(d6/16/2011 10:03 4252271007 ANM7 PAGE 02/08 

o 

U.S. Department 

Of Transportation 

Federal Aviation 

Administration 

Office of Regional Counsel 

June 16, 2011 

Nortbvi'est Mountain Region 

Colorado, Idaho, Montana, 

Oregon, Utah, Washington, 

Wyoming 

1601 Lind Avenue S.W. 

Renton, Washington 98057 

Tel; (425) 227-2161 

Fax: (425) 227-1007 

JEFFREY.HARPER@FAA.GOV 

VIA FACSIMILE AND CERTIFIED MAIL - RETURN RECEIPT REQUESTED 

Attn: Hearing Docket Clerk, AGC-430 

Hearing Docket 

Federal Aviation Administration 

Wilbur Wright Bldg - Room 2W1000 

800 Independence Aven\ie Southwest 

Washington, D.C. 20591 

I-..") 

Re: In the Matter of Cornerstone Aviation, Inc., FAA Case No. 2011NM070042 

CD 

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 Federal Aviation Admimstration (FAA) requests that the hearing in this matter be held in 

Salt Lake City, Utah and expects that the hearing will last one (1) day. Unavailability dates for the 

undersigned in 2011 for military duty are: May 20 through 23, June 23 through 27, July 8 through 

11, August 5 through 8, and September 9 through 12. 

Please address all communications for the FAA to the undersigned at; 

Federal Aviation Administration 

Northwest Moimtain Region, ANM-7 

1601 Lind Avenue Soxrthwest 

Rentofi, Washington 98057 

Telephone: (425) 227-2161 

FAX: (425)227-1007 

:Srey M. Harper 

FAA Attomey 

Enclosures; Request for Hearing 

Complaint 
0S/1G/2011 10:03 4252271007 ANM7 PAGE 03/08 

1 

CORNEWSTONE AVIATT©M 

PI.IOW 1 S O MO O I. S 

Jime3,2011 4A3V|-, 

Federal Aviation Administration 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building - suite 2W1000 

800 Independence Avenue Southwest 

Washington, DC 20591 

To whom it may concern. 

I am requesting a hearing on a Civil Penalty matter, FAA case No. 

2011NM070042 along withthe already requested hearing for the other Civil 

Penalty matters, FAA Case No. 20HNM070021 aud FAA Case No. 

2011NM070022. 

Sincerely, 

7 

Susan J. Horstman 

CEO 

Cornerstone Aviation 

shortsman(@.comerstoneaviation. com 

801-355-2244 

SALT LAICS INT'L AIRFOST: OGOEN AERPORT 

337 Norih 2370 West 38 H Airport BiJ.Bia8 830 

S4ltL«koCTty,UT84116 Ogdon, UT 8/1405 

TolcphonK 801'335-22'14 Telephnne: 801-£22-1322 
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JEFFREY M. HARPER 

FAA OFFICE OP REGIONAL COUNSEL 

1601 LiND AVE. SW. 

RENTON, WA 98057 

TELEPHONE; (425)227-2161 

FACSIMILE: (425)227-1007 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C 

In the Matter of: 

Cornerstone Aviation, Inc. 

FAA DOCKET Not Assigned 

FAA Case No. 2011NM070042 

Judge Not Assigned 

JUDGE NOT ASSIGNED 

COMPLAINT 

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

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

I. 

On May 24,2011, Cornerstone Aviation, Inc. vras advised through a Notice of Proposed 

Civil Penalty that the FAA proposed to assess a civil penalty in the amount of $5,500, On 

June 3, 2011, Cornerstone Aviation, Inc. submitted a written request for a hearing. 

n1. Cornerstone Aviation, Inc. (Cornerstone) is now and was at all times material hereto the 

holder of Air Agency Certificate No. QN7S767K, and conducts its operations pursuant to 

Part 141 of the Federal Aviation Regulations (FAR). 

2. Cornerstone's Authorized Courses of Training record pennits it to conduct training for 

the Private Pilot certificate. 

3. Cornerstone's Authorized Co\irses of Training record permits it to conduct training for 

the Commercial Pilot certificate. 

Complmnt 

Cornerstone Aviation, Inc. - 2011NM070042 

Page i of 5 

JEFFREY Mi HARPER, FA A ATTORNEY 

TEL: (425) 227-2161; FAX; (425) 227-1007 
06/16/2011 10:03 4252271007 ANM7 PASE 05/08 

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4. Cornerstone's Authorized Courses of Training record permits it to conduct training for 

the Instrument - Airplane rating. 

5. Cornerstone is authorized to provide the instrument training referenced above using the 

Jeppesen Sanderson, Inc. Instrument / Commercial Course Syllabus (the syllabus) for 

both ground and flight training. 

6. Mr. Samuel Golden enrolled in Cornerstone's Instrument - Airplane / Commercial course 

on September 7,2010. 

7. While enrolled in the Instrument - Airplane / Commercial course, Mr. Golden received 

no ground training. 

8. Mr. Golden received no ground training because he had completed a home study course. 

9. Cornerstone is not authorized to credit students with ground training received elsewhere. 

10. Mr. Golden's enrollment in Cornerstone's Instrument - Airplane / Commercial course 

was terminated on January 10,2011. 

11. Mr. Golden's Part 141 training records for his Instrument - Airplane / Commercial course 

were not certified as correct by the Chief Flight Instructor. 

12. Mr. Jason Lambert enrolled in Cornerstone's Private Pilot course on September 4,2008, 

and graduated from the course on July 1, 2009. 

13. Mr, Lambert's Part 141 training records for his Private Pilot course were not certified as 

coirect by the Chief Flight Instructor. 

14. Mr. Bryant Chase enrolled in Cornerstone's Private Pilot course on September 18,2009 

and graduated firom the course on May 21, 2010. 

15. Mr. Chase's graduation certificate for the Private Pilot course reads, in part "This is to 

certify that Cornerstone has successfully completed all stages, tests, and course 

requirements and has graduated from the [FAA approved] Private Pilot course 

conducted by Cornerstone Aviation." 

16. Mr. Chase's graduation certificate does not contain his name. 

m. 

1. By reason of the foregoing circumstance(s), Cornerstone violated the following 

Sections of the Federal Aviation Regulations (14 C.F.R.): 

Cornplaint 

Cometstonc Aviation, Inc. - 2011NM070042 

Page 2 of5 

JEFFREY M . HARPER, FAA ATTORNEY 

TEL: (425) 227-2161; FAX: (425) 227-1007 
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a. Section 141.83(a)(1), in that Cornerstone did not comply with its approved 

training course. 

b. Section 141,95(b)(2), in that Cornerstone issued a graduation certificate to a 

student that failed to contain the student's name, 

c. Section 141.101(a), in that Cornerstone failed to maintain a current and accurate 

record of the participation of a student enrolled in an approved training course. 

d. Section 141.101(c), in the Cornerstone failed to certify a student's record upon 

termination of that stiident' s training. 

2. Under 49 U.S.C. §§ 46301 (a) and (d), Cornerstone is liable for a civil penally not to 

exceed $11,000 for each of the violations noted. 

3. Under the facts and circumstances of this case, a civil penalty of $5,500 is appropriate. 

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

Law Judge enter an order that Cornerstone Aviation, Inc. be assessed a civil penalty in the 

amount of $S,500. 

Respectfully submitted this 16th day of June, 2011. 

Complaint 

Cornerstone Aviation, Inc. -2011NM070042 

Page 3 of5 

JEFFREY M, HARPER, FAA ATTORNEY 

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

In accordance with section 13.209 of the Federal Aviation Regulations, Cornerstone Aviation, 

Inc. must answer this Complaint not later than 30 days from tlie time it is served on it. Failure to 

file an Answer within 30 days without good cause shall be deemed an admission of the truth of 

each allegation contained iii the Complaint (14.C.F.R. § 13.209(f)). 

Complaint 

Cornerstone Aviation, Inc. 

Page 4 of 5 

•2011NM070042 

JEFFREY M. HARPER, FAA ATTORNEY 

TEL: (425) 227-2161; FAX; (425) 227-1007 
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CERTIPICATE OF SERVICE 

rhereby certify that the foregoing Complaint has been served via facsimile and certified mail 

Return Receipt Requested this date, to the following: 

Federal Aviation Administration 

800 Independence Ave. SW. 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building - Suite 2W1000 

Fax: 202. 493.5142 

I also certify that the foregoing Complaint has been served via Regular and Certified Mall -

Return Receipt Requested this date, to the following: 

Susan Horstman 

Chief Executive OfiRcer 

Cornerstone Aviation, Inc. 

337 North 2370 West #130 

Salt Lake City, UT 84116 

TEL: (801)355-2244 

Dated this 16th day of June, 2011. 

MOIFAIR CHIN 

Office of Regional Counsel (ANM-7) 

Federal Aviation Administration 

1601 Lind Ave. SW. 

Renton, WA 98057 

(425)227-2160 

Complaint 

Cornerstone Aviation, Inc. - 2011NM070042 

Page 5 of 5 

JEFFREY M. HARPER, FAA ATTORNEY 

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