U.S. Department ofTransportation

Federal Aviation Administration Office of the Chief Counsel

CERTIFIED- RETURN RECEIPT REQUESTED Hearing Docket Clerk FAA, AGC-430, Suite 2Wl000 Wilbur WrightBuilding 800 Independence Avenue, SW Washington, DC 20591 Re: Inthe Matter ofJenuifer Lauren FAA Case No. 2014S0275046 Enforcement Division Southern Team P.O. Box 20636 Atlanta, Georgia 30320 (404) 305-5200 (404) 305-5223 FAX

Enclosed herewithplease find a copy ofa request for hearing andthe original and one copy ofthe Complaint inthe above-referenced proceeding. The FAA requests that the hearing in this matter be held in the New York, New York area, and expects thatthe hearing will last one day. Please address all communications for the FAAto 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)

EnclosuresATTORNEYS AT LAW 700TWELVEOAKS CENTERDRIVE, SUITE 700, WAYZATA, MN 55391 TELEPHONE: 952/449-8817 FACSlMlLE: 952/449-0614

RICHARD BAR BRENDAN COLLINS STEVEN JOHN FELLMAN EDWARDD_ 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 2W1000 Washington, DC 20591 Attn: Docket Clerk, AGC 430 RE: JenniferLauren, CaseNo. 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'DIALNUl\.-fBER 952-449-8817

I represent Jennifer Lauren inthe above-referenced matter, and am inpossession ofa copy ofthe Final Notice ofProposed Civil Penalty dated as ofJanuary 19,2016. On behalfof my client, Jennifer Lauren, we hereby request a hearing on this matter.

cc: Brandan Goldberg Attorney Sincerely,

EnforcementDivision, Southern Team P.O. Box 20636 Atlanta, GA 30320 

### ®JINTERLAW, AnInternationalAssociation of IndependentLaw Firms in A1qjor World CentersU.S. DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS FEDERAL AVIATIONADMINISTRATION

FEDERAL AVIATION ADMINISTRATION, Complainant,

vs. JENNIFERLAUREN Respondent.

JUDGE NOT YETASSIGNED FAA Docket No. Judge

COMPLAINT "'' ,-, •-J '[:j \J)

The Federal Aviation Administration (FAA), by counsel, hereby files its Complaint, pursuant to Rule 208 ofthe Rules ofPractice (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 ofProposed Civil Penaltythat the FAAproposed to assess a civil penalty inthe 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 DeltaAirLines Flight #477 from Barcelona, Spain (BCN) to New York, NY (JFK). 3. During the above-described flight, you assaulted, threatened, intimidated, or interfered with a crewmemberin the performance ofa crewmember's duties. 4. Examples ofyourin-flight behavior include (but are not limited to) the following:

a. You approached a crewmemberwhile screaming about trying to find a friend. b. A crewmember asked you to calm down. c. You began to crawl onthe floor ofthe aircraft, and said, "Do you 

### think this is hysterical?"d. You saidto a crewmember, "I will fucking kill you." e. As a result ofyour above-describedbehavior, a crewmember discontinued the duties she was performingto block you from the cockpit. f. Youtold another crewmember that you were going to "go ballistic" onher. g. Youpushed a crewmember, causing her to collide with the back wall ofthe cabin. h. You called a crewmember, a "fuckingugly blondbitch." 1. You called another crewmember a "fat, ugly, unhappy blonde bitch." J. When one ofthe pilots toldyou to return to your seat, you removed some of your outer clothing and told him, "I'mnot yelling at you, butyou are an asshole." k. When one ofthe pilots toldyou to sit down immediately and follow the safety instructions or they would have to divert the plane, you told thepilot: 1. You didn't care whathe did. 2. Arrest me. 3. I can'tbe arrested. 4. You verbally abused the pilot. 5. You continued to verbally abuse the cabin crewmembers. 5. Crewmembers moved at least one otherpassengerto a different seat due to concern for thatpassenger'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 youto observe you. 8. As a result ofthe above, crewmembers were unable to remain in their assigned positions. 9. The captain diverted the flight to Shannon, Ireland (SNN) in orderto have you removed from the plane. 10. After touchdown, you yelled out to everyone aboard the plane that you "wantedto kill everyone aboard the plane." 11. InIreland, you were taken into custody and removed from the plane bylocal authorities. 12. You were subsequently tried in a local courtproceeding, where youplead guilty to causing a breach ofthe peace and to being intoxicated.III. 

### 13. By reason ofthe 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 ofthe Regulations. b. 49 U.S.C. Section 46318 ofthe United States Code whenyou 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 ofthe 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 ofFebruary, 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 ifappropriate, not later than 30 days after the date shown onthe Certificate ofService which follows.CERTIFICATE OF SERVICE I hereby certifY that a copy ofthe 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 JenniferLauren 6286 N Ventana ViewPl. Tucson, AZ 85750-0706 Jennifer Lauren 35 E 63RD Street Apt.3C NewYork, NY 10065 Troy A. Rolf, Esq. 700 Twelve Oaks Center Drive, Suite 700

# ~~I Program Analyst 

## FEB l 0 2016 Dated (original+ 1copy)