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FEDERAL AVIATION ADMINISTRATION, FAA DocketNo. CPI0S00004 Complainant, (Civil PenaltyAction) 

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vs. Richard C. Goodwin U.S. Administrative LawJudge RBK DEVELOPMENT, INC., Respondent DMS No. FAA-2010-0199



### ANSWERTO COMPLAINT Respondent, RBK Development, Inc., by counsel, for answer to the Complaint of the Federal Aviation Administration says: L Respondent admits thatthe Respondent has requested a hearing inregard to the proposed civilpenalty inthe amount of$73,500.

II. 1. Respondent denies the allegations contained inparagraph 1. 2. Respondent admits the allegations contained in paragraph2. 3. Respondent admits the allegations contained inparagraph 3. 4. Respondent is without sufficient.knowledge to admit or deny the allegations contained inparagraph4 and therefore denies such allegations. 5. Respondent is without sufficient knowledge to admit or deny the allegations contained inparagraph 5 and therefore denies such allegations. 6. Respondent admits the allegations contained inparagraph 6. 7. Respondent is without sufficient knowledge to admit or deny the allegations contained inparagraph 7 and therefore denies such allegations. 8. Respondent admits the allegations containedin paragraph 8. 9. Respondent is without sufficient knowledge to admit or deny the allegations contained in paragraph9 and therefore denies such allegations.10. Respondent is without sufficient knowledge to admit or deny the allegations contained inparagraph 10 andtherefore denies such allegations. 11. Respondentadmits the allegations contained inparagraph 11. 12. Respondent admits that it offered the shipment of hazardous material for transportation by air but denies that it did so knowingly and did so only as a result of an oversight by an employee ofRespondent. 13. Respondent admits that it offered the shipment of hazardous material for transportation by air but denies that it did so knowingly and did so only as a result of an oversight by an employee ofRespondent. 14. Respondent admits that it offered the shipment of hazardous material for transportation by air but denies that it did so knowingly and did so only as a result of an oversightby an employee ofRespondent. 15. Respondent admits that it offered the shipment of hazardous material for transportation by air but denies that it did so knowingly and did so only as a result of an oversightby anemployee ofRespondent. 16. Respondent admits that it offered the shipment of hazardous material for transportation by air but denies that it did so knowingly and did so only as a result of an oversightby an employee ofRespondent. 17. Respondent admits that it offered the shipment of hazardous material for transportation by air but denies that it did so knowingly and did so only as a result of an oversight by an employee ofRespondent. 18. Respondent admits that it offered the shipment of hazardous material for transportation by air but denies that it did so knowingly and did so only as a result of an oversight by an employee ofRespondent. 19. Respondent admits that it offered the shipment of hazardous material for transportation by air but denies that it did so knowingly and did so only as a result of an oversightby an employee ofRespondent. 20. Respondent admits that it offered the shipment of hazardous material for transportation by air but denies that it did so knowingly and did so only as a result of an oversightby an employee ofRespondent.

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21. Respondent admits that it offered the shipment of hazardous material for transportation by air but denies that it did so knowingly and did so only as a result of an oversightby an employee ofRespondent. 22. Respondent admits that it offered the shipment of hazardous material for transportation by air but denies that it did so knowingly and did so only as a result of an oversightby an employee ofRespondent. 23. Respondent admits that it offered the shipment of hazardous material for transportation by air but denies that it did so knowingly and did so only as a result of an oversightbyan employee ofRespondent. 24. Respondent admits that it offered the shipment of hazardous material for transportation by air but denies that it did so knowingly and did so only as a result of an oversightby an employee ofRespondent. 25. Respondent admits that it offered the shipment of hazardous material for transportation by air but denies that it did so knowingly and did so only as a result of an oversightby an employee ofRespondent. 26. Respondent admits that it offered the shipment of hazardous material for transportation by air but denies that it did so knowingly and did so only as a result of an oversightby an employee ofRespondent. 27. Respondent admits that it offered the shipment of hazardous material for transportation by air but denies that it did so knowingly and did so only as a result of an oversightby an employee ofRespondent. 28. Respondent admits that it offered the shipment of hazardous material for transportation by air but denies that it did so knowingly and did so only as a result of an oversight by anemployee ofRespondent. 29. Respondent admits that it offered the shipment of hazardous material for transportation by air but denies that it did so knowingly and did so only as a result of an oversight by an employee ofRespondent.


### III. 1. Respondent admits the allegations containedinparagraph 1. 2. Respondentadmits the allegations contained inparagraph 2.

33. Respondent denies that a civilpenalty inthe amount of$73,500 is appropriate.

WHEREFORE, Respondent, by counsel, respectfully requests that the Administrative Law Judge deny the civil penalty in the amount of$73,500 and conduct a hearing to determine the appropriatecivil penalty, ifany.



### BY:

__ ____**~~~** 

### __**-r~~** 

### ____________

. Stephen R. Snyder, # 200 WestMain Street Syracuse,Indiana 46567 Telephone: 574/457-3300 srs@sbmlawfirm.com Attorney for Respondent

CERTIFICATE OF SERVICE
The undersigned certifies that on the 

# /1 day ofApril, 2010, a true and correct copy of the foregoing pleading was serveduponthefollowing byFederal Express

- Overnight:
RashawnRichGeorge, Esq. Federal AviationAdministration SouthernRegion, ASO-7 600 Independence Avenue, S.W. Federal AviationAdministration Wilbur Wright Building

- Suite 2WlOOO 1701 ColumbiaAvenue Washington, DC 20591 College Park, GA 30337 Attention: HearingDocket Clerk, AGC-430
TheHonorableRichard C. Goodwin Office ofHearings, M-20 1200NewJersey Avenue, S.E. East Building Ground Floor Room E12-320 Washington, DC 20590

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