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;PmRTMENTOF 

!-\NiSPORWION 

v::\ETOPERATiONS 

I.INITED STATES DEPARTMENT OF TRANSPORTATION.,, ..,^, , ^- ^ ^ ^ r 

FEDERAL AVIATION ADMINISTRATION .i^iJ * vW 15 P i^ j b 

) 

In the Mailer of: ) 

Corporate Air ) FAA Case No. 2008NM700126 

) 

) 

RESPONDENT'S ANSWER TO COMPLAINT AND 

STATEMENT OK AFFIRMATIVE DKFENSES 

Respondent Corporate Air hereby answers, by counsel, the Complaint filed in this 

proceeding by Regional Counsel to the Federal Aviation Administration, and sets forth 

ailirmativc defenses to this civil penally claim. FoHoAving the numbering of the sections 

in the Complaint: 

I 

1. The allegations contained in Section I of the Complaint are admitted. 

U 

2. It is denied that Corporate Air regularly oilers or accept.'* hazardous material 

(HAZMA T). The remaining allegations contained in Section II (1) of the 

Complaiat arc admitted. 

3. The allegations contained in Section 11 (2) of the Complaint are admitted. 

4. The allegations contained in Section II (3) of the Complaint are denied, with 

strict proof demanded thereof. 
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5. Tlie allegations contained in Section TI (4) of the Complaint are admitted. 

6. The allegations contained in Section 11 (5) of the Complaint are admitted. 

7. The allegations contained in Section IT (6) of the Complaint are admitted, 

8. llic allegations contained in Section U (7) of the Complaint are admitted. 

9. It is denied that the aircraft was a Corporate Air aircraft. The remaining 

allegations c<intaincd in Section IT (8) of the Complaint are admitted. 

10. The allegations contained in Section 11 (9) of the Complaint are admitted. 

11. The allegations contained in Section II (10) of the Complaint are admitted. 

12. The allegations contained in Section II (11) of the Complaint are admitted. 

13. The Respondent is without sufficient information to either admit or deny the 

allegations contained in Section II (12) of the Complaint. They arc therefore 

denied. 

14. The Respondent is without sufficient information to either admit or deny the 

allegations contained in Section IT (13) of the Complaint. They arc therefore 

denied. 

15. The allegations contained in Section II (14) of the Complaint are admitted. 

16. The allegations contained in Section 11 (15) of the Complaint are admitted. 

17. The allegations contained in Section 11 (16) of the Complaint arc admitted. 
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18- The allegations contained in Section 11 (17) of the Complaint are admitted, 

although the Respondent denies that this allegation is relevant. 

19. The Respondent is without sufficient information to cither admit or deny the 

allegations contained in Section TI (18) of the Complaint. They are therefore 

denied. 

20. The Respondent is without sufficient information to either admit or deny the 

allegations contained in Section U (19) of tlic Complaint. They are therefore 

denied. 

21. The allegations contained in Section 11 (20) of the Complaint are admitted. 

Ill 

22. The allegations contained in Section TIT 1 (a)-(i) of the Complaint are denied. 

Further, the Respondent submits il is without personal knowledge or 

obligation to respond to the allegations contained in Section III. 

23. The allegations contained in Section 111 (2) - (3) of the Complaint are denied. 

24. All other allegations not specifically addressed arc hereby denied. 

RESPONDENT'S STATEMENT OF AFFIRMATIVE DEFENSES 

1. The Complaint fails to state a claim warranting the proposed penalty. 

2. The Complaint fails to state a claim upon which relief may be granted. 
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Wherefore, Respondent, CORPORATH AIR, respectfully requests that judgment be 

entered in it.s favor, and that the Complaint and civil penalty of the Federal Aviation 

Administration be dismissed with prejudice. 

This J day of November, 2010. 

CORPORATE 

Cynthia Chandler-Sncll 

Attorney Ibr Corporate Air 

Senior Attorney - Regulatory Affairs 

Federal Express Corporation 

3620 Hacks Cross Road 

Building B, 3'*' Floor 

Memphis, TN 38125 

(901)434-8361 

(901) 434-8283 FAX 

CERTIFICATE OF SERVICE 

1 htTchy certify that the foregoing Answer has been sent via Priority Ovcmight on 

this, the _ ^1 day of October, 2010 to: 

Federal Aviation Administration 

800 Independence Avenue, SW 

Wilbur Wright Building, Suite 2W1000 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Mr. Scott Morris, Attorney 

federal Aviation Administration 

Office of the Regional Counsel (ANM-7) 

1601 LindAve.,S.W. 

Ronton, WA 98057 

Cynthia Chandler-Snell