1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

SERVED: August 27, 2015 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

IN THE MATTER OF 

MICHELLE KRAEMER 

Docket No. FAA-2015-2441 

(Civil Penalty Action) 

ANSWER TO COMPLAINT 

Respondent Michelle Kraemer, by the undersigned attorneys, pursuant to 14 C.F.R. § 

13.209 hereby files her Answer to the FAA's Complaint. 

1. 

2. 

3. 

4. 

5. 

6. 

Admit. 

Admit. 

Admit. 

Admit. 

Admit. 

Admit. 

7. Admit. 

I. FACTS 

8. Insufficient evidence on which to admit or deny. 

9. Admit. 

10. Admit. 

11. Admit. 

12. Admit. 

ANSWER 

RECEIVED 

SEP- 3 2015 

HEARING DOCKET 

DOCKET NO.: FAA-2015-2441 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

13. Insufficient evidence on which to admit or deny. 

14. Admit. 

15. Insufficient evidence on which to admit or deny. 

16. Insufficient evidence on which to admit or deny. 

17. Insufficient evidence on which to admit or deny. 

18. Insufficient evidence on which to admit or deny. 

19. Insufficient evidence on which to admit or deny. 

20. Insufficient evidence on which to admit or deny. 

21. Insufficient evidence on which to admit or deny. 

22. Insufficient evidence on which to admit or deny. 

23. Admit. 

24. Insufficient evidence on which to admit or deny. 

25. Insufficient evidence on which to admit or deny. 

26. Admit. 

27. Insufficient evidence on which to admit or deny. 

28. Admit. 

29. Insufficient evidence on which to admit or deny. 

30. Insufficient evidence on which to admit or deny. 

31. Insufficient evidence on which to admit or deny. 

II. SANCTIONS 

In its Complaint, Complainant asks for the maximum civil penalty allowed by law for 

a first-time offense alleged to have been committed by Respondent. Complainant has no 

evidence that Respondent has ever been in a situation like the one alleged in the Complaint, 

because it has none, so the request for the full $11,000 civil penalty is Draconian, to say the 

least. Respondent has an alcohol dependency problem for which she is actively pursuing 

recovery, and this case is one where the interests of justice would be far better served by 

ANSWER DOCKET NO.: FAA-2015-2441 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

leniency. Respondent lost her job with Republic and her life has been turned upside down by 

this situatio 

Respondent respectfully requests that the Administrative Law Judge dismiss all the 

charges alleged against her, or in the alternative, reduces the civil penalty from the maximum 

$11,000. 

Respectfully Submitted, 

I 6/ 9J'tian :J. Cauri.eJt 

Brian J. Lawler, Esq. 

PILOT LAW, P.C. 

1551 9'h Avenue 

San Diego, CA 9210 I 

Telephone: (619) 255-2398 

Facsimile: ( 619) 231-4984 

blawler@pilotlawcorp.com 

Attorneys for Respondent 

ANSWER DOCKET NO.: FAA-2015-2441 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

CERTIFICATE OF SERVICE 

I hereby certify that the enclosed Answer has been sent via U.S. Mail and via 

facsimile to the following: 

Original and One Copy: 

Hearing Docket, Federal Aviation Administration 

800 Independence Ave. S.W. 

Washington, DC 20591 

Attn: Hearing Docket Clerk 

AGC-430 

Wilber Wright Building 

Suite 2Wl000 

One Copy (via U.S. Mail and facsimile) 

Ms. Briana Martino, Esq. 

FAA Office of Regional Counsel 

2300 E. Devon Ave. 

(AGL-7, Room 479) 

Des Plaines, IL 60018 

Tel: 847-294-7313 

Fax: 847-294-7498 

Hon. Richard C. Goodwin 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue SE (Ell-310) 

Washington, D.C. 20590 

Tel: 202-366-5121 (Staff assistant) 

Fax: 202-366-7536 

Dated: August 27,2015 

ANSWER 

bl :JJttian J. eawlett 

Brian J. Lawler 

DOCKET NO.: FAA-2015-2441