01-06-'16 07:58 FROM-Ames Research 15033642380 

William A. Curtright 

Respondent 

PO Box 1350 

Jefferson, OR 97352. 

Telephone: (503) 209-7388 

Fax: (503) 485-0812 

In The Matter of: 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

T-826 P0002/0006 F-424 

Docket No. FAA-2015-1319 

WILLIAM A. CURTRIGHT, 

Case No. 2014NM090046 

Respondent 

Judge J.E. Sullivan 

RESPONDENT'S REPLY TO COMPLAINANT'S RESPONSE TO THE AU'S ORDER OF NOVEMBER 19. 2015 

Respondent hereby responds with respect to Complainant's Response to the AU's Order in the 

above matter as follows: 

1, Unsigned Complaint. The Complainant says ''the oversight is a minor procedure defect." So 

it seems that the Complainant does not consider the Respondent's right to a hearing or 

response to be a minor defect. In this case, Respondent did not see the unsigned Complaint 

as official and did not know that a lawyer would be necessary or might be necessary to 

respond. It seems that Complainant would like to sidestep that right to a hearing on a 

procedural error bypassing the Respondent's right for a hearing. 

RESPONDENT'S REPLY TO COMPLAINANT'S RESPONSE TO THE AU'S ORDER 

OF NOVEMBER 19, 2015 

Docket No. FAA~2015·1319 

Case No. 2014NM090046 

Pilge1of5 

William A. Curtright 

Respondent 

Telephone: (503) 209-7388 

Fax: (503) 485~0812 
01-06-'16 08:05 FROM-Ames Research 15033642380 T-829 P0003/0006 F-424 

The FAA document they call a Complaint is NOT a Judicial Order. Respondent does not 

believe that a document from the FAA that does not have an official signature affixed to it 

has any legal effect at all. 

2. Foilure to comply with 14 C.F.R. 13.209((f). The scoles of justice seem tilted to the 

advantage of the government. Finances are paid for by the government and a punitive fine 

· of $11,000 is levied even though compliance of both aircraft and logs was confirmed by the 

inspectors. The Respondent feels the Complainant has overstepped his authority and hid 

documents of compliance from the Respondent. The Respondent had to press for those 

documents thot exonerated him. 

Complainont FAA writes that "Prose respondents should not be held to a Standard of 

Compliance has been rejected by the FAA Administrator." An English linguist should have 

been consulted when drafting this sentence. It seems as the FAA Administrator is being selfserving by rejecting multiple Respondents who fail to comply with the FAA secret standard 

of compliance. The FAA does not get to decide the rules when the FAA Is one party in a 

dispute. The rules for an independent Administrative Law Hearing are to be propagated by 

the administers of the independent dispute resolution organization. Complainant maintains 

th<1t it does not have to meet this mystery standard of compliance when the FAA sends a 

document that is not legally signed but the Respondent must do so. Surely this mystery 

standard of compliance requires legal signatures on legal documents. Complainant cannot 

have it both ways. 

3. Factual Issues. Respondent requested a hearing and Complainant FAA asked that the 

hearing be denied. Respondent was asked why he did not meet a deadline. Respondent 

RESPONDENT'S REPLY TO COMPLAINANT'S RESPONSE TO THE AU'S ORDER 

OF NOVEMBER 19, 2015 

Docket No. FAA-2015-1319 

Case No. 2014NM090046 

Page 2 of 5 

William A. Curtright 

Respondent 

Telephone; (503) 209-7388 

Fax: (503) 485-0812 
01-06-'16 08:05 FROM-Ames Research 15033642380 T-829 P0004/0006 F-424 

answered the question as to why the hearing should not be denied. The whole point of the 

requested hearing by Respondent is to allow him to provide evidence that Respondent met 

the demonds of on FAA letter that was not even legally signed. In fact, Respondent needs a 

hearing before an independent Administrative Law Judge to produce evidence to the effect 

that FAA inspectors from Portland concluded that the aircraft logbooks are in order. 

Respondent has in his possession that FAA document. 

In conclusion, Respondent is concerned for all pilots. The cost of legal defense for any pilot 

would be astronomical. The Issue here is the Comploinont may be used to getting pilots, who deserve a 

hearing, caught in a system that leaves them no recourse but to surrender at great cost. This, I believe, 

is not the intent of the FAA on a national level but that this council (Complainant) may be misusing his 

authority and power to prosecute possible innocent pilots. 

There are other issues which exist indicating wrongful actions by Complainant. The saying 

"what is good for the goose is good forthe gander" might be an appropriate phrase in this case. When 

the Complainant was asked why he would proceed after compliance he replied, "Well, we should get 

something out of this." That just seems wrong! Your Honor, with all due respect for those involved, I 

believe, this is an ethics issue. Thus I informed the Complainant that this was an ethics issue, the 

plaintiff was rude and arrogant. 

Therefore, Respondent asks with respect the Court either allow the hearing to be held or 

recognize a motion to dismiss the case. If the court will allow the motion, we would like to make that 

motion now. All compliance was demonstrated to inspectors. The inspectors have 3greed that all 

documents were in compliance ond that a correspondence document was suppressed or hidden. If a 

RESPONDENTS REPLY TO COMPlAINANT'S RESPONSE TO THE AU'S ORDER 

OF NOVoMSoR 19, 2015 

Docket No. FAA-2015-1319 

Case No. 2014NM090046 

Page 3 of S 

William A. Curtright 

Respondent 

Telephone: (503)209-7388 

Fax: (503) 485-0812 
01-06-'16 08:05 FROM-Ames Research 15033642380 T-829 P0005/0006 F-424 

dismissal is not allowed, we ask the court to allow the hearing to take place so that due process is 

served. 

Respectfully submitted this~ day of January, 2016. 

~v- ~ c~,_______ Dr. William A. Curtright, DBA 

Respondent 

RESPONDENT'S REPLY TO COMPLAINANT'S RESPONSE TO THE AU'S ORDER 

OF NOVEMBER 19, 2015 

Docket No. FAA-2015-1319 

Case No. 2014NM090046 

Page 4 of 5 

William A. Curtright 

Respohdent 

Telephone; (503) 209-7388 

Fax; (503) 485-0812 
01-06-'16 08:06 FROM-Ames Research 15033642380 

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 (Ell-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 REPLY TO COMPLAINANT'S RESPONSE TO THE AU'S ORDER 

OF NOVEMBER 19, 2015 

Docket No. FAA-2015·1319 

Case No. 2014NM090046 

Page 5 of 5 

T-829 P0006/0006 F-424 

William A. Curtright 

Respondent 

Telephone; (503) 209· 7388 

Fax: (503)485-0812 
01-06-'16 07:58 FROM-Ames Research 15033642380 T-826 P0001/0006 F-424 

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DATE: ~I /tJ.s-/;1.. 

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