02/25/2015 08:56 FAX 3107256816 AWP-7 141002 

Western-Pacific Region P.O. Box 92007 U.S. Department 

ofT ransportation Office of the Re!Jional Counsel Los Angeles, Cl\ 90009-2007 

Federal Aviation 

Administration 

FEB 2 5 2015 

Telephone: (310) 725-7117 

Facsimile: (310) 725-6816 

CERTIFIED MAIL- RETURN RECEIPT REQUESTED and FACSIMILE 

F edera! Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building-- Suite 2Wl 000 

Re: In the Matter of Arash Durrani; FAA Case No. 201 2WP050039 

Enclosed is a copy of a request fod1earing, received by our office on February 23. 2015, and 

the. origi11al and one copy of the Complaint in the above-referenced proceeding. 

T request that the hearing in this matter be held in the Los Angeles, Califomia, area, and 

expect !hat the hearing will last one (1) day. 

Please address all communi.cations for the Regional Counsel of the Westem-Pacific Region, 

to the undersigned, at: Office of the Regional Cotmsel, A WP-7.6, Federal A vi.ation 

Administration, Western-Pacific Region, P. 0. Box 92007, Los Angeles, CA 90009-2007, 

Telephone: (310) 725-7117, FAX: (310) 725-6816. 

Sincerely, 

NAOMI TSUDA 

Regional Co~, 

/ ;! 

Enclosures: Request for Hearing; Complaint; Certificate of Service 

NOTE TO RESPONDENT: SECTION 13 :•09 OF THE CP RULES OF PRACTICE 

REQUIRE THAT A WRITTEN ANSWER TO THE COMPLAINT BE FILED NOT 

LATER THAN 30 DAYS AfTER SERVICE OF THE COMPLAINT. AS AN 

ALTERNATNE TO FILING AN ANSWER, A MOUON MAY BE FILED PUF~SUANT 

TO SECTTON l3.208(D) OR SECTION 13.218(F)(l-4) OF THE RULES OF PR/\.CTICF. 
02/25/2015 08:56 F~' 3107256816 A\VP-7 

/ / 

/ 

<ebrua.ry 10, 2015 

:·-fearing Docket Clerk 

i 1ed eral Aviation Administrati.on 

HOO independence Avenue, SW 

'Ni.lbur Wright Building #2Wl000 

l.,Yashington, DC 20591 

.l~e: Arash Durn_mi 

Ca.se 112012WP050039 

Dear FAA: 

SA~~KS l 

SA<2Ks 

.\1' r.·:l(:cl: ,.< :ll" L_,\; 

i am requesting a formal hearing on the above noted case. 

l E you have any questions pie<tse feel free to contact my attorney, Stefan Sacks, at 

(323) 272-7877. 

''ours very lTuly, 

. . . 

i i #.-..., 

r-,~(Z::_{ \ (_) \_r'\_; ':·::. __ 

1\ rash Durrani 

cc. Lerre Green, Esq. 

Federal Aviation Administration 

Of6.ce of Regional Counsel 

P.O. Box 92007 

Los Angeles, CA 90009-2007 

i4J003 
02/25/2015 08:56 FAX 3107256816 AWP-7 

O.S. DEPARTMENT OJ\1' TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, DC 

ln the Matter of Arash Durrani: 

FAA DOCKET UNASSIG:~ED 

FAA CASE NO. 2012WP050039 

Respondent 

JUDGE NOT ASSIGNED 

COMPLAINT 

141004 

The Complainant files its Complaint, pursuant to Rule 208 of the Rules of Practice 

(14 C.F.R. 13.208), and states as follows: 

L 

Respondent A rash Durrani, was advi.>ed through a Final Notice of Proposed Civil 

Penalty, dated January 28, 2015, that the FAA proposed to assess a civil penalty in the 

amount of$24,000.00. On February 19,2015, Respondent submitted a written rcqllest for a 

hca<ing. The request was received by the agency on February 23, 2015. 

II. 

I. On or about September 25, 20 12, Respondent was a passenger on hoard 

United Airlines flight 473, operating from Chicago O'Hare IDtcmationa: 

Airpott, Chicago, Illinois, to John Wayne Airpon, Santa Ana, Califomia. 

2. Ou the above occasion, Unired Airlines flight 473 was operating under part 

J 21 of the Federal Aviation Regulations. 
02/25/2015 08:56 FAX 3107256816 AlVP-7 141005 

0 -' 

3. During the flight's safety briefing, a crewmember informed passengers that 

they were required to comply with lighted passenger informatim signs and 

crewmember instructions, including infonnation on seat belts. 

4. Later in the flight, Respondent refused repeated crcwmembers' inslwctions 

to return to Respondent's seat, and continued to walk about the aircraft whik 

the "Fasten Seat Belt" signs were lighted throughout the aircraft. 

5. Respondent became belligerent when crewmembers refused. to serve 

Respondent more alcohol and when crewmembers refi.tsed Respondent's 

repeated and loud invi.tations t-o drink shots with Respondent. 

6. Respondent physically assaulted several crewmembers by kissing them on 

their checks. 

7_ Respondent was restrained to keep Respondent in Respondent's scat. and 

w!Jile restrained, Respondent spat on passengers and screan1ed that 

Respondent would "murder them all." 

8. \Vhile restrained, you bittwo passengers, and tried to choke at least one 

passenger. 

9. Respondent's conduct referenced in the above paragraphs interfered with one 

or more crewmembers in the performance of the crew111embers' duties. 
02/25/2015 08:56 FAX 3107256816 AWP-7 

III. 

By reason of the foregoing facts and circtmlstances, Respondent violated the follnwing 

sections ofthc Federal Aviation Regulations (Title 14, Code of Federal Regulations): 

li1J 006 

4 

(a) Section 121.317(£), which stat(:s that each passenger required by Section 

121.31 l(b) to occupy a seat or berth shall fasten his or her safety belt about him 

or her and keep it fastened while tile "Fasten Seat Belt" sign is lighted: 

(b) Section l2L317(k), which states that each passenger shall comply with 

instructions given him or her by a crewmember regarding comp·,ianee with 

paragraphs (f), (g), (11), and (1) of this section; and 

(c) Section 121.580, which states that no person may assault, threaten, intimidate, or 

interfere with a crewmember in the performance of the crewmember's duties 

aboard an aircraf1. 

IV. 

I. Pursuan1. to Title 49 U.S.C Section 4630 l(a), Respondent is suJ:,ject to a civil 

penalty not to exceed $11,000.00 for each of the violations alleged. 

2. Under the facts and circumstan,;es of this case, a civil penalty of$24.000.00 

is appropriate. 
02/25/2015 08:57 FAX 3107256816 AWP-7 141007 

5 

WHEREFORE, the Complainant, respectft!lly requests that the Administrative Law 

Judge enter an order that Respondent be assessed a civil penalty in the amO\mt of· 

$24,000.00. 

Respectfully submitted, 

/', 

.. ).i ... -

~ . . I . . ' 

I,......- Co::= 

Licrre Green 

: Att<i;,ey 

\-Dffice of the Regional Counsel 

Federal Aviation Administration 

Western-Pacific Region 

DATED: FEB 2 5 2015 
02/25/2015 08:57 FAX 3107256816 AWP-7 

CERTIFICATE OF SERVICE 

I hereby certifY that on this date I have sent by facsimile and placed in the United 

States mail, postage prepaid, certified mail -return receipt requested, the executed original 

and one copy ofthc Complaint. addressed as :follows: 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building-~Suite 2 WI 000 

Facsimile: (202) 267-1293 

l further certify that on this date I have placed in the United States mail, postage 

prepaid, certified mail -rerum receipt requested, and regular mail, a true copy of the 

Complaint, addressed as follows: 

Dated: 

Arash Durrani 

141 Arena Street 

El Segundo, CA 90245-3902 

And a copy by first class mail to: 

Stefan E. Sacks, Esq. 

Sacks & Sacks 

190 1 A venue of the Stars, Suite 200 

Los Angeles, CA 90067 

FEB 2 5 2015 

n -fu /7 i~iJ· -;6_. JeffKrun~eg~l Technicia0-

0fficc of the Regional Counsel 

Federal Aviation AdnJinistration 

Western-Pacific Region 

Lawndale, Califomia 

l{l] 008 
02/25/2015 08:56 FAX 3107256816 AWP-7 li!J 001 

', 

Phon 

Fax: ~-

From 

Title: 

Hearing Docket Clerk, AGC-430 

.~ .. (202) 267,-1293 

Lierre Green 

FAAAttomex, AWP-7"6 

Federal Aviation 

Administration 

Office of the Regional Counsel, AWP-7 

PO Box92007 

Los Angeles, CA 90009-2007 

Telephone: (310) 725-7117 

Facsimile: (310) 725-6816 

Email: 

Facsimile 

~ February 25, 2015 ___j 8 Description of item being lr,lnsmrtted: 

Pages w/rover: Complaint 

D Per your Request D For Review 0 Please Comment 

D For Coordination ~ Hard Copy to Follow via US MAIL 

NOTES/COMMENTS: 

RE: Administrator, FAA v" Arash Durrani, 2012WP050039 

The irformation contained in this facsimile message is intended for the use of the designated ad<lressee only" 

The irformation transmitted may be subject to the attorney-client privilege or may be protected under the Privacy 

Act l' you are not the designated addressee and you receive this document through inadvertent error, any further 

review', dissemination, distribution or copying of this communication is strictly prohibited" IF YOU RECEIVE THIS 

COMMUNICATION IN ERROR, PLEASE NOTIFY THE SENDER IMMEDIATELY BY TELEPHONING (310) 725-

7100 ANP DESTROY THE ORIGINAL OF THIS COMMUNICATION, Thank You" 

0 U.S. Dep;'>rtment of lransportation