U.S. Department 

of Transportation 

Federal Aviation 

Administration 

June 30, 2014 

Southwest Region 

Arkansas, Louisiana, 

New Mexico, Oklahoma 

Texas 

CERTIFIED MAIL- RETURN RECEIPT REQUESTED 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbm Wright Building, Suite 2Wl 000 

In the Matter of Kenneth Santodomingo 

Office of Regional Counsel 

2601 Meacham Blvd., Rm. 663 

Fort Worth, TX 76137-0007 

(817) 222-5099 

(817) 222-5945/5092 FAX 

RECEIVED 

JUL -7 2014 

HEARING DOCKET 

Docket No. CP- To Be Assigned c) O 1 4 - Q L\ 0 1-

Case No. 2013SW050046 

Dear Sir or Madam: 

Enclosed are the original and one copy of the Complaint in the above-referenced proceeding. 

The Complainant requests that the hearing in this matter be held in the Dallas, Texas, area and 

expects that the hearing will last one (I) day. 

Please serve me with all documents in this matter. 

ERIC i_ ANDE~SQN Regi/onal Col/ns~V 

Sout~wes~ o/e?lof . 

Gregory S. Lander 

Attorney, Safety Enforcement Branch 

Federal Aviation Administration 

260 I Meacham Blvd. 

Fort Worth, Texas 76137-0007 

. Telephone: 817-222-5083 

Facsimile: 817-222-5945 . 

By: \ ;~ I GrJ~gory~>L!!!!der .· .. / 

Attorney, Safet:YEiiforcement Branch 

Safety Enforcement Branch 

Enclosme: Complaint Kenneth Santodomingo 

Kenneth Santodomingo 

COMPLATNT: 2013SW050046 
In the Matter of: 

U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

RECEIVED 

JUL -7 2014 

HEARING DOCKET 

FAA Case No. 2013SW050046 

KENNETH SANTODOMINGO 

FAA Docket CP No.- To Be Assigned 

Judge - Not Yet Assigned 

dO\l.\- 0~ 0 1 

COMPLAINT 

The Complainant files its complaint, under Rule 208 of the Rules of Practice in FAA Civil 

Penalty Actions, 14 C.F.R. § 13.208, and states the following: 

I. 

Respondent Oklahoma Skydiving Center was advised through a Final Notice of Proposed 

Civil Penalty that the FAA proposed to assess a civil penalty in the amount of $11,000.00. On 

June 27, 2010, Respondent submitted a written request for a hearing. 

II. 

I. On or about January 28, 2013, at approximately 04:08 a.m. local time, you knowingly 

aimed a beam of light from a laser pointer at a Dallas Police helicopter (aircraft), 

operating as "Air One," flying in the area of 7719 Lake June Road, Dallas, Texas. 

2. The laser beam aimed at the aircraft illuminated the helicopter's plexiglass windscreen. 

3. On board the police helicopter were two uniformed officers performing police duties; one 

flying and one observing. 

4. As a result of your actions, the police officer flying the helicopter was diverted from his 

duties when the laser obscured his vision and impaired his ability to control the aircraft. 

5. You admitted to law enforcement officials that you pointed the green laser at the 

helicopter and the laser used was identified by you to police. 

6. You were arrested and taken into custody by Dallas Police. 

7. On February 26, 2013, you waived yow right to trial and entered a plea of guilty to a 

violation of 18 United States Code (U.S.C.) § 39A. 

Kenneth Santodorningo 

COMPLATNT: 201JSW050046 
8. By reason of the foregoing, Oklahoma Skydiving Center violated the following sections 

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

a. Section 91.11 that states that no person may interfere with a crewmember in the 

performance of the crewmember's duties aboard an aircraft being operated. 

III. 

l. Under 49 U.S.C. § 46301(a)(1), you are subject to a civil penalty for each of the 

violations noted. The maximum penalty per violation is $11,000.00. By reason of the foregoing 

facts and circumstances we propose to assess a civil penalty for all of the violations noted in the 

total amount of$11,000.00. 

2. Under the facts and circumstances of this case, a civil penalty of $11,000.00 is 

appropriate. 

Complainant respectfully requests that the administrative law judge enter an order that 

Respondent Kenneth Santodomingo be assessed a civil penalty in the amount of$11,000.00. 

Submitted this 30th day of June 2014. 

/ 

ERIC~· ANDE]\SOf'l 

Regional Co~s~W 

Sopthwest ~gj6p 

/ // \ I "" . 

>::{/"/ ,/ 

By: .-· \"'\~.,. / 

/ ~';""-..,_ ------" 

otegory s.·r::ancier 

Attorney, Safety Enforcement Branch 

Federal Aviation Administration 

2601 Meacham Blvd. 

Fort Worth, Texas 76137-0007 

Telephone: 817-222-5083 

Facsimile: 817-222-5945 

gregory.s.lander@faa.gov 

Kenneth Santodomingo 

COMPLAINT: 2013SW050046 
CERTIFICATE OF SERVICE 

I certify that the foregoing original Complaint and one copy have been mailed this date 

by Certified Mail, Return Receipt Requested, and via facsimile, to: 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building, Suite 2Wl 000 

Fax: (202) 366-7536 

I certify that a copy of the Complaint has been mailed this date by Certified Mail, Return 

Receipt Requested, and regular mail to: 

Mr. Kenneth Santodomingo 

Reg. No. 45762-177 

P.O. Box 9000 · 

Seagoville, TX 75159-9000 

Syl C. Twa, Paralegal Specialist 

Federal Aviation Administration 

Southwest Region 

Office of the Regional Counsel 

Date:~ Jl)/ :J.t)!'( 

/,,, 

Kenneth Santodomingo 

COMPLAJNT: 20!3SW050046