too, as well, so this is my worst time ofthe year, but Ithink by mail is good. The last minute stuffon the E-mail, 

### minor communications, is fine on E-mail. So anyway, okay. JUDGE SULLIVAN: Well, I would encourage you both to exercise your best efforts to get this exchanged early as opposed to last minute and you're welcome to utilize E-mail, fax and the U.S. mail as you deem fit, and then why don't we schedule a new telephone conference shortly after September 9, 2016, so that we can talk about what's left to do and why. Mr. Shayne, starting with you, I'm going to look at my calendar for the week of early September 19 or 20. Do you have time available on either ofthose two days for a second litigation scheduling conference? 49

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### MR. SHAYNE: I do, Your Honor. JU[)GE SULLIVAN: Okay. Mr. Cmtright, same question to you) sir. 

### MR. CURTRIGHT: Okay. Rephrase the question What's on the 19th did you say? JU[}GE SULLIVAN: I'm looking at the days ofivlonday, September 19,2016, and Tuesday, September 20, 2016, to schedule another ·- a Iitigation scheduling conference. Do you have time available on either ofthose two days? MR CURTRIGHT: Ithink it would be betterfor us, Your Honor, ifit could be more like maybe Friday. Is that possible? JUDGE SULLIVAN: I am not available on Friday. MR CURTRIGHT: How about the 22nd, would that work? JUDGE SULLJVAN: I'm not available on the 22nd I'm giving you the dates that I'm available. !hat's what's happening. MR CURTRIGHT: Then, okay, I am going to write 

### you a brief. Okay. I guess that's the way it is. Your Honor, I'm at your -- I'm going to have to say that you're in charge,
right? 52 JUD>GE SULLIVAN: Oh, yes. Do you have time available? The question to you, Mr. Curiright, is do you have time open on your calendar on either day? 

### MR. CURTRIGHT: I'll make time available, say afternoon, would that be around 3:00 ourtime, Oregon time? JUDGE SULLIVAN: I have --I'm on the East Coast and so ifl'm scheduling something in the afternoon, it's usually in late morning for you. So, for example, right now it's 20 to 3:00 my time. 

### MR. CURTRIGHT: Yeah, right. So on my time would be

-- oh, Isee. Okay. JUDGE SULLIVAN: I'm ahead ofyou. So if! schedule this at I:30 on Tuesday, the 20th, that would be 10:30 in the morning your time. Could you be available for something on that date and time? 

### MR. CURTRJGHT: Okay. 10:30. JUDGE SULLIVAN: Well, it's 10:30 your time, but l'm going to use East Coast time for everything in my order. So it's going to say 1:30 p.m., East Coasttime. 

### 13 (Pages 49 to 52) 

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# In the Matter of: 

# William A. Curtright, DBA August 9, 2016

Condensed Transcriptwith Word Index



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### William 

## A. Curtright, DBA 8/9/2016 29 31 l March 9, 2015. So we've already supplied the I Your Honor. 2 EIR. 2 JUDGESULLIVAN: Okay. Thankyou. 3 MR. CURTRIGHT: Your Honor. 3 Well, then let's talk a little bit 4 JUDGE SULLIVAN: Okay. To who was 4 about discovery. Do you know what I am 5 that

-- what attorney was that at that time? 5 talking about when I refer to discovery, what 6 MR. SHAYNE: Thomas Flaherty, 6 that means? 7 FLAHERTY. 7 MR. C\IRTRIGHT: Yes, Your Honor. 8 MR. CURTRIGHT: Your Honor. 8 understand that there's --that you require 9 JUDGE SULLIVAN: Excuse me, 9 information to be sent that Imight have as 10 Mr. Curtright, ifyou wouldjust-- 10 discovery. 11 MR. CURTRIGHT: Ihave no other 11 JUDGESULLIVAN: Okay. Do you have 12 attorney, Your Honor. 12 some experience, then, in litigation in some 13 JUDGE SULLIVAN: Please be patient and 13 other forum that would help assist you in this 14 1will get back to you. 14 proceeding? 15 Mr. Shayne, when did Mr. Flaherty 15 MR. CURTRIGHT: Very little, Your 16 withdraw? 16 Honor. 17 MR. SHAYNE: I don't know that I ever 17 JUDGESULLIVAN: Okay. Was it in a 18 got any formal notification. I only know that 18 civil case by any chance, because there's 19 when I called him to discuss the case, he 19 different types ofrules that attach to
-- 20 informed me he's no longer representing 20 MR. CURTRIGHT: No, Your Honor, I 21 Mr. Cmtright. 21 haven't been in a lot ofbattles, so. 22 JUDGE SULLIVAN: Okay. Thank you. 22 JUDGE SULLIVAN: Okay. All right. 23 Getting back to you, Mr. Curtright, 23 Well, initial disclosures is a form of 24 can you tell me what familiarity you have, if 24 discovery where parties provide each other 25 any, with the Rules ofCivil Procedure or the 25 with certain information without being asked,
30 32 I FAA Rules ofPractice? I and the initial disclosures that I'm talking 2 MR. CURTRIGHT: Your Honor, Ihave no 2 about are outlined in Rule 26 ofthe Federal 3 experience in that matter. Also, I'd like to 3 Rules ofCivil Procedure and that's something 4 add that I have had no other attorney. So if 4 you can find on line ifyou type in Rules of 

### 5 he was communicating with an attorney, it was 5 Civil Procedure, Rule 26. 6 not with my authorization. 6 Butjust so you know, when you do 7 JUDGE SULLIVAN: Okay. So you don't 7 initial disclosures, and I'm going to give you 8 know a Thomas Flaherty and he was never hired 8 both a deadlin< to exchange infonnation of 9 to act for you. 9 this type, you give the name, address and 10 MR. CURTRIGHT: He was never hired, 10 phone number ofeach individual that you know 11 Your Honor. I talked to Mr. Flaherty for 11 that's likely to have discoverable information 12 about 20 minutes and that was my only 12 about the charge involved in this case. 13 conversation and offhe went. So anyway -- on 13 You give a copy or a description of 14 his own and I informed him that he was not my 14 the document ofanything that you have in your 15 attorney and I informed the FAA that he was 15 possession, custody or control that has 16 not my attorney. 16 anythingto do with this particular charge and 17 JUDGE SULLIVAN: Did Mr. Flaherty ever 17 the proposed fine. 18 advise you that he had contacted the FAA and 18 And forthc FAA, they also should be 19 asked for material on your behalf? 19 giving you an explanation ofwhy they are 20 MR. CURTRIGHT: Yes, he did, but he 20 proposing $11 ,000 as the penalty, what tlmns 21 was never -- he was informed he's not working 21 the basis for!hat. 22 for me, so Mr. Flaherty did so on his own. 22 Those are the initial disclosures to 23 JUDGE SULLIVAN: Okay. Did he ever 23 get the ball rolling so that you have an idea 24 forward that information to you? 24 ofwho is involved or who mightbe involved as 25 MR. CURTRIGHT: I don't believe so, 25 a witness for the opposing side and whatthey
8 (Pages 29 to 32) 

### For The Record, Inc. (301) 870-8025- www.ftrinc.net- (800) 921-5555

**-(~**

## . ' 

### completerecord ofh.,

### currentflight review. The LOI was datruiJ/4114 and sent9/5/14. (lOP 10)

. J. 

### Mr. Curtrightresponded to the LOIwith correspondencedated9/9/14. He explirinedthat the 

### airframe and maintenance logbooks were located in Canada 

### Mr. Curtrightdid enclose a complete copy ofhis currentflight review thatincludedthe instructor's endorsement. (lOP 11) k. 

### On 9/24/14, InspectorConroycontactedMr. 

### Curtrightbytelephone. InspectorConroy asked him 

### if 

### he il)tendedto present

### this office withthe airframe 

### and engine logbooks for N949JP to 

### allowthe FAAto conclude

### its investigation intothe aceident of6/15/14. 

### Mr. Curtrightrespondedthatthe logbooks were athis home in 

### C1111ada

### andthathe 

## was not in aposition to

### travelthere 

### andrecoverthem. InspectorConroythen asked Mr. 

### Curtright if 

### he couldprovide afuture date when

## Ire would be able to maketb.em availableto this office for inspection. Mr. 

### Curtrightrespondedthathe didnotexpectto travelto Canada anytime inthe nearfuture. (lOP 12) 

## 4 .'\
. . . ll.

.. .. . 

# ··*-·

# -j <:,·· o jl ; j- ! ' I "
- f

.. • " • • , ,,.,

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**~~** , ' ' fJ ' ' ' '

**~** ,.,' l.;, ' ' '' ' ,· " '' ' ,I c 

## :tPt'l "'< ' ,

(Revised- 04116/2013)FlightStandalds Dlstrl.ct0111"'!

**us.~.ment** 

### ofTranspOr!Ofion No{lbwestMoul\lllln !'legion Colorado, ldab<>, Moatana,

**~an,** Utah, Wi!Shinglan, Wyoming ·318llNW·2291hAvanue 

### Fedii!UI

**~allon** 

### AdmrnisiiOiiOn


### July 1, 2014 **Hillsb~.** Oregon 97124 liQ:MifS-@!Q,

**F~ ~03-$15-3;100**  nlarty.g.conroy@faa.gov



### CER11FIED MAIL/SPECIAL 

## DELIVERY-RETURNRECEll'TREQUESTED WilliamAliles Curtright 139516thSE Salem:, Oregon 97302 Dear Sir: 

### This officeis investigatinganaircraft 

### accidentinvolvingN949JP thtt occurredonJune 14, 2014, inTumer,Oregon

### withyou

### acting aspilot-in-command.

**Pl~ase**

### providethe following documents for myreview by

### JUly 17,2014. ·


## • Aircraftweight

## andbalance 

## • Airframe andEngine

## maintenance logboeks 

### • Airworthiness and

### Registrationcertificates • Documentationofcompliance

### with 14 CFRPart61.56(c) Icanbe reached at503-615-3240

## to make artangements for thismievt.

NM09: M. Conroy: MGC; 3240:7/1114: N:IFSDO ElectronicWorl< SpaceUnvestlga!lons\Accldent\N949JP • PA-18·135 - 6-14-2014\LOT 7-1-2014 N949JP- Curtrtghf.docSeptember 

### 9, 2014

Martin G. Conroy Aviation Safety Inspector FlightStandarc!s .Dist. Office 3180 NW 

### 229thAve. Hillsboro, OR 

### 97124 Re: EIR Number 2014NM090046 Dear Sir: As explained via email, tneaircraft logs are not in the United States;

**t~ey**are in canada where I also live. Iam now awaitingthe time to repair my aircraft repair. In

**~rderto** meetyour request, 1

have emailed the remaining docum_ents a.M the Certification ofAnnual Inspection as requested tothe Portland office_. All other documents have been provided to you as requested. Is it po55ible your people have nat opened youremails to check the attachments? They were sentto your Portland office. If you are still missing something let us know. We have provided a letterfrom the mechanic who dld the annual certification inspection. We recently emailed the weight and balance but again we will mail ittoyou. The event was on my private property. Ittook place after landing; there was asteering problem because ofacollapsed gear which caused a breaking to the left. The aircraftwas not airborne but inertill and the rail on tiJe floats pulll;!d the aircraft to the leftand into the grass, thus, our description ofthe event which damaged the aircraft, Your letters indicate you have never received any ofthis information which is troubling. We have provided you the aircraft weight and balance, a.irworthiness registration certificate, and documentation with the flight review requirements and all the documents you requested, yet you people act as ifyou neverreceived those items. We have provided to you the documents in aspirit of cooperation. Again, we hope this meets yaur needs ahd pray this brings closure for us both. Dr. 

## w. Ames Curtright

Ames ResearchLabomtories,-Inc. • 1891 161 "

# St SE, Salem.



### ~.usA97302 Toll-free: 888-345-0809 o Phone: 503-588-3330 • Fax: 503-364-2380 • amesstafi@arnestesearch.com

### FAA NO.: 

### N949JP Year: 1953

**--~---** 

### Certificate: 42137 Expiration: 2/2812015

# I Memorandum

To: WilliamAmes Curtright 

## From: Ben W. 

## Davidson 

## Date: 8/26/2014 Re: AnnualInspectionN949JP Bill, This letter is to verifYthatIcompletedanAnnualInspection onN949JP aPA-18 on September23rd, 2013. Atthattime1 providedyou with adiscrepcmcy listthat includedan expiredbattery inyourELTthat requiredreplacement. 

# Ifneed further assistance,please do nothesitate to callanytime before 9pm anyday. 

## (541) 490-6980. 

# Cff_tpc[2j
Ben W. 

## Davidson A&P2855347IA

1UNITED STATES OFAMERICA DepartmentafTranspmtation Federal AlllaHan AllrrlinlSIIalian MEDICAL CERTIFICATE THIRD CLASS

This certifiesthat (Full nameandaddress): WIJ..I.IAM AMES CURTRIG!fT 4135 PARADISE HILL TURNER OR 97392 USA 

# I

Dale ofBin• 

### IHeiQhl 

### IWeig•l 

### I Hair 

### I Eyes 

### I Sex 06/'1..6/1943 70 

### ,.._, BROWN BLUE M has metthe medical standardsprescribed inj:lart67, Federal Aviation RB! ulalians. farthisclassofMedical Certificate. Must. wear corrective lenses. 

# • • 

# i

Date ofExamination

**_l~;er's** Designation No. 

### '

**061261201~** 

# J "'"""l"jf.OI'

.. -:/, 

# ?;JJ._

**=:d'~.MD** / !



### 1tl!l!eNA~ 

# \.

**~** I 

### 1



### ~\. (. 

# ·--· Applicant 10: 199634:!314 

# """"'' FAA FannISBN IS.oBJ

**StlpetHdcs~Ei!IPOn** NSN 1JD52.11D.8,7ti-7DDl : **CO~OITIONS** OF ISSUE The holderofthis certificate must:
• Have it in hfs or her peJSOnal possession at all times

while exerdSill!J privileges ofan alnnan certificate. (14CFR § 61.3) • Understandthat !he issuance ofa medical certificate

by an AviationMedical Ekaminer may be reversecl by Ute FAAwihin 60 days. (14CFR §

**67.~7)** • Comply with validity standams specified forfirs<·.

second·, and tbild..class medical certificates. (14CFR § 61.231 Comply with anystatement offunctional, operational, and/or time limitation issued as acondilion of certification

. (14CFR § 67.41111 (Note: Aletterofa!Jthorization (orSODA) describing any suchlimitalians must be keptwith this certificate at all timeswi1Weexercising the privileges ofan ainnan certificate.) • Comply with th! standards relating to prohibitions on

oper.aliondurill!JI 111edtcal deficlency. (14CFR §§ S1.53. 63.19, and 65.49) For lntemationalOperations Only: Some holders may be affected bycertain icttemational medical standards. Consult lhe U.S. A.emnauticallnfcrmallon Publication for U.S. differences wi1h !CA.O Annex 1meclical standards.

-·--·--·-- -- ·---- ---- -·- •-- ---····-··- ••••-·--- ·- ·-- •

**--iOJinfioil~';tj,~;.,-** · •• ·--- •···-- ---- ·•·•··-- ·-- -- · ·- ••-·••---- ··- ··- •·- 

# (f) .

. AEROSPACE MEDICAL CERTIFICATION DIVISION, AAM • 300 FAA Civil Aerospace Medical Institute Mike Monroney Aeronautical Center P.O Box26080 Oklahoma City, OK 73125-9914

WILLIAM AMES CURTRIGHT 4135 PARADISE HILL TURNER OR 97392 USA

Dear Airman: Above is your new medical certificate. It supersed!!s any previous one you may have been issued. To validate tbis certificate, it is necessary that you sign it in the space provided {Ainnan's

**Signatur~).** This certificate must be in your possession at all times while exercising your pilot

**privileg~<;.**

**Creal~** on ThuiSday.

**J~ne** 26. 2014

### The Standard

### Pilot Log Name \\..-., 

# W , {::.,V\.1\, <2.

## "J 

# C
**\.>....'-.\v(,~U.\ ~~**  **~** LogltOokNundler_ 

### Penunent MailingAddress \ 

## 'e>'\\ \ 

## \Llli

**"<:::..~** 

### . "'=:::.\.; Flam----- 

# --------~~~~~~~~~~~~1~{)~~~Q~~~~~~~~~---------------•----------- Cerlilicates Held Rilling Record 

### Aircraft 

### '!We Ratings

**'~Woe** 

# -- Certificate Nlllllller 041PiANE 

## t=\

..**~** 

# 2\ !!1'\JDENTPILOT 

# u:... i! I <"



### SSI."\~ S.

### ~';-<\<?..:'flS

## ~ENGINE:' Q<>'l'IO g.es; 

## "\

**~**

## 'ci'
.....

**..~~...** \



### ~S,~. SPORT PILOT a MULTI-ENGINE: OLA\!D a sEA RECREATIONAL PILOT 

# s b,

# 1/ l"'l'\ Oftiii1Ln-ENGINE: Umil!dtoCenterUnaThrost PRIVATE PILOT 

### S"\"'>

## -<'1'1' 7

# -?tr::> a INS'llllJMENT COMMERCIAL PILOT aGUDER aAEROTOII'I a WINCHTOW FUGHT INSTRUCTOR 

## aPO~~~~~-sr~L IIRUNETRANSPORT PILOT a ROfDRCRAFT COI'TEil 0 J!;PLANE

**~VIATION** TECHNICIAN a LIGHTER-THAN-AIR 0AIFlSHIP a BALLOON 3ROUND INSTRUCTOR a POWERED.LIFT 

### ·• aGI BASIC a Gl ADVAI>ICED a Gl INSTRUMENT a OlHER RATINGS (Specify)

## Conroy. MartyG (FAA) Fton:l: 

### Sent To: 

### Subject:

**A_U!i~hments:** 

### Marty, **\llli!liiftii~iQiiitli~ ~ames@amesrl)sear'ch.com>** 

**IV19M~i!~®l~~l1:s7** 

### AM 

## Coiii'iiy;iiAartyG 

# (FAA) N949JPInformation
**oo~~?4-1':1Qt:9!~J~~47'iidtReg'bbroro114-o7o72014l04040.pdf;** 

### Pete

**D9SR7~7:t4 87:P.7:?1!~4:tll?~?tiiplllf;m~cljcal**  

### ooco7a7a4,oVQ720141132S1.pdf

Please. see attached. As 

### you mightrecallyoutookapictureofthe air-worthiness certificate whenyou came out, want me til.

### take anotherpictureforyou? itthatwas tape(! in the c;ockpitont!le wall. Airworthiness, wetdamaged reordered fresh ()ne, lli'AnnOal copyfrom log. IproVided a.mediCal certificateto you atthe time, and 1 

### have afresh New Medical exam lastweek.

1 

### feel sadforthe People thatwere lostatthe toast. It's a hard Job, yourJob.The pain you see 1 

### cannotimagine.Thanks for yourservice and for yourpastservice in 

### the military. As 

### 1 stood on my 

### hill on thefourth ofJulywatchingthe explosions offireworksfrorn all side.s. Itreminded meofViet Nam ofShens going off, ofcannonfile, and.the roUingthunderofArmageddon. It was differentfor me that night, it

### gave m.ethoughts ofwhatwas to come ifwedo not changethe course ofour country. Good Luckto you and God blessings.
Ames

1

### Conroy, MartyG(FAA) Fi'om: 

### Sent: To: Cc: 

### Subject:

Mr. Ames Curtright: Conroy, Marty G(FAA) 

### Mn!llllt'' i"[:!(l't

### c1Q>li'12:21 "M

**··~~,.**

### .....-f- ..**~-~''··** 

### _.,., . .

**;a,..~-** . r· .. 

### W,iUiii!l!iAnies Curtright' McKibbon, 

### BillJ (FAA);. 'Lewis Lar:ry' 

### RE.: N949Ji' lnfonrtation

I do have 

### a photograph of

### the airworthiness certificate, and 1 do not need another. 

### ldo. need 

### acomp1e.te tecord 

### ofyotl"r

### fllghtrl:!m-e:wthllt int:iiiilesthe iflstriitl!tlr's **efltftii'Sement~iilnature**

### .

............_ 

# --

**Plea~ pi'Q~ti!l~** 

# roe adate

**t~at** 

### Ican

## inspectthe aircraft

**welght/halaiill~**

# and alrrratnii/engine maihteriilnce logbooks. Thankvou. · --OriginaI Message--- From: Vl?illiam.Ames:.!3urtright lmailto:ames@amesresearch.coml sent: **Monda¥l~Uiy•07.20141167**

### AM To: Conroy, MartyG

### (fAA) Subject: N949JP Information Marty, Please see attached. As you might recall you took apicture oftheair-worthinesscertificate when you came out, want
me totake another picture for you? itthat wastaped inthe cockpit on the wall. Airworthiness; Wet damaged reordered fresh one_ Bi-Annual copy from log.
I provid.ed a medical certificate toyou at the time, and Ihave afresh New Medical exam lastweek.
Rest

### of

### DOcumentsaruorthin:Ganada



### log~,

### Will need some

### tlrfletQ

**~ithern'** Mytraveling$tyfe is a

## bitcramped 

### foi

### abit

## fwilfi\6t bira\iailable

### thi!rest 6fthisweek.
Ifeel sad forthe People thatwere lost at the coast. It'sahard Job, yourJob. The pain you see Icannot imagine. Thanks foryour service and foryour past service in the military. As I stood on my hill on the fourth ofJulywatchingtheexplosionsoffireworksfrom all sides. It reminded me ofViet Nam ofShells going off, ofcannon file, andthe rollingthunder ofArmageddon.
Itwas differentfor me that night, itgave me thoughts ofwhat was to come if

### we do not change the course ofour country. Good lucktoyou and God blessings.

Ames

1

### Conroy, Marty G(FAA) From: 

### Sent: To: 

### Subject: Attachments:


### To: 

### FAA Marty, ,__ ' _,____ ·----·---·-·

**-------·---~-----** ..--..-----.--- _____,_ ·- ,_,__,,



# ~=:=~~~~~:~~~~esresearthCOITl> WilliamAmes tiiitrighf N949JP tnformation

**WI!I\Jnt~Biii~~pgf; 20;!;~A'I!!Il\@j•1li~P~.()ti¢ri**  NC!ticii!:pdf -·.···c .............., ...... ..

It

### was apleasure to meet you 

### atAmes Raoe.h. 

### I



### hav~i!W~"'vgry

### •!!roundep

## Sil•'··h,ave



### n~!;~.~~ **~~.~~ ~g~tHHr;!;~** **~r~.Wi!'H?~.~~Jl.~!!!** t9;gq



### Milf~isvear,. butas you suggested Idid 

### locate Who d.id

### the ilijiltiaf and

**g(ll~** 

### leftefto lr\eefyrit.(f needs iSV()U 

### reejuested. I have

### been very busy

### with the patrioticevent I

### had (http:@tberinggftheeagles.com/l; nowthatitis over,.! have had a little bitniQre time. Keeping America safe for

**democ~cy.** Seemsas 

### we are gaingto haveto 

### continueourbattlefor freedom wiU neverend. The sacrifice of

### outbrothers, who died, we must notforget. 

### Thus we continueforthem. U 

### Tubesare on 

### line. Worth watching. Warmestand best,

Dr. W. Ames Curtright DBA Office, 503-588•7000 

### Cell, 503-209-7388

1'!2. Hobbs527.7

Viking Air Ltd. September II, 1997 The f'otlowing work was completed Under W/0 #14603i -11IIDO)fed EDO floats 89-.lOOO, r/!1 sin 3594, 1/h sin 3593 and installed Wipaire Ainpbib floam sin rib 21044, lib 21043. Wipaire Ampbib floats were installed
in accof!lance wjtb STC SA 00713CH and W"tpaire Master Drawing list for Piper PA 18 and model2100 floats reissued 6/.17/97. ,lauding gear system working nmmally and checked serviceable. - itBtallation
of Lalre and Ait Inc. Advilloly system in accotdance with ST SA 39CH and system checks IIOI'Vjceable.

"THE I.":A!NT -----· -i{le weiilbt and balance bad been amended
to show this change. ABOVE HAS

; ----- .The **uewwei~** and balimce
is as follows: - • •• ;- N")Vemptywoigbt-JS60,0

New C.G. -73.03 ACCORDANCE STANDARDS **Mome~,.II4001.5l.**

-·

·: .... i .

# I lwemorandum

To: WilliamAmes Clf1'tright From: Ben 

## W. Davidson D(lle: 8/2612014 Re: AnnualinspectionN949JP 

# -IM This.letter fs

## .to v_erify**t~t**

## IcompletedanArmllllfb;spection onN9.49JP aP A-I$on**Sept~mber**

## 23"'. 2013.. Atthatfimelprovided youwith adiscrepqncy listthl.ltincludedtlfl

### ~Ue4

### brJttety 

## inyour

## ELtth4f requiredreplacement 

# Ifneed further**~sistance,**

## please dD.nothesitate to calf 

## anytime before 9pm anyday. 

## (541) 490-6980. 

# (2S_(vt[}_j
Ben. 

## W. Davidson A.&P2855347IA

1

---- --- ______ .:______. _ __:__ ____:_: ___ • .....:; _____:cc _ _-,_

# Eighth Amendment to the United States Constitution The Eighth Amendment to the United States Constitution is the part of the United States Bill of Rights prohibiting the federal government from imposing excessive bail, excessive fines, or cruel and unusual punishment. The U.S. Supreme Court has ruled that this amendment's Cruel and Unusual Punishment Clause also applies to the states. The phrases in this amendment originated in the English Bill of Rights of 

# 1689.