UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION R E· .c E I VE D 

OFFICE OF HEARINGS 

WASHINGTON, D.C. JUN 2 6 2013 

HEARING DOCKET 

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In the Matter of: 

Southwest Airlines Co. 

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* * FAACaseNo.2010SW290189 

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Docket CP No. - To Be Assigned 

FDMS No. FAA 2013-0050 

Judge Richard C. Goodwin 

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ANSWER TO FIRST AMENDED COMPLAINT 

COMES NOW Respondent Southwest Airlines Co. ("Southwest"), through counsel, and answers 

the First Amended Complaint against it as follows: 

GENERAL DENIAL 

Except to the extent specifically and unequivocally admitted herein, all allegations contained in 

the First Amended Complaint are denied. 

ANSWER TO PART I 

Southwest admits the allegations contained in Part I of the First Amended Complaint. 

ANSWER TO PART II 

1. Southwest admits the allegations contained in Paragraph I of Part !I of the First Amended 

Complaint. 
2. Southwest admits the allegations contained in Paragraph 2 of Part II ofthe First Amended 

Complaint. 

3. Southwest admits the allegations contained in Paragraph 3 of Part II of the First Amended 

Complaint. 

4. Southwest admits the allegations contained in Paragraph 4 of Part II ofthe First Amended 

Complaint. 

5. Southwest admits the allegations contained in Paragraph 5 of Part II of the First Amended 

Complaint. 

6. Southwest admits the allegations contained in Paragraph 6 of Part II of the First Amended 

Complaint. 

7. Southwest admits the allegations contained in Paragraph 7 of Part II of the First Amended 

Complaint. 

8. Southwest admits the allegations contained in Paragraph 8 of Part II of the First Amended 

Complaint. 

9. In response to the allegations contained in Paragraph 9 of Part II of the First Amended 

Complaint, Southwest admits only that Figure 2, Step 18, Note (x) of Boeing Service Bulletin 

(SB) 737-32Al355, Revision 2, March 5, 2008, states as follows: "To get the necessary 

interference fit, it can be necessary to fabricate oversize bushings. CMM 32-16-31 gives data 

for fabrication of oversize bushings." 

10. In response to the allegations contained in Paragraph I 0 of Part II of the First Amended 

Complaint, Southwest admits only that CMM 32-16-31, at Page 2, states as follows: "Make 

oversize bushings per Fig. 1A." 

11. Southwest admits the allegations contained in Paragraph II of Part II of the First Amended 

Complaint. 

12. Southwest denies the allegations contained in Paragraph 12 of Part II of the First Amended 

Complaint. 

13. Southwest denies the allegations contained in Paragraph 13 of Part II of the First Amended 

Complaint. 

14. Southwest admits the allegations contained in Paragraph 14 of Part II of the First Amended 

Complaint. 

15. Southwest admits the allegations contained in Paragraph 15 of Part II of the First Amended 

Complaint. 

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16. Southwest denies the allegations contained in Paragraph 16 of Part II of the First Amended 

Complaint. 

17. Southwest denies the allegations contained in Paragraph 17 of Part II of the First Amended 

Complaint. 

18. Southwest denies the allegations contained in Paragraph 18 of Part II of the First Amended 

Complaint. 

19. Southwest denies the allegations contained in Paragraph 19 of Part II of the First Amended 

Complaint. 

20. Southwest denies the allegations contained in Paragraph 20 of Part II of the First Amended 

Complaint. 

21. Southwest denies the allegations contained in Paragraph 21 of Part II of the First Amended 

Complaint, including all subparts. 

ANSWER TOP ART III 

1. Southwest denies the allegations contained in Paragraph 1 of Part Ill of the First Amended 

Complaint. 

2. Southwest denies the allegations contained in Paragraph 2 of Part III of the First Amended 

Complaint. 

WHEREFORE, Respondent Southwest Airlines Co., through counsel, requests that the 

Administrative Law Judge enter an order finding that Respondent Southwest Airlines Co. did not 

violate any of the Federal Aviation Regulations as alleged by the Federal Aviation 

Administration in this matter, and further requests that the First Amended Complaint be 

dismissed and that no civil penalty be assessed against it. 

Respectfully submitted this 25th day of June, 2013. 

Dane B. Jaques, Esq. 

McKenna Long & Aldridge LLP 

1676 International Drive, Penthouse 

McLean, VA 22102 

Tel: 703-336-8800 

Fax: 703-336-8750 

djagues@mckennalong.com 

Counsel for Respondent Southwest Airlines Co. 

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CERTIFICATE OF SERVICE 

I hereby certify that I have this day served a copy of the foregoing Answer to First 

Amended Complaint on the following party's counsel or designated representative, at the address 

indicated, by UPS overnight delivery: 

Yolanda Ayala Bernal, ASW -7E2 

Federal Aviation Administration 

Southwest Region 

2601 Meacham Blvd., Room 663 

Fort Worth, TX 76137 

Fax: 817-222-5945 or 5092 

I also certify that I have this day served the original and one copy of the foregoing 

Answer to First Amended Complaint on the following, at the address indicated, by UPS 

overnight delivery: 

Hearing Docket 

Federal Aviation Administration 

600 Independence Avenue, S.W. 

Wilbur Wright Building- Suite 2W1 000 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

Fax: 202-493-5142 

I also certify that I have this day served a copy of the foregoing Answer to First Amended 

Complaint on the following, at the address indicated, by UPS overnight delivery: 

The Honorable Richard C. Goodwin, Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. (Ell-310) 

Washington, DC 20590 

Dated this 25th day of June, 2013. 

Fax: 202-366-7536 

s A. Eastwood 

erma Long & Aldridge LLP 

167 6 International Drive, Penthouse 

McLean, VA 22102 

Tel: 703-336-8800 

Fax: 703-336-8750 

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