### Inthe Matter of: William

## A. Curtright 

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

WASHINGTON, D.C.

DocketNo. FAA-2015-1319 FAA CaseNo. 2014NM090046 Judge J. E. Sullivan
COMPLAINANT'SMOTIONFOR PARTIAL DECISION (SUMMARYJUDGMENT) 

### Complainantmoves for SummaryJudgment, pursuantto the provisions of 14 CFR Section 13.218(f)(5) and Rule 56 oftheFederal Rules ofCivil Procedure (FRCP), since, after considering the pleadings andthe attached declarations and evidence, it shouldbe clearthatthere is no genuine issue as to the material facts alleged and discussedbelow, and the FAAis entitledto ajudgmentin this case as a matter oflawas tothe issue ofwhethertheviolationwas committed as alleged. Factual background 

### This matterarosewhen Aviation SafetyInspectors (ASIs) from the Portland Flight Standards District Office (FSDO) investigated an accidentthathad occurred onRespondent's property. An

### ASI informedRespondentthathe was requiredtoprovide accessto certain records. Respondentfailed to do so. OnJanuary 14,2015,the FAA issued aNotice ofProposed Civil Penalty (NPCP) which allegedthe following:
This officehas received areportofinvestigationfrom whichitappearsthat: 1. Youwere at all times material hereto the owner and/or operator ofaPiper Model PA18135, a U.S. registeredcivil aircraft, N949JP. 2. Onor about July 1, 2014, an Aviation SafetyInspector (ASI) from the PortlandFlight Standards District Office wrote you a letter demanding thatyouprovide aircraftweightandbalance, and aircraft and engine maintenance logbooks for N949JP.

1

### 3. You senttwo emails and aletter acknowledgingthatyouwere aware ofthe demand. 4. As ofthis time, youhave failedto providethe maintenance records referenced above. Byreasonofthe foregoing facts and circumstances, it appearsthatyouviolated Section 91.417 (c) ofthe Federal AviationRegulations (14 Code ofFederal Regulations (C.F.R.)) inthatyou owned or operated anaircraftfor whichyoufailed to make all maintenance records requiredto bekeptby this section available for inspectionbythe Administrator. Under49 United States Code Sections 4630l(a) and (d), you are subjectto a civil penaltynotto exceed $11,000 for eachviolationnoted. Wepropose to assess a civilpenaltyinthe amountof $11,000. AlthoughRespondentwas brieflyrepresentedby counsel, no informal conference was requested ottookplace. OnMay 19, 2015, Complainantfiledthe Complaintsubjudice containing the identical language. Respondentfailed to file atimelyAnswer1
, 

### but, apparently contactedthe FSDO and arrangedto have the records examined. Undersigned counsel was notifiedthatthe records hadbeenprovided and were in orderonAugust 17, 2015. Pursuantto the ALJ'srulings duringthe Prehearing Conference ofSeptember 20,2016,the parties then exchanged discovery, and this Motionfor SummaryJudgmentfollows. Forthe reasons that follow, Complaintasks forpartial summaryjudgmentonfactual allegations inthe Complaint, leaving only the sanctionfor adjudication.
ARGUMENT ANDBASIS FORREQUESTED RELIEF


### A. Standard ofReview 

### A Motionfor Decisionpursuantto 

## § 13.218(£)(2) is, for all intents and purposes, the same
as a Motionfor SummaryJudgmentunderFRCP 56 andis reviewedunderthe same standard. In RetheMatter ofScott McDougall, Doc. CP89EA0316 at 4 (1990). Motions for Summary

DAVIDF. S!IAYNE, FAAATTORNEY TEL: (425) 227-2165; FAX: (425) 227-1007

### shouldbe litigated inlight ofapplicable FAApolicy and 

## DOT precedence. See In ReSchuman Aviation Co. LTD, 

### FAA OrderNo. 2016-2 (2106). 

### CONCLUSION Forthe reasons statedabove, Complainant'sMotionfor Partial SummaryJudgment should be granted. Respectfully submittedthis 161h 

### day ofNovember, 2016. \ r··--,,\ 

### /'"' \



# cK~- DA\'Ib 

## F. SHAYNE FAAAttorney

DAVIDF, SHAYNE, FAAATTORNEY TEL: (425) 227-2165; FAX: (425) 227-1007

### William A. Curtright Respondent 

### PO Box 1350 Jefferson. OR 

### 97352 Telephone: (503) 209-7388 Fax: (503) 485-0812



### In The Matter Of: 

## UNITED STATES OFAMERICA DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS

WASHINGTON, D.C.
Docket No. 

### FAA-2015-1319 WILLIAM A. 

### CURTRIGHT, DBA 

### Case No. 

### 2014NM090046 Respondent 

### JudgeJ.E. Sullivan 

### RESPONDENTS SUPPLEMENTALANSWERS AND RESPONSES TO COMPLAINANT'S INTERROGATORIES AND REQUESTSFORPRODUCTION
INTERROGATORY 

### No. 1: Describe with specit1city all of the facts and arguments which you anticipate presenting in the 

### course of

### the Department of 

### Transportation (DOT) hearing in this matter pertainingtothe avoidance or mitigation ofthe sanction soughtbythe FAAinthis case. SUPPLEMENTAL ANSWER TO INTERROGATORY NO.1: The Respondent objects to Interrogatory Number 1 under Federal Rule 

### of Civil Procedure 502 (g) (1) and 

### {2) on the grounds that it seeks information that is privileged by virtue of the attorney-client privilege. Respondent would further object to Interrogatory No. 1 under Federal Rule ofCivil Procedure 502 (g) {1) and (2) and Federal Rule of Procedure Rule 26 (b)(S) in that Complainant seeks information that is protected by the "work product" privilege. The interrogatorycalls for disclosure of information or materials prepared in anticipation ofthe hearing and/or hearing preparation material by pro se Respondent representing himself in this case. Furthermore, Respondents supplemental answer to Interrogatory No. 1 is pursuant to Federal Rule of Civil Procedure Rule 26(e) and Rule 33 (b) (2) and would direct Complainant to the U.S. Department of Transportation Federal Aviation Administration National Policy Procedure Book dated, 10/01/07 Section 2150.38 page 4-10 section entitled: REGULATIONS CONSIST OF

Page 1 Respondents Supplemental Answers and Responses to Complainant's Interrogatories and Requests for Production Docket No. FAA-2015-1319 Case No. 2014NM0046 WH!lam A. Curtrlght,DBA Respondent Telephone: (503) 209·7388 fax (503)485·0812MULTIPLE ELEMENTS section B. Elements of regulations
......and section 

### c. Burden and Standard of Proof. (Herein attached for Complainants review). Additionally, respondent would refer Complainant to 2150.3 B 9. Letter of Investigation and Response section c. Sending the LOI to the Apparent Violator. And 2150.3B 10. Evidence section a. Further reference to complainant is to 2150.38 Types of Evidence. C 

### (8) Interviews and written statements of apparent violators. Normally, FAA investigative personnel interview the apparent violator, even though he or she may have provided written information. I f the interview is not possible or necessary, FAA investigative personnel indicate the reasons why it was not accomplished. Apparent violators are interviewed mainly to GIVE THEM AN OPPORTUNITY TO TELL THEIR SIDE OF THE STORY AND TO HELP ESTABLISH ALL PERTINENT FACTS AND CIRCUMSTANCES. AT TIMES, IT IS BEST FIRST TO GATHER SOLID EVIDENCE WITH WHICH TO INTERVIEWTHE APPARANT VIOLATOR. Respondent would state that the FAA attorney David Shayne ignored when documents were produced to him for compliance of production of Respondents log books. Additionally, FAA attorney David Shayne has ignored when Local authorities in Oregon told him that Respondent was in compliance. Further FAA Attorney David Shayne has not followed the FAA rules and ORDER 2150.3B Section 15. Legal Enforcement Actions section f. Civil Penalties. Chapter 2 Compliance and Enforcement Policy and Objectives 3. Compliance and enforcement philosophy d. Notifying Persons of potential Violations. ORDER 2150.3B page 2-3 g. Fairness. To be effective, the agency's compliance and enforcement program must be fair and reasonable and should be perceived as fair by those subjectto regulations..... It also requires good faith efforts to understand the apparent violator's position and take it into account, as well as to apprise the apparent violator ofthe agency's position in atimely manner. Respondent would also refer Complainant to the FAA Quarterly Enforcement Report 1/1/16- 3/31/16 and would showthe court that not one person is personally named fora civil penalty by the FAA. Further that ifComplainant's Attorney reviewed their own FAA Quarterly Enforcement Report of4-1-14 through1-1-16 that NOT ONE person has been named for acivil penalty by the FAA. Respondent would also state and/or argue that there is a lopsided scale ofjustice when one is involved with litigation with the FAA attorney, David Shayne. The scales have been titled to one side when dealing with attorney, David Shayne. He has abused his authority by not acknowledging that Respondent is in compliance and this case should have been closed over a year ago. Is this a misuse of power like the I.R.S. or is it political. It seems as though attorney, David Shayne is using his overbalanced power and a clear violation ofthe eight amendment of Page 2Respondents Supplemental Answers and Responses to Complainant's Interrogatories and Requests for Production Docket No. FAA-2015-1319 Case No. 2014NM0046 William A. Curtright,DBA Respondent Telephone: (5031209-7388 Fax (503)485-0812

### the constitution of the United States of America. Attorney, David Shayne has abused his authority in continuing to litigate a matter that is mute and has been resolved over a year ago. Further, the Complainant has no authority to continue in this suit because Complainant failed to give proper notice to Respondent in 2014. The notice sent by Complainant was not signed by any one and is therefore not proper notice of an alleged violation. Further, the alleged violation was not signed by an attorney or a bar number was not used in the complaint filed with the United States of America Department of Transportation Office of Hearing in Washington, D.C. This is aviolation ofthe FAA ORDER 2150.38 in that attorney, David Shayne, told the Honorable J.E. Sullivan during a conference that Section 8 and Cof the EIR was confidential and privilege when in fact according to the FAA ORDER 2150.38 Section Cofthe EIR is for two or more FAA investigative personnel are present during a conversation, that each one prepares a record of the interview for inclusion in Section Cofthe EIR. FAA ORDER 2150.38 also includes assurance from the outset the witness understands that any information provided may be used as evidence in subsequent enforcement, that the statement be signed and dated, that they summarize the interview with the witness to verify the interviewer's understanding and recollection of all relevant points. This report of interview is separate item of proof in the EIR. The report of interview must not contain personal opinions ofthe interviewer. Finally, attorney David Shayne testified before the Honorable Judge 

### J.E. Sullivan that the maximum amount ofthe civil penalty was under his discretion. However, when one reads the 2150.38, Chg 11 Appendix H of2/24/2016 A violation that poses a medium actual or potential risk to safety generally warrants a civil penalty in the minimum to moderate range. There is nothing in the 2150.3B ORDER that states it is in the discretion ofthe legal counsel.

INTERROGATORYNo.2: Identify by name, address and telephone numberall persons whom you know to have personal knowledge ofthe matters alleged in the Complaint. SUPPLEMENTAL ANSWER TO INTERROGATORY NO.2: The Respondent objects to Interrogatory Number 2 on the ground that the information is already in the Complainant's possession, and was already provided to Complainant in Respondents Initial Disclosure Document and is obtainable from Respondents Initial Disclosure Document. Additionally, respondent would show that Complainant's Interrogatories and Requests for Production were received on October 11, 2016 via certified return receipt which would make these answers due on November 10, 2016 Under Federal Rule of Procedure Rule 33(b) (2) herein attached a copy of the Received Complainant's Initial Discover Requests wherein Complainant states that Respondents response is due by October 27, 2016. Respondent would add that this is misleading to the Respondent when his responses are truly due on November 10, 2016.
Page 3 Respondents Supplemental Answers and Responses to Complainant's Interrogatories and Requests for Production Docket No. FAA-2015-1319 Case No. 2014NM0046 William A. Curtright,DBA Respondent Telephone: (503) 209-7388 Fax (503)485-0812Furthermore, Respondents supplemental answer to Interrogatory No. 2 is pursuant to Federal Rule ofCivil Procedure Rule 26(e) and Rule 33 (b) (2) and would state the following response: a. William Ames Curtright P.O. Box 1350 Turner, Oregon (503)209-7388 b. BillyJ. McKibbon Front Line Manager-heavy Helicopter Unit Portland Flight Standards Federal Aviation Administration (503)615-3235

c. Curt Cowley Portland Flight Standards Federal Aviation Administration (503)615-3235 d. Marty G. Conroy Aviation Safety Inspector Federal Aviation Administration Flights Standards District Office 3180 NW 229'h Ave Hillsboro, Oregon 97124



### INTERROGATORY No. 3: Identify by title, date, author, present custodian, and content, all documents, including correspondence, obtained by you or in your possession, relating to the assertions in the Complaint, your appeal, your answer, and any affirmative defenses which you anticipate raising inthis matter.
SUPPLEMENTAL ANSWER TO INTERROGATORY NO.3: The Respondent objects to Interrogatory Number 3 under Federal Rule of Civil Procedure 502 (g) (1) and (2) on the grounds that it seeks information that is privileged by virtue of the attorney-client privilege. Respondent would further object to Interrogatory No. 1 under Federal Rule of Civil Procedure 502 (g) (1) and (2) and Federal Rule of Procedure Rule 26 (b)(5) in that Complainant seeks information that is Page 4 Respondents Supplemental Answers and Responses to Complainant's Interrogatories and Requests for Production Docket No. FAA-2015-1319 Case No. 2014NM0046 William A. Curtright,DBA Respondent Telephone: {503) 209-7388 Fax {S03)485-0812protected by the "work product" privilege. The interrogatory calls for disclosure of information or materials prepared in anticipation ofthe hearing and/or hearing preparation material by pro se Respondent representing himself in this case. Additionally, respondent would show that Complainant's Interrogatories and Requests for Production were received on October 11, 2016 via certified return receipt which would make these answers due on November 10, 2016 Under Federal Rule of Procedure Rule 33(b) (2) herein attached a copy ofthe Received Complainant's Initial Discover Requests wherein Complainant states that Respondents response is due by October 

### 27, 2016. Respondent would add that this is misleading to the Respondent when his responses are truly due on November 10, 2016. Respondent reserves the Federal Rule of Civil Procedure Rule 26(e) and Rule 33(b) (2) to correct or update additional Answer's to Complainant's Interrogatories on November 10, 2016. Furthermore, Respondents supplemental answer to Interrogatory No.3 is pursuant to Federal Rule ofCivil Procedure Rule 26(e) and Rule 33 (b) (2) and would state the following response:



### a. William Ames Curtright P.O. 

### Box 1350 Turner, Oregon (503)209-7388



### INTERROGATORY No. 4: Identify by name, address and telephone number, all persons whom you intend to have testify as a factual or expert witness in your defense atthe hearing in this matter, and for factual witnesses,provide a detailed summary ofeach persons anticipated testimony. SUPPLEMENTAL ANSWER TO INTERROGATORY NO.4: The Respondent objects to Interrogatory Number 4 under Federal Rule of Civil Procedure 502 (g) (1) and (2) on the grounds that it seeks information that is privileged by virtue of the attorney-client privilege. Respondent would further object to Interrogatory No. 1 under Federal Rule of Civil Procedure 502 (g) (1) and (2) and Federal Rule of Procedure Rule 26 (b)(5) in that Complainant seeks information that is protected by the "work product" privilege. The interrogatory calls for disclosure of information or materials prepared in anticipation ofthe hearing and/or hearing preparation material by pro se Respondent representing himself in this case. Additionally, respondent would show that Complainant's Interrogatories and Requests for Production were received on October 11, 2016 via certified return receipt which would make these answers due on November 10, 2016 Under Federal Rule of Procedure Rule 33(b)(2) herein attached a copy ofthe Received Complainant's Initial Discover Requests wherein Complainant states that Respondents response is due by October 27,2016. Respondent would add that this is misleading to the Respondent when his responses are truly due on November 10,2016.
Page 5 Respondents Supplemental Answers and Responses to Complainant's Interrogatories and Requests for Production Docket No. FAA-2015-1319 Case No. 2014NM0046 William A. Curtright,DBA Respondent Telephone: (S03)209-7388 Fax (503)485-0812

### Respondent reserves the Federal Rule of Civil Procedure Rule 26(e) and Rule 33(b) (2) to correct or update additional Answer's to Complainant's Interrogatories on November 10, 2016. Furthermore, Respondents supplemental answer to Interrogatory No.4 is pursuant to Federal Rule ofCivil Procedure Rule 26(e) and Rule 33 (b) (2) and would state the following response:
a. William Ames Curtright P.O. Box 1350 Turner, Oregon (503)209-7388 The Respondent objects to Interrogatory Number4 under Federal Rule ofCivil Procedure 502 (g) (1) and (2) on the grounds that it seeks information that is privileged by virtue ofthe attorneyclient privilege. Respondent would further object to Interrogatory No. 1 under Federal Rule of Civil Procedure 502 (g) (1) and (2) and Federal Rule of Procedure Rule 26 (b)(5) in that Complainant seeks information that is protected by the "work product" privilege. The interrogatory calls for disclosure of information or materials prepared in anticipation of the hearing and/or hearing preparation material by pro se Respondent representing himself in this case.



### INTERROGATORY No. 5: Identify by title, date, author, present custodian, and content, all documents which you anticipate offering into evidence at the hearing in this matter, and through which witnessorwitnesses. SUPPLEMENTAL ANSWER TO INTERROGATORY NO. 5: The Respondent objects to Interrogatory Number 5 under Federal Rule of Civil Procedure 502 (g) (1) and (2) on the grounds that it seeks information that is privileged by virtue of the attorney-client privilege. Respondent would further object to Interrogatory No. 1 under Federal Rule of Civil Procedure 502 (g) (1) and (2) and Federal Rule of Procedure Rule 26 (b)(5) in that Complainant seeks information that is protected by the "work product" privilege. The interrogatory calls for disclosure of information or materials prepared in anticipation ofthe hearing and/or hearing preparation material by pro se Respondent representing himself in this case. Additionally, respondent would show that Complainant's Interrogatories and Requests for Production were received on October 11, 2016 via certified return receipt which would make these answers due on November 10, 2016 Under Federal Rule of Procedure Rule 33(b)(2) herein attached a copy ofthe Received Complainant's Initial Discover Requests wherein Complainant states that Respondents response is due by October 27,2016. Respondent would add that this is misleading to the Respondent when his responses are truly due on November 10,2016. Respondent reserves the Federal Rule ofCivil Procedure Rule 26(e) and Rule 33(b) (2) to correct or update additional Answer's to Complainant's Interrogatories on November 10, 2016. Page 6 Respondents Supplemental Answers and Responses to Complainant's Interrogatories and Requests for Production Docket No. FAA-2015-1319 Case No. 2014NM0046 William A. Curtright,DBA Respondent Telephone: (503) 209-7388 Fax (503)485-0812Furthermore, Respondents supplemental answer to Interrogatory No. 5 is pursuant to Federal Rule ofCivil Procedure Rule 26(e) and Rule 33 (b) (2) and would state the following

**resp~nse:**
a. William Ames Curtright P.O. Box 1350 Turner, Oregon (503)209-7388 All documents used as exhibits in Motion to dismiss, Motion for Summary Judgment, Respondents initial disclosure, respondents supplemental disclosure and any documents introduced into this action. b. Billy J. McKibbon Front Line Manager-heavy Helicopter Unit Portland Flight Standards Federal Aviation Administration (503)615-3235 Speed Memo dated August 14, 2015 Photo's of Log books
c. Curt Cowley Portland Flight Standards Federal Aviation Administration (503)615-3235 Speed Memo dated August 14, 2015 Photo's of Log books d. Marty G. Conroy Aviation Safety Inspector Federal Aviation Administration Flights Standards DistrictOffice 3180 NW 229'h Ave Hillsboro, Oregon 97124 Speed Memo dated August 14, 2015 Letter dated September 9, 2014 from Dr. W. Ames Curtrightto Martin G. Conroy Photo's ofLog books



### INTERROGATORY No. 6: With respect to each expert witness identified m response to
Page 7 Respondents Supplemental Answers and Responses to Complainant's Interrogatories and Requests for Production Docket No. FAA-2015-1319 Case No. 2014NM0046 William A. Curtright,DBA Respondent Telephone: {503)209-7388 Fax {503)485-0812

### Interrogatory No. 4, above, specify their specific area of expertise, and provide a synopsis oftheir credentials, background,training and experience SUPPLEMENTAL ANSWER TO INTERROGATORY NO. 6: The Respondent objects to Interrogatory Number 6 under Federal Rule of Civil Procedure 502 (g) (1) and (2) on the grounds that it seeks information that is privileged by virtue of the attorney-client privilege. Respondent would further object to Interrogatory No. 1 under Federal Rule of Civil Procedure 502 (g) (1) and (2) and Federal Rule of Procedure Rule 26 (b)(5) in that Complainant seeks information that is protected by the "work product" privilege. The interrogatory calls for disclosure of information or materials prepared in anticipation ofthe hearing and/or hearing preparation material by pro se Respondent representing himself in this case. Additionally, respondent would show that Complainant's Interrogatories and Requests for Production were received on October 11, 2016 via certified return receipt which would make these answers due on November 10, 2016 Under Federal Rule of Procedure Rule 33(b)(2) herein attached a copy ofthe Received Complainant's Initial Discover Requests wherein Complainant states that Respondents response is due by October 27,2016. Respondent would add that this is misleading to the Respondent when his responses are truly due on November 10, 2016. Respondent reserves the Federal Rule of Civil Procedure Rule 26(e) and Rule 33(b) (2) to correct or update additional Answer's to Complainant's Interrogatories on November 10, 2016. Furthermore, Respondents supplemental answer to Interrogatory No. 6 is pursuant to Federal Rule ofCivil Procedure Rule 26(e) and Rule 33 (b) (2) and would state the following response: Respondent does not plan on calling an expertwitness

INTERROGATORY No. 7: With respect to each expert you expect to call as a witness, state the subject matter on which the expert is expected to testify, and state the substance of the facts and opin!ons to which the expert is expected to testify, and a summary of the grounds for each such OpiniOn. 

### SUPPLEMENTAL ANSWER TO INTERROGATORY NO.7: The Respondent objects to Interrogatory Number 7 under Federal Rule of Civil Procedure 502 (g) (1) and (2) on the grounds that it seeks information that is privileged by virtue of the attorney-client privilege. Respondent would further object to Interrogatory No. 1 under Federal Rule of Civil Procedure 502 (g) (1) and (2) and Federal Rule of Procedure Rule 26 (b)(5) in that Complainant seeks information that is protected by the "work product" privilege. The interrogatorycalls for disclosure of information or materials prepared in anticipation ofthe hearing and/or hearing preparation material by pro se Respondent representing himself in this case. Additionally, respondent would show that Page 8Respondents Supplemental Answers and Responses to Complainant's Interrogatories and Requests for Production Docket No, FAA-2015-1319 Case No. 2014NM0046 William A. Curtright,DBA Respondent Telephone: (503)209-7388 Fax (503)485-0812Complainant's Interrogatories and Requests for Production were received on October 11, 2016 via certified return receipt which would make these answers due on November 10, 2016 Under Federal Rule of Procedure Rule 33(b)(2) herein attached a copy ofthe Received Complainant's Initial Discover Requests wherein Complainant states that Respondents response is due by October 27,2016. Respondent would add that this is misleading to the Respondent when his responses are truly due on November 10, 2016. Respondent reserves the Federal Rule of Civil Procedure Rule 26(e) and Rule 33(b) (2) to correct or update additional Answer's to Complainant's Interrogatories on November 10, 2016. Furthermore, Respondents supplemental answer to Interrogatory No. 7 is pursuant to Federal Rule ofCivil Procedure Rule 26(e) and Rule 33 (b) (2) and would state the following response: Respondent does not plan on calling an expert witness

INTERROGATORY No. 8: State by name, address, telephone number, date of conversation, and substance of conversation, all persons [other than legal counsel or spouse] with whom you have discussed the matters alleged in the Complaint. SUPPLEMENTAL ANSWER TO INTERROGATORY NO. 8: The Respondent objects to Interrogatory Number 8 under Federal Rule ofCivil Procedure 502 (g) (1) and (2) on the grounds that it seeks information that is privileged by virtue of the attorney-client privilege. Respondent would further object to Interrogatory No.8 under Federal Rule of Civil Procedure 502 (g) (1) and (2) and Federal Rule of Procedure Rule 26 (b)(S) in that Complainant seeks information that is protected by the "work product" privilege. The interrogatory calls for disclosure of information or materials prepared in anticipation ofthe hearing and/or hearing preparation material by pro se Respondent representing himself in this case. Additionally, respondent would show that Complainant's Interrogatories and Requests for Production were received on October 11, 2016 via certified return receipt which would make these answers due on November 10, 2016 Under Federal Rule of Procedure Rule 33(b)(2) herein attached a copy ofthe Received Complainant's Initial Discover Requests wherein Complainant states that Respondents response is due by October 27,2016. Respondent would add that this is misleading to the Respondent when his responses are truly due on November 10, 2016. Respondent reserves the Federal Rule ofCivil Procedure Rule 26(e) and Rule 33(b) (2) to correct or update additional Answer's to Complainant's Interrogatories on November 10, 2016.

Page 9 Respondents Supplemental Answers and Responses to Complainant's Interrogatories and Requests for Production Docket No. FAA-2015-1319 Case No. 2014NM0046 William A. Curtright,DBA Respondent Telephone: (503) 209-7388 Fax (503)485-0812Furthermore, Respondents supplemental answer to Interrogatory No. 8 is pursuant to Federal Rule ofCivil Procedure Rule 26(e) and Rule 33 (b) (2) and would state thefollowing response: Susan Bird Executive Assistant to William Ames Curtright 189116'"St. SE Salem, Oregon 97302 Respondent has not kept track ofthe specific dates that he has discussed the alleged matters in this complaint with Ms. Bird; however, there have been several discussions because Ms. Bird is my assistant and assists me with typing motions, and discovery in this alleged matter.



### INTERROGATORY No.9: Ifyou denyany or all ofRequests forAdmissions l 

### through 5, please explain in detail the specificreason for each andeveryfact denied. SUPPLEMENTAL ANSWER TO INTERROGATORY NO. 9: The Respondent objects to Interrogatory Number 9 under Federal Rule of Civil Procedure 502 (g) (1) and (2) on the grounds that it seeks information that is privileged by virtue of the attorney-client privilege. Respondent would further object to Interrogatory No. 1 under Federal Rule of Civil Procedure 502 (g) (1) and (2) and Federal Rule of Procedure Rule 26 (b)(5) in that Complainant seeks information that is protected by the "work product" privilege. The interrogatory calls for disclosure of information or materials prepared in anticipation ofthe hearing and/or hearing preparation material by pro se Respondent representing himself in this case. Additionally, respondent would show that Complainant's Interrogatories and Requests for Production were received on October 11, 2016 via certified return receipt which would make these answers due on November 10, 2016 Under Federal Rule of Procedure Rule 33(b)(2) herein attached a copy ofthe Received Complainant's Initial Discover Requests wherein Complainant states that Respondents response is due by October 27,2016. Respondent would add that this is misleading to the Respondent when his responses are truly due on November 10, 2016. Respondent reserves the Federal Rule of Civil Procedure Rule 26(e) and Rule 33(b) (2) to correct or update additional Answer's to Complainant's Interrogatories on November 10, 2016. Respondents supplemental answer to Interrogatory No. 9 is pursuant to Federal Rule of Civil Procedure Rule 26(e) and Rule 33 (b) (2) and would state thefollowing response: Respondent has already answered the Request for Admissions 1 through 5 and has already explained in detail the specific reasons for each and every fact denied. Complainants additional
Page 10 Respondents Supplemental Answers and Responses to Complainant's Interrogatories and Requests for Production Docket No. FAA-2015-1319 Case No. 2014NM0046 William A. Curtright,DBA Respondent Telephone: {5031209·7388 Fax (5031485·0812

### review are Respondents answer's to Complainant's Request for Admissions answers were the following on October 28, 2016.
REQUEST FOR ADMISSION NO 1. Admit that Attachment I is a true and correct copy of an electronic mail message (email) you sent to FAA Aviation Safety Inspector (AS!) Conroy on July 

### 1, 2014.
RESPONDENT ADMITS 

### IN PART AND DENY'S IN PART that this is a true and correct copy of an electronic mail message (email) respondent sent to FAA Aviation Safety Inspector (AS!) Marty Conroy on July l, 2014 because ofthe hand written notes in the right hand corner ofthe document are not the Respondents. Respondent would deny that this is a true and correct copy ofthe electronic mail message respondent sent to FAA Aviation Safety Inspector (AS!) Conroy on July !, 2014 and would ADMIT that a true and correct copy ofthe electronic mail message respondent sent to FAA Aviation Safety Inspector (AS!) Conroy on July 

### 1, 2014 does not include the hand written notes in theright hand corner ofthe documentthat Complainanthas produced. REQUEST FOR ADMISSION NO 

### 2. Admit that Attachment 

### 2 is a true and correct copy ofan email AS! Conroy sentto you on July 7, 2014. RESPONDENT DENY'S that Attachment 2 is a true and correctcopyofan email AS! Conroy sent to Respondent on July 7, 2014 because the Attachment 2 also includesan electronic mail message (email) that Respondent sentto ASI Marty Conroy on July 

### 7, 2014 at II 

### :57 AM. Respondent ADMITS that Attachment

### 2 is a true and correctcopy ofan 

### email AS! Conroy sent to Respondent on July 7, 2014 and an electronic mail (email)that Respondent sentto Marty Conroy, on July7, 2014 at II 

### :57AM. REQUEST FOR ADMISSION NO 3. Admit that Attachment 3 is a true and correct copy ofan email you sent to AS! Conroyon August 28, 2014. Respondent ADMITS thatAttachment 3 is a true and correctcopy ofan email that Respondent sent to AS! Conroy on August 28,2014 at 3:03PM. REQUEST FOR ADMISSION NO 4. Admit that Attachment 4 is a true and correct copy ofa Letter ofInvestigation AS! Conroysentto you on September4, 2014. Respondent DENY'S thatAttachment 4 is a true and correctcopy ofa Letter ofInvestigation AS! Conroy sentto Respondent on September4, 2014 becausethe document is not signed by anyone and is missingthe second page ofthe document. Additionally, the documenthas hand notations on itthat are not the Respondents and is not a true and correctcopy ofthe LetterofInvestigation AS! Conroy sent to Respondent on September4, 20I4. The Request for AdmissionNo. 4 ask for Respondent to assume and/or speculate that the documentcame from AS! Conroy. Also, the request for admission No.4 ask for Respondentto assume or speculate who Conroy is by not identifythe full name of Conroy. REQUEST FOR ADMISSION NO 5. Admit that Attachment 5 is a true and correct copy ofan letter you sent to AS! Conroyon September9, 2014. Page 11 Respondents Supplemental Answers and Responses to Complainant's Interrogatories and Requests for Production Docket No. FAA-2015·1319 Case No. 2014NM0046 William A. Curtright,DBA Respondent Telephone: (503) 209-7388 Fax (503)485·0812

### Respondent ADMITS AND DENY'S in part and DENY'S that Attachment 5 is a true and correct copy ofa letter Respondent sentto AS! Conroyon September 9, 2014; However, respondent ADMITS that Attachment 5 is a true and correctcopy ofa letter Respondent sentto AS! Conroy on September9, 20I4 with seven attachments ofthe following: I. Oregon Aircraft Registration Certificate; 2. Memorandum from Ben W. Davidson to William Ames Curtright dated 8/26/2014 re: annual Inspection N949JP; 3.Medical Certificate Third Class ofWilliam Ames Curtright; 4.The Standard Pilot Log ofDr. W. Ames Curtright DBA; 5.The second page ofthe Standard Pilot Log of Dr. W. Ames CurtrightDBA; 6. A certified handwritten note regarding a flight review; and 7. A documentreflecting a workorder.

INTERROGATORY No. I0: Ifyou denyany or all ofRequest forAdmissions 6 please explain in detail the specific reason for each and every fact denied and sate specifically whether you had a conversation with AS! Comoy and, ifso, what is yourrecollection ofthe conversation. SUPPLEMENTAL ANSWER TO INTERROGATORY NO. 10: The Respondent objects to Interrogatory Number 10 under Federal Rule ofCivil Procedure S02 (g) (1) and (2) on the grounds that it seeks information that is privileged by virtue of the attorney-client privilege. Respondent would further object to Interrogatory No. 10 under Federal Rule ofCivil Procedure 502 (g) (1) and (2) and Federal Rule of Procedure Rule 26 (b)(S) in that Complainant seeks information that is protected by the "work product" privilege. The interrogatorycalls for disclosure of information or materials prepared in anticipation ofthe hearing and/or hearing preparation material by pro se Respondent representing himself in this case. Additionally, respondent would show that Complainant's Interrogatories and Requests for Production were received on October 11, 2016 via certified return receipt which would make these answers due on November 10, 2016 Under Federal Rule of Procedure Rule 33(b)(2) herein attached a copy ofthe Received Complainant's Initial Discover Requests wherein Complainant states that Respondents response is due by October 27,2016. Respondent would add that this is misleading to the Respondent when his responses are truly due on November 10, 2016. Respondent reserves the Federal Rule of Civil Procedure Rule 26(e) and Rule 33(b) (2) to correct or update additional Answer's to Complainant's Interrogatories on November 10, 2016. Furthermore, Respondents supplemental answer to Interrogatory No. 10 is pursuant to Federal Rule ofCivil Procedure Rule 26(e) and Rule 33 (b) (2) and would state the following response: At this time Respondent does not recall the conversation; however, reserves the rights to amend this response pursuant to Federal Rule of Civil Procedure Rule 26(e) and Rule 33 (b) (2) before discovery ends. However, Respondent did not refer the aircraft N949JP as being in an accident, but an incident on June 14, 2014
Page 12 Respondents Supplemental Answers and Responses to Complainant's Interrogatories and Requests for Production Docket No. FAA-2015-1319 Case No. 2014NM0046 William A. Curtright,DBA Respondent Telephone: (503) 209-7388 Fax (503)48S-0812

### REQUEST FOR PRODUCTION NO. I: Provide a copy of all documents referred to tn 

### your answer to the preceding interrogatoriesNo. I through No. I0. SUPPLEMENTAL RESPONSE N0.1: The Respondent objects to Request for Production Number 1 under Federal Rule ofCivil Procedure 502 (g) (1) and (2) on the groundsthat it seeks information that is privileged by virtue ofthe attorney-client privilege. Respondent would further object to Request for Production No. 1 under Federal Rule of Civil Procedure 502 (g) (1) and (2) and Federal Rule of Procedure Rule 26 (b)(5) in that Complainant seeks information that is protected by the "work product" privilege. The interrogatory calls for disclosure of information or materials prepared in anticipation ofthe hearing and/or hearing preparation material by prose Respondent representing himself in this case. Additionally, respondent would show that Complainant's Interrogatories and Requests for Production were received on October 11, 2016 via certified return receipt which would make these answers due on November 10, 2016 Under Federal Rule of Procedure Rule 33(b)(2) herein attached a copy ofthe Received Complainant's Initial Discover Requests wherein Complainant states that Respondents response is due by October 27,2016. Respondent would add that this is misleading to the Respondent when his responses are truly due on November 10, 2016. Respondent reserves the Federal Rule ofCivil Procedure Rule 26(e) and Rule 33(b) (2) to correct or update additional Responses to Complainant's Request for Production on November 10, 2016. Interrogatory No. 10 is pursuant to Federal Rule ofCivil Procedure Rule 26(e) and Rule 33 (b) (2) and would state the following response: Furthermore, Respondents supplemental answer to Request for Production No.1 has produced all documents referred to in Respondents answer to the preceding interrogatories no. 1through No. 10. On October 27, 2016. Additionally, Respondent herein produces all documents referred to in Respondents Supplemental Answers to Complainants Interrogatories and Requests for Production of Documents.

Page 13 Respondents Supplemental Answers and Responses to Complainant's Interrogatories and Requests for Production Docket No. FAA-2015-1319 Case No. 2014NM0046 William A. Curtright,DBA Respondent Telephone: (503) 209-7388 Fax (503)485-0812

### VERIFICATIONOFINTERROGATORYSUPPLEMENTALANSWERSAND 

### REQUESTFOR PRODUCTION I, William A. Curtright, DBA as Respondent, I believe, based on reasonable inquiry, thatthe foregoing 

### ans,vers aretrue and correct to the bestofmy knowledge, 

### informationand belief. I verify underpenalty ofperjurythatthe foregoing is true and correct. Executed on November

### g, 2016



### William A. Curtright, DBA



### CERTIFICATE OF SERVICE l hereby certify that the foregoing Respondents Supplemental Answers and Responses to Complainant's Interrogatories and Requests for Production, has been served as designated bythe recipient this date, to the following:

David F. Shayne, FAA Attorney (email, fax and Certified Mail-Return Receipt Requested) Complainant's Counsel NorthwestMountain Region, ANM-7 Federal Aviation Administration 1601 Lind Ave. SW Renton, W A 98057 TEL: 425-227-1847

Dated November 9, 2016

William A. Curtright, DBA

Page 14 Respondents Supplemental Answers and Responses to Complainant's Interrogatories and Requests for Production Docket No. FAA-2015-1319 Case No. 2014NM0046 William A. Curtright,DBA Respondent Telephone: (503) 209-7388 Fa> (503)485-0812

### VERIFICATIONOFINTERROGATORYSUPPLEMENTALANSWERSANDREQUESTFOR PRODUCTION 

### I, WilliamA. 

### Curtright, DBAas Respondent, Ibelieve, basedonreasonableinquiry,thattheforegoing answers aretrueandcorrectto thebestofmyknowledge, informationandbelief. Iverifyunderpenaltyofpe!jurythattheforegoing is

### trueandcorrect. ExecutedonNovember9, 2016



# to~~ William A. 

### Curtright, DBA



### CERTIFICATE OF 

### SERVICE I hereby certify that the foregoing Respondents Supplemental Answers and Responses to Complainant's Interrogatories andRequests forProduction, has been served as designated by the recipient this date, to the following:
DavidF. Shayne, FAA Attorney (email, fax and Certified Mail-Return Receipt Requested) Complainant's Counsel NorthwestMountain Region, ANM-7 Federal AviationAdministration 1601 LindAve. SW Renton, W A 98057 TEL: 425-227-1847
DatedNovember 9, 

### 2016

William A. Curtright, DBA
Page 14 RespondentsSupplemental Answers and Responses to Complainant's Interrogatories and Requests for Production Docket No. FAA-2015-1319 Case No. 2014NM0046 William A. Curtright,DBA Respondent Telephone: (503) 209-7388 Fax (503)485·0812

# Attach1nent 1

### Conroy, Marty G (FAA) From: Sent: To: Subject:
June 1, 2014 To: Marty Conroy: Marty, William Ames Curtright <ames@amesresearch.com> Tuesday, July 01, 2014 4:58 PM Conroy, Marty G (FAA) Ames

I never received you Email. Here is mine. As I mentioned I will need some time to getthings foryou out ofcountry oras soon as I can locate things. Too muchjunk and stuff. Please re-list things you need nowto complete your investigation. The aircraft is now offof Floats, on wheels, As I mentioned the reason for incidentwas left gear collapse. As you know this is an amphibious Aircraft with Whip-line 2100 floats. This is an embarrassing and expensive and mechanical, or otherwise, one always wonders what one could have done better. Here is my description, hope it helps you. The wheels indicated down and locked. The braking power ofthe metal rail on the underside ofthe float was more than 1could compensate forthus a hard left braking occurred forcing the aircraft at a low rate ofspeed offthe runway. Less than 5 mph when the aircraft slowly went up a slight embankment, thus it rolled slowlytothe right striking and breaking the right wingtip and the prop struck the ground. I was very surprised to find myself in that position, because there was no real warning or expectations ofanything such as thatand no otherthan a perfect and great landing. Itwas more like standing up and falling over maneuver on the side ofan embankment at slow speed.

I have to say I wondered whether I even had to call NTSB on my own field, but I wanted to play itsafe and make the call. Cause of incidentwas gear failure. The Aircraft was on myAirport 21 Oscar GolfAmes Airport, Privately owned by myself, and the Aircraft a Super Cub PA 18 is owned solely by myself. Iwas not injured in anyway, the aircraft is repairable. One does notwantto waste a perfectly good air plane broken or otherwise. Nostalgic. Presently it has been taken offof Floats, and is on wheels. Looks good on wheels. I will repair it do afull work up on the aircraft and restore it with qualified personnel, with most likely a new engine and rebuilt wing to service. I have flown this aircraftfortwentyyears, without a dent. I have certainly had my time in it, Ithink I have gone through one Hobbs, and into another, so Ithink I have more time than Ithought in it.

1am loosing track of how many types of plane I have flown. Bob Hoover, my good friend crashed about twenty before he was twenty two. It did itfor a living although!I hope my discription helps. Iwill need some time to get those documents to you as Itravel a lot. I understand that Iwill not have to fill out any otherdocuments. My last biannual Ithink was late summer of2012 or 2013. I lose track oftime. You have my health certificate and Ijust completed a new one. I note you have myolder registration and a newer one was issued, I believe. Iwill look around forthat.
W. Ames Curtright

2! ' 

# Attachment 2

### Conroy, Marty G (FAA) From: Sent: To: Cc: Subject:
Mr. Ames Curtright: Conroy, Marty G (FAA) Monday, July 07, 2014 12:27 PM 'William Ames Curtright' McKibbon, Bill J (FAA); 'Lewis Larry' RE: N949JP Information

I do have a photograph ofthe airworthiness certificate, and I do not need another. I do need a complete record ofyour flight review that includes the instructor's endorsement signature. Please provide me a date that I can inspect the aircraft weight/balance and airframe/engine maintenance logbooks. Thank you. -----Original Message----- From: William Ames Curtright [mai!to:ames@amesresearch.com] Sent: Monday,July 07, 201411:57AM To: Conroy, Marty G (FAA) Subject: N949JP Information Marty, Please see attached. As you might recall you took a picture ofthe air-worthiness certificate when you came out, want me to take another picture foryou? itthatwas taped in the cockpit on the wall. Airworthiness, Wet damaged reordered fresh one. Bi-Annual copy from log. I provided a medical certificate to you atthe time, and I have afresh New Medical exam last week. Rest of Documents are north in Canada logs. Will need some time to get them. Mytraveling style is a bit cramped for a bit. I will not be available the rest ofthis week. Ifeel sad forthe People thatwere lost at the coast. It's a hard Job, yourJob. The pain you see Icannot imagine. Thanks for your service and for your past service in the military. As I stood on my hill on the fourth ofJuly watching the explosions offireworksfrom all sides. It reminded me ofViet Nam ofShells going off, ofcannon file, and the rolling thunder ofArmageddon. It was differentfor methat night, itgave me thoughts ofwhat was to come ifwe do not change the course ofour country. Good Luckto you and God blessings.

Ames

1

# Attach1nent 3

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

### Sent: To: 

### Subject: Attachments:
To: FAA Marty, William Ames Curtright <ames@amesresearch.com> Thursday, August 28, 2014 3:03 PM William Ames Curtright N949JP Information Weight-Balance.pdf; 2013 Annual Inspection Notice.pdf

It

### was a pleasure to meet you at Ames Ranch. I have beenvery grounded so I have not been able to get north and will not be able to go upthis year, but as you suggested I did locate who did the annual and gota letterto meetyour needs as you requested. I have been very busywith the patriotic event I had {**h!.\J;I;LLJl.iJ!h."lLngoftheeag~s.corn/);** nowthat it is over, I have had a little bit more time. Keeping America safe for democracy. Seems as we are goingto have to continue our battle for freedom will neverend. The sacrifice ofour brothers, who died, we must notforget. Thus we continue forthem. U Tubes are on line. Worth watching. Warmest and best,

Dr. W. Ames Curtright DBA Office, 503-588-7000 Cell, 503-209-7388

1IuFii7'1

'1- Hobbs 527.7 ,
I September

I 1, 1997 Viking Air Ltd. ' **~?** The following work was completed ·underW/0 #14603: - **r~oved** EDO floats 89-2000, rlh sin 3594, l/h sin 3593 and installed Wipaire Amphib floats sin rlh 21044, llh 21043. Wipaire Amphib flpats were installed
in accordance with STC SA 00713CH and Wipaire Master Drawing list for Piper PA 18 and mode12100 floats reissued 6/.17/97. **~landing** gear system working normally and checked serviceable. - installation
of Lake and Afr Inc. Advisory system in accordance with ST SA 39CH and system checks **se~ceable.**

"THE ;,/),! i·iT - tl.le weight. and balance had been amended
to show this change. A!;;)f'}l 'i=' f_t .;:. -::;:

• .

l::l·- <f- ,-IJ """ The new **w~ight** and balance

is as follows: **Newemptyweight~I560.0**

New C. **G.~** 73.08 ACCORDf.\NCE STANDf\RDS Moment"' 114001.51.

,,

# I Memorandum
To: WilliamAmes Curtright 

## From: Ben W Davidson 

### Date: 8/26/2014 Re: AnnualInspectionN949JP Bill, This letter is to verifYthatI completedanAnnualInspection onN949JP aPA-18 onSeptember

**23r~** 

### 2013. Atthattime1providedyouwith a discrepancylistthatincludedan expiredbattery inyourELTthat requiredreplacement. 

# Ifneed further assistance, pleasedo nothesitate to calianytime before 9pm (IJ1yday. (541) 490-6980.

A&P2855347IA

1

# Attachtnent4US. Department ofTransportation Federal Aviation Administration


### September 4, 2014 Northwest Mountain Region Colorado, Idaho, Montana, Oregon, Utah, Washington, Wyoming Flight Standards District Office 3180 NW 229th Ave. HJ!Isboro, Oregon 97124 503-615-3225, Fax: 503-615-3300 1-800-847-3240 marty.g.conroy@faa.gov



### CERTIFIEDMAIL/SPECIAL DELIVERY- RETURN RECEIPT REQUESTED EIR Number: 2014NM090046 William Ames Curtright 1895 16th 

### SE Salem, Oregon97302 Subject: LetterofInvestigation DearMr. Curtright: Personnel ofthis office are investigating an accident, whichinvolved the operation ofan aircraft, N949JP, onJune 14,2014. This office sent you a letter datedJuly 1, 2014 by registeredmail requesting youpresentto us the following documents: aircraft weight and balance record, the airframe and engine maintenance logbooks, the Airworthiness and Registration certificates, and documentation ofyour compliance withthe flight review requirement of 14 CFRPart 61.56(c). 

### To date, youhave not presented this office withthe airframe and enginemaintenance logbooks forN949.TP and a complete record ofyourrequired flight review that includes the instructor's endorsement signature. This may be contrary to the Federal Aviation Regulations. This Jetter is to inform you that this matter is underinvestigation bythe Federal Aviation Administration (FAA). In accordance withthe Pilot's Bill ofRights, we are infom1ing you that: (I) The nature ofthis investigationis to determine whether you acted as pilot in command ofN949JP in violationofthe FederalAviationRegnlations, and ifso, what, ifany enforcementaction should be taken. (2) Oral orwritten response to this Letteroflnvestigationis notrequired, and no action can be taken or adverse inference made against you for declining to respond to this Letter of Investigation.

NM09: MConroy: MGC; 3240; 9/4/14: N:\FSDO ElectronicWork Space\lnvestigations\Violation\2014\2014NM090046**~Curtright,** Wi!llam Ames\LO! 9-4-2014.doc

### 3 

### PRIVACYACTNOTICE 

### ThisNoticeis providedin accordance withSection (e) (3) ofthe PrivacyAct, 5U.S.C. Section552a (e) (3), and concerns theinformationrequested intheletter orform with which this Noticeis enclosed. A. Authority: 

### This informationis solicitedpursuantto 49 U.S.C. 

### §40113(a) andthe regulations issuedunder that statutoryprovisioncodifiedin 14 C.P.R. part 13. Submission of informationis voluntary. B. PrincipalPurposes: 1. 

### Therequestfor information is intendedto provide you with anopportunity to participate inthe investigation. 2. Therequestedinformationwillbe used to help determine whether ornot there has beena violation ofthe Federal AviationRegulations, and ifso, what, ifany, enforcement action shouldbe taken. C. Routineuses: 

### Records from this system ofrecords may be disclosed inaccordance with the following routineuses that appear 

### inthe System ofRecords No. DOT/FAA 847, General Air TransportationRecords onIndividuals, DOT 

## IFAA: I. Toprovidebasic ainman certificate andqualification informationto the publicupon request. 2. To disclose informationto theNational Transportation SafetyBoard (NTSB) in connectionwith its investigationresponsibilities. 3. To provide information about airmento Federal, state, andlocal law enforcement agencies whenengagedinthe investigation and apprehension ofdrug law violators. 4. Toprovideinformation about enforcement actions arising outofviolations ofthe Federal AviationRegulations to govermnent agencies, the aviationindustry, and the publicuponrequest. 5. To disclose informationto another Federal agency, orto a courtor anadministrative tribunal, whenthe Govermnent or one ofits agencies is apartyto ajudicialproceeding beforethe court or involved in administrativeproceedingsbeforethetribunal. D. Effect offailure to respond: 

### TheFAAcannotimpose any penaltiesuponyou ifyoufail to respondto this letter ofinvestigation. Ifyou fail to supply the requestedinformation, however,the FAAwill make detenninations aboutpossibleenforcement action for this matter withoutthe benefit ofyour comments onthis matter.

# Attachment 5September9, 2014

Martin G. Conroy Aviation Safety Inspector Flight Standards Dist. Office 3180 NW 229'" Ave. Hillsboro, OR 97124 Re: EIR Number2014NM090046 Dear Sir: As explainedvia email, the aircraft logs are not in the United States; they are in Canada where I also live. I am now awaiting the time to repair my aircraft repair. In orderto meetyour 

### request 1have emailed the remaining documents and the Certification ofAnnual Inspection as requested to the Portland office. All other documents have been provided to you as requested. Is it possible your people have not opened your emails to checkthe attachments? They were sent toyour Portland office. If you are still missing something let us know. We have provided a letterfrom the mechanic who did the annual certification inspection. We recently emailed theweight and balance but again we will mail itto you. The eventwas 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 inertia and the rail on the floats pulled the aircraftto the left and intothe grass, thus, our description ofthe eventwhich 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, airworthiness registration certificate, and documentation with the flight review requirements and all the documentsyou requested, yetyou people act as ifyou never received those items. We have provided to you the documents in aspirit ofcooperation. Again, we hope this meets your needs and pray this brings closure for us both. Dr. W. Ames Curtright

Ames Research Laboratories, Inc. • 1891 16 St. SE. Salem, Oregon USA 97302

**Toll~Fr~e: 8&8-345~0809**  • Phone: 503-588-3330 • Fax: 503-364-2380 o amesstaffiJ(j;tmesresearch.com

### FAA NO.: N949JP Year: 1953 Certificate: 42137 Expiration: 2128/2015

# ! I 

# ' 

# Memorandum

To: William Ames Curtright 

## From: Ben W. Davidson Date: 

### 8/2612014 Re: Annual1nspectionN949JP 

## Bill, This letter is to verify thatI completedanAnnualInspection onN949JP aPA-18 on September

**2Jr~** 

### 2013. Atthat time !providedyouwith a discrepancy list that includedan expiredbattery inyourELTthat requiredreplacement. 

# Ifneed fUrther assistance,please do nothesitate to callanytime before 9pm anyday. (541) 490-6980.

Ben W. Davidson A&P2855347IA

1UN!TE.D STATES OF AMERJCA Department ofTransportation Federal Avi,.llon Admle1islr.3!km MEDICAL CERTIFICATE THIRD CLASS

1 ;, This certifies that (Full name ;mdaddress):

IN1LLIAM AMES CURTRIGHT 4135 PARADISE HlLL TURNER OR 97392 USA
; Date of Birth 

### I Height 

### IWeight 

### I Hair 

### I 1----



### o6~"1Ml9-13 I 7o ns BROWl\ ! **Ey~** BLUE has metthe medical standards prescribed in part 67, Federal Avia1ion Re ulations, forthis classof Medical Certificate. Must wear corrective lenses_ CONDITIONS OF ISSUE The holder Df this certificate must:

Have it in his or her personal possession at aU Urnes while exercising prtvile.ges ofan airman certificate. (14CFR§61.3) Understand that the issuance ofa medical certificate by an Aviation Medical Examiner may be reversed by the FAA within 6G days. (14CFR § 67.407) Comply with validity standards specified fur first-, second-, and third--class medical certificates. (l4CFR § 6123) Complywith any statement offunctional, operational. and/or time limitation lssued as a condition of certification. (14CFR § 67.401) (Note: A letter of authorization (or SODA) describing any such limitations must be kept with this certificate at all times while exercising !he privileges ofan airman certificate.} Complv with the standards relating to prohibitions on operation during medical deficiency, (14CFR §§ 61 .53, 63.19, ar!d 65.49) For International Operations Only: Some holders may be affected by certain international medical standards. Consult the U.S. Aeronautical Information Publication for U.S. differences with ICAO Annex 1 medical"standards.

AEROSPACE MEDICAL CERTIFICATION DIVISION, AAM • 300 FAA Givi! Aerospace Medical Institute Mike Monroney.Aeronautical Center ; P.O Box 26080 Oklahoma City, OK 73125-9914
WILLIAM AMES CURTRIGHT 4135 PARADISE HILL TURNER OR 97392 USA

Dear Aimmn: Above i;; your new medical certificate !l

**:mpers.dt..~** any previous one you may

**hnn~** h<.>cn issued. T{l validate this cl:!rtiticate, it is necess<lry that yuu sign il in the s,pacc provided {Airmru1's Signature). This certificate nmS1 be in your possession at alt

**lim~s** while exercising your pilot privileges

Cn:,;teQ on Thursday.

**Jun~** 26.2014Certificates Held


# ,.,

# .. STUDENT PILOT SPORT PiLOT RECREATIONAL PILOT PRIVATE PILOT COMMERC!AL PILOT FLIGHT INSTRUCTOR AIRUNETRANSPORT PILOT a.V!AT'.ON TECHNICIAN ?:.ROUND INSTRUCTOR Logbook Number__ _ From-------- To_____________ _

Date Issued Certificate Number .G1lfRPlANE 

### I <'"

### 1 

# ~"(\~ S

# 4'2,-'\'6::'\\S~I~LE ENGINE



# ~D !Q.8EA -------- 0 MULTI-ENGINE 0 LAND 0 SEA --,--,.--,----- -----,----- Otc(LJLr1-ENG!NE Limited to Center Line Tnrust



# _,.S=W/~':;,LL\ **f-/-\\~<?j~'1t::4:l,."** S";"':>

# ''"'i'f·il:r:> 0 INSTRUMENT 

### ('L.............,.e



# --~I 0 GLIDE.R DAEROTOW 0 \1>/INCHTOW 0 **POW~e~~'** 0 WEIGHT-SrFT CONTROL ' q--' ('I

### ti'<:c>--"" 

# :il;;"'(, 0 ROTORCRAFT

.ELICOPTER 0 GY OPLANE 0 LIGHTER-THAN-AlA 0 ArRSHIP 0 BALLOON 0 POWERED. LIFT OGI BASIC 0 Gl ADVANCED 0 Gl INSTRUMENT 0 OTHER RA.TINGS (Specify)Inerllfvlha!the AIRCfiAFT IDENTifiCATION NUMBERI 4!>£P.:rt,::-' ;-H,p.qr

**u,~,.:.~.-.~14~** R.

**t::..Cof~r.n..~t;Nr P~v**  ....,.lf P.d • .4T

**~~** !lit

**!:~$** f/i-77-bCI II
..

$

**S"A-r'I$F'J'iif'r~t..}"** Co'JA.!'t?.t.a"f'E1> A Fr..; GN'Y 7Ce Vt!JE:..P

**~11'"--U.I'** '<!>Y G>l,

**!:~ ~>•N"**  

### '1'/1{'/e., 

## G!5-wC2..:..Jl.,. "-<'' t 

### -..ffr5''f?,...'lis' :L'jL" I '1 't-

1 Hobbs 527.7 Viking Air Ltd.

w **-'\6..""\J~** September 11, 1997

The following work was completed under W /0 # 14603: -removed EDO floats 89-2000, r/h s/n 3594, 1/h s/n 3593 and installed Wipaire

Amphib floats s/n rlh 21044, Vh 21043. Wipaire Ampbib floats were installed in

accordance with STC SA 00713CH and Wipaire Master Drawing list for Piper

PA 18 and mode12100 floats reissued 6117197.

- landing gear system working normally and checked serviceable.

- installation of Lake and Afr Inc. Advisory system in accordance with ST SA

39CH and system checks serviceable. "THE **£~':.~;1;-:T**

-the weight and balance had been amended to show this change. ABOVE Hi\S ;

The new weight and balance is as follows:

New empty weight =1560.0 New C.G. 73.08 ACCORD;C,i'-JCE STANDfiRDS **Moment~** 114001.51.

# Attachtnent 6

# RecordofTelephone Call
Name: William Ames Curtright 

## Address: 189116thSE Salem, Oregon 

## Phone: 503-209-7388 

## Date: 9/24/2014, at 2:46PM 

## Subject: EIR #2014NM090046
This office left a voice mail message on 9/16/2014 for Mr. Curtright regarding access to the aircraft and engine maintenance logbooks for N949JP. This aircraftwas involved in an accident on June 14, 2014. Mr. Curtright did not respond. On9/24/2014, I did make contact with Mr. Curtright by telephone. I asked him if he intended to presentthis office with the aircraft and engine maintenance logbooks to allow us toconclude our investigation into the accident on June 14, 2014. Mr. Curtright responded that the logbooks were at his home in Canada and that hewas not in a position to travel there and recover them. I then asked Mr. Curtright if he could provide me a future date when he would be able to recover them. Mr. Curtright responded that he did notexpectto travel to Canada any time in the nearfuture, because hewas "running a business." We politely concluded our conversation. 

# t{aiJ;vu(ij}- MARTIN G.



# CO~Y Aviation Safety Inspector