02/10/2015 10:~ FAX 3107256816 AWP-7 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF BEARlNGS 

WASHINGTON, DC 

American Medflight, Inc., 

Respondent 

FAA Case No. 2014WPll0010 

DMS No.: FAA 2014-0815 

FAA Region: Westem Pacific 

Judge: Richard C. Goodwin 

MOTION 1'0 DISMISS 

To: The Honorable Richard C. Goodwin and Respondent: 

Pursuant to 14 C.F.R. l3.218(f)(2), Complainant Federal Aviation 

Administration, tlu·ough counsel, hereby files this Motion to Dismiss. This motion is 

ba~ed on the fact the parties have settled thi~- matter, and the matter is paid in ful'l by 

Respondent. Tn addition, pursuant to the attached Settlement Agreement (Exhibi: A) 

signed by both parties, the Agreement serves as Respondent's statement of withdrawal of 

its request for hearing. Because a hearing is no longer required, Complainant hereby 

moves to cancel the hearing md terminate the proceedings. 

Respectfully submitted, 

NAOMTTSUDA 

Regional Counsel 

By: 

Dated: February 10,2015 

~002 
02/10/2015 10:20 FAX 3107256816 AlVP-7 

CERTIFICATE OF SERVICE 

I hereby certify that on this date I sent via United States mail, postage prepaid, the 

executed original of the COMPLAINANT'S MOTION TO DISMISS, addressed as 

:Follows: 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building-Suite 2Wl000 

Also by facsimile: 202-493-5142 

And by facsimile only to: 

Hon. Richard C. Goodwin 

Office of Hearings, M-20 

U.S. Department of Transportation 

l200New Jersey Ave., S.E. 

East Building Ground Floor, Room Ell-31 0 

Washington, D.C. 20590 

Facsimile: 202-366-7536 

I further certify that on this date I sent via United States mail, postage prepaid, a 

true copy of the COMPLAINANT'S MOTION TO DISMISS, addressed as follows: 

Michael L. Dworkin, Esq. 

465 California Street, Suite 210 

San Francisco, CA 94104 

Also by facsimile: 415-421-2560 

Dated: February 10,2015 

-

Ag~, w"-1Y Legal Technician 

Office of the Regional Counsel 

Federal Aviation Administration 

Western-Pacific Region 

Lawndale, California 

2 

141003 
02/10/2015 10:20 FAX 3107256816 AWP-7 I4J 004 

u.s. DeparTment Western-Paciiic Re&~ion P.O. Sox 92007 

of Tronsportation 

Fedsral Aviation 

Admir>litration 

Offics of the Regional Counsel Los Angele9, CA 90009M2007 

lele·phone: (310) "!25-7112 

F·acstmile; (310} "25-68'16 

January 21,2015 

Michael L. Dworkin 

law@avialex.com 

Rc: Your client AmericanMedflight FAA Case No. 2014WP1l0010 

Dear Mr. Dworkin: 

This will confirm the settlel!lent.ofthe abow-captioned case reached during a phone 

conversation yesterday. 

We agreed to issue an order assessing civil penalty, with a penalty amount of$7,300.00. 

Your client agrees to file a withdrawal of its request for a hearing within five (5) business 

days after you have signed this letter and retuthed ittome.lfthe request for hearing is not 

timely withdrawn, then this Jetter with your· signature will serve as your client's statement of 

withdrawal of the request fo; hearing. Jn addition, your client agrees to waive any potential 

claim under the Equal Access to .Justice Act. After the request for hearing has been 

withdrawn, the order will be issued. The factual allegations and alleged violations will 

remain as proposed in the October 7, 2014, Final Notice of Proposed Civil Penally. 

If this comports with your understanding of the agreement, please sign and date a copy of 

this letter, below, and return it to me at: lryll.Robbins-Umel@faa.gov, or by facsimile to my 

attention at (31 0) 725-6816 by Monday, January 26, 2015 COR 

Sincerely, 

NAOMI TSUDA 

Regional Counsel 

By: Ir~C:-.:S. "~."".u""mo:::_el:------ ~~ 

I have discussed this settlement witll my client and agree to the settle~ of the ~eferenced 

case as outlined above. :• 

/~Su~£~-- ······· ·-" 

/ 7/ MICHAEL L iJ:WtiRKIN ---

/ 

.r/ ,.',,...-

... / // ~. 

'tDati) 

Exhibit A 
02/10/2015 10: 2.'L.!'AX 3107256816 AWP-7 

202~: .. Hearing Clerk, FAA 

Judge Goodwin- 202-366-7536; 

To: Michael L. Dworkin, Esq. -415-421-2560 

Com pan~: 

Phone: 

Fax: r;, lryll Robbins-Umel 

~ Attorney 

l.are_, 2/10/2015 

Pages W/cover: 4 

141001 

Federal Aviation 

Administration 

Office of the Regional Counsel, AWP-7 

PO Box92007 

Los Angeles, CA 90009-2007 

Telephone: (31 0) 725-7100 

Facsimile: (310) 725-<'1816 

Email: 

Facsimile 

Description of item being transmitted: 

Motion to Dismiss 

American Medflight 

DMS No. FAA-2014-0815 

D Per your Request D For Review D Please Comment 0 For Coordination 0 Hand Copy to Follow via US Mail 

NOTES/COMMENTS: 

The information contained in this facsimile message is intended for the use of the designated addressee only. 

The information transmitted msy be subject to the attorney-client privilege or may be protected under the Privacy 

Act If you are not the designated addressee and you receive this document through inadvertent error, any further 

review, dissemination, distribution or copying of this communication is strictly prohibited. IF YOU RECEIVE THIS 

COMMUNICATION IN ERROR, PLEASE NOTIFY THE SENDER IMMEDIATELY BY TELEPHONING (31 0) 725-

7100 AND DESTROY THE ORIGINAL OF THIS COMMUNICATION. Thank You. 

0 U.s. DGpartmen1 of TrsnsponsUor'l