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')ro-r f\C 1;-;A)!QD(\~T!\TI0)\\ 

L [,1 I Vl r;:~>i,>:ir0i1\ir,U~~. DEPARTMENT OF TRANSPORTATION 

I! 1'.1 \,-," OFFICE OF HEARINGS 

..,. -; [) I,. F,EDERAL AVIATION ADMINISTRATION i-l , :;'\.i -<, JAN 27 2010 

,HEARING DOCKET 

1 

FEDERAL AVIATION ADMINISTRATION, 1 

Complainant, 1 

1 

vs. 1 FAA Case No. 2008CE170 150

1 Judge 

SKYDIVJj KENTUCKY LLC I 

Re~pondellt 

I f!.rtlft!Eml / a~01-/IJ/J .-----1 

Comes Skydive Kentucky T,l ,C, Respondent, by COl1n~el, and for it~ Answer to the 

Complaint ofthe Federal Aviation Administration, Complainant, states as follows: 

I 

1. Respondent admits paragraph J of the Complaint. 

IT 

2. Respondel1t admits paragraph 11-1 of Lhe Complaint. 

3. With reference to paragraph Il-2 ofthc Complaint, Respondent affinnativcly states 

that illlmely retained King Aircraft Title, Inc. (King Title) to handle the registration ofN5927B 

and timely sent the documents and lees to King Title which Respondent believed were required 

in order to appropriately register N5927B. For reasons unknown to Respondent, King Title did 

not timely follow·up on its assignment to timely cause N5927B to be registered to Respondent 

and Respondent was not notified hy King Title thal there was any problem in the titling process 
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prior to August 30,2008. Respondent was under the reasonable impression on and prior Lo 

August 30, 2008, that King Title was appropriately handling the registration ofN5927B and was 

unaware that registralionhad not been accomplished lIntil so advised by representatives or 

Complainant after August 30,2008, Re~"Pondent flLrther affirmatively states it did not 

intentionally al10w N5927B to be operated in violation of law. 

4. Respondent admits paragraph 11-3 ofthe Complaint. 

5. Respondent dcni0s paragraph 11·4 orthc Complaint. 

6. With reference to paragraph 11-5 ofthe Complaint, Respondent admits that the flight 

ofN5927Bon August 30,2008, a subJect ofthis action, terminated by landing in a field~C +\.L ~'w'II\ i! ........ 6-., .of ~,j .p.""... r""I\).. • 


7. Respondent admits paragraph II-6 of the Complain.t. 

8. Respondent denie!l paragraph JT-7 oCthe Complaint. 

9. Respondent admits paragraph 11-8 oHhe Complaint. 

10. Respondent admits paragraph 11-9 of the Complaint and aftirmatively states that at 

the time ofthe tlight on Augu!;t :'0,2008, that is a subject ofthis action, there was no inoperative 

equipment on N5927B LoRe~p()ndcnt's knowledge. 

I!. Respondent denies paragraph JT·lO ofthe Complaint 

12. With rcl,-:rcnce to paragraph 11-11 ofthe Complaint Respondent affirmativeJy states 

Li1at it had timely retained King Title to handle registration matters conceming N5927B, that it 

was unaware on August 30, 2008 that registration had not been completed, that N5927B had 011 

hoard an Aircraft bill of sale showing Respondent the owner ofN5927B and an Application to 

Register (pink copy) N5927B, to Respondent dated June tJ, 2008 autholizing operatiorJ [or a 

period not in excess ofninety (90) days and the remainder of said para!:,'raph is aumitted. 

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III 

13. With reference to paragraph III-I (a),(b),(c),(d) and (e), Respondent admits the 

provisions ofthe laws cited and denies any intenLional violation t.hereof 

14. With reference to 111-2, Rcspondent ad.m1ls the provisions of the laws cited ::md 

denies allY intentional vIolation thereof. 

15. Respondcnt denies paragraph TIT-3 oflhe Complaint. 


1(). Respondent denies an allcgatiolls of the Complaint nol admitted herein. 


Wherefore, Respondent respecLfully requests that the Administrative Law Judge: 


1. Dismiss the Complaint; 


2. Alternatively, assess a lesser and more reasonable civil penalty for those 

violations actually proven committed considering the facts; 

3. 	 All proper reliet: 

Respectfully submitted, 

lien K. ;lor $= 

Tt-IE GAILOR LA W OF[IICB, PLLC 

100 Professional Arts Building 

730 West Markel SLreet 

Louisville, Kentucky 40202 

(502) 584-7217; Fax (S02) 584-4848 

Counselfor Respondent 
.. _ ... _._

,. 

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CERTIFICATE OF SERVICE 

. . 13 tJr;. I hereby certify thal a copy of the roregoing Answer was mailed this __day of 

January, 2010 to; 

Hoaring Docket Clerk 

FAA, AGC·430, Suite 2Wl 000 

Wilbur Wright Building 

800 Independence Avenue, SW 

Washington, DC 20591 

Taneesha D. Marshall 

Federal Aviation Administration 

Office ofthe Regional Counsel, ASOa7 

Southern Region 

P.O. Box 20636 

Atlanta. GA 30320 

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