U.S. Department 

of Transportation 

Federal Aviation 

Administration 

Office of the Chief Counsel 

CERTIFIED- RETURN RECEIPT REQUESTED 

Hearing Docket Clerk 

FAA, AGC-430, Suite 2Wl000 

Wilbur Wright Building 

800 Independence Avenue, SW 

Washington, DC 20591 

Re: In the Matter of Jenuifer Lauren 

FAA Case No. 20 14S0275046 

Enforcement Division 

Southern Team 

P.O. Box 20636 

Atlanta, Georgia 30320 

( 404) 305-5200 

( 404) 305-5223 FAX 

Enclosed herewith please find a copy of a request for hearing and the original and one copy of the 

Complaint in the above-referenced proceeding. 

The FAA requests that the hearing in this matter be held in the New York, New York area, and 

expects that the hearing will last one day. 

Please address all communications for the FAA to the undersigned, at: 

Federal Aviation Administration 

Enforcement Division, Southern Team 

P. 0. Box 20636, Atlanta, GA 30320 

email: brandon.goldberg@faa.gov 

Telephone: (404) 305-5200 (main) 

s~~ 

BRANDON C. GOLDBERG, Attorney 

Enforcement Division, Southern Team 

P. 0. Box 20636, Atlanta, GA 30320 

email:Brandon.goldberg@faa.gov 

Telephone: (404) 305-5200 (main) 

Enclosures 
ATTORNEYS AT LAW 

700 TWELVE OAKS CENTER DRIVE, SUITE 700, WAYZATA, MN 55391 

TELEPHONE: 952/449-8817 FACSlMlLE: 952/449-0614 

RICHARD BAR 

BRENDAN COLLINS 

STEVEN JOHN FELLMAN 

EDWARD D_ GREENBERG 

KATI-IARlNE FOSTER .MEYER 

DAVID K- MONROE 

TROY A ROLF 

DAVIDP. STREET 

KEITH G. SWIRSKY 

THOMAS W. WILCOX 

CHRJSTOPHERB_ YOUNGER 

SVETLANA V. L YUBCHENKO 

February 2, 2016 

ViA FEDERAL EXPRESS 

Federal Aviation Administration 

600 Independence Avenue, S.W. 

Wilbur Wright Building- Suite 2W1 000 

Washington, DC 20591 

Attn: Docket Clerk, AGC 430 

RE: Jennifer Lauren, Case No. 201480275046 

Dear Sir/Ma'am: 

WASHINGTON, DC OFFICE~ 

l 055 THOMAS JEFFERSON STREET, N\V, SUITE 500 

WASHINGTON, DC 20007-4492 

(T) 202!342-5~00 (F) 202:142-5219 

WRITER'S DiRECT E-MAIL ADDRESS 

n·olf@gkg!aw .com 

WRITER'S DIRECJ' DIAL NUl\.-fBER 

952-449-8817 

I represent Jennifer Lauren in the above-referenced matter, and am in possession of a 

copy of the Final Notice of Proposed Civil Penalty dated as of January 19,2016. On behalf of 

my client, Jennifer Lauren, we hereby request a hearing on this matter. 

cc: Brandan Goldberg 

Attorney 

Sincerely, 

Enforcement Division, Southern Team 

P.O. Box 20636 

Atlanta, GA 30320 

®JINTERLAW, 

An International Association of Independent Law Firms in A1qjor World Centers 
U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

FEDERAL AVIATION ADMINISTRATION, 

Complainant, 

vs. 

JENNIFER LAUREN 

Respondent. 

JUDGE NOT YET ASSIGNED 

FAA Docket No. 

Judge 

COMPLAINT 

"'' ,-, 

•-J '[:j \J) 

The Federal Aviation Administration (FAA), by counsel, hereby files its Complaint, 

pursuant to Rule 208 of the Rules of Practice (14 C.F.R. 13.208), and states as follows: 

I. 

1. On January 19, 2016, Respondent, Jennifer Lauren was advised through a Final 

Notice of Proposed Civil Penalty that the FAA proposed to assess a civil penalty in the amount of 

$23,750.00. On February 2, 2016, the Agency Attorney received a written request for a hearing 

from the Respondent. 

II. 

2. On or about January 6, 2014, you were a passenger on Delta Air Lines Flight #4 77 

from Barcelona, Spain (BCN) to New York, NY (JFK). 

3. During the above-described flight, you assaulted, threatened, intimidated, or 

interfered with a crewmember in the performance of a crewmember' s duties. 

4. Examples ofyour in-flight behavior include (but are not limited to) the following: 

a. You approached a crewmember while screaming about trying to find a friend. 

b. A crewmember asked you to calm down. 

c. You began to crawl on the floor of the aircraft, and said, "Do you think this is 

hysterical?" 
d. You said to a crewmember, "I will fucking kill you." 

e. As a result of your above-described behavior, a crewmember discontinued the 

duties she was performing to block you from the cockpit. 

f. You told another crewmember that you were going to "go ballistic" on her. 

g. You pushed a crewmember, causing her to collide with the back wall of the 

cabin. 

h. You called a crewmember, a "fucking ugly blond bitch." 

1. You called another crewmember a "fat, ugly, unhappy blonde bitch." 

J. When one of the pilots told you to return to your seat, you removed some of 

your outer clothing and told him, "I'm not yelling at you, but you are an 

asshole." 

k. When one of the pilots told you to sit down immediately and follow the safety 

instructions or they would have to divert the plane, you told the pilot: 

1. You didn't care what he did. 

2. Arrest me. 

3. I can't be arrested. 

4. You verbally abused the pilot. 

5. You continued to verbally abuse the cabin crewmembers. 

5. Crewmembers moved at least one other passenger to a different seat due to 

concern for that passenger's safety. 

6. Crewmembers moved you to a different seat due to concern with your being 

seated in the exit row. 

7. The crewmembers had to rearrange their duty stations so that they could sit near 

you to observe you. 

8. As a result of the above, crewmembers were unable to remain in their assigned 

positions. 

9. The captain diverted the flight to Shannon, Ireland (SNN) in order to have you 

removed from the plane. 

10. After touchdown, you yelled out to everyone aboard the plane that you "wanted to 

kill everyone aboard the plane." 

11. In Ireland, you were taken into custody and removed from the plane by local 

authorities. 

12. You were subsequently tried in a local court proceeding, where you plead guilty to 

causing a breach of the peace and to being intoxicated. 
III. 

13. By reason of the foregoing, it appears that Jennifer Lauren failed to comply with the 

following Federal Aviation Regulations: 

a. Section 121.580 of the Federal Aviation Regulations in that no person may 

assault, threaten, intimidate, or interfere with a crewmember in the performance of the 

crewmember's duties aboard an aircraft being operated under this part of the Regulations. 

b. 49 U.S.C. Section 46318 of the United States Code when you physically assaulted 

a crewmember and threatened physical assault against others aboard the flight. 

14. Pursuant to 49 U.S.C. Sections 4630l(a)-(d), Respondent is subject to a civil 

penalty not to exceed $1,100 for each of the violations alleged. 

15. Under the facts and circumstances of this case, a civil penalty of $23, 750 is 

appropriate. 

WHEREFORE, the Agency, by counsel respectfully requests that the Administrative Law 

Judge enter an order that Respondent be assessed a civil penalty in the amount of $23,750. 

Respectfully submitted this \{{h. day of February, 2016. 

BRANDON C. GOLDBERG, Attorney 

Enforcement Division, Southern Team 

P. 0. Box 20636, Atlanta, GA 30320 

email: Brandon.goldberg@faa.gov 

Telephone: (404) 305-5200 (main) 

(404) 305-5230 (direct) 

(404) 305-5223 (fax) 

PLEASE NOTE: 

Pursuant to Title 14 CFR Section 13.209(a), you are required to file a written answer to this 

Complaint, or a written Motion to Dismiss if appropriate, not later than 30 days after the date 

shown on the Certificate of Service which follows. 
CERTIFICATE OF SERVICE 

I hereby certifY that a copy of the foregoing Complaint has been mailed this date by Certified 

Mail, Return Receipt Requested, to the following: 

Hearing Docket Clerk 

FAA, AGC-430, Suite 2Wl000 

Wilbur Wright Building 

800 Independence Avenue, SW 

Washington, DC 20591 

Jennifer Lauren 

6286 N Ventana View Pl. 

Tucson, AZ 85750-0706 

Jennifer Lauren 

35 E 63RD Street 

Apt.3C 

New York, NY 10065 

Troy A. Rolf, Esq. 

700 Twelve Oaks Center Drive, Suite 700 

~~I Program Analyst 

FEB l 0 2016 

Dated 

(original+ 1 copy)