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UNITED STATES DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

IN THE MATTER OF 

REDEMPTION, INC. 

DOCKET NO. FAA-2014-0115 

(Civil Penalty Action) 

ADMINISTRATOR'S OPPOSITION TO REDEMPTION'S MOTION TO COMPEL 

I. Introduction. 

Complainant Federal Aviation Administration ("Administrator"), through counsel, 

hereby opposes the Motion to Compel Discovery, Impose Sanctions, and Order Redemption Air 

Be Reimbursed ("Motion") filed by respondent Redemption, Inc. ("Redemption"). Redemption's 

motion is premised on an unstated and unfounded theory that an air carrier has an unquestionable 

right to have any officer or employee it chooses physically attend a deposition, including an 

officer or employee who is being criminally prosecuted for assaulting and harassing the 

deponent. Redemption's motion is unfounded and should be denied. 

ll. Factual Background. 

A. Redemption's President and Director of Operations Physically Attacked the 

Deponent. 

This case concerns the violent and unjustified refusal of Redemption's owner to allow the 

Administrator to conduct a records inspection. To understand Redemption's motion, it is 

important to understand why the Administrator has placed one condition on his willingness to 

allow Redemption to depose FAA Aviation Safety Inspector Christina Bryant. The Administrator 

has insisted that Insp. Bryant be deposed outside the physical absence of Robert G. Stanford, the 
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President and Director of Operations for Redemption. The Administrator makes this request 

because Mr. Stanford attacked Insp. Bryant for, in her official capacity,lawfully requesting to 

review certain Redemption records in furtherance of the Administrator's regulatory oversight 

function. Therefore, the story of Mr. Stanford's attack on this federal officer, completely 

Unmentioned in Redemption's motion, must be told. 

At all times relevant to this proceeding, Redemption was a certificated Part 135 air carrier 

operating out of Kodiak, Alaska. 1 On the morning of August 15,2013, FAA Aviation Safety 

Inspector Christina Bryant visited Redemption's main base.2 The purpose of Insp. Bryant's visit 

was to perform a quick, five minute follow-up records review of Redemption's load manifests.' 

Redemption's failure to accurately and completely prepare load manifests on numerous flights in 

2013 caused an investigation by Insp. Bryant4 that ultimately resulted in a $6,000 civil penaity. 5 

Therefore, Insp. Bryant's visit that day was part of the Administrator's effort to monitor 

Redemption's questionable ability to comply with regulatory norms. 

During Insp. Bryant's fust visit that day, Redemption was busy, so she indicated to a 

Redemption employee she was familiar with that she would return later when they were less 

busy.6 She returned around 12:35 p.m.7 

Upon arrival, she identified herself and stated the nature of her visit." She was greeted by 

Mr. Stanford.9 Inspector Bryant asked Mr. Stanford to suggest a time that afternoon for her to 

1 Complaint at 1-2, Answer at 1. 

2 Ex:. A at 2. 

3 Id. 

4 Ex:. B. 

5 Ex:. C. 

6 Ex:. A at 2. 

7 Id. 

Redemption. Inc. 

Administrator's Opposition to Redemption 's Motion to CompQ/ 

Docket No. FAA-2014-0115 

Page 2 
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quickly inspect Redemption's mainifests. 10 Upon learning of the nature ofinsp. Bryant's request, 

Mr. Stanford became loud and agitated.ll He refused to allow Insp. Bryant to inspect the 

manifests in time for her to catch her 3:00p.m. flight back to Anchorage. 12 In making his refusal 

plain, Mr. Stanford leaned towards Insp. Bryant, slammed his fists onto a desk while loudly 

saying "damn it." 13 He then loudly directed angry vulgarities towards her, including "fuck," and 

found need to loudly and angrily state that his refusal to permit the inspection as proposed was 

somehow related to his wife's "fucking dislocated shoulder", which he said caused her to be 

bedridden so that she, in his words, "can't even wipe her own damn ass." 14 Confronted by this 

display of rage, Insp. Bryant, who was travelling alone, raised her hands in a fearful, 

surrendering gesture to Mr. Stanford while backing away from him. 15 She retreated to another 

area within Redemption's base for safety. 16 

Approximately two minutes later, Mr. Stanford came around a corner and confronted 

Insp. Bryant a second time. 17 Mr. Stanford aggressively told Insp. Bryant, despite her status as a 

federal official performing official duties on behalf of the Administrator, to leave Redemption's 

premises. 18 In doing so, Mr. Stanford violently swung an exterior door open, yelled that Insp. 

8 Id. 

9 Id. 

10 !d. 

II Id. 

12 Id. 

13 Id 

-· 

14 !d. 

15 !d. 

16 Id. at 2·3. 

17 Id.at3. 

Is Id. 

Redemption. Inc. 

Administrator's Opposition to Redemption's Motion to Compel 

Docket No. FAA-2014-0115 

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Bryant was not welcome there, and used rapid, forceful motions to gesture her exit. 19 Mr. 

Stanford then quickly approached Insp. Bryant using long strides. By now she was frozen in 

fear. 20 She perceived his rapid approach as prelude to him physically ejecting her from the 

building, so she avoided contact from him by quickly exiting the opened door.'' As she exited, 

Mr. Stanford continued to make physical gestures for her to leave and yelled at her "get off my 

damn property, you are not fucking welcome here, you don't give a damn about people."22 

Once outside the building, Mr. Stanford continued his tirade. He scrambled forward, 

blocking Insp. Bryant's path further away from the building.23 He yelled at her, shouting that he 

"never wants to see [her] on [his] property again," that she "is not welcome here," and added 

how "sick [his] wife is and [Insp. Bryant] could give a shit about her."24 Inspector Bryant tried to 

apologize about how sick Mr. Stanford's wife is, but couldn't get much across to him because of 

his shouting and uncontrolled behavior. 

Mr. Stanford then entered a red truck with tan trim.'5 While entering the truck's driver's 

seat, he yelled at Insp. Bryant as she continued her retreat. 26 She is to "stay out of his aircraft," 

he yells, slamming the truck's door for emphasis.27 

Now seated in the truck, Mr. Stanford put the truck in reverse.28 Its tires screeching, he 

drove directly at Insp. Bryant.29 Fearful of being struck, shejumped.30 But, just as abruptly, Mr. 

19 Id. 

20 Id. 

21 Id. 

22 Id. 

23 Id. 

24 Id. 

~ Id. 

26 Id. 

27 Id. 

Redemption, Inc. 

Administrator's Opposition to Redemption's Motion to Compel 

Docket No. FAA-2014-011 5 

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Stanford stopped the tmck. 31 Pushing his head out of the truck window, he looked back at Insp. 

Bryant. 32 In angry and unrestrained voice, told her that he would not be back for her to inspect 

Redemption's records that day, and departed.33 

Immediately thereafter, Insp. Bryant proceeded to the safety of the nearby Alaska 

Airlines termina!.34 There, she realized that she could document Mr. Stanford's vehicular assault 

by taking photos of the skid marks he left in the parking lot." At approximately 1:55 p.m., while 

taking the photos in the lot, Insp. Bryant was startled to hear a tmck' s engine suddenly rev up. 36 

She immediately realized that the sound was coming from Redemption's nearby ramp.37 She 

looked up, and through a chain link fence, she saw the same truck Mr. Stanford drive earlier 

speeding directly towards her?8 In fear for her life, Insp. Bryant dashed for cover as the truck 

stopped just 5-10 feet away on the other side of the fence.39 She then retreated back to the 

relative safety of the Alaska Airlines terminal. 40 As she walked, she heard the truck's door slam, 

28 Id. 

29 Id. 

30 !d. 

3t Id. 

32ld. 

33 Id. 

34 Id. 

35 Id. 

36 Id. 

37 Id. 

38 Id. 

39 Id. 

•o Id. 

Redemption. Inc. 

Administrator's Opposition to Redemption's Motion to Compel 

Docket No. FAA-2014-011 5 

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and then saw Mr. Stanford walk towards the Redemption building in an angry and purposeful 

manner.41 

Later that afternoon, while she awaited a flight out of Kodiak, a somewhat becalmed Mr. 

Stanford entered the terminal and walked directly to Insp. Bryant.42 She told him that if he 

wanted to talk, they should do it outside, where she knew a Transportation Security 

Administration employee was present.43 Now outside, Mr. Stanford moved very close to Insp. 

Bryant.44 As she stood silently, he continued to unload his frustrations on her, angrily and 

intimately poking his fingers (including, on occasion, his lone middle fmger in an obscene 

manner) within inches of her, all in a threatening and intimidating manner to emphasize his 

objections to her lawful inspection request.45 At this point, Insp. Bryant ended the conversation 

by saying she needed to tend to her flight out.46 

Mr. Stanford's behavior towards Insp. Bryant became the subject of a federal criminal 

investigation. On January 13, 2015, Assistant United States Attorney Steven Skroki advised Mr. 

Stanford's attorney that the Department of Justice has determined to file charges against Mr. 

Stanford for his conduct towards Insp. Bryant. 47 

II 

II 

II 

41 Id. at 3-4. 

42 !d. at 4. 

43 Id. 

44 Id. 

45 Id. 

46 Id. 

47 Ex. D. 

Redemption. Inc. 

Administrator's Opposition to Redemption's Motion to Compel 

Docket No. FAA-2014-0115 

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B. The Administrator Objects to Mr. Stanford's Physical Presence at Insp. 

Brvant' s Deposition. 

The Administrator has consistently sought to accommodate Redemption's plan to depose 

Insp. Bryant. The lone condition that the Administrator insists on is that the deposition occur 

outside Mr. Stanford's physical presence due to the prolonged, hostile, and aggressive behavior 

he displayed towards Insp. Bryant, described above. 

The parties began discussing Insp. Bryant's deposition not long after the complaint was 

filed in April2014.48 After some back and forth, on October 30 the parties agreed to hold the 

deposition on November 20 at 9:00 a.m .. 49 

On November 5, some two weeks before the scheduled deposition, undersigned counsel 

first informed Mr. Cole of the Administrator's request that, because of Mr. Stanford's violent 

and abusive acts towards Insp. Bryant, Mr. Stanford be kept away from the depositionlocation.50 

When Mr. Cole objected, undersigned counsel offered that the Administrator had no objection to 

any other Redemption representative being there, that the sticking point was limited solely to Mr. 

Stanford's presence. 5

1 Mr. Cole again objected, again insisting that Mr. Stanford be physically 

present at Insp. Bryant's deposition. 5

2 

On November 12, Mr. Cole served notice a deposition notice on the Administrator stating 

that Insp. Bryant's deposition would occur at Mr. Cole's office on November 20.s3 Therefore, 

48 Ex. E, F, G, H, & I. 

49 Ex. J. 

50 Ex. Kat 1. 

Sl !d. 

52 Ex. L. 

53 Ex. M. It appears that Redemption failed to serve the notice on the hearing docket clerk. 14 

CFR 13.2200)(3). It also appears that Redemption neither requested nor served a subpoena for 

Insp. Bryant. 14 CFR 13.228(a). 

Redemption. Inc. 

Administrator's Opposition to Redemption's Motion to Compel 

Docket No. FAA-2014-0115 

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on November 17, undersigned counsel wrote to Mr. Cole and informed him that Insp. Bryant 

would not appear if Mr. Cole refused to exclude Mr. Stanford from the deposition room and its 

vicinity. 54 Mr. Cole responded that he would not exclude Mr. Stanford, that it was Mr. Stanford's 

right to be present, and threatened sanctions.55 

As noted above, the Administrator has always intended for Redemption to depose Insp. 

Bryant. Therefore, in an effort at compromise and to protect Insp. Bryant, on November 18 

undersigned counsel again wrote to Mr. Cole.56 In that letter, undersigned counsel offered to let 

Mr. Stanford to participate in the deposition, but to do so via the Administrator's video 

conferencing facilities. Mr. Cole was well-aware of these facilities, having used them just a 

month earlier in a deposition split between Anchorage and Oklahoma City.57 But Redemption 

refused to compromise, once again insisting without explanation that Mr. Stanford simply had to 

be physically present when Insp. Bryant was deposed. 58 

III. Argument. 

A. The Law Does Not Recognize an Inviolable Right of Witness Intimidation, 

At the center of Redemption's Motion is an obvious, unspoken truth. Redemption hopes 

to intimidate Insp. Bryant during her deposition by forcing her to suffer the physical p~esence of 

the man currently being criminally prosecuted for attacking her, Mr. Staoford. ~ 

While the law does generally try to accommodate a party's right to participate in all 

phases of the proceedings, the right is not unlimited. Rule 26(c) provides that, for good cause 

54 Ex. N. 

"Ex. 0. 

56 Ex. P. 

57 Ex. Q. 

ss Ex. R. 

59 Ex. D. 

Redemption. Inc. 

Administrator's Opposition to Redemption's Motion to Compel 

Docket No. FAA-2014-0115 

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shown, a person may be protected from abusive discovery that would cause "annoyance, 

embm1:assment, oppression, or undue burden or expense". 60 The rule specifically allows the court 

to "designate the persons who may be present while the discovery is conducted ... .''61 

It was in the spirit of Rule 26 that the Administrator attempted to accommodate 

Redemption's discovery request. The Administrator first suggested that a different Redemption 

representative participate, meaning one that hadn't attacked Insp. Bryant. That was rejected. The 

Administrator then offered to let Mr. Stanford participate via videoconference, using the smne 

sophisticated FAA facilities that Redemption's attorney had found acceptable during a 

deposition just a month prior. That too was rejected without elaboration. 

In appropriate circumstances, courts have prevented parties62 from being physically 

present during a deposition. In re Levine, 101 B.R. 260 (D.Colo.l989) (exclusion of parties from 

each other's depositions permissible); BCI Commun. Sys., Inc. v. Bell Atlanticom Sys .. Inc., 112 

F .R.D. 154 (N .D.Ala.l986) (good cause may exist to exclude a party from a deposition); 

Montgomery Elevator Company v. Superior Court, 661 P.2d 1133 (1983) (finding in "unusual 

situations" it would be appropriate to exclude a party from depositions); Beacon v. R.M. Jones 

Apartment Rentals, 79 F.R.D. 141, 142 (N.D.Ohio 1978) (finding, under particular 

circumstances which involved "subtle and sophisticated questions," good cause existed to 

exclude parties from deposition); Galella v, Onassis, 487 F.2d 986 (2nd Cir. 1973) (party 

excluded from deposition he called where party was subject to a temporary restraining order 

meant to protect deponent). 

6

° Fed. R. Civ. P. 26(c)(l). 

61 Fed. R. Civ. P. 26(c)(l)(E). 

62 While Mr. Stanford owns Redemption, he is not the company's only official, and therefore is 

not technically a "party" in this matter. 

Redemption, Inc. 

Administrator's Opposition to Redemption's Motion to Compel 

Docket No. FAA-2014-0115 

Page 9 
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Good cause exists for the Administrator objection to subjecting Insp. Bryant to Mr. 

Stanford's physical presence during her deposition. As described in detail above, in the summer 

of2013, Redemption was aware it was the target of an enforcement action initiated by Insp. 

Bryant. Upon seeing Insp. Bryant at Redemption's base, Mr. Stanford became enraged, yelling 

obscenities and other insults at her, physically confronting her, twice violently charging at her in 

his truck, then tracking her down in the airport some time later to confront her. Plainly, she is not 

safe in his presence. 

Out of respect for the process, the Administrator attempted to accommodate 

Redemption's discovery rights. The deposition would have occurred had Redemption been 

willing to either send a different representative or have Mr. Stanford participate via 

teleconference. Both reasonable accommodations that would have permitted Redemption to 

question Insp. Bryant about the events of the day in question. Both rejected without explanation. 

The only possible reason for Redemption's absolute insistence that Mr. Stanford be 

physically present for Insp. Bryant's deposition is that it intends to have him try to intimidate 

her. The Administrative Law Judge ("ALJ'') should recognize this tactic for what it is and deny 

Redemption's motion. 

B. Discovery Has Closed. 

Discovery closed on January 9, 2015.63 It lasted for nearly nine months, after the 

complaint was filed on April17, 2014 

Redemption did not formally notice Insp. Bryant's deposition until November 12,64 

setting it for November 20.65 When she did not appear, Redemption waited until December 31 to 

63 Amended Procedural Order, Oct. 7, 2014, at 1. 

64 Ex. M at2. 

65 Id. at 1. 

Redemption, Inc. 

Administrator's Opposition to Redemption's Motion to Compel 

Docket No. FAA-2014-0115 

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file the instant motion, giving no explanation for its 41 day delay. Redemption has also not 

requested that discovery be reopened. The motion, then, may be denied because it concerns 

discovery and discovery has closed. 

C. Barring Inw. Brvant from Testifying as a Discovery Sanction Would be Both 

Premature and Case-Ending. 

Redemption demands, as a result of Insp. Bryant's failure to appear at the deposition, that 

the Administrator be prevented from presenting her as a witness at hearing. In so doing, 

Redemption mischaracterizes the rule underlying witness preclusion as a sanction for a discovery 

violation. 66 

Under 14 CFR 13.220(n)(4), the ALJ may prevent a party from presenting certain witness 

testimony "[i]f [the] party has failed to comply with a discovery order or an order to compel." 

However, no discovery order or an order to compel has been issued in this matter. The rule does 

not apply. Nor should it, given the good cause explained above for keeping Mr. Stanford away 

from Insp. Bryant. 

The Administrator should incur no sanctions for refusing to direct Insp. Bryant to appear 

at a deposition it1 Mr. Stanford's physical presence, let alone the crushing, case-ending witness 

preclusion sanction Redemption demands. 

D. The Rules of Practice Do Not Allow for Money Sanctions for Discoverv 

Violations. 

In addition to witness preclusion, Redemption seeks monetary sanctions as a result of 

Insp. Bryant's failure to appear at the deposition, describing them as appropriate per Fed. R. Civ. 

P. 37.67 

66 Memorandum in Support of Motion to Compel Discovery or Impose Sanctions, at 3. 

67 Id. at 4-5. 

Redemption, Inc, 

Adminisrrator 's Opposition to Redemption's Motion to Compel 

Docket No, FAA-2014-0115 

Page 11 
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However, the Rules of Practice68 already specify the possible range of sanctions for 

discovery violations. Under both 14 CFR 13.217(±) and .220(n), the ALJ may: 

I) strike that portion of a party's pleadings; 

2) preclude prehearing or discovery motions by that party; 

3) preclude admission of that portion of a party's evidence at the hearing; or 

4) preclude that portion of the testimony of that party's witnesses at the hearing. 

That's it. Nowhere is there a sanction that would permit the ALJ to order that the moving 

party's expenses be paid. Moreover, those four sanctions have been described as serving in this 

forum the function that Rule 37 serves in the judicial branch.69 Nor is there any apparent 

precedent for a party to receive expenses for an alleged discovery violation, let alone one that 

preceded a discovery order or order to compel. The request for expenses should be denied. 

IV. Conclusion. 

For the foregoing reasons, Redemption's motion should be denied. 

DATED this~ of January, 2015. 

68 14 CFR 13, Subpart G. 

69 Matter ofLibertv Foundation. Inc., FAA Docket No. FAA-2012-0477, 2014 WL 1340047 

(Mar. 28, 2014 ) .. 

Redemption, Inc. 

Adminisrrator 's Opposition to Redemption's Motion to Compel 

Docket No. FAA-2014-0115 

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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that, on this day, I served a copy of the foregoing by the following 

means: 

One Copy via U.S. Mail, Postage Prepaid and by Facsimile: 

The Honorable Richard C. Goodwin 

U.S. Administrative Law Judge 

Attn: Patricia Matthews 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E.(E 11-31 0) 

Washington, DC 20590 

Fax: (202) 366-7536 

The Original and One Copy via U.S. Mall, Postage Prepaid and by Facsimile: 

Federal Aviation Administration 

ATTN: Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2W1000 

800 Independence Avenue, SW 

Washington, DC 20591 

FAX: (202) 267-1293 

One Copy via U.S. Mail, Postage Prepaid: 

Brent R. Cole 

Law Office of Brent R. Cole, P.C. 

821 N Street, Suite 208 

Anchorage, AK 99501 

DATED this~ of January, 2015. . 

12z;:,~,~ ~cv-;~10 Patricia L. Baysinger (/ (} 

Redemption. Inc. 

Administrator's Opposition to Redemption 's Motion to Compel 

Docket No. FAA-2014-0115 

Page 13 
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UNITED STATES DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

IN THE MATTER OF 

REDEMPTION, INC. 

DOCKET NO. FAA-2014-0115 

(Civil Penalty Action) 

DECLARATION OF CHRISTINA BRYANT 

I, Christina Bryant, declare as follows: 

1. I am an aviation safety inspector employed by the Federal Aviation Administration, 

Complainant in this matter, and my declarations herein are based on personal knowledge. 

2. On August 15 and 16,2013, I prepared a written report of the events surrounding my 

efforts as an inspector to review certain aviation records belonging to Redemption, Inc, in 

Kodiak, Alaska on August 15, 2013. 

3. Attached to this declaration is a true and correct copy of that report. 

4. In light of Mr. Stanford's behavior towards me on August 15, 2013, I prefer that he not 

be physically present if! am deposed in this matter. 

I declare under penalty of perjury that the foregoing is true and correct. 

DATED this __ day of January, 2015. 

Chiistina Bryant 

Exhibit A 

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On August 15, 2013, FAA Aviation Safety Inspector, Christina Bryant, was verbally and 

physically threatened by the Director of Operations of Redemption Air while at 

Redemption's main base of operations located atl420 Airport Way, Kodiak, Alaska 

99615. Inspector Bryant was on duty and assigned to conduct a follow-up records review 

of Redemption Air's load manifest due to an on-going federal investigation resulting 

from the company's systemic inability to accurately and completely prepare load 

manifests for their multi engine aircraft. 

Inspector Bryant arrived in Kodiak on ERA flight 888 armmd 11:00 AM and walked 

across the parking lot to the coffee shop and Redemption Air (Doing Business as Island 

Air). The two businesses are connected by a common waiting area for Island Air's 

passengers. Walking up to Island Air's reception desk with my identification tag hanging 

unobstructed from my neck, I made eye contact with a receptionist whom I have worked 

with before and gave a wave to indicate I would return when they were less busy booking 

paying passengers. I then walked to another operator to speak with them. 

Incident #l: 

Around 12:35, I returned to Island Air. I walked through the waiting area where multiple 

passengers were still waiting for their flight. I identified myself to the receptionist I 

waved at earlier and asked if Mr. Mike Gerber or Bob Stanford would be available for a 

quick follow-up records inspection. The receptionist informed me "Bob" would be 

arriving in a few minutes. I waited for his arrival by the restrooms, out of the way of 

company operations. When Mr. Stanford appeared from behind the reception desk, he 

asked me if he could help me. I indicated there was another gentleman that was waiting 

for him as well who arrived prior to me. Mr. Stanford insisted on working with me first. 

From across the reception desk, I shook Mr. Stanford's hand as I identified myself. I 

stated that I was here to conduct a follow up inspection and would like to review the load 

manifests. I asked him ifthere was a good time to meet with him or another person to 

accomplish this task. Mr. Stanford informed me that his wife just dislocated her shoulder 

and the next couple days would work. I replied that my flight home left at 3 this 

afternoon. He offered he could meet me at 3. I asked if there was anyone else that would 

be available for this follow-up i11spection. Mr. Stanford began to get very agitated and 

the volume of his voice increased to a constrained, agitated yell. Mr. Stanford began to 

slow his speech, using very pointed, short articulation. Mr. Stanford said no, he was 

going to do it. I then asked if he could do it any earlier. He sharply replied no. I 

indicated thatlt was a quick follow-up inspection that would take less than 5 minutes. At 

this point, he slammed the receptionist desk with his fist to emphasize his "damn it" and 

informed me very rnatter-of-factly that he will be here at 2. Mr. Stanford continued on 

with more inappropriate language, including the f-word, explaining that his "wife has 

fucking dislocated shoulder, laid up in bed, can't even wipe her own damn ass". l 

explained to him that 2 would be tight because I would like to be checked in an hour prior 

for my enroute home. During my reasoning, I was interrupted with Mr. Stanford's, very 

loud voice, using the f-word, leaning over the desk while trying to explain to me about 

his wife's dislocated shoulder. At this point, I put my hands up in a surrendering motion 

and I physically back up out of fear. I told him I am sorry about his wife and state that I A 

Exhibit --'--L....---

Page_d_ of Lf- pages 
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don't want to make a scene. Mr. Stanford turns and walks away into the back of the 

office. The receptionist closest to me looks at me, mouths to me "I'm sorry". I walk 

around the corner and stand in front of the company's large map, out of the way, and 

begin to text my Front Line Manager to make him aware of what just happened. 

About 2 minutes later, Mr. Stanford comes around the comer, sees me standing in front 

of the map and very aggressively tells me I need to leave. He opens the door to the 

outside, which swings open with force, and continues to yell, you are not welcome here. 

Mr. Stanford gestures I exit the premises in a hostile way using rapid, forceful motions. 

While I was frozen in disbelief, Mr. Stanford approaches me in long strides and, although 

he never physically touches me, Mr. Stanford proceeds to put his arm around to my back 

as though he is going to fling me toward the door. I jump forward and as I continue to 

move toward the door, Mr. Stanford is repeatedly yelling at me, "get off my damn 

property, you are not fucking welcome here, you don't give a damn about people". At 

this point he is now very close behind me and I can see his arms out both peripherals 

aggressively waving his arms in shooing motions as I move out the door. Be follows me 

onto the porch and then down the stairs. Mr. Stanford then steps in front of me, and 

continues to threaten and belittle me by yelling in my face how "(he) never wants to see 

me on (his) property again, I am not welcome here and how sick (his) wife is and (I) 

could give a shit about her." I again try to apologize about how sick his wife appears to 

be but can't get much across because of the volume of his voice and the uncontrolled 

behavior Mr. Stanford was displaying. 

Mr. Stanford then walks to his red, with tan trim, truck. He opens the driver side door 

and yells at me again warning me "to stay out of his aircraft". He gets in and slams the 

door. The next thing I realize is I hear tires screeching on the pavement as he backs out 

of his parking spot next tO the fence separating the ramp from the parking lot. I 

physically jump because I realize I am in his direct path, if he were to continue 

backwards. He stops the truck abruptly, strains his head out of the window because he 

has to look directly bacl< at me and says in a very angry, unrestrained voice that he will 

not be back at two. 

Incident #2: 

After this incident, I spoke with my FLM and decided to go directly to the Alaska 

Airlines main terminal because it was the busiest, safest place I could think of. There I 

immediately sat down and documented what occurred. I ensured I sat in a spot not in 

direct line with the door but could make sure no one could approach me without warning. 

Around 13:55, I headed out to the parking lot to take photos to document the skid marks 

left by Mr. Stanford. While doing this, I heard a vehicle engine rev up which seemed to 

be coming from the direction of the Island Air ramp. Alarmed, I looked up and saw 

through the chain link fence, Mr. Stanford's red, with tan trim, truck speeding directly 

toward me. Again, I am frightened he will not stop. In survival mode I dash out of the 

immediate threat as the truck comes to an abrupt stop 5-l 0 feet from the fence. As my 

adrenaline spikes, I can hear my own heart pounding rapidly. l tum and swiftly walk 

back towards the Alaska Airlines terminal. While I am walking, I hear the door of the 

txllibit -iL.~-

Pags_3. ___ ,,I·-· Lj_Pcl'~-': 

" t - .,.·,-·-·-·- .:? - . • .. . i l,, !. 
2015-01-15 15:45 ARCALROLEG02 9072712800 » 2024935142 p 18/43 

truck slam and tum my head and see Mr. Stanford walk toward his building in a very 

angry, purposeful manner, I pass a TSA gentleman on the sidewalk of the Alaska 

Airlines terminal. As I enter the Alaska Airlines building, I glance back and notice Mr. 

Stanford is coming across the parking lot. I fumble with my phone as I walk up to the 

ticket counter, There are only 2 or 3 women behind the ticket counter. I manage to get 

my phone onto video, just in case something happens, just as Mr. Stanford enters the 

terminal and walks directly towards me. He approaches me in a more controlled manner 

than the previous encounter. Mr. Stanford immediately offers me the opportunity to go 

over and look at the requested documents at Island Air in April's office. Knowing there 

is a TSA guy outside, I offer to take the conversation outside. I stop on the ramp just 

outside of the door where Mr. Stanford continues to unload his frustrations on me. I do 

not speak a word and listen to him as he becomes more emotionally charged and 

moreangry as he vents. During this time, Mr. Stanford becomes more animated and 

begins to poke his fingers within inches of me to emphasize his comments in an 

intimidating, threating way invading. Mr. Stanford also violated my personal space by 

stepping too close. using inappropriate hand gestures. I would back up each time I felt 

threatened, however, he would step toward rne to closing the gap. During this time, Mr. 

Stanford even used the "f-u" hand gesture, swinging his uncomfortably close to my 

abdominal area. I ended the conversation by interrupting Mr. Stanford by expressing my 

need to go check in to my flight. I tell him thank you and walk back into the terminal. 

(hindsight, I am not sure what I thanked him for) 

At 14:24, I texted a fellow inspector who was assigned to travel to Kodiak the next day, 

Friday August 16, in light of these incidents. While we were coordinating where we 

would leave the car keys, I mentioned to him that I was hungry, but had nowhere to get 

food. I explained to him that the coffee shop is in the same building as Island Air; where 

I was earlier threatened and escorted off the property. The other option for food was to 

get in 1he Government Car and drive into town, However, this was even more-so risky 

because the G-Car is located in a private parking lot immediately behind and obstructed 

from public view by the Island Air building. The Island Air ramp is adjacent to this 

parking lot with the car normally parked up against the fence that separates the two. 

At 14:55, I called Island Air and asked to speak with April, the person Mr. Stanford left 

the requested documents with, for my review. During the conversation, I made it clear 

that, unfortunately, because of the happenings of earlier this afternoon, I did not feel 

comfortable to go back to Island Air. I told her I appreciated her willingness to have 

these·docurnents available and wanted to be courteous so she wasn't waiting for. She 

thanked me and didn't blame me for my decision. 

iExill!lldt - .. -/{ __ _ 

Fi'ag8__/d_ •.11 .. L£~~eq2c 
2015-01-15 15:46 ARCALROLEG02 9072712800 » 2024935142 p 19/43 

U.S. Deportment 

of Tronsportatlon 

Federal Avlctlon 

Administration 

Anchorage Flight Standards District Office 

Alaskan Region 

CERTIFIED MAIL- RETURN RECEIPT REQUESTED 

April18, 2013 

Redemption Air (R19C) 

Robert Stanford President 

P.O. Box 125 

Kodiak, Alaska 99615 

Mr. Stanford: 

SOC W. ~sm Ave, Suite 101 

Anchorage, AK 99503-5815 

Phone: (907) 271-2000 

Fax: (907) 271-4777 

1·800·294-5116 

After a recent records inspection at your base of operations at Kodiak, Alaska on April13, 

2013, personnel of this office are investigating company compliance with weight and 

balance and load manifest requirements on the multi-engine aircraft on the Redemption Air 

Operation Specifications. Our available information indicates weight and balance has not 

been sufficiently calculated or recorded; therefore, these actions may be contrary to the 

regulations. 

This letter is to inform you that these matters are under investigation by the Federal Aviation 

Administration. We wish to give you the opportunity to present any evidence or statements 

you might care to make regarding this matter within ten (10) days of receipt of this letter. 

Any discussion or written statement furnished by you will be given consideration in our 

investigation. My telephone number is (907) 271-2131. 

Sincerely, ., 

~ 

.... :--.-;,:-:-:.r.~~ /'.~~-

-- (... - Christina Bryant 

Principal Operations Inspector 

i:J(flibit _ ... 8=::. __ _ 

?ag;;_,_J,_ of ... -Lpagsa 

I I 
2015-01-15 15:46 

U. S. Department 

of Transportation 

Federal Aviation 

Administration 

ARCALROLEG02 

Case No. 2013AL030070 

APR 10 2.014 

9072712800 » 

Alaskan Region 

Office of' the Rt:gional Counsel 

CERTIFIED MAIL-RETURN RECEIPT REQUESTED 

Robert G. Stanford, President 

Redemption, Inc. 

P.O. Box 25 

Kodiak, AK 99615 

2024935142 p 20/43 

222 W. 7th Avenue #14 

Allchoroge, Alosko 99513-7587 

PH: (907) 271-5271 

fAX: (907) 271·2800 

ORDER ASSESSING CIVIL PENALTY 

On November 5, 2013, Redemption, Inc., (Redemption) was advised through a Notice of 

Proposed Civil Penalty that the FAA proposed to assess a civil penalty in the amount of $7500. 

We have considered the information submitted in response to this Notice. On March 14, 2014, 

Redemption accepted our offer to settle this matter under the terms contained herein, but this 

· office did not learn of Redemption's acceptance tmtil after a Final Notice of Proposed Civil 

Penalty was served on March 18, 2014. 

In accordance with the settlement agreement, after considering all the evidence in this matter, 

including the information presented during the informal conference on February 11, 2014, it has 

been determined that: 

1. At all times mentioned herein, Redemption was the holder of Air Carrier Certificate No. 

RI9A557W and appropriate operations specifications authorizing it to conduct on-demand 

and commuter operations under part 13 5 of the Federal Aviation Regulations (FAR) using 

the business names "Island Air" and "Island Air Service." 

2. On or about March 30, 2013, Redemption operated civil aircraft N5891 V, a Britten-Norman 

Model BN-2A-26 Islander, a multiengine airplane, on a passenger-carrying flight in air 

commerce that was subject to part 135 of the FAR from Kodiak, Alaska, to Old Harbor, 

Alaska. 

3. On or about April!, 2013, Redemption operated civil aircraft N5891 Von a passengercarrying flight in air commerce that was subject to part 135 of the FAR from Karluk, Alaska, 

to Kodiak, Alaska. 

4. On or about April 1, 2013, Redemption operated civil aircraft N5891V on a passengercarrying f\ight in air commerce that was subject to part 135 of the FAR from_Po,-t,Lions, (1 

Alaska, to Kodiak, Alaska. J:ltniO!t -- c 

Page;. :.J.._ of _,3_1~gea 
2015-01-15 15:46 ARCALROLEG02 9072712800 » 2024935142 p 21/43 

5. On or about April 1, 2013, Redemption operated civil aircraft NS891 Von a passengercarrying flight in air commerce that was subject to part 135 of the FAR from Larsen Bay, 

Alaska, to Karluk, Alaska. 

2 

6. On or about April 1, 2013, Redemption operated civil aircraft N5891V on a passengercarrying flight in air commerce that was subject to part 135 of the FAR from Kodiak, Alaska, 

to Larsen Bay, Alaska. 

7. On or about April 2, 2013, Redemption operated civil aircraft N5891V on a passengercarrying flight in air commerce that was subject to part 135 of the FAR from Kodiak, Alaska, 

to Old Harbor, Alaska. 

8. At the time of each ofthe above flights, Redemption had not prepared a load manifest that 

included the actual total weight of the loaded aircraft or the center of gravity of the loaded 

aircraft. 

9. The operation of civil aircraft NS891 Vas described above was careless or reckless so as to 

endanger the life or property of another. 

Based on the foregoing facts and circumstances, Redemption violated the following Federal 

Aviation Regulations: 

(a) Section 91.13(a) in that Redemption operated an aircraft in a careless or reckless manner 

so as to endanger the life or property of another. 

(b) Section 135.63( c)(2) in that Redemption operated a multi engine aircraft under part 13 5 of 

the FAR when it had not prepared a load manifest that included the total weight of the 

loaded aircraft. 

(c) Section 135.63(c)(5) in that Redemption operated a multiengine aircraft under part 135 of 

the FAR when it had not prepared a load manifest that included the center of gravity of 

the loaded aircraft. 

THEREFORE, IT IS ORDERED, pursuant to 49 U.S.C. § 4630l(d)(2), that Redemption be, and 

hereby is, assessed a civil penalty in the amount of $6,000.00. 

We hereby acknowledge receipt of your electronic payment in the runount of $6,000.00, which 

we accept in full satisfaction of this matter. You may consider this matter closed. 

HOWARD L. MARTIN, JR 

Regional Counsel 

By: 

Glenn H. Brown · 

Senior Attorney 
2015-01-15 15:47 ARCALROLEG02 9072712800 » 2024935142 p 22/43 

3 

CERTIFICATE OF SERVICE 

I hereby certifY that this Order has been mailed this date by certified mail, addressed to: 

Robert G. Stanford, President 

Redemption; Inc. 

P.O. Box 25 

Kodiak, AK 99615 

Federal Aviation Administration 

Office of the Regional. Counsel 

222 W. 7th Avenue, #14 

Anchorage, AK 99513-7587 
2015-01-15 15:47 

Black. Craig (FAA) 

From: 

Sent: 

To; 

Cc; 

Subject: 

Brent, 

ARCALROLEG02 9072712800 » 

Skrocki, Steven (USAAK) <Steven.Skrocki@usdoj.gov> 

Tuesday, January 13, 2015 4:20 PM 

Brent Cole (brent@akcolelaw.com) 

Black, Craig (FAA); Allison, Daryl (FBI) 

Redemption Air-Stanford 

2024935142 p 23/43 

Our office has elected to proceed against Mr. Stanford on his actions against the FAA Inspector and prosecute the 

case. I will advise when we will file the charges. Just wanted to give you notice as It appears administrative action of 

some type appears imminent. 

-Steve 

Steven E. Skrocki 

Assistant UnHed States Attorney 

Senior LHigation Counsel 

Dtsnucr or AL.\SKA 

222 W. 7 ... Ave. I Room 253 I Anchorage, Alaska 99513 

~907-271-3390 I"' 907-271-1.500 I :.:::1 steven.skrocki@usdoj.gov 

i:nflibit __ .L_ -
2015-01-15 15:47 

Black. Craig (FAA) 

From: 

Sent: 

To: 

Subject: 

Brent, 

ARCALROLEG02 9072712800 » 

Black, Craig (FAA) 

Tuesday, June 03, 2014 3:38 PM 

'Brent Cole' 

RE: Redemption Air 

I will, I'm having to do some coordination with OOJ on this, but we'll make her available. 

Craig Wm. Black, Attorney 

FAA: Alaskan Region 

(907) 271-3570 

From: Brent Cole fmallto:brent@akcolelaw.com] 

sent: Monday, June 02, 2014 6:04PM 

To: Black, Craig (FAA) 

Cc: Karin Gustafson 

Subject: Redemption Air 

Craig: 

2024935142 p 24/43 

Please let me know when your complaining witness (Ms. Bryant) will be available to be deposed regarding this 

case. Thanks. 

Our address is; 

Law Office of Brent R. Cole, P. C. 

821 N Street, Suite 208 

Anchorage, Alaska 99501 

Our Telephone Number; (907) 277-8001 

Our Fax Number; (907) 277-8002 

WARNING: The information contained in this email (including any attachments) is CONFIDENTIAL and may contain 

PRIVILEGED COMMUNICATIONS. If you are not the Intended recipient of this email, you may not read, retain, copy, distribute, 

or disclose the content of this email. If you have received this email in error, please advise us by calling (907) 277-8001 and/or by 

return email. Thank you. 

Law Office of Brent R. Cole, P.C. 

..---.

,.-_ :.,:(!~~\;;'.: - f.::;-

1 
2015-01-15 15:47 

Black, Craig (FAA) 

From: 

Sent: 

To: 

Subject: 

Attachments: 

Brent, 

ARCALROLEG02 

Black, Craig (FAA) 

Friday, July 18, 2014 8:27AM 

'Brent Cole' 

Houlton, Redemption 

9072712800 » 

Superseding Order following Settlement, Revised.pdf 

2024935142 p 25/43 

Got your message yesterday. Attached Is the revised order I'd like to Issue in the Houlton matter. As requested You'll see 

that I've removed all references to the weather conditions and the weather observers from both the findings and the 

determination of emergency, making this merely a case about Mr. Houlton's careless (not reckless) failure to maintain 

altitude during approach, which ultimately led to him crashing short of the runway. I think this should take care of your 

concerns. Please review and advise. 

As for Redemption Air, nothing seems to have changed since we last spoke. In my view, enough time has passed since 

Christina Bryant gave birth that I'm not so hesitant to ask her to sit for a depo, if that's what you'd like. I haven't spoken 

to Steve Skroki in a few weeks-though, and as I've explained our first priority Is to not Interfere with his prosecution, so 

I'll be coordinating the depo with him if that's what you want. I am surprised that Judge Goodwin hasn't set the hearing 

yet. 

Anyhow, take a look at this draft and let me know your thoughts, I think It addresses all of your concerns. 

Craig Wm. Black, Attorney 

FAA: Alaskan Region 

(907) 271-3570 

~J(ilitJic ·-- __ }:::_ __ _ 

1 
2015-01-15 15:47 ARCALROLEG02 9072712800 » 

LAWOI'l'TC~ OF 

BRENT R. COLE, P.C. 

DRE.NTR. COl.l!:-brc:nt@nkcolclaw.com 

PATRICI{ N. DERGT-putrl~ll@nkc:olelaw.conl 

VIA E-MAIL- craif!.black@faa.r:ov 

Craig Black, Esq. 

Office of the Regional Counsel 

222 West 7th Avenue, #14 

Anchorage, AK 99513 

8:21 N STREET, S'UlTE:tOB 

A-NCHORA0f.1 t-I.ASKA !l95111-~ll6 

October 7, 2014 

Re: Robert G. Stanford, Redemption, Inc, 

Case File No. 2013AL030106 

0Ul' File No. 139.078 

Dear Craig: 

2024935142 p 26/43 

TELEPHONE (907) l77-8001 

"r'ELECOPI~R (PC\7) 277-SOO:Z: 

With the Court's recent order, I am again requesting that you make available Ms. 

Christina Bryant for deposition. Please let me know Ms. Bryant's and your availability so we 

can schedule her deposition. 

Very truly yours, 

LAW OFFICE OF BRENT R. COLE, P.C. 

-s~OL 

Brent R. Cole 

BRC/ksg 

cc: Client 
2015-01-15 15:48 ARCALROLEG02 9072712800 » 

Slack. Craig (FAA) 

From: 

Sent: 

To: 

Subject: 

Attachments: 

Brent Cole <brent@akcolelaw.com> 

Wednesday, October 08, 2014 10:43 AM 

Black, Craig (FAA) 

RE: Brent Cole Letter--Redemption, Inc. 

Brent R Cole.vd 

I'll let you know next week on the timing for Ms. Bryant, 

Brent Cole 

Our address is: 

Law Office of Brent R. Cole, P. c. 

821 N Street, Suite 208 

Anchorage, Alaska 99501 

our Telephone Number: (907) 277-8001 

Our Fax Number: (907) 277-8002 

2024935142 p 27/43 

WARNING: The information contained In this email (including any attachments) Is CONFIDENTIAL and may contain 

PRIVILEGED COMMUNICATIONS. If you are not the intended recipient of this email, you may not read, retain, copy, 

distribute, or disclose the content of this email. If you have received this email in error, please advise us by calling (907) 

277-8001 and/or by return email. Thank you. 

Law Office of Brent R. Cole, P.C. 

From: Cralg.Siack@faa.gov [mallto:Cralg.Biack@faa.gov] 

Sent: Wednesday, October 08, 2014 9:39AM 

To: Brent COle 

Cc: Karin Gustafson 

Subject: RE: Brent Cole Letter--Redemption, lnc. 

Dear Brent, 

Thank you for your letter of yesterday, I spoke to Christina Bryant yesterday morning, she's back at work from her 

materniW leave. She indicated that she's generally available to be deposed, so let's do this, To suggest some dates, after 

looking at my calendar I think I could schedule It for pretty much anytime during the week of October 27. 

As for the USDOJ angle of this, I also spoke to Steve Skroki yesterday and told him you'd asked to depose Bryant. He told 

me DOJ was evaluating what it wanted to do with the case and would get back to me. You can expect me to coordinate 

with DOJ, but absent any specific objection from them I think we should just proceed In this civil penalty action with 

Redemption, now that Judge Goodwin's Indicating he hasn't forgotten about the case and is starting to think of 

scheduling it for early next year. 

So let me know when you'd like to depose Ms. Bryant and I'll coordinate that. And we'll see you here tomorrow In the 

Robyn Surk matter. 

::~il•:~h , ... H_ .. ___ .. 

. ,.",:'' J ... Q .. nt;re! 

1 
2015-01-15 15:48 

Craig Wm. Black, Attorney 

FAA: Alaskan Region 

(907) 271-3570 

ARCALROLEG02 

From: Karin Gustafson [mallto:Karln@AKColelaw.com] 

Sent: Tuesday, October 07, 2014 5:17 PM 

To: Black, era lg (FAA) 

Subject: Brent Cole Letter--Redemption, Inc. 

9072712800 » 

Attached is a letter to you from Brent Cole. Please let us know If you have any questions. 

Karin Gustafson 

Law Office of Brent R. Cole, P.C. 

821 N Street, Suite 208 

Anchorage, Alaska 99501 

(907) 277-8001 (voice) 

(907) 277-8002 (fax) 

karin@akcolelaw.ccm(email) 

2024935142 p 28/43 

WARNING: The information contained In thiS email (Including any attachments) is CONFIDENTIAL and may be 

PRIVILEGED COMMUNICATIONS. If you are not the Intended recipient of this email, you may not read, retain, copy, 

distribute, or disclose the content of this email. If you have received this email in error, please advise us by calling (907) 

277-8001 and/or by return email. 

2 
2015-01-15 15:48 

Black, Craig (FAA) 

From: 

Sent: 

To: 

Subject: 

Attachments: 

ARCALROLEG02 9072712800 » 

Brent Cole <brent@akcolelaw.com> 

Tuesday, October 28, 2014 4:38 PM 

Black, Craig (FAA) 

RE: Brent Cole Letter--Redemption, Inc. 

Brent R Cole.vcf 

2024935142 p 29/43 

I would like to take Ms. Bryant's deposition the week of November 17, 2014, Please advise a time convenient to you end 

Ms. Bryant. Thank you. 

Brent Cole 

our address is: 

Law Office of Brent R. Cole, P. C. 

821 N Street, Suite 208 

Anchorage, Alaska 99501 

Our Telephone Number: (907) 277-8001 

our Fax Number: (907) 277-8002 

WARNING: The information contained in this email (including any attachments) Is CONFIDENTIAL and may contain 

PRIVILEGED COMMUNICATIONS. If you are not the intended recipient of this email, you may not read, retain, copy. 

distribute, or disclose the content of this email. If you have received this email In error, please advise us by calling (907) 

277-8001 and/or by return email. Thank you. 

Law Office of Brent R. Cole. P.C. 

From: era lq. Slack@faa .gov [ma lito :Cra lg .Biack@faa.gov] 

Sent: Wednesday, October 08, 2014 9:39AM 

To: Brent Cole 

Cc: Karin Gustafson 

Subject: RE: Brent Cole Letter--Redemption, Inc. 

Dear Brent, 

Thank you for your letter of yesterday. I spoke to Christina Bryant yesterday morning, she's back at work from her 

maternity leave. She indicated that she's generally available to be deposed, so let's do this. To suggest some dates, after 

looking at my calendar I think I could schedule it for pretty much anytime during the week of October 27. 

As for the USDOJ angle of this, I also spoke to Steve Skroki yesterday and told him you'd asked to depose Bryont. He told 

me DOJ was evaluating what it wanted to do with the case and would get back to me. You can expect me to coordinate 

with DOJ, but absent any specific objection from them I think we should just proceed in this civil penalty action with 

Redemption, now th1lt Judge Goodwin's indicating he hasn't forgotten about the case and is starting to think of 

scheduling it for early next year. 

So let me know when you'd lil<e to depose Ms. Bryant and I'll coordinate that. And we'll see you here tomorrow in the 

Robyn Burk matter. idrlil~llllut .::Z:: 

1 
2015-01-15 15:48 

Craig Wm. Black, Attorney 

FAA: Alaskan Region 

(907) 271-3570 

ARCALROLEG02 

From: Karin Gustafson [mailto:Karln@AKColelaw.com] 

Sent: Tuesday, October 071 2014 5:17PM 

To: Black, Craig (FAA) 

Subject: Brent Cole Letter-Redemption, Inc. 

9072712800 » 

Attached is a letter to you from Brent Cole. Please let us know If you have any questions. 

Karin Gustafson 

Law Office of Brent R. Cole, P.O. 

821 N Street, Suite 2 08 

Anchorage, Alaska 99501 

(907) 277-8001 (voice) 

(907) 277-8002 (fax) 

karin@akcolelaw com( email) 

2024935142 p 30/43 

WARNING: The information contained In this email (Including any attachments) Is CONFIDE:NTIAL and may be 

PRIVILE:GED COMMUNICATIONS. If you are not the intended recipient of this email, you may not read, retain, copy, 

distribute, or disclose the content of this email. If you have received this email in error, please advise us by calling (907) 

277-8001 and/or by return email. 

2 
2015-01-15 15:49 

Black, Craig (FAA) 

From: 

Sent: 

To: 

Subject: 

ARCALROLEG02 9072712800 » 

Black, Craig (FAA) 

Thursday, October 30, 2014 9:28AM 

'Brent Cole' 

RE: Timber Houlton commercial license 

2024935142 p 31/43 

Let's pencil In Christina Bryant for Thursday, Nov 20, 9A, I presume at your office. Also, Timbre Houlton can expect a call 

from the Fairbanks FSDO re his temporary. 

Craig Wm, Black, Attorney 

FAA: Alaskan Region 

(907) 271-3570 

From: Brent Cole [mallto:brent@akcolelaw.com] 

Sent: Thursday, October 30, 2014 8:08AM 

To: Black, Craig (FAA) 

subject: RE: Timber Houlton commercial license 

Please let me know when Ms. Bryant will be available for deposition the week of November 18-21. Thank you. 

Brent Cole 

Our address is: 

Law Office of Brent R. Cole, P. C. 

821 N Street, Suite 208 

Anchorage, Alaska 99501 

Our Telephone Number: (907) 277-8001 

Our Fax Number: (907) 277-8002 

WARNING: The information contained in this email (including any attachments) Is CONFIDENTIAL and may contain 

PRIVILEGED COMMUNICATIONS. If you are not the intended recipient of this email, you may not read, retain, copy, 

distribute, or disclose the content of this email. If you have received this email in error, please advise us by calling (907) 

277-8001 and/or by return email. Thank you. 

Law Office of Brent R. Cole, P,C. 

From: Cralg.Biack@faa.gov [mallto:Cralg.Biack@faa.gov] 

Sent: Wednesday, October 29, 2014 2:55 PM 

To: Brent Cole 

Subject: RE; Timber Houlton commercial license 

Brent, 

I'll work on getting a tempororY with commercial privileges for Mr. Houlton so that it's available to him on Friday, I'll· 

contact you when It's ready, shouldn't be difficult. Though Mr. Houlton will need to apply to Oklahoma City himself to 

get his commercial privileges on a permanent certificate like he likely did to get his private privileges this summer. 

1 
2015-01-15 15:49 ARCALROLEG02 9072712800 » 2024935142 p 32/43 

As for Ms. Bryant and Stanford/Redemtlon, I've spoken to her and should be able to do her deposition November 18-21, 

I'll let you specify a date and time. I've also again asked DOJ today to get off the pot and figure out what they want to do 

.with the criminal aspect of this, so you may hear something from them very soon. 

Craig Wm. Black, Attorney 

FAA: Alaskan Region 

(907) 271-3570 

From: Brent Cole [mallto:brent@akcolelaw.com] 

Sent: Wednesday, October 29, 2014 2:07 PM 

To: Black, Craig (FAA) 

Subject: Timber Houlton commercial license 

Craig: 

Will his certificate be sent soon? 

Our address is: 

Law Office of Brent R. Cote, P. C. 

821 N Street, Suite 208 

Anchorage, Alaska 99501 

Our Telephone Number: (907) 277-8001 

Our Fax Number: (907) 277-8002 

WARNING: The information contained in this email (including any attachments) is CONFIDENTIAL and may contain 

PRIVILEGED COMMUNICATIONS. If you are not the intended recipient of this email, you may not road, retain, copy, distribute, 

or disclose the content of this email. If you have received this email in error, please advise us by calling (907) 277"8001 and/or by 

return email. Thank you. 

Law Office of Brent R. Cole, P.C. 

2 
2015-01-15 15:49 

Slack. Craig (FAA) 

From: 

Sent: 

To: 

Cc: 

Subject: 

ARCALROLEG02 9072712800 » 

Black, Craig (FAA) 

Wednesday, November 05, 2014 1:47 PM 

'Brent Cole' 

Brown, Glenn (FAA) 

RE: Bryant Depo 

2024935142 p 33/43 

Just to be clear: our case is against Redemption, and we have no problem with a Redemption representative being 

present. We have a problem with Mr. Stanford being present. If this was a run-of-the-mill case where the the 

respondent's DofO hadn't been assaultive towards our ASI and he wasn't facing criminal prosecution because of it, we 

wouldn't need to Insist on this stipulation. But he was, and so we do, 

Let us know your position, you deserve time to prepare a motion to compel if necessary. 

I'll be on leave starting tomorrow and back on Nov l7, with Glenn Brown covering In my absence. 

Craig 

From: Brent Cole [mai!tg:brent@akcolelaw.com] 

Sent: Wednesday, November OS, 2014 12;48 PM 

To: Black, Craig (FAA) 

Subject: Re: Bryant Depo 

Crag 

I will discuss your request with my client but do not expect my agreement with your request. My client has a 

right to be present In this action at any depositions and my expectation is you will need an order from the 

judge excluding him from being present. 

Sent from my HTC 

---- Reply message .,,_ 

From: "Cralg.Biack@faa.gov" <Craig.Biack@faa.gov> 

To: "Brent Cole" <brent@akcolelaw.com> 

Subject: Bryant Depo 

Date: Wed, Nov 5, 20:1.4 12:31 PM 

Brent, 

For Christina Bryant's depo, we'll need to agree that Mr. Stanford will not be present, either during the deposition or Its 

vicinity, I've spent more time with her of late, and It's apparent to me that he truly shook her that day, so I Intend to 

hold her exposure to him to an absolute minimum. And given DOJ's Interest in this, I don't think Judge Goodwin will 

have a problem enforcing this detail. 

I'm keeping this penciled In at the time I suggested: Nov 20 at 9A. 

l 
2015-01-15 15:49 

Craig Wm. Black, Attorney 

F'AA: Alaskan Region 

(907) 271-3570 

ARCALROLEG02 9072712800 » 2024935142 p 34/43 

2 
2015-01-15 15:49 

Black, Craig (FAA) 

From: 

Sent: 

To: 

Subject: 

Attachments: 

ARCALROLEG02 9072712800 » 

Brent Cole <brent@akcolelaw.com> 

Friday, November 07, 2014 2:05 PM 

Black, Craig (FAA) 

deposition 

Brent R Cole.vcf 

2024935142 p 35/43 

we will be Issuing a notice of deposition for Ms. Bryant. My client, Mr. Stanford, Is the owner of Redemption and will 

not waive his right to be present. Thank you. 

Our address is: 

Law Office of Brent R. Cole, P, C. 

821 N Street, Suite 208 

Anchorage, Alaska 99501 

Our Telephone Number: {907) 277-8001 

Our Fax Number: (907) 277-8002 

WARNING: Tho information contained in this email (including any attachments) io CONFIDENTIAL and may contain 

PRIVILEGED COMMUNICATIONS. If you are not the intended recipient of this email, you may not road, retain, copy, distribute, 

or disclose the content of this email, If you have received this email in error, please advise us by calling (907) 277-800! and/or by 

rotum email. Thank you. 

Law Office of Brent R. Cole, P.C. 

L-__ 

?~!m!Ei~·· .,.L_ nt . ./ .... :· 

l 
2015-01-15 15:50 

.! 

~ ,I 

ARCALROLEG02 

\ 

Brent R. Cole 

Law Office of Brent R. Cole, P.C. 

821 N Street, Suite 208 

Anchorage, AK 99501 

(907) 277-8001 

Attorn.eys for Redemption Air, Inc. 

9072712800 » 2024935142 p 36/43 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASIDNGTON,DC 

In the matter of: 

Redemption Air, Inc. 

) 

) FAA Case No. 2013AL030106 

) Docket No. FAA-2014-0115 

(Civil Penalty Action) 

NOTICE OF DEPOSITION OF CHRISTINA BRYANT 

PLEASE TAKE NOTICE that Redemption Air, Inc., pursuant to 49 CFR § 821.!9, will 

take the video deposition of Christina Bryant, before a Notary Public or some other person 

qualified to take oaths, in the Law Office of Brent R. Cole, P.C., Anchorage, Alaska, on 

November 20, 2014, at 9:00 am, and said examination will continue from day to day until 

completed. You are invited to attend and examine if you so desire. 

DATED this /!'~day of November, 2014, at Anchorage, Alaska. 

LAW OFFICE OF BRENT R. COLE, P.C. 

Attorneys for Redemption Air, Inc. 

NOTICE OF DEl'OS!TION OF CHRISTINA BRYANT 

In re: Redemption Air, Inc.; Docket No. FAAn2014~0115 

Poge I of2 
2015-01-15 15:50 ARCALROLEG02 

) 

CERTIFICATE OF SERVICE 

This is to certify that on this 'f)_[ day ofNovcmber, 

20 14, a true and .correct copy~oregoing document 

was 

0 Mallcd 

• Fax~:d 

-~ Hand-delivered 

to the fall wing: 

Craig Wm. Blac~ Esq. 

Office of the Regional Couns~l 

222 West 7th Avenue, #14 

Anchorage, AX 995 13·7587 

Cmjg B\Mk¥1\fi)ll.gov 

Fax: 27 I -2800 

cC~~~ 

9072712800 » 

NOTICE OF DEPOSITION OF CHRISTINA BRYANT 

In re: Redemption Air, Inc., Docket No. FAA-2014-0115 

Pa~o 2 of2 

2024935142 p 37/43 
2015-01-15 15:50 ARCALROLEG02 9072712800 » 

U.S, Department 

ofTrnnsportntion 

Federal Aviatlon 

Administration 

VIA MAIL AND FAX 

Brent R. Cole 

Law Office of Brent R. Cole, P.C. 

821 N Street, Suite 208 

Anchorage, AK 99501 

RE: 

Our file: 

Dear Brent, 

Redemption Inc. 

2013AL030106 

Alaskan Region 

Office of the Regional Counsel 

222 West Seventh Avenue #14 

Anchorage, Alaska 99513-7587 

November 17,2014 

2024935142 p 38/43 

(907) 271-3570 voice 

(907) 271-2800 fa:x 

craig.black@f~utgov ema(/ 

As I have made clear for months, the FAA is willing to allow Redemption Inc. to depose 

Christina Bryant. The only condition we have placed is that Robert Stanford not be present. As 

I've explained, Mr. Stanford's assaultive behavior towards Ms. Bryant on the day in question 

was such that we intend to minimize Ms. Bryant's exposure to him. As I have also explained, we 

have no objection to the presence of any other Redemption representative at the deposition. 

I take it from your recent email that, despite all that, Mr. Stanford intends to be present at Ms. 

Bryant's deposition. Therefore, please take note that, unless you promptly confirm to me that Mr, 

Stanford will not be present, either in the room or its vicinity, Ms. Bryant will not attend. 

Sincerely, 
2015-01-15 15:50 ARCALROLEG02 9072712800 » 

LAWOP1'1C~Otr 

BRENT R. COLE, P .C. 

BRE.NT R. COLE-bunt@alu:;ct~I.4W.I:~M 

P;\ 'I'I\ICK N. BERGT-patriek@ak~qtehlWo~om 

VL4 E-MAIL- craig.black@tiu:,go~ 

Craig Black, Esq. 

Office of the Regional Counsel 

222 West 71:)1 Avenue, #14 

Ancb.orage, AK 99513 

&21 N STREF;T,SUlTE:lOS 

ANCHORAGE.; ALASKA 99~01-1136 

November 17,2014 

Re: Robert G. Stanford, Redemption, Inc. 

Dear Craig: 

Case File No. 2013AL030106 

Our File No. 139.078 

) 

2024935142 p 39/43 

TELEPHONE (90?) 277wl001 

T~I,.:~COi>II:;R (9Q7}277..SOO:Z 

As we have previously discussed, my client has a right to be present at Ms. 

Bryant's deposition. If Ms. Bryant fails to show for he~ deposition on November 20, 

2014, we will seek sanctions against the government. 

Very truly yours, 

LAW OFFICE OF BRENT R. COLE, P.C. 

~,C.L 

Brent R. Cole 

BR.C/cdb 

cc: Clic:nt 

I .,., 
2015-01-15 15:50 

U.S. Department 

of Transportation 

Federal Aviation 

Administration 

ARCALROLEG02 

VIA MAIL AND FAX 

Brent R. Cole 

Law Office of Brent R. Cole, P.C. 

821 N Street, Suite 208 

Anchorage, AK 99501 

RE: 

Our:fLle: 

Dear Brent, 

Redemption Inc. 

2013AL0301D6 

9072712800 » 

Alask:m Region 

Office of the Rt!gional Counsel 

222 West Seventh Avenue #14 

Anchomgo, Alaska 99513-7587 

November 18, 2014 

2024935142 p 40/43 

(907) 271-3570 vole< 

(907) 271·2800 fa> 

cmlg.blnck@fna.gov email 

I have received the letter you emailed to me today insisting on Mr. Stanford's presence at Ms. 

Bryant's deposition. 

As a compromise, we would be willing to allow the deposition to include th~ use of our 

Anchorage video conferencing facilities, facilities you found acceptable for the Robyn Burk 

deposition just last month. We could, for example, have Mr. Stanford participate from the 

Anchorage FSDO while Ms. Bryant participates here in our office in the federal building. 

I would need to con:fm the availability of the facilities, but I'd be willing to make that 

arrangement if you find it acceptable. So please let me know. 

Sincerely, 

HOWARD L.tv.LARTIN, JR 

Regional Counsel 

By: 
2015-01-15 15:51 

i31ac:k. Craig (FAA) 

From: 

Sent: 

To: 

Cc: 

Subject: 

ARCALROLEG02 9072712800 » 

Black, Craig (FAA) 

Wednesday, October 08, 2014 2:47 PM 

'Karin Gustafson' 

'Brent Cole' 

RE: Robyn Burk Depo 

2024935142 p 41/43 

I understand your concern. Our technology hasn't always been ideal, and I always sweat these kinds of details too. 

However, I did test the system about an hour ago and it worked just fine, I was able to view the conference room in 

Oklahoma City, talk to people In the room, and they saw me and heard me fine. I don't think there's anything more we 

could do at this point, other than cross our fingers and hope nothing changes between now and tomorrow. 

As for "plugging Into" our system, I don't know about that, I think the court reporter will simply be able to set up a 

microphone and catch the audio as it arrives from the lV monitor, I'm not sure there's an audio jack to be used, or 

whether it's the correct kind for the reporter's system. But If there Is, he or she Is welcome to it. 

See you tomorrow. 

craig wm. Black, Attorney 

FAA: Alaskan Region 

(907) 271-3570 

from: Karin Gustafson fmallto:Karln@AKColeLaw.com] 

Sent: Wednesday, October OS, 2014 2:41 PM 

To: Black, Craig (FAA) 

Subject: RE: Robyn Burk Depo 

Brent has been concerned about the possibility of technical difficulties in the video conferencing system in tomorrow's 

deposition. Our court reporters assure us that typically it's just a matter of plugging In to your system, and they'll be 

good to go. So can you tell me If the system has been In recent operation and has It been working well. 

I'm sorry to bug you, but we're a little nervous about this as it's new to us. 

Karin Gustafson 

Law Office of Brent R. Cole, P.C. 

821 N Street, Suite 208 

Anchorage, Alaska 99501 

(907) 277-8001 (voice) 

(907) 277-8002 (fax) 

karin@akcolelaw.com<email) 

WARNING: The Information contained in this email (including any attachments) is CONF'IDENTIAL and may be 

PRIVILEGED COMMUNICATIONS. If you are not the Intended recipient of this email, you may not read, retain, copy, 

distribute,' or disclose the content of this email. If you have received this email in error, please advise us by calling (907) 

277-8001 and/or by return email. 

1 
2015-01-15 15:51 ARCALROLEG02 

From: Cra!g.B!ack@faa.goy [maj!to:Cra!g.B!ack@fag.gQv] 

Sent: Tuesday, october 07, 2014 8:33AM 

To: Karin Gustafson 

Subject: Robyh Burk Depo 

Dear Karin, 

9072712800 » 2024935142 p 42/43 

We should be all set to host Robyn Burk's depo using our vldeoconferencing system Thursday at lOA, please let me 

know if this comes off your calendar for some reason. Otherwise we'll expect Brent then. 

Thanks. 

Craig Wm. Black, Attorney 

FAA: Alaskan Region 

(907) 27l-3570 

2 
2015-01-15 15:51 ARCALROLEG02 9072712800 » 2024935142 p 43/43 

' 

LAWOFFictOJt 

BRENT R. COLE, P.C. 

BRENT R. COLt-b~rtt@,.k~oltolaw.ccln 

fWl':!t1CK N. BERGT-patr!~k®d~t:olclllW.eom 

VL4 E-MAIL- craig.black@faa.gov 

Craig Biack, Esq. 

Oftice of the Regional Counsel 

222 West 7th Avenue, #!4 

Anchorage, AK 99513 

8ll N STRF.!i:T, SUIT! ln8 

ANC'lf0MG£t ALASKA .9!Jt'i01-21J~ 

November 18, 2014 

Re: Robert G. Stanford, Redemption, Inc, 

Case File No. 2013AL030106 

Our File No. 139.078 

Dear Craig: 

TEI,.EPHONE (907) 2."1'7-aOOI 

n.:u:cdPIER (907) :277-3002 

I am in receipt of your letter, dated November 18,2014. My client is unwilling to waive 

his presence at Ms. Bryant's deposition. As such, there is no need to make arrangements for 

video conferencing. As wo have previously discussed, my client intends ro be present for the 

deposition. 

Very truly yours, 

LAW OFFICE OF BRENT R. COLE, P.C. 

~·~.L Brent R. Cole 

BRC/pnb 

cc: Client 

J Qf ] 
2015-01-15 15:41 ARCALROLEG02 9072712800 » 2024935142 p 1 

FEDERAL AVIATION ADMINISTRATION 

Alaskan Region 

Office of the Regional Counsel 

222 West Seventh Avenue, Box 14 

Anchorage, Alaska 99513 

PH: (907) 271-5269 FAX: (907) 271-2800 

FACSIMILE TRANSMISSION COVER SHEET 

TO: Judge Richard C. Goodwin 

Hearing Docket Clerk 

FAX No: (202) 366-7536 

(202) 267-1293 

FROM: Craig Wm. Black, Esq. 

RE: In the Matter of Redemption, Inc. 

FAA-2014-0115 

Number of pages (not including this cover sheet): " 42 • 

Administrator's Opposition To Redemption's Motion To Compel 

Tb.o iufurm~tior~ .:onl4inl'd in thi• fRo;:.Jmlle fll.;&;~~gc !s prlvltoli.<Xl and prot~Ct"d under th lllw. It is intended for the u.., of the inrli'>'idual or ~nlity nom<>:! ohav:c. lflhe rer.der nr ~hiA "'""~I!C I~ net th\' lntondod t...CipioJ11. ur the 

~Hiploy~c or nJi!ll\t fCS)>Otl&lblo to lloliv~r It to th~ int~d~ recipient, you nr<: !>crcl>y nt~tiiiW ilmt any dl&s~mlnMion, illstrl!Jutlon, or copY hill ctt!llil com.nuulc..tlu!l i• ~hi~Uy proltiblt<>LI. lfy<>u h1wc =civcd this f11lc. in error, tli~.~<Wil 

imm<Xl>~loly nchfY !be ..,ndaby td~j'lilnne, pn.;l re!Unt the orlgl1111l tnO~~e tO~~~ ~lth~ al:luvo Blldr~n via tha U.S. Pc•IH] Scrrvic~.