12/20/2010 6 . 11PM FAX 

(gjOOO 1/0017 

Michael Selig, MD, FACC, CFl-H 

2816 0refield Road 

Allentown. PA. 18104 

"j 1 

iARTMENTOF, 

HOPERMiONS 

i::r 9q p 9: 50 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

Federal Aviotion Administration 

Laura Ponto, Cynthia Dominik, 

Latonya Williams 

Complainants 

M & R Helicopters, LLC. 

Respondent 

Honorable Judge Ronnie Yodei 

Docket: 2010-1211 

RESPONDENT'S REPLY TO COMPLAINANTS LATE RESPONSE TO RESPONDENTS 

MOTION TO DISMISS AND MOTION TO STRIKE ALLEGATION 

AND NOW, comes respondent, MICHAEL B. 5EL1G. MD, FACC. 

principle for MR Helicopters, LLC, (MRH) whom avers and files the following Reply 

to Complainants past deadline Response to MRH's Motion to Dismiss and Motion 

to Strike Allegation (Mr Baker was not on a Drug/Alcohol program), that does 

not directly address the respondents enumerated paragraphs and in breach of 

Rule §206.2, in addition to being loquacious while cobbling color of Law 

statements, that are impermissibly vague and inaccurate, side stepping 

respondents argumenis, 

1. On November 19, 2010, respondent received the certified mail 

served complaint. 

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12/20/2010 B;11PM FAX 

2. On November 27, 2010, Preliminary Objections was taxed and 

submitted to Ms Pontes department, to which no objection or answer was 

submitted in the 10 day deadline period in violotion to §13.21B(d) Exhibit 1-fax 

confirmation sheet). 

3. On November 29, 2010, a Motion and Brief to Quash, Strike or 

Dismiss Complaint was faxed and sent to Mr Pontes department, to which no 

objection or answers were received within the 10 day deadline under § Rule 

13.220(d) (Exhibit ll-fax confirmation sheet). 

4. Ms Dominik of the FAA enforcement division of the chief counsel 

called respondent directly admitting that the complainants did not file 

responses within the )0 day deadline period, were in breach of this regulation 

and thereby requested a continuance. Exhibit 2 shows call log of respondents 

telephone showing Ms Dominiks number 202-267-7560. 

5. Respondent refused a continuance and requested the case be 

dismissed on these grounds, 

6. Complainants makes an incredible claim that the motion to dismiss 

does not have a basis even though respondent stated in the Motion os well as 

the associated brief, that prima face proof has been provided that 

categorically states Mr Baker always was on a drug/Alcohol program. Had Ms 

Williams or Ponto had done their due diligence to check this material fact, they 

would have found the statement correct. 

7. The alleged violation for Mr Baker according to Ms Williams 

^Vj Sn9e6t202 XVd 6S:eL 0L0S/G3/SL 
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120003/0017 

Inspector Statement lOP 9 record, was due to "inability to find FAA approved 

drug and alcohol testing program intormotion for Flight Methods". Mr Baker was 

not employed by Flight Methods, but by Air Methods Corporation, therefore Ms 

Williams erred in this fundamental fact driving the violation, 

8. Ms Pontes then claims a basis for the violation could therefore be 

locking compliance with item A4499(o) which states that: 

The certificate holder who operates under title 14 code 

of Federal Regulations Part 135 cerfiiies that it will 

comply with requirements of pari 12 J appendences I 

and J and part 40 for its antidrug and alcohol misuse 

program. 

MRH did have its own program compliant with part 121 appendences I 

and J and part 40 through NADE for its antidrug and alcohol misuse program for 

which the pilot respondent -who was not in any other program, was primarily 

on. 

9. Complainant admits that the above regulations ore not clearly 

evident in the signed operation specifications, but because they are publicly 

available and published somewhere in a Federal Registry to be found only 

through a random search and find mission, that the respondent should be held 

responsible to those regulations, 

10. The FAA*5 own Drug/Alcohol abatement officer Vincent Roots during 

his "in camera" audit of MRH in April 2004, failed to inforrTi MRH or was informed 

himself, of the FAA changed definition of the word "employer" that occurred in 

Februory 2004, apparently listed somewhere in a Federal Registry, affecting 

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appendices 1 and J, thereby encouraging a violation rather than encouraging 

compliance. 

11. Complainants failed to respond to the fact that MRHS regular FAA 

operations and maintenance inspectors, Frank Aiotta and Gerry Henininger, the 

Allentown FSDO manager Mr Wadsworlh, which is across the street from where 

ihe aircraft has been inspected and hangared for 10 years, were also unaware 

of the regulation change somewhere in the Federal Registry, even though 

always asserting that all personnel performing safety sensitive functions were on 

a program, thereby confirming compliance rather than violation and thus 

encouraging the violation, 

12. The complainants chose therefore to hold MRH to a higher standard 

than their own FAA officers. 

13. The signed operation specification A449- had a control number of 

January 22, 2004, thereby respondent agreed to conditions directly related to 

the regulations at that point in time, before the definition of "employer" was 

changed. 

14. Footnote 4 makes assertions that MRH is incredibly arguing that it 

has no obligation to comply with safety regulations unless it is given explicil 

notice. What is incredible is complainant's argument that MRH should have 

complied with a regulation change that none of the above local authorities did 

not know of, or was Informed of, contrary to other transparent notification 

practices that occur routinely in the operation and maintenance procedures. 

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15. Complainants incredibly allege that because Mr Baker was not on 

respondents own drug program, but on a program of another employer, that 

the statement that he was on a program does not qualify and the statement 

can not be affirmed despite the proof and the pretenses set forth above. 

16. At best the above cose scenario is interpretational: 

In Administrative Law "/n the interpretation of the 

language of regulations, where doubt exists as to the 

intent of the mean/ng of the language written and 

enacted by a governing body, ihe language shall be 

interpreted in favor of the Party and against any implied 

extension of a restriction". 

It is asserted that the MRH always had its own drug program since 

inception, could have easily included the additional personnel in that program, 

had the respondent been informed or been aware of the regulation change by 

s^r Roots or MRHs local inspectors or other method as they have done in all other 

aspects of operations and in the consistent forthright transparent manner for all 

other operational changes. 

17. Contrary to Judicial Estoppels, complainants altempted 1o redirect 

their offense concerning the new definition of "employer" appendices I and J, 

clauses hidden, omitted, not evident in the operation specifications, 

compliance statement or even the FAR/AlM by asserting that Mr Baker was not 

on MRH's own prograrm, even though on another companies program and the 

complainants already released and withdrew all such similar violations agoinst 

the other AP/IA, thereby showing prima foci© legal inconsistency, 

b 

WVj 2nS8Gt20 2 XVJ GS:eL 0102/GZ/2 1 
010006/0017 

12/20/2010 B;13PW FAX '*' 

18. Once realizing and forced to cobble together color of law 

arguments, that Mr Baker was on on approved drug and alcohol program, 

complainants attempted to re-craft for a better offense by asserting that Air 

Methods did not authorize Mr Baker to perform maintenance under their repair 

station certificate, knowing that Mr Baker under regulation is permitted 1o perform 

his safety sensitive functions under his own A/P certification. 

19. Once realizing and forced to cobble together color of law 

arguments, that Mr Baker was on an approved drug and alcohol program, 

complainants attempted to re-craft for a better offense by asserting that the 

testing program is somehow differenf for a pilot than that of a mechanic, when 

they both fall under safety sensitive functions to which there is not different testing 

program. One is either drug/alcohol free or not no matter what function they 

perform. 

20. Complainants allege that withholding requested discovery does not 

warrant dismissal of the complaint. Complainants responded past the 10 day 

filing deadline to the Respondents Motion to Compel Discovery and on that basis 

alone in addition warrants dismissal of the complaint that has fundamental legal 

insufficiency and interpretational discrepancies, for a company whom decided in 

good judgment for the best interests and safety of the public to withdraw all 

operations due to the respondents tragic 5 year divorce, alienation of his children 

and other human factors such as medical practice workloads beyond his 

capability. 

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21. Complainants refused to produce or object to full disclosure of 

redacted, spoliated and altered documents or to provide their quoted references 

according to rules of procedure, for withholding information, when respondent 

stated he was unable to locate those documents, By claiming that documents 

are publicly available is unacceptable in litigation according to standard rules of 

evidence and in breach of Rule 901(7). 

22. Respondent makes note of the complainant confirmation and 

admission that the alleged violation is valid and proper in that the last violation of 

Mr Baker occurred on July 24, 2008 and the notice of proposed Civil Penalty was 

issued on July 23, 2010,1 day before the 2 year statue of limitations. Respondent's 

office is closed on Fridays, (Hospital rounds only). The complaint was not received 

or served until July 27, 2010,3 days past the statute of limitations (Exhibit 3). Strict 

proof is demanded on trial, thereby the violation is past the deadline period once 

again. 

23. Complainants incredibly allege that even though MRH ceased 

operating under name and certificate number, respondent could have obtained 

another pilot to continue operations. The complainants perhaps wittingly or 

unwittingly failed to disclose that respondents tasks, responsibilities and liabilities 

extended past his pilot functions, as a single pilot operation but included 

operations control, maintenance scheduler and assistance and every aspect of 

the operation, thereby complainants again attempt to impair the dignify of the 

court, 

7-

ao/iooia 

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I2]000t)/0017 

12/20/2010 6:13PM FAX 

By way of further answer, respondent decided in good judgment for th© 

best interests and safety of the public, considering his own human factors and in 

accordance to regulatloris, to withdraw all part 135 operations due to the 

respondents tragic 5 year protracted divorce (2006 to present Hearing docket of 9 

pages already submitted), alienation of his children, relocation, financial and 

emotional devastation and other human factors such as his solo cardiology 

practice and hospital workloads beyond his capcity. The position taken by 

complainants represents "beating an injured man who already down", behavior 

that is unconscionable, even though no harm or damages have been done and 

in good judgment and in good faith relinquished his operations for the public 

safety. 

24. It is further averred that while the violation does not hove clear, 

transparent undisputed merit, lends many issues to interpretation and fine print, 

appears to be prosecutorial overreaching, breaches rules of court, has many 

procedural defects, violates judicial estoppels, while respondent has made every 

effort to operate in good faith and judgment, victim to circumstances, the 

company MRH no longer exists, has no assets, has lost monies during the time 

frame and continues to loose (Exhibit 4). 

25. On December 1, 2010, a Motion for Deposition of Latonya Williams 

was faxed and sent to Mr Pontes department, to which no objection or ansvs/ers 

hove been received within the 10 day deadline under § Rule 13.220(d) or to tfiis 

date, yet another breach and reason to dismiss this complaint. 

8 

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12/20/201 0 6;13PM FAX 

1210003/0017 

26. It is respondent's averment that the persistence to pursue this 

complaint with so many defects shows the complainants in true light as 

malfeasant, in abuse of discretion and process, in breach of duty and conduct 

and in attempting to obstruct justice for respondent to pursue this violation. 

27. The sanctions are thereby inappropriate, frivolous, trivial and in alt 

aspects, points to issues that are or have been moot. 

28. In all and best efforts for judicial economy, the case therefore 

should be dismissed to allow the administrations seasoned efforts be properiy 

directed to other areas or high volume, large operation violation cases most 

pertinent to the public safety of our counlry. 

WHEREFORE, the respondent prays that this Honorable Court will dismiss the cose. 

^.vVx 

Respectfully Submitted, 

Michael B. Selig, MD, FACC , CFl-H ^ ^ ' ,^ ^ 

Date 

-9 

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12/20/2010 6: 13PM FAX 

11/30/£OJ.O 0:14PU FAX 

310O1O/0017 

@0002 

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O 

U.S. Deportmen t office of ih« Chlof Counsal 600 Indapwidsnce Ave., Sw. 

oT Tfansportoilon Waehlngton, DC 20591 

F«<l«rol AvlQllon 

Administration 

FEDEI^LE;CPKESS ^^^^ ^ >^;,^,,f, 

July 23, 2010 

Dr. Michael B. Sclig 

president 

M&RHelicopters,LLC ^ JUL 2 7 2010 

2045 Westgatc Dr. 

Suite 205 

Bethlehem, PA 18017 

RE: CaseKo: 2009SO950434 

NOTICE OF PROPOSEP CIVIL PENALTY 

Bused upon a report of investigation, it appears that: 

1. M & R Helicopters, LLC (M & R Helicopters) is now, and at all times mentioned 

in this document was, the holder of Air Carrier Cenificato No. MR3A020K, issued under 

14 C.F.R. part 119 and authorized to conduct operations under 14 C.F.R. part 135 of the 

Federal Aviation Regulations. 

2. At all times mentioned in this document, M & R Helicopters' operations 

specifications required it to comply with 14 C.F.R, Part 121, Appendices I and J and 49 C.F.R. 

Port 40 for its antidrug and alcohol misuse prevention program, 

3. At all times mentioned in this document, 14 C.F.R. § § 135.251 (a) and 135.255(a) 

required that M & R Helicopters test each employee who performs a safety-sensitive function 

listed in 14 C.F.R. part 121, Appendix I and J in accordance with those appendices. 

4. Under 14 C.F.R. part 121, Appendix I, § III, an employee who performs aircraft 

maintenance or preventive maintenance duties, directly or by contract for M & R Helicopters, is 

performing a safety-sensitive function and must be subject to drug testing under an antidrug 

program implemented in accordance with that appendix. 

5- Under 14 C.F.R. part 121, Appendix J, §n.A, an employee who performs aircrafl 

maintenance or preventive maintenance duties, directly or by contract for M & R Helicopters, is 

performing a safety-sensitive function and must be subject to alcohol testing under an aJcohol 

misuse prevention program (AMPP) implemented in accordance with that appendix. 

fAfe-^ 

^ ^ j 3nse6t20 2 XVJ 00: n 0L02/62/ 2 

iL0/3L0i a SWQ <• — 
12/20/201 0 G:14PM FftX 

,SCHEDUL E C 

(Form 1040) 

—•n^wrrai R*»«iwy s«>Vic» (99; 

^Vif c •v'V«' U 

Profit or Loss From Business 

(Sou Proprlstordhip) 

i2|0013/0017 

OMBN». I«*5-0074 

•- Partnerships, joint ventures, etc, niiutflle Fonn 1065 or10d5-B. 

••Amch toFwiBlMO, 1M<|NR, or 1041. - 9a« Instructian* for 5ch«dule c (Form ^ 040), 

2007 

<MUchlT<»nl _ _ 

Bxiu«nc«N». 0 9 

MICHAEL B SEIIG 

A PrinclM' «t«lM5i or proTtuJan, Innlvdlno sfOdiiEl er lerwiM CMt ln«bbell«m) 

HELIC(yTER TBAHSPORTATIOia 

M&R HELICOPTERS, LLC 

0 DT>play»rlftmi»iiS»r<BIR),TTiny~ 

E AMiMit-MiMiineiuriingtwitewrMmno-)*'2045 WESTGXtE DRIVE SUITE 10 1 

y AccounluriQ method: (1) jXlCuah O) [jAccrual (3> [ J 0(her <»pocify) - ^ ____J1 » 

a Dia you -msurpally peifticlpat«' io th« operation of this ousineu durino 2007? If 'No,' Kca Inslructiena lot limit on looses. 

H j][X° " sw^tetJ o< acquired thla bLisiness durinfl 2007, cheek hare -. ^> ._^ 

"(XTYM 

\ Incoma 

'niJo 

1 GroM r9C«lpE5 or salM. Caution. IT this incoma was reported t& you an Form W-2 and lh« p~ i 

'Staluloiy amployoe' box on that torm was checked, sea the Instructions and ch«ck hor© •'J | 

2 Ratwns and ollovencos ,... 

3 SubUac» lino 2 from line > 

A C<a\ of goods sold ^fftan jinft 4 2 on page 2) 

B OroH profit. Subtract line 4 from line 3 ,,, 

e other inooma, including federal and Slate gasoline or fuel tax credit or refund 

(see instructlorw) 

7 pro w fncomo. Add Hne» S and B. 

1,440 . 

1.440 , 

1,440 , 

ir^^D: 

Exgenses . Enter expenses for buslnew os> of yaur home only on llna 30 

9 Advertisfns. 

^ Car and truck oxpensoB 

(see instrucltons), 

10 ConunisBlorts and tees.. 

11 Conlracl labor 

(soe lo«trocllons) 

12 Depletion 

19 Deproelatlen and section 

179 experiw deduelion 

(not Included In Part »ll) 

(see instructloni) 

U EmplDvea benefit programs 

(other than on line IS) 

IB Insurance (other than health). 

i e Intereat: 

a Mortgi0« (paid (o bania, eic)...... 

bOther 

^y Legal A profasaionel aorvteeg^, 

10 

n 

12 

^8 

14 

15 

16a 

iftfe 

17 

764. 

68,254 , 

7.228 . 

18 OHice eKpanae 

19 Pension and profit-sharing plans 

20 Rent or lease (see instructions): 

• Vehicles, machinefy, end equipment. 

b Otiier business propariy ,,,. 

21 Repairs and maintenance 

22 Supplies (not included in Pan 111).... 

23 Taxes and llcenaea 

24 Travel, meals, and «ntertainmer\t! 

• Travai 

bDaductibie meals and enlsrtalnment 

(see inetructlons) ,, 

Zft utilities 

20 Wag«> (lesa emplDyment credits)..., 

27 Other expanses (from line •*fl ori 

P«Qe Z> • • • 

IS 

19 

aoa 

20b 

21 

M 

23 

24a 

24 b 

26 

26 

3,221 . 

13,574, 

2,4B7 . 

4,630 , 

2B Tola! evpcnsas before expanses for buelnasv use of home. Add lines 8 through 37 In columns. 2ft 120,156. 

29 Tontatlvo profit (lo»»). Subtract line 28 from line 7 

30 Enpanses tor business use of your home. Attach Form 9929. , 

31 Net profit or OO«B)> Subtrvol line 30 from line 29. 

e If a profit, ertter on botb Ferin 1040, lln» 12. and Schedule SB. line 2 or on Form 

1040NR» Ima.ia Csialutoiy amployaes, $e« inatfiicUons), Estates ana trusts, enter on 

Z9 •iifi,7ie. 

30 

1 

Fonmckl.Hnea , 

• If a (OSS, you must 0° l« Una 92, 

32 If yeu have a loss. Check the box that desoribes your invesimont In this actlvjiy (see jnsirucllons). 

• If you checked 32a. enter the IM S on both Form 1040. lino 12, and Schedule SE, line 2, or on Form 

1Q40NR. Itnti a (rtatutory employeos. s«e lnstriictlon«), Eetates and trustn, enter on Form 1041, line 3. 

If you cheeked 3gb, you mu»t attach FonnClOB, Your loss may be tirnHad. 

31 •118,7ie-

^ A A forPapetwork Reduerien Act Nellc«i ea« Perm 1040 InatmcUone, 

__, Air.lnvostmenl Is 

321(7 ] at ( W 

,—, Some Investment 

92b [ I is not at risk. 

Schedule C (Form 1040) 200 

Foizouai. <:Bi\i(07 

'eAkf L^ 

iLO/CLOi a SWO VVJ 3tLS66t202 XVJ OO-l^l 010S/6S/2I 
12/20/2010 6:14PM FftK 

Scliedule C (Form 1040> 2007 MICHAEL B SELIG 

110014/0017 

Sold (see InttrviCtlons) 

33 li^elhod(5> jsed to value cloalno Inventory: a |_Jcoat b |_J Lower of coi l or market " T [_J Other (attBcFi explanation)" 

is^mmmsnriissm^ 

.34 Was tham any chanoe in daiermining quantities, costs, or valLiBiioru between Opening and closing Inventory? _ . 

tt 'Yes,'*Uach explanation Qfe a FJ n 

39 Inventory at beginning of year. If different from last year'Q closing inventory, 

attach explanatlori , , 

38 PurohDsofi less cost of llams withdrawn for personal use.., 

97 Coat of labor. Do not Include any amounts oald to yourself. 

Sfi Maleriels and Supplies. ,,, 

39 Other costs , 

40 Add lines 3a through 3* 

41 (nventory.at end of year. 

42 costpf goods told . Subtraet line 41 from line 40, Enter Ihfl result here and on page 1. line 4. 

35 

a 

37 

39 

89 

40 

41 

1,163 

1,160 

1,168 

42 costof goods told. Subtraet llna 41 from line 40, Enter Ihfl result here and on page 1. line 4 | 42 | 

liRitfeJiySw Infomtaitlon o n Your V«hic|ei complete this part only if you are clalmina car or truck expenses on line 9 and are not 

required to file Form 4662 Tor this buslnau. 9ee the instrucllons for line 13 lo find out if you must file Form 4062. 

4S When did you place your vehicle In service for business purposea? (month, dey, year) 

44 Of the total number of miles you drove your vehicle during 2007, enter the number of miles you used your vehicle for: 

aBusinees _ _ b Commuting (soo instructions) _ cOlher _ 

At Do you (or your spouse) have another vehicle avellsble for personal use? Q Yes Q N

40 Was your vehicle available for personal os* during off-duty houn?..,, Q Yes [[ ] Ut 

47a Do you have oYldenceto support yoqr deduction?. , LJYBB QN 

blfYes.'Is the evidence written? ._. ._. -,.,-... HYes HN 

raBSE^JB^ Other Expanses. y»t below business expi^nses not Included on lines 8-g6_of line 30. 

JANK^CHM^S. 

DWIG_ PROGRAM, 

J)UKS_ AND. SOTlCRIPTIONg. 

JLIGHT_Il^mRjJCTlpM. 

m&L 

^OTSIDE SERVICES, 

J'pSTJ^gB 

JELEPHONE 

15 

274 

94 

1.311 

1,684 

90 

96 

B66 

48 Total other ewxtmeg. Enter hers and on page 1, line 27. 46 4,630 

Schedule C (Form 1040) 20

FDizensL ae/15/oy 

iLO/tLOia SWO ^ VVJ StLSGGt20S XVJ l0:i?L 0L03/G2/21 
12/20/2010 S-.14PM FAX 

1210015/0017 

SCHEDUL E C 

(Form 1040!) 

D«psf unani of ifw Treatury . 

Irtern4l Reveoua Servjca (99 ) 

Profit or Loss Prom Business 

(Sole Proprietorship) 

*• Partnerships, joint ventures, etc, generally rnust file Form 1065 or 1065-6, 

'Attach to Form 104D, 1040NR, or 1041. *>$«« Instructions for Schedule C {Form 1040). 

Nftrrbg ol DroprLvLor 

MICHAEL B SEUIG 

-nr 

OMBNe. 19^9.0074 

2008 

AHBch(r»nl rta 

3iqu«nc« No, W 

fit Princlp*! buslMni or proltuton, l/icliJdina protfvict (H (arvlct (M< inilrudlDiK) 

HELICOPTER TRANSPORTATION 

C Eliisln«tE nano. \t no soparala buafnets nan<c, lov c blank, 

PR HELICOPTERS. LLC 

nrlal ««ri,rf^/ hllmhrir /^^M\ 

itr •mpi^«riiinDiiu>«r(mii;, iTiny • — — 

E Buiintia iddraH (MciiKJina w<» »r «ani „o.j-_2045_ WESTGATE_DRIVE _SyiTE_205_ 

Cily. town Of posloWiCT. SW», und ZIP coac BETHLEHEM , P A 1901 7 

F Accountino method; ll ) [XjCash (^1 Q]Accrual (3) (_]Other (specify) •• ^ 

G Did you 'materially participate' in the operation of this business during 200S? If 'No,' see instruciions ior llmJl on losses. 

H If you started or acquired this business during 2008, check here 

•[xfYes^'T No 

PartlrjJg^iil lr^come 

Gross receipts or sales. Caution. See the instructions and clwck the box if: 

• This income was reported \o you on Form W-2 and trie 'Statutory omployao' box on iJial torm was 

checked, or 

• You are a member of a qualified joint venture reporting only rental reel estate ineomo not sub|ect r—i 

to self-employment tax. Also sea instructions for limit on losses ^ | j 

Returns and allowances 

Subtract line 2 from line 1 

Cost of (joods sold (irom line 42 on papa 2). 

Gross profit. Subtract line 4 from line 3 

6 Other income, including federal and stale Qaaoline or fuel tax credit or refund 

(sea instructions) 

7 Gross income. Add lines 5 and G 

Piaiirt'lltfflf.j| Exponsos . Enter expenses for business use of your home only on lino 30 

1,465 . 

1,465 , 

1,465 . 

1,465 . 

8 Advertising. 

10 

72 

13 

xpe 

(see instructions; 

Commissions and fees.. 

imrscnsDOT 

(see instructions) 

Depletion 

Depreciation and section 

17^ expense deduction 

(not Included In Part III) 

(see instructions) 

14 Employee benefit programs 

(other men en line 19) 

15 Insurance (other than health). 

16 Interest; 

a Mortgage (paid to banKs, etc) 

b Other 

17 Lecjal & professional services 

10 

11 

12 

13 

14 

15 

16i 

16b 

17 

1.00ft, 

145 

85,21 1 

6,109, 

865 

18 Office expense.. 

19 Pension and profit-sharing plana, .. . 

20 i^ent or lease (see instructions)'. 

a Vehicles, machinery, and equipment. 

b nthPf hiisineg< nmnorlv . , , 

21 Repairs end maintenance 

22 Supplies (not included in Part 111). 

23 Taxes and licenses 

24 Travai, meals, and entertainment: 

a Travel 

b Deductible meals and entertainment 

(seo instructions) 

25 Utilities 

26 Wages (less employment crcdiii) — 

27 Other expenses (from lino 4B on 

page 2) 

ia 

19 

20 a 

J ^ 

21 

22 

23 

24 a 

24 b 

25 

26 

27 

.?..?7$. 

5^537 , 

4,345 . 

,,(i^i--;:>:fft,i:;';:,iiif-:-,:A>'^-.., 

28 Total expenses before expenses for business use of home. Add lines 6 through 27.. 

29 Tentative profit or (loss). Subtract line 28 from line 7 

30 Expervses for business use of your home. Attecti Foim 8B2a 

31 Nat pront or (loss). Subtract line 30 from line 29-

• If a profit, enter on both Form 1040, line 12, and Schedule SE. line 2 or on Form 

1040NK, line 13 (if you checked the box on ling 1, see instructions). Estates and 

trusts, enter on Form 1041, llh« 3. 

• If a loss, you must go lo line 32. 

32 If you have a lo^s, check the box that describes your investment in this activity (see instructions). 

• ir you chookod 32a, enter the loss on both Form 1040. Una 12, and Schedule SE, line 2, or on Form 

104t)NR, lino 13 (if you checked the box on line 1, see the line 31 instructions). Estates and trusts, enter 

on Form 1041, line a. 

• If vou checked 32b, you mvsl attach Fonn 6198. Your loss may be llmiled. 

28 107,096. 

29 -105,631 . 

30 

31 -105,631 

_^ All investment is 

32 a [X] at risk. 

- _ Soma Invoslment 

32 b n is noi at risk. 

BAA For Paperwork Reduction Act Notice, see Form 1040 Insntidlons. 

F0IZ911SL IVVVOQ 

Schedule C (Form 104O) 2008 

iio/sioia SWO VVJ 3tLSe8t30S XVd lOtL 0L02/G2/S 
@]0016/0017 

12/20/201 0 6;14PM FAX 

iqe : 

36 

Schedule C (Form 1040) 2006 MICHAEL B SELI G 

PartiH^i,,! Cos t o f Good s Sof d (sec inalfuctlona) 

33 Melhod(s) used to value closing inventory, a [_J Cost b [_J Lower ofTost or "market" c ( J OtheRattacTi expiifiiationF' " ' "" 

34 Was there any change in determining qoentitles, costs, or valuations between opening and closing inventory? , , , , 

If 'Yes," attach explanation , LlYe s MN o 

1,168. 

36 Purchases less cost of items withdrawn for poroonol use 

37 Cost of labor. Do not include any amounts paid to yourself.. 

38 Materials and supplies 

39 Other costs , 

40 Add lines 35 throuoh 39 

41 Inventory at end of year 

42 Cost of goods sold. Sutrtraet line 41 from line 40. Enter Ihe result here and on page 1 ^ lino 4 

37 

36 

39 

40 

41 

42 

-i,Qoe. 

160, 

160. 

tPatty'rVv.-'l Informd^lo n o n You r Vehicl e Complete thb part only it you are claiming cai of truck expenses on line 9 and are not 

required lo file Form 4562 for this business. See the instructions for line 13 to Rnd out if you must file Form 4562. 

43 vvnen did you place your vehicle in service for business purposes? (month, day, year) ^_ 

44 Of the total number of miles you drove your vehicle during 2008, enter the number of miles you used your veliicle for: 

a Business b Commuting (see instructions) _ _ cOther _ 

45 Was your vehicle available for personal use during off-duty hours? 

46 Do you (or your spouse) have another vehicle available for personal use?. 

47 a Do you have evidence to support your deduction?. 

b If 'Yes,' is the eviderKe v>ritten7 

QYes QNO 

QYCS QNO 

LJY« LJNo 

Piart.V'vy!| Otho r Expanses . List below business expenses not included on tines 8-26 or tine 30. 

_BANK. CHWIGES_ 

DUES AND SUBSCRIPTIONS 

JEASABILITY _STUDy_ ^ 

FLIGHT INSTRUCTION 

_FUEL___ 

POSTAGE 

_TEIjEPHONE_ 

TESTING COSTS 

5 5. 

1,175. 

922, 

1,482, 

96, 

580 , 

3 0 , 

4B Total other expenges. Enter here and on peflg 1, line 27, 48 4_^34S. 

Schedule C (porm 1040) 2008 

FDizoiirt lujowi 

iL0/9L0l SWQ <• 

VVJ 

StLSeBtSOS XVd LO:i?L OLOS/GE/Z 
1210017/0017 

12/20/2010 6-15PM FAX 

U.S. DEPARTMENT OF TRANSPORTATION 

'Federal Aviation AcfmlnlstraHon "" 

Cynthia Dominik, Loura Fonto, Latonya Williams 

CoiTiplainants 

Docket: 2010-1211 

V, 

M & R Helicopters, LLC. 

Respondent 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY thot I have this day setved the foregoing entrie(s); 

RESPONDENT'S REPLY TO COMPLAINANTS LATE RESPONSE TO RESfONDENTS MOTION TO DISMISS 

AND MOTION TO STRIKE ALLEGATION 

RESPONDENT'S SUPPORTING BRIEF TO ANSWERS TO COMPLAINANTS RESPONSE TO MRH S MOTIONS 

TO DISMISS AND STRIKE ALLEGATION 

upon ail parties of record in Ihis proceeding, in accordance wiiti the requirements of Rule 29 

purjuont to 28 U. S. C. § 17ii)6. 

Service bv fet-class mail, oostoae prepaid, addressed as follow^: 

Federo) Aviation Administration 

800 Independence Avenue, SW 

Wilbur Wright Avenuo-Suite 2W1000 

Washington- D.C. 20591 

Att; Hearing Docket Cierk, AOC-430 

FAX 202 493 5142 

The Honorable Ronnie A. Yoder 

US Department of rronsporfation 

Office of Hearings, M-20, Room El 2-320 

120O New Jersey Avenue. S.E. 

Washington, DC 20590 

FAX 202 366 7536 

Laura Ponto, Esq, 

Enforcement Division/AGC-300 

Office of the Chief Counsel 

FAA 

800 Independence Avenue, 5W 

Washington, DC 20591 w V v \ \ 

PAX 202 267 5106 . ^ CiV^ V - / ^ 

By: ^ ^ \y 

Michoel B. Selig, MD. FACC. ^ 

r^ <;wn ^ VVd 2t!LSS6tiS02 XVd lO-VL 0L03/6S/ S