02/U/201 1 1C!;02 FAX 2024935142 FAA + OMS 121001/017 

"'PARIivpTpF 

Michael Selig, MO, FACC, CFI-H'^'^O^'^'^''^' 

2816 0refielclRoad 

Allen town, PA. 18104 

'-jO?r:MQ-'Z 

•;•: n i 

DECEIVED 

HEAR/NG DOCKET 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

Federal Aviation Administration 

Laura Ponto, Latonya Williams 

Complainants 

M & R Helicopters, LLC. 

Respondent 

Honorable Judge Ronnie Yoder 

Doc Iceh 2010-1211 

NOTICE OF FILINGS 

NASA FORM AND PETITION TO RULEMAKING, PROPOSED CHANGES 

AND NOW, comes respondent, MICHAEL B. SELIG, MD, FACC, 

principle for MR Helicopters, LLC, (MRH) (non-existent since 2009) whom files the 

following submissions to NASA and Rulemaking. 

1. Respondent for the reasons set forth in prior pleadings believes the 

alleged civil penalty has been filed in bad faith and continued with unrelenting 

disregard to governmental spending. 

2. It is respondent's averment that the cited violation was initiated for a 

time period when MRH was not even in operation and therefore is frivolous from 

the onset. 

1 -
02/14/2011 10:02 FAX 2024935142 FAA - DMS 0002/01 7 

3. It is respondent's averment that the regulation cited for violation was 

not clearly stated or written, word for word in the compliance statement or 

operation specifications or even present in the FAR/AIM. 

4. It is respondent's averment the location on a remote site of the 

regulations cited for violation was not exactly noted or referenced, therefore in 

affect concealed, hidden and ambiguous from the compliance statement and 

operations specifications. One can only premise that if a mechanic is on a 

monitoring program by whatever means, that would indicate compliance. 

5. Respondent's was never informed of this violation change, until years 

later that a regulation change occurred in February 2004 concerning 14 C.F.R. 

part 121 appendices 1 and J, definition of employer. 

6. Because there is no notification process for the Drug/Alcohol 

abatement program in place, similar and following suit to that which exists for its 

operations and maintenance compliance procedures, it is respondent's 

averment that it was impossible to know of this change, unless first locoting the 

regulations and second the randomly comparing regulations side by side to 

differences, an impractical and time consuming process fraught with error, 

encouraging violation rather than compliance in the spirit of assuring safety. 

7. The is no sign off procedure as there is for the operations and 

maintenance compliance protocols, cleariy delineating in spelled out written 

format and then confirming knowledge of the changes by signoture 

authorization and even return of the old, replaced voided operation 
02/14/201 1 10:03 FAX 2024935142 FAA * DMS 0003/01 7 

Specifications. 

8. In fact, respondent was audited by FAA drug/Alcohol abatement 

officer Mr Vincent Roots in April 2004, after the regulation change occurred, who 

also was never Informed the in -house regulation change and therefore unable 

to inform MRH of the regulation change. 

9. In fact, respondents local Allentown FAA operations and 

maintenance inspectors were not informed of their own agency regulation 

change and even though frequently inspected all of MRH operations, finding 

MRH always complying with regulations, never informed them of this change. 

10. It is respondent's averment and proof hereto that the agency is 

trying to hold MRH to a higher standard than even its own officials, who were not 

informed of the regulation change. 

11. It is respondent's proposal through Nasa and through rulemaking 

that in order to encourage compliance in the spirit of safety, that all 

drug/alcohol regulations be contained within the compliance statement and 

operation specifications 

12. It is respondent's proposal through Nasa and rulemaking that in order 

to encourage compliance in the spirit of safety, that all drug/alcohol regulation 

changes be set forth in a notification process identical to those which currently 

exist for the operation specifications. 

13. It is respondent's averment and request hereto, that the agency 

dismiss the violation as the process is flawed and unjust. 

3-
02/14/201 1 10:03 FAX 2024935142 FAA ^ DMS 0004/01 7 

WHEREFORE, the respondent prays that this Honorable Court will either dismiss 

the matter before this court and that rulemaking make the above proposed 

changes to provide unambiguous disclosure and a forth right method of 

notification. 

Respectfully Submitted, 

Michael B. Selig, MD, FACC . \ n \A ^ 

Date * 

fF 
02/14/201 1 10:03 FAX 2024935142 FAA •s- DM S 21005/017 

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02/14/201 1 10:03 FAX 2024935142 FAA * DMS 0006/01 7 

CONSEQUaiCCS / OUTOMIE 

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TIT>E OF AIRCHMT (MAKE / MOOe.) AND BUM E TTPE 

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(.-^•iMuJ ni« iiiiMMfii, ^ a *rial can ba aora ID prvwil if fi^^ui^HKA. o< cofjeci trie silualion 

Hicrhael Selig, HD, FACC2eie Orefl^ld Road 

Allentown, PA. 18104 

In reierence ro Federal Violation docket r«<Tu.l3C<oro.arg 2010-lzil 

U.S. DEPARTMENT OF TBAMSPOBTATIOM 

OFFTCF. OF HZAHrUGS 

WASHfNGTON, D.C. 

Federal AviBcion Adinin^strsti.oTi 

L^ura PonLO 

Con^lAinanL 

M 4 R Kellcopter?, T,LC. 

Rcapandenr TAH Caar. 200950950431 

PBZLIHINART OBJECTIONS 

AND NOW, cornea reaponden, MTCHAEL B. SEIIG, MD, FACC, piir.ciple for MR 

rialicopcera, LiC, (hiRH) whore avers and fi'eo tho following Pr6li=j.:i4iy ObJecLiona pursuar.t to 

$13.20fi(d) to Che complaint auluiitced by the Federal Aviation MminLitracian aaaocxate i,aura 

Ponto, Eaq. hereby assercin? that the allegarlona nade in the coTnpl?ir.r arr. c^rred, not proper, 

teaaonable oi acceptable, and thereby :he ccmplaint anould be atricken and diamiased. 

Count TConatitutea conclusions of law to which no answer ia required purauant to the 

federal rules of court. 

Count II 

1. Aqreed in part. MRH haa net been able to carry on part I3 i operations alnce 

Aucfuat ZODI, on account of the sir.glo pilot operator naa either bean unavailable to paaa or ta)ce 

hia flijht e«aB for personal reasons (protracted divorce, iiabiiiry isauea) or the inspector i/aa 

unavailable to perform a fll<7ht exan (medical leave) . HUH haa sini:e ceaaaa operating under the 

name and under the certificate nuaibei. ownership of helicopter has changed, linanciaia nave been 

irlsaed, chefeby rendering the compliir-t moot-
02/14/2011 10:03 FAX 2024935142 FAA + DMS 12007/017 

ASVS-M»ifiten»FEtniocfTFarTn lJ3!9/\l4:ilAM 

2 . Denied. The operation apecificatlons were algnsd off in ?004 (Exhibit 1) . Ac the 

time of Sign off, the regulation nou finding MlMt in violation had been changed without 

notification. By way of further anawar 14 C.F.R. part 121, Appendix I and J and 49 C.F.R. 

part 40 are not dlaeloaed, clearly delineated or spelled out in the eompllance statement, 

operational apecifieatlona, not readily available ir, the FAH/AIH and thereby one can asaune az a 

less iiRportant than other regulatioca that are clearly disclosed In the signed operational 

specifications- ?he*e regulatlona were thereby hidden aAd concealed. 

3. Oanied. Regulatiena 135.251 and 135.2S5 as written in the conpliance scatenient and 

confinned by the respondent does not inherently atata that MHH must directly teat each employee 

who perfocna a safety senaiti-re function (Exhibit 2) but empirically states that any contractor 

be covered by an FAX approved drug and alcohol testing prograTM. These individuals referred to, 

did comply with .Tiandatory drug and alcohol testing regulationa by way of their fell time 

wnployera. 

In ad.'niniaLrative law in the Interpretation of the language of regulations, wnara doubt 

exists as to the InKent of the iwaning of the language writLen and enacted by a governing body, 

the language shall he interpreted In favor of the operator and against any implied extension of 

the restriction"^. 

4. Dcniod- All individuals performing aaiaty aenaitivc functions on MRH aircraft were 

at all Llinea subject to randon drug and alcohol testing programs and have never had a history of 

a positive testing result over the last 10 itnown year period. 

5. iTenied. All individuals performing safety sensitive functions on MP H aircratt at 

aJ1 times have been subject to alcohol teacing under the alcohol nlsuse progran and have never 

tested positive. 

6. Denied. At all times were individuals performing safety sensitive function were 

Bu£);eet to DOT recjuired random drug testing or have ever tested positive, 

7. Denied, At all times wers individuals perfomlng safety sensitive functions were 

subject to CiO'f required randon alcohol testing, 

B. Agreed. 

9. Denied, nr Baker at all timea was In a random pool for DOT re<^icad drug and 

alcohol testing at the tinie or parfDrming referenced functions in paragraph 8 and clearly .within 

the known regulations clearly pursuant to the operational specificationa, the compliance 

atatenent and the standard FAR/AIM. 

By way of further answer, a regulation change occurred in February 2004, no notification 

procedure was in place to inform the operator of this change, contrary to the routine protocol 

followed by all other operation specification chapters which included a regular notification 

procedure, written operational specification revisions, replaced pages and subsequent ro-signoff 

and confirniation ol the new pages chat the operator is aware and agre«e. It vs therefore not 

reasonable, proper or acceptable to hold HRH rasponsible for changea he was not formally or 

otherwise notified of. 

In addition, MRU was inspected by Vincent Roots ol the FAA drug al>acement program in 

April of 2D04 (Exhibi~ 3) and found eoiq>liant with Che regulations, even chough a regulation 

chaiign h.7d occurred in February of 2004. Therefore the PAA s own drug aAatencnt officer rfas 

dl.-:a not informed of -he regulation change juac as MRH was not. It is therefore not proper, 

reasonable or acceptable to hold the operator Lo a standard higher than their own drug 

inapectian officers who themselves did not )cnou or inform MR H of the regulation changes. 

Furthermore, MlVfi .tialntenance inspector, Gerry tienningcr, MRH operation in.ipcctor, Frank 

Alocta, the Aller-town FSDO manager, Mr Hadsworth, also were not aware el the reg--l»;ie.-. i^r.ir.ge. 

The Allentown FSDO is located across the street fren the MRH aircraft and it a officer s 

Inspected frequently during their daily occurrence at the Lehigh Valley International Airport 

(ABE) where the aircraft has been hangaced for over 10 years, never to find MRU in violation or 

FAA regulations. 

10. Denied. Mr Balcer uaa in a random poa2 for DOT required drug and alcohol testing at 

all times under Aii Methods Corporation including the tLiie of performing referenced functions on 

MfiH aircrafc (Exhibit 4J. 

il. Denied. There is all reason to believe and in good faith, that under the stated 

circumstances that MRH operated ir. due diligence and in accordance tc the knowledge sets of the 

Allentown FSDO, ita inspectors and Che regulations that were clearly set forth, eritten and 

described ir. the compliance statement, the operational specifications and the FAR/AIM . 

By w^y of further answer, it is r.ot proper, reasonable or acceptable to expect an 

operator to randomly find and hunt for regulations, no t clearly written, spelled out in the 

conipliance staCe.Tient, operation specificationa and FAR/AIH, Co review hundreds of pages of text 

at a remote site, Co focus, f^^nd, comprehend and deteimlne if a random regulation cnangc had 

occurred. iT is not clearlf sLjiLrd whnre Che exact aeurce location of these unidentified and 

tmte://irtAfi-itf^f *iT.ni» aDw/HTHL_Eni<miinurUK« ,ar(iiutl> Nml Pag^ iol ^ 
02/14/201 1 10:0 3 FAX 2024935142 FAA * DMS 1008/01 7 

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hidden (fine print) regulationa are to be located or on what t).3ie incerval to coatplate this 

tedious hit or mips aearch procedure that is prone to miointerpretatlon and error, therefore, it 

Is impassible Co ever be thoroughly ccmpliani at any point in time, if a regulation change or 

update randomly occurs. It is also unjosalble to do cms time consuming, random search on a 

regular oasis and is more prone to mistake and entrapment than a forthright notification 

procedure, that la consistent and already in place for proceduria pertaining to the other 

chapters in the operational specifications. 

Once MRIl was made aware of the regulations that had changed without the respondent, the 

FAA operational and maintenance inspectors and the Allentown FSDO being alerted, the two parttime A/P mechanics were enjoined to the existing drug and alcohol program. 

Count III. 

1. Denied. 

2. Denied, 

WHEREFORE, The reepundent prays to this Honorable Court that ;he proposed vicl^tion, conaiaLing 

of a judgment against MRH, (wnich currently ooee not njtisc, with no financial assets) and a f:n« 

of Si4Q0 (Xifty four hundred dollars) b« -.nimadlaLely STaiCCT:T» and DISMISSED. 

Bespcctfully Submitted, 

Michael B. Selig, MD, FACC. 

Date 

rH«I N OF R/F:NT S HNMA N Pri>rOhM«NCl- CaNSIDFRAHOMS 

- Kowlncpmntairi ani>» . Hou II i^M QQCU'an a - ('frnipiions, ludMmM" , J^"«' w • IWllnn. TM irvici.T>j 

• Conln&uiRig rnrrnn . (;cnT«clivi ar.iiOfi« . FMCinr* *tlwK\<nQ ire •uaJily or hun^ftn imilQn^9nct 

NASA AUC 277D Umunry 1 DM 1 MAIMTBilANCE FORM 

f Print fhlaPati a | ( aoa a 

R-om HM NASAAvtaUen SafatyAi porting Syalam: 

NASAha* astabllahed an Akiaiion Safety Reporting S)Oleni (ASRS)» IdendlyiBsuea In lh« aviation syBtem which naad to 

be addressed. The progrBin ofwhlcA ttlta ayalem ia e part is described in detail in FM/UvisoryCircular 0M6O . Your 

a»slatanoe in inlbrniing us about such lasues is essandal U ma succaEa ol ma program. Plaaae All out ihl* foim at 

completely as passible. 

The information you provide on the Idanlity sMp will be used only If NASA da(BrmineB ihai it i» nocasaaiy ID contact you for 

HjrtberinfonTiBtlOn. THIS IDENTFTYSTPP WILL BE RETURNEO OIRECTLYTO YOU. Tha raSjm orihe idenlityalrip asaurec 

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Safety Board as required byNTSBRegulaton 630.5 (49CFRa30.5). 

Thank you for )cur oonlribuban loaviabon safsty. 

hnpE://in>n.Hi\ci- jnLnaH.vnr/HTML FIIS/mii>ilenanc*.[nui]k.hmil 
02/14/2011 10:03 FAX 2024935142 FAA •s- DM S 21009/017 

AjflS- M»in1»r«nu nportVorm U2J/11 <:32 < 

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Thank you (brsuOmilang youriepe/Ton }0114)1-2S06^1:j8. 

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02/14/201 1 10:03 FAX 2024935142 FAA + DMS 0010/01 7 

http://www.regulations.gov/ 

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Michael Selig - Letter - CPlOSOOOll (FAA-2010-1211-0004) 

INFORMATION 

First Name: 

Middle Name: 

Last Name: 

Mailing Address: 

Mailing Address 2: 

City: 

Country: 

State or Province: 

Postal Code; 

Email Address: 

Phone Number: 

Fax/ International Number: 

Organization/ Org Unit: 

Submitter's Representative: 

Government Agency Type: 

Government Agency: 

Michael 

B. 

Selig 

2816 Orefield Road 

allentown 

pa 

18104 

dThelicop@ptd.net 

610 769 7000 

MR Helicopters 

Michael Sclig 

^aa 

COMMENT 

Michael Sclig, MD, FACC. 2816 Orefield Road 

Allentown, PA. 18104 VS. DEPARTMENT OF 

TRANSPORTATION OFFICE OF HEARINGS 

WASHINGTON, D.C Federal Aviation 

Administration Laura Ponto Complainant v. M & R 

Helicopters, LLC. Respondent FAA Case 

2009SO950434 PRELIMINARY OBJECHONS AND 

NOW, comes respondent, MICHAEL B. SELIG, MD, 

FACC, principle for MR HeUcopters, LLC (MRH) 

whom avers and files the following Preliminaiy 

Objections pursuant to §13.208(d) to the complaint 

submitted by the Federal Aviation Administration 

associate Laura Ponto, Esq. hereby asserting that the 

allegations made in the complaint are erred, not 

proper, reasonable or acceptable, and thereby the 

complaint should be stricken and dismissed. Count I. 

Constitutes conclusions of law to which no answer is 

required pursuant to the federal rules of court. Count 

II1. Agreed in part. MRH has not been able to carry on 

part 135 operations .since August 2007, on accovmt of 

the single pilot operator has cither been unavailable to 

pa,ss or take his flight exam for personal reasons 

(protracted divorce, liability issues) or the inspector 

was unavailable to perform a flight exam (medical 

leave), MRH has since ceased operating under the 

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02/14/2011 10:04 FAX 2024935142 FAA •> DMS 21011/01 7 

h ttp:/ / www. regulations.gov / 

name and under the certificate number, ownership of 

helicopter has changed, financial have been closed, 

thereby rendering the complaint moot. 2. Denied. The 

operation specifications were signed off in 2004 

(Exhibit 1). At the time of sign off, the regulation now 

finding MRH in violation had been changed without 

notification. By way of further answer 14 C.F.R. part 

121, Appendix I and J and 49 C.F.R. part 40 are not 

disclosed, clearly delineated or spelled out in the 

compliance statement, operational specifications, not 

readily available in the FAR/AIM and thereby one can 

assume are less important than other regulations that 

are clearly disclosed in the signed operational 

specifications. These regulations were thereby hidden 

amd concealed. 3. Denied, Regulations 135,251 and 

135.255 as written in the compliance .statement and 

confirmed by the respondent does not inherently state 

that MRH must directly test each employee who 

performs a safety sensitive function (Exhibit 2) but 

empirically states that any contractor be covered by an 

FAA approved drug and alcohol testing program. 

These individuals referred to, did comply with 

mandatory drug and alcohol testing regulations by 

way of their full time employers. In administrative law 

"In the interpretation of the language of regulations, 

where doubt exi.sts as to the intent of the meaning of 

the language written and enacted by a governing 

body, the language shall be interpreted in favor of the 

operator and against any implied extension of the 

restriction". 4. Denied. All individuals performing 

safety sensitive fimctions on MRH aircraft were at all 

time.<3 subject to random drug and alcohol testing 

programs and have never had a history of a positive 

testing result over the last 10 known year period. 5. 

Denied, AU individual.s performing safety sensitive 

functions on MRH aircraft at all times have been 

subject to alcohol testing under the alcohol misuse 

program and have never tested positive. 6. Denied. At 

all times were individuals performing safety sensitive 

function were subject to DOT required random drug 

testing or have ever tested positive. 7. Denied, At all 

times were individuals performing safety sensitive 

ftinctioi\s were subject to DOT required random 

alcohol testing. 8, Agreed. 9. Denied- Mr Raker at aU 

times was in a random pool for DOT required drug 

and alcohol testing at the time of perforrrung 

referenced functions in paragraph 8 and clearly within 

the known regulations clearly pursuant to the 

operational specifications, the compliance statement 

and the standard FAR/AIM. By way of further 

answer, a regulation change occurred in February 

2004, no notification procedure was in place to inform 

the operator of this change, contrary to the routine 

protocol followed by all other operation specification 

chapters which included a regular notification 

procedure, written operational spjecification revisions, 

replaced pages <ind subsequent re-signoff and 

confirmation of the new pages that the operator is 

2 of 4 1/29/201111:04 AM 
02/14/2011 10:04 FAX 2024935142 FAA 4 DMS 21012/01 7 

http://www.Tegulations.govy 

aware and agrees. It is therefore not reasonable, proper 

or acceptable to hold MRH responsible for changes he 

was not formally or otherwise notified of. In addition, 

MRH was inspected by Vincent Roots of the FAA drug 

abatement program in April of 2004 (Exhibit 3) and 

found compliant with the regulations, even though a 

regulation change had occurred in February of 2004. 

Therefore the FAA's own drug abatement officer was 

also not informed of the regulation change just as 

MRH was not. It is therefore not proper, reasonable or 

acceptable to hold the operator to a standard higher 

than their own drug inspection officers who 

themselves did not know or iriform MRH of the 

regulation changes. Furthermore, MRH maintenance 

inspector, Gerry Henninger, MRH operation inspector, 

Frank Alotta, the Allentown FSDO maitager, Mr 

Wadsworth, also were not aware of the regulation 

change. The Allentown FSDO is located across the 

street from the MRH aircraft and it's officer's 

inspected frequently during their daily occurrence at 

the Lehigh Valley International Airport (ABE) where 

the aircraft has been hangared for over 10 years, never 

to find MRH in violation of FAA regulations. 10. 

Denied. Mr Baker was in a random pool for DOT 

required drug and alcohol testing at aU times vmder 

Air Methods Corporation including the time of 

performing referenced functions on MRI-1 aircraft 

(Exhibit 4). 11. Denied. There is all reason to believe 

and in good faith, that under the stated circumstances 

that MRH operated in due diligence and in 

accordance to the knowledge sets of the Allentown 

FSDO, its inspectors and the regulations that were 

clearly set forth, written and described in the 

compliance statement, the operational specifications 

and the FAR/AIM. By way of further answer, it is not 

proper, reasonable or acceptable to expect an operator 

to randomly find and hunt for regulations, not clearly 

written, spelled out in the compliance .statement, 

operation specifications and PAR/AIM, to review 

hundreds of pages of text at a remote site, to focus, 

find, comprehend and determine if a random 

regulation change had occurred. It is not clearly stated 

where the exact source location of these unidentified 

and hidden (fine print) regulations are lo be located or 

on what time interval to complete this tedious hit or 

miss search procedure that is prone to 

misinterpretation and error, therefore, it is impossible 

to ever be thoroughly compliant at any point in time, if 

a regulation change or update randomly occurs. It is 

also impossible to do this time consuming, random 

search on a regular basis and is more prone to mistake 

and entrapment than a forthright notLFication 

procedure, that Ls consistent and already in place for 

procedures pertaining to the other chapters in the 

operational specificarions. Once MRH was irtade 

aware of the regulations that had changed without the 

respondent the FAA operational and maintenance 

inspectors and the Allentown FSDO being alerted, the 

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02/14/201 1 10:0 4 FAX 2024935142 FAA ^ DMS 0013/01 7 

http://www.regulations.gov/ 

two part-time A/P mechanics were enjoined to the 

exisHngdrug and alcohol program. Count IIL 1. 

Denied. 2. Denied, WHEREFORE, The respondent 

prays to this Honorable Court that the proposed 

violation, consisting of a judgment against MRH, 

(which currently does not exist, with no financial 

assets) and a fine of $5400 (fifty four hundred dollars) V V ^ 

be immediately STRICKEN and DISMISSED. t\k ^ 

Respectfully Submitted, Michael B, Selig, MD, FACC. A 

T~. ^-'^'^^ 

Attachments: ^ 

4 of 4 1/29/201111:04 AM 
"^/i^/^u n 10:04 FAX 2024835142 

FAA 

+ DMS 0014/017 

Michael Selig, MD, FACC, CFl-H 

2816 Orefield Road 

Allentown, PA. 18104 

^"' • ? 2011 

'BEARING DOCKET 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

Federal Aviation Administration 

Laura Ponto, Latonya Williams 

Complainants 

M & R Helicopters, LLC. 

Respondent 

Honorable Judge Ronnie Yoder 

Docket: 2010-1211 

MOTION FOR SPECIFIC DISCOVERY 

TRAVEL LOG FOR LATONYA WILLIAMS 

AND NOW, comes respondent, MICHAEL B, SELIG, MD, FACC, 

principle for MR Helicopters, LLC, (MRH) (non-existent since 2009) whom files the 

following MOTION for specific discovery of Latonya Williams pertaining to her 

travel operations. 

1. Respondent has requested pre-trial meetings and hearing ^o be 

held in Allentown, PA, the place of original jurisdiction and for reasons given in 

other pleadings, 

2. Complainants now state that to come to Allentown "would be a 

tremendous inconvenience and expense". 

1 of 3 
02/14/2011 10:04 FAX 2024935142 FAA ^ DMS 0015/017 

U.S. DEPARTMENT OF TRANSPORTATIO 

FEB - 7 2j „ 

BEARING DOCKET 

FederQl Aviation Adnnlnistrotlon 

CyntMa Oominik, Laura Ponto. 

Latonya Williams ., ,. . .^ ^ j 

Complainants Honorable Judge Ronnie Yoder 

V, Docket: 2010-1211 

AA 8> R Helicopters, LLC. 

Respondent 

Am^'l^ ^ CERTIFICATE Of SERVICE - 0^ -I ^ d^ ^ "^O U 

I HEREBY CERTIFY thot I have this day served the foregoing entriejs): 

RESPONDENTS REPLY TO MOTION TO DISMISS 

TRUTHS OF ADMISSIONS 

RESPONDENTS REPLY TO COMPLAINANTS RESPONSE TO THE MOTION TO HAVE 

THE HEARING LOCATION 

AT THE US DISTRICT COURT. ALLENTOWN, PARESPONDENTS REPLY TO COMPLAINANTS RESPONSE TO THE MOTIONS: 

DEPOSITION OP LATONYA WILLIAMS 

DEPOSITION OF CYNTHIA DOMINIK 

AND 

THE PRE-TRIAL CONFERNCE 

AT GALLAGHER REPORTING. ALLENTOWN, PA. 

RESPONDENTS REPLY TO MOTION FOR JUDGMENT TO DISMISS 

JUDICIAL ESTOPPELS, LEGAL INCONSISTENCY 

RESPONDENTS REPLY TO COMPLAINANTS RESPONSE TO THE MOTION FOR MORE DEFINITE 

STATEMENT 

ORDER AND SEHLEMENT 

RESPONDENTS REPLY TO MOTION TO DISMISS COMPLAINANTS PROPOSED PROCEDURAL SCHEDULE 

RESPONDENT'S REPLY TO COMPLAINANTS ANSWERS TO THE MOTION TO COMPEL DISCOVERY AND 

NEW MAHER 

RESpdkDENTS REPLY T ^ MOTION TO DISMISS COMPLAINANTC PROPOSED PROCEDURAL SCHEDULE 

MOTION FOR MORE DEFINITE STATEMENT 

FAILING TO MEET FILING DEADLINES 

MOTION FOR MORE DEFINITE STATEMENT 

119.69 SHUTDOWN AND HUMAN FACTORS 

MOTION FOR MORE DEFINITE STATEMENT 

CHANGING THE FUNDAMENTAL CAUSE OF ACTION 

MOTION FOR MORE DEFINITE STATEMENT 

r/MLINC TO MCLT HLII-K? 0CADLIMC5 , ^ A 
02/14/201 1 10:0 4 FAX 2024935142 FAA •> DMS 12016/017 

Upon all parties of record in this proceeding, in accordance with the requirements of Rule 29 

pursuant to 28 U. S. C. § 1746 . 

Service bv first-^lass mail, postage prepaid, oddressed as follows: 

Federal Aviation Administration 

800 Independence Avenue, SW 

Wilbur Wright Avenue-Suite 2W1000 

Washington, D.C. 20591 

Att: Hearing Docket Clerk, AGC-430 

FAX 202 493 5 U2 

Laura Ponto, Esq, 

Enforcement Division/AGC-300 

Office of the Chief Counsel 

FAA 

800 Independence Avenue, SW 

Washington, DC 20591 

FAX 202 267 5106 

The Honorable Ronnie A. Yoder 

US Department of Transportation 

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

1200 New Jersey Avenue. S.E. 

Washington, DC 20590 

FAX 202 366 7536 

Michael B. Selig, MD, FACC. 

2816 Orefield Road 

Allentown, Pa. 18104 

610 360 3953 

Date: 

JAN 2 4 2011 

^ i 4 JAN 3 0 2011 
02/14/2011 10:04 FAX 2024935142 FAA * DMS 0017/017 

U.S. DEPARTMENT OF TRANSPORTATION 

Federal Aviation Administration 

Cynthia Dominik. Laura Ponto, 

Latonya Williams 

Complainants 

M & R Helicopters, LLC. 

Respondent 

V, 

Honorable Judge Ronnie Yodei 

Docket: 2010-1211 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY thot I have this day sensed the foregoing entrie(s): 

NOTICE OF FILINGS 

NASA FORM AND PETITION TO RULEMAKING, PROPOSED CHANGES 

MOTION POR SPECIFIC DISCOVERY 

TRAVEL LOG FOR LATONYA WILLIAMS 

AMENDED CERTIFICATE OF SERVICE 1-24-11 

upon all parties of record in this proceeding, in accordance with the requirements of Rule 29 

pursuant to 28 U, S. C. § 1746. 

Service f v fifst-clo^^ moil, oo^taae prepaid, addressed as fpilovys: 

Federal Aviation Administration 

800 Independence Avenue, SW 

Wilbur Wright Avenue-Suite 2W1000 

Washington, D.C-20591 

Att: Heoring Docket Clerk, AGC'-430 

FAX 202 493 5142 

Laura Ponto, Esq. 

Enforcement Dlvision/AGC-300 

Office of the Chief Counsel 

FAA 

800 Independence Avenue, SW 

Washington, DC 20591 

FAX 202 267 5106 

The Honorable Ronnie A. Yoder 

US Department of Transportation 

Office of Hearings, M-20, Room 612-320 

1200 New Jersey Avenue. S.E. 

Washington. DC 20590 

FAX 202 366 7536 

By:__ . 

Michael B. Selig, MD, FACC. 

2816 Orefield Road 

Allentown. Pa. 18104 

610 360 3953 

Date: 

> . > 

V ,%^-A\