In the matter of 

RECEIVED 

BEFORE THE APR 0 8 2015 

u.s. DEPA~~~~~To~~~~di~~~RTATio~ EARl NG DOCKET 

WASHINGTON, D.C. 

Docket No. FAA-2013-0291 

FAA Case No. 2011S0290032 

AIRBORNE MAINTENANCE AND 

ENGINEERING SERVICES 

Respondent 

Administrative Law Judge 

J.E. Sullivan 

RESPONDENT'S STIPULATION REGARDING THE AMOUNT OF THE 

FAA'S PROPOSED CIVIL PENALTY OR, IN LIEU THEREOF, 

PARTIAL WITHDRAWAL OF REQUEST FOR A HEARING 

ON THE AMOUNT OF THE PROPOSED CIVIL PENALTY 

In the Order Granting in Part and Denying in Part the FAA's Motion for Summary 

Judgment, served April I, 2015, Your Honor held that there are genuine issues of material fact in 

dispute regarding the amount of the FAA's proposed civil penalty and reconfirmed the hearing 

scheduled for May 5-9, 2015 for the sole purpose of addressing the amount of the proposed civil 

penalty. April!, 2015 Order, ordering paragraphs 3 and 4. 

Respondent has filed notices of appeal of the April!, 2015 Order and of Your Honor's 

March 30, 2015 Order Denying Respondent's Cross-Motion for Summary Judgment. 

Respondent hereby stipulates that if Your Honor's April!, 2015 and March 30,2015 Orders are 

sustained after Respondent has exhausted its rights of appeal, it will not dispute the amount of 

the civil penalty ($61,875) proposed in the FAA's Complaint1 

or the per aircraft equivalent 

thereof ($20,625) based on the FAA's position as stated in its Motion for Summary Judgment 

(Pages 23-24) that the penalty was calculated on a per aircraft basis. Alternatively, pursuant to 

1 The April!, 2015 Order states that the FAA proposed a civil penalty of$64,875 in this matter. 

The FAA Complaint, however, actually proposed a civil penalty of $61,875. FAA Complaint, 

dated June 20,2013 at p. 3. 

1 
§13.215, Respondent hereby withdraws its request for a hearing previously submitted on June 

13,2013 but only on the issue of the amount of the proposed civil penalty. In light of the 

foregoing stipulation, or alternatively, the partial withdraw of the request for a hearing, a hearing 

for the purpose of addressing the amount of the civil penalty is no longer necessary. 

Dated: April 7, 2015 

Respectfully submitted, 

SILVERBERG GOLDMAN, L.L.P. 

Attorneys for 

AIRBORNE MAINTENANCE AND ENGINEERING 

SER~ l /)/'/ 

By ~~!!~s Robert P. Silverberg, Esq. 

1101 30'h Street, N.W. 

Suite 300 

Washington, D.C. 20007 

Tel: (202) 944-3304 

Fax: (202) 944-3306 

Email: rsilverberg@sgbdc.com 

2 
CERTIFICATE OF SERVICE 

I hereby certify that on this 7111 day of April 2015, I caused a true copy of the foregoing 

Respondent's Stipulation Regarding the Amount of the FAA's Proposed Civil Penalty or, in Lieu 

Thereof, Partial Withdrawal of Request for a Hearing on the Amount of the Proposed Civil 

Penalty to be served upon the following: 

Federal Aviation Administration 

600 Independence Avenue, S.W. 

Wilbur Wright Building 

Suite 2W1000 

Washington, D.C. 20591 

(Attention: Hearing Docket Clerk, AGC-430) 

Tel: (202) 267-0377 

(original and one copy by F edEx) 

The Hon. J.E. Sullivan 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200New Jersey Avenue, S.E. (E1l-310) 

Washington, D.C. 20590 

Fax: (202) 366-7536 

(one copy by First Class Mail and facsimile) 

Christopher R. Stevenson, Attorney 

Federal Aviation Administration 

Office of the Regional Counsel, ASO-7 

Southern Region 

P.O. Box 20636 

Atlanta, Georgia 30320 

Fax: (404) 305-5223 

(one copy by First Class Mail and e-mail)