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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 opposesthe Motionto Compel Discovery, Impose Sanctions, and OrderRedemption 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 criminallyprosecuted for assaulting and harassing the deponent. Redemption's motion is unfounded and should be denied. ll. Factual Background. 

### A. Redemption's President and Director ofOperations Physically Attacked the Deponent. This case concerns the violent and unjustified refusal ofRedemption's owner to allowthe Administrator to conduct a records inspection. To understand Redemption's motion, it is important to understand why the Administrator has placed one condition onhis 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 ofRobert G. Stanford, the

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President and DirectorofOperations for Redemption. The Administratormakes this request because Mr. Stanford attacked Insp. Bryant for, in her official capacity,lawfullyrequesting to review certainRedemption records infurtherance ofthe Administrator's regulatory oversight function. Therefore, the story ofMr. Stanford's attack onthis federal officer, completely Unmentioned in Redemption's motion, mustbe told. At alltimes relevant to this proceeding, Redemption was a certificated Part 135 air carrier operating out ofKodiak, Alaska. 1 Onthe morning ofAugust 15,2013,FAA Aviation Safety Inspector ChristinaBryant visited Redemption's mainbase. 2 The purpose ofInsp. Bryant's visit
was to perform a quick, five minute follow-up records review ofRedemption's load manifests.' Redemption's failure to accurately and completely prepare load manifests on numerous flights in 2013 caused an investigationby Insp. Bryant 4 that ultimately resulted in a $6,000 civil penaity. 5 Therefore, Insp. Bryant's visit that day waspart ofthe Administrator's effortto monitor Redemption's questionable ability to comply with regulatory norms. During Insp. Bryant'sfust visitthatday, Redemption was busy, so she indicated to a Redemption employee she was familiar with that she would return laterwhenthey were less busy. 6 She returned around 12:35 p.m.7 Upon arrival, she identified herselfand stated the nature ofhervisit." She was greetedby Mr. Stanford. 9 Inspector Bryant asked Mr. Stanfordto suggest a time that afternoon for herto

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/ DocketNo. FAA-2014-0115 Page 2

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quickly inspect Redemption's mainifests. 10 Upon learning ofthe nature ofinsp. Bryant's request, 

### Mr. Stanford became loud and agitated.ll Herefused to allow Insp. Bryant to inspect the manifests intime for her to catch her 3:00p.m. flight backto 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 Hethen 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 somehowrelated to his wife's "fucking dislocated shoulder", which he said causedher to be bedridden so that she, inhis words, "can't even wipe her owndamn ass." 14 Confronted bythis display ofrage, Insp. Bryant, who was travelling alone, raisedher hands in a fearful, surrendering gesture to Mr. Stanford while backing awayfrom 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 onbehalfofthe 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'sMotion to Compel DocketNo. FAA-2014-0115 

### Page3

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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. Bynow she was frozen in fear. 20 She perceived his rapid approach as prelude to himphysically ejecting her from the building, so she avoided contact from him by quickly exiting the opened door.'' As she exited, 

### Mr. Stanford continued to makephysical gestures for her to leave and yelled ather "get offmy 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'spath further away from the building.23 He yelled at her, shouting that he "neverwants 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 abouther."24 InspectorBryanttried to apologize about how sick Mr. Stanford's wife is, but couldn't getmuch across to himbecause of his shouting and uncontrolled behavior. 

### Mr. Stanford then entered a red truck withtan trim.'5 While entering the truck's driver's seat, he yelled at Insp. Bryant as she continued herretreat.26 She is to "stay out ofhis aircraft," he yells, slamming the truck's door for emphasis.27 Now seated in the truck, Mr. Stanfordputthe truck in reverse.28 Its tires screeching, he drove directly at Insp. Bryant.29 Fearful ofbeing struck, shejumped.30 But,justas 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'sMotion to Compel DocketNo. FAA-2014-0115 Page 4

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Stanford stopped the tmck. 31 Pushing his head out ofthe truck window, he looked back at Insp. Bryant.32 In angry and unrestrained voice, told her thathe would notbe back for herto inspect Redemption's records that day, and departed. 33 Immediatelythereafter, Insp. Bryantproceededto the safety ofthe nearbyAlaska Airlines termina!. 34 There, she realized that she could document Mr. Stanford's vehicular assault bytaking photos ofthe skid marks he left inthe parking lot." At approximately 1:55 p.m., while taking thephotos in the lot, Insp. Bryant was startled to hear a tmck'

### s engine suddenly rev up.36 She immediatelyrealized that the sound was coming from Redemption's nearby ramp. 37 She looked up, and through a chain 

### link fence, she sawthe same truck Mr. Stanford drive earlier speeding directlytowards her?8 

### In fear for her life, Insp. Bryant dashed for cover as the truck stoppedjust 5-10 feet away on the other side ofthe fence.3 9 She then retreated backto the relative safety ofthe 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. 

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andthen sawMr. Stanford walk towards the Redemption building in an angry and purposeful
manner.41 Later that afternoon, while she awaited a flight out ofKodiak, a somewhatbecalmedMr. Stanford enteredthe terminal and walked directlyto Insp. Bryant.42 Shetold him that ifhe 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 continuedto unload his frustrations onher, angrily and intimately pokinghis fingers (including, on occasion, his lone middle fmger in an obscene manner) within inches ofher, all in a threatening and intimidating mannerto 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 behaviortowards Insp. Bryant became the subject ofa federal criminal investigation. OnJanuary 13, 2015, AssistantUnited States Attorney Steven Skroki advised Mr. Stanford's attorney thatthe Department ofJustice 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'sMotion to Compel DocketNo. FAA-2014-0115 Page 6

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B. The Administrator Objects to Mr. Stanford's Physical Presence at Insp. Brvant's Deposition. The Administrator has consistently soughtto accommodate Redemption's plan to depose Insp. Bryant. The lone conditionthatthe Administrator insists onis thatthe 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 afterthe complaint was filed inApril2014.48 After some backand forth, on October 30 the parties agreed to hold the deposition on November 20 at 9:00 a.m..49 OnNovember 5, some two weeks before the scheduled deposition, undersigned counsel first informed Mr. Cole ofthe Administrator's request that, because ofMr. 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 otherRedemption representative beingthere, thatthe 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 OnNovember 12, 

### Mr. Cole served notice 

### a depositionnotice on the Administrator stating that Insp. Bryant's depositionwould occur at Mr. Cole's office onNovember 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). Italso appears thatRedemption neither requested nor served a subpoena for Insp. Bryant. 14 CFR 13.228(a). Redemption. Inc. Administrator's Opposition to Redemption'sMotion to Compel DocketNo. FAA-2014-0115 Page 7

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onNovember 17, undersigned counsel wrote to Mr. Cole and informed him that Insp. Bryant would not appear ifMr. 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 Redemptionto depose Insp. Bryant. Therefore, in an effort at compromise and to protect Insp. Bryant, onNovember 18 undersigned counsel again wrote to Mr. Cole. 56 In that letter, undersigned counsel offered to let Mr. Stanfordto participate inthe deposition, butto do so viathe Administrator's video conferencing facilities. Mr. Cole was well-aware ofthese facilities, having used themjusta month earlier in a deposition split between Anchorage and Oklahoma City.57 ButRedemption 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 ofWitness Intimidation, At the center ofRedemption's Motion is an obvious, unspoken truth. Redemption hopes to intimidate Insp. Bryant during her deposition by forcing her to sufferthe physical**p~esence** of the man currently being criminally prosecutedfor attacking her, Mr. Staoford.**~** While the law does generally tryto accommodate a party's rightto participate in all phases ofthe proceedings, the right is notunlimited. 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'sMotion to Compel DocketNo. FAA-2014-0115 Page 8

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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 "designatethe persons who may be present while the discovery is conducted
... .''61 Itwas inthe spirit ofRule 26 thatthe Administrator attempted to accommodate Redemption's discovery request. The Administrator first suggested that a different Redemption representative participate, meaning one thathadn't attacked Insp. Bryant. Thatwas 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 depositionjusta monthprior. Thattoo 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 ofparties 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" itwould 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, underparticular 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 nottechnically a "party" in this matter. 

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Good cause exists for the Administrator objectionto subjecting Insp. Bryant to Mr. Stanford'sphysicalpresence during her deposition. As described in detail above, inthe summer of2013, Redemption was aware it was the target ofan enforcement action initiated byInsp. Bryant. Upon seeing Insp. Bryant at Redemption's base, Mr. Stanfordbecame enraged, yelling obscenities and other insults at her, physically confronting her, twice violently charging atherin his truck, then tracking her down in the airport some time later to confront her. Plainly, she is not safe inhis presence. Out ofrespect for the process, the Administrator attempted to accommodate Redemption's discovery rights. The depositionwouldhave occurred had Redemption been willingto either send a different representative orhave Mr. Stanford participate via teleconference. Bothreasonable accommodations that would have permitted Redemption to question Insp. Bryant about the events ofthe day in question. Both rejectedwithout explanation. The onlypossible reason for Redemption's absolute insistence that Mr. Stanford be physicallypresentfor Insp. Bryant's deposition is that it intends to have him try to intimidate her. The Administrative LawJudge ("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, afterthe complaintwas filed onApril17, 2014 Redemption did not formally notice Insp. Bryant's deposition until November 12,64 setting itfor 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. 

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file the instant motion, giving no explanationfor its 41 day delay. Redemption has also not requested that discovery be reopened. The motion, then, may be denied because 

### it concerns discovery and discoveryhas closed. C. Barring Inw. Brvant from Testifying as a Discovery SanctionWould beBoth Premature and Case-Ending. Redemption demands, 

### as aresult ofInsp. Bryant's failure to appear atthe deposition, that the Administrator be prevented from presenting her as a witness at hearing. In so doing, Redemptionmischaracterizes the rule underlying witness preclusion as a sanction for a discovery violation.66 Under 14 CFR 13.220(n)(4), the ALJ mayprevent a party from presenting certain witness testimony "[i]f [the] party has failed to comply with a discovery order or an orderto compel." However, no discovery order or an order to compel hasbeen issued inthis matter. The rule does not apply. Nor should it, giventhe good cause explained above for keeping Mr. Stanford away from Insp. Bryant. The Administrator should incur no sanctions for refusing to direct Insp. Bryantto appear at a deposition 

### it1 Mr. Stanford's physicalpresence, let alone the crushing, case-ending witness preclusion sanction Redemption demands. D. The Rules ofPractice Do NotAllow for Money Sanctions for Discoverv Violations. In additionto witness preclusion, Redemption seeks monetary sanctions as a result of Insp. Bryant's failure to appear at the deposition, describingthem as appropriate perFed. R. Civ. P. 37.67

66 Memorandum in Support ofMotion to Compel Discovery orImpose Sanctions, at 3. 67 Id. at4-5. Redemption, Inc, 

### Adminisrrator 's Opposition to Redemption'sMotion to 

### Compel DocketNo, FAA-2014-0115 

### Page 11

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However, the Rules ofPractice68 already specifythe possible range ofsanctions for discovery violations. Under both 14 CFR 13.217(±) and .220(n), the ALJ may: I) strike thatportion ofa party's pleadings; 2) preclude prehearing ordiscovery motions bythat party; 3) preclude admission ofthat portion ofa party's evidence at the hearing; or 4) preclude that portion ofthe testimony ofthat party's witnesses at the hearing. That's it. Nowhere is there a sanction that would permitthe ALJ to order that the moving party's expenses be paid. Moreover, those four sanctions have been described as serving inthis forum the function that Rule 37 serves inthejudicial 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. Forthe foregoing reasons, Redemption's motion should be denied. DATED

# this~ ofJanuary, 2015.

68 14 CFR 13, Subpart G. 69 Matter ofLibertv Foundation. Inc., FAA DocketNo. FAA-2012-0477, 2014 WL 1340047 (Mar. 28, 2014)
.. Redemption, Inc. Adminisrrator 's Opposition to Redemption'sMotion to Compel DocketNo. FAA-2014-0115 Page 12

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CERTIFICATE OF SERVICE I HEREBY CERTIFY that, on this day, I served a copy ofthe foregoing by the following 

### means: 

### One Copy via U.S. Mail, Postage Prepaidandby Facsimile: The Honorable Richard C. Goodwin U.S. Administrative LawJudge Attn: PatriciaMatthews Office ofHearings, M-20 U.S. Department ofTransportation 1200 NewJerseyAvenue, S.E.(E11-310) Washington, DC 20590 Fax: (202) 366-7536 

### The Original andOne Copy via U.S. Mall, Postage PrepaidandbyFacsimile: 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 ofBrent R. Cole, P.C. 821 N Street, Suite 208 Anchorage, AK 99501 DATED

# this~ ofJanuary, 2015.
.

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



### Redemption. Inc. Administrator's Opposition to Redemption 's 

### Motion to Compel DocketNo. FAA-2014-0115 Page 13

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UNITED STATES DEPARTMENT OFTRANSPORTATION OFFICE OF HEARINGS

WASHINGTON, D.C.
IN THE MATTER OF REDEMPTION, INC. DOCKETNO. 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 FederalAviationAdministration, Complainant inthis matter, and my declarations herein arebased onpersonal knowledge. 2. OnAugust 15 and 16,2013, I prepared a written report ofthe events surrounding my efforts as an inspector to review certain aviationrecords belonging to Redemption, Inc, in Kodiak, Alaska onAugust 15, 2013. 3. Attached to this declaration is a true and correct copy ofthatreport. 4. In light ofMr. Stanford's behaviortowards me onAugust 15, 2013, I prefer that he not be physicallypresent 

### if! am deposed in this matter. I declare under penalty ofperjurythatthe foregoing is true and correct. DATED this
__day ofJanuary, 2015.

ChiistinaBryant

Exhibit 

# A Page_/_,ot_y_pages

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OnAugust 15, 2013, FAAAviation Safety Inspector, Christina Bryant, was verbally and physically threatened by the Director ofOperations ofRedemption Air while at Redemption's mainbase ofoperations located atl420 Airport Way, Kodiak, Alaska 99615. Inspector Bryant was on duty and assigned to conduct a follow-up records review ofRedemption Air's load manifest due to an on-going federal investigation resulting from the company's systemic inabilityto accurately and completelyprepare load manifests for their multiengine 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 walkedto 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 myselfto the receptionist I waved at earlier and asked ifMr. 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 bythe restrooms, out ofthe way of company operations. WhenMr. Stanford appeared from behind the reception desk, he asked meifhe could help me. I indicated there was another gentleman that was waiting for him as well who arrivedpriorto 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 iftherewas a good time to meet with him or another person to accomplish this task. Mr. Stanfordinformed me that his wifejust dislocated her shoulder andthe next couple days would work. I replied that my flight home left at 3 this afternoon. He offered he couldmeet me at 3. I asked ifthere was anyone else that would be available for this follow-up i11spection. Mr. Stanford beganto get very agitated and the volume ofhis voice increased to a constrained, agitated yell. Mr. Stanford beganto slow his speech, using very pointed, short articulation. 

### Mr. Stanford said no, he was going to do it. I then asked ifhe could do it any earlier. He sharplyreplied no. I indicated

### thatlt was a quick follow-up inspection that wouldtake less than 

### 5 minutes. At this point, he slammedthe receptionist desk with his fist to emphasize his "damn it" and informed me very rnatter-of-factly thathe will be here at 2. Mr. Stanford continued on withmore inappropriate language, including the f-word, explaining that his "wife has fucking dislocated shoulder, laid up inbed, can't even wipe her own damn ass". l explainedto him that 2 would betight because I would like to be checked in an hour prior for my enroute home. Duringmy reasoning, I was interrupted with Mr. Stanford's, very loud voice, using the f-word, leaning overthe desk while trying to explain to me about his wife's dislocated shoulder. At this point, Iputmyhands up in a surrendering motion and I physically back up out offear. I told him I am sorry abouthis wife and state that I 

# A Exhibit --'--L....--- Page_d_of 

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don't want to make a scene. Mr. Stanford turns and walks away into the back ofthe office. Thereceptionist closestto melooks at me, mouths to me "I'm sorry". I walk around the corner and stand in front ofthe company's large map, out ofthe way, and begin to text my Front Line Manager to make him aware ofwhatjust happened. About 2 minutes later, 

### Mr. Stanford comes around the comer, sees me standing in front ofthe map and very aggressivelytells me I need to leave. He opensthe door to the outside, which swings open with force, and continues to yell, you are not welcome here. 

### Mr. Stanford gestures I exitthe 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 neverphysicallytouches me, Mr. Stanford proceeds to put his arm around to my back as though he is going to fling me toward the door. Ijump forward and as I continue to move toward the door, Mr. Stanford is repeatedly yelling at me, "getoffmy damn property, you are not fucking welcome here, you don't give a damn about people". At this pointhe is now very close behind me and I can see his arms out bothperipherals aggressively wavinghis arms in shooing motions as I move outthe door. Be follows me onto theporch and then downthe stairs. Mr. Stanford then steps infront ofme, and continues to threaten and belittle me by yelling inmyface how "(he) never wants to see me on (his) property again, I am not welcome here and howsick (his) wife is and (I) could give a shit about her." I again try to apologize about how sick his wife appears to be butcan't get much across because ofthe volume ofhis voice and the uncontrolled behavior

### Mr. Stanford was displaying. 

### Mr. Stanfordthen walks to his red, withtan trim, truck. He opens the driver side door and yells atme again warning me "to stay out ofhis aircraft". He gets in and slams the door. The next thing I realize is I heartires screeching onthe pavement as hebacks out ofhis parking spot next tO the fence separating the ramp from theparking lot. I physicallyjump because I realize I am in his direct path, ifhe were to continue backwards. He stops the truck abruptly, strains his head out ofthe window because he has to look directly bacl< at me and says in a very angry, unrestrained voice that he will notbe back at two. 

### Incident#2: After this incident, I spoke with my FLM and decided to go directly to the Alaska Airlines mainterminal because 

### itwas 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 approachme without warning. Around 13:55, I headed outto the parking lot to take photos to document the skid marks left by Mr. Stanford. While doing this, I heard a vehicle engine revup which seemed to be coming from the direction ofthe Island Airramp. Alarmed, I looked up and saw through the chain link fence, Mr. Stanford's red, with tantrim, truck speeding directly toward me. Again, I am frightened he will not stop. 

### In survival mode I dash out ofthe immediatethreat as the truck comes to an abrupt stop 5-l0 feet from the fence. As my adrenaline spikes, I can hear my ownheart pounding rapidly. l tum and swiftly walk backtowards the Alaska Airlines terminal. While I am walking, I hearthe door ofthe txllibit

# -iL.~- Pags_3.
___ ,,I·-·

## Lj_Pcl'~-': " t
- .,.·,-·-·-·- .:?
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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 onthe sidewalk ofthe Alaska Airlines terminal. As I enter the AlaskaAirlines building, I glance back and notice Mr. Stanford is coming across the parking lot. I fumble with myphone as I walk up to the ticket counter, There are only 2 or 3 women behind the ticket counter. I manage to get myphone 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 opportunityto go over and look at the requested documents at Island Air in April's office. Knowing there is a TSA guy outside, I offerto take the conversation outside. I stop on the rampjust outside ofthe doorwhere Mr. Stanford continues to unload his frustrations on me. I do not speak a word and listento him

### as he becomes more emotionally charged and moreangry as he vents. During this time, Mr. Stanfordbecomes more animated and begins to pokehis fingers within inches ofme to emphasize his comments in an intimidating, threating way invading. Mr. Stanford also violated mypersonal space by stepping too close. using inappropriate hand gestures. I would back up eachtime I felt threatened, however, he would steptoward rne to closingthe gap. During this time, 

### Mr. Stanford even usedthe "f-u"hand gesture, swinginghis 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 thankyou 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 Kodiakthe next day, Friday August 16, in light ofthese 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 thatthe coffee shop is in the same building as Island Air; where I was earlier threatened and escorted offthe 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 IslandAirbuilding. The Island Airramp is adjacent to this parking lot withthe carnormally 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. Duringthe conversation, I made it clear that, unfortunately, because ofthe happenings ofearlier this afternoon, I did not feel comfortable to go backto Island Air. I told her I appreciated herwillingness to have these·docurnents available and wanted to be courteous so she wasn't waiting for. She thanked me and didn't blame mefor 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 StanfordPresident 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 yourbase ofoperations at Kodiak, Alaska onApril13, 2013, personnel ofthis office are investigating company compliance with weight and balance and load manifest requirements onthe 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 youthat these matters are underinvestigation bythe 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 ofreceipt ofthis 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.~~ ~** **/'.~~-**


### -- (... 

# - ChristinaBryant Principal Operations Inspector

i:J(flibit

_ ... 

## 8=::.

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

### 2015-01-15 15:46

U. S. Department ofTransportation Federal Aviation Administration 

### ARCALROLEG02

Case No. 2013AL030070 

### APR 10 

## 2.014 9072712800 »

Alaskan Region Office of'the Rt:gional Counsel

CERTIFIED MAIL-RETURN RECEIPTREQUESTED
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



### ORDERASSESSING 

### CIVIL PENALTY OnNovember 5, 2013, Redemption, Inc., (Redemption) was advisedthrough a Notice of Proposed Civil Penaltythatthe FAAproposed to assess a civil penalty inthe amount of$7500. We have consideredthe information submitted inresponse to this Notice. OnMarch 14, 2014, Redemption accepted our offerto settle this matter underthe terms containedherein, but this
· office did not learn ofRedemption's acceptance tmtil after a FinalNotice ofProposed Civil

Penalty was served onMarch 18, 2014. In accordance withthe settlement agreement, after considering all the evidence inthis matter, includingthe informationpresented duringthe informal conference onFebruary 11, 2014, ithas been determinedthat: 1. At alltimes mentioned herein, Redemption was the holder ofAir Carrier Certificate No. RI9A557W and appropriate operations specifications authorizing itto conduct on-demand and commuter operations under part 135 ofthe Federal AviationRegulations (FAR) using 

### the business names "IslandAir" and "IslandAir Service." 2. On or about March 30, 2013, Redemption operated civil aircraft N5891V, 

## aBritten-Norman Model BN-2A-26 Islander, a multiengine airplane, on a passenger-carrying flight in air commerce that was subjectto part 135 ofthe FAR from Kodiak, Alaska, to Old Harbor, Alaska. 3. On or aboutApril!, 2013, Redemption operated civil aircraftN5891Von a passengercarrying flight in air commerce that was subject to part 135 ofthe FAR from Karluk, Alaska, to Kodiak, Alaska. 4. On or about April 1, 2013, Redemption operated civil aircraftN5891V on a passengercarrying f\ight in air commerce

### that was subjectto part 135 ofthe 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 NS891Von a passengercarrying flight in air commercethat was subject to part 135 ofthe FAR from Larsen Bay, Alaska, to Karluk, Alaska. 2

6. On or about April 1, 2013, Redemption operated civil aircraftN5891V on a passengercarrying flight in air commerce that was subject to part 135 ofthe FARfrom Kodiak, Alaska, to LarsenBay, Alaska. 7. On or about April 2, 2013, Redemption operated civil aircraft N5891V on a passengercarrying flight in air commerce thatwas subject to part 135 ofthe FAR from Kodiak,Alaska, to Old Harbor, Alaska. 8. At the time ofeach ofthe above flights, Redemption had not prepared a load manifestthat included the actual total weight ofthe loaded aircraftorthe center ofgravity oftheloaded aircraft. 9. The operation ofcivil aircraft NS891Vas described above was careless orreckless so as to endangerthe life orproperty ofanother. Based onthe foregoing facts and circumstances, Redemptionviolated the following Federal AviationRegulations: (a) Section 91.13(a) inthat Redemption operated an aircraft in a careless orreckless manner so as to endangerthe life orproperty ofanother. (b) Section 135.63( c)(2) in thatRedemption operated a multiengine aircraft underpart 135 of the FAR when it had notprepared a load manifestthat includedthe total weight ofthe loaded aircraft. (c) Section 135.63(c)(5) inthat Redemption operated a multiengine aircraft underpart 135 of the FAR when ithadnotprepared a loadmanifestthat included the center ofgravity of the loaded aircraft. THEREFORE, IT IS ORDERED, pursuant to 49 U.S.C. § 4630l(d)(2), thatRedemption be, and hereby is, assessed a 

### civil penalty in the amount of$6,000.00. 

### We hereby acknowledge receipt ofyourelectronic payment in the runount of$6,000.00, which we accept 

### infull satisfactionofthis matter. You may considerthis matter closed. HOWARD L. MARTIN, JR Regional Counsel
By: Glenn H. Brown · SeniorAttorney

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

### 2024935142 p 

### 22/43

3 

### CERTIFICATE OF SERVICE I hereby certifY that this Orderhas 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 ofthe Regional.Counsel 222 W. 7thAvenue, #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 

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Our office has elected to proceed against Mr. Stanford on his actions against the FAA Inspector and prosecute the case. Iwill advise when we will file the charges. Justwanted to give you notice as It appears administrative action of some type appears imminent. -Steve Steven E. Skrocki Assistant UnHed States Attorney SeniorLHigation 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 

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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 ofBrentR. Cole, P. C. 821 N Street, Suite 208 Anchorage,Alaska 99501 OurTelephone Number; (907) 277-8001 OurFaxNumber; (907) 277-8002 WARNING: The information contained in this email (including any attachments) is CONFIDENTIAL and may contain PRIVILEGED COMMUNICATIONS. Ifyou are notthe Intended recipient ofthis email, youmay notread, retain, copy, distribute, or disclose the content ofthis email. Ifyou have receivedthis email in error, please advise us by calling (907) 277-8001 and/or by return email. Thankyou. Law Office ofBrentR. 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 

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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 ofemergency, 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 ofthe runway. Ithinkthis should take care ofyour 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 Bryantgave birth that I'm not so hesitantto ask herto sit for a depo, ifthat's whatyou'd like. Ihaven'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 coordinatingthe depo with him if that's whatyou want. Iam surprised that Judge Goodwin hasn't set the hearing yet. Anyhow, take a look at this draft and let me know your thoughts, Ithink It addresses all ofyour 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 ofthe Regional Counsel 222 West 7th Avenue, #14 Anchorage, AK 99513 8:21 N STREET, S'UlTE:tOB A-NCHORA0f. 1t-I.ASKA**!l95111-~ll6**

October 7, 2014

Re: Robert G. Stanford, Redemption, Inc, Case File No. 2013AL030106 0Ul' FileNo. 139.078 Dear Craig: 

### 2024935142 p 

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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 timingfor 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. Ifyou are not the intended recipient of this email, you may not read, retain, copy, distribute, or disclose the content of this email. Ifyou 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 ofyesterday, 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 ofthis, I also spoke to Steve Skroki yesterday and told him you'd asked to depose Bryant. He told me DOJ was evaluating what itwanted 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 itfor early nextyear. 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 letterto you from Brent Cole. Please let us know Ifyou 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 

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WARNING: The information contained In thiS email (Including any attachments) is CONFIDENTIAL and may be PRIVILEGED COMMUNICATIONS. Ifyou are notthe Intended recipient ofthis email, you may not read, retain, copy, distribute, or disclose the content of this email. Ifyou 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 

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I would like to take Ms. Bryant's deposition the week of November 17, 2014, Please advise atime 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 ofthis email, you may not read, retain, copy. distribute, or disclose the content ofthis 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: eralq.Slack@faa.gov [malito:Cralg .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 ofyesterday. 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 dothis. 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 ofthis, 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 07 1 2014 5:17PM To: Black, Craig (FAA) Subject: Brent Cole Letter-Redemption, Inc. 

### 9072712800 »

Attached is a lettertoyou from Brent Cole. Please let us know Ifyou have any questions. Karin Gustafson Law Office of Brent R. Cole, P.O. 821 N Street, Suite 208 Anchorage, Alaska 99501 (907) 277-8001 (voice) (907) 277-8002 (fax) karin@akcolelaw com(email) 

### 2024935142 p 

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WARNING: The information contained In this email (Including any attachments) Is CONFIDE:NTIAL and may be PRIVILE:GED COMMUNICATIONS. Ifyou are not the intended recipient ofthis email, you may not read, retain, copy, distribute, or disclose the content of this email. Ifyou 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 

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Let's pencil In Christina Bryant forThursday, Nov 20, 9A, I presume atyour 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. Ifyou 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 himselfto 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 » 

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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 offthe pot and figure outwhatthey want to do .with the criminal aspect ofthis, 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 ofBrentR. Cote, P. C. 821 N Street, Suite 208 Anchorage, Alaska 99501 OurTelephone Number: (907) 277-8001 Our FaxNumber: (907) 277-8002 WARNING: The information contained inthis email (including any attachments) is CONFIDENTIAL and may contain PRIVILEGED COMMUNICATIONS. Ifyou are not the intended recipient ofthis email, youmay notroad, retain, copy, distribute, or disclose the content ofthis email. Ifyou have received this email in error, please advise us by calling (907) 277"8001 and/orby return email. Thankyou. Law Office ofBrentR. 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 

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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. Ifthis 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 myagreement 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 orderfrom 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 herthat 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 atthe 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 » 

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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 

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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 ofBrent R. Cole, P, C. 821 N Street, Suite 208 Anchorage, Alaska 99501 Our Telephone Number: {907) 277-8001 Our FaxNumber: (907) 277-8002 WARNING: Tho information contained inthis email (including any attachments) io CONFIDENTIAL andmay contain PRIVILEGED COMMUNICATIONS. Ifyou are not the intended recipient ofthis email, you may notroad, retain, copy, distribute, ordisclose the content ofthis email, Ifyou have received this email in error, please advise us by calling (907) 277-800! and/orby rotum email. Thankyou. Law Office ofBrent R. Cole, P.C.



# L-
__**?~!m!Ei~··**.,.L_ nt
. ./

.... :· l

### 2015-01-15 15:50


## .!**~** ,I 

### ARCALROLEG02

\



### Brent R. 

### Cole Law Office ofBrent R. Cole, P.C. 821 N Street, Suite 208 Anchorage, AK 99501 (907) 277-8001 Attorn.eys for Redemption Air, Inc. 

### 9072712800 » 

### 2024935142 p 

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U.S. 

### DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS WASIDNGTON,DC In the matter of: Redemption Air, Inc. 

### ) 

### ) FAA Case No. 

### 2013AL030106 ) DocketNo. 

### FAA-2014-0115 (Civil PenaltyAction) 

### 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 ifyou so desire. DATED 

### this

## /!'~day ofNovember, 2014, atAnchorage, Alaska. LAW OFFICE OF BRENTR. COLE, P.C. Attorneys 

### for Redemption Air, Inc.

NOTICE OF DEl'OS!TIONOF CHRISTINA BRYANT In re: RedemptionAir, Inc.; Docket No.**FAAn2014~0115** Poge I of2

### 2015-01-15 15:50 ARCALROLEG02

)

CERTIFICATEOFSERVICE 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 ofthe Regional**Couns~l** 222 West 7th Avenue, #14 Anchorage, AX995 13·7587 Cmjg B\Mk¥1\fi)ll.gov Fax: 27I-2800

# cC~~~ 9072712800 »

NOTICE OF DEPOSITIONOF CHRISTINABRYANT In re: RedemptionAir, Inc., Docket No. FAA-2014-0115**Pa~o** 2 of2 

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### 2015-01-15 15:50 ARCALROLEG02 9072712800 »

U.S, Department ofTrnnsportntion Federal Aviatlon Administration

VIA MAIL AND FAX Brent R. Cole Law Office ofBrent R. Cole, P.C. 821 N Street, Suite 208 Anchorage, AK 99501 

### RE: Ourfile: Dear Brent, RedemptionInc. 2013AL030106 Alaskan Region Office ofthe Regional Counsel 222 West Seventh Avenue #14 Anchorage, Alaska 99513-7587 November 17,2014 

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(907) 271-3570 voice (907) 271-2800 fa:x**craig.black@f~utgov** ema(/

As I have made clear for months, the FAAis willing to allowRedemption Inc. to depose Christina Bryant. The only condition wehave placed is that Robert Stanfordnotbe present. As I've explained, Mr. Stanford's assaultive behavior towards 

### Ms. Bryant onthe day inquestion was such that we intend to minimize Ms. Bryant's exposure to

### him. AsI have also explained, we have no objectionto the presence ofany other Redemption representative atthe deposition. I take itfrom yourrecent email that, despite all that, 

### Mr. Stanford intends to be present atMs. Bryant's deposition. Therefore, please take note that, unless youpromptly confirm to me that Mr, Stanfordwill not bepresent, either inthe room orits 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 ofthe Regional Counsel 

### 222 West

### 71:)1 Avenue, 

### #14 Ancb.orage, AK 99513 &21 NSTREF;T,SUlTE:lOS ANCHORAGE.; ALASKA**99~01-1136**

November 

### 17,2014

Re: Robert G. Stanford, Redemption, Inc.

DearCraig: CaseFileNo. 

### 2013AL030106 OurFileNo. 

### 139.078 

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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 seeksanctions against the government. Verytrulyyours, LAW OFFICE OF BRENTR. COLE, P.C.

# ~,C.L Brent R. Cole 

### BR.C/cdb cc: Clic:nt 

# I .,.,

### 2015-01-15 15:50

U.S. Department ofTransportation Federal Aviation Administration 

### ARCALROLEG02

VIA MAIL AND FAX Brent R. Cole Law Office ofBrent 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 ofthe Rt!gional Counsel 222 West Seventh Avenue #14 Anchomgo, Alaska 99513-7587 November 18, 2014 

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(907) 271-3570 vole< (907) 271·2800 fa> cmlg.blnck@fna.govemail

I have receivedthe letter you emailed to me today insisting onMr. Stanford's presence at Ms. Bryant's deposition. As a compromise, we would be willing to allow the depositionto include**th~** use ofour Anchorage video conferencingfacilities, facilities you found acceptable for the RobynBurk depositionjustlast month. We could, for example, have 

### Mr. Stanford participate from the Anchorage FSDO while Ms. Bryantparticipates here in our office in the federal building. I would need to con:fm the availability ofthe facilities, butI'dbe willing to make that arrangementifyou 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 

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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'tthink there's anything more we could do atthis 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 Ifthere 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 oftechnical 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 Ifthe 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 newto 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. Ifyou 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, 

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

### me know ifthis comes offyour calendar for 

### some reason. Otherwise we'll expect Brent then. Thanks. Craig Wm. Black, Attorney FAA: Alaskan Region (907) 27l-3570

2

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### '

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 West7thAvenue, #!4 Anchorage, AK 99513 8ll N STRF.!i:T, SUIT! ln8 ANC'lf0MG£t ALASKA**.9!Jt'i01-21J~**

November 18, 2014

Re: RobertG. Stanford, Redemption, Inc, Case File No. 2013AL030106 OurFile No. 139.078 Dear Craig: TEI,.EPHONE (907) 2."1'7-aOOI n.:u:cdPIER (907) :277-3002



### I am in receipt ofyour 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. Verytruly yours, 

### LAW OFFICE OF BRENT

### R. COLE, P.C.

# ~·~.L BrentR. Cole BRC/pnb cc: Client


# J Qf ]

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FEDERALAVIATION ADMINISTRATION Alaskan Region Office ofthe 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: CraigWm. Black, Esq.

RE: In theMatter ofRedemption, Inc. FAA-2014-0115

Number ofpages (notincluding 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.., ofthe 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 copYhill 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~.**