William A. Curtright 

Respondent 

PO Box 1350 

Jefferson, OR 97352 

Telephone: (503) 209-7388 

Fax: (503) 485-0812 

In The Matter Of: 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

H 

Docket No. FAA-2015-1319 

WILLIAM A. CURTRIGHT, 

Case No. 2014NM090046 

Respondent 

Judge J.E. Sullivan 

RESPONDENT'S REPLY TO ORDER SETIING DEADLINES FOR THE FAA TO SUPPLEMENT 

ITS MOTION. FOR THE RESPONDENT TO RESPOND AND SHOW CAUSE, AND 

GRANTING/RESERVING OTHER RELIEF 

Respondent Dr. Wm. Ames Curtright, DBA's response to FAA's Complaint is as follows: 

We were served with the Complaint dated May 19, 2015. The document was not signed by 

Complainant FAA attorney David Shayne, which made me question the formality of the document. 

Because there was no signature, it was not realized that a response was necessary. 

Also, we have now noted that on page 3, separate from the actual Complaint, is a statement of 

four single-spaced lines suggesting a response was needed (Exhibit 2). Not being an attorney, this 

information was inadvertently missed and, thus, not understood to be a legal document bound by a 

response with a formal deadline. As already stated, lack of a signature suggested an informal issue. 

Our first objective was to respond asking why, since the logs were lost, we wondered why a 

complaint was filed in the first place. 

On February 10, 2015, we did respond with a letter to Mr. Shayne (See Exhibit 3). Prior to this 

letter we had responded with calls and other communication. We believed that progress on compliance 

with FAA requests was being made toward a resolution because we were in continuous contact with the 

FAA by phone, FAX and letters. However, the communication seemed to be more of a one way street. 

RESPONDENT'S REPLY TO ORDER SffiiNG DEADLINES FOR THE FAA TO 

SUPPLEMENT ITS MOTION, FOR THE RESPONDENT TO RESPOND AND SHOW CAUSE, 

AND GRANTING/RESERVING OTHER RELIEF 

Docket No. FAA-2015-1319 

Case No. 2014NM090046 

Page 1 of 3 

William A. Curtright 

Respondent 

Telephone: (503) 209-7388 

Fax: (503) 485-0812 
We believed our actions to be a good faith effort to meet the demands of the FAA. We were unable to 

immediately locate the logbooks for the aircraft when they were requested by the FAA because all who 

complete maintenance or repairs needed to have access to the logbooks to document their work on the 

aircraft. Locating the logbooks was further complicated by the fact that the aircraft used to travel to our 

distant second home near an airport where the aircraft was sometimes worked on was grounded. This 

prevented us from searching for the logbooks at that distant location to rule it out or discover the 

logbooks there. Therefore, we were unable to provide the logbooks to the FAA within the time line 

requested and time was needed to locate lost logs and gather things together. 

Finally, after a letter was written to the director of Portland FSDO and a visit to our offices 

ensued, Portland FAA inspected logs, and appeared to be fully satisfied that both the pilot and aircraft 

were in compliance. (See Exhibit 1). 

CONCLUSION 

In conclusion, as to the initial Complaint, we did not know a formal reply was necessary since 

there was no signature. 

Also, we were responding in the only way we knew how by pointing out we had lost the 

documents. The FAA legal counsel Mr. Shane chose to ignore that. The pilot, aircraft and the logs were 

shown to be in compliance. FAA legal counsel David Shayne seemed reluctant to share information 

and did not forward this information to us until pressed. Also, counsel seems reluctant to dismiss the 

complaint or withdraw the complaint even after we had complied. 

Respectfully submitted this j_L day of November, 2015. 

L\_') l/~ C.l_ __, --~~~~~~~~~ .. ~-=-~,=-~--~·~ ' 

Dr. William A. Curtright, DBA 

Respondent 

RESPONDENT'S REPLY TO ORDER SETIING DEADLINES FOR THE FAA TO 

SUPPLEMENT ITS MOTION, FOR THE RESPONDENT TO RESPOND AND SHOW CAUSE, 

AND GRANTING/RESERVING OTHER RELIEF 

Docket No. FAA-2015-1319 

Case No. 2014NM090046 

Page 2 of 3 

William A. Curtright 

Respondent 

Telephone: (503) 209-7388 

Fax: (503) 485-0812 
SERVICE LIST 

ORIGINAL & ONE COPY 

Federal Aviation Administration (Fax and Fed Ex Overnight) 

800 Independence Avenue SW 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building, Suite 2W1000 

Fax: (202) 267-1293 

Judge J.E. Sullivan (Fax and Fed Ex Overnight) 

U.S. Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE (E11-310) 

Washington, DC 20590 

TEL: 202-366-6941 

FAX: 202-366-7536 

ONE COPY 

David F. Shayne, FAA Attorney (Certified First Class Mail) 

Complainant's Counsel 

Northwest Mountain Region, ANM-7 

Federal Aviation Administration 

1601 Lind Ave. SW 

Renton, WA 98057 

TEL: 425-227-1847 

RESPONDENT'S REPLY TO ORDER SETIING DEADLINES FOR THE FAA TO 

SUPPLEMENT ITS MOTION, FOR THE RESPONDENT TO RESPOND AND SHOW CAUSE, 

AND GRANTING/RESERVING OTHER RELIEF 

Docket No. FAA-2015-1319 

Case No. 2014NMQ90046 

Page 3 of 3 

William A. Curtright 

Respondent 

Telephone: {503) 209-7388 

Fax: {503) 485-0812 
SPEED MEMO 

SUBJECT 

EIR No. 2014NM090046, Lost Logs 

TO: DATE OF REPLY 

Marty G Conroy 

cc Bill McKibbon SIGNATURE OF REPLIER 

TITLE ROUTING SYM. 

---·--~--·-

INITIAL MESSAGE 

INSPECTOR STATEMENT 

On Thursday, 08-13-2015, ASI's Curt Cowley and Terry Juran Inspected the aircraft maintenance records of Supercub 

N949JP. at Mr Curtnght's place of business in Salem. Or. Mr Curtright was pleasant and curteous. He allowed us 

unrestricted access to the aircraft logbooks without distraction. 

The records were well organized and complete. back to the birth of the aircraft. The records did not appear to the 

alterered or edited 1n anyway. No descrepantcies were noted, and the aircraft appears to have been airworthy at the time 

of the accident 

I 

REPLY MESSAGE 

---- FROM: DATE OF INITIAL MESSAGE 

~§<. st 1J'12015 

FEDERAL 

Flight Standards 

AVIATION 

District 

ADMINISTRATION 

Office SIG~AT~;(~:t~ 

3180 NW 2291

' Avenue 

I./ (/ . r v I 

Hillsboro. OREGON 97124 

TITLE ASI t' ROUTING SYM 

NM09 

Resp. Reply to Order Setting Deadlines 

Exhibit I, pg. 1 
William Ames Curtright 

From: 

Sent: 

To: 

Subject: 

Attachments: 

David. F. Shayne@faa.gov 

Wednesday, October 14, 2015 2:15PM 

ames@amesresearch.com 

RE: Docket No. FAA-2015-1319, Curtright 

document2015-08-16-071730.pdf 

Here is a copy of the email I received and the memo 

Sorry David, 

This is to confirm the records have now been provided and examined to our satisfaction. Attached is a speed memo from 

inspector Cowley regarding his examination of the records. 

Best regards, 

Billy J. McKibbon 

Front Line Manager- Heavy Helicopter Unit 

Portland Flight Standards 

Federal Aviation Administration 

(503) 615-3235 

We value your feedback. 

Flight Standards Service Quality Management System (QMS) Feedback 

Form:http:/ /www.faa.gov/about/office_org/headquarters_offices/avsjoffices/afs/qms/ 

From: William Ames Curtright [mailto:ames@amesresearch.com] 

Sent: Wednesday, October 14, 2015 1:58PM 

To: Shayne, David F (FAA) 

Subject: Docket No. FAA-2.015-1319, Curtright 

David, I note that this matter is still before the courts. I also note the Order for Reassigning the proceedings to a new Judge. 

Thus I note that this matter isn't dismissed as of yet. 

I Could you send me a copy of your last letter to the court requesting the 

Dropping and closure of this matter. 

As you know Curt Cowley visited our offices and reviewed all documentation of the lost documents from Portland, Oregon 

Dr. Wm. Ames Curtright, BS, DBA 

CEO/President 

Ames Research Laboratories, Inc. 

ames@amesresearch.com 

Phone: 503-588-7000 

1 

Resp. Reply to Order Setting Deadlines 

Exhibit I . pg. ~ 
DAVID F. SHAYNE 

FAA OFFICE OF REGIONAL COUNSEL 

1601 LIND AVE., SW 

RENTON, WASHINGTON 98057 

TELEPHONE: (425) 227-2165 

FACSIMILE: (425) 227-1007 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of: 

William A. Curtright FAA Case No. 2014NM090046 

Judge Not Assigned 

JUDGE NOT ASSIGNED: 

COMPLAINT 

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

pursuant to Rule 208 of the Rules of Practice (14 Code of Federal Regulations (C.F.R.) Section 

13 .208), and states as follows: 

I. 

On May 6, 2015, William A. Curtright was advised through a Final Notice of Proposed 

Civil Penalty that the FAA proposed to assess a civil penalty in the amount of $11,000. On May 

11, 2015, Mr. Curtright submitted a written request for a hearing. 

II. 

1. William A. Curtright was and at all times material hereto was the owner and/or 

operator of a Piper Model PA-18135, a U.S. registered civil aircraft, N949JP. 

2. On or about July 1, 2014, an Aviation Safety Inspector (ASI) from the Portland Flight 

Standards District Office wrote Mr. Curtright a letter demanding that he provide 

COMPLAINT 

FAA v. William A. Curtright 

FAA Case No. 20 !4NM090046 

Page 2 of5 

DAVID F. SHAYNE, FAA ATTORNEY 

TEL: (425) 227-2165: FAX: (425) 227-1007 

Resp. Reply to Order Setting Deadlines 

Exhibit 2 pg. 1 
aircraft weight and balance, and aircraft and engine maintenance logbooks for 

N949JP. 

3. Mr. Curtright sent two emails and a letter acknowledging that he was aware of the 

demand. 

4. As of this time, Mr. Curtright has failed to provide the maintenance records 

referenced above. 

III. 

1. By reason ofthe foregoing facts and circumstances, J\1r. Curtright violated Section 91.417 

(c) of the Federal Aviation Regulations (14 Code of Federal Regulations (C.F.R.)) in that 

he owned or operated an aircraft for which he failed to make all maintenance records 

required to be kept by this section available for inspection by the Administrator. 

2. In accordance with Sections 46301(a) and (d) of Title 49 ofthe United States Code 

(U.S.C.) (Transportation) [49 U.S.C. Sections 46301(a) and (d)], Mr. Curtright is liable 

for a civil penalty not to exceed $11,000 for each of the violations noted. 

3. Under the facts and circumstances of this case, a civil penalty of $11,000 is appropriate. 

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

Law Judge enter an Order that William A. Curtright be assessed a civil penalty in the amount of 

$11,000. 

Respectfully submitted this 19th day ofMay 2015. 

David F. Shayne 

FAA Attorney 

COMPLAINT 

FAA v. William A. Curtright 

FAA Case No. 2014NM090046 

Page 3 of5 

DAVID F. SHAYNE. FAA ATTORNEY 

TEL: (425) 227-2165; FAX: (425) 227-1007 

Resp. Reply to Order Setting Deadlines 

Exhibit 2, pg. 2 
ANSWER 

In accordance with Section 13.209 of the Federal Aviation Regulations, William A. Curuight, 

must answer this Complaint not later than thirty (30) days from the time it is served. Failure to 

file an Answer within thirty (30) days without good cause shall be deemed an admission of the 

truth of each allegation contained in the Complaint [14.C.F.R. § 13.209(£)]. 

COMPLAJNT 

FAA v. William A. Curtright 

FAA Case No. 2014NM090046 

Page 4 of5 

DAVID F. SHAYNE. FAA ATTORNEY 

TEL: (425) 227-2165: FAX: (425) 227-1007 

Resp. Reply to Order Setting Deadlines 

Exhibit;), pg. 3 
CERTIFICATE OF SERVICE 

I hereby certifY that the foregoing Complaint has been served via facsimile and/or certified mail - Return Receipt Requested this date, to the following: 

Federal Aviation Administration (Original and one copy) 

800 Independence Avenue SW 

Washington, D.C. 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2WIOOO 

Fax: (202) 267-1293 

William A. Curtright 

P.O. Box 1350 

Jefferson, OR 97352 

Dated this 19th day of May 20 15. 

I 

~~01 Ter ·Kirk 

Office of Regional Counsel (ANM-7) 

Federal Aviation Administration 

1601 Lind Ave. SW 

Renton, W A 98057 

(425) 227-2007 

COMPLAINT 

FAA v. William A. Curtright 

FAA Case No. 20 14NM090046 

Page 5 of5 

DAVID F. SHAYNE, FAA ATTORNEY 

TEL: (425) 227-2165; F A.X; (425) 227-1007 

Resp. Reply to Order Setting Deadlines 

Exhibit ::2, pg. 4 
• Complete items 1, 2, and 3. Also complete 

Item 4 if Restricted Delivery is desired. 

• Print your name and address on the reverse 

so that we can return the card to you. 

• Attach this card to the back of the mailpiece, 

or on the front if space permits. 

1. Article Addressed to: 

David .S ~ ... e. 

F I+ IT f.l1tono. t.c; 

I ~o I L; vvl A-Ve... ~tu 

Ke. "'iB"" WA 1 <t t) s:-7 

D. I 

If YES, enter delivery address below; 

3. Service Type 

)ii'CertHied Mall 

D Registered 

D 

D Express Mall 

0 Return Receipt for Merchandise 

C.O.D. 

2. Article Number 

(Transfer from service label) 7004 2890 DODO 2884 7728 

PS Fonm 38i i, February 2004 Domestic Return Receipt 102595-02:-~1540 : 

Resp. Reply to Order Setting Deadlines 

Exhibit S, pg. 1 
February 10, 2015 

VIA FIRST-CLASS CERTIFIED RETURN RECEIPT REQUESTED AND FEDEX 

David Shayne 

FAA Attorney 

1601Lind Avenue SW 

Renton,WA 98057 

Re: FAA Case No. 2014NM090046 

Dear Mr. Shayne: 

This is in reference to your notice of proposed civil penalty dated January 14, 2015. 

All documents have been provided to Martin Conroy in Flight Standards District Office in Hillsboro, 

Oregon. In an aircraft collapsed gear incident on the Super Cub amphibious aircraft, the left wheel 

collapsed; the aircraft, after landing nearly perfectly, continued to slide off the runway when the rail of 

the left float banked the aircraft to the left up a slight slope. 

Mr. Conroy has been provided all documents certifying the aircraft was airworthy and weight and 

balance. My logs are lost We cannot find them. I live in Canada as well, but since I have no aircraft 

available, I cannot get north. I plead not guilty because of non-intentional circumstance. I have an 

attorney. Please contact him for further communications. 

The weight and balance we have provided again through my attorney. 

This aircraft is now down and cannot fly, but we have provided all possible documents, Far further 

assistance, please contact my attorney, Thomas J. Flaherty, 503-245-2500. He will assist you with any 

defense I might need. 

Best regards, 

0: 

"'b.~ 503-588-7000 Ex 110 

C: 503-209-7388 

ames@amesresearch.cam 

Enclosures 

cc Thomas J. Flaherty, Attorney.,--~ 

Resp. Reply to Order Setting Deadlines 

Exhibit 1, pg. 2 
Ref: SHIPPING• 

SPECIAL: 

September 9, 2014 Oap: 

Dlilta= OSSep14 

Wgt: 1.00 LBS 

DV• 

HI\NOLINS• 

0.00 TOTf!!L: 

Martin G. Conroy 

Aviation Safety Inspector 

Flight Standards Dist. Office 

3180 NW 229'" Ave. 

Hillsboro, OR 97124 

Re: EIR Number 2014NM090046 

Dear Sir: 

Sns: •• 20AY •• TRGK: 5565 019! &&01 

As explained via email, the aircraft logs are not in the United States; they are In Canada where I 

also live. I am now awaiting the time to repair my aircraft repair. In order to meet your request, 

I have emailed the remaining documents and the Certification ofAnnuallnspectiQ!ljls requested 

to the Portland office. 

Ali other documents have been provided to you as requested. Is it possible your people have 

not opened your emails to check the attachments? They were sent to your Portland office. If 

you are still missing something let us know. 

We have provided a letter from the mechanic who did the annual certification inspection. We 

recently erf,ailed the weight and balance but again we will mail it to you. 

The event was on my private property. It took place after landing; there was a steering problem 

because of a collapsed gear which caused a breaking to the left. The aircraft was not airborne 

but inertia and the rail on the floats pulled the aircraft to the left and into the grass, thus, our 

description of the event which damaged the aircraft. 

Your letters indicate you have never received any of this information which is troubling. ~-

We have provided you the aircraft weight and balance, airworthi~ess registration certificate, 

and documentation with the flight review requirements and all the documents you requested, 

yet you people act as if you never received those items. 

We have provided to you the documents in a spirit of cooperation. Again, we hope this meets 

your needs and pray this brings closure for us both. 

Dr. W. Ames Curtright 

B.?I 

0.64 

1.84 

9.19 

Ames Research Labomtories, Inc. • 1891 161

" St. SE, Salem, Oregon USA 973°" . . Toll-Free: 888·345-0809 o Phone: 503-588-3330 o Fax: 503-364·2380 •lllllesstaff@arne Resp. Reply to Order Setting Deadlines 

Exhibit;;i, pg. 3