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U.S. DEPARTMENT OF TRANSPORTATION MAR 2 3 2015 

OFFICE OF HEARINGS 

WASIDNGTON, DC HEARING 

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In the Matter of: 

STARJET, INC. 

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TO: Honorable Richard C. Goodwin and Respondent 

FAAEIR2014WP230019 

FDMS NO. FAA 2014-1115 

ALJ- GOODWIN 

MOTION TO DEEM ALLEGATIONS ADMITTED 

COMES NOW, Complainant. by her counsel, and files this motion to deem the 

allegations admitted pursuant to Rules 13.218(a) and 13.209(e) of the Rules of Practice in FAA 

Civil Penalty Actions (14 C. F. R. 13.218(a) and 13.209(e). This motion is made on the grounds 

that Respondent failed to file an answer to the complaint. 

On December 21, 2014, by regular USPS mail to the Complainant, Respondent requested 

a hearing following its receipt of the December 10,2014, Final Notice of Proposed Civil Penalty. 

On January 6, 2015, the Complainant filed the Complaint with a cover letter. In the cover letter 

to the Complaint, Complainant notified Respondent that a written Answer to the Complaint be 

filed not later than 30 days after service of the Complaint. On January 9, 2015, the Department 

of Transportation (DOT) Hearing Docket Clerk acknowledged receipt of the Complaint. On 

January 15, 2015, in a Notice of Assigmnent of Proceeding, DOT Chief Administrative Law 

Judge Ronnie A. Yoder assigned this proceeding to Administrative Law Judge Richard C. 

Goodwin. 

Per Respondent's request, on February 11,2015, the Complainant sent, by electronic mail 

transmission, the Complaint to Respondent, as Respondent expressed an understanding that it 

had to file an Answer responding to each paragraph/point of the Complaint. 
On February 19, 2015, your Honor served on the parties a Procedural Order. The 

Procedural Order addressed the Rule 13.209(a) requirement to file an answer, quoted Rule 

13.209(e)- Specific denial of allegations required, and stated under Rule 13.209(f) that a failure 

to file an answer without good cause is deemed an admission of each allegation in the complaint. 

The Respondent has not filed an Answer to the Complaint and the time for Respondent to 

file a timely Answer has passed. 

Accordingly, the Complainant respectfully requests that your Honor deem the allegations 

admitted on the grounds that the Respondent has failed to file an answer to the complaint. In the 

event this motion is granted, Complainant submits that the parties could adequately brief the 

issue of sanction by written argument. 

WHEREFORE, the Complainant respectfully requests that Your Honor issue an Order 

deeming the allegations admitted. 

Respectfully submitted, 

Federal Aviation Administration 

Western-Pacific Region 

Lawndale, California 

NAOMI TSUDA 

Regional Counsel 

By:~.~~ !:1 a J. oscano 

Attorney 

Dated: March 17,2015 

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FAA EIR 2014WP230019 

FDMS No. FAA 2014-1115 

CERTIFICATE OF SERVICE 

I hereby certify that on this date I have placed in the United States mail, postage prepaid, the 

executed original and one copy of the MOTION TO DEEM ALLEGATIONS ADMITTED 

addressed as follows: 

and a true copy to: 

Also by facsimile: 

Also by facsimile 

Hearing Docket 

Federal Aviation Administration 

Wilbur Wright Building, Suite 2W1000 

Attn: Hearing Docket Clerk, AGC-430 

800 Independence Avenue, S.W. 

Washington, DC 20591 

The Honorable Richard C. Goodwin 

Administrative Law Judge 

U.S. Department of Transportation 

Office of Hearings, M-20 

East Building Ground Floor 

Room E12-320 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

(202) 366-7536 

PekkaKaru 

President/Director of Operations 

Starjet, Inc. 

26 Washington Blvd, 2"d Floor 

Marina Del Rey, CA 90292 

(310) 301-1556 

Dated: March 17,2015 

Agnes:Ebilane, 

a~oacr.JJ~ Legal Technician 

Office of the Regional Counsel 

Federal Aviation Administration 

Lawndale, California 

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