U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

FEDERAL AVIATION ADMINISTRATION FAA DOCKET NO. TBA 

FDMS NO. FAA-2013-1082 

Complainant CASE NO. 201250700133 

vs. Assigned to Judge Richard C. Goodwin 

RIDAN INVESTMENTS, INC. 

Respondent RECE\VED 

ANSWER TO COMPLAINT 

MAR 2 4 Zot4 

HEARING DOCKET 

Respondent, Ridan Investments, Inc. ("Ridan"), by its attorney, hereby files 

its Answer to the Complaint filed by Complainant Federal Aviation Administration 

("FAA") pursuant to Rule 209 of the Rules of Practice (14 C.F .R. 13.209) as 

follows: 

1. Answering paragraph 1, Ridan lacks sufficient information and belief 

to admit or deny the allegation as to when the Agency Attorney received a written 

request for a hearing and denies on that basis. Ridan admits that it received 

notice after January 14, 2014 through a Final Notice of Proposed Civil Penalty 

that the FAA proposed to assess a civil penalty in the amount of $55,000. 

II 

2. Answering paragraph 2, Rid an lacks sufficient information and belief to 

admit or deny the allegations and denies on that basis. Ridan denies that it knowingly 

offered a one-piece shipment to Federal Express on February 19, 2012 that contained 

hazardous materials. 

3. Answering paragraph 2 (misnumbered), Ridan lacks sufficient information 

and belief to admit or deny the allegations and denies on that basis. Rid an denies that 

it, as opposed to different entity that shared the same address, offered the alleged 

shipment for transportation. 

4. Answering paragraph 3. Rid an lacks sufficient information and belief to 
admit or deny the allegations and denies on that basis. 

5. Answering paragraph 4, Ridan lacks sufficient information and belief to 

admit of deny the allegations and denies on that basis. 

6. Answering paragraph 5, Ridan lacks sufficient information and belief to 

admit of deny the allegations and denies on that basis. 

7. Answering paragraph 6, Rid an lacks sufficient information and belief to 

admit of deny the allegations and denies on that basis. 

8. Answering paragraph 7, Ridan lacks sufficient information and belief to 

admit or deny the allegations and denies on that basis. 

9. Answering paragraph 8, Ridan lacks sufficient information and belief to 

admit or deny the allegations and denies on that basis. Rid an denies that it, as 

opposed to different entity thclt shared the same address, offered the alleged shipment. 

10. Answering paragraph 9, Rid an lacks sufficient information and belief to 

admit or deny the allegations and denies on that basis. Ridan denies that it, as 

opposed to different entity that shared the same address, offered the alleged shipment 

11. Answering paragraph 10, Rid an lacks sufficient information and belief to 

admit or deny the allegations and denies on that basis. Riden denies that it, as 

opposed to different entity that shared the same address, offered the alleged shipment.. 

12. Answering paragraph 11, Rid an lacks sufficient information and belief to 

admit or deny the allegations and denies on that basis. Rid an denies that it, as 

opposed to different entity that shared the same address, offered the alleged shipment. 

13 Answering paragraph 12, Ridan lacks sufficient information and belief to 

admit or deny the allegations and denies on that basis. Ridan denies that it, as 

opposed to different entity that shared the same address, offered the alleged shipment. 

14. Answering paragraph 13, Rid an lacks sufficient information and belief to 

admit or deny the allegations and denies on that basis. Rid an denies that it, as 

opposed to different entity that shared the same address, offered the alleged shipment. 

Ill 

15. Answering paragraph 14 and all of its subparts.(subparagraphs1-24, 

inclusive) Ridan incorporates by reference its responses to paragraphs 2-13, above. 

Rid an denies that it, as opposed to a different entity that shared the same address, 

offered the alleged shipment and denies that a civil penalty of $55,000 is appropriate 

under the facts and circumstances of this case .. As to all other allegations in paragraph 

14 and its subparts, (subparagraphs 1-24, inclusive) Ridan lacks sufficient information 

and belief to admit or deny the allegations and denies on that basis. 
WHEREFORE, Ridan, through its attorney, respectfully requests that an order be 

entered denying the FAA's request that Rid an be assessed a civil penalty in the amount 

of $55,000, or any amount at all 

Ridan further requests that the complaint be dismissed with prejudice pursuant to 

14 C.F.R 13.16 c (subsections 1-3) as Ridan did not knowingiy ship the alleged 

materials but rather, it has determined that the identity of the sender was incorrectly 

entered in the online Fed Ex form and that the correct name of the sender/shipper was 

not entered. Ridan did not know the contents of the alleged shipment. It is a real estate 

investment company and is not engaged in the business of packaging, manufacturing, 

selling, distributing, or shipping hazardous mat~rials of any kind. Accordingly, F~idan 

does not, and could not, have a history of any prior violations. 

Respectfully submitted this 171

h day of March, 2014. 

By:c> ~ r- \___ 

LAWRENCE M. BUREK 

Attorney for Respondent Ridan Investments, Inc. 
CERTIFICATE OF SERVICE 

I hereby certify that an original and one copy of the foregoing document 

has beer. mailed on this date by Certified Mail, Return Receipt Requested to the 

following: 

Hearing Docket Clerk 

AGC-430 

Federal Aviation Administration 

Wilbur Wright Building - Suite 2W1 000 

800 Independence Avenue, S.W. 

Washington, DC 20591 

I hereby certify that a copy of the foregoing document has been mailed on 

this date by Certified Mail, Return Receipt Requested to the following: 

Christopher R. Steven!>on 

Federal Aviation Administration 

Office of the Regional Counsel, AS0-7 

Southern Region 

P.O. Box 20636 

Atlanta, GA 30320 

Tel: 404-305-5200 

Fax: 404-305-5223 

HON. Richard C. Goodwin 

U.S. Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. (E11-31 0) 

Washington, DC 20590 

Attn: Patricia Matthews 
I hereby certify that a copy of the foregoing document has also been sent 

on this date electronically as an email attachment and in PDF format to the 

Honorable Richard C. Goodwin, U.S. Administrative Law Judge at 

Richard.Goodwin@dot.com pursuant to the Procedural Order dated March 4, 

2014. 

Executed this 181

h day of March, 2014 at S a Ana, California. 

\ 

s 

Lega ssistant 

Law Office of Lawrencf! M. Burek 

Attorney for Respondent 

Ridan Investments, Inc.