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U.S. DEPARTMENT OF TRANSPORTATION 

ApI'

, '( "f\ ~ " 2010 OFFICE OF HEARINGS 

I: 4FtEDERALAVIATION ADMINISTRATION r'iEARING DOCKET 

FEDERAL AVIATION ADMINISTRATION, FAA Docket No. CPI0S00004 

Complainant, (Civil Penalty Action) r-At:1 ~f)fD" 0I'1J 

vs. Richard C. Goodwin 

U.S. Administrative Law Judge 

RBK DEVELOPMENT, INC., 


Respondent DMS No. FAA-2010-0199 


ANSWER TO COMPLAINT 

Respondent, RBK Development, Inc., by counsel, for answer to the Complaint of the 

Federal Aviation Administration says: 

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Respondent admits that the Respondent has requested a hearing in regard to the proposed 

civil penalty in the amount of $73,500. 

II. 

1. Respondent denies the allegations contained in paragraph 1. 

2. Respondent admits the allegations contained in paragraph 2. 

3. Respondent admits the allegations contained in paragraph 3. 

4. Respondent is without sufficient. knowledge to admit or deny the allegations 

contained in paragraph 4 and therefore denies such allegations. 

5. Respondent is without sufficient knowledge to admit or deny the allegations 

contained in paragraph 5 and therefore denies such allegations. 

6. Respondent admits the allegations contained in paragraph 6. 

7. Respondent is without sufficient knowledge to admit or deny the allegations 

contained in paragraph 7 and therefore denies such allegations. 

8. Respondent admits the allegations contained in paragraph 8. 

9. Respondent is without sufficient knowledge to admit or deny the allegations 

contained in paragraph 9 and therefore denies such allegations. 
10. Respondent is without sufficient knowledge to admit or deny the allegations 

contained in paragraph 10 and therefore denies such allegations. 

11. Respondent admits the allegations contained in paragraph 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 of Respondent. 

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 of Respondent. 

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 

oversight by an employee of Respondent. 

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 

oversight by an employee 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 

oversight by 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 of Respondent. 

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 of Respondent. 

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 

oversight by an employee of Respondent. 

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 

oversight by an employee of Respondent. 

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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 

oversight by an employee of Respondent. 

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 

oversight by an employee of Respondent. 

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 

oversightby an employee of Respondent. 

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 

oversight by an employee of Respondent. 

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 

oversight by an employee of Respondent. 

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 

oversight by 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 

oversight by 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 an employee of Respondent. 

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 of Respondent. 

III. 

1. Respondent admits the allegations contained in paragraph 1. 

2. Respondent admits the allegations contained in paragraph 2. 

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3. Respondent denies that a civil penalty in the 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 appropriate civil penalty, if any. 

BY:__ ____~~~__-r~~____________ 

. Stephen R. Snyder, # 

200 West Main 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 of April, 2010, a true and correct copy of 

the foregoing pleading was served upon the following by Federal Express - Overnight: 

Rashawn Rich George, Esq. Federal Aviation Administration 

Southern Region, ASO-7 600 Independence Avenue, S.W. 

Federal Aviation Administration Wilbur Wright Building - Suite 2WlOOO 

1701 Columbia Avenue Washington, DC 20591 

College Park, GA 30337 Attention: Hearing Docket Clerk, AGC-430 

The Honorable Richard C. Goodwin 

Office ofHearings, M-20 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor 

Room E12-320 

Washington, DC 20590 

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