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U.S. Department 

of Transportation 

Federal Aviation 

Administration 

April 6, 2012 

Hearing Docket 

Federal Aviation Administration 

Atten: Hearing Docket Clerk 

Hearing Docket Room 2014, AGC-400 

600 Independence Avenue, S.W. 

Washington, D.C. 20591 

800 Independence Ave .. S.W. 

Washington, D.C. 20591 

Re: In the Addison Jet Management, Inc. I 

FAA Case No. 20 II SW91 0053 /r.ffi 6l.Pld. • O ~:o5 .9-01@ ~ f\uJf\- c_f()- b 11 Db 

Dear Madam: 

Pursuant to Rule 208 ofthe Rules of Practice (14 C.F.R. 13.208), the Federal Aviation 

Administration hereby files the complaint in the above referenced matter. 

Y-s~ ~· Autumn Killingham 

Enforcement Division 

Office of the Chief Counsel 

(202) 267-7728 

cc: Gerald P. Shaw 

Addison Jet Management 

7515 Lemmon Ave 

Dallas, Texas 75209 
U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

) 

In the Matter of Addison Jet Management, Inc. · ) 

) 

JUDGE NOT ASSIGNED 

FAA Case No. 2011SW910053 

COMPLAINT 

The Federal Aviation Administration ("Complainant") by counsel, hereby files its Complaint, 

pursuant to Rule 208 of the Rules of Practice (14 C.F.R. 13.208), and states as follows: 

I. 

On October 4, 2011, Respondent was advised through a Notice of Proposed Civil Penalty that 

the FAA proposed to assess a civil penalty in the amount of $8149. On March 30, 2012, 

Respondent submitted a written request for a hearing. 

II. 

1. At all times mentioned in this document, Addison Jet Management, Inc. 

("Addison") was the holder of Air Carrier Operating Certificate No. 15JA697J issued under 14 

C.F.R. Part 119 and appropriate operations specifications issued under 14 C.F.R. §135. 

2. On or about January 18, 2010, Addison hired Victoria McKown as a pilot, a 

safety-sensitive position. 

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3. On or about August 2, 2010, Ms. McKown operated civil aircraft N213HP (listed 

on Addison's operations specifications as Airplane M/M/S CE-650-650 SIN 6500133) as pilotin-command on a round-trip flight from Dallas, Texas to San Diego, California under Part 135 of 

the Federal Aviation Regulations. 

4. Pursuant to 49 C.P.R. §40.25(a) and (b), Addison did not obtain drug and alcohol 

record checks from DOT -regulated employers who had employed Ms. McKown during any 

· period during the two years before the date of Ms. McKown's application to Addison. 

5. Pursuant to 49 C.P.R. §40.250), Addison did not ask Ms. McKown whether she 

refused pre-employment drug or alcohol testing, or whether she tested positive on any preemployment drug or alcohol test for application to safety-sensitive transportation work covered 

by DOT testing rules. 

III. 

1. By reason ofthe foregoing, Addison violated the 49 C.P.R. § 40.25, in that Ms. 

McKown was not subject to a drug and alcohol records check implemented in 

accordance with this subpart, specifically that she and all DOT-regulated employers 

who had employed her during the two years before her date of application to Addison 

were not questioned about her drug and alcohol test results. 

2. Under the facts and circumstances of this case a civil penalty of $8149 is appropriate. 

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WHEREFORE, the Agency, by counsel respectfully requests that the Administrative Law Judge 

enter an order that Respondent be assessed a civil penalty in the amount of $8149. 

Peter J Lynch 

Assistant Chief Counsel 

for Enforc 

Killingham · 

En cement Division 

0 ICe of the Chief Counsel 

(202)267 -7728 

PLEASE NOTE: 

Pursuant to Title 14 CFR § 13.209(a), you are required to file a written answer to his Complaint, 

or a written Motion to Dismiss if appropriate, not later than thirty (30) days after the date shown 

on the Certificate of Service which follows. 

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CERTIFICATE OF SERVICE 

I hereby certify that the foregoing Complaint, in the Matter of Addison Jet Management, Inc., 

FAA Case No.2011SW910053, has been mailed this date by Certified Mail to: 

Gerald P. Shaw 

Director of Operations 

Addison Jet Management 

7515 Lemmon Ave. 

Dallas, TX 75209 

The original and;-a copy was also delivered to: 

Hearing Docket 

Room 2014, AGC-400 

Federal Aviation Administration 

600 Independence Avenue, S.W. 

Washington, DC 20591 

~Ocw'w April 6, 2012 

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