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 AviationAdministration 800 Independence Avenue, SW Washington, DC 20591 Attn: Hearing Docket Clerk, AGC-430 Wilbm Wright Building, Suite 2Wl000 In the Matter ofKenneth 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

DocketNo. CP- To Be Assigned 

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# 1- Case No. 2013SW050046 Dear Sir or Madam: Enclosed are the original and one copy ofthe Complaint in the above-referencedproceeding. The Complainant requests thatthe hearing in this matterbe held in the Dallas, Texas, area and expects thatthe hearing will last one (I) day. Please serve me with all documents inthis matter.

ERIC

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Regi/onal

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. Gregory S. Lander Attorney, Safety Enforcement Branch Federal Aviation Administration 260I Meacham Blvd. Fort Worth, Texas 76137-0007

. Telephone: 817-222-5083 Facsimile: 817-222-5945



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# I**GrJ~gory~>L!!!!der**.·.. / Attorney, Safet:YEiiforcementBranch Safety Enforcement Branch Enclosme: Complaint Kenneth Santodomingo Kenneth Santodomingo COMPLATNT: 2013SW050046In 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 

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# 0 1 COMPLAINT
The Complainant files its complaint, under Rule 208 ofthe Rules ofPractice 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 ofProposed Civil Penalty thatthe 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 of7719 Lake June Road, Dallas, Texas. 2. The laserbeam aimed at the aircraft illuminated the helicopter's plexiglass windscreen. 3. Onboard the police helicopter were two uniformed officers performing police duties; one flying and one observing. 4. As a result ofyour actions, the police officer flying the helicopter was diverted from his duties when the laser obscuredhis 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 laserused 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 ofthe foregoing, Oklahoma Skydiving Center violated the following sections ofthe Federal Aviation Regulations (Title 14, Code ofFederal Regulations):
a. Section 91.11 that states that no person may interfere with a crewmember inthe performance ofthe crewmember's duties aboard an aircraft being operated.

III. l. 

### Under 49 U.S.C. 

### §46301(a)(1), you are subjectto a civil penalty for each ofthe violations noted. The maximum penaltyper violation is $11,000.00. By reason ofthe foregoing facts and circumstances we propose to assess a civil penalty for all ofthe violations noted in the total amount of$11,000.00. 2. Under the facts and circumstances ofthis case, a civil penalty of$11,000.00 is appropriate. Complainant respectfully requests that the administrative lawjudge enter an order that Respondent Kenneth Santodomingo be assessed a civil penalty in the amount of$11,000.00. Submittedthis 30th day ofJune 2014. /**ERIC~·** 

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# s.·r::ancier Attorney, Safety EnforcementBranch 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: 2013SW050046CERTIFICATE OF SERVICE I certify thatthe foregoing original Complaint and one copyhave been mailed this date by Certified Mail, Return Receipt Requested, and viafacsimile, to:
Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591 Attn: Hearing Docket Clerk, AGC-430 Wilbur Wright Building, Suite 2Wl000 Fax: (202) 366-7536 I certify that a copy ofthe 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 ofthe Regional Counsel

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Kenneth Santodomingo COMPLAJNT: 20!3SW050046