09/17/201 0 1G:17 FAX 2024935142 FAA + DMS @1001/015 

UNITED STATKS DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

IN THE MATTER OF 

PRECISION DISPLAYS AND TOOLS 

FAA DOCKET NO. CPO9AL0O08 

(Civil Penalty Action) 

DMS NO. FAA-2009-0733 

.HEPARTMENT OF 

inAMSPORWION 

•i^AhlOPERATiONS 

TM 

FAA'S NOTIFICATION TO .lUDGE RE PRECISION DISPLAYS' 

COMPLIANCE WITH ORDER ON MITIGATION OF PENALTY. 

AND MOTION FOR DECISION SETTING PENALTY 

I. Introduction. 

Complaindnt Federal Aviation Adniinisiration ("FAA"), through counsel, hereby (1) 

notifies the judge of respondent Precision Displays and Tools' ("Precision Displays") 

compliance with the judge's Order on Mitigation of Penalty served August 24, 2010 ("Order on 

Mitigation"); and (2) moves the judge under 14 C.F.R. § 13.218(e)(5) for a decision ordering 

Precision Display-S to pay the $20,000 civil penalty as the FAA prayed in Us complaint. 

II. Background. 

On August 4, 2010. the judge granted the FAA'.s Motion for Decision on Violation.' 

With lliiit order, the judge deemed as proven those allegations of the complaint which concerned 

the violations (effectively summary judgment establishing the 18 regulatory violations as 

alleged), and limited the August 17, 2010 hearing requested by Precision Displays to the proper 

civil penalty to be imposed.^ 

Order Granting Motion for Decision, served August 4, 2010. 

Id. at 2-3. 
09/17/201 0 1G:17 FAX 2024835142 FAA * DMS §1002/01 5 

During the hearing, the FAA explained why the $20,000 civil penalty it prayed for was 

appropriate. In so doing, the FAA addressed all relevant factors including the circumstances of 

the violations, the nature of the shipped materials and the ha7.ards they po.sed. Precision 

Displays' culpability, and the penalty guidance contained in F/\A Order 2150.3B, In response. 

Precision Displays owner Robeit Pcrsckian made general, nonspecific efforts to place Precision 

Displays' ability to pay in issue by speaking generally about the health problems both he and his 

25 year old daughter have stniggled with in recent years and describing how those issues and the 

recent recession combined to decrease Precision Displays' business of late. Beyond M:r. 

Persckian's testimony, at the hearing Precision Displays presented no evidence of its financial 

situation or ability to pay. 

As the judge noted,' it is a respondent'.s burden to demonstrate an inability to pay. 

Hampton Air Service.s. FAA Order No. 97-11 (February 19, 1997; Matter of Guiffrida. FAA 

Order No. 92-72 (December 21, 1992). Nevertheles.?. during the hearing, the judge directed 

Precision Displays to gather,certain financial information and provide it to the FAA for further 

review and suspended the hearing pending that action. The resulting Order on Mitigation 

detailed the financial information that Precision Displays was to provide, and directed the FAA 

to inform d\e judge "whether Respondent has complied with this Order.'"* 

III. Notification Regarding Precision Displays' Compliance. 

" Tr. 43 ("And it's incumbent upon you to demonstrate to the Court that you cannot afford to pay 

whatever it is Mr. Black is asking for."). 

Order on Mitigation at 2. 

Precision Displays and Tools DMS No. FAA-2009-0976 

FAA's Notificaiion to Judge Re Precision Displays' Compliance 

with Order on Mitiealion of Penally, and Motion for Decision 

Seirin}^ Penalty Pa^je 2 
09/17/201 0 16:17 FAX 2024935142 FAA * DMS @1003/015 

As a icsuli of the Order on Mitigation, the FAA received a large box of financial records 

from Precision Displays on September 2, 2010.^ It contained four large bundles of documents, 

one each for 2007, 2008. 2009, and 2010 (tlirough June 30). 

The box contained some, but not all, of the information that the judge directed Precision 

Displays to provide. In addition to being unsorted and generally disorganized, very few of the 

documents provided by Precision Displays arc complete. In particular, nearly all of the banking, 

line of credit, and credit card statements appear to have been printed by the financial institutions 

on two sides. But in providing tho.se statements. Precision Displays copied only one side, 

significantly diminishing the statements' utility and suggesting actual contempt for the judge's 

direction. For example, for a typical 7 page statement, Precision Displays almost uniformly 

provided only pages 1, 3, 5, and 7. forcing die FAA to guess what was on pages 2, 4, and 6, 

thereby undermining the judge's order. Moreover, it appears that Precision Displays has not 

produced information on all of the accounts under its control. And many statements for those 

accounts it has disclosed are mi.ssing. as detailed below. The FAA is prepared to elaborate 

should the judge find these practices material to the issues that remain in this matter. 

A. WTiat Precision Displays Disclosed. 

In its Order on Mitigation, the judge directed the FAA to provide notice of what Precision 

Displays provided pursuant to the order. The following is a catalog of everything that Precision 

Displays provided following the order. 

1. 2007. 

The FAA received the following from Precision Displays for year 2007: 

•' Ex. P. 

Precision Displays and Tools DMS No. FAA-2009-0976 

FAA's Notification to Judge Re Precision Displays' Compliance 

with Order on Miti nation of Penalty, and Motion for Decision 

Setting Penalty Paf^e 3 
09/17/201 0 16:1 7 FAX 2024935142 FAA * OMS E|004/01 5 

6 cSic. 

year-end balance sheet for Mayolo, Inc.; 

year-end profit and loss sheet for Mayolo, Inc.; 

federal and state tax returns for Mayolo, Inc., identified as an S corporation; 

federal and state tax returns for Robert Persckian and his wife Maria Valencia; 

monthly statements for ten credit cards: 

o Amex Business Platinum Card for "Robert Persekian, Precision Jewerly TL";* 

o Amex Blue for Business for "Robert Pcrsckian, Precision Displays" (not 

November); 

o BofA Platinum Plus for Business for "Maria Valencia" (not January or 

November); 

o BofA Visa for "Robert J. Persekian" and "Daad Persekian"; 

o Capitol One Visa Business Card for "Maria V. Barajas" of "Mayolo Inc. DBA 

Traderit Market" (not October-December); 

o Chase Southwest Airlines Rapid Rewards Visa for "Robert Persckian"; 

o Citi Platinum Select Card for "Robert Persekian"; 

o Discover Platinum Card for "Robert Persekian" (January-April only); 

o Home Depot Card for "Robert Persekian"; and 

o Prudential Financial FIA Card Services for "Maria B Valencia" and "Regino 

Barajas"; 

monthly statements for three lines of credit: 

o BofA Commercial Loan to "Mayolo Inc DBA Trade Rite Market" (not 

January. May, or December); 

o BofA Premium CreditLine lo "Robert J. Persekian DBA Precision Boxes 

Displays" (not July); and 

o WaMu Business Line of Credit to "Maria Valencia Barajas DBA Precision 

Jewelry Displays" (not August or December); and 

monthly statements for seven bank accounts: 

o BofA business checking account for "Robert J. Persekian. Precision 

Displays"; 

o BofA business checking account for "Mayolo, Inc. DBA Trade Rite Market" 

(not January); 

Precision Disr>lcm and Tools DMS No. FAA-2009-0976 

FAA's Notification to Judf^e Re Precision Di.'iplays' Compliance 

with Order on Mitiaation ofPetuilty. and Motion for Decision 

Setting Penalty Page 4 
09/17/201 0 16:17 FAX 2024935142 FAA + DMS @1005/015 

o WaMu business checking accouiil for "Maria Valencia Barajas DBA 

Precision Jewerly Displays, Tools, Boxes and Supplies" (not January-June); 

o WaMu business checking account for "Mayolo, Inc. DBA Precision Displays 

and Showcases" (July-October only); 

o 2 WaMu business checking accounts for "Mayolo, Inc. DBA Precision 

Displays and Tools" (both lack January-June, one also lacks NovemberDecember) 

o WaMu business money market account for "Maria Valencia Barajas and 

Robert John Persekian, Precision Jeweli-y Displays Tools Boxes" (AugustDecember only). 

2. 2008. 

The FAA received the following from Precision Displays for 2008: 

• year-end balance sheet for Mayolo, Inc.; 

• year-end profit and loss sheet for Mayolo, Inc.; 

• federal and state tax returns for Mayolo, Inc., identified as an S corporation; 

• federal and state tax returns for Robert Persekian and his wife Maria Valencia; 

• monthly .statements for fifteen credit cards: 

o Amex Business Platinum Card for "Robert J. Persekian, Precision Jewerly 

TL";^ 

o Amex Blue for Business for "Robert Persekian, Precision Displays" (not JulyDecember); 

o Amex Costco Business Card for "Maria Valencia, Trade Rite" (November, 

December ouly); 

o BofA Platinum Plus for Business for ''Maria Valencia" (not January); 

o BofA Visa for "Robert J. Persekian" and "Daad Persekian" (not April. 

August, or September): 

o Barclays US Airways Dividend Miles for "Maria V, Barajas, Precision 

Displays" (August-December only); 

o Barclays US Airways Dividend Miles for "Robert J. Persekian, Precision 

Di.splays" (August-December only); 

o Chase Southwest Airlines Rapid Rewards Visa for "Robert Persekian": 

o Citi Platinum Select Card for "Robert Persekian" (not April); 

^Sic. 

Precision Displays and Tools DMS No. FAA-2009-0976 

FAA s Notification to Judge Re Precision Displays' Compliance 

with Order on Mitiaation of Penalty, and Motion for Decision 

Setting Fenalry page 5 
09/17/201 0 16:18 FAX 2024935142 FAA ^ DMS i006/01 5 

o Citi Advantage World MasterCard for "Maria Valencia" (July-December 

only); 

o Discover Platinum Card for "Robert Persekian" (August-December only); 

o Home Depot Card for "Robeit Pcrsckian"; 

o Home Depot Card for unidentified debtor (August-December only); 

o Pnidential Fimmcial FIA Card Services for "Maria B Valencia" and "Regino 

Barajas"; and 

o WaMu credit card for "Maria Barajas" (December only); 

• monthly statements for three lines of credit: 

o BofA Commercial Loan to "Mayolo Inc DBA Trade Rite Market"; 

o BofA Premium CreditLine to "Robert J. Persekian DBA Precision Boxes 

Displays" (not April); and 

o WaMu Business Line of Credit to "Maria Valencia Barajas DBA Precision 

Jewelry Displays" (not March or May); and 

• monthly statements for ten bank accounts: 

o BofA business checking account for "Robert J. Persekian, Precision 

Displays"; 

o BofA business checking account for "Mayolo, Inc. DBA Trade Rite Market" ; 

o WaMu business checking account for "Maria Valencia Barajas DBA 

Precision Jewerly Displays, Tools. Boxes and Supplies" 

o 2 WaMu business checking accounts for "Mayolo, Inc. DBA P*recision 

Displays and Showcases" (Febiuary-April only); 

o 2 WaMu busine.ss checking accounts for "Mayolo, Inc. DBA Precision 

Displays and Tools" (January-April only); 

o WaMu checking account for "Maria Valencia Barajas" (April, May, July, 

October-December only) ("Robert J. Persekian" added to account in July); 

o WaMu Certificate of Deposit account for "Mayolo Inc." (May only) ; and 

o WaMu business money market account for "Maria Valencia Barajas and 

Robert John Persekian, Precision Jewelry Di.splays Tools Boxes" . 

3. 2009. 

The FAA received the following from Precision Displays for 2009: 

• year-end balance sheet for Mayolo, Inc.; 

• year-end profit and loss sheet for Mayolo, Inc.; 

Precision Displays and Tools DMS No. FAA-2009-0976 

FAA s Notification to Judge Re Precision Displays' Compliance 

with Order on Mitigation of Pencdty. and Motion for Decision 

Setting Penalty Page 6 
09/17/201 0 16:1 8 FAX 2024935142 FAA * DMS g|007/01 5 

H Sic. 

federal and state tax returns for Mayolo, Inc., identified as an S corporation; 

federal and state tax returns for Robert Persckian and his wife Maria Valencia; 

monthly statements for fifteen credit cards: 

o Amex Business Platinum Card for "Robert J. Persekian, Precision Jewerly 

TL" (January-April only); 

o Amex Costco Business Card for "Maria Valencia, Trade Rite" (January-June 

only); 

o BofA Platinum Plus for Business for "Maria Valencia"; 

o BofA Visa for "Robert J. Persekian" and "Daad Persekian"; 

o Barclays US Airways Dividend Miles for "Maria V. Barajas, Precision 

Displays" (Not January); 

o Barclays US Airways Dividend Miles for "Robert J. Pcrsckian, Precision 

Displays"; 

o Capitol One Visa Business Card for "Maria V. Barajas" of "Mayolo Inc. DBA 

Traderit Market" (not August); 

o Chase Southwest Airlines Rapid Rewards Visa for "Robert Persekian"; 

o Citi Platinum Select Card for "Robert Persekian"; 

o Citi Advantage World MasterCard for "Maria Valencia"; 

o Discover More Card for "Robert Persekian"; 

o Home Depot Card for "Robert Persckian"; 

o Home Depot Card for "Maria Valencia"; 

o Prudential Financial FIA Card Services for "Maria B Valencia" and "Regino 

Barajas"; and 

o WaMu credit card for "Maria Barajas" (December only); 

• monthly statements for three lines of credit: 

o BofA Commercial Loan to "Mayolo Inc DBA Trade Rite Market" 

(January-June only), with demand letter dated June 18; 

o BofA Premium CreditLine to 'Robert J. Persekian DBA Precision Boxes 

Di-splays" (not August-IDeccmber); and 

o WaMu Business Line of Credit to "Maria Valencia Barajas DBA Precision 

Jewelry Displays" (not July); and 

• monthly statements for six bank accounts: 

Precision Displays and Tools DMS No. FAA-2009'0976 

FAA's Notification to Judge Re Precision DispUrys' Compliance 

with Order on Mitination of Penalty, and Motion for Decision 

Selling Penalty Page 7 
09/17/2010 16:18 FAX 2024935142 FAA * DMS 0008/01 5 

o BofA business checking account for "Robert J. Persekian, Precision Displays" 

(January-April only): 

o BofA business checking account for "Mayolo, Inc. DBA Trade Rite Market" 

(January-May only); 

o WaMu business checking account for "Maria Valencia Barajas DBA 

Precision Jewerly Displays. Tools, Boxes and Supplies" (became Chase 

account in April); 

o 2 WaMu business checking acc<junts for "Mayolo, Inc. DBA Precision 

Displays and Showcases" (became Chase accounts in April); and 

o WaMu checking account for "Maria Valencia Barajas and Robert J. 

Persckian" (became Chase account in April). 

4. 2010. 

The FAA received the following from Precision Displays for 2010: 

• January 1-June 30 balance sheet for Mayolo, Inc.; 

• January 1 -June 30 profit and loss sheet for Mayolo, Inc.; 

• monthly statements for thirteen credit cards: 

o BofA Platinum Plus for Business for "Maria Valencia" (not January); 

o BofA Visa for "Roben J. Persckian" and "Daad Persekian"; 

o Barclays US Airways Dividend Miles for "Maria V, Barajas. Precision 

Displays"; 

o Barclays US Airways Dividend Miles for "Robert J. Persekian, Precision 

Di.splays"; 

o Capitol One Visa Business Card for "Maria V. Barajas" of "Mayolo Inc. DBA 

Traderit Market"; 

o Chase Southwest Airlines Rapid Rewards Visa for "Robert Persekian"; 

o Chase MasterCard for unidentified debtor; 

o Citi Platinum Select Card for "Robert Persekian" (not January); 

o Citi Advantage World MasterCard for "Maria Valencia"; 

o Discover More Card for "Roben Persekian"; 

o Home Depot Card for "Robert Persekian"; 

o Home Depot Card for "Maria Valencia"; and 

o Prudential Financial FIA Card Services for "Maria B Valencia" and "Regino 

Barajas"; 

Precision Displays and Tools DMS No. FAA-2009-0976 

FAA s Notification to Judge Re Precision Displays' Compliance 

with Order on Mitiaation of Penalty, and Motion for Decision 

Setting Penalty Pcige S 
+ DMS 121009/015 

09/17/2010 16:18 FAX 2024935142 FAA 

• monthly statements for one line of credit: 

o Chase Business Line of Credit for "Maria Valencia Barajas": and 

• monthly statements for four bank accounts: 

o Chase checking account for "Maria Valencia Barajas DBA Precision Jewerly 

E>isplays, Tools, Boxes and Supplies"; 

o 2 Chase checking accounts for "Mayolo, Inc, DBA Precision Displays and 

Showcases"; and 

o Chase checking account for "Maria Valencia Barajas and Robert J. 

Persekian". 

B. What Precision Displays Failed to Provide. 

The following is a discussion of what the judge, through the Order on Mitigation, ordered 

Precision Displays to provide, and what Precision Displays actually provided. 

1, "Tax returns for 2007. 2008 and 2009 for Precision Displays and Tools 

and Robert Persekian, individually" 

Precision Tools provided the tax returns a.s directed. 

2. "Copies of the most recent credit card statements for all credit cards in 

the names of Precision Displays and Tools and/or Robert Persekian, 

individually " 

Precision Tools provided numerous credit card statements, as noted above. However, 

some card statements appear suddenly with prior balances, while other statements abruptly stop 

on cards that carry a balance. Nearly all of the statements are only partially copied: most 

statements appear to have been printed on two .sides, but only one side was copied to the FAA. 

On some of the cards, the debtor is unidentified. Other cards appear to be for businesses, 

particularly Mayolo Inc., or for individuals, such as Regino Barajas and Daad Persckian, with no 

known relationship to Precision Displays. 

Precision Displays and Tools DMS No. FAA'2009-0976 

FAA 5 Notification to .Judge Re Precision Displays' Compliance 

with Order on Mitieation of Penalty, and Motion for Decision 

Setting Penalty Page 9 
09/17/2010 16:18 FAX 2024935142 FAA ^ DMS glOIO/015 

3. "Annual credit card statements for 2007. 2008 and 2009 for Precision 

Displays and Tools and Koheri Persekian, individually" 

None provided. 

4. "Profit and Loss statement for Precision Di.vplays and Tools for the first 

si.x (6) months of calendar 2010" 

Not provided. Precision Displays did produce a profit and loss statement for the 

requested period for Mayolo, Inc., which appears to be a parent company u> Precision Displays. 

However, judging from the disclosed financial information, Mayolo Inc. appears to have 

unknown relationships lo numerous other businesses, including: 

• Precision Boxes Displays; 

• Precision Displays and Showcases; 

Precision Di.splays and Tools; 

Precision Jewelry Displays; 

• Precision Jewelry Displays Tools Boxes; 

• Precision Jewerly Displays, Tools, Boxes and Supplies; 

• Precision Jewerly** TL; 

• Trade Rite; 

• Trade Rite Market; and 

• Traderit Market 

5. "Copies of any outstanding judgments against Precision Di.'iplays and 

Tools and/or Robert Persekian, individually" 

None provided. 

6. "Any other information Respondent deems relevant lo its prayer for 

mitigation " 

• 

* 

"Sic. 

Precision Displays and Tools DMS No. FAA-2009-0976 

FAA's Notification to Judge Re Precision Displays' Compliance 

with Order on Mitigation of Penalty, and Motion for Decision 

Setting Penalty Page 10 
09/17/201 0 16:18 FAX 2024935142 FAA + DMS 12011/015 

None provided. Beyond the items identified in subsection A above, and some loose 

copying receipts apparently generated in response to die judge's order, Mayolo provided nothing. 

Notably, it did not provide an index of the disclosed records or any explanation as to why they 

support Precision Displays' claimed inability to pay the proposed penalty. 

IV. The Judge Should Find tiiat Precision Displays Ha<; Failed to Demon.strate an 

Inability to Pay and Order Precision Displays to Pay a $20,000 Penalty as the FAA 

Requests. 

This case has gone on long enough. Precision Displays has had ample opportunity to 

prove its claimed inability to pay and has failed to do so. Moreover, despite the court generously 

agreeing to suspend the hearing to give Precision Displays additional time to support it'? claimed 

inability to pay, all Precision Displays has done is make half-hearted copies of some 

tangcntially-rclcvant financial records and mailed them to the FAA. 

Undersigned counsel has reviewed all of the records disclosed by Precision Displays and 

sees no reason to believe Precision Displays cannot pay the penalty as proposed. Lideed, the 

records document a business and lifestyle of high spending combined with an ability to convince 

major financial institutions to grant tremendous credit to Precision Displays and its associated 

individuals and entities. 

Precision Displays appears to be shielding significant information from this proceeding. 

In addition to failing to make decent copies of most everything, accounts come and go without 

explanation. Furthermore, there is evidence that significant assets may be being .shielded from 

view. For instance, since at least December 2008, a Washington Mutual (now Chase) checking 

account under Mr. Persekian's name has been used to wire over a half a million dollars to 

unknown accounts. Those accounts include one that, according to the statements, is a 

Precision Displays and Tools DMS No. FAA-2009-0976 

FAA's Notification to Judge Re Precision Displays' Compliance 

with Order on Mitigation of Penalty, and Motion for Decision 

.Selling Penally Page 11 
09/17/201 0 16:19 FAX 2024935142 FAA + DMS 0012/01 5 

"Precisions Displays" account with the Mexico-based financial institution Case De Bolsa. 

Precision Displays has produced no information regarding that account, and it doesn't appear on 

any of Precision Displays' profit and loss, balance sheets, or tax returns. Simply put, it's unclear 

where these funds went or for what purpose. 

As noted above, it is Precision Displays obligation to demonstrate an inability to pay. In 

this case, it has not done so. The judge should recognize this failure and, after allowing 

Precision Displays and opportunity to respond to this motion, rule on the requested penalty. In 

the alternative, the judge should reconvene the hearing to resolve whatever issues remain 

regarding the penalty to be imposed, 

V. Conclusion. 

For the foregoing reasons and the reasons addressed during the hearing, the judge .should 

conclude this matter by ordering Precision Displays to pay the requested $20,000 civil penalty in 

this matter. Failing that, the judge should reconvene the hearing to resolve the outstanding 

question of the amount of penalty to be ordered. 

DATED this _//) -a"av of September, 2010. 

HOWARD L. MARTIN, JR. 

Regional Counsel 

Iff Attorney 

"• To protect Precision Displays' reasonable interest in keeping its financial records private, the 

FAA has not attached any financial records to this pleading. Nevertheless, it stands by its 

characterization of all the records described, and is committed to providing dicrn with whatever 

protections the judge deems fit. in camera or otherwise. 

Precision Displays and Tools DMS No. FAA'2009-0976 

FAA's Notification to Judge Re Precision Displays' Compliance 

with Order on Mitifjation of Penalty, and Motion for Decision 

Setting Penalty Page 12 
09/17/201 0 16:1 9 FAX 202493514 2 FAA •» DMS i013/01 5 

CERTIFICATE OF SERVICE 

Re: Precision Displays and Tools 

FAA Docket No. CP09AL0008 

DMS No. FAA-2009-0733 

I HEREBY CERTIFY that on this date I have served a copy of the foregoing by postage-prepaid 

mail, facsimile, and email to; 

The Honorable Richard C. Goodwin 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor, Room EI2-320 

Wa.shington, DC 20590 

Fax: (202) 366-7536 

Email: Richard.Goodwin@dot.gov 

I HEREBY FURTHER CERTIFY that on this date I have served (1) the original and two copies 

of the foregoing by postage-prepaid mail, and (2) the original of the foregoing by facsimile lo: 

Federal Aviation Administration 

ATTN: Docket Clerk, AGC-430 

Wilbur Wright Building - Suite 2W1000 

800 Independence Avenue, SW 

Washington, DC 20591 

FAX: (202) 493-5020 

I HEREBY FURTHER CERTIFY that on this date I have served one copy of the foregoing by 

postage-prepaid first-class mail to: 

Robert Persekian 

Precision Displays and Tools 

1555 Alum Rock Avenue, Suite 20 

SanJo.se, CA 95116 

DATED: ^^ . //9 . ^tP/ ^ 

Precision Displays and Tools DMS No. FAA-2009-0976 

FAA's Notificaiion to Judge Re Precision Displays' Compliance 

with Order on Mitigation of Penalty, and Motion for Decision 

Setting Penalty Page 13 
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Federal Aviation Administration 

Office of Regional Counsel 

222 West 7th Avenue, Box 14, AAL-7 

Anchorage, AK 99513-7587 

Precision Di.iplavs and Tools DMS No. FAA-2009-0976 

FAA's Notification to Judge Re Precision Displays' Compliance 

with Order on Mitiealion of Peiuilrw and Motion for Decision 

Setting Penalty Page 14 
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^ . P