Q7/27/2B11 12:10 ^252271007 ^NM7 PAGE. 01/12 

FACSIMILE MESSAGE 

FEDERAL AVIATION ADMINISTRATION 

OFFICE OF REGIONAL COUNSEL 

ANM-7 

1601 LIND AVENUE S.W. 

RENTON, WASHINGTON 98057 

The inforrriation. contained in this facsimile message is legally privileged and confidential 

information ^md is intended only for the use of the individual named on this cover sheet. 

If the reader of this message is not the intended recipient, you are hereby notified tliat any 

use, dissemination, distribution, or eopy of this facsimile is strictly prohibited. If you 

have received this facsimile in error, please immediately notify us by telephone at 

425-227-2007.' 

DATE: 

TO: 

FAX NO.: 

PHONE NO.: 

RE: 

Motion to Consc 

July 27, 2011 

Judge Goodwin 

202-493-5142 

(lf}/L\j3/t'?9cn^^^-i^-

FAA Case No. 

2011NIVI070021,22,42 

DMS 2011-0484, 0481, 

0489 

lid.^le and Discovery 

NO. PAGES: | including cover 

FROM: 

FAX NO.: 425-227-1007 

PHONE NO.: 425-227-2007 

EMAIL: 

^0(1 ' fNo^ft- Off- i6^y-(* 
D7/27/201 1 12:l e 425227108 7 ANM7 TMGE 02/1 2 

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JEFFREY M. HARPER J'^^AfjyfgT OF 

FAA OFFICE OF REGIONAL COUNSEL ,.- -' ;V^:2-,_-j^J./,^'|j:iJ |,^^ 

1601 LIND AVENUE SOUmrs'EST •-'-'vr'-.u I 'J, l:n.-\I.UisO 

R£>rn:JN. "WASHTNGTON 98057 

TELEPHONE: (425)227-2161 /GiJ JiiL 2'"-i P i^ ^4 2 

FACSI>ro,E: (425) 227-1007 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

FA.A. Docket No. Unassigaed 

F.AA Case No. 20nNM07002I 

DMS No. FA.A.-2011 -0484 

In the Matter of: 

Cornerstone Aviation, Inc. 

FAA Docket No. Unassigned 

FA.\ Case No. 2011NM070022 

DMSNO.F.AA-2011-04SI 

FAA Docket No. Unassigned 

FA.A. Case No. 2011NIVTO70042 

DMS No. FA.A.-2011-0489 

Judge Richard C. Goodwin 

TO: Honorable Richard C. Goodwin: 

MOTION TO CONSOLIDATE 

Complainant, through his undersigned counsel, pursuant to Rules of Practice 13.205(a) and 

13.21 S(a), seeks to consolidate these cases for hearing. 

The complaint in DMS No. FAA-2011-0481 was served on May 18, 2011. On July 20, 2011 the 

Administrative Law Judge (AU) entered an amended procedural order in the case stating that the 

parties should be prepared to hold the hearing on or ai^er October 21, 2011 in Salt Lake City, Utah. 

The complaint in DMS No. FAA-2011 -0484 was sensed on May 25, 2011. On July 20, 2011 the 

ALJ entered a procedural order in tlae case stating that the parties should be prepared to hold the 

hearing onor after October 21, 2011. 

The complaint in DMS No. FA.\-20] ] -0489 was scr\'ed on June 16,2011. On .July 20, 2011 the 

A U entered a procedural order in tiie case stating that the parties should be prepared to hold the 

hearing on or ^e r October 21, 2011. 

In each case, the procedural orders stated that venue would be in Salt Lake Cit>', Utah. 

Each complaint alleges similar violations of the Federal Aviation Regulations, specifically, 

violations of Part 141 -Pilot Schools relating to the accuracy of required records and 

conipJjTng with the Respondent's approved course of training. Undersigned counsel 

Motion to Consolidme JEFTREYM. FUjlPER, FAA .ATTORNEY 

Comersionc Aviation, Inc. •. TBI.: (425) 227-216]; FAX: (425) 227-1007 

¥.\A Cast. Nos. 20I1NM070021. 201INN-TOTOO^^, aod 2011NM070042 

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believes that there will be significant overlap of the witness testifying in these cases. 

Accordingly.judicial economy would be realized by consolidating these cases. 

Undersigned counsel has corresponded with Cornerstone's representative, Susan HorstraaiL 

regarding this motion. She has indicated Cornerstone has no objection to consolidating 

these cases. 

Complainant respectftiJly requests that the AL.i enter an order consolidating these cases for 

a single hearing. 

Dated tlnis .27th day of July, 20) 1. 

Je*&cy M. Harper 

F.'\A Attocney 

Morion to Ccnsolidaic 

Cornerstone .A.nation. Inc. 

FAA Car.e NtPS- 2011NM070021. 201 INM070022, and 201 INMOTOO'l^ 

Page 2 of J 

JEFRRTY H HARPER, FA.A ATTORNEY 

TCL. (-(25} 227-2/61; FAX; (425> 227-1007 
C17/27/2011 12:1 0 4252271Q07 vt,jM7 F"GE 04/1 2 

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CERTTFICATE OF SERVICE 

I hereby certify that the foregoing Motion to Consolidate has been served \i3 facsimile and 

Certified Mail - Return Receipt Requested this date, to the following: 

The Honorable Richard C. Goodwin 

Office of hearings, M-20 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor. Rm El 2-320 

Washineton- D.C. 20590 

TEL: (202) 366-2139 

FAX: (202) 366-7536 

Attn: Hearing Docket.Clerk, A.GC-430 

Wilbur Wright Building - Suite 2W1000 

Federal Aviation Administration. 

800 Independence Ave. SW. 

Washington, DC 20591 

F.\X: (202) 493-5142 . 

Susan Horstman 

Chief Executive Officer 

Cornerstone Aviation, Inc. 

337Nor1h 2370 West ?^130 

Salt Lake Citv. UT 84116 

TEL: (801)355-2244 

F.^X-.(80() 355-2754 

DATED this 27th day of July, 2011. 

MOIFAIR CHIN 

Office of Regional Counsel (ANM-7) 

Federal Aviation Administration 

1601 LindAve. SW 

Ronton; WA 98057 

(425 227-2160 • • 

Mpn'pn to Consolidate TIT..-^^. „ x i Tf 

n ^ • . JEPTT^VM.R^PJStF.AA ATTORNEY 

r-i. ^ ^. ^ •''•' • it.1-'(''25;227-21o ;F.-'vX'(•42>t 227-1007 

FAA Case Kos. 201 lNT.fO70021. 2011NM070022. and 2011X^07004-? 

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JEFFREY M. HARPER 

FAA OFFICE OF REGIONAL COUNSEL 

1601 LiND A VHNUE SOUTHWEST 

RENTON, WASHINGTON 98057 

TELEPHONE: (425)227-2161 

FACS.1MILE: (425) 227-1007 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARESGS 

WASHINGTON, D.C. 

FAA Case No. 20nNM070021 

DMS No. F.AA-2011-0484 

In the Matter of: 

Cornerstone Aviation, Inc. 

FAA Case No. 2011NM070022 

DMS No. FAA-2011-04S1 

F.\A Case No. 2011NM070042 

DMS No. FAA-2011-0489 

Judge Richard C Goodwin 

COMPL.4JNANT^S PaXJAL PJSCOVERY REQUEST 

To: Respondent 

In accordance -with.14 C.F.R. § 13.220 and the Federal Rules of Civil Procedure, please respond to 

the following Interrogatories. Requests for Production of Documents, and Request for Admissions, 

separately and ftilly under oath by August 26,2011. 

These discovery requests are intended to discover information and/or documeots not only within 

your personal knowledge or obtainable by you, but also information in the possession of or 

obtainable by your attorneys, investigators, representatives, employees, agents, or anyone acting on 

your behalf or on their behalf. 

These discovery- requests axe continuing in nature and any information winch may be discovered by 

you subsequent to the service and filing of your answers must be brought to the attention of the 

agency attotney through supplemental answers when it becotues available to you, at a reasonable 

time prior to the hearing in this matter. If there are any additions, deletions or .changes in the 

answers or information provided at any time prior to hearing the Respondent is specifically 

requested.to 50 immediately inform the agency attorney. If such information is not furnished, tbc 

agency attorney at the time of the hearing will move to exclude from eWdence such 

infonreiafion requested and not furnished. 

Ccinplaiii2nl\'; Iniiinl Discovery Request 

Comersionc Aviation. Inc. - 2011NMO7O02I, 

2011NM070022, 201INM070042 

Fa£c I of6 

JEFFREY M. R\R.t^. F.^-^ ATTORNEY 

TEL: (425) 227-2] 61; FAJC: (425) 227.J007 
G7/27/2Q11 12:16 d25?271pig7 ANM7 PAGE g&/12 

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Tlie agency attorney further requests that the Respondent produce the documents identified and 

designated herein for inspection and copying at the Federal Aviation Administration (PAA) Office 

of Regional Counsel, Suite 570, 1601 Lind Avenue, Soutliwest, Renton, Washington 98057, by 

August 26, 2011. 

SHOULD YOU FATL TO ANSWER THESE DISCOVERY REQUESTS, 

AGENCY COUNSEL WILL MOVE TO COMPEL DISCOVERY. 

FAILURE TO COMPLY WITH YOUR DISCOVERY OBLIGATIONS CAN RESULT IN 

PRECLUSION OF INFORAL4TION YOU WISH TO PRESENT AT A HEARING. 

PRTVILEGE 

If, in responding to, or failing to respond to these hnterrogatories, Requests for Adniission and 

Requests for Production you invoke or rely upon any privilege of any kind, state specifically the 

nature of the privilege; the basis upon which you invoke, rely upon, or claim it, including any 

statutory or decisional reference; and identify all documents or other information, including 

contacts and communications, which you believe to be embraced by the privilege invoked. . 

DATED this 27th day of July, 2011, 

Jo&ey M. Harper 

FAA Attorney 

Corap lain ant's Inilial Di?eovcr>' Request 

Comersiptie Aviation, Inc. -2011NM070021, 

2011KM070022. 2011NM070042 

JEFFREY H . HARPER. FA.A ATTORNEV 

TEL: (425) 227-2161: F.-^; (425) 227-1007 \ 
B7/27/2011 12:10 4252271007 

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AI'iM7 

INTERROGATORIES 

PAGE 07/12 

htterrogatorv No. 1: Identify by name, address, and telephone number all persons whom you knowto have personal knowledge of the matters alleged in Hie Complaint. 

Inten-ogatorv No. 2: Identify by title, date, author, preseut custodian, and content, all documents, 

including correspondence, obtained by you or in your possession, relating to tiie assertions hi the 

Complaint, your appeal, your answer, and any affirmative defenses which you anticipate raising in 

this matter. See Request for Production No. 1. 

Interrogatoiy No. 3: Identify by name, address and telephone number, all persons whom you intend 

to have testily as a factual or expert witness in your defense at the hearing in this matter, and for 

factual witnesses, provide a detailed summarv^ of each person's anticipated testimony. 

Interrogator^' No. 4: Identify by tide, date, author, present custodian, and content, all documents 

which you anticipate offering into evidence at the heari.ng in this matter, and through wlijch v^dtness 

or witnesses. See Request for Production No. 2. 

Interrogatory No. 5: Witli respect to each expert uitness identified in response to Intemogatory 

No. 3. specify' thek specific area of expertise^ and pro-vide a synopsis of tlieir credentials, 

backgroimd, training, and experience. 

Interrogaton^ No. 6: With respect to each expert you expect to call as a witness, state the subject 

matter on which the expert is expected to testify, state the substance, of the facts and opinions to 

which the expert is expected to testify, and provide summary of the grounds for each such opinion. 

IhtenrogatorvNo. 7: Describe "\\ith specificity all of the facts which you anticipate presenting in the 

course of the hearing in this matter pertaining to the avoidance or mitigation of the sanction souglit 

Mr. Michaelby the FAA in this case. 

Interrogator^No. 8: State by name, address, telephone number, date of conversation, and substance 

of conversation, all persons, other than legal counsel or your spouse, with whom you have 

discussed the matters alleged in the Complaint. 

Intenrogatorv No. 9: Describe with specificity all facts or evidence you intend to rely upon in 

support of any affirmative defenses raised in any Answer to the Complaint. 

REQUESTS FOR PRODUCTION 

Request for Production No. 1: Provide a copy of all documents referred to in your answer to 

.Interrogatory No. 2. 

Request for Production No. 2: Provide a copy of all documents refenred to in your answer to 

Interrogatoiy No. 4. 

Request for Production No. 3: Provide a copy of ail documents that support your answer to 

Interrogatory No. 9. 

Request for Production No. 4: Provide a copy of all exhibits that you intend to offer or -will use 

during the bearing m this matter. 

Complainant's Initial Discovery Request 

Comastone A\-iation, Inc. - 2011NM07002 K 

2011NM070022, 201 ^^fM0700•i2 

Page 3 of 6 

JEFFREY M R'^Rrcr., FAA ATTQRNEV 

TEL: (425) 227-2161; FAX: (425) 227-1007 
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REQUEST FOR ADMISSIONS 

Under 14 C.F.R. § 13.220(h) and Rule 36 of the Federal Rules of Civil Procedure, you are requested 

to admit the truth of tiie following matters. A matter is admitted tmless responded to in a reasonable 

time. The Rules of Practice in FAA Civil Penalty Actions, 14 C.F.R- § 13.220(d), defines a 

reasonable time to be 30 days. The agency requests that an answer is served upon the agency 

attorney either admitting the matter, specifically denying the matter, stating why tlie matter cannot 

be atimitted or denied^ or objecting to the request with reasons for the objection stated within 30 

days of the date of service upon you, that is, August 26,2011. 

I F YO U FAIL TO RESPOND TO THESE REQUESTS FOR ADMISSIONS IN WRITING, 

THE FACTS CONTAINED THEREIN ARE DEEMED ADMITTED, ABSENT A JUDGE'S 

RULING THAT YOUR FAaURE TO ANSWER WAS DUE TO CIRCUMST-AJVCES 

BEYOND YOUR CONTROL. See 14 C.F.R. § 13.220(])(t). 

Request for Admission No. 1: Admit that the Jeppesen Sanderson. Inc. Instrument / Commercial 

Course Syllabus includes a Pilot Record Folder to use for tracking pilot traming that complies witii 

die recordkeeping requirements of 14 C.F.R. Part 141. 

Request for Admission No. 2: Admit that Cornerstone Aviation, Inc. (Cornerstone) uses tlie 

Jeppesen Sanderson, Inc. Instrument / Commercial Pilot Record Folder to maintain its Part 141 

records for Instrument / Commercial students. 

Request for AdmissionNo. 3: Admit that Ms. Haley A. ^^^dson was enrolled in Comerstone's 

Instrument-Airplane course of training on .Tune 10, 2010. 

Request for Admission No. 4: Admit that Ms. Haley A. W^ilson's Cornerstone part 141 

Instrument / Comniercial Pilot Record folder shows "0" hours credit for pre\'ious ground training. 

Request for Admission No, 5: Admit that Ms. Haley A. Wilson did not receive any credit for 

previous training under 14 C.F.R. § 141.77(c). 

Request for AdmissionNo. 6: Admit that Ms. Haley A. Wilson received ground training ffom 

Utah Valley Uuiversit>', Utah. 

Request for Admission No. 7: .Admit that Utali Valley University* is not a certificated pilot school 

imder 14 C.F.R. Part 141. 

Request for Admission No- 8: Admit that Mr. N^tichael Staim began training for the Instrument / 

Commercial Course on or about August 25, 2010. 

Request for Admission No. 9: Admit that Michael Stann's Part 141 pilot training records for his 

Au^st 25, 2010 Instrument / Commercial Course enrollment show be received flight training for 

the histrument / Commercial Course on September 18,2010. . 

Complainant-5 [niuai Discovco' Request 

Cornerstone .M'iaiion, Inc. - 20UNM07002I. 

2011NM070022.2011NM070042 

Page 4 of 6 

.TEFFRE~1- M . HARPEK, FA-A. ATTORt>'ET 

TEL. (425) 227-2161; FAX: (425) 227-1007 
07/27/2011 12:10 4252271007 ANM7 PAGE 09/12 

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Request for Admission No. 10: Admit that Mr. Michael Stann's Part 141 pilot training records for 

his August 25, 2010 Instrument / Commercial Course enrollment show he received flight training 

for the Instrument / Commercial Course on September 21, 2010. 

Request for Admission No. 11: Admit that Mr. Michael Stann's Part 141 pilot training records for 

his August 25, 2010 Instrument / Commercial Course enrollment show he received flight training 

for the Instrument / Commercial Course on September 28; 2010. 

Request for Admission No. 12: Admit that Mr. Michael Stann's Part 141 pilot training records for 

bis August 25, 2010 Instrument / Commercial Course enrollment show he received flight training 

for the Instrument / Commercial Course on September 30, 2010. 

Request for Admission No. 13: Admit that Mr, Michael Stann's Part 141 pilot training records for 

his August 25,2010 Instrument / Commercial Course enrollment show he received flight training 

for the Instrument / Commercial Course on October 5,2010. 

Request for Admission No. 14: .A-dmit that Mr. Michael Stann's Part 141 pilot training records for 

his August 25^ 2010 Instrument / Commercial Course enrollment show he received flight training 

for the Instrument / Commercial Course on October 9, 2010. 

Request for Admission No. 15: Admit tiiat Mr. Michael Stann's Part 141 pilot training records for 

his August 25, 2010 Instrument / Cominercial Course enrollment show he received flight training 

for the hstrument / Commercial Course on October 12, 2010. 

Request for Admission No. 16: Admit that Mr. Michael Stann's training for the Instrument / 

Commercial was restarted on or about October 21, 2010. 

Request for Adniission No. 17: Admit that Cornerstone has two Pilot Record Folders for Mr. 

Michael Stann's Instrument / Commercial trainjns. 

Complainant's Initial Discovery Request 

Comerstont Aviation, be. - 2011NM070021; 

2011NM07007.2. 2011KM070042 

Page 5 of 6 

JEFFKEY M. K-VKPER, F.AA ATTORN'EY 

TEL- (425) :27-2161; FAX: (425) 227-1007 
07/27/2011 12:10 (1252271007 ANM7 PAGE 10/12 

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CERTIFICATB O F SERVICE 

I hereby certify fliat tlie foregoing Complainant's Initial Discover>- Request has been served via 

facsijnile and Certified Mail - Return Receipt Requested this date, to the following: 

Honorable Richard C. Goodwin 

Office of hearings, M-20 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor, Rm 812-320 

Washington, D.C 20590 

FAX: 202.366.7536 

Atm: Hearing Docket Clerk. AGC-430 

Wilbur Wright Building - Suite 2W1000 

Federal Aviation Administration 

800 Independence Avenue SW 

Wasliington. D.C. 20591 

.FAX; 202.493.5020 

Susan Horstman 

Clijef Executive Officer 

Cornerstone Aviation, Inc, 

337 Nortli 2370 West #130 

Salt Lake City, UT S4116 

FAX: (801) 355-2754 

Tlh Dated this 27'^,day of July, 2011. 

MOIF.'MR CHIN 

Office of RegionaJ Counsel (.'\NM-7) 

Federal Aviation Administration 

1601 Lind Ave. SW 

Renton-WA 98057 

425.227.2160 

Complaiaanfs Initial Discover,' Reqne:;! 

Comerfion': Aviation. Inc.-20nNMn7n021. 

20n>n^'1070O22. 20UNM070042 

page 6 of6 

JEFTOEV M, HARPER. F.-VA .A.TTOR.NHy 

TEL: (425) 227-2161; FAX. (425)227-1007 
07/27/2011 12:11 4252271007 ANH7 PAGE 11/12 

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JEFFRI^YM. HARPER 

F.AA OpncE OF REGIONAL COUNSEL 

1601 LtKD AVENUE SOUTI-TOTSST 

RENTON, WASHTNGTON 98057 

TELEPHO-NE: (425)227-2161 

FACSIMILE: (425) 227-1007 

UNITED STATES OF AMERIC A 

DEPARTIVIENT O F TRANSPORTATION 

OFFICE O F HEARINGS 

WASHINGTON, D.C, 

FAA Case No. 2011NM070021 

DMS No. FA,V2011-0484 

Tn the Matter of: 

Cornerstone Aviation, Inc. 

FAA Case No. 2011NM070022 

DMS No. F.AA-2011-0481 

FAA. Case No. 20UNM070042 

DMS No. FAA-2011-0489 

Judge Richard C. Goodwin 

COMPLAIN.VNT'S INITIAL DISCOVERY RESPONSE 

To: Respondent 

In accordance with 14 C.F.R. § 13.220 and die Federal Rules of Civil Procedure (FRCP), enclosed 

is the Administrator's initial response to your discover}' requests contained within your answers to 

the complaints in these casesIn each instance, you requested that I send you "a complete 'Discovery' of the material the Federal 

Aviation Administration (F.AA) has obtained on all my violations." I am interpreting your request as 

a "Request tor Production of Documents" as described in 14 C.F.R. § 13.220(b) and FRCP 

34(1)(A). If ^at interpretation is in error, please let me know as soon as possible. 

Enclosed is a complete copy of the documentary evidence currentiy ^Wthin tiie custody and control 

of the FAA, by FAA case number. Not included are copies of e-correspondence between the two 

parties subsequent to the issuance of the Notices of Proposed Civil Penalties and the pleadings in 

tiiese cases. 

DATED this27'*' day of July 2011. 

f&ey M. I-Iarper 

FAA Attorney 

Complainant's Initial Discoven' Response 

Coma-ptonc Aviation, Inc. - 201 INMOTOOSl, 

2011 N"M070n22, 2011NM070042 

Page 1 of2 

JEFTvREY M. HARPE?^ F.AA AT^OR^'EY 

TEL: (425) 227-2161; F.^X: (425) 227-1007 
07/27/2011 • 12:10 4252271007 ANM7 PAGE 12/12 

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CERTIFICATE O F SERVICE 

I hereby certify that the foregoing Complainant's hnitial Discovery Request has been sensed via 

facshnile and Certified Mail -" Return Receipt Requested this date, to the following: 

Susan Horstman 

Chief Executive Officer 

Cornerstone Aviation. Inc. 

337 North 2370 West #130 

Salt Lake Cvt>',UT 84116 

TEL: (801)355-2244 

FAX". (801) 355-2754 

Dated tliis 27th, day of July, 2011. 

MOIFAIJK CHIN 

Office of Regional Counsel (AKN^-7) 

Federal Aviation Administration 

1601 LindAve. SW. 

Renton, WA 98057 

425.227.2160 

Complainant's Initial Discover^' Response 

Coirirslionc .A-viatinn, Inc. - 2aUNM070021. 

2011NM070022, 201 lM^'fn70042 

Page 2 of 2 

JEFFREY M. HARPER, FA A ATTORNEY 

TEL: (425) 227-2161: FAX; (425) 227-1007