SERVED: APRIL 30, 2012 

UNITED STATES DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

) 

FEDERAL AVIATION ADMINISTRATION, ) 

) 

Complainant, ) FAA DOCKET No. CP10SW0020 

) 

v. ) (Civil Penalty Action) 

) 

OKLAHOMA SKYDIVING CENTER, ) 

) 

Respondent. ) DMS No. FAA-2010-1215 

) 

INITIAL DECISION 

OF ADMINISTRATIVE LAW JUDGE RICHARD C. GOODWIN 

Found: 1) Respondent violated 14 CFR §§91.405(a), 91.7(a), and 91.13(a) as 

charged; and 

2) Respondent is assessed a civil penalty of $8,000. 

I. Background 

D r" J· . ~l .J 

Respondent Oklahoma Skydiving Center ("Respondent" or "Oklahoma 

Skydiving"), is a Part 91 operator located at the Cushing, OK airport.1 It operates a 

skydiving service. The instant matter grew out of a ramp inspection conducted by 

agents of the Federal Aviation Administration ("Complainant," "FAA," or "the agency") 

on an aircraft owned and operated by Respondent. 

The agency's Complaint, as amended, asserts that Oklahoma Skydiving violated 

the following Federal Aviation Regulations ("FARs"): 14 C.F.R. §91.405(a), which 

requires operators to inspect their aircraft and to have discrepancies repaired between 

inspections in accordance with FAR rules; §91.7(a), which bars the operation of a civil 

aircraft unless it is in an airworthy condition; and §91.13(a), which prohibits a person 

1 Exh. A-3. Complainant's exhibits will be designated "Exh. A-" and Respondent's as "Exh. R-." 

Complainant's Brief will be "Compl. Br.," Respondent's, "Resp. Br.," and Complainant's Rebuttal Brief, 

"Compl. Rebut." 
2 

from operating an aircraft in a careless or reckless manner so as to endanger life and 

property. The agency seeks a civil penalty of $8,000. 

Respondent denied the allegations. 

A hearing on the charges was held on January 10,2012, in Oklahoma City, OK I 

determined that a written decision was reasonable and appropriate under the 

circumstances (Tr. 312). The parties have filed briefs and the matter now is ready for 

decision. 

The burden of proof rests with the agency. To prevail it must establish proof by 

a preponderance of the reliable, probative, and substantial evidence. 14 C.F.R. §§13.223 

and 13.224; Toyota Motor Sales, FAA Order No. 94~28, pp. 6~7, 1994 FAA Lexis 275, p.lO 

(September 30, 1994). Complainant also bears the burden of justifying the amount of the 

civil penalty it seeks. Phillips Building Supply, FAA Order No. 2000~ 20, p. 8, 2000 WL 

33125266, p. 4 (August 11,2000). The burden shifts to Respondent to prove any 

affirmative defenses it may assert. Continental Airlines, Inc., FAA Order No. 98~6, p. 5, 1998 

WL 231441, p. 8 (April?, 1998). 

I hold that the facts and circumstances of this case justify findings of violations of 

each count and warrant an assessment against Respondent of $8,000. 

II. The Evidence 

A. The Ramp Inspection and Aftermath 

The ramp inspection triggering this case took place on the morning of July 11, 

2009, at Respondent's hangar facility in Cushing, OK. It was a busy Saturday morning. 

The aircraft in question, a Cessna 206, was being readied to carry skydivers. People were 

milling about. Some were getting ground instruction; others were donning parachutes 

(Tr.156). 

A vtation safety insp~ctors Lana Boler (then Lana West) and Robert Terry of 

FAA's Flight Standards District Office ("FSDO") in Oklahoma City, OK carried out the 

inspection (Tr. 24~ 25, 28, 66, 68, 151~53, 191; Exhs. A~ 3, A~9). Each inspector testified for 

Complainant. They stated that their examination uncovered four discrepancies. These 

formed the basis for the agency's Complaint. 

The first alleged discrepancy involved the seat stops installed on the pilot's 

seat rails. This type of aircraft has two such stops. The inspection disclosed that they 

were held by bolts with locknuts. This was an incorrect way to secure the seat, the 

inspectors stated. The method used did not conform to the aircraft's type design. The 

seat stops required a Cessna seat stop pin and cotter pin. Moreover, the installed seat 

stops were unsafe, the agency claimed; they presented a "significant" safety risk for the 

pilot. It was explained that seat stops prevent seats from sliding backward at critical 

times of flight, such as rotation. Seat sliding at such a time could lead to a stall spin and 
3 

result in an accident. The installation of incorrect seat stops has resulted in "numerous" 

accidents, inspector Boler testified (Tr. 46/47,52/53,60/61,78/79,122/23,131,133/34, 158; 

Exh. R/K). 

A second asserted discrepancy concerned a hole that had punctured the left 

flap. The inspectors observed the head of a screw poking through the lower skin of the 

flap. The flap skin was torn around the screw head. The punctured flap, they 

concluded, did not conform to the type design of the aircraft. Additionally, this 

condition risked jamming the flap. "Asymmetrical flap" could result// a "significant" 

problem of controllability, the FAA inspectors stated. Inspector Terry elaborated that, if 

one flap came down and the other did not, a controllability issue would obtain at slow 

air speeds // possibly leading to a "very dangerous situation" approaching stall speed. 

With a condition of asymmetrical flap, inspector Terry stated, "you could very well be 

asking for trouble ... " (Exhs. A/3, A/5; Tr. 33,43/44,53/54,61,97,143/44, 158/63). 

The third charged discrepancy involved the underside of the center area of 

the right flap. Inspector Boler noticed that it had multiple cracks in the lower skin. 

Cracks in the flap do not conform to the type design of the aircraft, she testified (Tr. 37/ 

41, 53, 61,100/01, 103; Exh. A/7). 

The fourth and final alleged discrepancy concerned the left side window. 

The window was broken in half. The inspectors observed duct tape covering two 

crossing cracks // a vertical crack which had split the window in two, and a horizontal 

crack that extended horizontally from that crack aft. 

A cracked window did not meet the aircraft type design, inspector Boler stated. 

Nor is duct tape considered an accepted or approved method of repair. The witness 

asserted that a cracked window is a potential safety hazard - a risk for impact with the 

horizontal stabilizer, the vertical stabilizer, or the rudder during flight. Such impact 

could cause loss of control. Inspector Terry wondered if the duct tape was strong 

enough to hold. Could part of the window fly back and hit a control surface, possibly 

rendering the aircraft uncontrollable? The inspectors concluded that the operator 

unacceptably risked the safety of the aircraft in this condition (Exh. A/6; Tr. 51/53, 105/ 

06,109/12,137,144,157/58, 161). 

Following the inspection, inspector Boler met with Oklahoma Skydiving's owner, 

Mr. Jack Reeves. She explained the inspectors' findings to him. Mr. Reeves insisted that 

the asserted discrepancies failed to render the aircraft unairworthy. More specifically, he 

claimed that the bolts he had installed were stronger than Cessna's seat/stop 

specifications (Tr. 77,164,166,179,288, 299). 

Before the inspectors left, inspector Boler issued to Oklahoma Skydiving an 

Aircraft Condition Notice ("Condition Notice") (Tr. 54, 57, 164; Exh. A/8). The 

Condition Notice warned that the four discrepancies therein listed (and, as noted, the 

basis for the charges in the Complaint) presented an imminent hazard to safety; the 
4 

Condition Notice also warned that operation of the aircraft prior to correction would be 

contrary to the F ARs (Exh. A~8; T r. 112, 297). The FAA witnesses elaborated that the 

discrepancies made the aircraft unairworthy because 1) they did not meet the type design 

of the aircraft; and 2) rendered the aircraft unsafe to fly (Tr. 57, 176~77, 183, 191). 

It is not disputed that Mr. Reeves said, and repeated, that he would operate the 

aircraft and take skydivers that day despite the inspectors' warnings. A short time later 

the inspectors, who had left the facility, observed the Cessna take off. They soon saw 

two passengers jump out of the aircraft (Tr. 58~60, 142~43, 164~65, 167~68, 298~99; Exh. 

A~9). Oklahoma Skydiving performed probably 35 cycles that weekend, Mr. Reeves 

acknowledged. About one hundred skydivers parachuted out (Tr. 301, 306). 

The discrepancies were properly addressed by July 17,2009. The Cessna's 

tachometer showed that 19.7 hours had elapsed following the ramp inspection (T r. 100, 

112,212, Exh. A~10). Mr. Reeves stated that he had taken the Condition Notice and 

aircraft to his mechanic the Monday following the inspection Quly 13th)~~ operating it 

without obtaining the required ferry permit - and received the properly repaired aircraft 

four days later, on the 1th (Tr. 299~300, 309). 

B. Findings and Conclusions 

1. Section 91.405(a) 

This provision obligates regulated entities such as Respondent to fix (or 

appropriately defer) unresolved discrepancies before operating. A discrepancy 

unaddressed or improperly addressed renders an aircraft unairworthy. Delaware Skyways, 

LLC, FAA Order No. 2005~6 (March 18, 2005), p. 5. Complainant proved that Oklahoma 

Skydiving violated this section. 

Respondent asserts in its defense that the agency failed to show that the 

inspectors' examination of the Cessna 206 on July 11,2009 had uncovered any 

discrepancies. It points out that the inspectors did not have any source material with 

them, such as a manual or type certificate data sheet, to confirm their beliefs: 

Respondent argues that observation alone is an inadequate basis for finding 

discrepancies (Tr. 82~83). Additionally, the inspectors never consulted relevant 

maintenance records to determine if the supposed discrepancies they had observed had 

in fact already been properly addressed. Oklahoma Skydiving also asserts that the 

alleged discrepancies were matters too insignificant to affect the airworthiness of the 

aircraft. 

These arguments are rejected. I find that Complainant showed that each of the 

four instances under review constituted a discrepancy. 

Initially, it is found that the inspectors were trustworthy. Their testimony was 

credible. That finding, coupled with their expertise, constitutes sufficient ground for 

upholding their determination that discrepancies were present based solely on their 

scrutiny of the aircraft. The inspectors testified that each of the four issues they 
5 

uncovered constituted an improper deviation from the aircraft's type design; they 

additionally stated that the matters risked the safety of flight to an unacceptable degree. 

Their testimony was persuasive. Either of these conclusions, concerning any of the four 

matters, would render the aircraft unairworthy. 

It is true that, as Respondent pointed out, not every nick or scratch renders an 

aircraft unairworthy. Not every departure from factory condition constitutes a 

discrepancy (Tr. 61, 144). But it was the inspectors' considered view that the matters 

addressed in the Condition Notice - and confirmed by their subsequent review of the 

aircraft's type certificate data sheet (Tr. 133) -either diverged from factory or otherwise 

approved or accepted conditions, or affected safety, or both, in sufficient degree to 

compel the conclusion that the aircraft was not airworthy (Tr. 61). The inspectors' 

expertise and experience warran~s the conclusion that they proved their points. No 

persuasive evidence suggesting a contrary conclusion, moreover, came to light. Against 

this background, I find that the four issues each constituted a discrepancy. 

It was not Complainant's duty to confirm or bolster the inspectors' findings by 

initiating an examination of any documents to which Respondent may have had access 

touching on maintenance. When the inspectors notified Oklahoma Skydiving of their 

findings following their ramp inspection, the burden of production shifted to 

Respondent. Respondent, after all, was in the best position to know where pertinent 

records might be located and what those records contained. To ask the agency to 

assume the burden of locating maintenance records under these circumstances would be 

unreasonable and unfair as well as illogical. It was Oklahoma Skydiving's obligation to 

inform and turn over to the FAA any records demonstrating maintenance complianceto, in effect, mount its affirmative defense. As such, an inference that the required 

maintenance had not been performed may be drawn from the failure of Respondent to do 

so (seeTr. 64). 

The evidence in fact showed that inspector Boler had asked to see Respondent's 

logbooks. But they were not produced (T r. ll6). Respondent's owner, Mr. Reeve'S, 

maintained at the hearing that the logbooks were off site and effectively unavailable (Tr. 

302~03). Nonetheless, the ipspectors could have been directed to the logbooks- or any 

documents touching on maintenance ~~ then or later. They were not. In these 

circumstances the agency was entitled to presume that neither the logbooks, nor any 

other documents in Respondent's possession or control, contained any information 

tending to absolve Respondent of the discrepancies the inspectors had noted.2 

Maintenance records, as the Administrator often has stated, are the linchpin of 

the agency's enforcement efforts. The agency is permitted to rely on them in determining 

whether required maintenance has been performed. Watts Agricultural Aviation d!b/ a 

Growers Air Service, FAA Order No. 91~8 Quly 5, 1991), pp.15~16, review den. sub. nom. Watts 

2 In a similar vein, see California Helitech, FAA Order No. 2000-IS (August II, 2000), in which the 

Administrator stated that a counterargument that discrepancies asserted by the agency were nonetheless 

within limits "would be an affirmative defense on which [Respondent] would have the burden of proof" (p. 

7, n. I2). 
6 

Agricultural Aviation v. Busey, 977 F.2d 594 (D.C. Cir.1992). The FAA, then, may sustain its 

burden of proving that the required maintenance has not been performed by relying on 

the absence of written maintenance entries. See, e.g., Delaware Skyways, LLC, FAA Order No. 

2005~6 (March 18, 2005). 

2. Section 91.7 

Complainant showed that Respondent violated 14 C.F.R. §9l.7(a) by operating 

the aircraft in an unairworthy condition. 

To be airworthy, inspector Boler testified, an aircraft must 1) conform to its type 

design or properly altered condition and 2) be safe for flight (Tr. 57, 61). This is the 

Administrator's test. See, e.g., Delaware Skyways LLC, FAA Order No. 2005~6 (March 8, 

2005), p. 2; California Helitech, FAA Order No. 2000~ 18 (August 11, 2000), p. 3 n. 7. Both 

parts of the test must be satisfied before an aircraft may be considered airworthy. 

Complainant proved that Respondent's aircraft was not airworthy under either 

prong of the test. As the discussion above concludes, the evidence showed that each of 

the discrepancies caused the aircraft to fail to conform to its type design. That 

circumstance itself created an unairworthy aircraft. Further, three of the four 

discrepancies rendered the aircraft insufficiently safe for flight, thus failing the second, 

independent prong of the test.3 

Respondent acknowledged that its Cessna 206 operated without addressing the 

inspectors' asserted discrepancies. 4 Against this background, I find and conclude that 

Respondent violated section 9L7(a) of the FARs as charged. 

3· . Section 91.13(a) 

I find and conclude that this allegation was· also proved. 

In the absence of extraordinary circumstances, careless or reckless operation of 

an aircraft follows as a residual violation once Complainant has established operation of 

an unairworthy aircraft. Ace Pilot Training, FAA Order No. 2005~12, 2005 WL 2214609 

(August 17, 2005), p. 9; USAir, Inc., FAA Order No. 1992~70 (December 21, 1992), p. 6. The 

record in this case does not show any extraordinary circumstances justifying a finding 

3 Complaina,nt was not required to show that the described conditions were unsafe in fact. It was enough to 

demonstrate that the conditions carried the potential for harm. Polynesian Airways, FAA Order No. 1994-

40 (December 9, 1994); David H. Mayer, FAA Order No. 1997-12 (February 20, 1997). This Complainant 

did so. 4 With one exception. Mr. Reeves testified that he had installed one ofthe two required Cessna-authorized· 

seat stops before the inspectors left the hangar. He also stated that he had installed the second one after 

they left, having told them that he would do so. See Tr. 80-82, 166, 177-79, 295-300, 310. The inspectors, 

however, neither recalled that he had installed a seat stop in their presence nor recalled that he had 

promised to install the second one prior to operating. Mr. Reeves supplied no independent proof, such as 

maintenance records, of his statements or his purported action. The evidence, I fmd, failed to prove either 

of Respondent's claims. 
J 7 

that Oklahoma Skydiving did not violate l4 C.F.R. §9l.l3(a) as well. The evidence in fact 

plainly demonstrates the elements of the violation. It shows that, by operating in the 

face of the inspectors' findings and warnings, Respondent put the safety of its pilots and 

its customers, the skydivers, at unacceptable risk. By its actions Oklahoma Skydiving 

endangered life and property to an unacceptable degree. Complainant thus proved a 

violation of §91.13( a). 

Respondent's principal witness, a pilot and mechanic holding A & P and flight 

engineer certificates, testified that the inspectors' conclusions were incorrect. The 

matters they identified could not properly be labeled as discrepancies, he stated. Nor did 

the alleged discrepancies render the aircraft unairworthy. 

The witness' expertise, however, was limited. Additionally, his conclusions often 

were significantly, if not fatally, qualified. In sum, his testimony was unpersuasive. I 

give it very little weight. It does not appreciably affect my findings and conclusions. I 

discuss the witness' testimony in greater detail below. · 

After the witness asserted that Respondent's seat/rail securement was 

acceptable, he acknowledged that he did not know if it conformed to the aircraft's type 

design (Tr. 243/44). He had not looked at any data (Tr. 263). He also stated that he 

believed that the screw poking through the skin would neither create an imminent 

hazard nor take the aircraft out of its type design (T r. 246, 249); but he acknowledged 

that he had relied only on the photograph in evidence and was not sure what the 

photograph in fact showed. Nor had he consulted the relevant manual (Tr. 249/50). 

Further, after initially asserting that the window repair appeared acceptable (Tr. 252), 

the witness again admitted that he had failed to review the manual; indeed, he did not 

"have enough data to go on right now" (Tr. 255). Nor did he know whether the cracks 

near the rivets presented an imminent flight hazard, because he had not consulted 

relevant manuals (Tr. 256). Indeed, the witness acknowledged that he did not review 

any of the pertinent maintenance manuals (Tr. 270). 

Additional testimony further threw the witness' conclusions into doubt. He 

stated that he has never has__returned a Cessna to service (Tr. 261/62). Indeed, he has 

never looked at a Cessna 206 maintenance manual (Tr. 275). (He has flown one "once or 

twice" (Tr. 234)). The witness did not actually see the alleged discrepancies (Tr. 273). 

Nor did he see the aircraft, let alone inspect it for the conditions cited (Tr. 239). The 

witness did little more than review the Enforcement Investigative Report and study the 

photographs and other exhibits (Tr. 237/41). 

The circumstances surrounding the witness' testimony, I conclude, severely 

undermined its persuasiveness. For that reason I largely discredit it. 

Finally, I reject any notion that the conduct of any of the agency's enforcement 

personnel is germane to any questions under review. Any suggestion that inquiry into 

Complainant's adherence to a guidebook or manual for agency investigators is pertinent 

is rejected. This proceeding is concerned with whether Respondent violated the 

allegations set out in the Complaint. Whether and to what extent any agency 
8 

investigator followed any guidelines simply ~sa distraction.5 

In view of the foregoing, I find and conclude that Respondent violated FAR§§ 

9l.405(a), 91.7(a), and 9l.l3(a) as set out in the Complaint.6 

III. Penalty 

The agency has asked for a total civil penalty of $8,000. It argues that this 

amount is reasonable and justified by the circumstances (Compl. Rebut., p. 27). 

Respondent takes exception. It asks that no violation be found and that no civil penalty 

be assessed (Resp. Br., p.17). 

I conclude that the proof warrants a civil penalty in the amount of $8,000. 

A. Issues 

Complainant is obligated to consider the following factors when determining the 

civil penalty amount: (1) the nature and circumstances of the violation; (2) the extent 

and gravity of the violation; (3) the respondent's degree of culpability; ( 4) the 

. respondent's history of prior violations, if any; (5) the respondent's ability to pay the civil 

penalty; ( 6) the effect on the entity's ability to stay in business; and (7) other matters as 

justice may require. See, e.g., Folsom's Air Service, Inc., FAA Order No. 2008~ 11 (November 6, 

2008), p. 11. The determination weighs whether the violation was inadvertent or 

deliberate, the private or public character of the violation, and the attitude of the 

violator. The agency also considers the respondent's size, particularly in determining the 

offender's ability to absorb the sanction. An appropriate civil penalty must reflect the 

totality of the circumstances surrounding the violations (Tr. 110~ 11, 117; Folsom's Air Service, 

Inc., FAA Order No. 2008~11 (November 6, 2008), p.12; Eastern Air Center, Inc., FAA Order 

No. 2008~3 Qanuary 28, 2008)). A civil penalty should have deterrent as well as punitive 

purposes. CaliforniaHelitech, FAA Order No. 2000~18, (August 11, 2000), p.ll. It should 

provide sufficient incentive to deter the respondent and similarly~situated entities from 

future violations. Folsom's A~r Service, Inc., Id., p. 20. 

The agency has issued enforcement guidelines for its employees to follow in 

recommending appropriate sanctions. The guidelines also advise the public of the 

sanction policy that the Administrator intends to abide by in adjudicating individual 

cases. Folsom's Air Service, Inc., FAA Order No. 2008~ ll (November 6, 2008), p. 13. (A 

relevant excerpt was admitted as Exhibit A~ 2. It is also found at www.airweb.faa.gov ). 

The guidelines set out penalty recommendations within three ranges of amounts -

designated minimum, moderate, and maximum - to best reflect the nature and 

5 I note, moreover, that inspector guidelines in evidence in this proceeding, Order 8900.1, appear to apply 

only to matters in the jurisdiction of the National Transportation Safety Board ("NTSB"). See Exh. R-C; Tr. 

124-26. Respondent also relied on excerpts from Order 8900.1 in its brief. See, e.g., Resp. Br., pp. 13-14. 

The NTSB, of course, is a different agency with a different enforcement framework and responsibilities. 

NTSB materials, while often persuasive, simply are not applicable in FAA proceedings. 6 I have considered all other arguments advanced by Respondent and reject them without comment. 

\ 
,, 9 

circumstances of each violation. Mitigating and/or aggravating factors are also part of 

the calculus. 

Complainant states that its civil penalty determination followed the guidelines 

(Com pl. Br., p. 31; see Exh. A-2). Under them, among other things, an unairworthy 

aircraft having an actual or potential adverse effect on safe operation warrants a civil 

penalty in the moderate-to-maximum range. The agency concluded that, in view of the 

guidelines' recommendations and all the factors pertinent to this case, a civil penalty in 

the amount of $8,000 is justified. 

B. Decision 

In weighing all the facts and circumstances, I find and conclude that a civil 

penalty assessment of $8,000 is appropriate. It is commensurate with the nature and 

extent of the violations, while accounting in suitable measure for mitigating and 

aggravating factors. 

The record shows that Respondent's aircraft was flown approximately 35 times, 

carrying about 100 passengers, over two days without resolving four known 

discrepancies. These actions unnecessarily reduced the aircraft's margin of safety. The 

aircraft was operated continually outside the specifications of its type certificate and in 

an unsafe condition. Moreover, the aircraft was flown in defiance of warnings that it 

was not fit to operate and that operation would unacceptably risk the safety of the pilot 

and skydivers. This circumstance constitutes an aggravating factor in the calculus. The 

aircraft also was flown to be repaired without seeking or obtaining a Special Flight 

Permit required for a ferry flight. While this fact was not cited as a violation, it also 

constitutes an aggravating factor. Respondent's actions, I find, warrant a significant 

penalty. 

The sanction amount of $8,000, I conclude, suitably accounts for the totality of 

the circumstances of this case. It is substantial. It also is within the guidelines' 

moderate-to-maximum range of suggested penalty amounts. I find also that the penalty 

has sufficient "'bite," or deterrent effect. See Toyota Motor Sales, Inc., FAA Order No. 94-28 

(September 30, 1994), p.ll. 

I note also that a civil penalty in the same amount has been levied in roughly 

similar circumstances. Ace Pilot Training, a Part 141 flight school, was assessed a civil 

penalty of $8,000 for operating four aircraft in violation of two FARs: 14 C.ER. §39.3, 

which prohibits operation of aircraft when Airworthiness Directives are incomplete, and 

(as a residual violation) 14 C.F.R. §91.13(a). Ace Pilot Training, FAA Order No. 2005-12 

(August 17, 2005). 
10 

Oklahoma Skydiving Center is hereby assessed a civil penalty of $8,000 for 

violations of FAR §§91.405(a), 91.7(a) and 9l.l3(a) as described in this Initial Decision.

7 

Attachment - Service List 

7 Any appeal from the Initial Decision to the Administrator must be in accordance with section 13.233 of 

the Rules of Practice, which requires 1) that a notice of appeal be filed no later than 10 days (plus an 

additiona15 for mailing) from the date of this order and 2) that the appeal be perfected with a written brief 

or memorandum not later than 50 days (plus 5 for mailing) from the date of this order. Each is to be sent to 

the Appellate Docket Clerk, Room 924-A, Federal Aviation Administration, 800 Independence Avenue, 

S.W., Washington, DC 20591, and to agency counsel. Service upon the presiding judge is optional. 

____________________ ......... .. 
SERVICE LIST 

ORIGINAL & ONE COPY 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building-Suite 2W1000 1 

Bret A Glenn, Respondent's Counsel 

Bret A Glen, Attorney at Law. P.C. 

414 N.W. 4th Street, Suite 200 

Oklahoma City, OK 73102 

TEL: 405-702-4980 

FAJ(: 405-702-4984 

ONE COPY 

Gregory S. Lander, Complainant's Counsel 

Attorney, Safety Enforcement Branch 

Office of the Regional Counsel 

Southwest Region 

Federal Aviation· Administration 

2601 Meacham Blvd., Room 633 

Fort Worth, TX 76137 

TEL: 817-222-5083 

FAJ(: 817-222-5945 

The Honorable Richard C. Goodwin, Administrative Law Judge 

Office ofHearings, M-20 ,, 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E., Room (Ell-310) 

Washington, DC 20590 

TEL: 202-366-2139 Attorney-Advisor 

202-366-5121Staffi Assistant 

F AJ(: 202-366-7536 

FAA Docket No. CP 1 OSW0020 

(Civil Penalty Action) 

1 Service was by U.S. Mail. For service in person or by expedited courier, use the following address: Federal 

Aviation Administration, 800 Independence Avenue, S.W., Wilbur Wright Building-Suite 2W1000, Washington, 

DC 20591; Attention: Hearing Docket Clerk, AGC-430.