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CONTENTS

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I. LARRY'S RESUME

This section, and Nos. II and III show my background and from whence my interests arise.

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II. HOW OTHERS SEE LARRY'S WORK

Must see.

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III. LARRY'S AVIATION BACKGROUND

This is a quick look at my love affair with aviation. It started in 1934 at the age five in Ann Arbor, Michigan. My dad took me to the airport and paid five bucks so I could ride in a Ford Trimotor. I remember it vividly. This was followed in 1940 by a ride in a Twin-Beech. The Navy flew dad and myself from Anacostia Naval Air Station down to Langley, Va. The Navy wanted Harold Smith to see the facility operated under the auspices of the National Advisory Committee for Aeronautics, sort of the forerunner of NASA. As he was Director of the Budget, NACA no doubt wanted to show him why they needed more money, in view of President Roosevelt's push to build thousands of military aircraft, to better prepare the country for war came. The wind tunnel I well remember.

view Larry's Aviation background

IV. NEH STUDY PROPOSAL

This is a comprehensive statement of my work and what's wrong with FAA enforcement. It was submitted in a grant request to the National Endowment for the Humanities. It was a long shot, perhaps too controversial. NEH is a federal foundation run by academics for academics, like NEA is for artists, but it was worth a shot.

view neh study proposal

V. CONSULTANT TO GAO

For six months in 1980 I was a consultant to the United States General Accounting Office on the legal aspects of FAA enforcement. Not long, it's a must read. The Chief Counsel never responded in writing to the memorandum which I had prepared. It asked key questions about enforcement. He did, however, send four lawyers to a meeting with myself and two GAO officials. Leading that group was Deputy Chief Counsel Jonathan Howe. No attempt was made to give a substantive answer to any question asked in the memo. At the very start, with aforethought, I asked Jonathan how the FAA justified having no rule that pilots and mechanics could read which warned them of license penalties. His response: "Oh, everybody knows how the system works, anyway." So much for the rule of law.

view consultant to GAO

VI. FAA PUNITIVE CERTIFICATE SANCTIONS (EMPEROR)

Make a file, print it out, and read at leisure. Don't be put off if you're not a lawyer. It's not some erudite Harvard Law Review article on arguments pro and con for the death penalty. Basically it is a report about legal detective work. That's how The Flyer described my work. If you have an ongoing certificate action, make sure your lawyer, if you have one, reads it. If not, and you want to see someone hem and haw, ask the FAA lawyer to answer this simple question: why does not the FAA have a rule for license penalties? Then ask the ALJ, if you go that far.

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VII. MARSH STATEMENT WHITEPAPER

What I call a whitepaper covers key features of the license penalty system and provides relevant quotes from a 461-page sworn statement given to me by John E. Marsh, Jr. He agreed to let me take it just like a deposition. I'd stopped in D.C. right after New Years 1996, and spent five hours with John telling him what was happening in enforcement. John is and was the experts' expert on the subject. Having worked with him at the FAA in 1967-68, and he was helpful when I was at the GAO, I knew him to be an honest and sensitive man. He deserves a medal for moral courage. He verifies the key points about license penalties -- and more. For sure print it out and, if you are involved in an enforcement case, make extra copies for your counsel, the FAA lawyer and ALJ. Insist they put it in the case file. Should anyone want a copy of the statement, I can send a 3-1/2, 1.44 meg, floppy, copied right from the disk provided by the court reporter. Just send $25 as a contribution to this effort. If you want copies of the transcript, that'll be quite a bit more.

view Marsh Statement

VIII. SUMMARIES OF EMERGENCY CASES

My comments explain how the summaries came about. The emergency cases horror stories will tell you for sure that something is rotten in Denmark. It is hard to believe this kind of thing is happening in America, but it is, I assure you. It's been going on for three-quarters of a century.

view summaries of emergency

IX. FAA ABUSE OF POWER: A CASE STUDY

Had I not been an inveterate newspaper reader, I might have missed the short article in the financial section of the Arizona Daily Star, about May 10, 1985, noting that the FAA had issued an emergency order revoking the three operating certificates of the Go Group here in Tucson. (Sometimes I wish I had.) I went down and offered my services, and that's what got me going on this crusade for Justice ever since. (It should have taken only two or three years. But that's a long, long, story, some of which you'll read here in the future.) The Go Group operated ten Vickers Viscounts in charter for entertainment groups, did some airline work with a Part 121 certificate, and had an authorized repair station. If you have ever been associated with an emergency revocation of an operator, and want to see how easily FAA lawyers can get away with phonus balonus charges, you'll want to read this. It's lengthy, so make a file, print it out, read at leisure.

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