06/13/2011 10:15 FAX 3107256816 AWP-7 21002 

< S ^ 

U.S, Department 

of Transportation 

Federal Aviation 

Administration 

JUN 1 3 2011 

Western-Pacific Region 

Office of the Regional Counsel 

P.O. Box 92007 

Los Angeles, C A, 90009-2007 

Telephone: (310) 725-7117 

Facsimile; (310)725-6816 

CERTIFffiD MAIL - RETURN RECEIPT REQUESTED and FACSrMTLE 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building - Suite 2W1000 

, - -• > 

Re: In the Matter of K.S. Aviation, Inc. d/b/a Sierra Academy of Aeronautics: 

CaseNo.2oiiwpnooo9/j^oil-i\ooA--C^ I5(.Y5 j^Dr^^H ' ^V^^i 

Enclosed is a copy of a request for hearing dated June 2, 2011, and the original and one copy 

of the Complaint in the above-referenced proceeding. 

I request that the hearing in this matter be held in the Los Angeles, California area., and 

expect that the hearing will last one (1) day. 

Please address all commtmications for the Regional Counsel of the Western-Pacific Region, 

to the undersigned, at: Office of the Regional Counsel, AWP-7.6, Federal Aviation 

Administration, Western-Pacific Region, P. O. Box 92007, Los Angeles, CA 900Ci9-2007, 

Telephone: (310) 725-7117, FAX: (310)725-6816. 

Sincerely, 

NAOMI TSUDA 

Regional Counsel 

By: ..yr^^<9La7yu'^-^.,/&^^p&-—' 

Lierre Green 

Attorney 

Enclosures: Request for Hearing; Complaint; Certificate of Service 

NOTE TO RESPONDENT: SECTION 13.209 OF THE CP RULES OF PRACTICE 

REQUIRE THAT A WRITTEN ANSWER TO THE COMPLAINT BE FILED NOT 

LATER THAN 30 DAYS AFTER SERVICE OF THE COMPLAINT. AS AN 

ALTERNATIVE TO FILING AN ANSWER, A MOTION MAY BE FILED PURSUANT 

TO SECTION 13.208(D) OR SECTION 13.2]8(F)(l-4) OF THE RULES OF PR/\CTICE. 
06/13/2011 10:15 FAX 3107256816 AWP-7 

121003 

CYRIL LAWRENCE, INC. 

A PROFESSIONAJ, LAW COR?DILATION 

211.1 "K" Street 

CYRIL L, LAWR£NCF. Merced, Caiiforeia 95340 ccrtifiai spcdMifi - TI^L.TM 

' Slate Bar pfCiimonHa . 

Telephone (209) 383-6854 Facsimile (209) 383-6856 

Email Address; lawoffice@cyrlllawrence.com 

Board of Legal Specialiiiiion 

June 2, 2011 

Federal Aviation Administration 

Attention; Hearing Docket Clerk, AGC-430 

Wilbur Wright iBuilding - Room 2W1000 

800 Independence Avenue, SW 

Washington, DC 20591 

Re: K.S. Aviation, Inc. dba Sierra Academy of Aeronautics 

Notice of Proposed Civil Penalty (14 C.F.R. 13.16) 

Case No: 201IWPI70OO9 

Our File No: 37-19 

Gentlemen: 

This office represents K.S. Aviation, Inc. in connection with the Final Notict: of Proposed 

Civil Penalty, a copy of which is attached, proposing a civil penalty for the violations alleged. 

K.S. Aviation, Inc. hereby requests a hearing in accordance with Subpart G of Part 13 of tlie 

Federal Aviation Regulations with the understanding that a Complaint will be filed. I request 

that the hearing be held in Fresno, California to determine the reasonableness of the proposed 

civil penalty under the facts and circumstances i:)f the infraction under Title 49 U.S.(\ section 

46301. 

I am sending this request both to the Federal Aviation Administration at the :ibove 

address, and to the Federal Aviation attoniey Lierre M. Green, P.O. Box 92007, Los Angeles, 

California 90009-2007. I request that all future documents in this case be sent to the 

'ondersigned. 

Very truly yours, 

CYRIL LAWRENCE, INC. 

A Professional Law Corporation 

By: 

'ni L. Lawrence 

CLL/af 

Lnclosure 

cc: L. Green 

Sierra Academy of Aeronautics 
06/13/201 1 10:1 5 FAX 310725681 6 AyVP-7 0004 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, DC 

In the Matter of K.S. Aviation, Inc. 

d/b/a Sierria Academy of Aeronautics, FAA DOCKET UNASSIGISED 

FAACASENO. 201 IWPl 70009 

Respondent. 

JUDGE NOT iASSIGNED 

COMPLAINT 

The Complainant files its Complaint, pursuant to Rule 208 of the Rules of Practice 

(14 C.F.R. 13.208), and states as follows: 

Respondent, K.S. Aviation, Inc. d/b/a Sierra Academy of Aeronautics (KS), was 

advised through a Final Notice of Proposed Civil Penalty, dated May 31,2011, that the 

Federal Aviatibn Administration (FAA) propi)sed to assess a civil penalty in the amount of 

$30^000.00. Ojn June 2, 2011, Respondent submitted a written request for a hearing. 

II. 

1. Resporident now, and at all times was, the holder of Air Agency Certificiite No. 

SRJS020K, authorizing it to operate a pilot school under Part 141 of the Federal 

Aviatioli Regulations. 

2. At all relevant times. Respondent was the owner and operator of a Cessna model 

152 aircraft. Civil Registration No. N4932P. 
06/13/2011 10:15 FAX 3107256816 AWP-7 ^^^ ^ 

3. Between June 1, 2009 and February 8, 2011, Respondent operated N4'>32P on 

approximately 1084 flights without an effective U.S. registration certificate 

issued!to its owner. 

III. 

By reason of the foregoing facts and circumstances. Respondent violated the folk'wing 

sections of the Federal Aviation Regulations (Title 14, Code of Federal Regulafiois): 

91-203(a)(2), which states that except as provided in § 91.715, no person may 

operate a civil aircraft unless it has within it the following: an effective U.S. 

registration certificate issued to its owner or, for operations within the United 

States, the second duplicate copy (pink) of the Aircraft Regi:3tration 

Application as provided for in § 47.31(b), or a registration certificate issued 

under the laws of a foreign country. 

IV. 

1. Pursuant to Title 49 U.S.C. Section 46301(a)(1)(A), Respondent is subject to 

a civil penalty not to exceed $25,000.00 for each of the violations alleged. 

2. Under the facts and circumstances of this case, a civil penalty of $30,000.00 

is appropriate. 
06/13/201 1 10:1 5 FAX 3107256816 AWP-7 Sl006 

WHEREFORE, the Complainant, respectfully requests that the Administrative Law 

Judge enter an order that Respondent be assessed a civil penalty in the amount of $30,000.00 

Respectfully submitted. 

<i»»u 

Lierre Green 

Attorney 

Office of the Regional Counsel 

Federal Aviation Administration 

Western-Pacific Region 

DATED: JUN 1 3 2011 

cc: FAT FSDO/AWP-230 
06/13/2011 10:15 FAX 3107256816 AWP-7 il007 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, DC 

In the Matter of K.S. Aviation, Inc. 

d/b/a Sierra Academy of Aeronautics, FAA DOCKET UNASSIGlSfED 

FAACASENO. 2011WP170009 

Respondent. 

JUDGE NOT ASSIGNED 

COMPLAINT 

The Complainant files its Complaint, pursuant to Rule 208 of the Rules of Practice 

(14 C.F.R. 13.208), and states as follows: 

I. 

Respondent, K.S, Aviation, Inc. d/b/a Sierra Academy of Aeronautics (KS), was 

advised through a Final Notice of Proposed Civil Penalty, dated May 31, 2011, that the 

Federal Aviation Administration (FAA) proposed to assess a civil penalty in the amount of 

$30,000.00. On June 2, 2011, Respondent submitted a written request for a hearing. 

II. 

1. Respondent now, and at all times was, the holder of Air Agency Certificate No. 

SRJS020K, authorizing it to operate a pilot school under Part 141 of the Federal 

Aviation Regulations. 

2. At all relevant times, Respondent was the owner and operator of a Cessna model 

152 aircraft, Civil Registration No. N4932P. 
06/13/201 1 10:1 5 FAX 3107256816 AWP-7 "SlOOS 

3. Between .June 1, 2009 and Febmary 8, 2011, Respondent operated N4932P on 

approximately 1084 flights without an effective U.S. registration certificate 

issued to its owner. 

III. 

By reason of the foregoing facts and circumstances. Respondent violated the following 

sections of the Federal Aviation Regulations (Title 14, Code of Federal Regulatio is): 

91.203(a)(2), which states that except as provided in § 91.715, no person may 

operate a civil aircraft unless it has within it tlie follovang: an effective U.S. 

registration certificate issued to its owner or, for operations within the United 

States, the second duplicate copy (pink) of the Aircraft Registration 

Application as provided for in § 47.31(b), or a registration certificate issued 

under the laws of a foreign country. 

IV. 

1. Pursuant to Title 49 U.S.C. Section 46301(a)(1)(A), Respondent is oubject to 

a civil penalty not to exceed $25,000.00 for each of the violations alleged. 

2. Under the facts and circumstances of this case, a civil penalty of $30,000.00 

is appropriate. 
06/13/2011 10:15 FAX 3107256816 AWP-7 ISlOOg 

WHEREFORE, the Complainant, respectfully requests that the Administative Law 

Judge enter an order that Respondent be assessed a civil penalty in tlie amount of $30,000.00 

Respectfully submitted. 

(lG7>^^ 

Lierre Green 

Attorney 

Office of the Regional Counsel 

Federal Aviation Administration 

Western-Pacific Region 

DATED: JUN 1 3 2011 

cc: FAT FSDO/AWP-230 
06/13/2011 10:16 FAX 3107256816 AWP-7 SOlO 

CERTIFICATE OF SERVICE 

I hereby certify that on this date I have sent by facsimile and placed in the United 

States mail, postage prepaid, certified mail - return receipt requested, the executeii original 

and one copy of the Complaint, addressed as follows: 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building—Suite"2Wl 000 

Facsimile: (202) 493-5142 

I further certify that on this date I have placed in the United States mail, postage 

prepaid, certified mail — return receipt requested, and via facsimile where indicatCil, a true 

copy of the Complaint, addressed as follows: 

Cyril Lawrence, Inc. 

2111 "K" Street 

Merced, CA 95340 

Fax: 209-383-6856 

Dated: JUN 1 3 2011 

Jeff Kamber'g, Legal Technician 

Office of the Regional Counsel 

Federal Aviation Administi-ation 

Western-Pacific Region 

Lawndale, California 
06/13/20J.1 10:16 FAX 3107256816 AWP-7 IglOll 

CERTIFICATE OF SERVICE 

I hereby certify that on this date I have sent by facsimile and placed in the United 

States mail, postage prepaid, certified mail - return receipt requested, the executed original 

and one copy of the Complaint, addressed as follows: 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC^430 

Wilbur Wright Building—Suite 2W1000 

Facsimile: (202) 493-5142 

I fiirther certify that on this date I have placed in the United States mail, pc'Stage 

prepaid, certified mail - return receipt requested, and via facsimile where indicated, a true 

copy of the Complaint, addressed as follows: 

Cyril Lawrence, Inc. 

2111 "K" Street 

Merced, CA 95340 

Fax: 209-383^6856 

Dated: JUN 1 3 2011 

Jeff Kambefg, Legal Technician 

Office of the Regional Counsel 

Federal Aviation Administration 

Western-Pacific Region 

Lawndale, California 
06/13/2011 10:15 FAX 3107256816 AWP-7 laooi 

Federal Aviation 

Administration 

To: 

Phone: 

Fax: 

From: 

Title: 

Date; 

Hearing Docket Clerk, AGC-430 & Cyril 

Lawrence, counsel for Respondent 

(202) 493-5142 & (209) 383-6856 

Lierre Green 

F/V\ Attorney. AWP-7,6 

June 13. 2011 

Pages w/cover: 

11 

Office of the Regional Counsel, AWP-7 

PO Box 92007 

Los Angeles, CA 90009-2007 

Telephone: (310)725-7117 

Facsimile: (310) 725-6816 

Email: 

Facsimile 

Description of item being transmitted: 

Complaint 

D Per your Request • For Review D Please Comment 

• For Coordination ^ Hard Copy to Follow via US MAIL 

NOTES/COMMENTS: 

RE: Administrator, F/\A v. K.S. Aviation. Inc. d/b/a Siena Academy of Aeronautics, Case No 2011WP170009 

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