## 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 Matterof: 

### 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 theAU's Order in the above matteras follows: 1, Unsigned Complaint. The Complainantsays ''the oversight is a minorprocedure defect." So itseems thatthe Complainant does notconsiderthe Respondent's rightto a hearing or response to be a minordefect. In this case, Respondent did notsee the unsigned Complaint
as official and did not know that a lawyerwould be necessary or might be necessary to respond. Itseems that Complainant would like to sidestep that right to a hearing on a procedural error bypassing the Respondent's rightfor 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 documentthey call a Complaint is NOT aJudicial Order. Respondent does not believethat a documentfrom the FAAthat 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 ofjustice seem tilted tothe advantage ofthe 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 ofcompliance from the Respondent. The Respondent had to press forthose documentsthot exonerated him. Complainont FAA writesthat "Prose respondents should not be held to aStandard 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 withthe FAA secret standard ofcompliance. The FAA does not getto decide the ruleswhenthe FAA Is one party in a dispute. The rules for an independentAdministrative Law Hearing are to be propagated by the administers ofthe independent dispute resolution organization. Complainant maintains th<1t itdoes not have to meetthis mystery standard ofcompliance whenthe FAA sends a documentthat is not legally signed butthe Respondent must do so. Surelythis mystery standard ofcompliance requires legal signatures on legal documents. Complainant cannot have it bothways. 3. Factual Issues. Respondent requested a hearing and Complainant FAA asked thatthe hearing be denied. Respondent was asked why he did not meet a deadline. Respondent
RESPONDENT'S REPLYTO COMPLAINANT'S RESPONSE TO THE AU'S ORDER OF NOVEMBER 19, 2015 Docket No. FAA-2015-1319 Case No. 2014NM090046 Page 2 of5 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 whythe hearing should not be denied. The whole point ofthe requested hearing by Respondent is to allow him to provide evidence that Respondent met the demonds ofon 

### FAA letterthatwas noteven legally signed. In fact, Respondent needs a hearing before 

## an independentAdministrative Law Judge to produce evidence to the effect that 

### FAA inspectors from Portland concluded thatthe aircraft logbooks are in order. Respondent has in his possession that 

### FAA document.
In conclusion, Respondent is concerned for all pilots. The cost oflegal defense forany 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 butto surrender at great cost. This, I believe, is notthe intent ofthe 

### FAA on a national level 

### butthatthis council (Complainant) may be misusing his authority and powerto prosecute possible innocent pilots.
There are otherissues which exist indicatingwrongful actions byComplainant. The saying "what is good forthe goose is goodforthe gander" might be 

## an appropriate phrase in this case. When the Complainant was asked why he would proceed aftercompliance he replied, "Well, we should get something out ofthis." Thatjust seems wrong! Your Honor, with all due respectforthose involved, I believe, this 

### is an ethics issue. Thus I informed the Complainant thatthis was an ethics issue, the plaintiffwas rude 

## and arrogant. Therefore, Respondent asks with respectthe Court eitherallow the hearingto be held or recognize 

### a motion to dismiss the case. Ifthe court will allowthe 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 documentwas suppressed or hidden. Ifa

RESPONDENTS REPLYTO COMPlAINANT'S RESPONSE TO THE AU'S ORDER OF NOVoMSoR 19, 2015 Docket No. FAA-2015-1319 Case No. 2014NM090046 Page 3 ofS 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 courtto allow the hearingtotake place sothat due process is served. Respectfully submitted



## this~ day ofJanuary, 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 of5 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 WilburWright 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 NewJersey 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 REPLYTO COMPLAINANT'S RESPONSE TO THE AU'S ORDER OF NOVEMBER 19, 2015 Docket No. FAA-2015·1319 Case No. 2014NM090046 Page 5 of5 

## 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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