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7/23/2019 Motion to stay 2
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ORGNAL
IN THE
UNITED
STATES
COURT OF
FOR THE
DISTRICT
OF
COLUMBIA
CIRC
TTFR
r
A.
TAYLOR,
4
RECEiVED
Petition
for Review
vs .
Case
No.__________
MICHAEL
P. HUERTA,
15—i
4.5
Respondent
PETITIONER’S
EMERGENCY
MOTION FOR STAY
PENDING REVIEW
OR,
IN
THE
ALTERNATIVE,
FOR
EXPEDITED
REVIEW
Petitioner,
John
A.
Taylor,
pro
Se, hereby moves this
Honorable
Court,
pursuant
to FRAP
18 a ,
Circuit
Rule
18
and
49 U.S.C.
46110 c ,
to
t y
enforcement
of
an
Interim Final
Rule
issued
by
Respondent Federal
Aviation
Administration
“FAA” , and submits
the following
in
support of
his motion.
I. INTRODUCTION
AND
SUMMARY
Sec.
336 a
of the FAA
Modernization and
Reform
Act
of
2012
“the
Act” specifically
prohibited Respondent Federal
Aviation Association
“FAA”
from
promulgating any rule or
regulation regarding a model
aircraft that are
flown
strictly
for hobby
or recreational
use and
which
are
operated
meeting
certain
general safety criteria.
‘H.R.
658/P.L. 112-95,
Feb.
14,
2012,
126
Stat.
11.
A
copy
of
the
relevant portions
of
the Act
is
attached
hereto
as Exhibit
I
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Despite
the clear
prohibitions
of
the
Act
the FAA
has
issued
n Interim Final
Rule
which
established
a
national
registration
database
for
small unmanned aircraft.
Registration is
mandatory and the
penalties
for noncompliance include large fines
and imprisonment.
The FAA released
the Interim Rule
on
December 16
2015 with
n
effective
date
of
December
21 2015.
This
was
timed
specifically to coincide with the receipt
of new
hobby
aircraft
received
as
Christmas presents. The
Interim
Final Rule
requires
registration of new
hobby
aircraft
prior to
use
subject to
the aforesaid severe
penalties.
Prior
to the
issuance
of the
Interim Final Rule
the
FAA had
a long standing Rule
that
hobby
aircraft need not
be registered.
Petitioner and other
similarly situated
consumers
will suffer
irreparable harm
if
forced
to
register
their
hobby
aircraft with the
FAA prior to
use
in
direct
violation of the congressional
prohibition or risk hefty fines
and/or imprisonment.
II.
FACTUAL
AND PROCEDURAL BACKGROUND
Petitioner
incorporates herein y
reference the factual allegations of
the
Petition for Review.
Petitioner is
a
model
aircraft hobbyist. Petitioner is
the
owner of
one
or more small
unmanned
hobby
aircraft that
were
operated
by
Petitioner
prior
to December 21 2015 and a small
unmanned hobby aircraft that was acquired subsequent
to
December
21 2015.
In
addition
Petitioner
desires
to
acquire
additional small unmanned hobby
aircraft.
Petitioner’s aforesaid
aircraft
have
been or will
be
operated
as part
of a
small
unmanned
aircraft
system which includes hand held radio directional
controls.
2
8
FR 78593. A
copy of
the
Rule is attached
hereto
as
Exhibit
2.
2
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The
FAA
Modernization and
Reform
Act
of
2012 “ the
Act”
was enacted
by
Congress
and
signed
by th e President
on
February
14, 2012.
Sec. 336 a of the
Ac t
provides that
the
administrator
of the
Federal
Aviation Administration
may
no t promulgate any rule
or regulation
regarding
a
model
aircraft,
or an aircraft
being
developed
as a
model
aircraft if...”
the aircraft
is
“flown strictly
for
hobby
or recreational use. .
and
meets other safety criteria.
Petitioner’s aforesaid
aircraft
meet
the
definition established
by Sec .
336 a of
the
Act specifying
aircraft that are
no t
properly
subject to
regulation
by
the
FAA.
On
December
16,
2015,
the
FAA
issued
an Interim
Final
Rule
80
FR
78593
which
amends
Title 14
of
the
Code
of Federal
Regulations,
and
creates
an entirely
new
set
of
regulations
and
procedures
for
registration.
The
function
of the
Interim
Final Rule is
to create
a
registry
for
small
unmanned aircraft. 14
CFR
48.1 b ,
created
by
the Interim
Final Rule,
provides, “Small unmanned
aircraft
eligible
for
registration in
the United
States
must
be
registered and
identified.
.
pursuant
to
specified
requirements.
The
Interim
Final
Rule
sets
a
trigger date of
December
21, 2015
for the requirement
that
newly-
acquired
small
unmanned aircraft
be
registered
“prior to operation”
14
CF R
48.5 a .
Small
unmanned
aircraft
acquired prior
to the trigger date
must be
registered
no
later than February 19,
2016
Id. .
It is clear from
the
timing of the issuance of
the Interim
Final
Rule, and
it
has
been
widely
reported in
the
media, that the
aforesaid trigger date was
knowingly
and
intentionally
timed to
coincide with
the timing of gifts
exchanged
for
Christmas.
While
Petitioner
s
aircraf t meet the
criteria of the
Act for
those aircraft for
whom
FAA regulation
is prohibited, they also meet the
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definition
of aircraft which
the
FAA
mandates must
be registered pursuant
to
14 CFR 48.1 b : a
Petitioner’s
aircraft are
unmanned aircraft
that
are capable of sustained
flight in the
atmosphere;
b Petitioner’s aircraft are
unmanned aircraft
that are
flown
within
visual
line
of sight of the
person
operating
the
aircraft; and
c
Petitioner’s aircraft are
unmanned
aircraft that
are
f lown for
hobby
or recreational purposes. Peti tioner’s
aforesaid aircraft are,
or wil l
be,
part of small
unmanned aircraft systems.
Model
aircraft meeting the registration
criteria under the Interim
Final
Rule
have been
in
existence for many decades Prior
to adoption of the Interim
Final Rule, the FAA’s
longstanding rule, articulated on their
website,
was
that,
“Registration is
no t
required for
model
aircraft operated
solely
for hobby
or recreational purposes ”
As such,
tha t rule was
the s tatus
quo
as
of
enactment
of t he Act, a nd registration of model
aircraft was
no t
required
under FAA
rules.
etitionerf iled an action for declaratory and
injunctive
relief
seeking
injunction regarding the
Interim F inal Rule in the
U.S.
District
Court
for the District
of
Maryland
Greenbelt Division ,
Case No. PW G 15CV3934, on December 23,
2015. Petitioner simultaneously
filed
a
Motion for
a
Temporary Injunction
or
Temporary Restraining
Order. J udge G rimm
conducted a
hearing
on
Petitioner’s
motion, with
counsel
for
Respondent participating
by
phone . Couns el
for
Respondent
raised the
argument that
this Court ,
and no t the District Court, has
proper
jurisdiction to review
this
matter. Based
largely on
that argument,
Judge
Grimm
declined
to
The Academy of Model eronauticsadvertises that it was founded i n 1936.
Exhibit
3.
5
U.S.C.A.
551 4 provides
that, “rule’
means the who le or a part of an agency statement
of
general or particular
applicability and future effect designed
to implement, interpret, or prescribe
law
or
policy
or
describing the
organization procedure or practice
requirements
of
an agency
and
includes the approval or
prescription for the
future of rates, wages,
corporate or financial structures
or
reorganizations thereof, prices, facil i ties, appliances,
services or
allowances
therefor
or of valuations, costs, or
accounting,
or practices bearing
on
any of the
foregoing”
4
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grant the
TRO, bu t
has indicated
that the parties will
be
heard on
jurisdiction and the meri ts of
the
motions
in the near future.
III. ARGUMENT
A. Standard
for Review
The standards
for granting
a Motion
for
Stay Pending Review
under
FRAP 18 a and Circuit
Rule
18 a
are
the
same as those for obtaining
an injunction
in
federal
court.
To
obtain
a
preliminary
injunction, moving
parties must establish
that
1
they
are
likely to
succeed
on the
merits,
2
they
are
likely
to
suffer
irreparable harm
in the
absence
of preliminary
relief,
3
the balance of equities t ips in
their
favor, and
4
an
injunction
is
in
the
public
interest.
Winter v Natural Res. Defense
Council,
Inc.,
555
U.S.
7, 20,
129 S.Ct. 365, 172
L.Ed.2d
249
2008 ;
see Dewhurst
v
CenturyAluminum
Co.,
649
F.3d
287 , 290 4th Cir.201 1 ; CSXTransp.,
Inc. v Williams, 406 F .3d
667 , 670
D.C.
Cir.
2005 ; accord
Washington Metro. Area Transit
Comm ‘n v Holiday
Tours,
Inc.,
559 F.2d
841,
843 D.C.
Cir . 1977 .
“The test
is a
flexible
one.
‘If
the
arguments
for one
factor
are particularly s trong, an injunction may
issue
even
if
the
arguments in other areas are rather weak.’
We
have
often
recognized that
injunctive relief
may
be justified, for
example,
‘where
there
is a particularly
strong
likelihood
of success
on the
merits
even if there
is a relatively
slight showing of
irreparable
injury.” CSX Transp. , Inc.
v.
Williams,
406 F.
3d 667, 670
D.C.
Cir.
2005 citations omitted .
6
Petitioner
has
researched the arguments raised
by
counsel for Respondent regarding jurisdiction.
While
there
appears
to
be
a
split in the Circuits, it appears likely that
proper
jurisdiction lies with the Circuit Court, pursuant to
49
USC
§46110.
It
is
Petitioner’s intention to voluntarily dismiss
the
District Court
action.
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B. Petitioner
is
likely
to
succeed
on
the Mer its
Adoption
of the Interim
Final Rule
is
a
blatant violation
of
the prohibitions
specified in
the
Act.
It is
a
rule
or regulation regarding
a
model
aircraft
that are
f lown s tr ic tly for hobby or
recreational
use
and
which are operated
meeting
the safety
criteria
of the
Act.
The Act
prohibits “ any ru le o r
regulation” related
to
such
aircraft.
A s the
Supreme
Court
has
frequently
observed, use of th e word “any”
in
statutory
text
generally indicates Congress’s intent
to sweep broadly
to reach all varieties of the
item
referenced.
See, e.g. United
States
v
Gonzales,
520
U.S.
1
5,
117
S.Ct.
1032,
137
L.Ed.2d
132 1997
quoting Webster’s Third
New
nternational ictionary
97
1976
in concluding
that, ‘[r]ead naturally,
the
word
‘any’
has an
expansive meaning, that is, ‘one o r some indiscriminately
of
whatever kind” ;
accord HUD
v
Rucker,
535 U.S.
125, 131, 122
S.Ct.
1230,
152
L.Ed.2d 258
2002 same ; Ruggiero v County
of
Orange 467 F .3d
170, 175
2d Cir.2006 noting that
“Congress
made
[the
phrase
at issue]
even
broader when
it
chose the expansive
word
‘any’ to
precede
the
list”
internal
quotation
marks omit ted . The Cour t
most
recently applied this
principle in interpreting the phrase
“any
air
pollution
agent
or combination of such agents,
including any
physical,
chemical.
substance
or matter which is emitted into or
otherwise enters the
ambient air” in
the Clean
Air Act.
Massachusetts
v
EPA, U.S. 127 S.Ct.
1438, 1460, 167 L.Ed.2d 248
2007
quoting
42
U.S.C.
7602 g ellipsis and emphases
in
original .
It
concluded that
“[o]n
its
face,” the quoted
language “embraces all
airborne
compounds
of
whatever stripe,
and underscores
that intent
through
the
repeated
use
of
the word
‘any.”
The FAA ha s articulated the
position that this new rule is no t
a
new rule
at
all , s ince the
FAA has
long
had authority and mandate to register all
aircraft. The argument
seems
be
a long the l ines
ee 9 U.S.C.
40102 and 14C.F.R. 1.1.
6
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that the
long standing
rule exempting
model aircraf t f rom registration, which
was in effect
at
the
time of
the
Act,
was
a violation
of
the mandate
to register all aircraft,
so
now they’re
going to
reverse
that
rule despite
Congress’
clear direction
that
th e FAA
should no t regulate hobby
aircraft.
However,
the
congressional
intent of
the Act is
clear
Congre ss do es not wan t t he FAA
regulating
hobby aircraft.
The FAA’s arguments are
nothing more than
an
attempted
end run to
evade a directive from
Congress
that
could not be clearer.
The Inter im Final
Rule isn’t merely the exercise of an
authority existing prior to enactment of
the
Act,
it
is
a
new
rule
and a
new process, which vio lates
the
Act.
Assuming arguendo, t ha t t he FAA were
to
concede that
the
Interim
Final Rule is
prohibited,
but
embark
on
applying
the registration
requirements for
traditional
aircraft
to hobby aircraft, they
would
be modifying their
prior rule i.e., hobby a ir cr af t need not
be
registered , which
itself
would
be a rule
in
violation
of
the Act.
Further, if the
aircraft registration requirements are applied
by
th e FAA using th e broad language
of
the authorizing statute, then registration
would
be
required of every Frisbee
and
paper
airplane.
Any
attempt to
exempt
those
aircraft,
while leaving in
small unmanned
hobby aircraft,
would
again
be
a
violation of th e Act
as a
rule that regards
aircraft
for whom regulation is
prohibited.
Legal gymnastics aside, any action leading to
a
registry of hobby aircraft
would
clearly be
contrary
to
Congress’ legislative intent. Congress was presumably aware of the FAA’s
8
It
s
noteworthy that Sec.
336 b
the
Act
provides that nothing the
Act limits
the
authority of the FAA
to
“pursue
enforcement
action against persons operating
model
aircraft
who
endanger
the safety of the
national airspace
system.”
While
t he FAA properly
retains
the
aforesaid
safety
enforcement
authority, the FAA’s Interim
Final
Rule
extends to
all
hobby aircraft, regardless of how safely they
may be
operated.
As they
are
contrivances
or
devices
that are
“invented, used, or designed
to
navigate,
or fly in, the
air.”
See,
49
U.S.C. 40102 and
14
CFR 1.1.
7
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longstanding r ule and
practice of no t
registering
hobby
aircraft
at
the
time
Congress
enacted the
Act. nforcement
of the
Interim
Final Rule
would
change
the
status quo
ante in a manner
clearly
inconsistent
with
Congress intent.
C.
Petitioner and Others Similarly
Situated will
Suffer Irreparable
Harm
As
indicated above, this
Rule
wa s
timed to
cover
the exchange
of
gifts at Christmas.
Children
all
over
merica
who receive
hobby
aircraft
for
Christmas will
be
unlawfully
required
to navigate
a
federal regulatory
website,
patently
prohibited
by
Congress,
prior
to using
their
new
acquisitions.
Further,
if
the Interim
Final Rule
is
no t
enjoined,
Petitioner and other
hobbyists will
be forced to
choose between
entering
personal
information
in an
unlawful
and
publicly available database
or
risking
multi thousand
dollar fines and/or imprisonment.
D. The
Balance
of Equities
Favors
Issuance
of
a S tay or Other Injunctive
Relief
The FAA
pushed
the
Interim
Final
Rule through, providing
only
five
5 days
between
the
release date and the
date
on which new aircraft acquisitions
must be
registered.
Petitioner submits
that
the
FAA
hoped
the
unlawful registration
process would
be
ensconced
before
anyone could take
meaningful action and
it
would
become
afate
accompli a
‘done
deal”
and
a
functioning bureaucracy
that
a
court would
be
reluctant
to
dismantle.
The
FAA wil l suf fe r
no
harm
if
enjoined from enforcing the
Interim Final
Rule.
Hobby
aircraft
have been around
for many decades
and
free from
registration with no resulting
harm . Whil e
some forms
of hobby aircraft
are becoming increasingly
popular,
Congress’
direction on this
issue
remains clear, and
it
has taken
no
action
to
reverse
itself.
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Dangerous
operation
of
a
hobby
aircraft
remains subject
to enforcement
action
by
the
FAA.
If
injunctive
relief is granted,
th e FAA will
remain free
to
take effective
and
lawful actions
to
protect the
merican
public from
dangerous operators
of
hobby aircraft,
and
to
educate
the
public
as to
hobby
aircraft safety issues.
Hobby
aircraft registration does nothing
to
further those
goals and,
more importantly,
violates the
Act.
E.
Issuing the
S tay or
Other
Injunctive Relief
is in the Public Interest
Petitioner
is
loath
to engage
in
policy
arguments in
this
motion,
since
Congress
has
spoken
so
clearly
on
the subject
through the
Ac t
and
it is
no t
the province
of
th e FAA o r th e Cou rt
to
override
Congress’
expressed legislative
intent.
Certainly,
it is
in
the public interest
that
th e FAA not
be allowed
to
violate
the Act
or
evade
the
Congressional directive embodied therein.
It
is
in the public interest no t
to allow full implementation
of a
database that
w il l gathe r and
make public
inappropriate
personal information f rom tens
of thousands
of
Americans, rather
than
delaying
implementation of
the
program
unti l the legalities of the program can
be
fully litigated
and
determined by
the
Court.
The FAA retains full
authority under
t he Act
to
address
safety concerns.
Registration
under the
Interim
Final Rule
will
do
nothing
to
increase
safety, while creating an
illusion
that
a vague
“something” is being done.’°
10
While the underlying
policy considerations are outside
of
the scope
of this action, Plaintiff
notes that hobby
aircraft
have
a
remarkable
safet y record. Wh il e multicopter hobby aircraft so-called “drone”
hobby aircraft are the
new boogeyman even they
have
a surprisingly good record as
far as
recreational
hobbies go. While stories
of
their
abuse
and unsafe fly ing
fill
the media,
Plaintiff was
unable to
f ind an
account of
a
single person who has suffered
serious
harm at the hands of a multicopter . Again, such considerations
are
the province of Congress,
and they have
chosen to prohibit model aircraft regulation.
10
See,
Urbain Knapp Bros.
Manuf
Co.,
217 F.2d
810
Cir . 1954 ,
cert.
deniea 349
U.s. 930
1955 ; Bass
Richardson,
338
F.Supp. 478, 490 S.D.N.Y.
1971 .
9
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To
the degree
the
FAA may a rgue
that the Interim
Final
Rule is
an
educational
undertaking,
it
is
noteworthy that nothing in the
Interim
Final
Rule
includes
any
educational
mandate.
A person
may register while
knowing nothing whatsoever
about safe
operation. Of course, once the FAA
leads
u s o ut on to
this
slippery slope,
there’s
no
telling
where they’ll take it.
Whil e the FAA
is prohibited
from
regulating safely operated
hobby aircraf t, there
is
nothing
in
the
ctto interfere with
the FAA’ s enforcement of safety requirements
or
education of
the
pub lic . They
remain free to protect the public
from
dangerous operation.
Petitioner
is pursuing
this
matter almost
ent ir ely in the
public
interest.
Petitioner is
purely
an
aircraft
hobbyist
and
has no financial
stake
on
the outcome.
In
addition,
Respondent
would
suffer
no discernable
monetary harm in the unlikely event that
issuance of
injunctive relief is
ultimately
deemed to
be wrongful . Petitioner
requests that no
security
be required under
Circuit
Rule
18 b ,
or that such security
be
entirely nominal.”
IV.
CONCLUSION
The
Interim
Final Rule clearly
violates
th e A ct an d
Petitioner
therefore
has a
high likelihood
of
success
on the
merits.
Petitioner
and
other
similarly situated hobbyists
will suffer
irreparable harm
if
forced
to
choose
between
putting personal
information
into an
unlawful
and
publicly available
government
database
or risking draconian penalties.
The
equities favor Petitioner
in
that FAA has created artificial time
constraints for
action
and
will
suffer
no apparent
irreparable harm if the injunctive relief is granted.
Prohibiting establishment of
an unlawful registration
database
is
in the public
interest.
See,
Urbain
Knapp
Bros.
Manzf
Co.,
217 F.2d
810
Cir . 1954 , cert. denieaç 34 9 U.S.
930 1955 ; Bass
Richardson, 338
F.Supp. 478, 490
S.D.N.Y. 1971 .
10
USCA Case #15-1495 Document #1590546 Filed: 12/24/2015 Page 10 of 14
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WHEREFORE
Petitioner
requests
this
Honorable
Court
to
issue
an order
staying
Interim Final
Rule
80
FR
78593
and
prohibiting Respondent
from:
A.
Enforcing
upon
or
further implementing
the
provisions
of
the
Interim Final
Rule
80
FR
78593 .
B. Requiring
or accepting
registrations
for model aircraft
operated by Petitioner or others
solely for
hobby or
recreational purposes that meet
the use criteria
set
forth
in
Sec.
336 a
of
the
Act.
C. Taking enforcement
action regarding Petitioner or other persons
who fai l
to
comply
with
the registration
or other requirements of the
Interim
Final Rule
80
FR
78593 .
D. Disseminating
any
registration
information received
by
Respondent from
Petitioner or
others
pursuant
to
the
registration process
established by
the Inter im Final Rule
80 FR
78593 .
E. Continuing
to
maintain any registration information received
by Respondent from
Petitioner
or others
pursuant
to
the registration
process
established by
Interim Final
Rule
80
FR 78593 .
STATEMENT
OF
NOTICE
TO RESPONDENT
On
December 24,
2015, prior
to
the f il ing of this action,
Petitioner provided
notice of
his
intention
to
pursue this
motion, its
general nature
and
the
date
and
time
to be
presented for
consideration
to the Court at
10
AM on December 24,
2015 along
with
Petitioner’s telephone
contact information,
by
telephone calls
to
the Office of
Chief
Counsel of the Federal
viation
USCA Case #15-1495 Document #1590546 Filed: 12/24/2015 Page 11 of 14
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Administration
the
Office
of
the
Attorney General
of
the United
States the Assistant
U S
Attorney
for
Maryland
and the Office
of
the
U S
Attorney
for the District
of
Columbia
In
addition
Petitioner
emailed
copies
of
the
Petition and
this
Motion
to
the last known
addresses
of
the Chief Counsel
of
the Federal Aviation
Administration and
the Assistant
Chief
Counsel
for Regulations
of
the Federal
Aviation Administration
the Office
of
the
U S
Attorney
for
the District
of
Columbia
as well
as
the
Assistant
U S
Attorney for Maryland
who
represented counsel
in the
U S
District Court
action
spectfully Submitted
John
ay r prose
5 rara Drive
Silve
S
ring Maryland 20906
jat@
ol enstock com
AFFIDAVIT
I JOHN A
TAYLOR
HEREBY
CERTIFY
under penalty
of
perjury
that the
representations
contained
herein are
true
and correct
to
the best
of
my
knowledge information
and
belief
Jo
Taylor
12
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DISCLOSURE
STATMENT
PURSUANT
TO
CIRCUIT RULES
18 a 4
26 1
This
matter
does
not involve
a corporation,
association,
joint venture, partnership, syndicate.
or
other
similar
entity.
John
Taylor
CERTIFICATE
PURSUANT
TO CIRCUIT RULES
4
28 a 1 A
The following
is list
of
all parties,
intervenors,
and amici
who have
peared
before
the
district
court, and all persons who
are parties,
intervenors,
or
amici
in
this
court:
Federal
Aviation Administration
Serve:
Michael
P
Huerta,
Administrator
Federal
Aviation Administration
800 Independence Avenue,
SW
Washington, DC 20591
Attorney General
of
the United States
Main
Justice Building
10th
and
Constitution Avenue,
NW
Washington,
DC
20530
U.S.
Attorney
for the District
of
Columbia
5554thSt.,NW
Washington,
20530
CERTIFICATE
OF SERVICE
HERBY CERTIFY
that
a
copy
of this
filing was
delivered
to
the
person identified below
by
First
Class
Mail Postage
Prepaid
on the
7..’t’lay
of
Ocg j v 201cE’
Federal
Aviation Administration
Serve:
Michael P Huerta,
Administrator
Federal
Aviation Administration
13
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8 Independence Avenue
SW
Washington
DC
2 59
Attorney General
of
the
United
States
Main
Justice
Building
th
and
Constitution
Avenue NW
Washington
DC
20530
U S
Attorney
for
the District
of
Columbia
5554thStNW
Washington 20530
John
[or
4
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