NTSB Hearing Document se-4661

This is the transcript (se-4661) of Jim Campbell's 1980 NTSB hearing.
After hearing the evidence and Campbell's testimony the Judge ruled that Campbell's
 personality disorder disqualified him from an FAA Medical or Pilot Certificate.

This document has been scanned directly from an NTSB certified original.



             BEFORE THE NATIONAL TRANSPORTATION SAFETY BOARD
        
- - - - - - - - - - - - - - - - - - -X
In the Matter of:                     :
                                      :
LANGHORNE M. BOND, ADMINISTRATOR,     :       Docket Number
FEDERAL AVIATION ADMINISTRATION,      :       SE-4661
Complainant,                          :
                                      :
                 - against -          :
                                      :
JAMES RICHARD CAMPBELL,               :
                  Respondent.         :
- - - - - - - - - - - - - - - - - - -X

Tuesday, November 18, 1980
26 Federal Plaza, Room 208
New York, New York
        
          The above-entitled matter came up for hearing pursuant to Notice
at 9:15 a.m.
        
BEFORE:   The HONORABLE JOYCE CAPPS, Administrative Law Judge.
        
APPEARANCES:       
     For the Administrator:
          SHARON HAUSELT, ESQ.
          Federal Aviation Administration
          800 Independence Avenue Southwest
          Washington, DC 20591
        
     For the Respondent:
          JAMES RICHARD CAMPBELL
          41 Stone Fence Road
          Oakland, New Jersey


                                I N D E X
                                                                 FUR. FUR.
     WITNESS             DIRECT    CROSS     REDIRECT  RECROSS   RD.  RC.
        
     Sandra Taylor       33        58        80        82
        
     Thomas Powers       84
                         (Cont.)
                         133       162       181       183       184
        
     Barton Pakull       187       202
        
     James Campbell      209       224


                             E X H I B I T S
        
     EXHIBITS NO.             FOR IDENTIFICATION   IN EVIDENCE

     Administrator's No. 1         5

     Administrator's No. 2         103                103




                         P R O C E E D I N G S

JUDGE CAPPS: This opens the hearing in the matter of Langhorne M. Bond,
Administrator, Federal Aviation Administration, Complainant, versus James
Richard Campbell, Respondent, docket number SEÄ4661.

My name is Joyce Capps, the Judge who's been assigned  to hear and decide
this case.

Will counsel for the Government represent herself, please.

MS. HAUSELT: Sharon Hauselt, H-A-U-S-E-L-T, 800 Independence Avenue
Southwest, Washington, DC 20591.

JUDGE CAPPS: Sir, you are Mr. James Richard Campbell, the Respondent
herein?

MR. CAMPBELL: Yes, ma'am, I am.

JUDGE CAPPS: And you have no counsel?

MR. CAMPBELL: No, ma'am, I couldn't afford it.

JUDGE CAPPS: all right, the Government does have the burden of proof in
this case.  Do you wish to give an opening statement?

MS. HAUSELT: Your Honor, I have a couple of preliminary matters and then I
would give an opening statement.

JUDGE CAPPS: All right, I'll entertain some preliminary matters.

MS. HAUSELT: The first one is I never received any information from Mr.
Campbell with regard to a discovery request, so at this time I'd like to
know if he intends to put any witnesses other than himself.

MR. CAMPBELL: No, I do not.

MS, HAUSELT: Also, Your Honor, prior to giving my opening statement I would
like to introduce into evidence the record so that as I'm speaking, you
could refer to the record.

JUDGE CAPS: All right. Is this the packet of medical evidence and
applications that are involved in this particular case?

MS. HAUSELT: Right. I never certified a true copy of Mr. Campbell's medical
records which also includes copies of all his Interim Certificates, and I
would offer them as Administrator's Exhibit No. 1.

JUDGE CAPPS: All right. Mr. Campbell, have you seen this document?

MR. CAMPBELL: I believe I've seen most of them.

MS. HAUSELT: I have a copy for Mr. Campbell.

JUDGE CAPPS: All right. I'll take it and mark it - This is the standard
packet of documents that comes into every medical case. The reason I ask
you to obtain a copy of it is usually a copy is furnished to the Respondent
in the case, and I want to make sure that was done.

MR. CAMPBELL: I requested my file sometime ago and I didn't receive it. I
believe that's all the information that's been gathered up until this
point.

JUDGE CAPPS: All right. (Whereupon, the document described was marked for
identification as Administrator's Exhibit No. 1.

JUDGE CAPPS: Are you a member of the Bar? Are you an attorney?

MR. CAMPBELL: No, ma'am, I'm not.

JUDGE CAPPS: All right. Let me caution you to this, Mr. Campbell. You have
no attorney representing you, but yet I want everything that goes on during
these proceedings to be fully understood by you. So, therefore, if anything
occurs throughout this proceeding that you don't fully understand, don't
hesitate to ask me to explain it. I'll be happy to do it. I want to do it,
because this is your day in Court, and I want you to fully understand just
what is occurring as far as procedure is concerned, because you're not
being a lawyer, you know, some of these things might be new to you. But I
want to assure you that things will be conducted according to the accepted
modes of procedure around here, as long as I'm sitting up here.

MR. CAMPBELL: Thank you.

JUDGE CAPPS: Now, don't be shy about it. You just pipe right up if you've
got a question.  All right, now, what we're doing now is what occurs in
every trial. Both sides have a chance to get up and tell the Court what
their evidence will show; their theory of the text; they're showing what
evidence they've got to support the allegations they have made.  You will
have the same opportunity to explain to me what you will put forth by way
of evidence to convince me of your side of the case. Now, this is called
opening statement.  I'm going to hear the opening statement of the person
having the burden of proof here, which is the Government.

MS. HAUSELT: Judge Capps, as I speak, I'm going to refer to the record, and
I will try to give you the page numbers because it's quite a long and
lengthy record, and we're talking about a period of time here, I believe
going back as far as 1974.

First of all, the section that we're dealing with, as you know, is a
personality disorder which has been severe enough to have manifested itself
by repeated overt acts and by that the term, personality disorder, you'll
hear testimony from Drs. Pakull and Dr. Powers indicating that a
personality disorder is a deeply ingrained maladaptive pattern of behavior.
So, what we're talking about here is not just an occasional lapse that any
person might have. We are talking about a pattern of behavior that has
repeated itself over a period of time, and it's something which is a
serious mental illness, and because of that has been found to be a
specifically disqualifying trait under the Regulations.

Now, there's two parts to what we have to show. We have to show you that
there's a personality disorder and, also, that it is of such a nature that
it's severe enough to have manifested itself by repeated overt acts, and
we'll be going into quite a bit of detail of over twenty different episodes
in time, which we will offer as the overt acts.

Just speaking to the file itself, and sort of the chronology of the events
here -- Mr. Campbell, I believe, graduated from high school in 1974 and
from information which he gave Dr. Powers -- Dr. Powers is a psychiatrist
who saw him at FAA request. Now, from information that we received from Dr.
Powers, following high school Mr. Campbell went out to Colorado, so that
would be sometime in -- sometime in the summer of 1974. He remained there
for approximately a year and a half. Having a problem with a personal
relationship which he related to Dr. Powers, he then returned to his home
in New York City and lived with his parents. In November of 1977, Mr.
Campbell attempted to jump off the World Trade Center in New York. However,
he was stopped by the guards at the top of the World Trade Center, and he
was not able to complete the jump, and at that time he was arrested. He was
attempting to parachute jump, I may add. And that is documented -- the
arrest, itself, is documented on pages 94 through 101, which includes his
arrest record in New York State.

In the Fall of 1978, approximately the month of October, November and
December, Mr. Campbell resided in the area of Tulsa, Oklahoma, and at that
time, and I refer Your Honor to pages 46 and 47 -- Mr. Campbell presented
himself to friends and acquaintances as a doctor, and, in fact, was giving
friends and acquaintances drugs, and these people complained to the
authorities and that is how this problem came to light.

Following that escapade, the authorities found out about it, and rather
than put him in jail or arrest him they requested that his family return
him to New Jersey where he could receive psychiatric care.  He did, in
fact, return to New Jersey with his father, where he underwent
psychotherapy for about five months, about January to May of 1979,
receiving treatment from a Dr. Dorsey, who was recommended to Mr. Campbell
by his grandfather, who is a doctor. And Dr. Dorsey's report is included in
-

JUDGE CAPPS: Dr. who?

MS. HAUSELT: Dorsey, D-O-R-S-E-Y. And his report is included on page 54.

Mr. Campbell, then, in May of 1979, went to the area of Atlanta, Georgia
where he was employed by Brown Aviation, Incorporated, and we have
information in the file on page 36 from a Mr. Brown indicating that for the
first two months Mr. Campbell was an ideal employee and he had no
complaints whatsoever with him. However, in about the third month of his
employment his mood began to shift quite frequently and he was -- Mr. Brown
caught him in a number of fabrications and stories which were preposterous
and untrue.

He was subsequently fired from that position, and at that time, or shortly
thereafter in September and October of 1979 Mr. Campbell turned up in New
Hampshire, and there he received employment from Nashua Aviation in Nashua,
New Hampshire and that is how Inspector Taylor, who will be testifying,
came to meet Mr. Campbell. While employed by Nashua Aviation, he was also
temporarily employed by Daniel Webster College, which is a small college
nearby.

While in New Hampshire, Mr. Campbell indicated that he was qualified in a
variety of areas, including being a stuntman, being a member of the Screen
Actors Guild, having formerly taught in the Aircraft Owners and Pilots
Association Ground School. All of those claims were subsequently proved to
be false. He also attempted to start up a parachute club while up in New
Hampshire, and in relationship to his employment at the college, and at
that time he indicated he was qualified as a parachute rigger, which, under
the Federal Aviation Regulations is regulated, and you do need a
certificate for that. He did not have such a certificate.

JUDGE CAPPS: Is he a parachute -

MS. HAUSELT: Parachute rigger.

JUDGE CAPPS: Rigger ?

MS. HAUSELT: You have to pack parachutes.

JUDGE CAPPS: What was his employment at Webster College ?

MS. HAUSELT: He was employed to teach, I believe, courses relating to
ground school type courses -- meteorology and some flying. He was also
doing some flight instructing at Nashua Aviation .  During the time he was
attempting to set up this parachute club, he also claimed to be a certified
jump instructor, which is something regulated by the U. S. Parachute
Association. He claimed to be affiliated with them. In fact, he was not
current at the time he was attempting to set up this program for
parachuting. And a variety of other problems came to light, including the
newspaper article which I referred to on page 46 and 47, which is the
account of his masquerade as a doctor in Oklahoma.

That article came to light on the campus at Daniel Webster. His
qualifications were subsequently brought into question and also due to that
question, various other discrepancies in his record turned up in addition
to those that I have mentioned with regard to teaching and not being
qualified as a parachute rigger, and various other claims made to other
people .

About this time the FAA got wind of a question with regard to Mr.
Campbell's medical qualifications for a first class, in particular, medical
certificate, and Dr. Cahill, who is the Regional Flight Surgeon in New
York, requested some information from Mr. Campbell, and at that time Mr.
Campbell was -- around this time Mr. Campbell was fired from Daniel Webster
and told people in the area he was leaving to go to Florida.

He subsequently turned up in California where he managed to get employment,
again, with Webster & Piper Sales in Fresno, November of 1979, and in the
record there's a letter from Dianne Stuart of Webster & Piper Sale
indicating problems, which again surfaced with Mr. Campbell's employment,
concerning false representations of qualification.

JUDGE CAPPS: When was this employment?

MS. HAUSELT: This employment was November of 1979 up through about January
16th, 1980.  Various claims were made by Mr. Campbell in the area of stunts
and airman certification which were untrue. Stories surfaced with regard to
his past, and a tragedy having occurred in his past which he claimed, which
were untrue.  There were problems with his teaching, and he was also
questioned as far as having taken certain items from the company, so he was
fired, again, from Webster & Piper Sales.  And, he then managed to talk
himself into another job in Nappa, California, where he was employed in
February -from February 4th to approximately February 29th, 1980.

And, while there, the FAA had finally accumulated and traced down all of
these various leads and stories that had been going on from one side of the
country to the other, and at that time his medical certificates were
suspended for failure to provide, and, subsequently, on receiving more
information from him and having him evaluated by Dr. Powers, the FAA issued
an Order of Revocation which is the subject of this hearing today.

I'd like to point out to Your Honor that in a case of this type it is just
virtually impossible for the FAA to subpoena all of the people who have
indicated that various stories and lies and behaviors of Mr. Campbell's
were abnormal, but there are letters from all of these people in the file,
and I have spoken to them myself, personally, as has Miss Taylor.

JUDGE CAPPS: Who is Miss Taylor?

MS. HAUSELT: Miss Taylor is an Inspector from New Hampshire, GATO
Inspector, and she'll be testifying for the Administrator.

Your Honor, I would just caution you at this point that part of the
personality disorder -- part of the problem we're speaking of here is a
very adaptability to lie, and through the testimony of Dr. Powers, Dr.
Pakull and Miss Taylor I will attempt to show the variety of
inconsistencies which appear in this file, and, also, Mr. Campbell is not
just here because he fabricates stories. We're talking about some stories
which have gone beyond the bounds of just a little white lie. We're talking
about stories such as pawning oneself off as being capable of rigging
parachutes for other people, when one is not qualified, such a claim being
something which could severely injure another person.

Also, we're talking about making a claim of being a doctor when one is not
qualified, and issuing drugs and whatnot; offering one's assistance to
people in need of medical when one is not qualified. So, we're talking
about a situation where a person consistently puts himself in a position of
being unable to resist the impulse to fabricate a story in order to improve
or to build up a grandiose self image, and this is not something which is a
mere personality trait which can be considered fleeting. This is something
which is an integral part of Mr. Campbell's character. By that I mean it is
a severe personality disorder, and the various episodes around the country,
I think, will support the fact that there have been many overt acts in this
case.

JUDGE CAPPS: Mr. Campbell, under the normal rules of courtroom procedure,
you are entitled to give your opening statement now, or, you can do what we
call reserve opening statement. That means let the Government put on their
case; They've got the burden of proof; let them put on their case, and
then, when they have rested, we turn to you and you can give your opening
statement. It's up to you, whichever you prefer. Do you wish to give it now
or to reserve?

MR. CAMPBELL: I will give mine now.

JUDGE CAPPS: All right.

MR. CAMPBELL: First of all, I take -- I personally disagree with quite a
few statements, both contained on the written record, and exemplified by
Ms. Hauselt. At any rate, first of all, the history up until, I would
imagine Christmas of '78, I imagine -- in other words it's up until my
departure from Tulsa, Oklahoma, is substantially correct except for a few
factors.

Specifically, number one, I left Oklahoma of my own free will, unbeknownst
to me at the time that the authorities were aware of my activities.

Number two, the authorities did not alert my parents to the problem. Excuse
me, my grandfather was first alerted to the problem by a young lady I was
familiar with, and at that point, as a matter of fact, it was the evening
of Christmas. My grandfather explained to me what was happening; that this
was abnormal and aberrant behavior and that he would like to see something
done, at which point plans for my return to Tulsa, Oklahoma were canceled.
The very next day we found out that the police were aware of the
activities.

Yes, I did represent myself, at times, as a physician; at times as a
medical student, and so forth. To the best of my knowledge I did not
dispense any type of -- I don't know what the proper word would be -- a
drug that would have to be prescribed. I did, at one period of time, give
several Tylenol capsules marked as Tylenol, in a Tylenol bottle, to a young
lady at the airport, while I was learning to fly at the time.

The article from the Tulsa World, I believe, appeared after, approximately
two weeks, maybe three weeks after my departure from Tulsa. My father, in
an attempt to find out what had happened and to clear up matters in Tulsa,
flew to Tulsa, met with this young lady who had alerted my grandfather of
the problem; Tulsa met with a representative of the Tulsa PD, at which time
it was apparently agreed upon that they would let matters lie where they
were and I would receive psychiatric care.

You have to excuse me - it's a little slow -- it's kind of hard to make up
as you go along. I really wasn't prepared for this today. At any rate, at
that point my father gathered up a great majority of my possessions, made
disposition of a few others, specifically an old car and so forth, and I
left Oklahoma with the understanding that nothing would be done by Tulsa PD
as long as I didn't show my face there again, so to speak, and this was a
quote from one of the detectives. Now, the article in the Tulsa World
contained quite a few inaccuracies, although the basic content is correct.

Following Tulsa, Oklahoma I left to go home, stayed at home from
approximately two days before Christmas to May of, I guess that's '79, and
received some care from a Dr. Dorsey of Hopewell Junction, New York. There
were not a great deal of sessions. I did gain quite a bit, but frankly I
don't feel that a lot was done; more my fault than his. Dr. Dorsey is a
rather outstanding physician -- his qualifications certainly bear that out.
I received also a great deal of care, and I think the majority of help from
my grandfather. My grandfather is a physician with a rather outstanding
psychiatric background, although he is not Board certified. He did run a
psychiatric hospital for the Army during World War II and held several high
offices with the AMA in New York State. As a GP, also, I think he had a
rather rare, but vital insight into the nature of the human mind. I have
continued that consultation with him throughout the past several years, and
my opinion has been -- well has produced the greatest benefit thus far.

In May of 19 -- I don't think it's '79, but at any rate -- May that year
when I left to go down to Perry, Georgia, I went first to Opeloca Airport
in Florida on a package deal for the CFI and Double I rating; found out
that they had changed their prices and was in the process of returning home
because I could not afford the rates. On the way back I stopped in at
Perry, Georgia. I had spoken to Mr. Brown on the phone. He had stated the
fact that he was an Examiner qualified to designate Certified Flight
Instructor of Airplane Instrument Multi-Engine. I stopped in. After a
period of time with him, explaining my difficulties and so forth, he put me
up in a small trailer there and volunteered to give me the instruction
necessary for the rating and to give me the check ride.

A friend of his, who was a Principal of the local school and a certified
flight instructor, Mr. Bob McLendon, rendered instruction, as did Mr.
Brown, and Mr. McLendon recommended me for Certified Flight Instructor
rating. At the time I was made aware of the fact that Mr. Brown had gone
through quite a large amount of flight instructors in the previous year --
I believe at least a half a dozen. There was a flight instructor there at
the time, who was also in the process of leaving. He was part-time, working
at Warner Robbins Air Force Base.

Shortly after I came on, also another flight instructor at the time, John
Williams, came onto the staff. Mr. Williams brought me a great deal of
experience and a great deal of insight into the nature of aviation and how
the so-called system worked while I worked there, and for the first
few months things were fairly good, despite the fact that I did refuse
several flights by Mr. Brown, considering the fact that his 135 Certificate
was dropped, and these were of an air-charter nature. I had also found
myself in extreme disfavor just after July 4th -- I don't know the exact
date -when his daughter eloped with one of my students. Mr. Brown accused
me of knowing about the situation, which was true, but only thirty minutes
before the actual wedding, by which time I believe Jim knew.  I really
don't know for sure; I do know he was aware very shortly, via phone call,
of his daughter's impending wedding. Quentin, the gentleman who married his
daughter, had just received his private license, as recommended by me
several weeks before. From that point my situation in regards to Mr. Brown
went steadily downhill.

Mr. Williams, the other flight instructor in residence, also had a great
deal of problems concerning policy, concerning pay, concerning promises
that were not kept and were not -well, they had made arrangements,
specifically, for a raise in pay which did not develop until approximately
a month later, although he did come through on it, and I believe Mr.
Williams was also asked to fly a few flights that would come more under 135
than 91, and Mr. Williams refused. I believe his quote is, "I'm not giving
my ticket to anybody."

I developed a rather strong friendship with Mr. Williams. He gave me a
great deal of aid and help in obtaining my Certified Flight Instructor
Instrument Airplane, and during the latter part of August I had started
making phone calls, specifically with the idea and intention of leaving
Brown Aviation. Now, Nashua Aviation, my employer afterwards, can bear this
out -- that I did make contact with them in early and late August. As a
matter of fact, going as early as June, with the possible intention of
finding employment. Eventually, I believe, I spoke to Gary Stuart on both
occasions prior to my leaving Brown, and he had indicated, "Come on up, we
need instructors", and, in fact, when I did arrive there, they were also
still short at the time with the school semester already starting.
I gave Mr. Brown what I thought was going to be two weeks notice. He
thereby informed me he did not want me around. Now, I quit. I have
witnesses to that effect. I can produce statements. You just have to give
me time, and this is, I think, easily verifiable; just a matter of tracking
the people down.

Also, and this is something I cannot prove, but I'm going to enter it
anyway -- Mr. Brown produced additional evidence of the fact that I had
been doing nasty things behind his back, simply because he had recordings
of his phone -- excuse me, of conversations made on his telephone.

JUDGE CAPPS: What type of conversations? Seeking other employment?

MR. CAMPBELL: Seeking other employment; conversations with the Pastor of my
church; conversations with my parents; conversations with friends; he had
two lines, and apparently one of them had a full-time tape recorder on it.
In fact, he played back a recording I had with my Pastor which was rather
shocking. I don't know, really, how to prove that, because he said that if
I disappeared and didn't give him anymore trouble, he was going to "destroy
them". At any rate -

MS. HAUSELT: I realize that Mr. Campbell's not a lawyer and doesn't
understand that a lot of this would be of the nature of testimony which, I
believe, should be given under oath, and I would prefer if he could just
summarize and then give the details of his testimony while he's under oath.

JUDGE CAPPS: Yes, that's true. Except so much has gone on, and this appears
to be the easiest way for him to do it. I may be able to ask him, when he's
under oath, if his testimony would be the same as the opening statement, in
narrative form.

MS. HAUSELT: I'd prefer to have it under oath at some point.

JUDGE CAPPS: Well, okay, we'll have to go through all of this, then. Do you
want to shorten it up?

MR. CAMPBELL: Yes, ma'am, if that would help the proceeding.

JUDGE CAPPS: Yes. Just tell me, generally, what you're going to show by way
of proof.

MR. CAMPBELL: Brown Aviation -- I resigned. He told me to leave
immediately, otherwise he had threatened me with arrest, and I did, in
fact, leave, by motorcycle from Perry, Georgia to Nashua, New Hampshire.
I arrived in Nashua, New Hampshire the first week of September. I assumed
employment shortly thereafter, employed both as a flight instructor for
Nashua Aviation and Supply Company and for Daniel Webster College.

During this period of time I felt I had represented myself in an honest and
fair manner, although, frankly, and things had followed me along from my
background that were very hard to explain, and frankly I had to go along
with what I had said in the past, whether or not it was true. These
statements, I felt, were of a minor nature. Anything else that I thought
was of major nature I corrected in the best way possible. Frankly, to save
my stature, and I guess I really don't know the words -- save my pride,
more likely.

I worked at Nashua Aviation and Supply Company uneventfully and with a
great deal of support from my students and from most of the people I worked
with, for several weeks, at which time a copy of the article that had
appeared in the Tulsa World appeared, first, on campus, at Daniel Webster
College, and then at Nashua Aviation and Supply Company; the people at
Daniel Webster College had supplied Nasco with that article. It was given
to the Chief Flight Instructor. At a flight instructor meeting afterwards
he asked, "Is this you?" and I said, "Yes, it is." I offered what I felt
was my justification at the time. He said, "Well, until something else
happens, just keep on going". At the time, they were happy with my work,
and for somebody to keep me after seeing an article of that nature, I was
rather flattered that they had that much confidence.

The situation was extremely difficult -- the situation was extremely
confusing and culminated, eventually, in the appearance of the FAA and two
people, a Ms. Taylor, and another gentleman who I'm afraid I don't remember
his name. We did have a discussion; I presented log books, my side of the
story and so forth. Several days later Dr. Cahill from the New England
Region -- I believe he's the Flight Surgeon, showed up at Nasco with a
letter stating in effect, and I'm paraphrasing, we find that you may or may
not be qualified to hold a medical certificate. This letter also stated he
had received, on October 10th, the date of this letter, that he had
received information from Dr. Dorsey. Dr. Dorsey's first communication to
Dr. Cahill came two days later -- October 12th. The letter from Dr. Dorsey
was rather short, rather sparse, and apparently this was intentional. Dr.
Dorsey was not aware of how much information was required.

When Dr. Cahill had presented himself at Nashua Aviation and supply
Company, he had said to my Chief Flight Instructor that I am grounded. He
had said specifically that this letter grounded me, period. And he told
Steve Rachelson that I was, in effect, grounded, although this letter
seemed to indicate differently. It only cast doubt; it was not an actual
suspension or revocation as far as I can see. I left the Nashua Aviation
and Supply Company. I left Daniel Webster College, rather upset, greatly
troubled, and specifically with the idea of finding employment somewhere
else and raising enough money to get the evaluations and/or the treatment
anybody felt I needed. Frankly, at the time, I didn't feel that I did, and
that situation has since changed.

I had said to various people that I was heading south, west, east,
overseas, whatever was the case, specifically to throw them off the track.
Specifically I did not want anybody to know where I was going, because
Tulsa had already followed me to Nashua and I was going to be damned if I
was going to let anything else spoil things while I was trying to rebuild
what had already crumbled. I had left for California after receiving a tip
from a gentleman who had instructed me for my Multi-Engine Instructor's
Certificate, about Western Piper and Fresno, California. I spoke to Mr.
Dale Ewell on the phone. Mr. Ewell said, "Fine, we need an instructor".
Mr. Ewell also said that he could get me out there by carrying a couple
airplanes from Harrisburg, which was where they were keeping several dozen
Tomahawks, to Fresno, and eventually San Jose. This I did.

JUDGE CAPPS: This is Harrisburg, Pennsylvania'?

MR. CAMPBELL: That's correct. That's where the departure was for
California. I eventually carried two Tomahawks from Harrisburg to Fresno.
I arrived in Fresno; was told I would be getting $1,000 a month, a minimum
of 100 hours flight time, various benefits and so forth. This was not to be
the case. My employment for Western Piper was rather difficult. I had some
immediate problems with another flight instructor, ego problems, frankly.
We did not get along. At first I took quite a liking to the secretary,
Dianne Stuart, which later turned into tolerance, I imagine the word is.
Mrs. Stuart and I have very divergent views on morality and so forth. I did
not get along with her, not in the slightest. Also, at Western Piper things
were catching up with me. I was really running, frankly. Stories were
popping up; some were too embarrassing to specifically deny, and as a
result I had to agree with them and say, yeah, yeah, and drop it; not the
case -- did not work that way.

Through an ad that appeared in the Fresno Bee, I believe, a daily
newspaper, there was an ad for flight instructors promising a rather large
salary at the time for a flight instructor, in Nappa, California. I made an
appointment to go up and speak to the people at the International Air
Service Company. At that time I went up and was interviewed, I was given a
flight check with one of Japan Airlines Captains, and the Chief Flight
Instructor for the International Air Service Company, and I passed it.
However, the check ride itself was simply an introductory. I was given
almost not quite a month's training in addition to the check ride, to
prepare me to be a flight instructor for Japan Airlines. I left -- I quit,
actually, about the same time I was about to be fired from Western Piper.
There were a great deal of problems; a great deal of differences; a great
deal of difficulties.

I also would like to put in the record one specific point that I told Mr.
Ewell, at the time I was hired, that I had had previous psychiatric
consultations with a physician, and that I had had personality problems. I
did attempt to downplay them, and explained that, to me, they were not all
that serious.

In Nappa, California I started working for Japan Airlines. I started in
their first several days of ground school. As a matter of fact, it was
several weeks of ground school concerning job procedures, the IASCO
procedures, aircraft systems, teaching, just the gamut -- it was absolutely
incredible the range of matter that they had us digest in a very short
period of time, including memorizing five pages of checklists and so forth.
It was difficult, very enjoyable.

I was in the process of digesting this material when Mr. Ed Scarboro, the
Chief Flight Instructor from the International Air Service Company, showed
up; said these two gentlemen who would like to speak to you. These two
gentlemen identified themselves as the FAA and said, "We would like to see
your certificates", quote, unquote -- that is all I was told. I said,
"Well, they're in my car, if you'll follow me out". I had my Torerro in the
parking lot; we started walking out and I said, "What's this all about?" He
said, "Well, we just need to see your certificate". I went into the glove
compartment of my car, turned around, I said, "Well, what's the problem?"
And they said, "Let's just see your certificate".

They examined my Pilot's Certificate, my Flight Instructor's Certificate,
my Medical Certificate, handed me back my Pilot's Certificate, my Flight
Instructor's Certificate and a letter from the FAA indicating suspension;
in other words, seizing my Certificate without letting me know first
exactly what was happening. At that time I became extremely upset, almost -

JUDGE CAPPS: Which Certificate did they seize?

MR. CAMPBELL: The First Class Medical Certificate issued by Dr. Reynolds of
Fresno, California.

JUDGE CAPPS: Oh, I thought you said they gave that back to you.

MR. CAMPBELL: No, they gave me back my Pilot's Certificate, my Flight
Instructor's Certificate, but not my Medical Certificate, instead handing
me the letter of suspension. This was February 7th, I believe the letter
was dated, I believe, January 29th. I may be incorrect. I became extremely
upset, almost to the point of tears; explained the fact that I was in the
process of trying to raise funds in order to get the consultation and get
the evidence I needed to refute this, and I made exception with items on
the form, and they said, "Look, there's nothing we can do about this. We
are just here to present the forms." They accompanied me into Mr.
Scarboro's office where they explained that the process involved could be
lengthy, but may, indeed, be taken care of in a short period of time. They
also explained what was needed, specifically evidence to the contrary to
prove that I was qualified to hold the Certificate. Mr. Scarboro and I were
both of the impression and opinion that we could clean this whole matter up
rather shortly, so he kept me on the payroll, kept me in flight training,
at a great deal of expense to them, and I proceeded for the next month, to
undertake flight training and eventually pass a very rigid check ride to
Japan Airlines standards in order to be a flight instructor for the Japan
Airlines pilot training program at the Flight Crew Training Center.

I saw two doctors, a psychologist and a psychiatrist. The psychologist gave
me a battery of written testing, which was submitted to Dr. Sexton, who
told me that wasn't good enough and that I had to have other tests. I went
back a second time, at even more expense, got the tests done, psychological
written testing and oral testing, in addition to a bit of discussion. The
psychologist presenting the test at the time said, "Frankly, there is very
little difference between the tests" and he was rather doubtful about the
fact that the FAA wanted to give my Medical Certificate back. He felt that
I was being stalled.

JUDGE CAPPS: Wait a minute, we're running out of tape.

MR. CAMPBELL: I also completed several visits with a psychiatrist. Both
reports were submitted. After some consideration by the Western Region
Flight Surgeon -- I hope that's the term, Dr. Sexton -- he said, "I'm
worried about your impulse control" and explained that he would have an
interview with one of his doctors. In other words, somebody that they had
said, now, he said, frankly, it would be several weeks. The problem, at the
time, was the fact that I was nearing the check ride for Japan Airlines, at
which point I was either going to pass and/or fail, and if I passed, I was
going to have to go to work, or go on inactive list and not draw a
paycheck, which was staring me in the face, with additional expenses
mounting at the time; I was getting a little bit terrified.

I made numerous phone calls to various State and Government agencies trying
to get some help, specifically because there was a several-week lapse
between that phone call and the appointment made with Dr. Powers, all to no
avail, although the only concession I got was a gentleman from a
congressman's office in -- I'm trying to remember -- it's a county just
east of Nappa -- excuse me, west of Nappa -- I'm afraid I don't know, and I
can find out -- said that Dr. Sexton had promised, since the appointment
was on a Friday, he would evaluate it that evening and give me the results
as soon as possible, specifically that evening. This gentleman also offered
to provide a statement to that effect because, frankly, at that time I did
not believe it. That statement was never taken. It was offered. He was
willing to offer a notarized statement or whatever the proper legal
terminology is.

The appointment did take place with Dr. Powers. I spoke to him, in the
neighborhood, I believe, of less than two hours. I'm not quite sure if it
was more or less. During this period of time I gave him information as he
requested, although he apparently found great fault with the fact that I
did not respond until questioned about the World Trade Center incident.
Now this incident has been a matter of FAA record for many, many, many
months.

JUDGE CAPPS: Okay, you can tell me your side of that incident during the
testimony.

MR. CAMPBELL: Okay, fine, all right. At which point I went home for the
weekend, chewed a couple of fingernails, waited for a decision and
approximately two o'clock in the afternoon, Monday, I called Dr. Sexton for
I think the third time that day, badgered the poor man, and at which time
he apologized and said he was going to have to deny my Certificate. After I
calmed down, about fifteen minutes later, I'd gone in to speak to Scarboro,
told him what had happened, my parents were in San Francisco that weekend,
specifically to see me. I told them, and I made preparations to go home,
specifically because I was broke, and I had to borrow money to go home.
I went home. I found employment as an electronics technician. I had been
doing that job for eight months now. I found employment, I think, four days
after I got home. I was helped a great deal by a letter of recommendation
provided by the International Air Service Company who had said, at the
time, although that situation may have changed because of information they
have received, that they would be glad to have me back providing openings
existed. I went home. There is not a whole lot more to say, except for the
fact that I have recently -- first or second week of September -- enrolled
myself in the West Bergen Mental Health Center and am following the
prescribed program of treatment.

JUDGE CAPPS: All right, when did you enroll there?

MR. CAMPBELL: It was in September. I don't have an exact date.

JUDGE CAPPS: Of this year?

MR. CAMPBELL: Of this year.

JUDGE CAPPS: And, what's the name of the --

MR. CAMPBELL: West Bergen Mental Health Center.

JUDGE CAPPS: Westberg?

MR. CAMPBELL: West Bergen -- Bergen County.

JUDGE CAPPS: West Bergen --

MR. CAMPBELL: Mental Health Center. I spoke to one of their staff workers,
and their psychiatrists who have lined me up with a specific therapist,
and, matter of fact, I've got an appointment tomorrow night. The idea here
is no longer to gain just Medical Certificate, but specifically to remove
any doubt from my mind or anybody else's that I have a problem or will have
a problem or allow the problem to grow. The idea here, specifically, is the
problem has always existed. It's just a matter of control. I believe my
control's improved. It has a ways to go yet. I do not feel that I am
dangerous as a pilot. I think my record bears that out. I've been a damned
good flight instructor, and I'm proud of my record.

I also feel that my acts, well, although I have not felt a great deal of
guilt over a great deal of them, that have happened recently; I offer no
explanation other than the fact that I was disturbed up until Tulsa,
Oklahoma, and even, for instance, afterwards. However, I do believe that I
am a competent pilot in command.  I do believe I am a competent flight, and
I do believe I can prove that. Thank you.

JUDGE CAPPS: All right, we'll have a five-minute recess before the first
witness is heard.

(Whereupon, a five-minute recess was taken.)

JUDGE CAPPS: Miss Hauselt, you may call your first witness now.

MS. HAUSELT: Your Honor, I call Inspector Sandra Taylor.

Whereupon,

                           SANDRA TAYLOR

having first been duly sworn by Judge Capps, was examined and testified as
follows:

JUDGE CAPPS: At this point, let me give some more of my Law School
instructorship to Mr. Campbell. What is going to happen now is we've got
a witness on the stand under oath. This witness has been called by the
Government. The Government is now going to conduct what we call the direct
examination. Listen carefully, because you will have the right to
cross-examine this witness on any of the testimony brought out during the
direct examination. Do you understand?

MR. CAMPBELL: Yes, ma'am.

JUDGE CAPPS: All right.

                            DIRECT EXAMINATION

BY MS. HAUSELT:

Q. Can you state your name for the record?

A. Yes. My name is Sandra Ann Taylor.

Q. And what is your business address?

A. My business address is the Portland General Aviation District Office,
Portland International Jetport, Portland, Maine, 04102.

Q: And you're employed by FAA?

A. Yes,

Q: In what capacity?

A: I am a Aviation Safety Inspector.

Q: What is your employment background with regard to  aviation?

A. I have worked as a flight instructor.

Q: For how long?

A: For approximately two years. I have held a Flight  Instructor's
Certificate for about five years. I have worked  as an Air Traffic
Controller for one year, and my present job for two and a half years.

Q. And could you just give us what your ratings certificates are?

A. Yes. I hold a Commercial Pilot's Certificate with an instrument in
Multi-Engine Rating; a Flight Instructor's Certificate, instrument and
multi-engine.

Q. And you know Mr. Campbell, who is the Respondent in this case?

A. Yes, I do.

Q. How did you come to know him?

A. I was called by Steve Rachelson, who was, at the time, the Chief Flight
Instructor for Nashua Aviation. He called and -

JUDGE CAPPS: Wait. He was Chief Flight Instructor?

THE WITNESS: Yes.

JUDGE CAPPS: For what?

THE WITNESS: Nashua Aviation and Supply Company. He called and told me of
the problem that Daniel Webster College was having with Mr. Campbell and
asked me if I would call Oklahoma City and verify that he did have valid
Pilot's Certificate.

BY MS. HAUSELT: (Resuming)

Q. What was the problem that he described with regard to Mr. Campbell?

A. He told me that Mr. Campbell was, at the time, working for Nashua
Aviation and Daniel Webster College as an instructor and he wanted to form
a parachuting club and he had approximately two hundred people interested
in this club, and they found out through the newspaper article from the
Tulsa Tribune that he had some past problems, and they were concerned.

Q. Did they question his qualifications?

A. Yes.

Q. What did you do with regards to Mr. Rachelson's request?

A. I called Oklahoma City and found out that the Certificates that he holds
right now are valid certificates.

Q. And in the course of that investigation, did you ascertain whether or
not Mr. Campbell was qualified as a parachute rigger?

A. I didn't at that point.

Q. But at a later time?

A. I did, yes.

Q. And what was the result of that? Was he qualified?

A. No, he was not qualified. Oklahoma City had no record of him having a
Parachute Rigger's Certificate.

JUDGE CAPPS: Why didn't you ascertain that at the time you ascertained the
validity of his current certificates?

THE WITNESS: Because at the time that wasn't the problem. That never
entered into it.

JUDGE CAPPS: Nobody told you anything about parachute rigging intentions?

THE WITNESS: No. That it was just to form a parachute club

JUDGE CAPPS: All right, did that parachute rigging activity or intended
activity subsequently come to your attention from someone?

THE WITNESS: Yes, from Mr. Campbell.

JUDGE CAPPS: From Mr. Campbell, himself.

THE WITNESS: That was the first time I heard about it.

JUDGE CAPPS: So you had contacted Mr. Campbell; is that correct?

THE WITNESS: Yes.

JUDGE CAPPS: All right.

BY MS. HAUSELT: (Resuming)

Q. Getting back to your initial check on Mr. Campbell's rating -- did you
make any phone calls to persons who had given him the tests?

A. Yes, I did. One of the Certificates that Mr. Campbell held was a
temporary certificate for flight instructor certificate, which meant that
he just recently took his flight instructor flight test, so I contacted a
James Brown, who was the examiner, and I talked to Mr. Brown about Mr.
Campbell.

Q. And where does Mr. Brown reside?

A. I -- Georgia.

Q. And what did Mr. Brown relate with regard to Mr. Campbell's employment?

A. Mr. Brown said that Mr. Campbell worked for him for approximately three
months. When Mr. Campbell first came there, he was given the necessary
instruction and the flight test to get his flight instructor's certificate,
and then began working for Mr. Brown, and two out of the three months that
he was there he was an ideal employee, and Mr. Brown said the third month
it was like someone pushed a button. That's a quote from Mr. Brown. His
personality changed completely and he had to be fired.

Q. Okay, did Mr. Brown relate any other information with regard to Mr.
Campbell?

A. Yes, he told me that one of the reasons he had to be fired was because
Mr. Campbell was telling his students stories about his parachuting while
they were supposed to be getting flight instruction, and his students were
beginning to complain that they weren't receiving the flight instruction
that they were paying for.

Q. At that time Mr. Brown did not relate anything with regard to -- I refer
you to page 36 -- do you have a copy -- at that first phone call that you
had with Mr. Brown, he did not relate anything with regard to Mr.
Campbell's conversation with a minister on the telephone which is embodied
in the second to the last paragraph, that letter on page 36?

A. Not my first conversation, no.

Q. At a subsequent time, did you speak with Mr. Brown?

A. Yes, I did.

Q. And at that time did he relate anything with regard to this story?

A. Yes, he told me the story that is written in his letter here.

Q. Okay, could you just relate what that was?

A. Okay. He said that a friend -- a girl -- from Alabama had come up to
Georgia to visit a friend out there, and while she was there, the girl and
Mr. Campbell met and they went out a couple of times. One day Mr. Campbell
came in to speak to James Brown, and he said that the girl had to go home
immediately because her house had burned down the night before, and so he
made sure that she got on a bus, home to Alabama. He discovered shortly
afterwards that that never occurred. She did go home on the bus, but she
went home because her stay was over. She was just going home; that was all.
Her house had never burned down. Later Mr. Campbell said that on the way to
Alabama the bus that the girl was taking had an accident and the girl was
in critical condition in the hospital, and Mr. Campbell went to see her a
couple of times in Alabama.

One afternoon Mr. Campbell was talking to the minister on the telephone,
and he was in Mr. Brown's office or building there in Georgia, and Mr.
Brown went to make a phone call, and he didn't realize that Mr. Campbell
was on the phone, and he picked up the telephone and overheard Mr. Campbell
telling the minister about the girl in the accident, and he said, frankly,
he just decided to continue listening rather than put the phone back down
again, and he heard Mr. Campbell tell the minister that he was there in
Alabama with his girlfriend and she was right down the hall from him and he
proceeded to tell the minister of the injuries, the head injuries and she
was in critical condition; I can't recall all the injuries that he said.

Q: Well, at the time he was telling the minister he was in Alabama, he was
sitting in his office in Georgia?

A. Yes.

Q. Did Mr. Brown, in either conversation you had with him, relate any other
information with regard to Mr. Campbell?

A. I don't believe so.

Q. Okay.

JUDGE CAPPS: Let me ask you this. Was the girl, in fact, ever involved in a
bus accident?

THE WITNESS: No.

JUDGE CAPPS: All right. Go ahead.

BY MS. HAUSELT (Resuming):

Q. Getting back to the problems at Nashua and Daniel Webster College, after
you checked out Mr. Campbell's ratings and spoke with Mr. Brown, what did
you do at that time?

A. I arranged to have a meeting with Mr. Campbell and myself and another
inspector in the office, Mr. David Greensbach. We went to Nashua Aviation
and met with Mr. Campbell and Steve Rachelson.

Q. And during the course of that conversation, what did Mr. Campbell relate
to you?

A. Okay. The first thing that we did was to tell him why we were here and
of the problems with Daniel Webster College. And, immediately Mr. Campbell
says that what Daniel Webster College is doing to him was a felony and he
currently engaged an attorney in Nashua and had a lawsuit against Daniel
Webster College. He also said that he had a student rally in the auditorium
of Daniel Webster College, with approximately two hundred people there and
it made the faculty look foolish because the students were on Mr.
Campbell's side. He was questioned about the newspaper article, about the
doctor in Tulsa, and Mr. Campbell said that that did happen; however, it
happened at a time in his life when he was not himself, and the reason for
it was because he had lost his wife and his child in a car accident.

Q. That's what he told you was the reason for this behavior in Oklahoma?

A. Yes.

Q. Were you ever able to ascertain whether or not Mr. Campbell had been
married?

A. No, I wasn't.

JUDGE CAPPS: You were not able to ascertain that?

THE WITNESS: No.

BY MS. HAUSELT (Resuming):

Q. You could not find any proof that he had been married; is that correct?

A. Right, that's correct.

Q. In the course of your investigation, did you ascertain whether or not
Mr. Campbell had related the story of his wife and child being killed to
other people?

A. Repeat that question.

Q. In the course of your investigation, did you ascertain whether or not
Mr. Campbell had told this story of his wife and child being killed to
anyone other than yourself during the course of your interviewing?

A. Yes, he told that to very many people.

Q. And, in fact, he told that to the Dean of the College; did he not?

A. Yes.

Q. And that information is set forth in the file, Your Honor, pages 16 to
33, which is a compilation of information from the Dean of Daniel Webster
College. Did you, at anytime, speak with Dean Schultz of Daniel Webster
College?

A. Yes, I did.

Q. And, what did he relate to you with regard to Mr. Campbell's problems at
the school?

A. DR Schultz had told me that he had hired Mr. Campbell to teach a
meteorology and a private pilot ground school course there at the College,
and during the course of his teaching he became concerned because he was
receiving some complaints that Mr. Campbell was spending the time talking
about parachuting rather than teaching the course. And, about the same time
Dr. Schultz said that a Howard White, and I cannot recall his title -- New
England Conference of some kind, I can't remember -

Q. Would it be the New England Conference Coordinator for the US Parachute
Association?

A. Yes. He came in to see Dr. Schultz and he told him  there were a couple
of things that he should know about Mr.  Campbell, and that is when the
problem started.

Q. And this information is set forth in Dr. Schultz'  report on pages 27
through 33. What did Mr. White indicate was the problem with Mr. Campbell's
parachuting; his certificates?

A. Mr. White did not say anything that I recall, at least

Q. Okay, you spoke to Mr. King?

A. Yes.

Q. It was Mr. White that first brought the problem to Dr. Schultz'
attention?

A Yes.

Q. And in the course of your investigation, you, yourself, did not speak to
Mr. White -- you spoke to Mr. King?

A. Yes.

Q. Who is Mr. King?

A. I cannot remember without looking it up.

Q. Okay, go ahead and take a look at your notes.

A. He is the Executive Director for the United States Parachuting
Association.

Q. And, in your conversation with Mr. King, what did he tell you concerning
Mr. Campbell's affiliation with the U.S. Parachuting Association?

A. Mr. King told me that Mr. Campbell did belong to the U.S.P.A., the
United States Parachuting Association, at one time, but he was currently
suspended from it for various reasons. The first reason is because he tried
to parachute off the top of the World Trade Center. The second reason was
Mr. Campbell was using the U.S.P.A., insasfar as saying he was a current
U.S.P.A., instructor, and he was not. He had also rented several films from
the U.S.P.A. which Mr. King could not get Mr. Campbell to return. So, for
these reasons he was suspended.

Q. At the time you began -- you were investigating this part of the case
and the parachuting aspects of the case, did you ascertain at this time
whether or not Mr. Campbell had a Parachute Rigger's Certificate?

A. Yes, I did.

Q. And, what was the result of that search?

A. Oklahoma City has no record of Mr. Campbell ever having a Parachute
Rigger's Certificate.

JUDGE CAPPS: Had he ever applied for one?

THE WITNESS: They have no record of him ever doing that in any respect.

BY MR. HAUSELT (Resuming):

Q. I want to refer you to pages 39 and 40 in the record, and Miss Taylor,
could you tell us what those pages are?

A. These are the application for employment which Mr. Campbell filled out
before he started to work for Nashua Aviation.

Q. And, at the bottom of page 39, what did he indicate with regard to his
parachuting skills?

A. He put down that he was an FAA Senior Parachute Rigger, an instructor
certified in parachutes.

Q. And as a result of your investigation, you ascertained that neither of
those claims were correct?

A. Yes.

Q. Also, referring to this application, on page 40, at the top of the page,
Mr. Campbell indicated there that he was employed by the Screen Actor's
Guild in Burbank, California. Did you make any inquiries with regard to
that?

A. Yes, I did, and they have no record of him ever belonging to the Screen
Actor's Guild.

Q. And, as a result of your investigation, did you ascertain whether or not
Mr. Campbell had indicated to people that he had been a stuntman in various
James Bond movies and different television series such as Charlie's Angels?

A. Yes, he has.

Q. And that information was also encompassed in Dean Schultz' report on
pages 16 through 33O

Did Dr. Schultz indicate to you that those types of claims had been made to
him?

A. Yes, he did.

Q. And did Dr. Schultz indicate whether or not he, himself, had attempted
to verify whether or not Mr. Campbell was employed by the Screen Actor's
Guild?

A. Yes, he, himself, called and got the same answer as I did.

Q. Did Dr. Schultz indicate that Mr. Campbell had made any other claims
with regard to his teaching in the past?

A. Yes. Dr. Schultz said that Mr. Campbell had told him that he was an
instructor for the Aircraft Owner's and Pilots Association, a ground school
instructor.

O And did Dr. Schultz attempt to verify that information?

A: Yes, he did.

Q. And what was the result of that search?

A. The AOPA does not have any record of Mr. Campbell ever working for them?

JUDGE CAPPS: What's the name of that company?

THE WITNESS: Aircraft Owners and Pilots Association.

BY MS. HAUSELT (Resuming):

Q. Did you, yourself, make any efforts to verify whether he was employed by
the Aircraft Owners and Pilots Association?

A. Yes, I called, also.

Q. And what did they tell you?

A. He was never employed.

Q. As a result of your investigation, what action did  the FAA take?

A. After my investigation, I wrote a memo to Dr. Cahill,  the Regional
Flight Surgeon, and Dr. Cahill wrote a letter to  Mr. Campbell requesting
further medical records from him

Q. About this time Mr. Campbell was also fired from Daniel Webster College;
was he not?

A. Yes, he was fired from Daniel Webster College, and he was suspended from
Nashua Aviation from teaching until this matter was cleared up.

Q. And eventually what was the result of his teaching position at Daniel
Webster? What happened with regard to the teaching position? Did he keep
it?

A. No. No, he lost that.

Q. Then he was fired by the College?

A. Yes.

Q. When he left the area, where did he indicate that he was going?

A. He indicated that he was going to fly for Air South in Florida.

Q. And was he ever traced to their company in Florida?

A. No.

Q. And this was about the same time that he was told that he was under
investigation by the FAA?

A. Yes.

Q. I just want to ask you -- concerning your interview with Mr. Campbell,
the interview that you had -- questioning him about the certificate -- what
was your first impression of him when you met him?

A. My first impression of Mr. Campbell was that he was very convincing, and
I believed everything that he was telling me, and I did believe that he was
a victim of other people's prejudices.

Q. And he told you about his wife and child and you believed that part of
the story?

A. Yes, I did.

Q. And as a result of your investigation -- strike that - what did your
later investigations reveal about what Mr. Campbell had told you during the
interview?

A. My later investigation as to what he told me revealed that nothing that
he told me was correct or undistorted. It was basically untrue.

Q. With the exception of the fact that he did have, to the best of our
knowledge, valid FAA Certificates, except for his medical?

A. Yes.

Q. After Mr. Campbell left the area and went to California, in the course
of preparation for this hearing and your investigation, did you speak with
anyone at Western and Piper Sales in Fresno?

A. Yes, I did.

Q. What was their title?

A. I spoke with the bookkeeper at Western.

Q. And that is someone other than Dianne Stuart?

A. Yes.

Q. Dianne Stuart's letter appears on pages 34 and 35. What did the
bookkeeper at Western and Piper Sales tell you with regard to the
employment of Mr. Campbell with Western and Piper?

A. She told me that Mr. Campbell worked with them for approximately two to
three months and he was fired, eventually, for several reasons. The first
reason was he was suspected of taking money from the petty cash drawer.
Another reason was his wild stories and she related only one of those to
me.

Q. What was the story that she related to you?

A. She told me that Mr. Campbell was asked to shave off his beard. It is part
of the dress code for
Western Air, and Mr. Campbell said he would rather not
because while he was
in Vietnam he got a shrapnel wound in the jaw, and the
beard was hiding
that.

Q. How old was Mr. Campbell at that time?

A. He was approximately seventeen.

Q. During the Vietnam War?

A. Approximately seventeen.

Q. What else did the bookkeeper at Western and Piper tell you, if anything?

A. Yes, she did. She had also said that Mr. Campbell started to give away
their instructional supplies and books to his friends as Christmas gifts
around Christmas time. She also told me that Mr. Campbell made
approximately $200 worth of long distance telephone calls, and when later
confronted with it for payment, he denied that he ever made the calls.

Q. I want to refer you to page 34 and 35, which is the letter from Dianne
Stuart at Western and Piper, and ask you, what does she -- in that letter,
is there any indication that Mr. Campbell has ever had a problem in flying,
actually in flying situations?

A. Yes. Mr. Campbell would claim that he had more than one malfunction in
the aircraft which forced him to make emergency landings on more than one
occasion, and when inspected by the mechanics and the FAA, they could find
nothing wrong with the airplane.

Q. And this happened on more than one occasion?

A. Yes.

Q. And did Mrs. Stuart indicate that Mr. Campbell also related the story of
his wife and child being killed in a car accident to people at Western and
Piper, on page 34?

A. She did.

Q. And, on page 35, does she also indicate that Mr. Campbell had a problem
with regard to some friends being killed while skydiving?

A. Yes.

Q. And what was that?

A. Mr. Campbell had told her that five of his friends were killed in a
skydiving accident, and he was quite upset about that.

Q. And what did the investigation by local authorities come up with?

A. The skydiving accident happened several years earlier.

Q. And does Mrs. Stuart also indicate that Mr. Campbell represented himself
as a parachute rigger out at Western and Piper?

A. Yes, she did.

Q. And, with regard to Mr. Campbell's attempt to jump off the World Trade
Center, what did he tell people out in Western Piper Sales concerning his
jump?

A. He told people at Western Air that he did jump off the World Trade
Center.

Q. And he had the article referrals to back it up?

A. Yes.

Q. When you spoke to the bookkeeper at Western Piper, what did she indicate
were some of the problems that students had with Mr. Campbell as an
instructor?

A. One problem in particular the students had was a lot of students had
complained that they did not want to get into the same airplane with Mr.
Campbell because of his grooming.

JUDGE CAPPS: That is very general. Did she get more specific?

THE WITNESS: Yes, she did.

JUDGE CAPPS: Okay, I'd like to hear it.

THE WITNESS: She said that the students did not want to get into the same
airplane with Mr. Campbell because of his odor.

BY MS. HAUSELT (Resuming):

Q. And did they attempt to verify where he was residing at that time?

A. Yes, they did.

Q. And were they able to?

A. No, they weren't able to find out.

Q. And, what did she relate -- did she indicate whether or not she knew
whether he had a place to live?

A. She indicated to me that she did not know, but she had suspected that he
did not have a place to live.

Q: Did she give you any opinion with regard to Mr. Campbell's behavior?

A. Yes, she had told me that, as an example, when Mr. Campbell was
confronted with the telephone calls, he became very angry, and -

JUDGE CAPPS: Confronted with what telephone calls?

THE WITNESS: The telephone calls that he made all over the country and
charged to the company.

JUDGE CAPPS: Oh, I see; the long distance calls.

THE WITNESS: Yes.

JUDGE CAPPS: Okay.

THE WITNESS: Mr. Campbell became very angry, and it was her opinion and
other people's opinion that he could become very violent, and they were
actually afraid of him going out to the flight line and deliberately
breaking and smashing airplanes on the front line.

BY MS. HAUSELT (Resuming):

Q. At the time he made all these phone calls, was there any effort made to
trace the phone calls?

A. Yes, there was. The telephone company, themselves, traced the phone
calls and did find out that Mr. Campbell did make the phone calls.

Q. So, it was verified by the phone company, through the people who
received the phone calls that Mr. Campbell had made them?

A. Yes.

Q. And when he was confronted with this, he denied it?

A. Yes, he denied it.

Q. Did the bookkeeper relate any other information, or did she give you an
opinion as to -- did she give you her opinion as to Mr. Campbell's
behavior?

A. Yes, she did.

JUDGE CAPPS: Now, the bookkeeper is not Mrs. Stuart?

THE WITNESS: No, she's not.

JUDGE CAPPS: all right, now we're back on the bookkeeper. This other stuff,
Mrs. Stuart told you?

THE WITNESS: No, no, no. The bookkeeper told me. I have never spoken with
Mrs. Stuart.

JUDGE CAPPS: Okay.

MS. HAUSELT: The references to what Mrs. Stuart said are in a letter on
page 34 and 35.

JUDGE CAPPS: I've got that down, yes.

MS HAUSELT: Conversation that I had with Mrs. Stuart.

BY MS. HAUSELT: (Resuming)

Q. Okay, you can continue.

A. It was her opinion that Mr. Campbell could not take care of himself.

Q. In the course of your investigation, did you ascertain where --

JUDGE CAPPS: Wait -- I'll need some more explanation along those lines.

THE WITNESS: That's all she said. I didn't pursue | it any further.

JUDGE CAPPS: Okay.

BY MS. HAUSELT: (Resuming)

Q. Did she make any comment with regard to his medical state?

A. Not that I -

Q. Did she make any comments as to whether she thought Mr. Campbell was
mentally stable or unstable?

A. Yes, she did. She said -- not her exact words, but she did say that she
thought Mr. Campbell was not stable.

Q. I think, for the purposes of the Judge, you should tell the Judge, to
the best of your knowledge, or the best of your recollection, what words
she used.

A. Exact words?

Q. Yes.

A. Okay. She said Mr. Campbell was looney tunes.

Q. In the course of your investigation, did you find out where Mr. Campbell
went after he left Western Piper in Fresno?

A. Yes. He went up to work for IASCO.

Q. And, did you speak to -

JUDGE CAPPS: What is IASCO?

THE WITNESS: I'll have to look that up, too.

JUDGE CAPPS: Is that International --

THE WITNESS: Air Service Corporation.

BY MS. HAUSELT: (Resuming)

Q. And they are affiliated with Japan Airlines?

A. Yes.

Q. And what -- did you speak to anyone at IASCO?

A. Yes. I spoke to a Mr. Scarboro.

Q. And he's the Chief Flight Instructor?

A. Yes, he is.

Q. And, what did he relate were Mr. Campbell's duties at the time?

A. Mr. Campbell was assigned to teaching single engine airplane students,
primary students.

Q. And at anytime was Mr. Campbell involved in operating Boeing 747's or
any other air carrier jets?

A. No, he wasn't.

Q. And Mr. Scarboro's statement is summarized in a letter, Your Honor, on
page 7.  After Mr. Campbell's Medical Certificate was suspended, he then
returned to his home; is that correct? To the best of your knowledge?

A: He returned to Nashua.

Q. Did you receive any information from people in Nashua?

JUDGE CAPPS: Now, is Nashua -- is that New Hampshire?

THE WITNESS: Yes, it is.

BY MS. HAUSELT: (Resuming)

Q. That they had seen Mr. Campbell?

A. Yes. Mr. Campbell had talked to several people who I did get statements
from. Mr. Campbell was at both the campus  of Daniel Webster College and
Nashua Aviation School in a Japan Airlines uniform, and was telling people
that he was either captain or co-pilot. He has used both terms -- on a
Falcon Jet, and was flying from California to Boston to England to Japan,
and he was, at that time, in Boston, overnight at a layover.

Q. And those letters -- are those letters the letters that we find in the
file on pages 11 through 15?

A. Yes, they are.

Q. And did you speak with any of the people who wrote these letters,
personally?

A. Yes, I spoke to two of them.

Q. Who were they?

A. A Robert Swift, who is now the Chief Flight Instructor for Nashua
Aviation.

Q. And Mr. Campbell related to him that he was the captain of a Falcon 20
and the co-pilot on a 747?

A. Yes.

Q. And he was wearing his Japan Airlines uniform?

A. Yes.

Q. Who else did you speak to?

A. I also spoke to a flight instructor there, Don Conlon.

Q. And what did he relate with regard to Mr. Campbell?

A. He said that Mr. Campbell told him he was a captain on a Falcon Jet and
he was going to school to become co-pilot on a 747.

Q. And at that time he was wearing his uniform?

A. Yes, he was.

Q. When you spoke to Mr. Scarboro from IASCO, did he indicate whether or
not Mr. Campbell properly retained his uniform when he left?

A. He never returned the uniform when he left.

Q. But he was asked to return it?

A. Yes, he was asked to return it then, and also afterwards.

Q. And, in fact, on page 8, which is a letter of Mr. Campbell, he indicates
to Mr. Scarboro that he would send the uniform back, did he not?

A. Yes.

MS HAUSELT: Your Honor, I have no further questions.

JUDGE CAPPS: All right, you may cross-examine the witness.

CROSS-EXAMINATION

BY MR. CAMPBELL:

Q. It seems we have quite a bit of material here to cover. I'm going to
have to start, I guess, in order, with the documents presented and as the
information presents itself, as questions occur. Specifically, the first
question I have in reference to your investigation, under what right of
what legal process were you entitled to make this investigation?

A. There was some question as to whether you were able, legally, to hold a
Medical Certificate, and it was our concern and the FAA, when it was
brought up, that you were going to teach two hundred people how to
parachute, whether you had the proper certificate and/or ratings necessary
to do it.

Q. What does the FAA require for parachuting instructor?

A. Nothing, but we do for a rigger.

Q. There is no license, whatsoever, actually required for the instructor of
parachuting?

A. Not by the FAA, no.

Q. Under any legal jurisdiction that you know of, is a parachuting
instructor certificate required?

A. No, not that I know of.

Q. Was it your understanding that I, at one time, had passed an
instructor's certification course and held, at one point, a valid
parachuting instructor's certificate?

A. No, you didn't.

Q. At no time did I hold a valid parachuting instructor's certificate; is
that -

A. There is no such thing.

Q. As issued by the United States Parachute Association.

A. Okay, yes, at one time you did.

Q. And, that -- strike that -- okay, going back to Daniel Webster College,
at that point in time you started investigation by calling some people I
had worked for. I would like to specifically go back to Mr. Brown's letter,
which is rather important. Mr. Brown did state to you that no fire -- I
repeat, no fire had occurred in the home of the young lady I was seeing?

A. What page are you on?

Q. I believe that's 36.

A. That is what Mr. Brown told me last week.

Q. All right. Did Mr. Brown indicate at any time any problems with any
other instructor?

A. No.

Q. And Mr. Brown stated -- what did Mr. Brown state in reference to how I
left employment?

A. He said you were fired.

Q. He said I was fired?

A. Yes.

Q. All right. Did he give any rationale whatsoever for the sudden change in
behavior that he described?

A. No, and I didn't ask him for it either.

Q. Did he, at any time, expound on any other incidents, specifically
involving his daughter?

A. No; I had never heard of that before.

Q. Now, he had stated that he was listening in on the phone during a
conversation with my pastor when, supposedly I was in Alabama; is that
correct?

A. Yes, but he said he did that accidentally, at first.

Q. Accidentally, at first. He made no mention of any other phone calls?

A. No, not to my knowledge. I did not question him very thoroughly.

JUDGE CAPPS: And he did not volunteer any other instance of overhearing
telephone conversations?

THE WITNESS: No, he really didn't volunteer anything. I had to specifically
ask him for everything, as I did with all the witnesses.

BY MR. CAMPBELL (Resuming)

Q. By any chance did you investigate Mr. Brown's background?

A. No, I didn't.

Q. To your knowledge, has Mr. Brown ever had any problems with the Federal
Aviation Administration or any law enforcement agency?

A. As far as -- the only thing that I had asked about Mr. Brown was when I
called the local Federal Aviation office down there, to get a telephone
number for Mr. Brown, and I did ask whether or not he was considered a good
examiner, and they said, yes, we have no problems with him.

Q. I have some questions about the application for employment. I do not
take issue with statements concerning parachute rigging and so forth;
however, I would like to know under what circumstances was this document
reproduced?

A. Under what circumstances?

Q. Who reproduced it and how? I do take exception to something on here that
I know I didn't put down.

A. Steve Rachelson reproduced it while you were there watching him do it,
while you were there for the interview.

Q. I don't recall. Did you see me watching him reproduce this thing?

A. No, I don't remember that. We reproduced your application and your
Pilot's Certificate.

Q. In your conversations with the United States Parachute Association, did
they bring up a letter from Oklahoma from a Mr. Ken Hills in regards to a
rigger problem on a Rigger Certificate?

A. Yes, they did.

Q. Let me ask you something -- what is the -- under what circumstances,
under what FAA jurisdiction, how does the FAA control parachute rigging?
What parachutes are required to be packed, supervised or inspected by a
certified rigger?

A. The FAA -- okay -- a person cannot pack someone else's parachute or his
own reserve emergency chute without a rigger's certificate.

Q: All right

A: You may pack your own, but you cannot pack your own reserve chute.

Q. Let me ask you this -- page 43, 44, 45 -- it is my understanding that
the removal or tampering with any piece of equipment directly covered or
directly controlled by the Federal Aviation Administration is a violation;
is that correct?

A. I don't really know what you're referring to.

Q. This is packing card, a packing data card, called PC

A. On page what?

Q. Page 44 and 45 -- would removal of such a certificate from a pack
reserve constitute a violation?

A. I don't know.

Q. It was my understanding that it is.

Page 44 -- would you please take a look at the owner' name and address and
please state.

A. The owner's name is Jim Campbell. There is no address.

Q. All right. Now, the configuration this is rigged in - let me ask you
this -- I realize that you're expertise not being parachuting, but I'm just
going to have to try this same tack because there's a problem here, and I'd
like to bring it out. In what's called a cutaway rig, a rig containing a
total of three parachutes, only the actual reserve, the one used for
emergency purposes, would be covered by the FAR's; is that correct?

A. No.

Q. What other parachute would be covered?

A. Well, maybe I did not understand your question. It isn't that a reserve
chute is covered by the Regulations. The Regulations deal with what a
person can do and cannot do with or without a certificate.

Q. But that's not the question here. The question - may I expound on this a
little bit?

A. Certainly.

Q. Basically, this -- this rig is part of what's called an intentional
cutaway rig used for air shows, three parachutes. What happened was I
attached an extra set of D rings to the front end of what's called a
piggyback rig, where the main and reserve are in tandem on the back.

MS. HAUSELT: Your Honor, I'll object. Mr. Campbell is not under oath.

JUDGE CAPPS: He's establishing a premise right now to his question that
will be coming up. I think he's trying to make the import of his question
clearer to the witness, and that's why I'm going to allow this premise to
be established in the question.

MS. HAUSELT: The premise.

JUDGE CAPPS: Yes, that's right. I'm not taking that as any sort of
statement.

BY MR. CAMPBELL: (Resuming)

Q. Okay, we're talking about an intentional cutaway rig, specifically
contains three parachutes, two mounted on the back of which construction,
in my opinion and as far as I know, really do not matter, and the actual
emergency parachute being carried on the chest mount. Now, the -- under
the circumstances the main is released, the reserve is deployed, possibly
released, and the third parachute, the chest mount, becomes the actual
reserve. Would it be correct to state that the reserve, the chest mount,
would be the only one that would need to be covered under Federal Aviation
Administration Regulations?

A. I don't believe I have enough knowledge to say yes or no to that
question The only thing that I am going by is what the Regulations say.

JUDGE CAPPS: But the Regulations do say that if you pack another's
parachute or a reserve parachute, it requires the FAA Certificate.

THE WITNESS: Right, it does.

JUDGE CAPPS: So, the import of his question - is one of these three-part
parachutes is characterized as a reserve. Would that require -- even if
it's his own parachute -- the fact that it's a reserve, would that require?

THE WITNESS: Yes, it would.

BY MR. CAMPBELL: (Resuming)

Q. In that case, if I am jumping with three reserve type manufactured
parachutes, all three would require certification and inspection and
packing by a certified rigger?

A. I don't know.

Q. Okay, let me expand a little on the premise The rig was used as an
intentional cutaway rig. The first, the main was a square-type canopy, the
second was a reserve -

MS. HAUSELT: Your Honor, I object. I think that we understand that what
he's saying is he had one main chute and he had one or more "reserve"
chutes. The question is, do those reserve chutes have to be packed by a
parachute rigger. That's a legal question. I have a copy of the
Regulations. I'll look it up, but whether or not Miss Taylor can answer
that detailed a question about how the Regulation is interpreted, I don't
know, and I believe she's indicated that she doesn't. But what the
Regulation says is that you can't pack a reserve chute, and I'll look it
up, but I assume any -- a reserve chute is a reserve chute, whether you
have one or two.

JUDGE CAPPS: Well, the issue before me is really not his qualification for
an FAA Rigger Parachute Certificate. What I am concerned with is this is
one of many instances of certain statements made by the Respondent as to
his qualifications which, in fact, checking with Oklahoma City records
indicates an application was never made for -- that's the only point I have
to decide here. It's not really, technically, what you would need this
thing for anything. She explained that that's how the FAA got involved in
this in the first place. That's all.

MR. CAMPBELL: Okay, well, my premise here is simply that this reserve did
not need a rigger to pack it. I packed it. I signed it, specifically
because it was set up as a reserve and I was curious to see how it would
work. It was also specifically marked as an intentional cutaway rig; this
card was removed at some time. I don't even remember losing it, to be
frank, because I lose them rather easily, and my supposition is this --
that this rig did not need a rigger to be packed.

JUDGE CAPPS: All right, that is not really one of the allegations being
made, that you rigged a parachute in violation of an FAA requirement that
you have a certificate before you did that. The thing that's before me is
that you have stated you were an FAA certified parachute rigger, when, in
fact, you were not. That's all.

MS. HAUSELT: Your Honor, I believe that the card, and I will take this up
on re-direct, there is a question as to whether or not Mr. Campbell did
sign his own reserve chute when he was not qualified to do so, and I'll
bring that up on re-direct.

BY MR. CAMPBELL: (Resuming)

Q. I'm just going to have to leave that because it's rather complex.  46,
47, the newspaper article -- let me ask this  from your point of view or
from the FAA's point of view, as far as you are concerned, what part did
this newspaper article play in the investigation and conclusions on the
part of Dr. Cahill and your report to Dr. Cahill?

MS. HAUSELT: Your Honor, I'll object. She's not qualified to speak. She's
not a medical doctor. She's only here to give what her investigation
revealed. She can't say how this medical determination was made in Mr.
Campbell's case. That's what we have the FAA doctor for.

JUDGE CAPPS: Sustained.

BY MR. CAMPBELL: (Resuming)

Q. Let me ask you this -- what was your impression of the newspaper
article?

A. I'm sorry, I didn't hear the question.

Q. What was your impression of the newspaper article?

A. As with any newspaper article, take it with a grain of salt.

Q. Did you make any attempt to verify any of the statements or speak to
anybody in Oklahoma concerning the article itself?

A. No, I did not. The only person that I talked to about it was you.

Q. Did you speak to Dr. Dorsey at all?

A. No, I never did.

Q. Let's go back a moment. In your conversations with Dr. Schultz, Dr.
Schultz said that one time or another his words were, "instructed for the
Aircraft Owners and Pilots Association Ground School"?

A. Yes, he told me you told him that you worked for the Aircraft Owners and
Pilots Association on those weekend ground school courses.

Q. I had worked on, not taken one?

A. You had taught one.

Q. Okay, I had physically taught one. Was there any verification of that in
the form of a written resume'?

A. From the AOPA?

Q. No, from me to Dr. Schultz, saying, for one thing, for one reason or
another, that I had taught for the Aircraft Owners and Pilots Association?

A. Not that I know of, but I do not know --

Q. In your investigation of the Aircraft Owners and Pilots Associations,
were you able to ascertain whether I had taken any of their clinics?

A. No, I never asked that. That wasn't the issue.

Q. It can be an issue, dismissing the standards.  Now, Dr. Schultz, did he
indicate during the period of time that this was being questioned, during
the time that I was still in the area, did he indicate any desire to
quickly get the matter over with or to resolve the matter in a quiet
disposition or take care of it as -- or on the QT, I guess would be --

A. No, I don't recall him making those statements.

Q. Are you aware of any other problems he's had with any other faculty?

A. Yes.

Q. By any chance, could you repeat what you know of that?

A. Problems that he has with his faculty have been recent problems, the
past six to eight months, with instructors quitting and leaving.

Q. What about any problem where an instructor of the College was let go or
fired?

A. No, I don't know about that.

Q. In your investigation, did you check with -- strike that -- I have an
excuse, not being -- this is difficult - what I'd like to do is just --
we've talked quite a bit of Steve Rachelson, and as a matter of fact, I
think you've known him for quite some time.

A. Yes, he's also a friend of mine.

Q. Yes, he talked about you before.

What was Steve's general attitude toward my employment? At the time he
called me, what was his general attitude toward my employment and his
judgment of the job I had done?

A. He did not say what his opinion of your performance was. The only thing
-

Q. He'd never say that I did a good job, a bad job, mediocre?

A. No, he never did; not that I remember. He was willing to keep you there
until matters could be cleared up.

Q. Okay, about the last thing I have here is -- now, this is going to be
very important, I think -- we have a situation where I was at Nashua in the
past several months, well, actually, going backwards, but several months
after I originally left, and apparently a statement said that I had showed
up in uniform and so forth; what time did this occur? What day?

A. April 18th and 19th, 1980.

Q. April 18th and 19th.

A. Yes.

Q. You're absolutely sure of this? There's no doubt in your mind?

A. No doubt.

Q. Absolutely? All right. And, also, there is a statement from one person
here -

JUDGE CAPPS: April 18 and 19 what year?

THE WITNESS: 1980.

BY MR. CAMPBELL: (Resuming)

Q. Okay, there's a statement here from Richard T. Sweet. Did you speak to
him, specifically?

A. No, I didn't.

Q. If I may repeat it -- " I am writing by request of Robert Smith, who is
my flight instructor, concerning Mr. James Campbell; I'm not sure what the
date was exactly at the time he had been around. In his exact words, he
told me that he flew for Japan Airlines over the route that went from
California to Japan and England. He also said he was in 747 training for
one week a month and that he flew Falcons the other three weeks. Who is
Richard Sweet?

A. I believe he was just a student there.

Q. I don't know the gentleman. That's why I'm asking. Let me ask you who
Jimmy Cotes was?

A. I believe he's also a student. I would have to double check.

JUDGE CAPPS: Did you speak to him?

THE WITNESS: No, I didn't.

JUDGE CAPPS: All right. A student at Nashua or at Daniel Webster?

THE WITNESS: No, Nashua Aviation.

JUDGE CAPPS: And, the same Ray Cote and Sweet?

THE WITNESS: No, all the statements are from Nashua Aviation.

JUDGE CAPPS: Okay.

MR. CAMPBELL: I have a question for the Judge.  Do I have a right to
question Miss Taylor in the future or is this my only opportunity?

JUDGE CAPPS: Well, this is your only opportunity to question her, unless
there is re-direct, and then you'd have a chance at re-cross.

MR. CAMPBELL: I see.

JUDGE CAPPS: Do you want to recess to enable you to look through some of
that stuff and get your thoughts in mind?

MR. CAMPBELL: I was not aware that Miss Taylor would be here. The
possibility apparently had existed, although some doubt was cast on that.

JUDGE CAPPS: Do you want a ten-minute recess to --

MR. CAMPBELL: I'd appreciate five or ten minutes. I really would.

JUDGE CAPPS: All right, we'll take a ten-minute

(Whereupon, a ten-minute recess was taken.)

JUDGE CAPPS: You may continue your cross-examination.

MR. CAMPBELL: Thank you very much.

BY MR. CAMPBELL: (Resuming)

Q. In reference to your conversations with Western Piper personnel,
specifically the bookkeeper and whatever knowledge you may have concerning
Mrs. Stuart, number one, the bookkeeper who rendered various opinions, for
instance, by any chance is she a psychologist or a psychiatrist?

A. Not that I know of.

Q. Does she have any type of medical training which would enable her to
make such a judgment?

A. No, not that I know.

Q. What about Mrs. Stuart?

A. Not that I know.

Q. By any chance, did Western Piper indicate to you any of the problems I
had with them concerning their maintenance procedures?

A. No.

Q. Now, specifically the statement from Mrs. Stuart concerning a landing
that I had to make in a Tomahawk on a highway during a period of inclement
weather in November last year, in fact, about this time last year if I
remember correctly. There is a statement here that said that -- just a
moment and I'll read it back -- "Mr. Campbell arrived at that location by
ferrying a Tomahawk from our factory in Pennsylvania, which provided him
with free transportation from his home on the East Coast to our place of
business in central California. Then inflight a sort of emergency arose,
forcing him to set the aircraft down on a Maryland interstate highway.
Investigation by the FAA and the aircraft factory representatives could
find no cause for the incident." Are you aware of any investigation?

A. No, just what I read here.

Q. Would any investigation of this nature be brought to your attention?

A. No, there's no reason for it to be.

Q. Would something like this be easily verified?

A. No, it would be very difficult to verify it.

Q. All right. Okay. She also stated, producing newspaper articles and
photos, - Well, In reference to World Trade Center escapade; I guess that's
the best word for it -- "Producing newspaper articles and photos to back up
his claim". Specifically, the only newspaper articles I'm aware of were
published in this area. Did she state anything about the content of those
newspaper articles?

A. No, she didn't. You are referring to Mrs. Stuart?

Q. Mrs. Stuart, that's right.

A. I did not talk to Mrs. Stuart, personally.

Q. Okay. In your conversation with the bookkeeper, was any reference made
to any such article?

A. No, this was never brought up at all.

Q. Okay.

A. Oh, I'm sorry, yes, it was.

Q. All right. Specifically what?

A. She had told me that you did tell her and others that you did parachute
off the World Trade Center.

Q. All right. Did she mention anything about producing newspaper articles
and so forth?

A. No, it wasn't mentioned.

Q. In reference to the International Air Service Company, and I take a
great deal of interest in this, for two reasons. One, because I hope to
resume employment there someday, which may or may not be possible.
Exactly, during your request of information from the International Air
Service Company, what information did you give them concerning my
situation?

A. Are you referring to a page in particular?

Q. There is a letter from the International Air Service Company, right
here, page 7, and here is some other documentation that goes with it, from
Ed Scarboro concerning my employment with the International Air Service
Company, my responsibilities and my performance. In order to get this
information, I'm sure you had to make a request. What information was given
to Mr. Scarboro during this request?

A. I did not make the request for this particular letter.

MS. HAUSELT: Your Honor, I would state for the record that I made the
request and I made the initial contact with Mr. Scarboro.

JUDGE CAPPS: Yes, the letter is addressed to Ms. Hauselt.

MR. CAMPBELL: My mistake, I'm sorry.

BY MR. CAMPBELL: (Resuming)

Q. In other words, you had nothing to do with the International Air Service
Company, then?

A. Yes, I did.

Q. You did? Did he characterize my performance during my brief time at
International Air Service Company?

A. Yes, he did.

Q. Specifically what did he say?

A. He said you a very good employee.

MS. HAUSELT: Your Honor, I would state that I would object. This is
irrelevant. We do not claim that Mr. Campbell is not a technically
qualified pilot. What we were after is his judgment that goes to his
personality.

JUDGE CAPPS: Well, she has testified, though, about conversations -- a
conversation with Mr. Scarboro, so I'm going to allow him to go into this.
I think you were in the process of his characterization of the Respondent's
performance while he was employed by International Air Service Company, and
what was that characterization?

THE WITNESS: Mr. Scarboro had no problems with Mr. Campbell. He said he was
a very good employee, and a good pilot.

MR. CAMPBELL: Thank you.

BY MR. CAMPBELL: (Resuming)

Q. Just for a point I'll be bringing up later, could you please tell me
protocol involved in the seizure of that Medical Certificate?

A. Say that again.

Q. What is the protocol involved in the seizure of the Certificate?

A. I couldn't answer that. I don't know.

Q. Going back to Mr. Brown -- did you make any attempt to verify any of the
statements in that letter, specifically did you check with the young lady
involved concerning her situation and her plight?

A. No, I didn't.

Q. And, in reference to a statement by the United States Parachute
Association, did they or did they not state that they suspended my
instructor privileges in relation to the United States Parachute
Association?

A. All they said was you had been suspended from the U.S.P.A. by them.

Q. I had been suspended from the U.S.P.A.?

A. Yes.

Q. When did they say they did this? This is very important.

A. I talked to them last week.

Q. Okay. Did they specifically say when they had done that?

A. No, they did not.

Q. And, just as a point here -- Miss Taylor has some qualifications that
will be of use to me, a great deal, and I have a question which has nothing
to do with the testimony. It's an aircraft problem. I would like, if
possible, for her to venture an opinion.

JUDGE CAPPS: Off the record.

(Whereupon, an off the record discussion was held.)

JUDGE CAPPS: Back on the record.

BY MR. CAMPBELL: (Resuming)

Q. Western Piper made statements concerning some problems with aircraft
when they were not able to find "problems". In reference to one of those
problems which involved a Seminole, let me ask you, in your opinion what
would be the result -- the Seminole -- this was a '79 Mott Turbo -- it's
not fuel injected or anything to that extent, with an overly rich engine in
combination with intermittent carb heat control which kept the carburetor
heat on -- could that or couldn't that not result in a very rough engine?

A. Yes, it could.

MR. CAMPBELL: Thank you very much. That's all I have to ask.

JUDGE CAPPS: Any re-direct?

MS. HAUSELT: Yes, Your Honor.

RE-DIRECT EXAMINATION BY MS. HAUSELT:

Q. When you spoke to Mr. King of the U.S. Parachute Association, did he
indicate whether or not Mr. Campbell was using the U.S.P.A. name?

A. Yes, he said he was.

Q. And, at the time he was using that name, was he current?

A. No, he was not.

Q. I want to refer you to page 43, 44 and 45. This is the parachute log of
Mr. Campbell that was forwarded to the FAA by Mr. Hill, who is the
President, I believe, of a parachute group out in Talequa, Oklahoma.
Specifically, you're referring to page 45 -- did Mr. Campbell sign for his
reserve chute on page 45?

A. Yes, he did.

Q. And, the column marked, "remarks" -- it says emergency there?

A. Yes, it does.

Q. Now, under the heading of "Single" there is the initials JRC and also
JRC again. Of what significance would those be in ascertaining whether or
not Mr. Campbell was qualified?

A. The symbol was a three letter identification symbol. Whether it is
issued by the FAA or the U.S.P.A. I cannot remember. However

Q. It's FAA.

A. It's FAA, okay -- however, checking with the U S P A. and also a
parachute rigger in my office, I have learned that the three letter symbol
is never the person's own initials.

Q. So, in this case we have a card indicating that Mr. Campbell signed his
own emergency chute?

A. Yes.

Q. And he did not have a parachute rigger's certificate from the FAA which
would be necessary to do so at that time?

A. Correct.

Q. With regard to the article printed in the Tulsa Tribune, as appears on
pages 46 and 47, did you ever speak to anyone from the Tulsa Tribune about
that article?

A. Yes, I did. I spoke to the City Editor.

Q. And did they verify that the article was published in their paper?

A. Yes, they did.

Q. At the time you spoke to Mr. Campbell in your interview with him, did he
indicate to you that he had taken any action against the Tulsa Tribune?

A. Yes, he did.

Q. What did he say?

A. He said he currently had a lawsuit against the Tulsa Tribune.

Q. And, from the letter of Dr. Schultz; He apparently told the same thing
to Dr. Schultz, is that correct?

A. Yes

Q. And when you spoke to the City Editor, did he indicate whether not Mr.
Campbell had ever filed an official lawsuit?

A. Yes, he said Mr. Campbell never did.

MS. HAUSELT: I have no further questions.

JUDGE CAPPS: Do you have any re-cross?

MR. CAMPBELL: Yes.

JUDGE CAPPS: Just limit it to her -

MR. CAMPBELL: Yes, just limit it to her re-direct.

JUDGE CAPPS: -- redirect, all right.

RE-CROSS EXAMINATION BY MR. CAMPBELL:

Q. With reference to the United States Parachute Association, they stated
that I was using their name. Now, did they say in what fashion and what
occasions did I use them?

A. They did not say what occasions. They said using their name in saying
that you were a U.S.P.A. parachute instructor.

Q. Did they say U.S.P.A. parachute instructor or U.S.P.A. certified
parachute instructor

A. Well, I don't remember that.

Q. All right. And, in reference to the Tulsa Tribune

JUDGE CAPPS: You don't remember that -- it could have been either way that
they stated it?

MISS TAYLOR: Yes, it could've been either way.

JUDGE CAPPS: All right.

BY MR. CAMPBELL: (Resuming)

Q. In reference to the Tulsa Tribune, first of all, did they state where
they got their information?

A. No, they didn't.

Q. And, the City Editor stated that he had no knowledge of any legal
action?

A. Right, he said -

Q. Specifically, he did not speak of a phone call between my father's
attorney and the Tulsa Tribune?

A. No, he did not. The only thing he did say was that you, yourself, called
and said that you were going to sue them, but it never happened.

Q. I called them?

A. Yes.

MR. CAMPBELL: That's the last of my questions.

JUDGE CAPPS: You may call your next witness.

MS. HAUSELT: The Administrator will call Dr. Thomas Powers.

Whereupon,

                 THOMAS ROBERT POWERS having been first duly sworn by
the Administrative Law Judge, was examined and testified as follows:

                  DIRECT EXAMINATION BY MS. HAUSELT:

Q. Would you state your name, for the record?

A. My name is Thomas Robert Powers.

Q. And what is your business address?

A. I have - my principal business is now at 680 Bancroft in San Leandro. I
have an office also at 350 Parnassas in San Francisco.

Q. What is your occupation?

A. I am a psychiatrist.

Q. Could you briefly summarize what your education was in the medical
field?

A. I had taken my undergraduate and medical school training at Northwestern
University in Evanston and in Chicago, Illinois. I graduated in 1966.
Following that I did an internship in straight medicine at the Northwestern
University Medical School at various hospitals. After that period of time,
I was taken into the United States Public Health Service where I was
detailed to the Peace Corps. I served for two years in Malowi which is in
Africa doing volunteer help and public health work for that country. I then
returned to spend about a year and a half as the Chief Medical Officer of
the Peace Corps program in Washington, DC During that time I did some
volunteer work as a physician with the Georgetown Free Clinic. On leaving
Washington I went to a small town in Colorado where I was in general
practice, setting up a private health clinic. Following that I went to
California where I entered the University of California residency in
psychiatry at London Quarter which is in San Francisco. During that time,
also, I obtained a masters degree in public health from the University of
California School of Public Health at Berkeley.

Since that time I've been engaged in the practice of psychiatry. For the
first three years I was in a part-time private practice. I was between
three-fourths and two-thirds time a faculty member at the University of
California Medical School in the Department of Psychiatry. Since that time
I functioned as a faculty member for about three years, then went into
full-time private practice of psychiatry and I've been in full-time private
practice of psychiatry since that time. Presently I continue to maintain a
faculty position at the University of California Medical Center in San
Francisco, where I'm an Assistant Clinical Professor. I'm also presently
Chief of Psychiatry at Eden Hospital in Casper Valley, California.

Q. And you still have a private practice?

A. Yes, and also full-time private practice.

Q. And are you Board certified in any others?

A. I'm Board certified in psychiatry.

Q. Did you ever meet Mr. Campbell?

A. Yes. I met Mr. Campbell on the occasion of his coming to my office after
he had scheduled an appointment to be seen at the request of the FAA. That
was in March 1980 and I believe the specific date was the 3rd. No, I'm
sorry - March 7th, 1980.

Q. Okay, before we get into the substance of your interview with Mr.
Campbell, I want to ask you a few preliminary questions. Could you briefly
explain as best you can, in layman's terms, what is meant by a personality
disorder?

A. Yes, well, I think, first of all, it would be important to define what
is meant by personality because we have a general understanding of
personality which we're all, more or less, familiar with. But, then there's
the more specific definition of personality that we use in clinical
psychiatry. Personality is that complex of deeply ingrained patterns of
behavior which include the way that one perceives and thinks about the
entire outside world and one's environment and oneself.  Then, there are
also personality traits, and these are the more prominent aspects of
personality, and do not in themselves imply any kind of psychopathology.
We all have personality traits that are identifiable.

Personality disorder, however, implies an inflexible and maladaptive
pattern or patterns of sufficient severity because significant impairment
in adaptive functioning or subjective distress on the part of the
individual, and it's only when the personality traits become so rigid and
maladaptive as to cause significant impairment in social or occupational
functioning that is adaptive functioning, that they can be considered to
constitute a personality disorder.

Q. Okay. As a result of your interview with Mr. Campbell, did you come to a
conclusion as to whether or not he suffered from a personality disorder?

A. I did.

Q. And -

A. And, he does have a personality disorder.

Q. I'd like to refer Your Honor to pages 48 through 53 which is Dr. Powers
report of his interview with Mr. Campbell, and I would like to ask Dr.
Powers to relate, in his own words, the substance of his interview with Mr.
Campbell, pointing out what occurred which was of clinical significance to
him in the course of the interview.

A. As I indicated, Mr. Campbell was seen in my office in San Francisco on
March 7th. He was seen for an extended period of time, which was necessary
to do a reasonable job of thorough or complete psychiatric evaluation. We
had to pause about midway through the session. We were there about two and
a half hours. During that time it was my objective to obtain as complete a
psychiatric history, including family history, history of childhood, early
development, occupational history, mental history and so forth, as well as
history of the immediate problem for which he was seeking this evaluation.
During that time, also, I collected information pertaining to his own
personal psychiatric history, medical history and also did a mental status
examination. Now, let me just review, I think, the essentials of that exam
so that I can convey to the Court what my impression was at the time. He
came in for the appointment He was on time.

JUDGE CAPPS: Wait, let me -- before you go into that -- how many times did
you see him?

THE WITNESS: I saw him on one occasion, on day only.

JUDGE CAPPS: Just this one time?

THE WITNESS: One time only for approximately two and a half hours.

JUDGE CAPPS: all right, go ahead.

THE WITNESS: Mr. Campbell identified himself as a twenty-three year old
single Caucasian male who was presently employed as a private flight
instructor for the International Air Service Company in Nappa, California,
Japan Airlines Flight Department. He indicated that he was seeing me at
the request of the FAA because he had received an emergency Order of
Suspension of his second class Airman's Certificate, and that that had
previously been granted by the FAA.

JUDGE CAPPS: Let me interrupt here. Isn't it an Order of Revocation?

MS. HAUSELT: Originally there was an Order of Suspension which required
further information because Mr. Campbell could not provide medical
information. Then, once he submitted to the interview and more data was
obtained, it was subsequent that the Order of Revocation was issued.

JUDGE CAPPS: All right, that is what is before me now, the Order of
Revocation.

MS. HAUSELT: That's correct.

JUDGE CAPPS: All right, continue, doctor.

THE WITNESS: Mr. Campbell described his present problem as dating back,
approximately a year and a half prior to that time. He stated at that time,
"I had a problem which I dealt with in a socially unacceptable manner." He
then gave extensive background for that event. He also gave a family
history and indicating he was the oldest member of a large family from the
metropolitan New York City area. He described himself, his early childhood
as being a socially isolated student in high school and at that time
becoming interested in flying, largely through participating in the
Aviation Explorers. It was in that connection in the summer of '72, he
attended a meeting of that organization at which he met a young girl,
Ellen, to whom he became romantically attached.

Now, on completing high school, he decided to move to Colorado to pursue
this relationship with the girlfriend and to attempt to find work. He did
so. He found a job working as a Jack-of-all-trades in an airport in
Colorado, and then developed a working relationship with a Rocky Mountain
Para-center as an instructor and demonstrator of parachutes. He described
the relationship with the girlfriend in some detail, in particular that it
was very close, they were very much in love and that this was an extremely
important relationship to him; in fact, had been the most serious
relationship in his life up to that time. He also described that the
relationship ended rather abruptly in June of '76 which Mr. Campbell
attributed primarily to interpersonal problems between himself and the
girl's father, and of that broken relationship he said at that time, "I
was frankly shattered. To this day I don't understand what happened.
At that time he returned home to live with his parents, continued his
parachute jumping, was trying to save money to go to flight school, did
some odd jobs in electronics and security work and line work at an airport.

He states that during this period of time he was emotionally upset, largely
due, he felt, to the breakup of his romance and the unexpected deaths of
several friends who were killed while skydiving. And, during that time he
began to date a female student at the Naval Academy, whom he states was
killed in a motorcycle accident while home on leave in Texas. Another
friend was lost about that time in a hang gliding accident. He states that
at this time he was quite depressed, began talking with his own mother
about dying, but strongly denied any suicidal ideation at this time. He
also denied hallucinations, unusual thoughts, excessive use of alcohol or
any drugs. Then, a short time later he became a job prospect at Talakoff,
Oklahoma, which offered him the opportunity to fly and work as an
instructor. During that time he describes a very active social life with
much dating and partying and an abundance of female companionship. He did
not chemical abuse at that time or at any other time, except occasional
beers and that being on social occasions.

At about that time he decided to visit his girlfriend back in Colorado and
he described driving, I think, straight through overnight to visit this
girlfriend, and he was quite shocked and dismayed to find that she had
undergone what he estimated as being a personality change and that her
opinions had become quite negative towards him; she was very bitter and
really was a quite different person, and this left him feeling very bad.

Next, he decided to move to Tulsa, Oklahoma, feeling, again, very depressed
and guilty for everything that had happened to Ellen and in this
relationship, and then he said that after moving to Tulsa, in an attempt to
deal with these, he had increasing feelings of social isolation. He stated
he began to feel a closer identification with his grandfather who is a M.D.
That's when the masquerade thing started, and that's a direct quote. Mr.
Campbell said that at that time, "I first began to describe myself as a
medical student. Then I was a resident, and then, finally, I was Dr.
Campbell. I had a coat and an I.D. tag that I got from my grandfather's
clinic, and I just did it to get social recognition. I really didn't think
about it."

In explaining this masquerade, Mr. Campbell stated that, "My grandfather
has been my ultimate model in life. He's been a G.P. for many years. He
goes down to the Caribbean one weekend a month, or did so in the past, to
take care of poor people. I wanted to be like my grandfather, and then the
whole thing blew up in my face. Two weeks later it got published in the
papers, but the article was full of a lot of garbage." By this I think he
meant that the statements in the article were untrue. "I then went home,
and my grandfather referred me to Dr. Dorsey, a psychiatrist. From January
to April of that year I went to see Dr. Dorsey." Mr. Campbell feels that he
made considerable progress in therapy during that time, resolving whatever
psychiatric problems he had.

Next he found employment in Georgia with a charter airlines, which he
described as a shaky operation. Initially he was quite enthusiastic about
this job and the man he worked for, whom he referred to as "Jim".  After a
few months, though, because he suddenly changed his feelings about this man
and his flight school or the airlines, he quit the job and then went to New
England to take another position at a flight school as an instructor in
meteorology and instrument ground school. At that point he stated he was
feeling very good. "I was ecstatic", he said, and I quote. "I flew forty
nine point seven hours in one week. I felt very much in control of things.
Then one day this article hit the campus, and to quote an old expression,
the fit hit the shan." He then went on to describe a situation in which he
was the center of a turmoil, apparently about whether or not he should be
suspended, fired or some other official action taken.

Specifically, at that time, his adequacy as a teacher was in question. He
stated that, "Some of my methods may have been a bit theatrical, but then
when some of these hundreds of articles hit the campus, there was an
attempt to get rid of me. The President of the college was running for
governor that year. Then the FAA got ahold of it, and that's why I'm here
now." The patient, at that time, apparently was instructed by the FAA
Regional Office to supply additional medical information. Mr. Campbell
states he complied with this order, however, "The information wasn't what
they wanted. Of course, they didn't bother to tell me that."

Mr. Campbell then went on to indicate that the above described events were,
in his estimation, the only reason that his Medical Certificate had been
called to closer scrutiny by the FAA. However, on closer questioning, and
this was in the later part of the interview, just in kind of going through
the review of systems and hitting on some points that I thought I wanted to
have, for sure, clarified, in asking him about a history of arrests, he
suddenly recalled that he had omitted mentioning an event which, on
reconsideration, he thought would perhaps be of some significance. While
this appeared at the time to be a blatant prevarication, he apologetically
indicated that he simply forgot to mention the item as he didn't think it
would be of much consequence. He then described the event for which he was
arrested in New York City on November -- in November of 1977, for
attempting to jump off the World Trade Center Building in downtown
Manhattan with a parachute. He attempted to downplay the event as simply a
technical challenge, but he then went on to quickly explain how he had
spent six months researching the project and had written several hundred
pages of notes and had also surveyed the site by having friends flying
around the tower in a helicopter and dropping smoke bombs to assess the
wind directions and currents.

He attempted to further explain his own reasons for attempting this jump by
stating that a friend of his, by the name of Owen, whom he referred to as a
hero, had successfully jumped from the other of the two towers of the World
Trade Center. He stated further, he was going to be a real big gag, and
that's a quote. Continuing his quotation, "I was looking for a peak
experience. When I landed, I was going to disappear and leave a note, 'The
phantom of the World Trade Center was here'." He stated he was apprehended
by the security police at the top of the building just as he was about to
jump. He stated he was then charged with trespassing, resisting arrest and
disorderly conduct. He was taken to the police station, booked and held in
a jail cell. He went on, in quotation, "I got stuck in this clink with a
group of homosexuals, murderers and petty thieves. One transvestite said,
"and parenthetically he added, "And this was really funny; see that guy
there -- he's crazy, he tried to jump off the World Trade Center building."
Mr. Campbell indicated that these charges were later dropped.

When I asked him about the comment that his cellmate had made, whether he
thought that this behavior might seem crazy, he responded by saying, "It
wasn't crazy; it was just against the law." He went on to say that, you
know, he had this whole thing carefully planned; he was going to do a five
second delay, which would give him plenty of time to get clear of the
building and get his chute open, and he went on then to describe in his own
terms, similar events that had been attempted by various dare devils. For
example, a man by the name of Philip Critique who he said had walked across
between the two towers on a tight wire in 1974. Mr. Campbell said to me at
the time, "Now, he's crazy." Then he said, "There was a guy who climbed up
the side of the building with some devices which he designed which worked
very well. He wasn't crazy."  I just point this out to the Court because
I'll refer back to this later on.

In getting a more complete past psychiatric history, Mr. Campbell stated
that he had seen a psychiatrist, a Dr. Dorsey, in early 1979, which I had
referred to earlier, after he returned from Oklahoma to his home in New
Jersey. In addition, I had a copy of a letter at that time, from the FAA
which indicated that Mr. Campbell had been treated with psychotherapy from
January to May of 1979 and that, basically, what was indicated in that
letter was a bare bones description of a personality disorder.

BY MS HAUSELT: (Resuming)

Q. Excuse me, doctor, that was in the letter of Dr. Dorsey which appears in
the file?

A. Yes; I'll refer back to that also later on.

JUDGE CAPPS: What number is that; page number?

MS. HAUSELT: That would be page 54, Your Honor.

THE WITNESS: In addition, there was some history of a possible subdural
hematoma which was some significance and importance to evaluate. That had
been sustained while parachute jumping. At the time Mr. Campbell indicated
that he was rendered unconscious and taken to a hospital and that there was
a pretty thorough evaluation of that injury and no indication at the time
of any brain damage of consequence.

He, also, in giving a history of whom he had seen, for whatever reasons
psychiatrically, indicated he had seen a psychiatrist and a psychologist
recently, a Dr. McKnight, who is a psychiatrist, and a Richard Landine, who
is a psychologist, for psychiatric and psychological evaluation. Past
medical history at that time, Mr. Campbell stated that he had had a
diagnosis of duodenal ulcer and it became irritative, for which he was
hospitalized when he was in the fourth grade. He also stated that he had
sustained a broken nose approximately five years ago, and he referred again
to the head injury which took place in '76, and he said that at that time
he could not recall any other illnesses or injuries.

Asking about medications, Mr. Campbell told me that he occasionally takes
Chlortrimeton which is an antihistamine, for a problem with his nose which
had developed subsequent to the time of his fracture which he sustained in
high school.

Asking about personal habits, Mr. Campbell indicated that he does not use
any type of street drugs; his alcohol use was described as limited to two
or three beers a week, and that he'd only been intoxicated once in his
life.

Asking about social, educational and military history, Mr. Campbell
indicated that the only other time he had been arrested or cited for
traffic regulations was six years ago when he received a speeding ticket.
His formal education included completion of high school, as well as some
considerable training in flying and parachuting skills. Mr. Campbell
indicated he spent time in the Air Force, about which a detailed history
was not obtained.

Under personal habits he mentioned sky diving and scuba diving.

Family history, he gave some more details there, indicating both his
parents were forty-five years old and had been in good health. His father
is a representative for a pharmaceutical company, and he said his mother's
pursuing a Ph.D. in psychology. He indicated he had six siblings ranging in
age from twenty-one to ten years of age, all of whom he thought to be in a
good state of physical health and he told me one of the siblings had had
any kind of psychological history and had been seeing a child psychologist,
so basically there was no family history of any kind of mental illness.

Developmental history was taken, and he indicated he was a product of a
normal pregnancy and delivery and that there were no particular problems in
his early childhood or during the school years, with the exception that in
high school he had some problems with his father. He described a pretty
much normal sexual developmental history.

In the review of central nervous system symptoms, which is always relevant
to a psychiatric history, Mr. Campbell indicated that he was sleeping
normally; he had had no fluctuations in weight; and his sex drive was
normal, and he had no particular problems of a sensory nature or anything
that might suggest a, either an organic brain problem or a psychosis.

Mental status examination -- this is gathered throughout the entire course
of the interview and also by asking whatever necessary specific questions.
Mr. Campbell presented himself in an outgoing, and I think, grandiose
manner, with a kind of quality of seriousness that he was in a lot of
difficulty, he wanted very much for me to understand and believe him, and I
felt, initially, that I really should believe him, but then, and that I
wanted to believe him, but then, as the interview went on I began to
question myself, and I found myself asking, well, just why is it that you
feel you want to believe this man. That question continued in one corner of
my mind as we went along. There was only minimal anxiety noted in the
course of the exam, which was somewhat discrepant with the circumstances.
His vocabulary was average. His speech, on one or two occasions, seemed to
me to be pressured.

JUDGE CAPPS: What do you mean by pressured?

THE WITNESS: Well, that means that he was really intent upon getting a
point across, so much so that it was hard to interrupt his flow of speech,
and that's an important clinical sign when we're looking for certain types
of feeling disorders.

JUDGE CAPPS: But does it show compulsion or something on that part, or what
does it signify to you, as a psychiatrist?

THE WITNESS: It shows that a certain possibility of an affective disorder
or, also, a number of other things, but the particular significance is that
it sometimes, and, in fact, typically is frequent in the presence of
affective disorder, which is a primary disorder of mood. There was,
however, no looseness of associations; no blocking or idiosyncratic
thinking present. He denied hallucinations, and there was no delusional
material present at the time of this examination.

His recent and remote memory were intact. He was oriented in three spheres;
able to extract appropriately in the ordinary context of conversation. His
defense mechanisms employed included excessive use of denial and
rationalization, the mood although somewhat anxious

MS HAUSELT: Could I just stop you for a second?

BY MS. HAUSELT: (Resuming)

Q. When you make comments concerning delusional material, hallucinations,
in that part of your exam, what type of disorder are you focusing on, when
you discuss that?

A. Well, here, again, would be an effort to confirm the presence at that
time or historically of a psychotic process. As I say, he employed defense
mechanisms extensively, particularly excessive use of denial and
rationalization. The mood, although somewhat anxious, the affect was fairly
mobile, however, at times depressed.

At one point he became outwardly angry and furious, demanding, and this was
near the end of the exam, that the examiner was supposed to phone the FAA
to give an oral report to the physician who'd requested this evaluation.
When I pointed out that the hour was late -- it was just a few minutes to
five o'clock, he stated that he had in his possession a notarized statement
from a Congressional aide who had assured him that immediate action would
be taken following completion of my evaluation. When I asked him to produce
the document, he just kind of suddenly shifted the topic and quickly
cooling his rage, and implying that, well, he had enlisted the support of
the offices of several Congressmen or two Congressmen in the area and a
Senator, and that they had promised him that they would help him obtain a
speedy resolution of this bureaucratic snafu which had caused his Medical
Certificate to be suspended.

Q. So he never produced the notarized statement from this party?

A. No, he did not. It was my observation that his insight was markedly
impaired and that his judgment was extremely limited. Well, basically,
then, my diagnosis was that of a personality disorder, a mixed type with
predominantly narcissistic and borderline features and I thought it also
important to consider a bit further, perhaps, the possibility of a primary
affective disorder which I had mentioned before.

Q. Let's just stop right there a minute. At this time I'd like to have
marked a copy of - Doctor, let me first ask you -- your diagnosis is based
on criteria set forth in the DSM-3; is it not?

A. Yes.

Q. And what is a DSM-3?

A. Well, a DSM-3 is the most recent edition of the official diagnostic and
statistical nomenclature for psychiatric diagnosis that is published by the
American Psychiatric Association and it's the official nomenclature or
diagnostic nomenclature that's in use in the clinical practice of
psychiatry in this country today. The DSM-3 just came out; it's a further
refinement of DSM-2, but basically it's the same nomenclature and there are
only minor differences between the two.

MS HAUSELT: Okay, Your Honor, at this time I would have marked as
Administrator's Exhibit Number 2 pertinent pages from DSM-3 for the
criteria as set forth for a mixed personality disorder with borderline and
narcissistic features, and offer that into evidence. I have a copy for Mr.
Campbell.

JUDGE CAPPS: All right, I'll note that -- I'm familiar with this
publication from other cases I've heard. It is received in evidence as
Exhibit A2.

(Whereupon, the document described was marked for identification as
Administrator's Exhibit A-2, and received in evidence.)

MS. HAUSELT: Your Honor, excuse me for a minute - we're looking for a copy
so that Dr. Powers can refer to it.

THE WITNESS: I think I have a copy here. I've got the most relevant
materials here in my notes.

BY MS HAUSELT: (Resuming)

Q. Could you explain what is meant by the term mixed personality disorder?

A. Well, the nomenclature is such that in this area there's quite a
likelihood, in fact, even a probability that you will have overlap or, in
some cases, a mixture of the criteria for the various categories of
personality disorder, and the protocol there calls for making a diagnosis
of a mixed - personality disorder of a mixed type when you have significant
number of elements from more than one category. So that means that there's
some overlap, and it should be individual shared features from more than
one category of personality disorder.

JUDGE CAPPS: Which categories, in his case, were mixed, in your opinion?

THE WITNESS: Well, this was, as I pointed out, mixed narcissistic and
borderline type. I'll elaborate on what those are

JUDGE CAPPS: So you were unable to diagnose this as a narcissistic
personality disorder, as opposed to any other type such as borderline and
vice versa?

THE WITNESS: No, actually he meets the criteria for both narcissistic and
borderline.

JUDGE CAPPS: All right.

THE WITNESS: And, then he also, you know, he has features from some of the
other categories too, but it's predominantly narcissistic and borderline

BY MS HAUSELT: (Resuming)

Q. Can either one of those, in the hypothetical type of question -- if a
person met all of the criteria for narcissistic then that person would be
diagnosed as having a personality disorder, had a psychiatrist interviewed
them and gone through the proper consultation that is here?

A. That is correct.

Q. And the same would be true for borderline?

A. That's correct.

Q. What are the features of the narcissistic personality?

A. Well, the essential feature is a personality disorder in which there is
a grandiose sense of self-importance or uniqueness, a kind of special
quality that this person perceives about himself. It's a very special
quality. There's a preoccupation with fantasies of unlimited success and
there is an exhibitionistic need for a constant attention and admiration
and the behavior of an individual is driven to that end, obtaining this
kind of attention and admiration. There are characteristic responses to
threats to that individual's self esteem and characteristic disturbances in
interpersonal relationships. These might be feelings of entitlement or
deserving, you know, special consideration because, after all, this is a
unique set of circumstances which just, you know, really hasn't happened
before; this is the kind of approach that the individual might take. There
would be a tendency for exploiting interpersonal relationships, and also
relationships would be characterized as being really kind of split, and
that is that initially the individual would overly idealize the other, the
person in the relationship, and then at some point there would be a sudden
reversal, and at this point the relationship would turn completely around
and probably not be able to continue, and that there's a particular kind
of, well, persistent and pervasive lack of empathy on the part of the
individual with this type of personality disorder, and by that I mean, it's
as if he doesn't or she doesn't realize that other people have feelings and
what those feelings are, or that others have rights or that others have
their own personal integrity which has to be expected.

Q. What are the traits of a borderline personality disorder?

A. Well, they are quite similar, and I would indicate just briefly that
they are fewer in number, but they encompass some of the same features that
I've already discussed. Essentially what happens in borderline personality
is that this is a, I think, less healthy or less well developed type of
personality, and that there's instability in a variety of areas which
include interpersonal relationships and behaviors, mood, self image.
There's no single feature that you can say is invariably present in a
borderline personality, but it does generally tend to include one aspect
which is that of transient psychotic episodes. At that time there may be
brief loss of contact with reality. Also, more mood fluctuation than say in
a narcissistic personality disorder, where you may have depression lasting
for longer periods of time than say, just a few hours or a few days. In the
borderline type of individual this may go on for longer periods of time,
but usually not for months as we see in a depressive state.

Q. Dr. Powers, is it uncommon or common for a person to have a mixed or --
when a person has a personality disorder, to have a mixture of traits?

A. Yes, it's very common. In fact, I think it's, you know, close to half
the time one finds a mixture of personality traits rather than a pure,
well, a diagnosis that you could fit exactly to one of the individual
categories. After all, you know, we're talking about something that's
extremely complex which is human behavior and human psychology, and you
know, each of us are individuals and it's very difficult to describe an
individual or diagnose an individual in terms of just a category which is
defined as a constellation of characteristics. So, that, really, I think
that almost the rule is that there will be a mixture of elements from one
or more of the categories of personality disorder.

Q. Okay. You listed on your diagnostic impression on page 53, number 2,
rule out primary affective disorder bipolar-type; could you explain what
that means?

JUDGE CAPPS: We have to change the tape.

THE WITNESS: Could you repeat that question.

BY MS. HAUSELT: (Resuming)

Q. On page 53 of your report in your diagnostic impressions, you listed
under number 2, rule out primary affective disorder bipolar type; what is
that and how does it relate to Mr. Campbell?

A. Yes, that specifically is the most severe type of disorder, and it's
characterized by periods of very high ion, or as we say, manic periods, and
also by periods of re depression, and that's the so-called bipolar, both -
you know, the upswing and the downswing of the mood to the extremes of the
spectrum.

JUDGE CAPPS: Just peaks and valleys all the time?

THE WITNESS: Well, not just peaks and valleys. I think we all tend to
experience emotional peaks and valleys. I'm talking about displacement of
the mood to the extreme, which at the high end of the spectrum means acute
mania, which most oftentimes a psychotic manifestation. An individual
speaks with pressure, rapidly, is very -- is likely to be very convincing,
may be able to be very successful in sales or in other type of endeavor at
that time. And, at the other extreme is depressed to the extent that
usually one has to be concerned about a psychosis at that end of the
spectrum where there is a pervasive feeling of worthlessness, hopelessness,
and oftentimes suicidal ideation and intent.

JUDGE CAPPS: But you ruled these out in his case?

THE WITNESS: Well, I felt that I had pretty much ruled it out when I made
the primary diagnosis of personality disorder. However, there were things
that he had told me about his history and there were some things that I
observed in the interview which I mentioned earlier, the pressure of
speech, that caused me to think that perhaps it might be an individual with
an affective disorder who I was seeing at a period of time when the mood
was relatively normal. But my primary diagnosis, really, was that of a
personality disorder. Also, according to DSM-3 now, you are asked to make
diagnoses in both categories, as I did in this case.

BY MS. HAUSELT: (Resuming)

Q. I'd like to now talk specifically about the criteria of DSM-3 as they
relate to Mr. Campbell's interview with you and information that you had at
that time, and referring to Administrator's Exhibit Number 2, as you feel
you need it, could you explain what aspects of Mr. Campbell's behavior fit
the guidelines set forth under DSM-3 for narcissistic personality
disorders?

A. Yes, well, as I pointed out, in the narcissistic personality disorder
you have this grandiose sense of self or uniqueness, a special attribute.
This to me was conveyed in his presentation in the interview situation. He
also made reference to it in terms of his historical data. There's one
other thing that happened that I think I'd want to include here because
it's of significance in this kind of work to observe what happens in the
entire transaction with the individual, beginning from the first telephone
call, and, as in my case, I have somebody working in the office who does
telephone work - it's important to know what happens when the individual
calls and talks with that person, and we have a woman who works in our
office who's been doing this for a number of years and she's quite good at
it. In fact, she's just about concluded her master's degree in psychology
and, herself, is pursuing a career in psychology.

On her first or second or third telephone contact with Mr. Campbell,
indicated to me that he was at first very insistent and then forceful and
then persistent in trying to obtain an early appointment with me. He began
calling a week or so prior to the time that I was able to see him, and that
she said also, "You know, Dr. Powers, he became very angry with me over the
telephone". And that's not an ordinary occurrence, but when that happens,
Betty Kerr, she's my receptionist, will draw that sort of thing to my
attention, and she did on this occasion. So, in that sense, you know, he
was trying to convey to her that this was really an unusual situation that
demanded that I change my schedule which was solidly booked. In fact, I
gave him the first possible hour that I had available in my schedule for
the interview.

Again, in support of the element of the grandiose sense of self or
uniqueness, the historical data that he gave me, he described himself as a
dare devil, a would-be dare devil, and a pilot who had done some rather
unusual things.

Also, specifically, the way in which he described his masquerade. "I became
Dr. Campbell. I did it to get attention." Also, the World Trade Center
incident, he described with great enthusiasm, and in a somewhat convincing
way that he'd done months of research, with extensive notes which consisted
of hundreds of pages, and that he'd even gone to the trouble of getting a
friend to fly him around the World Trade Center in a helicopter and drop
smoke bombs to see which way the wind was blowing around the building so
that he'd be able to execute his jump safely, presumably. And in the way in
which he described the events that had led up to his coming to see me,
which was a really highly unusual set of circumstances.

As I mentioned before this, in the narcissistic personality disorder,
there's a preoccupation with fantasies of either success or power or
brilliance or beauty or sometimes ideal love. This he related to me in the
history of his relationship with Ellen and that this was a really perfect
love kind of relationship which had started in the high school years and
blossomed for many years and was very strong until it ended suddenly and
abruptly.

Also, he described himself in what was his fantasy of how the jump from the
World Trade Center building would be completed, "the phantom of the World
Trade Center". And, then, also his description of his function as a teacher
at Daniel Webster College, he described himself as being a very, very
successful and popular teacher and that he enjoyed that very much and the
students enjoyed him and he got a lot of positive reinforcement about the
terrific job that he was doing, despite the problems that he'd had with
these other matters.

Then, there's this quality of exhibitionism which is really a driven need
and a continuing need. I would point out that all of these elements
persist, not just at times of illness or difficulty, but they persist
pretty much all the time in the individual, and there's this particular
need for exhibitionism in the aim of gaining attention and admiration from
his surroundings. And, this, paradoxically as we understand it
psychologically, is really to support a somewhat less conscious perception
of the self as being really needy and kind of hollow or empty on the
inside. Along this line he told me about his performance as a skydiver. He
was a showman, a stuntman, a dare devil. Also, in this category would be
the incident that he described as impersonation of a M.D. where he really
played the role of another person to get social recognition.

JUDGE CAPPS: I think I've heard enough example that gave rise to his
conclusion, so do you want to get to the next question?

BY MS. HAUSELT: (Resuming)

Q. Okay -

JUDGE CAPPS: In fact, I think I understand the basis for his diagnosis from
the history - I must say the very detailed history, and you should be
complimented for it, Dr. Powers.

THE WITNESS: Can I just go on to include one or two from each of the main
categories, because that, then, would establish the diagnosis. You do have
to have features present

JUDGE CAPPS: Okay, just mention them, because I've heard these in the
history portion that you gave.

THE WITNESS: Okay, then, when challenged or finding some kind of stress,
the individual responds with either cool indifference or marked feelings of
rage, or feelings of inferiority or shame of humiliation or defeat. This is
typified in two examples right in the context of my work with him, and that
was with my receptionist on the telephone and with me directly. Also, in
his relationships with many other people, where he would get suddenly
infuriated.

Then there's characteristic disturbances also consequent in all
interpersonal relationships. Again, the relationship with Ellen and with
Ellen's father; possibly also, although we don't have sufficient data, with
his own father. There's a lack of empathy, a lack of respect for the
feelings of people who are ill, and this goes on to effect situations of
employment, dealings with agencies, with family members and it's a kind of
pervasive quality of impoverishment of interpersonal relationships.

BY MS. HAUSELT: (Resuming)

Q. Okay, just briefly, I want to ask you if you could touch on the features
of the borderline personality disorder which you feel were indicated to you
in your interview with Mr. Campbell

A. Borderline personality disorder, as I pointed out, is again -- it's a
constellation of enduring personality features that render the individual
likely to be unstable and vulnerability in terms of function or even
possibly transient psychotic episodes. There's a certain quality of
impulsivity or unpredictability. You really cannot guess what the
individual's likely to do next, and in this case I'd point out the World
Trade Center event and the impersonation of a physician.

There's a pattern of, again, unstable and intense interpersonal
relationships. This overlaps with the narcissistic, as I pointed out.
There is, oftentimes, inappropriate and intense anger. This, again, you
know, was reflected towards the examiner and my receptionist, and this
overlaps with narcissistic.

There is a more specific disturbance in identity in the case of the
borderline disorder then in the narcissistic, and this would be evidenced
in Mr. Campbell's case by his wanting to be "Just like my grandfather" and
then, "I became Dr. Campbell". This also, as I pointed out earlier, more
affective instability and more marked mood shifts, maybe in terms of
depression, maybe in terms of irritability. Again, these were evidenced in
the interview, and he gave me a history of episodes of rather severe
depression from childhood to the teens and into his early adult life.

There is, in particular, a kind of intolerance to being alone, and this
could be seen in Mr. Campbell's description for his rationale for
impersonating a physician. He said at the time, "I was very lonely and I
needed friends", and there may be also and typically, or physically, or
personally self-damaging acts, and I would point out here, again, the World
Trade Center event and perhaps even the injuries sustained while skydiving,
and other injuries, although the history of other injuries is not clear at
this point. And, then, also in the borderline configuration there are more
or less chronic feelings of emptiness or boredom which is again a more
serious manifestation of what you see in the narcissistic personality
disorder which is almost unconscious, this feeling of emptiness, and is
compensated for by the grandiosity, which is much more
pervasive in the narcissistic form.

Q. Then Mr. Campbell fits both the categories of borderline and
narcissistic?

A. Yes, he does.

Q. Would Mr. Campbell be classified as having a personality disorder under
DSM-2?

A. Yes, he would.

Q. Based on your interview with him, does Mr. Campbell have a personality
disorder which is severe enough to have manifested itself by repeated
overreaction? Yes, he does.

Q. Could you just briefly summarize what overt acts -- would those overt
acts be the same type of things which you have mentioned in going through
the DSM-3 criteria?

A. Yes, they are, and, well, are you speaking with reference to my
evaluation at this point?

Q. Just, at this point up to what you knew at the time of your evaluation?

A. Yes. I was speaking in what preceded from this basis of my information
at that time in my interview with him at that time.

Q. Just based again, on your information at that time and assuming for some
reason legally there were not sufficient overt acts under the regulations,
do you have an opinion as to whether or not Mr. Campbell has a personality
disorder of the type which would, in the now, within the next two years,
make him unable to safely perform as a pilot?

A. I think he does.

Q. Could you just explain, mostly in layman's terms, what is the nature of
Mr. Campbell's personality disorder which makes him -- which, in your
opinion, makes him unable to safely perform the privileges of an airman?

A. There are a number of features, but I think I would focus primarily upon
the impairment of judgment and, likewise, I think that one would have to
mention the sudden and unpredictable mood changes, and I think, also, his
excessive use of denial and rationalization to explain to himself, I think
at times quite convincingly, as well as to other people, how certain things
happened to occur to him and what his accounting for those events is or
might happen to be.

I think, also, that although in his case he has evidenced some considerable
insight, that there is a significant defect in insight or impairment of
insight in that he sees only part of the problem, at the same time
acknowledging that he has a problem, so that he, in effect, hides the
problem from himself, thinking, yes, well, I have this problem and I have
to attend to it, but I don't think he really realizes how it affects his
judgment at times, particularly in an emergency type of situation. This is
why I feel that it's unlikely that he can be considered reasonably safe to
fly an airplane, because there will be times when things will occur which
he will be convinced he is doing his absolute level best, and perhaps in
that immediate situation, he would be doing his best to manipulate
circumstances or people or situations to solve the problem, but he would be
doing so at great risk to himself, to other people or to property.

Q. You have heard all the testimony here today; is that correct?

A. Yes.

Q. And you have reviewed the rest of the medical file and events which came
to light after your initial interview with Mr. Campbell?

A. Yes.

Q. When you interviewed Mr. Campbell, did he tell you anything concerning
whether or not he had prescribed drugs for people out in Oklahoma while he
was posing as a doctor?

A. No, he did not, and as I recall, he even said that he'd done nothing
wrong at the time. He just passed himself off in the identity of a
physician, perhaps giving some first aid, but had not prescribed drugs and
had not performed surgery or anything of that kind.

Q. So he didn't tell you that he had assisted a woman who had suffered a
heart attack and, in fact, ridden in an ambulance with her to the hospital
posing as Dr. Campbell?

A. I think he may have recalled that incident, however, he didn't describe
it quite so specifically.

Q. He did not mention that he had scheduled his girlfriend for a
hysterectomy?

A. No, he did not.

Q. Did he mention, or did he indicate to you, how he came to return to New
Jersey from Oklahoma?

A. Well, he said he went by himself, voluntarily, or that was the
impression that I had.

Q. Did he state whether or not he had been in the Service?

A. He indicated that he had spent some time in the Air Force.

Q. Did he indicate that he had ever been married?

A. I'd say he was not married and had not been married.

Q. He never said anything to you concerning very traumatic events of the
loss of a wife and child?

A. No, in fact, I asked him also if he had any children, and he said, no, I
have no children.

Q. Did he ever tell you that he had been fired by his employers in Georgia?

A. No, he didn't. In fact, if that's, I think, the job that he referred to
as working for a man by the name of Jim in Georgia, and I believe that's
the only job in Georgia that I've heard described today, he said that he
left that job voluntarily because he was disenchanted with the man and his
operation, after being initially very enthusiastic about working for him.

Q. Now, I want to refer you to Mr. Brown's letter on page 36, and I'd like
to ask you if there is anything of clinical significance in what is related
to the FAA by Mr. Brown?

A. Sorry, can you repeat that question?

Q. Yes. Referring you to the letter of Mr. Brown on page 36, is there
anything of clinical significance in that letter which would bear on your
diagnosis of a personality disorder?

A. Yes. In the third paragraph where Mr. Brown describe getting complaints
from students and customers, that he is no longer teaching them to fly the
airplane himself -- teaching them to fly, flying the airplane himself, and
telling them how great it was.

MR. CAMPBELL: Your Honor, I have to object to this line of questioning,
specifically, number one, no one has verified Mr. Brown's statement. I
believe I can disprove Mr. Brown's statement given the opportunity, and on
top of that, commenting about the observations of a non-professional
observer.

JUDGE CAPPS: Mr. Brown's letter is in evidence and it can be commented upon
by any witness. You'll have the opportunity in your case to attack certain
portions of it that you feel are not true or accurate.

MR. CAMPBELL: I see. Thank you.

JUDGE CAPPS: At this point, I think we're going to have to take about a
five-minute recess. I want to make a few phone calls.

(Whereupon a five-minute recess was taken.)

JUDGE CAPPS: Back on the record.

BY MS. HAUSELT: (Resuming)

Q. Okay, I believe we were on page 36, Mr. Brown's letter; is there
anything else of clinical significance with regard to what he's related?

A. Well, this letter points out one of the primary diagnostic features for
the narcissistic personality disorder, and one of the important associated
features, and that is that what is described in the letter is the kind of
thing that the individual with the narcissistic personality does, to
support this grandiose sense of self, and later on in the second from the
last paragraph, in describing this apparent outright contradiction of what
has been said, with the facts and circumstance in order to support or
rationalize this sense of self there may be distortion, fabrication or
outright lies, and I'm inclined to believe that this is an example of that.

JUDGE CAPPS: Let me ask you something at this point, There has been a
tremendous amount of evidence thus far in the case of what are purported to
be untruths. At the time of these utterances by the Respondent, is it your
professional opinion that he, in fact, believed the things he was saying at
the time?

THE WITNESS: Yes, it is, and it's convincing not only to the individual but
also those surrounding him. And, it's usually -- and this is really an
important part of the problem -- it's a mixture of truths, half-truths,
more severe distortions and outright lies, and as the web becomes more
complex and intricate, the individual with this disorder really loses track
of where he or she might be in that web, and they don't know, themselves,
the difference between fact and fan

JUDGE CAPPS: The fabrication just rolls like a snowball?

THE WITNESS: That's right. And then it becomes, you know, usually the
response to that when the individual is confronted is a kind of emotional
outburst or a sudden cooling and almost unbelievable kind of emotional
distance or indifference.

BY MS. HAUSELT: (Resuming)

Q. I want to refer you both to the testimony of Inspector Taylor and also
the letters from Dean Schultz at Daniel Webster which are on pages 16
through 33, and ask you what, if any medical or clinical significance is
there to Mr. Campbell's claim of being a stuntman in the Screen Actor's
Guild and in various movies?

A. Well, this, again, would, I think be probably, at best, an exaggeration
or very possibly a prevarication or an outright lie in support of his need
for the recognition and esteem.

Q. And is there any clinical significance to his claim of teaching for the
Aircraft Owners and Pilots Association? Would that be the same type of
thing?

A. This would be the same kind of thing.

Q. What about his style of teaching and his failure to follow the orders of
Dean Schultz with regard to not showing up at particular classes after he
had been suspended?

A. Well, this would be both, you know, need to fulfill the grandiose sense
of himself and the need for exhibitionistic kind of outlets.

Q. What clinical significance is there to his having claimed to be a
parachute rigger, and, in fact, signing his own emergency chute when not
qualified to do so?

A. Well, again, I think that this would be, perhaps a kind of slip-up on
his part I'm not sure. It doesn't seem that in that situation that he would
be particularly trying to impress someone, although it may have been at the
time. I don't have enough information, but I think it is an example of the
kind of behavior which, at the very least, but also, perhaps the most
dangerous, it is inclined to trip up the individual who has this disorder.

Q. What does such behavior say with regard to Mr. Campbell s judgment?

A. That his judgment is severely impaired.

Q. And this would be similar for his claim of being a U.S.P.A. instructor,
when he is not; correct?

A. Yes.

Q. I want to ask you about the story which has been related to a variety of
people and apparently first originated when Mr. Campbell was confronted
with the newspaper article of his behavior of pretending to be a doctor,
that is posing a story of the reason for that behavior being his wife and
child were killed in a car accident; of what clinical significance is this
fabricated tragedy about his wife and child?

A. Well, this, again, would be one of the associated features found quite
commonly in that there would be distortions, fabrications or outright lies
in support of whatever set of circumstances at the time needs to be
maintained to continue the kind of state of uneasy equilibrium with the
need for gratification and admiration from others and also the problem with
maintaining consistency and validity in the truth.

Q. I want to refer you to pages 34 and 35, which is a letter from Dianne
Stuart at my request, and ask you if there is anything of clinical
significance in the information set forth in that letter.

A. I think quite possibly so. I don't know fully what happened. Again,
there's something that I was told in the course of my conversation with Mr.
Campbell which appears to relate to the incidents that are mentioned here.
I recall at the end of the interview he was wanting to state the case for
all the things that he was capable of doing that reflected his skill, his
ability as a pilot and his judgment and function under pressure, and he
said, at the time that, and I think he said in the last month or so, he had
had three emergencies, one of which consisted of he was taking someone up
for skydiving and that the individual had jumped out and his parachute had
gotten caught in the tail assembly and Mr. Campbell was able to maintain
the aircraft and maneuver so that the skydiver got free of the tail
assembly.

He also mentioned that he had an engine failure in a single-engine plane
that required a forced landing on a highway which he executed safely and
also that he had engine failure or some kind of mechanical problem in a
multi-engine aircraft which he had also solved without incident. And he
was, at the time, attesting that these were examples of the kind of
behavior that he wished that the FAA knew about so that they'd give him
credit for, and, I think, it sounds to me like that's what is being
referred to here, although, again, the time framework has been distorted
and these things apparently happened sometime earlier and also they were
described a little bit differently to me than they are described in this
letter. In fact, they were described quite differently to me than they're
described in this letter.

Q. Is it quite possible that in Mr. Campbell's mind there was some kind of
emergency?

A. I think it's quite possible and quite likely. I want to point out,
again, that in the last paragraph on that page there's another incident
which is changed slightly, but also important. In this occasion Mr.
Campbell described he had a wife who was pregnant at the time, who was
killed, and so you have a sort of constantly changing story; one time --
well, when he was seen by me, he indicated he wasn't married, he had no
children. On other occasions he reportedly has a wife and child who were
killed, and then on this occasion he had a wife who was pregnant, who was
once, at a time, killed in an automobile accident which he uses as a way of
accounting for some unusual situation or behavior.

MS. HAUSELT: Your Honor, at this time I have a problem with regard to a
letter which I have not received that would explain the circumstances.
There is a Detective Larry Brown with the Fresno Police department that I
have spoken to on a couple of occasions, and he had some dealings with Mr.
Campbell which are pertinent to this case. When I first spoke to him in May
of 1980, when the case was originally set for hearing, he had promised to
send me a letter similar to those in the file with regard to his dealings
with Mr. Campbell. He was subsequently, I learned from the Police
Department, injured in the line of duty and has been recovering for some
time. I did manage to get a hold of him last week through his superior, and
he has promised to send me a letter with regard to his dealings with Mr.
Campbell. Those are referenced in the FAA file on page 77. However, I
clearly acknowledge that this is somewhat weak hearsay of a notation in our
file, and I would ask that the record be kept open for me to submit this
letter at a later date so that at this time I could ask Dr. Powers some
hypothetical questions based on what I believe that letter will relate.

JUDGE CAPPS: All right, no. I'm not going to allow that at this late date.

MS. HAUSELT: Okay.

JUDGE CAPPS: Because I will be rendering an oral decision today in this
case. I think the Respondent is entitled to a decision in his case as soon
as possible, and I'm going to render that decision and order today, so, no,
I cannot allow the record to remain open.  Is there any way you can get the
hypothetical based on other facts in evidence?

MS. HAUSELT: I will refer to the record as it is currently constituted.

JUDGE CAPPS: All right, and I'll just give that the weight that I think it
should be entitled to.

MS. HAUSELT: Okay.

BY MS. HAUSELT: (Resuming)

Q. Dr. Powers, I want to refer you to page 77 which represent notes to both
Dr. Sexton and his office, which is the Regional Flight Surgeon's Office of
the western region, relating information that they received from the Fresno
GATO and there is information there indicating that, and I ask you this in
terms of were you to have information concerning Mr. Campbell that he had
told someone that he was qualified as a scuba diver and asked them to give
him certification without any test, and when the person refused, then got
into the water with them and subsequently proved that they did not know how
to scuba dive; of what clinical significance would that be?

A. This, again, would point out, if so, that the individual has a defect in
judgment and also engages, in terms of the problem with interpersonal
relationships engages in manipulation of others to serve needs of the
moment; so much manipulation that the rights and the well being and the
integrity of the other person may be really severely overlooked or
neglected.

Q. And I would ask you of what clinical significance it would be should Mr.
Campbell have made the claim that he -- when asked about a gunshot wound in
his leg, which was noticed at the time of the scuba lesson, asked how he
received that, indicated that while flying John Connolly and others,
Governor Reagan, and President-elect Reagan was now included, around for
Swift-Air in Nevada -

MR. CAMPBELL: Your Honor, I object. I don't know where they got this
information from. It's ridiculous, and unless they can provide some type of
substantiation, I don't see how this can even be read into the record.

First of all, I know nothing about this, and it's just caught me completely
by surprise. In fact, it's kind of hysterical, especially considering the
fact I was in Fresno working the entire time. Mr. Brown knew where I was
working the entire time and he had seen me working at that time. I wasn't
working for, what it is -- Swift-Air -- or something to that extent.
Everything I've seen so far, it may be a misunderstanding or somebody's
attempt or for that matter, just blatantly and absolutely true, but this is
science fiction.

JUDGE CAPPS: All right, you will have a chance in your case in chief to
attack the contents of page 77. It is in evidence. I'm allowing her to go
ahead and pose her hypothetical question on that. As I said, I'll give it
the weight I think it's entitled to.

MS. HAUSELT: Your Honor, I would merely state the good faith basis for my
questions, that I have spoken to Sergeant Brown on the phone and had
conversations where this information was -

JUDGE CAPPS: Of course, that can't come into evidence. I can't consider
that as evidence.

MS. HAUSELT: I just wanted to indicate that I have a good faith basis for
my question, Your Honor.

JUDGE CAPPS: Well, Ms. Hauselt, I've had you in enough cases. I don't think
you would do anything improper along those lines. But, as far as ruling on
his objection is concerned, I am going to allow you to frame your
hypothetical question to this expert using the facts from page 77 of the
exhibit that is in evidence, and as I've explained to the Respondent, he is
entitled in his case in chief to state under oath that these facts were
never supplied to these people by him, which is the basis of his objection.

BY MS. HAUSELT: (Resuming)

Q. Again, Dr. Powers, referring you to page 77, and assuming that Mr.
Campbell had told someone that he was engaged in flying Governor Connolly
and Reagan and during the course of that -

MR. CAMPBELL: Excuse me, where does it state Reagan? I mean, let's keep
this to the facts, and I hate to be nit-picking, but at this stage of the
game it's the only defense I have.

JUDGE CAPPS: Is Reagan included?

MS. HAUSELT: Connolly and Reagan to Reno from Swift Air -- while he was
there, he saved an eleven-year old girl from being raped and was shot in
the leg in the process.

BY MS. HAUSELT: (Resuming)

Q. Of what clinical significance would such a fabrication be?

A. Well, again, it would be an example of how the individual distorts,
fabricates, outright lies to support his inflated sense of self. It would
also be of significance to me in that if, in fact, it were a gunshot wound,
this would be an important omission from the historical data that I have
obtained from Mr. Campbell at the time of my interview.

Q. Mr. Campbell did not indicate he had ever been wounded?

A. No, he did not.

Q. Referring you to pages 7 through 10 and 11 through 15, we have some
information there with regard to Mr. Campbell's employment by Japan
Airlines and his subsequent use of a uniform following his being suspended
from their employment. Of what clinical significance is such behavior?

A. Well, this would be, I gather, the most recent or more recent example of
a kind of bending of the facts, distortion and then outright lies,
including in this specific instance again, a masquerade, a confusion of
identity, adopting the role of a pilot for the airlines that the insignia
and the uniform represent. And it's not only a questionable example of his
judgment, but an example of where the boundaries of self and reality become
so blurred as to be crossed back and forth with relative ease and grace
and, I think, probably convincingly so.

JUDGE CAPPS: Off the record.

(Whereupon, an off the record discussion was had.)

JUDGE CAPPS: At this time we are going to suspend the proceedings in order
to take some time off for lunch. We'll recess now and reconvene at a
quarter to three.

(Whereupon, a lunch recess was taken.)

               AFTERNOON SESSION

JUDGE CAPPS: Back on the record.

You are still under oath, Doctor.

Whereupon,

                DR THOMAS POWERS

having been on the witness stand at the time of the recess, resumed the
stand and was examined and testified further as follows:

DIRECT EXAMINATION (Continued)

Q. (By Ms. Hauselt) I believe where we had left off, we had gone through
information which had come to light after your interview with Mr. Campbell.
In regard to the line of questioning we just went over , were -- did the
incidents of lying and behavior which we have just gone through constitute
overt acts which were manifested as a result of Mr. Campbell's personality
disorder?

A. Can you remind me of exactly where we were, and what documents we were
referring to?

Q. Okay. Well, I believe the last question was the clinical significance of
Mr. Campbell's using the Japan Airlines uniform back in Nashua, New
Hampshire, and his claim with regard to his employment past, and we had
gone through a series of questions concerning his employment in Georgia and
his claims in Nashua to have been in the Screen Actor's Guild, his methods
of teaching, his failure to follow the orders of the dean at the school,
his claims or being a parachute rigger - those questions.

A. Yes.

Q. Were those types of behavior be overt acts manifested as a result of a
personality disorder?

A. Yes. All of these are examples of overt acts.

Q. I'd like to ask you a similar question to what I asked you earlier --
now, are these episodes and acts which we discussed consistent with your
diagnosis of a mixed personality disorder including both narcissistic and
borderline features?

A. Yes, they area.

Q. And could you just briefly summarize how they fit into that criteria of
DSM-3?

A. Well, all of these manifestations for which we have a written record or
direct observational evidence or second-hand information would be examples
of the kinds of features that are required to make specific diagnosis of
narcissistic personality disorder, on the one hand, where we have to meet
the requirement of making observations of the individual having a grandiose
sense of self or uniqueness, and a need to support that sense of self.
This may be done in various ways -- through masquerading, through
manipulating, through distortion and fabrication, or outright lies.
Also there is a preoccupation with a fantasy life, which may involve
fantasies of success -- in this case, for example, we could think of an
individual masquerading as a successful airline pilot, wearing the uniform,
discussing with other people the kind of work that the individual in
involved .

Or he could be masquerading as, let us say, a physician and introducing
himself as a physician, prescribing medications, wearing the white coat of
a physician, a name tag indicating that he is a physician. Likewise, with
these kinds of examples of attention-seeking behavior that are very obvious
of exhibitionistic, we fulfill another requirement in the diagnostic realm
of criteria, in that there is a constant need for attention and admiration
on the part or the individuals surrounding the person with the personality
disorder of the narcissistic type.

Likewise, when challenged or threatened, if there is a direct threat made
or if the individual is called into question and account for his behavior,
there may be a response of cool indifference which is sometimes quite
remarkable or just the opposite of that may occur -- he may fly into a rage
-- an explosive rage.

There may be extreme feelings of shame, humiliation, or defeat.

Q. Where do we see evidence of this in the file?

A. Well, I think the account of the dean at Webster College -- when
confronted with certain facts of the situation which developed there; in
the letter and notes that the dean supplied, I think -- on Page 32, on the
top of the page, paragraph goes on to say, "I wrote a letter to Mr.
Campbell that afternoon, which he received personally. "After reading, it,
he stormed into my office. He was obviously infuriated, especially about
the prohibition against the parachute club meeting. He accused me of taking
away his livelihood and he screamed that; he was going to sue me and the
school, following which he slammed the door violently and he left the
building."

Other examples would be those that I referred to in my direct observation,
and that of my perceptions. For example, if there was a failure of response
to efforts to manipulate or move in the direction that Mr. Campbell wanted
to go, there was anger. In my case, there was a kind of threat. And then
there was a sudden cooling and change.

Q. Wouldn't you expect a person to be somewhat angry, under those
circumstances?  What is abnormal about that?

A. Well, I think anger certainly is to be considered a normal response.
But it is a question of the context and the way in which it is handled.
I think one does not try to force an issue when it is obvious: that there
is no way that the outcome is likely to be changed -- or very unlikely that
the outcome is going to be changed. For instance, when he was told by my
receptionist that I had no time -- I really had no time -- I had given him
the first available hour, and I think it was because I had some
cancellations that I was able to move his time up.

Likewise, if we consider the accounting of the events at Daniel Webster
College, I think that the dean pointed out, as I recall he gave a very good
explanation as to why he could not allow Mr. Campbell to meet with the
classes -- either the classes he'd been asked to teach or the organization
that Mr. Campbell wanted to do, I guess on a voluntary basis, which was not
required as part of his teaching assignment. But there was a very serious
question as to his having the proper certification to engage in that type
of activity. And when confronted with those facts -one might, I suppose,
feel the normal frustration and some degree of anger.  But one would not
respond by threatening lawsuits, screaming and slamming doors. That is not
normal behavior.

Q. Is there any significance to the fact that the behavior occurred in
several different situations?

A. Yes. In fact, as I pointed out, I think early on you have to see an
on-going pattern of this kind of manifestation in the individual, that is
present pretty much all of the time, to make a diagnosis of personality
disorder. This is not an occasional event; it is a constant recurrent type
of manifestation.

JUDGE CAPPS: It is just when the individual does not get his way?

THE WITNESS: Well, it can be that, or I think anytime that the individual
is threatened in terms of the sense of self or in terms of his functional
capabilities

It might come -

JUDGE CAPPS; You mean his ego is threatened, or his self image?

THE WITNESS: His self image, his --

JUDGE CAPPS: And the image he is trying to project?

THE WITNESS: Right.

JUDGE CAPPS: Oh, I see.

THE WITNESS: Who he is, or at the time -- who he may think he is or who he
is trying to convey that he is. But it also might be simply in -- it could
happen in driving a car, and someone bumps into your car and causes a dent.
And sure, it's an unfortunate circumstance, but there might be a sudden
angry outburst of temper that is kind of a miniature psychosis. During this
period of time, there is such an angry outburst that you almost have to
consider that this is a transient psychotic event. It is a very short
duration and it is not the same as an ongoing process of psychosis such as
we have in schizophrenia, which is another diagnosis entirely.

Q. (By Ms. Hauselt Continuing) I didn't mean to throw you off the track,
but getting back to the DSM-3 criteria, what events support those criteria
with regard to the narcissistic personality?

JUDGE CAPPS: He has been through this already. Are you asking for just
events that were brought to the doctor's attention subsequent to his
meeting with the Respondent?

M5. HAUSELT: Right.

JUDGE CAPPS: All right.  Just limit it to those.

THE WITNESS: All right. There are more, and I can definitely go about it in
a fairly organized and speedy fashion. I reviewed the file , and beginning
with the information, we have -- and these are all incidents which came to
my attention outside of the context of the interview -- beginning with
Pages 81 and 82 -- however, in some cases, they relate to things that I
learned in the interview, but they may be appearing in slightly modified
form.

In Pages 81 and 82, we have memorandum from the chief of Portland GADO 15,
Mr. John Van Horn that's the October 5th, 1979 -- and the last paragraph on
the first page, at the end of the description that is rendered there, of
Mr. Brown's description of Mr. Campbell's performance for the first two
months. He was an excellent employee. The third month it was like someone
pushed a button. He did a complete turn-around and caused quite a bit of
trouble. This would be the kind of thing that one expects to find -- if the
need that this type of individual has to exaggerate -- well, I'm sorry --
what happens in the inter-personal relationships of the person who has a
personality disorder. There is an overidealization in the beginning, and
then for some very small or perhaps even significant reasons, there is a
sudden dramatic change. And it's like night and day. And there is no going
back. It's what we call "splitting." And this is an example of that kind of
psychological operation.

On Page 82 there is a reference to Mr. Campbell telling several others that
he had spent -- that he was at one time a stunt pilot and did the flying in
the movie, "Hooper." Well, I gather from the preceding testimony that
that's of questionable validity. Again, a distortion, fabrication, or
twisting of the facts, to support an exaggerated sense of self. There's the
description of Mr. Campbell as a very flamboyant individual. This, I think,
is a layman's way of saying that this individual is exhibitionistic. That
is another one of the criteria.

One Page 76, there is a notation from someone's notes that Mr. Campbell had
-- is observed to undergo very marked and quite wide mood swings, all
within 30 minutes. This is kind of affective disturbance which is observed
in the borderline individual, and also can be observed in the narcissistic
type of personality configuration.

On Page 73, we have a notation from Sandy Taylor at the bottom of the page.
By the way, he owes the flight school in New Hampshire $165 in phone bills.
This would be an example of the kind of lack of empathy and the
manipulation of others to accomplish one's ends.

On Pages 55 and 56, this is the copy of the psychiatric evaluation from Dr.
McKnight, which I think I must say I disagreed in terms of his overall
conclusions and I found much lacking, particularly from the history. But
it certainly occurred to me that Dr. McKnight was not in possession of all
the facts of the history of this individual, much the same as myself, when
I had the chance to interview the individual. It was only by having some
additional time and by going back and carefully questioning, that I began
to see that there were some holes in the information that he had given me.

JUDGE CAPPS: What page are you referring to in Dr. Knight's -

THE WITNESS: McKnight -- that's pages 55 and 56. Again, here is an example
of information which is slightly distorted, in that -- at least in Dr.
McKnight's accounting -- of Mr. Campbell's account of his World Trade
Center episode, that he was only thinking about jumping off the World
Trade Center. So I think that, well, there's none other mention in his
concluding paragraph under "impressions" -- Dr. McKnight says that he
observes that this is a young man who is somewhat of an over-achiever in
his chosen field, that of air science for piloting. It seems to me that
this is what Mr. Campbell would like others to believe of him. And he was
successful in conveying and portraying that kind of image, and that is
basically a successful young pilot pressing the outer limits, and in all
ways achieving success. Here again, this is the over-exaggerated and
exhibitionistic driven empty self, and the failure - the failure of jobs
-- the broken relationships -- the shortcomings, the mismatching of stories
and facts -these were left out of the interview with Dr. McKnight.

Also, that occasion, he saw a psychologist who performed a number of tests.
I think in many ways I can agree with the description of some of the
dynamics. However, again, in this case, the psychologist just did not go
far enough, and probably because he didn't have adequate historical
information or correct historical information. Also, there was, I think, a
very important omission, and that is that is that no standardized
personality test as such -- no personality inventory, for example, was
given.

There were other types of tests of personality functions, but in terms of
the best kind of a survey test which would be likely to turn up evidence
across the board, of problems in personality functioning, one would think
of giving the classical Minnesota MultiPhasic Inventory of Personality, or
the California Personality Inventory, or other such similar tests. And this
test was omitted from this evaluation. And I really don't understand,
because he had several tests done, and these were observed to be
incomplete, and then he was sent back and given a couple more. But he still
didn't get what I would consider to be a very important test, and that is
the basic MMPI -- Minnesota MultiPhasic Personality Inventory. So I would
disagree with the overall findings that this is a psychiatrically normal
individual, principally on the thoroughness of the testing, and the
inadequacy of historical information. And the psychologist has to go on
that in attributing his tests. On Page 54 -- I'm sorry -

Q. And the presentation of one's self in the psychiatric interview in such
a matter that one withholds valuable information about one's past -- would
that be consistent with the personality disorder which we are talking
about?

A. Yes, it would be.  As I have pointed out before, at times, consciously
withholding and other times being kind of drawn in to the role that one has
created, and maybe only being semi-consciously aware that there is
distortion of facts, but in either cased this is part of the dynamics of
the personality disorder. Then there is on Page 54 the letter from Dr.
Dorsey. Again, he mentions in the second paragraph, without specifically
giving a diagnosis of personality disorder, he gives the bare bones of
that diagnosis.

Likewise, the end of the last paragraph, he indicates that treatment was
terminated not by mutual agreement, as is the case in psychotherapy, when
such has been completed successfully, but that the treatment was terminated
by Mr. Campbell finding employment out of the area. This means that the
treatment was not probably - and I think in fact most likely insufficient
even in Dr. Dorsey's eyes. And I think later evidence would attribute it to
the fact that it was incomplete.

On Page 46 and 47, there is an article from the Tulsa trip, again this
indicates that here is an individual who has a tremendous need to gain
support from his surrounding environment. And this need will drive the
individual to extreme lengths including, in this case, masquerading as a
physician without license or education or any of the requirements for being
a physician, except the kind of externals -- the garb, the nametag and a
very convincing demeanor.

Also, here again we have an example how there is a disregard for the rights
and integrity of others, and this contributes all the way along the line to
impoverishment of interpersonal relationships. In this case, he shows a
flagrant lack of empathy by not only introducing himself as a physician to
people who are ill, but he also prescribes medications for them, indicating
that he is a physician.

On Pages 44 and 45, we have the parachute rigger's card entries which were
inappropriate and distortions of qualifications. Again, this shows such a
blurring of distinctions, and poor judgment that here he may have been
endangering his own life or property of others.

On Page 43 we have the letter from someone who recognized this behavior,
and was trying to do something to kind of shore up the gap that he saw in
this individual's reality testing. And he was saying to an authority in the
parachute organization, in essence, "please do something about this
individual because he doesn't have what he says he has, and he is going to
get himself in trouble and he is going to get other people in trouble."

On Page 40, we have an application for employment which I thought curious
in that there is an indication that he was a member of the Screen Actor's
Guild,, which was not mentioned in my interview with him -also that he left
that job because he had too many injuries. That information was also
omitted from the history that I obtained from Mr. Campbell.

We have on Pages 37 and 38 -- this is a letter or memorandum "to whom it
may concern" from Mr. Steve Rikelson to Sandy Taylor. He is described by
Mr. Rikelson in that correspondence as having a pronounced tendency towards
extroversion. And then he goes on to specify the kinds of things that he --
that had come to his attention - claims that Mr. Campbell has made that
were never really confirmed. There was some question of their validity, and
there appears again to be a confusing mixture of fact -- somewhat -- slight
distortion, serious distortion to outright fancy and prevarication.

On Page 36, we have again the letter from Mr. Brown to Dr. Pakull, an
indication that there was both in terms of his work performance -- which
was not in accord and appropriate to the situation -- but that he was
beginning to do things which basically were directed at again the need to
fulfill this grandiose sense of self.

And again, an incident was accounted, which was apparently an outright lie,
and the fact that he was terminated from that job -- which again points out
the difficulty in interpersonal relationships. On Pages 34 and 35 we have
an accounting of the emergency landing and some other similar kinds of
events -- hasty landings due to serious aircraft malfunctions. I think
these are hard to evaluate, but certainly they can be examples of the kind
of situation that would predictably develop with an individual who has
difficulty sorting out fact from fantasy. It is possible in the press of
circumstances, whether it is a real emergency or whether the facts have
been distorted, that something impulsive, hasty and dangerous may be done.
Again, the story -- at least inconsistent with the facts that I was given
in my interview with Mr. Campbell -- of a wife who was pregnant and who was
killed in an automobile accident -- a confusion of fact with fantasy --
either that or outright lying.

In the second to last paragraph of that letter, there is again a notation
of Mr. Campbell's response in a situation where he was confronted --- where
his self image was called into question, at that time with the apparent
charging of $130 worth of long-distance phone calls to relatives. And at
that time, according to this description, Mr. Campbell became not only
totally unreasonable but also completely irrational.

On Pages 16 through 33, we have again a series of events that took place at
Daniel Webster College which show how Mr. Campbell was caught up in a
situation where he had apparently told some tall tales about himself.
This situation gradually escalated into kind of a full community crisis.
And in the course of trying to work his way out of what I suppose he
thought at the time was a perfectly righteous and explainable and in his
best interests, matters became even more complicated and ended up in an
explosive outburst in the dean's office, and he was terminated from his
position there. And then there is the question of his function as a teacher
--- again, the kind of relationships he had as a teacher with his students,
and the questions of identity and boundaries come up in that context -- and
also in his relationship with the dean, where it appears in the record that
he directly disobeyed written orders.

On Page 19, -- well, I could go through and point out more specific items,
but we've already been over that. So I would move on to Pages 7 to 15,
which appear to be the most recent example in the record. Again, extremely
poor judgment and inability to suspend a drive to feed this empty and needy
self with exaggeration and distortion and again, a kind of role-playing
that I think amounts to really a confusion of identity.

And here we have -- first at Page 9 -- this is a memorandum from Mr.
Scarborough, written, I think, shortly after the time that Mr. Campbell
left JAL IASCO in Napa, saying "somehow it seems to me I didn't get back
from you a red jacket, wings and epaulettes. Would you please stick these
items in a box and mail them to me. Thanks, Ed S." And he has enclosed, or
someone has enclosed in the record, an inventory which was made of items
checked out on the date of employment. And that includes, sure enough,
a uniform with a red windbreaker, a cap, wings, shoulder boards and
stripes. And these items were noted at the bottom of the page either
returned or not returned on 3/11/80, and in this case the uniform, was not
returned on 3/11/80, which I gather is when Mr. Campbell left, or about the
time that he left working for this organization.

JUDGE CAPPS: What page was that?

THE WITNESS: That is on Page 10. You see that the top of the page, it is
initialed "EMD," and date of employment, "February 4th, 1980." And the
items were checked off, I gather, when he received them, and then at the
bottom of the page there are zeroes next to the items that were returned
on 3/11/80.  And unreturned items included I guess the Jeppson manual and
the uniform and some of the others

JUDGE CAPPS: Yes, I see that.

THE WITNESS: Then following that, on Pages 11, 12, 13, 14 and 15, with
dates some of seven or eight weeks later, accountings of individuals who
had met Mr. Campbell and spoke with him dressed fully in the uniform, with
insignias that depicted Japan Air Lines. And also they indicated that Mr.
Campbell had specifically said that he was working for Japan Air Lines and
had flown into Boston the night before. He said he was a captain on the
Falcon 20 and a co-pilot on a B747. Again, here is an example -- I think it
is evidence now that this is a continuing process, that the identity does
become confused because of the need that this individual has to fill this
tremendous void within. Such distortions occur as really a question not
only judgment but occupation functioning, social functioning, and really,
I think if not to cause significant subjective distress on the individual,
to certainly raise questions in that individual as to why it is that all
the world seems to be turning against or finding fault.

JUDGE CAPPS: Let me ask you this -- do you know, when you see a movie with
Danny Kaye playing all these characters, it is funny as the devil.

THE WITNESS: Yes.

JUDGE CAPPS: And you look and you say, "Well, there's nothing wrong with
somebody blowing their own horn -- you know, good con man. He puts his best
foot forward."  Some people look up to that.  Obviously this Respondent was
able to do that; he was able to talk himself into many, many jobs right in
the same industry.  What differentiates the behavior here to make it
dangerous to air safety for this man to go up in the air?

THE WITNESS: Well, I think generally speaking that there is evidence of a
serious impairment of judgment such that I would wonder if in judging that
it was safe and appropriate to do what he indicated to me he did -- that
is, to plan to jump off the World Trade Center Building -- to get -- just
at the last minute as he is going over the side, albeit with a parachute on
and he is an experienced parachutist.  But this is taking a real risk with
his own life

JUDGE CAPPS: Well, are you saying that we can't tell, because of his
unpredictable nature, what he might do when he once got up in the clouds?

THE WITNESS: That's right.  You don't know what is going to happen next. I
think I can go further to say that given pressing circumstances that he
could be counted on to make faulty judgments

JUDGE CAPPS: If there is the slightest bit of pressure brought to bear?  Is
that it?

THE WITNESS: If there is pressure of if - even if there is not pressure --
if it just happens to fit with a particular kind of scheme or scam or
fantasy that is going on at the moment, For instance -- I don't know that
there was any particular pressure involved when he says -- and I don't know
whether to believe this or not -- that is one of the problems -- but he
says that he went up with a friend and they flew around the World Trade
Center Building and they were dropping smoke bombs out to see which way the
wind was blowing. I believe that that is a violation of air safety. It is
at least doing something that I think is probably likely to meet with the
disapproval or the authorities, both of the city and of the state if not
the FAA.

Also, I was think of another example of that - but in any event, basically
it is difficult to predict, except to say you are not sure what is going to
happen next, but like as not there is going to be faulty judgment, because
there has been such faulty judgment in the past. And there has been lack of
insight as to how that judgment was faulty. So therefore there is no
learning from continued experience.

JUDGE CAPPS; So in your testimony is he has removed himself from being a
charming, lying rascal -

THE WITNESS: Yes.

JUDGE CAPPS: -- to a person who doesn't even know himself who he is.

That affects his judgment and causes defects in that judgment?

THE WITNESS: Yes. And in his perception of reality and what is appropriate
and what is inappropriate. You mentioned Danny Kaye, and the kind of madcap
things we see in the media and on television and in the movies -- you know,
it's quite likely, I think, that perhaps there is a place for Mr. Campbell
in the Screen Actors Guild. It would certainly be more appropriate for him
to do this type of thing on the stage or in a controlled setting where no
one is going to suffer -- where there is a net at the bottom when the
person goes off the top of the World Trade Center, in case something goes
wrong.  He would not smash himself as a result of faulty judgment.

Now, on Page 7, I think finally the last example is that we began
confirming information that while at - I asked if Mr. Campbell was not
involved in the operation of Falcon Aircraft. "We do not operate Boeing
747's or other air carrier jets."

Q. (By Ms. Hauselt Continuing) Dr. Powers, you were present during Mr.
Campbell's opening statement, were you not?

A. Yes

Q. I want to ask you if -- I noticed you took notes at that time.  Was
there anything of clinical significance stated during those opening
remarks?

A. Well, I was making note of some discrepancies that I was hearing,
between what I had been told or I had been led to believe, and what I was
hearing then.  But I think that - most of those I have been over -- there
are one or two things I would care to comment on, in that Mr. Campbell said
that with respect to his treatment with Dr. Dorsey that he had relatively
few sessions, that he felt that little progress had been made.

However, he felt that he had been seen by his grandfather and had been
spending some time talking with his grandfather, who has had some time, I
gather, directing a state hospital, but who is a GP, and therefore not
specifically trained in dealing with psychopathology or personality
disorders which I think are probably some of the most difficult kinds of
cases to work with. And he at the time conveyed to the Court that he was
getting what he needed, in this relationship with his grandfather. Well,
I would submit to the contrary -- that he was getting what he was seeking,
which is evident from other examples of his behavior. But he is not about
to get the appropriate kind of psychotherapy that is required for the
treatment of the personality disorder.

JUDGE CAPPS: Did I read somewhere in the record -- refresh my recollection
-- that his grandfather thought he was schizophrenic?

THE WITNESS: Well, I don't remember reading that per se. I just don't
remember.

JUDGE CAPPS: I thought I saw something in there.

THE WITNESS: Well, somewhere in the record it was noted that somebody at
one time or another thought that he was schizophrenic and then confronted
him with that, at which time he did not respond with anything except kind
of tacit agreement.  And I don't know what else to place that time, but he
indicated that he had had some mental problems and it stopped at that --
that particular point.

MS. HAUSELT: Your Honor, just to clear that up -- I believe there is a
reference in the Tulsa Tribune article that his parents have said that.
However, we are not alleging that Mr. Campbell has a psychosis.

JUDGE CAPPS: Which would be schizophrenia, right.  Okay. I knew I had read
that somewhere. Okay. You were going to give us other examples from his
opening statement .

THE WITNESS: Well, Let me just review those notes for a minute.

(The Witness examined his notes.)

To give us an example of the kind or thing that happens to him, when
describing what to place at the Daniel Webster College -- and this I wrote
down from his statements here earlier today -- "I went along with what had
been said in the past, even though some of it was not true, to save my
pride." This is the way he explains it to us, and this is the way he
explains it to himself, and I think he believes it himself. I think he
believes it himself more than we are able to believe it.  Likewise, he
said, "When I left there, I wanted to throw them off the track, so I told
them I was going in all directions." And that to him made a lot of sense at
the time. But what it amounted to was that he was telling people different
things at the same time. And that is inconsistent with the truth.

JUDGE CAPPS: Tell me, what is your professional opinion as to what the
prognosis for the Respondent is, with your -- with the diagnosis you have
found and all you know from this case, from having been in here today and
having studied all the records, plus your own interview and personal
observation of him? What is your prognosis for his condition?

THE WITNESS: At this point in time I would say that I consider his
prognosis extremely guarded. The reason for that is because he is -- has
not conveyed to the court today, in my observation, that he is really
involved in psychotherapy for its own sake, to really get at the
personality disorder which he is suffering with.

JUDGE CAPPS: He doesn't have the proper motivation?

THE WITNESS: Well, I think his motivation is to clear up the problem -

JUDGE CAPPS: Yes. To get his certificate back.

THE WITNESS: I don't think it is so important, really, whether or not this
man flies an airplane again.  He may be able to, at some time in the
future, if he really gets into treatment and stays at it for sufficient
time and intensity to change his behavior and therefore to change his
personality.  That is what is going to be required, and this is going to
take a long time and a lot of work and effort on his part.

JUDGE CAPPS: But it can be done with proper treatment?

THE WITNESS: Yes, it can.

JUDGE CAPPS: Under a proper doctor that knows what he is doing?

THE WITNESS: Yes.

Q (By the Board) And as long as there is the proper desire to be cured, on
the part of the Respondent -is that about it?

A. Yes. The proper desire and motivation.  And there is one other thing
that is in his favor. He is relatively young, which not only means that he
has got more time to work on it, but that his personality is in some ways
still in the formative phases.  And that gives him statistically a little
better prognosis. Otherwise it would be even worse, if he were ten years
older.

Q. You can teach a new dog new tricks?

A. That's right.

Q. Yes. Go ahead, I'm sorry I interrupted, but that was really uppermost in
my mind there -- this prognosis deal.

A. That was really the end of what I wanted to say about the notations that
I made on what Mr. Campbell had said earlier.

Q. (By Ms. Hauselt Continuing) Okay, Doctor, just in conclusion I would ask
you -- based on the regulations and as a result of all the testimony and
your own background with this case -- do you have an opinion as to whether
or not Mr. Campbell has a personality disorder which is severe enough to
manifest itself by repeated overt acts?

A. Yes, I do. He does have such a personality disorder.

Q. And as pertaining to the second regulation at issue, and putting aside
the question of the overt acts, do you have an opinion as to whether or not
Mr. Campbell has a personality disorder which now or within the next two
years may reasonably be expected to make him unable to safely perform his
duties of his certificate?

A. Yes, I do.

Q. And what is your opinion?

A. That he is unlikely to change without sufficient and appropriate and
complete treatment of his problem.

MS. HAUSELT: I have no further questions.

JUDGE CAPPS: Okay. Would you like a brief recess -- maybe five minutes --
before we go into your cross-examination?

MR. CAMPBELL: That's not necessary.

JUDGE CAPPS: All right. Go ahead.

CROSS-EXAMINATION

(By Mr. Campbell) I am going to have to run over some material in here,
specifically about your evaluation.

The first question I have is specifically how much information did you have
a chance to look over, or how much information had you received from the
FAA at the time of my evaluation?

A. I had had a conversation with Dr. Sexton, at which time he gave me some
of the information that I later received in a written form, in terms of
letters and the evaluation from Dr. Knight and the psychologist, Lundey.
There were some other notes that had been made in his office, that he sent
me copies of. I received those prior to the time that I saw you.

Q. By any chance did this information include any data on the attempted
World Trade Center -

A. It did.

Q. We talked for several hours. During this time, there were some
disagreements over what specifically happened. You stated pretty much close
to the end of this that with reference to my request to get some
information concerning the outcome for any results that you might be able
to give me -- and I am reading from the mental status examination that I
came up "angry and furious, demanding that the examiner was supposed to
phone the FAA at the exam and give an oral report to the requesting
physician."  "When the examiner pointed out that the hour was late, he
stated that he had in his possession a notarized statement -- that
immediate action would be taken. "When asked to produce the document, he
shifted the topic, quickly cooling his rage, and informing me that he had
enlisted the help of a congressman in dealing with the bureaucratic snafu
that resulted in his suspension."  Now, you are specifically stating that I
said that I had in my possession the notarized statement. Is that correct?

A. Yes.

Q. All right. And I became outwardly angry and furious. That is also correct?

A. Yes.

Q. All right. Let me ask you sir --- is frustration a normal reaction? Is
that within the normal realm?

JUDGE CAPPS: I hope it is, as frustrated as I get sometimes. Please say
it's normal.

THE WITNESS: Yes, it certainly can be.

(By Mr. Campbell Continuing) Would you consider the period from early
October to early March an easy time to get frustrated in -- specifically
over having one's career killed over his head?

A. I think some frustration was to be expected.

Q. And if a person was promised second-hand certain results, and had
expected those results, and did not receive them after he built up some
dependence on getting that information/that would specifically inform
employers, parents and so forth, wouldn't that be - or would that be --
normal reaction?

A. Well, let's not lose sight of the context. The context is late on Friday
afternoon, and demands are being made in the office of the physician which
cannot be responded to, and an explanation is given as why. I told you, as
I can recall, that I really had to look over the data and think about it
and write a report, and if from that report there would be
forthcoming some action on the part of the FAA.

But it was not really my position to decide anything, but merely to give an
evaluation, write a diagnosis, to submit a report and the rest of it would
be handled by the FAA. That was out of my realm. That kind of explanation
should have been given appropriate consideration, and utilized in holding
some of the anger in check. And specifically I would refer I don't know
whether you had a notarized statement in your pocket or not -- maybe you
did.  But it seemed to me to me -- you know, I was being intimidated and
somewhat threatened and coerced in that situation, to do something that I
was not prepared to do.  And it was inappropriate of you to require me to
do it.

Q. So at that time you said you were not capable or prepared to give any
impressions or judgments in relations to my medical.

A. Well, I think I gave you some feedback right at the time.

Q. No, sir. I can't recall.

A. We had an exchange of information at that time as I recall.

Q. Well, please refresh my memory as to what that was.

A. Well, I can't remember my exact words, but I think I did indicate at
that time that there were some real problems in what you had told me. And
I think you then said something -- you had copies of the regulations with
you, that you referred to. You had them in your attach‚ case -- your flight
kit. And you, I think, had also at the time to some extent pretty much
appraised the situation and you said something to the effect, "You- don't
think I could be considered under Section -- whatever it was -- referring
to psychosis, which is automatically disqualifying; or alcoholism, which is
automatically disqualifying.

Q. At the time, I think you zeroed in on a section which specifies that a
medical certificate for an airman can be disqualified for having an history
of personality disorder with -- overaxed. And I think you read to me out of
the manual at the time, saying something to the effect that it looks like
it will be this, which is Catch-22. Do you recall that?

Q. That I do. That was during the course of the examination itself; not at
the conclusion.

A. Well, it was near the conclusion.  In any event, I thought to leave well
enough alone at that point, as far as you were concerned.

Q. All right. Let me ask you this:  You put a lot of faith in a lot of
hearsay evidence, specifically letters and reports from various people from
non-professional backgrounds, who may or may not be associated or may or
may not really have the knowledge of the situation. Would your opinion
change very greatly if you were to find out that a great deal of this
information is misleading?

A. Well, I suppose I could change my opinion. However, I think it would
require some doing to explain this whole pattern of events, in addition to
what I observed at the time that I spent with you, and -this business about
you wanting to be given an appointment ahead of anybody else that I wanted
to see.

Q. Doctor, we aren't talking about explaining.  I'm talking about producing
irrefutable evidence to the contrary of these statements.

A. Well, yes, if you could refute point by point all of the items that have
been presented today, then I would have to reconsider, but I don't think I
could reconsider -- I could reconsider, including the other information
that is in addition to what I learned about you in my interview.  I would
not change my diagnosis.

Q. Okay. Let's talk about one thing.  You had a great deal to say about,
and have indicated a great deal of interest during the course of the
interview, and frankly, it caused me a few problems here. Specifically,
going back to the World Trade Center -- and there has been a great deal of
disagreement on this -- specifically, the act of jumping off of a tall
building with a parachute and with preparation is in your mind not a stable
act?

A. I think that my point there was in terms of evaluating judgment, that
that is the example of extremely poor judgment.

Q. Doctor, are you a parachutist?

A. I am not.

Q. Do you have any knowledge of parachuting?

A. Very little.

Q. Are you aware of what general -- at terminal velocity -- for instance a
term used to describe an average velocity after acceleration -- are you
aware that it takes approximately 350 feet for a parachute to open, max.,
and that the building is 1,377 feet tall?

A. I don't know these particular facts. But I would guess that it is
possible to jump off the building with a parachute on, and survive.

Q  It is more than possible. It's been done twice.  Now, in that respect,
you also made a statement - and this is something I take a great deal of
exception to -- that there were flights in the World Trade Center, there
were smoke rings. However, do you still maintain that objects were dropped
from the aircraft?

A. I don't know, but that is what you told me. That you had a friend fly
you around the building in a helicopter and you dropped smoke bombs to see
what way the wind currents were -- to see what the wind was doing around
the building.

Q. Are you absolutely sure, now, of dropping objects from the machine?

A. That's what you told me.

Q. Around the Center?

In relation to the fact that I have two substantial -- not rather
substantial, but I could feel complete evaluations by a psychiatrist and a
psychologist, a letter from another psychiatrist and a letter -- for what
good it may do and whatever attention it may be paid -- from my
grandfather, who we will grant is not a psychiatrist, but I often wonder if
a general practitioner does not have a little bit more insight than the
average psychiatrist into people -- how did you find one man's testimony
able to refute four?

A. Well, I don't. I am just stating my opinion. I will leave it to the
Court to decide which -

Q. Personally, I wouldn't give myself that much credit for being able to
fool four professionals, especially  one that has been acquainted with me
all of my life.

A. I did say why I thought that the evaluations submitted by Drs. McKnight
and Lundey were incomplete, insufficient, and therefore wrong. I think I
can substantially agree with what Dr. Dorsey had to say, in that he
basically is giving the bare bones of the personality disorder in his
letter. And I don't remember exactly what your grandfather had to say but I
would insist that it is not appropriate for you to seek or obtain treatment
for a personality disorder from your grandfather.

Q. Well, I maintain nobody would know me quite as well.

A. Well, that is in fact of the problem.  He would know you so well as to
again fall into this kind of blind spot that you have created, where issues
of reality and judgment come into -

Q. I think his judgment is extremely important.

MS. HAUSELT: Your Honor, I would ask that you explain to Mr. Campbell that
during the course of his cross-examination, he is not to interject his own
comments.

JUDGE CAPPS: That's right. This is not a time for commentary from you, Mr.
Campbell. All this is is the opportunity for you to ask questions and to
elicit answers.  That is all. You make no comments, other than to voice a
question.

MR. CAMPBELL: All right. Thank you.  In reference to your opinion
concerning my suitability as a pilot, let me ask you first if you have any
flight experience, specifically a license or any type of rating or any type
of instruction, upon which to base a judgment from a practical standpoint?

THE WITNESS: I have no experience or pilot certification of any kind in
that regard.  I've flown in a lot of airplanes, though.

Q. (By Mr. Campbell Continuing) Can you tell me specifically when Dr.
Sexton came to you?

A. I think he -- I don't know Dr. Sexton. I think I am known to the FAA
regional office in Los Angeles. I have worked with some of the staff there.
I think it is likely that someone else there - possibly one of the
attorneys that I have worked with on other cases somewhat similar to this
case -- might have said that I was in their area and would be available
perhaps to do an evaluation on behalf of the FAA of yourself.  That is my
guess. I really don't know. I don't know Dr. Sexton.

Q. Okay. In reference to your comment concerning Dr. Lundey's psychological
testing, you seemed to indicate that there are some omissions.  Are you
aware that the tests taken were the exact tests that the FAA had requested,
and apparently this was on a form letter, so this is established procedure?

A. No, I wasn't-aware of that at all. But I will repeat that they were
deficient in two respects one, I think in respect that there was
insufficient historical data given at the time on the part of the
individual being examined; and then I would have myself wanted to see the
results of one very important additional instrument -- which is the MMPI.

Q. All right. In what ways are these tests deficient?  I would just like to
clarify that just a little bit, and specifically since the psychological
written testings seemed to come out in my favor, how does one fool a piece
of paper and a pencil?

A. It's not easy.  But I think that it is possible, and we see it happen
again and again. And most often it is for lack of the sufficient and
correct clinical information which in reading the evaluations and summaries
written up by Dr. McKnight and Dr. Lundey - there was just insufficient
data available to them.  They didn't go far enough with their inquiry

Q. Well, from the information you just gave me, and some statements you
made during the interview back in March, it seemed to indicate to me that
you didn't have a whole lot more information than they did.

A. Well, I didn't. But I had a little more, and in this case it might have
been the critical difference.

Q. You had more information at the time this report was made, approximately
five days later?

A. Well, I knew that for one thing that - that those reports had been done
and that they had been considered to be perhaps lacking and that they did
not sufficiently explain all that was going on.  So I found myself with the
question in my mind shortly after the beginning o_ the interview - for
instance, why it was that I really wanted so much to believe what you were
telling me.

Q. I'm going to go back to the World Trade Center here, because according
to your diagnostic formulation you stated "this is a young- man with a
history of two dramatic examples of severe impairment of judgment."  First
of all, would you consider the World Trade Center as one of those?

A. Yes.

Q. I take it you consider the events in Tulsa, Oklahoma as the other?

A. Yes.

JUDGE CAPPS: What events in Tulsa, Oklahoma?

THE WITNESS: Well, this is the series of events at which time he was
impersonating a physician.

JUDGE CAPPS: Oh, right. Okay.

Q. (By Mr. Campbell Continuing) Well, let me ask you this, and if I seem to
be repeating myself, I am sorry.  I am just trying to reach an
understanding of the rationale behind your title of "severe impairment of
judgment" in respect to the World Trade Center.  First of all, the severe
impairment of judgment  does that lie more in the fact that it was an
illegal enterprise or something where a possibility o_ risk presented
itself?

A. Well, I think both.  As I recall you telling me about that situation,
you said that "they caught me with one leg over the side of the building,"
It doesn't seem to me that those are the optimum circumstances for even the
best of daredevil parachutists to successfully leap from the top of a tall
building.  If you've got security guards hanging on to one arm, how are you
going to pull a ripcord? And at the same time, yes, it was against the law.
Had you gained permission from those who owned the building and the thing
had been properly carried out legally, I suppose that that would be a
different set of circumstances.  But again, you didn't do that. You
disregarded the fact that you Were in violation of the law to trespass and
jump off somebody else's building .

Q. By any chance did you have an opportunity to get a little bit more
information about the attempt itself, specifically the incidents leading
directly up to the arrest ?

A. The only thing I knew was what you told me about that, except that this
had allegedly had occurred and that this was omitted from your description
of it until the very end.

Q. Were you aware that the attempts stopped not at the arrest but simply
because the attempts stopped when another person entered the immediate
area?

A. No, I was going to go on what you told me, which was that it stopped
when you had one leg over the side of the building.

Q. Correct. That was the point at which it stopped. Are you aware - and
this is a matter of police record - are you aware of the fact that the
attempt stopped when the danger presented itself to a person other than
myself - that the attempt stopped when another person had crossed the fence
and was in the process of trying to stop me from making the jump?  I think
this makes a big difference in impairment of judgment.

JUDGE CAPPS: Put a question mark on that, and I will allow it.  Otherwise,
it's going to be a form of testimony which I don't allow.  Does that have a
question mark on it?

MR. CAMPBELL: Yes, it does, Your Honor.

JUDGE CAPPS: Okay.  He put a question mark on it.

THE WITNESS: I really can't - I don't recall that you told me that.  But
you did explain some of the circumstances; my recollection is that the
security guards were there and you said, as I recall, that you had one leg
over the side of the building.

Q. (By Mr. Campbell Continuing) All right, sir. By any chance does that
make any difference to you in the -   All right, now, in relation to some
statements I had made during my opening statement, you had ventured some
opinions about them, specifically in respect to some comments I had made
about being caught and having problems with pride and so forth.  In your
opinion, does this fit into a situation where there were deliberate
fabrications or fabrications simply based on the fact that one's back was
up against the wall?

A. I honestly don't know, Mr. Campbell.  All I know is that the stories
don't match with the facts, and when we have this kind of discrepancies
then usually there is either distortion, outright lying, or there is an
even more serious thing going on, which the individual isn't aware of -
that there is a real distortion of reality, such that you don't know when
you are telling the truth and when you are not telling the truth.  And I
think that you are at risk for getting into kind of situation on that
day-to-day basis.

Q. So it is your opinion that at this point I not aware of the difference
between right and wrong?

A. I don't know that. It could possibly be so, in a given situation.

Q. Do you find your qualifications any better or equal to, or even lacking,
with respect to Dr. McKnight, Dr. Lundey, or Dr. Dorsey?  What I am getting
here is we've got three different opinions, and I would just like to know
the rationale which says "you are right, they are wrong."

A. Well, as I said before, I disagree with two of them. I don't know what
their qualifications are, so I can't really answer that question.

Q. Oh, yes - one other question.  This, I think is going to be rather
important. I am sure that as a practicing psychiatrist you have had the
opportunity to speak to people about this, but do you find a lot of
prejudice toward mental illness or people who have experienced any type of
mental health problem, or people who have consulted with psychiatrists,
psychologists?

A. There is considerable prejudice and much of it is irrational and
unwarranted.

Q. Would that - would some of those feelings manifest themselves at times
in trying to either damage someone or make false statements concerning
someone?  Is that within the realm of possibility?

A. It certainly is.

Q. What is - throughout this procedure, there has been some references to
"con man."  Is that an accurate characterization in this particular
circumstance?

JUDGE CAPPS: I was the only one who used that phrase, and you've just
voiced it out of context.

THE WITNESS: You would have to be more specific, because I don't know what
you are referring to.  I don't remember the incident which the Court has
referred to - the Judge introduced that notion by way of seeking further
explanation of something I had said.  Could you be more specific?

Q. (By Mr. Campbell Continuing) Well, what I am trying to establish is the
absence of a malicious intent.  Was there any evidence of malicious intent
through the fabrications - that you have seen?

A. Malicious? In what way malicious?

Q. Hurt somebody else.  Did you know of any deliberate attempt on my part
to hurt anybody else?

A. I would say that what I was aware of was a conspicuous absence of
feeling of that sort, when it would have been appropriate to consider that
possibility that someone might be hurt, that someone might be deprived of
their rights - individual rights, property rights and so forth.  There was
a lack of empathy and a total absence of feeling of that kind, That would
be the kind of point that I would make.

Q. Okay. No more questions, Your Honor.

JUDGE CAPPS: Redirect?

MS. HAUSELT: I have a couple, Your Honor.

               REDIRECT EXAMINATION

MS. HAUSELT: Dr. Powers, is there any indication from the record that at
the time Mr. Campbell attempted to jump off the World Trade Center, that
the area below was cleared of pedestrians, vehicles and other obstructions?

A. None that I am aware of. I would gather not, because it seemed to me
that this was a kind of a surprise on his part, and there were no
preparations made, except that he had a parachute on.

Q. Had there been a person who as claimed by Mr. Campbell came over the
fence in an effort to stop Mr. Campbell from jumping over the edge of the
World Trade Center - what did that indicate about Mr. Campbell's
understanding of other people's feelings and well-being?

A.  Well, I fail to see the point that he is driving at. I don't see that
it really makes a shred of difference but apparently to him it does.  And
that he can make those kinds of distinctions, I think is part of the
problem, It's like what I referred to earlier today, in his accounting of
the difference between a man who walks across from building to building on
a tightwire, and one climbing the side like a mountain climber.  And the
one was questionable judgment or and the other was not. I can't make those
kinds of distinctions either, which Mr. Campbell apparently is able to. And
I don't share his point of view in that regard.

Q. Would you make, or would you be able to make a diagnosis of a
personality disorder based on psychological testing?

A. No

Q. Is that the theory you had, without all the information of the
individual's past history ?

A. Yes, it is.

Q. If you had received no information about Mr. Campbell, and merely relied
on what he told you, do you think you could have diagnosed him as having a
personality disorder?

A. It would have been difficult.  I think I could have done it, had I been
given more time. But that would have been difficult. I think Mr. Campbell
has shown us today here that he is extremely verbal and adept at portraying
his intelligence and his ability to stand on his feet and speak for himself
and to be entirely convincing in a role which is, I gather, rather
unfamiliar to him - and that is defending himself in a court of law.

MS. HAUSELT: I have no further questions, Your Honor.

JUDGE CAPPS: Thank you, Dr. Powers.

MR. CAMPBELL: Your Honor?

JUDGE CAPPS: Do you have another one -

MR. CAMPBELL: I have still one question.

JUDGE CAPPS: Okay. Go ahead.

                     RECROSS EXAMINATION

Q. You had mentioned some personality tests - I believe the MMPI. Is that
correct?

A. Yes.

Q. Would those -

MS. HAUSELT: Your Honor, this goes beyond the scope of the Redirect
questioning.

JUDGE CAPPS: That is outside of -

MR. CAMPBELL: She asked questions about psychological testing.

JUDGE CAPPS: Yes, way back on Direct.

MR. CAMPBELL: She just asked questions on psychological testing.  She asked
specifically if -

JUDGE CAPPS: Oh go ahead and ask it. It will save time.  Go ahead and ask
your questions. You are allowed to ask. Go ahead.

Q. (By Mr. Campbell Continuing) Sir, would those tests have any bearing on
your opinion at this time, or could they make a difference?

A. Can you ask the question again.  I'm not sure what it is that you are
asking about.

Q.  Could the MMPI possibly make a difference in your decision, at this
time?

A. No, it would not.  All right. Thank you.

            FURTHER REDIRECT EXAMINATION

Q. (By Ms. Hauselt) But in your opinion, that might have made the
difference in the evaluation of

Dr. Lundey and Dr. McKnight?

A. Yes. That was my point.

MS. HAUSELT: I have no further questions.

JUDGE CAPPS: Let me ask you this;

Dr. Dorsey - he didn't make any diagnosis,

THE WITNESS: No.

JUDGE CAPPS: Because his treatment was ceased before it's natural
culmination, in his opinion, because the Respondent moved out of the area.
Is that right?

THE WITNESS: It was terminated for that reason. I don't know if that is the
reason why he didn't venture a diagnosis.  What he did do was - in more
descriptive language - gave some of the essential elements of a personality
disorder, in that letter.

JUDGE CAPPS: Yes, I noticed in that letter he did cite certain things -

THE WITNESS: Right.

JUDGE CAPPS: - and that leads you to think that that was an inherent
diagnosis - I mean, coming from a psychiatrist like it was.

THE WITNESS: If we had Dr. Dorsey here today, and asked him, he would agree
that that was the diagnosis - the diagnosis of personality disorder was
correct.

JUDGE CAPPS: He would that these are symptoms -these things that he - or
characteristics.

THE WITNESS: These are the manifestations and the characteristics, yes.

JUDGE CAPPS: That DSM

THE WITNESS: The Diagnostic Statistical Manual is a standard in the field.

Q. (By the Board) That is so you all will know what each other is saying,
and talking about, right?

A. That's correct.

Q. Much less, us -

A. More importantly, you, I would say - in this case.

JUDGE CAPPS: Okay. I have no further questions  Thank you, Dr. Powers. We
will take a five minute recess before your next witness.

(The witness was excused.)

(A five-minute recess was taken.)

JUDGE CAPPS: Back on the record.

MS. HAUSELT: We call Dr. Barton Pakull.

Whereupon,

                 DR. BARTON PAKULL assumed the witness stand, and having
been duly sworn by the Administrative Law Judge, was examined and testified
as follows:

                          DIRECT EXAMINATION

Q.  (By Ms. Hauselt) Would you state your name for the record?

A. Barton Pakull. First name, B-a-r-t-o-n, last name, Pakull, P-a-k-u-l-l.

Q. What is your business address?

A.  800 Independence Avenue, SW, Washington, D.C.

Q. A. And you are - where are you employed?

A. I am employed for the Federal Aviation Administration in the office of
Aviation Medicine.

Q. In what capacity?

A. I am the chief psychiatrist on the staff of the Federal Air Surgeon.

Q. Are you Board certified in psychiatry?

A. I am Board qualified in psychiatry.

Q. Dr. Pakull, could you briefly summarize what your medical education is,
or was?

A. Yes. I am a graduate of Syracuse Medical School, in 1961. I took the
prescribed residency in psychiatry, in the Department of Psychiatry in
Syracuse, completing that in 1965.  I also parenthetically in 1965 received
training as a flight surgeon in the Army, and served as an Army flight
surgeon in Viet Nam in 1965-66.

Q. When did - what did you do after 1966?

A. After serving in the Army as both a flight surgeon and with the Special
Forces and paratroopers, I served in the Peace Corps for three years.  I
served as Deputy Chief Psychiatrist in the Peace Corps. Following that, I
was staff psychiatrist -chief psychiatrist - currently - with the Federal
Aviation Administration, since 1970.

Q. And do you have any aviation and flying background?

A. I am a licensed hot air balloon pilot and a parachutist.

Q. And you have reviewed the-file in this case?

A. Yes, I have.

Q. Could you just explain briefly what personality disorder is?

A. Well, much the same as has already been testified to by Dr. Powers quite
eloquently and quite directly.  He referred to the fact that there are
different types of personality, and that a personality disorder is an
extreme and maladaptive pattern of behavior that is ingrained, that occurs
and usually is seen to manifest early in life - in adolescence - and
persists throughout out life.  It is a pattern of behavior and a
constellation of behavior that is recognizable, so that you see what the
person is like - it's a personality disorder when that is both extreme and
maladaptive.  In that sense, a personality disorder is in some instances
more clearly observable, or just as clearly observable by lay people as it
is by professionals. It is just that we can articulate and explain or
categorize it, but the manifestations are things that are within the
purview of all lay people.

Q. Okay. What are the characteristics of a person suffering from a
personality disorder?

A. Well, they vary, depending on the personality disorder.  However, with
reference to the Aviation Medical Certification Regulations, part 67, which
although I have not written, I am quite familiar with - we are referring
to overt acts related to personality disorder.  We are referring to those
types of personality disorders specifically that bear upon judgment that
bear upon the kind of judgment involved in aviation and in aviation safety.
This is not with specific reference to intelligence or proficiency
Personality disorders of certain types, that manifest themselves in overt
acts, are related to safety because they are related to kinds of judgment
that people will make

Q. Okay. Let me ask you a general question.  In your opinion, based on the
file and all the testimony that you have heard today, does Mr. Campbell
suffer from a personality disorder?

A. Yes, he does.

Q. And has that personality disorder manifested itself by repeated overt
acts?

A. That is correct.

Q. Could you outline briefly what some of those overt acts were?

A. Yes In general it has been testified to and observed and is in the
record and is acceded to, to some extent, by Mr. Campbell himself, that he
has shown poor impulse control.  He has shown poor judgment. He has shown
an inability to take responsibility for his acts, with a tendency to blame
other people. And he has evidenced that he does not understand; that he
feels little guilt for some of the things that he has done.  Some of these
overt acts - they've been gone into in quite detail, and they are quite
numerous. But they can be grouped, and at least they could be referred to
in certain individual cases.

For instance, the incident about the World Trade Center, which in itself is
an irresponsible action because obviously someone jumping off a tall
building is doing something that is illegal, first of all, which makes it
an irresponsible act by itself - one of many that would manifest itself in
this.  But secondly, he did not understand that this involved danger to
other people, when you land on other people in a parachute.

Posing as a doctor - now I understand from some of the comments not under
oath by Mr. Campbell that he would take issue with some aspects of the
article written in the Tulsa newspaper.  Be that as it may, whether or not
he in fact did - and I don't know that he didn't do it - I mean, as far
as I know, he did attempt to treat people - the posing as a doctor is an
irresponsible act because it can pose a risk to the life and safety of
other people.

This is poor judgment. If a person and these experiences have occurred to
me - I have become familiar with experiences such as this, where a person
suffering from a heart attack or incapacitating situation,  other people
rush to the wrong person, thinking he is a physician, instead of taking
proper action of calling for proper servicing.  This is a life-threatening
kind of situation, an example of possible irresponsibility.

His claims of being an instructor for - that's AOPA - it is in Aircraft
Owners and Pilots Association organization, where he made a claim to have
done some ground school that was not - he had made claims to credentials
he doesn't have, and his - the credential of having a parachute rigger, are
examples of poor judgment where he puts people at risk.  I myself in the
purview of being a student parachutist know that I would not want to put my
life and my safety in the hands of somebody who would be impulsive or who
would not be completely qualified, or would do these things without being
qualified.

Certainly in my responsibilities of chief psychiatrist at the FAA I am
concerned, and let this concern be manifested throughout the office of
Aviation Medicine at the FAA, that we are concerned with lapses of judgment
because this - if it reflects itself in this kind of personality, we
expect it might reflect itself in aviation activity and impinge upon the
safety of others.  In fact, in this case it did impinge on itself in
aviation activity. But even without that, I would consider having this
personality and having these overt acts - even outside of aviation -
would be sufficient for us to want to take action under part 67, which we
have a right to do.

Again, there are other aspects that reflect on this kind of acting-out
personality disorder, such as taking things. It has been alluded to films;
in one case, educational materials in the case of one of the other
employment - places he was employed at.  These are examples of an
acting-out personality - irresponsible actions, financial irresponsibility.
The business with the phone calls; also the business with non-payment-on
Page 73, non-payment of bills.

Again, these are overt acts that are not in aviation, hut they don't
necessarily have to be in aviation to be overt acts that reflect an
acting-out personality.  And an acting-out personality is a person with
poor impulse control, poor judgment, who we would not want to have
responsibility within aviation.  Misrepresenting himself as a JAL pilot,
including taking the uniform and not returning the uniform, also reflects
overt acts of the nature which has already been alluded to.

But I feel that it is important, although it would seem minor, to -
perhaps to other people - it is important within the evidence there are at
least two occasions where one of the reasons why there was objections to
what he was doing was not in the technical sense proficiency, but was his
digressions from his responsibilities to students - digressions that in
some cases may have involved showboating in the air and on the ground.
Such cases - at least in two of the parts of the evidence - I think it
was Brown Aviation as well as at Webster College, where there was evidence
that some students were falling away from him because of these kinds of
behaviors.

Sometimes, in a young person, you might consider it immaturity. But
continuing on into early adulthood, and under the pressures of
responsibility, it begins to he what we call a personality -"character -
personality disorder."  And these are the kinds of- overt acts that we
would associate with this behavior.  And finally I would point out that he
does manipulate people; he tried to manipulate Dr., Towers; he tried to
manipulate the student body at Daniel Webster College against the
administration.

And frankly, I, as a bureaucrat can very much identify with the
administrator of a college or an administrator or someone running a school
- a training school for pilots - where you have a great deal of
responsibility and legal liability to make sure that the person that is
representing yourself has proper credentials and is acting in a proper way.
You are liable, and you worry about it, and the notes there reflect the
worry that the administrator at the college had.  He asked for credentials
and they weren't forthcoming. There were promises and he was told there
were credentials, and he was worried even before he received the copy of
the article about this person - the Tulsa article.  Even before that, he
was worried about this man's employment.

And I think these are examples of the things that you see in this kind of
- these kinds of acting - out personalities, that make them unreliable and
therefore unsafe.  And of course I don't know-he has perhaps alluded, not
on the testimony, that he didn't actually treat people. But for a person
that treats somebody even with a non-:prescription drug, it is a dangerous
thing - an act of irresponsibility that when reflected with all these other
acts, on the personality, is the kind of personality that FAA,-I feel,
cannot be represented as an airline pilot, as an instructor of pilots, as
an instructor of parachutists.

Q. Is the problem something that he will Outgrow? it a function of
immaturity?

A. Generally speaking, the answer would be "no." But I wouldn't want to say
the prognosis is impossible for him to change.  I would like to see a
number of years of stability in employment, stability in his relationships
with people, an absence of the kinds of behavior that he has shown before -
which is impulsivity, prevarication, blowing himself up, avoiding
responsibility for what he does, not paying his debts, conning people, et
cetera, et cetera, and making rationalizations.  A few years of absence of
this might convince the FAA and psychiatrists that perhaps this is
ameliorated, for whatever reason - whether through therapy, or through
experience .

JUDGE CAPPS: I love you psychiatrists.  You're the only branch of medicine
that never uses the word "hopeless." You all don't think any case is
hopeless, do you?

THE WITNESS: No, I think there is always room for hope for everything.

Q. (By Ms. Hauselt Continuing) Taking all you know of this case, and based
on the personality disorder that Mr. Campbell has, do you think that he
understands what the truth is?

A. I am not sure that I can answer that question, directly that way.  For
instance, I don't think - I think he understands the facts, but he doesn't
give them the way I would give them, in terms of judgment.  So I can only
compare him to myself , and I think he understands the truth at times.
Although I can understand - I'm not sure, I haven't examined him
directly- where there is a possibility that he lacks even the ability at
times to tell the truth from not truth.  I'm talking about that aspect of
his personality that deals with this prevarications and elaborating more
and more stories.  At some point he begins to understand or believe his own
stories, and he confuses them.

Q. Okay. Based on your own experience as a parachutist and also your
position with FAA, what in your opinion is irresponsible about his act of
attempting to jump off the World Trade Center with a parachute.

A. Well, if you are asking - you are including my own personal feelings
when you ask "in my experience as a parachutist," because I can recall my
experience as a novice parachutist, before I was in the military, putting
my life in the hands of people who were the earliest parachute instructors.
Its very important these people be - and in my knowledge and my
familiarity with these people - be very responsible people, not
dare-devils.

The act of transgression of law, in itself, is irresponsible. The act of
doing something spectacular like that, may be nice, but it doesn't go along
with the kind of personality, especially if it is extreme, and reflects a
personality disorder of the kind of person who would be instructing people
in flying - instructing people in parachute jumping.  So it is
irresponsible to make the attempt, and of course I worried about the people
down below. He may be okay, but we are now in the neighborhood of the World
Trade Center, and I don't want to be walking around looking up to see if
someone is dropping a smoke bomb or someone is descending in a parachute.

Q. Okay. You reviewed the report of Dr. Dorsey in the file on Page 54.

A. Yes, I have.

Q. Are Dr. Dorsey's comments consistent with the personality disorder?

A. Yes, very much so, when they describe - I would say they describe what
I feel I see in the whole record.  Let's read the second paragraph - yes -
the end of the middle paragraph, It very much describes it.

Q. Okay. with regard to the psychiatric and psychological evaluation done
by Dr. McKnight and Dr. Lundey, do you agree with them?

A. Oh, no. First, it's already been mentioned that both of them seem to be
convinced that he will never do this again. And I can't see how they can
say this.  I take that back. I was thinking about Dr. Dorsey's report. In
order to make an accurate assessment of a behavior disorder or a behavior
and personality disorder - personality disorders are called "behavior
disorders" because much of what is manifested is behavior that is
observable.  You have to know what the person is doing. It is extremely
difficult to make an accurate diagnosis -you may make very strong
inferences, but to make an accurate diagnosis of an acting-out type
personality disorder, which is what we are concerned with - without
knowing what the behavior is, because characteristics of some of these and
many of these disorders is the person is also facile in making explanations
and prevarications and doesn't tell you what happened.  So if you don't
know what happened and can't measure up what happened, to what they say, it
is very difficult to make the diagnosis

JUDGE CAPPS: When you say "behavior" when you've just used it now - that
term - do you mean the pattern of behavior?

THE WITNESS: And specific acts.

JUDGE CAPPS: Not just - oh, specific acts -

THE WITNESS: And specific acts.

JUDGE CAPPS:-that constitute a pattern.

THE WITNESS: That is correct.

JUDGE CAPPS: That are recognizable by even lay people.

A. And that is why parenthetically I do place some credence on comments -
colloquial comments such as they are - by lay people who have come in
contact with him, as we have seen in the record.  That tells me something,
because someone says "he is loony," they are responding to something. They
may not be psychiatrically trained, but they are lay people who are
responding to something. There is something wrong.  I can say as a
psychiatrist that this is not psychosis, this is not schizophrenia. But I
understand what they mean, and it helps me to understand, "yes, this is a
personality disorder that manifests itself this way," even though at the
same time, many people - including some psychiatrists and psychologists -
could be fooled because they don't see all the parts of the behavior.

Q. (By Ms. Hauselt Continuing) Okay. So in your mind, is there any question
that Mr. Campbell suffers from a personality disorder?

A. Not at all.

Q. And that disorder has been manifested by repeated overt acts?

A. Yes.

Q. If you put aside the question of the overt act, in your opinion and
based on the record, does Mr. Campbell have a personality disorder which
may reasonably be expected now or in the next two years to make him unable
to safely perform the duties of his certificate?

A. That is correct. He does have a personality disorder and I could not
predict that he could not continue to manifest that personality disorder
continually over the next two years.

MS. HAUSELT: I have no further questions, Your honor.

JUDGE CAMPBELL: Cross-examination.

                           CROSS-EXAMINATION

Q. (By Mr. Campbell) In line with the previous question, Dr. Power, might I
get you to venture some ideas on a prognosis of the future?

A. I don't know.

Q. I would say - I know this sounds self-serving but the very act of
losing your medical certification may motivate you and say make enough
impact to make you understand or begin to understand how people like myself
and others think and act, and begin to modify one's behavior .

JUDGE CAPPS: Can that sometimes work on an individual suffering from a
personality disorder?

THE WITNESS: Yes, it does happen.

JUDGE CAPPS: You mean, all of the talking to him by friends and parents,
and the cajoling and trying to make him understand, won't do it.  But
something that he wants very badly - if he is denied that - it can make
him sit up and take notice?

THE WITNESS: Something that really slaps you in the face.  The trouble with
friends and relatives is that they are too kind and not tough enough. You
need to be slapped in the face to really realize. That is what perpetuates
this personality disorder - if you can't pin them down.  You have to nail
them to the floor. They keep running away to other parts of the country and
starting all over again. They keep fooling people. They keep getting away
with it.  So it perpetuates the personality. They have not learned enough
that it is not in their best interests, that they have to earn and work for
release of basic character development that most of us undergo.  That needs
to be learned at a much later age. It does happen. It happens in prison,
and through prison.

Q. (By Mr. Campbell Continuing) Also in line with the previous question:
In the event that you were to discover that: a great deal of the
information presented in the form of various hearsay testimonies on the
part of various non-professional people were discovered to be incorrect
erroneous, misleading or false, would that have any difference on your
judgment?

A. It is inconceivable to me that all of these people, who don't know each
other, just keep coming up with the same kinds of feelings about this
person that "I don't want him working for me. I don't want him teaching my
students. I don't trust him. He is not reliable. He doesn't pay his bills,
"et cetera, et cetera.  Those opinions, alone, help me to make up my mind
about what the personality is, even though there may be distortions. There
are always going to be distortions. There are so many stories I don't know
which is true and which isn't true.  Now I still can't make up my mind
whether the person described here actually was in the service, or was in
the reserves, did receive certain kinds of training in the Air Force, or
didn't, or did have somebody that they knew who may have died in a
parachute accident, did have a close friend, did have a wife, didn't have a
wife - there are all kinds of distortions of people hearing messages from
one to another, They do distort.  But the basic pattern is certainly
evidenced throughout the record.

Q. Okay. would you also agree with Dr. Powers in respect that many people
in the "outside world" hold great deal of prejudice in relation to any type
of mental health problem or mental illness?

A. Yes, that is certainly a generalization that is hard to disagree with.

Q. Now, one question I have - you have indicated or have started to talk a
little bit about what you would like to see before granting a medical
certificate in the future.  I am just curious if you would expound on that
just a little bit.

A. Just a little bit -- may I say that this would be in terms of the way
the regulation is set up; the way we have set up that to operate in the
FAA.  This is in terms of granting an exemption to a denial for certain
mandatory denials. And in the case, the mandatory denial for a personality
disorder manifesting itself by overt acts, it has been in my experience
quite rare that our medical consultants -- psychiatric consultants -- have
recommended an exemption, but it does happen.

And what I know they will want to see, and I want to see it - many years,
a number of years of stable behavior.  It is not something that you need to
be a psychiatrist to understand, because you don't - don't need to he a
psychiatrist to understand the issues of why a person like that, no matter
what label you give it, should not have the responsibilities of a pilot or
a commercial pilot, and what it takes for us to be convinced that they
could have the responsibilities,  These are not difficult concepts for an
educated Lay person to comprehend.

Q. Well, are you aware that several years, or many years, as the case may
be, in the competitive environment that is currently in the job market in
aviation, pretty much would put the end to a person's career in that area
especially if that would put someone near the 30-mark by the time the
situation like this would be resolved ?  And I mention this specifically
just to call your attention to the gravity of what is happening here.

A. I don't know what job market you are referring to.  In my opinion, your
chances of being an airline pilot are zero. I mean, if I worked for an
airline and I know that doctors have worked for airlines - why in a
competitive market would they ever want anyone, if we cut off the last
eight months, the last three jobs, they just don't want - they have no
right to take that kind of chance in hiring you to fly a 747, past the age
of 40.  When you are talking about the job market for commercial aviation
and flight instruction, there is always room for people. When you are
talking about other kinds of Class 2 commercial responsibilities, it
depends upon the job market.  I think reflected in your question is your
lack of understanding. My concern is not with your career; my concern is
with public safety.  If I had your background, my concern was in my
reputation and changing my reputation by my acts, not in getting my
certificate.  We think differently and see things differently.

Q. We do think differently. However, is what you are saying pretty much
that the FAA has no concern for the individual?

A. We have a great deal of concern for the individuals in the air and on
the ground below the planes that are flying above them, as well as the
individual who is being carried by the pilots.

Q. Well, how do you explain the FAA's actions up to now have been all
punitive and were never a request for information or request for help of
one type or another -

MS. HAUSELT: Object to this form of the question.

JUDGE CAPPS: Sustained. You don't have to go through it.

Q. (By Mr. Campbell Continuing)  I have no other questions, Your Honor.

JUDGE CAPPS: Any Redirect?

MS. HAUSELT: No , Your Honor.

JUDGE CAPPS: Thank you, Dr. Pakull.

                       (The witness was excused.)

MS. HAUSELT: That concludes the case for the Administrator, Your Honor.

JUDGE CAPPS: All right. The Government has rested. That means they have put
on all of their evidence that they have to present.  Now, we turn to the
Respondent's case in chief. You have indicated that you have no other
witnesses other than yourself.  Is that correct?

MR. CAMPBELL: That is correct.

JUDGE CAPPS: All right. If you will step up here, and be sworn, I will hear
your testimony.

MR. CAMPBELL. Am I allowed to bring this up with me, just to refer to?

JUDGE CAPPS: Certainly.

Whereupon,

        JAMES R. CAMPBELL assumed the witness stand, and having been duly

sworn by
the administrative Law Judge, was examined and testified as follows:

                         DIRECT EXAMINATION

Q. (By the Board) Okay, I am going to ask you a few preliminary questions.

For the record, state your name and current address?

A. My name is James Richard Campbell. I am currently residing at 41 Stone
Vance Road, Oakland! New Jersey.

Q. Mr. Campbell, are you the respondent named in this case?

A. Yes, I am.

Q. At the commencement of this trial, you availed yourself of the
opportunity to give an opening statement, which was a rather detailed
opening statement in narrative form.  In the interest of saving time, and
to avoid for you having to repeat a lot of the stuff that you told me in
your opening statement, I'm going to ask you this question:  Is there
anything in that opening statement that you told me that you would not be
willing to have considered said under oath?

A. I stand by everything that I said.

Q. You did not tell me any untruth?

A. As far as I know, that is correct.

Q. All right. So if I were to ask you to start  telling me your side of the
story, of necessity you would have to repeat a lot of the things you said
in that opening statement?

A. Yes, m'am.

Q. And do you want to stand by that now that you're under oath?

A. Yes, m'am.

Q. All right. Then what I am going to do is accept that opening statement
and the information you put forth in that opening statement as testimony
sworn to under oath by you.

A. All right.

Q. I am going to ask you now if there is anything that you failed to tell
me in the opening statement, that you think I should know?

A. Quite a bit.

Q. Okay. I am going go try it this way I'm going to let you start in a
narrative form to bring out some of this stuff.  If I see that it's not
working, I'll let you know. You will be the first to know. And then I'm
going to start asking specific questions.

A. Okay. Well, I'll do my best to be brief.

Q. Okay.

A. I think the smartest thing right now is simply to attack the literature
as I see it, and any comments I can render - I will keep those down.  In
reference to the International Air Service Company, page 7 - everything
there is correct as is -as is all the information presented from the
International Air Service Company.

Q. Let me ask you this, specific question; There was a press release that
came out when you were at Daniel Webster College.

A. There was a press release prepared. It was never released.

Q. All right. There was a press release prepared.

A. Correct.

Q. Did you give them the information for that press release?

A. Some of that information I did.

Q. Did you look over the press release after it had been prepared?

A. I had the opportunity to look it over. They had asked me if there were
problems. I said, "Yes,' and that was as far as they'd gotten.  Shortly
thereafter, things blew up.

Q. So you never made the corrections that should have been made on that?

A. There was some opportunity - very little.

Q. Was there anything in that press release that you maintain now was just
pulled out of the air, that was not gotten from you?  Now, the reason that
I am asking the question this way is if I was going to prepare somebody -
a press release on somebody - on you - I'd go to you and I'd say, "Here,
Campbell, I've got to prepare this darn press release. I've got to get
information from you."  'So, you feed it to me and I'll take it down."  All
right. That is the way it is generally done. Are you saying that it is not
the way it was done in this case?

A. To a certain extent, yes, and to a certain extent, no.  A lot of the
information was "I have this and this and this. I'm going to write it up.
Give me a little bit more information on your flying; a little bit more
information on your family; a little bit more information on the World
Trade Center; a little bit more information about where you are from," and
so forth.  A lot of the information they had gotten from students. A lot of
information was done either over the phone or in person. It was a rather
hectic atmosphere the first few days, because we were preparing for
students and we were preparing the flight program -in addition to preparing
classes.  There was very little time for any kind of dialogue.

Q. Let me ask you this - have you ever been a stuntman in the movies?

A. In the movies - no.

Q. You didn't work on the "Moonraker" or "Hooper." You didn't do any of
those movies, did you?

A. Well, they make the mention of flying in "Hopper." There is none, so I
certainly couldn't have done that.  And "Hooper" - I know who did it. I am
a buddy of the guy who did filming and in fact he used to show up at IASCO
a lot, but no, that is not me.  And in the past I had claimed -

Q. Did you ever do any stunt work or flying or anything in "Charlie's
Angels?"

A. M'am, nothing in organized media -

Q. Nothing in television or movies?

A. There was a news broadcast in Tulsa, Oklahoma, where a gentleman from
News Center 8, or some such, came in to take his parachute jump. It was his
first in a year. That was televised, and during that period of time there
was some pictures of him and me in free-fall, turning a back loop and
things like that.  However, there was nothing of any commercial nature such
as films, television.  I have recently been involved with a few things that
might be commercial, but God only knows how they will work out.

Q. I'll tell you - the issue before me is whether or not you are now
suffering from a personality disorder that has manifested itself in certain
overt acts that laymen and psychiatrists and virtually everybody would not
consider exactly normal acts of normal people.  Now, you have told me about
- I mean, you've owned up to it - you have admitted that you did pose as
a doctor.  Was that for three months?

A. Something around that neighborhood - yes.  Keep in mind that during
that period of time, I was escalating from one end to the other. It was
either as a medical student or as a resident or as a doctor, or whatever
would work at the time.

Q. Work to do what?  A. Well, for instance of people who knew a little bit
more of my background, it was obvious that I was not a doctor.  However, it
was more suitable, it was easier to believe that I was a medical student.

Q. Tell me this - just out of curiosity, why did  you want anybody to
think you were either a medical student or a doctor? when you were in fact
not?

A. At the period of time, I was hurting a great deal. The only person who
has never disappointed me, the only person who has ever proven themselves
to be absolutely unimpeachable as far as his wisdom and as far as his
guidance, as far as judgment, the only person that I have ever known who
just exceeds the basic tenants of being good, is my grandfather.  He has
been -

Q. Well, wait. I know what you are saying - You want to emulate him - you
have such respect for him.

A. Well, not emulating, but I see how he deals with people and I see what
people look to him as. I see the way he is able to help people.  I don't
know so much if I wanted the emulation so much as the interaction, if that
makes any sense at all.

Q. Well -

A. Well -I wanted the involvement, the vitality, the

Q. But don't you see -

A. I wanted to be needed.

Q. - he worked for all that, He sure did. I didn't.

Q. He got his degree,

A. I went back. I said, "Yes, that's me." and it's not over yet.

Q. All right. Tell me this: Have you ever been married?

A. No, m'am.

Q. Have you ever had any little kids?

A. No, m'am.

Q. That evidence that's come out about you saying something about a girl
came out there to Tulsa - did her parents' house really burn?

A. There was a young lady by the name of Gayle, in Georgia. she was
visiting her uncle, and I believe his name was Frank.  Her house, and it is
a matter of record, was burned out - not burned down - burned out. And I
saw this house, because immediately after leaving Brown Aviation, I drove
four hours - it's about 240-245 miles from that area to - this was out
near Birmingham, -just south - I forget the name of the town.  And I drove
out there while they were in the process of knocking out the windows and
the frames were charred - knocking out the middle of the living room.
What had happened, apparently was her little brother - and I may be
incorrect in this - apparently was playing with matches,

Q. Okay. Let's go say that's true, then. The hoes did burn out.

A. That is true. I can prove that.

Q. She wasn't in a bus accident, thought was she?

A. No, m'am. I never stated that. I don't know

Q. Somebody made that up?

A. That, or a misunderstanding. Jim Brown and I did not get along, and when
I left it was ugly.

Q. Well, how could he misunderstand you saying a girl is in a bus accident
and is in critical condition, and you were there next to her - and you
weren't?  How could he misunderstand all that?

A. The best person you could speak to on her circumstances would be my
pastor, and I am sure he has no knowledge of such a conversation.  I'll
tell you this much -

Q. You are saying that that entire conversation with your pastor never took
place?

A. I had a conversation with my pastor about a lot of things,

Q. But not about Gayle?

A. I had a great deal to say about Gayle. Gayle was the first casual
relationship I had had in a long time.

Q. but you never told your pastor that Gayle was hurt, or anybody else that
Gayle was hurt and critically injured?

A. The only thing I said about Gayle was that was worried about Gayle -
specifically with what she had to go back to.

Q. All right. Let's get on that bit about the Japan Air Line pilot and
co-pilot and the 747's and all that jazz.  Did you do all that?

A. I was at Nashua Aviation. - I don't know the exact date.- I am sure I
can figure it out - in a Japan Air Lines uniform..  However, on the
weekend, when I was still working for Japan Air- Lines, I managed-to bum a
ride out there. It was a kind of a crazy deal where we busted every rule in
the book.  And I was out there, and it was just before I left, and to be
very frank, a lot of this is a surprise. I'm not really prepared with any
real information, other than the fact that I was out there.

Q. You know, we got a lot of statements that You went there -

A. However, two of these people I don't even know.

Q. Well, they knew you, according to their statements

A. Everybody knows me out there.

Q. I know. I imagine you make an impression.  They said - a lot of them -
that you were there dressed up in this Japan Air Line pilot uniform, after
Japan Air Line said you no longer worked for them.

A. I think that is incorrect.

Q. Are you telling me right now - looking me eyeball to eyeball.

A. Eyeball to eyeball.

Q. That you have never worn a Japan Air Line uniform, when you were not in
their employ?

A. I can't say that, because I was - the end of my employment occurred
February 29th. I was around for several weekends - several weeks
afterwards, just hanging around and hoping, waiting for Dr. Powers and
waiting for Dr. Sexton, waiting for various things.  I had a lot of time on
my hands with absolutely nothing to do except occasionally ride observer -

Q. You mean you were still wearing the uniform, though?

A. Oh, sure. At work, though. Back and forth, at home and so forth.  The
legal fine if - I don't know how much of IASCO's records you have, and I
am rather distressed to find out how much you do have, including personal
correspondence.  But they kept me around for weeks afterwards, I don't
know. Maybe they felt sorry for me. I don't know.  All I know is that God
love them, they really were quite supportive and quite helpful and I came
in every morning in the uniform, hoping to have a word, hoping - it was
the last - I don't know, I guess it was my last stand.  I couldn't give it
up quite -that easily, and yet it was valid. It was real.  And while I was
there, I thought I did a good job. They wrote me a letter of recommendation
that was beautiful. It got me hired when I came back here, in about 20
minutes flat, in a very good company.

Q. Let me ask you this - why did you have somebody from a New Jersey
congressman's office call me late Friday afternoon, and try to change my
mind about: denying you a second request for containment?

A. Oh, boy, that's a kettle of -

Q. You should have known better than that.

A. M'am, I had early in October written a letter saying "I have just
received a letter saying my hearing is November 18th. Nobody has checked
with me on that date. I am not prepared to defend myself upon November 18th

Q. Yes, but I had already denied that request.  Don't you know that after a
judge rules, that is the end of it?

A. I do know that now.

Q. So you thought you could get that congressman -

A. I was desperate.

Q. - to judicially intervene and try to strong-arm me into changing it?
Well, he found out differently - I can clue you into that. I was ready to
report him for attempting any type of judicial intervention.  Now, you have
heard some of this testimony today? Does that sound like to you what these
two psychiatrists have said is evidence of some of this manipulative
characteristics?

A. M'am, what does a person do when drowning? They clutch at -

Q. You say it was an act of desperation?

A. Yes, it certainly was.

Q. Okay.

A. If this goes down here, I am finished in aviation. Now, it's just not a
job. I have got a good job - in fact, .it's paying more than I had been
used. to, on an average. But you're talking about a fellow who is sitting
on the airport fence at age, 8, after peddling a bicycle 16 miles out to
the airport, just looking at people and saying, "Give me a ride, Mister."
This is not a living. This is a way of life. And I have kept up with every
form of aviation. I built myself a motorized hang glider and I have been
flying the absolute hell out of that thing ever since, simply because it
doesn't require a license.  It is the only thing I am going to be able to
fly for years.

Q. Well, let me give you some Dutch aunt advice.

A. Thank you.

Q. If you are ever involved in a judicial proceeding again, don't ever
either you yourself or urge somebody else on your behalf to intervene in
that judicial decision process, ever.

A. I have no idea how the system works.

Q. Because we are rather proud of the judicial system, and the fact that it
is inviolate from any type of pressure.  That's what makes us independent.
That's what makes the system work.

A. Yes, m'am.

Q. And it's resented terribly by the judge - him or herself - and I am
asking you this question because it still disturbs me so much that I want
it on a record somewhere that I was incensed and that it didn't - it
certainly didn't have the effect that you intended.  In fact, it had the
reverse effect. I would have died before I would have changed my mind.  I
have been trying to get a continuance for six or seven weeks. The original
hearing was delayed for a great period of time, during which the Federal
Aviation Administration accrued a great deal of information which at the
time I was not prepared to fight.  However -

Q. All right. You had gone into that with just about every member of my
staff, at the office.

A. I sure -

Q. That's all been related to me.

A. I sure have.  Okay. I have asked all the specific questions I want to
ask.  Do you nave any questions that you want to ask?

MS. HAUSELT: Yes, I do, Your Honor.

                          CROSS- EXAMINATION

(By Ms. Hauselt) Mr. Campbell, where are you now employed?

A. M'am, that is none of your business.

JUDGE CAPPS: I beg your pardon.

(By Ms. Hauselt Continuing) It is my business, Mr. Campbell.

A. I refuse to answer. I've had my jobs taken away from me. This is a
non-aviation job. I do not believe the FAA is entitled to that information,
and if they find out they've got a problem or if they have a person who has
had a problem, I'll wind up on the street.  And I can't afford that. I'm
broke now.

Q. Mr. Campbell, I want to ask you a question -  Are you aware that a lot
of the testimony today has been to the effect that you do have a
personality problem - a personality disorder?

A. I am very aware.

Q. And part of the problem that you have is that you deny these things to
other people.  Now, I'm going to ask you again where you are employed?

A. Do I have to answer that question?

JUDGE CAPPS: Yes, you do, or else not take the stand.  If you take the
stand, you open yourself up to cross-examination. And if you've got a
non-aviation job that does not involve any of your certificates as an
airman, an instructor, or parachutist or any other type of FAA certificate
you have, there is nothing to fear.  Are you getting paranoid on us?

THE WITNESS: Yes, m'am.  I've lost my living. What do you expect?

JUDGE CAPPS: She has asked you a perfectly valid question.  And yes, you
must answer it. Taking the stand is not a one-way street. You don't get up
there and just answer the questions you want to answer and then refuse the
questions you don't want to answer.  You have opened the door to answer a
question. And I am instructing you to answer the question posed.

THE WITNESS: May I ask a question?

JUDGE CAPPS: I'll tell you what -

THE WITNESS: M'am, I'm scared to death -okay?

JUDGE CAPPS: All right. Look, I'll make a deal with you.  You said you were
an electronics technician

THE WITNESS: Correct.

JUDGE CAPPS: You write down for me where you are working, because you have
stated under oath that it doesn't involve any of your FAA certificates or
aviation.

THE WITNESS: That's correct.

JUDGE CAPPS: And you wouldn't lie to me, right?

THE WITNESS: I hope not.  I think I'm smarter than that.

JUDGE CAPPS: Okay - You write .down here where you work, if you are scared
of those FAA people.

(The witness wrote down the name of his work place.)

JUDGE CAPPS: Off  the record.

(Short discussion off the record)

JUDGE CAPPS: Back on the record)  I can understand his fear a little bit,
of what he has been through. He has written down for me where he works, and
it does have nothing whatsoever to do with the entire aviation industry.
By no stroke of the imagination could it even be closely connected.

MS. HAUSELT: Your Honor, I was going to just note my objection for the
record, and there is no way of verifying what he wrote down. There is no
way of knowing, and I am going to note my objection.  I think that he
should be instructed to answer my question. And I don't think that -

JUDGE CAPPS: Usually - listen, have I ever seen this type of thing occur?
No, I haven't. But I have to play it by ear and I think in this situation
this is the best way to handle it. I am certainly keeping what he wrote
down here in my notes of the record. And I want to state that I certainly
wouldn't lie on the record -

THE WITNESS: Would it help if I produced a pay stub? I might even have one
with me, or a medical card or something.

(The witness produced two documents.)

JUDGE CAPPS: He has shown me two employment documents here, that
substantiate to my satisfaction the name of the employer he put down, and
he described what he does for that outfit.  So I am willing to state on the
record that I am the first to admit that I think this is unusual, but I
think the circumstances here call for it, and that's why I did it.

MS. HAUSELT: Okay. I'll move on.

Mr. Campbell, were you ever in the service?

THE WITNESS: Yes, m'am.

(By Ms. Hauselt Continuing) When?

A. It's a good question. The latter part of 1975 to June of 1975

Q.  And where were you stationed?

A. First in San Antonio, Texas, for basic training. Upon completion of
basic training, to the Lowry Air Force Base, Colorado.

Q. And you were only in the service for approximately six or eight months?

A. There was a period of time before that - it was called "inactive." That
was from October of '74, early in my senior year of high school with the
United States Army National Guard, 3rd/104 Armed CAB, that was at the time
- they've since been reassigned.  I made a switch from Army to Air Force
in June of that year. I didn't go until November. I was trying rather hard,
and in -fact even succeeded in getting a nomination to one of the service
academies, which was the reason for the period of time with the military.
That attempt was unsuccessful

Q. And Mr. Campbell, you were terminated from the armed services.  What was
the reason for that?

A. It was an honorable discharge.

Q. What is your military service number?

A. It would be the same as my social security number - 146524672.

Q. Mr. Campbell, do you have a copy of the record which I gave you - the
Administrator's copy of your medical file?

A. I've got quite a bit of information here. If you'll call my attention to
where it is -

Q. Mr. Campbell, I want to refer you to page 103 of that medical file.
Specifically, I want to draw your attention to Section Number 11, and what
did you indicate was your service?  Did you indicate on your application
that you had served with the Air Force or the Army at any time?

A. At the time, I wasn't, though.

Q. At any time did you indicate that you were part of the armed services -
at any time?

A. During the period of time when I was a member

Q. On the application itself, you checked the blank, "None," under -

A. "Extended active duty" - yes.

Q. And you also - you did not put down your military service number.  Is
that correct?

A. That's correct.

Q. Now, the next application, on Page 105, you also did not put down any
military service number or indicate any prior military service, did you?

A. That's  correct.

Q. And also on your application on Page 107, you again did not indicate any
armed service, did you?

A. Correct.

Q. Mr. Campbell, while you were in the service you were never at Viet Nam,
were you?

A. No, m'am.

Q. And you never received a shrapnel wound to your face, did you?

A. No, m'am. Tree branch, but not shrapnel.

Q. Mr. Campbell, have you ever been wounded in any way?

A. I have been hurt several times in various ways.

Q. Have you ever received a gunshot wound?

A. Not that I know of.

Q. Mr. Campbell, isn't it true that you had some scuba instruction from a
Detective Larry Brown?

A. I had no scuba instruction from Detective Larry Brown. Let me give you a
little background here -

Q. No, I'm not asking you for background.  I'm merely asking you -

A. I received no instruction from Detective Brown. I received an
evaluation, nothing more.

Q. And you are telling me that you did not tell Detective Brown that you
had received a gunshot wound while taking various dignitaries around
Nevada?

A. I did not state to Detective Brown that I was taking any dignitaries
anywhere.

Q. And you did not indicate to him at any time. that after he confronted
you with the fact that he could not verify your original story, you did not
indicate to him that you had been involved in an altercation between a
Mexican man and woman - a domestic quarrel in which you were shot?

A. At the time, I was involved in an altercation.  A gunshot did not occur.
An injury did occur. The altercation is past history.

Q. There was an injury to you?

A. That's correct.

Q. Didn't I just ask you if you were ever injured or wounded, and you said
no.

A. It's - you said - "gunshot."  I said no.

Q. Where were you injured?

A. Upper right portion of the thigh.

Q. And that was in the course of an altercation in Nevada?

A. That was not exactly where it was.

Q. It was - I believe you told the Detective Brown, at - Field.

A. Detective Brown asked for information. Larry Brown was supposedly a
"friend." I supplied him -

Q. Did you ever tell him that, yes or no?

A. I told him that, yes. To throw him off the track, yes.

Q. So you felt he was asking you too many questions and you made up a story
to throw him off the track?

A. Oh, very definitely. I was scared to death.

Q. I see. Mr. Campbell isn't it also true that you never mentioned this
injury to Dr. Powers in your interview with him?

A. That's correct. I had frankly forgotten all about it. It was not that
serious and I haven't thought of it up until this point, or until it was
brought up today, which was why that statement was such a surprise.  And it
very much was.

Q. Okay. But you never indicated that you had been injured in any way, to
Dr. Powers?  Isn't that correct? Other than the operations that are listed
in his report.

A. As far as I know, that is correct.

Q. Have you ever received any other injury other than the one we know
about, where you were sky diving and you injured your head?

A. There was one puncture wound to the face, in the cheek.

Q. And that was what you referred to, where you were hit with a tree limb?

A. By a tree limb - puncture. I was riding Reserve at the time.

Q. Okay, Mr. Campbell, I want you to take a look at Page 40 in the file
that we have, and under your employers at the top of Page 40, you listed
Screen Actors Guild, did you not?

A. That is correct. I did.

Q. And you listed as the reason for leaving, "too many injuries."  Is that
correct?

A. Correct. That is absolutely correct.

Q. Your episode in attempting to jump off the World Trade Center, in
November of 1977 - you were involved in several helicopter flights around
the World Trade Center.

A. We were in the vicinity of the heliport, which is located not too far
from the base at the World Trade Center.

Q. Suppose I were to tell you that to be doing that, you would be in a
restricted area ?

A. We were within the regulations, according to the pilot.  I was not the
pilot in command.

Q. Mr. Campbell, you never made any arrangements with authorities in order
to make that jump, did you? -such as clearing the street below of
pedestrians.

A. It was already cleared. Filming for "The Wiz" had been completed that
week. The entire area was  barricaded. All doors to the plaza were locked
with chain and lock. It is a matter of police record.  As, a matter of
fact, complaint was made with the Daily News for printing different
material than that. But there was nobody, not a soul, in the plaza at the
time the jump would have occurred.  It is in the police record.

Q. Okay. Mr. Campbell, that is a matter of police record, is it not,
according to you?

A. It would have to be. They finished filming "The Wiz" right then,

Q. And you didn't make any effort to bring any police records with you,
with regard to your jump, did you?

A. I had no idea that this was going to be brought up. However, a call to
- a call to a Patrolman Al Hallker at the World Trade Center might be able
to clear this, up.  It's got to be record that .

Q. Mr. Campbell, I would prefer, and it is the proper protocol for you to
merely answer my question, not to volunteer extraneous information.

A. Excuse me,

Q Now, Mr. Campbell, I understand that there have been two successful jumps
off the World Trade Center?

A. That is correct.

Q. And one of those was by an unidentified person in the fall of this year?

A. That is substantially correct.

Q. And that person wouldn't have been you, would it?

A. No, it was not. The person has been since identified, and used my
methods and is familiar with the research that I had done.

Q. But you yourself never made a successful jump off the World Trade
Center?

A. Not off the World Trade Center, no.

Q. But you yourself did tell other people on the West Coast that you had
made such a jump successfully, didn't you?

A. No. That is not true.

Q. In October and December of 1978, you were living in the Tulsa, Oklahoma
area.  Is that correct?

A. That is correct.

Q. And you posed as a doctor at that time?

A. Occasionally, yes.

Q. And at that time, did you or did you not give people drugs?

A. Would you please define "drugs?''

Q. Any kind of over the counter or prescription drugs.

A. An over the counter drug in the form of Tylenol, yes.

Q. And at that time you indicated that you were giving someone treatment
for "female problems," did you not?

A. That is incorrect. The offer was extended, the treatment never occurred.

Q. But you offered the treatment, did you not?

A. It was -

Q. So what you say is that you offered to prescribe drugs, but you never
actually prescribed them?

A. No, no.  No drugs were ever offered to be prescribed - not that I know
of. And my memory of this particular incident is fairly clear.

It has been dragged up many times.

Q. Mr. Campbell, isn't it a fact that you offered yourself as a doctor to
various acquaintances and friends?

A. I have offered to help them, yes,

Q. And in fact you offered to help a woman who'd had a heart attack?

A. That is incorrect.

Q. A woman who had suffered, shall we say, an incapacitating -

A. Pulmonary embolism.  I portrayed myself at time as a medical student. I
rendered the proper first aid. I didn't ride in the ambulance to the
hospital.

Q. But you never - to the scene, did you not?

A. That was where I was working.

Q. And you at that time told people that you were medical resident?

A. No, that is incorrect. I said "medical student."

Q.  Medical student?

A. That is correct.

Q. Mr. Campbell, didn't you offer also some medical treatment to a young
girl who had received a severe cut by bumping her head on a propeller?

A. It was on a rotor blade on a helicopter. I offered to go get some
aspirin and instead got Tylenol.

Q. And you didn't indicate in any way that you would be offering her a
prescription drug?

A. No

Q. So what you are saying Mr. Campbell, is that this article that was
published in the Tulsa Tribune is substantially and largely based on false
information?

A. Its content is basically correct. Individually, there are quite a few
inaccuracies.

Q. Mr. Campbell, did you ever undertake to sue the Tulsa Tribune for libel?

A. We had spoken - my folks, had spoken to an attorney. I was under the
impression that suit was being undertaken.  At no time have I called the
Tulsa Tribune, and such legal action is still under consideration. It just
needs somebody to pay for it.

Q. Mr. Campbell, what if I were to tell you that the Tulsa Tribune stands
by their article as being accurate and a fair representation of fact?

A. Then they're going to have to produce their source, aren't they?

Q. Perhaps if you sue them.

A. I'd like to. I wish I could afford it.

Q. Mr. Campbell, after your masquerade as a doctor, you went home with your
father, didn't you?

A. I went home first. My father then went to Tulsa, Oklahoma, and returned
with a great deal of my belongings.  I went home before the incident became
public knowledge.

Q. Okay, Mr. Campbell, I want to talk about what you were doing in the
summer of 1974, up through the summer of 1976.  What were you doing at that
time and where were you living?

A. '74 to '76 -- good question - I was in the neighborhood of Colorado -
most of it - let me think. Colorado until late summer of '76.  That is
correct.

Q. And then where were you?

A. A combination of home and - during the weekdays, and at the drop zones
on the weekends.

Q. Mr. Campbell, isn't it true that you never indicated that you were
anywhere other than living in Colorado, to Dr. Powers during that period of
time?

A. Could you restate it?

Q. Yes.  During the period of time from summer of 1975 up to the summer of
1976, you told Dr. Powers that you were living in Colorado, attempting to
pursue a relationship with a girl named Ellen, did you not?

A. That is incorrect.  The girl's name was Evelyn, and I was attempting to
pursue a relationship with the young lady -

Q. And you at no time indicated to Dr. Powers that you were in any way
affiliated with the armed services, did you, during that time?

A. I was affiliated with the armed services at the time. I was stationed at
Lowry Air Force Base from sometime in January of '76 to June 22nd, 1976.

Q. And you were living in the San Antonio area, were you not, for awhile?

A. About six weeks, for basic training, yes.

Q. And you never mentioned that fact to Dr. Powers.

A.  No.  It did happen rather quickly, and I did forget about it.
Everybody wants to forget basic training.

Q. Mr. Campbell, it was during the fall of '77 you made your attempt to
jump off the World Trade Center, is that correct?

A. That is correct.

Q. And then you moved to Oklahoma in the fall of 1978?

A. No. I moved there in the spring of 1978, and I believe I left New Jersey
May 28th - about three weeks after -

Q. But it was in December of 1978 that you finally returned from your home,
from Oklahoma to your home.  Is that correct?

A. That is correct.

Q. Okay, Mr. Campbell, I want to refer you again to your application for
employment.  And that is on Page 39 to 40 of the record.

A. Yes, m'am.

Q. Mr. Campbell, on that application for employment, did you not indicate
there that for the period of time from June of 1976 up through December,
1978, you were employed by the Screen Actors Guild in Burbank, California,
and you left that because of too many injuries?

A. That is correct.

Q. And you mentioned nothing about the fact that you were in Oklahoma
during that time, you were in basic training during that time, you were in
Texas during that time?

A. It certainly wouldn't have helped my application

Q. It certainly wouldn't have. I'll agree with you there.  Mr. Campbell -
you haven't received any injuries during the stunts performed for the
Screen Actors Guild, did you?

A. I have already stated that - no.

Q. Okay. Because you haven't worked for them.

A. That is correct.  Besides, nobody works for them.

Q. Mr. Campbell, you are not and you have never been a parachute rigger.
Is that correct?

A. That is correct.

Q. And on your application for employment with Nashua Aviation, you did
indicate that you were an FAA senior parachute rigger, didn't you?

A. I had intended to be, within two weeks, yes.

Q. But you were not, at the time that you filled out the application?

A. No, I was scheduled for a course.

Q. Mr. Campbell, referring to your use of the Japan Air-Lines uniform, you
were not employed by Japan Air Lines on April 18th and l9th of 1980, were
you?

A. That is correct.

Q. And in fact on April 9th, you sent a letter to Japan Air Lines
indicating that you would return your uniform at a subsequent date?

A, Yes, as soon as I got some stuff on the West Coast, yes.

Q. And have you ever returned that uniform to Japan Air Lines?

A. No. It is still sitting in an unopened box in the corner of my room.

Q. Mr. Campbell, did you ever tell anybody up at Nashua Aviation that you
had been flying 747's for Japan Air Lines?

A. I stated that I was one of the flight instructors involved in teaching
flight engineers for various aircraft, including Boeing 747, how to fly, or
was going to be.  And I was working at the time with captains and first
officers who were constantly flying those machines.

Q. Mr. Campbell, didn't you tell people at Nashua Aviation that you in fact
had come in on a plane from Boston, and that you were involved in the
Falcon Program at NASA?

A. It is no secret that I wanted to be in the Falcon Program; in fact,
while I was at IASCO, I made a couple of motions toward that area.

Q. Mr. Campbell, in your desire to attain that goal, isn't it possible that
you told people that you had already attained it because you thought you
would be attaining it soon thereafter?

A. I do not think so.

Q. Mr. Campbell, since you have been back in New Jersey living with your
family, what have you been doing in the aviation area?

A. I am very active in ultra light technology - design and testing - and
a whole lot of flying.

Q. And have you been involved in anything else with regard to hang gliders
other than testing and designing?

A. Just flying.

Q. Flying them yourself?

A. Oh yes. Very much so.

Q. Any other kind of organized activities?

A. Not yet. I am hoping to get an air race going is spring. It's in the
planning stages.

Q. Mr. Campbell, at the time when you were down in Georgia, and you were
involved with the young woman by the name of Gayle, she was never in the
hospital for any injuries, was she?

A. No. I have stated that.

MS. HAUSELT: May I have a minute, your Honor?

JUDGE CAPPS: Yes.

Q. (By Ms. Hauselt Continuing) Isn't it true that when you left Western
Piper Sales, you had at least $100 or more of phone calls?

A. Which were paid for, yes. In fact, I may even have the receipts with me.

Q. When were they paid for?

A. Prior to my leaving. In fact, by several weeks, in any case.

Q. Isn't it true that when you were originally confronted with those phone
bills, you denied that they were yours?

A. I did not deny that they were mine. I denied the fact that I did not
have authorization for the calls.  I did not have a phone in my apartment.
I had explained everything to Diane and she said either use a HARTS line or
write it down, which was done.

Q. Mr. Campbell, isn't it also true that when you left Nashua, you left
over $165 of phone bills there?

A. That's absolutely correct, They also owe re money.

Q. So those phone bills were never paid?

A. Neither was my paycheck.

Q. Mr. Campbell, just answer the question - Were the phone bills paid?

A. Those phone bills - no.

MS. HAUSELT: Your Honor, I have no further questions for Mr. Campbell.

JUDGE CAPPS: I have no further questions, either.  You will be able to give
a closing argument now.  Did you have anything else that you wanted to
state under oath?

THE WITNESS: Can you give me a moment, just to check through here? I've got
some notes here - I just want to check with them.

JUDGE CAPPS: Okay. We can take a five-minute recess.

Off the record.

(A five-minute recess was taken.)

JUDGE CAPPS: Back on the record.  What is it you feel should be brought to
my attention?

THE WITNESS: Specifically, throughout the entire history has been presented
- at no time, in my opinion, have I jeopardized the safety of someone in
my responsibility.

JUDGE CAPPS: Oh, that's a closing argument,

THE WITNESS: That's a closing -

JUDGE CAPPS: Yes.

THE WITNESS: I didn't know if that was -

JUDGE CAPPS: Yes. That is a closing argument.  Why don't you hold that in
advance and give it to me in the form of a closing argument?

THE WITNESS: Okay. Fine.

JUDGE CAPPS: Does the Government wish to give any closing argument?

MS. HAUSELT: Your Honor, I will just speak in rebuttal.  I don't have very
much to say in closing.

JUDGE CAPPS: All right. I'll allow that.  All right.

THE WITNESS: My ball?

JUDGE CAPPS: Yes.

THE WITNESS: All right. I could probably go through each one of these
documents one by one and pick out inaccuracies. However, for every
inaccuracy there is going to be a truth as well, which is equally as
damaging.  The problem has been that each time after the awareness of a
problem came to me that it was always going to he the next place that was
going to be better; the next place was going to be different, and I was
going to make a change.  Slowly but surely, it's been happening little by
little by little, the problem is that during this process quite a bit of
information has to light, and a great deal of it is unfavorable, and
unfortunately a great deal of the unfavorable is also true.  This means
that most probably I expect to lose my flight privileges for the great
majority of time after. What they are trying to prove-they being Ms.
Hauselt and Dr. Powers and Dr. Pakull-is that I am an unsafe pilot, to
which I can only rebut that I have handled -

JUDGE CAPPS: Wait. Let's get something straight.

THE WITNESS: Yes, m'am.

JUDGE CAPPS: I want you to know the issue here.  That is not what the
Government is saying. That is not what this has all been about. Nobody has
said you were an unsafe or unqualified pilot, as far as your piloting
techniques go.  What they are saying is that you are medically unqualified
to pilot an aircraft, due to certain disorders here - personality
disorders.  But they tried to establish through evidence of overt acts -
and you've sat here and listened to the overt acts - that have been
alluded to. So I just want you to know: that nobody is arguing about
piloting techniques.

THE WITNESS: All right. Most specifically in response to being medically
unqualified, at one time I would have probably agreed with the FAA and
their investigation, especially in weight of the evidence, it is certainly
warranted.  However, I believe and I still believe now, that I can within
the letter of the law, as far as the medical certificate goes, safely and
legally execute the privileges as underlined by my medical certificate.  I
realize that this disagrees with several learned gentlemen with a great
deal more training in the area of human behavior than I do, but I like to
think that I know my own mind.

There are several areas of contention throughout this entire proceeding,
which - not the proceeding here, but over the past year - which I find
questionable.  Specifically they are Dr. Kagill's statement of having
received medical information on October 10th, when no information was
received until the 12th.  The seizure of a certificate when the certificate
excuse me - the seizure of a certificate before that seizure was made
known to me, specifically taking the certificate and then giving me the
order of suspension; not offering me the opportunity to surrender the
certificate as ordered, within the letter of the law.

There are several statements - Mr. Brown, Mr. Piper, Nashua - and
statements related to the Aircraft Owners and Pilots Association and the
United States Parachute Association.  Briefly I worked for Mr. Brown. I did
a good job for him as long as I was able. The last month there was a big
change, and the change was in both of us. Specifically, I couldn't stand
him and he couldn't stand me.  he causes, in my opinion - 1. my inability
or my refusal to bend to what he wanted; his extreme displeasure at the
affair with his daughter; his extreme displeasure with the fact that I had
allied myself with John Williams in response to several pay demands, and so
forth; my refusal to cover for him on a few matters with his wife; my
refusal to cover on some 135 instances, and so forth; also some questions
on maintenance - not many.

Western Piper specifically - I was promised a lot and given very little.
Western Piper - there were problems there, and most of them were mine.
However, Western Piper also provided aircraft with extreme maintenance
problems resulting in a forced landing in a Seminole, due to the fact that
right after a 100-hour inspection the right engine turned rich - the
carburetor heat control on the right engine was inoperative, going to "Full
On" - presenting myself with an aircraft with a right engine so rich it
was loading up, and running so rough that it made an emergency landing
necessary.  I cut the propeller and landed. But in evidence of that, there
was another pilot in the aircraft, a Ron Sterling, a multi-engine student,
and he was shaken all the way on down. So I am pretty sure that was not my
imagination.  In response to Western Piper's accusation concerning the
Tomahawk, to my knowledge the FAA did not inspect the aircraft at the
scene, specifically because of a city .and a truck stop right next to route
whatever it was - I think it was 51 - and it was in West Virginia, and
not Maryland.  The factory certainly never saw the aircraft.  That is a
fact

Nashua - there is very little I can say about Nashua except for the fact
that there was a lot of confusion and a lot of misunderstanding, I loved it
there and leaving it was very hard.  However, I created a great deal of
situations on my own, simply because of my - not being able to swallow my
pride enough to say what had been following me was not true.

AOPA - I never worked for them; I did attend many of their ground schools.
United States Parachute Association - in my resumes and publicly, I have
represented myself as a USPA-certified Instructor. I did attend, complete,
and pass the United States Parachute Association certification course, for
the jump master/instructor certificate, in addition to competing at the
Nationals and being a staff member at the Nationals, and competing in
several conference meets, and so forth.

The USPA also made statements concerning - about a reserve. The reserve
listed on the card - whatever it was - was a secondary reserve. It was
the one meant to be cut away. It was kind of a joke to write down a packing
card.  Emergency deployment means it is deployed under emergency
circumstances - exact same thing - a cutaway followed by a short period
of free fall, possible instability and a subsequent reserve pull with
deployment. Both came out beautifully. The card was removed unbeknownst to
me, which indicates to me a serious problem, because anytime anybody
tampers with a rig, whether it is the reserve or not, that indicates a
grave problems to me.  And if anybody ever - if I ever catch anybody
messing with my reserve, they've got some problems.

Psych evaluations done by Dr. McKnight and Dr. Lundey, Dr. Dorsey, and Dr.
Schwartz would seem to downplay a problem, and I would seem - well,
personally I don't downplay it as much as they did, to be very frank.
However, I do not see myself in as bad a situation as Dr. Powers portrays,
to my apologies.

Throughout this situation there has been a great deal of questions raised,
and I believe a great deal of information covered under the Privacy Act
that has been given to the various people in the course of this
investigation, and I am very curious about that.  If you are trying to
ground everybody that ever jumped off a building or similar - you're going
to have to ground about ten pilots, and two of them are flying for major
airlines.

And as far as the World Trade Center is concerned, I have not attempted it.
I had the opportunity a short time ago, when called by a gentleman saying,
"Hey, let's go do it."  And the temptation was very great, but I have no
desire to spend another night in jail like I did then. I have no desire to
get myself in the same kind of problems as the failure - and it was a very
real failure to me - presented itself after the World Trade Center.  And
it was a defeat, not so much because I didn't do it, but because that it
was done for all the wrong reasons - under all the wrong circumstances.
Under a legal situation where there would be no legal encumbrances, I would
love to try it.  However, I do not see that happening.

I do believe that a great amount of statements issued; a great amount of
the testimony simply has been prejudiced by the fact that anybody having a
mental health problem or mental illness in this country takes on the
proportion of social leper.  Mental illness has become a social disease,
and I expect to spend quite a bit on the ground in the next few years,
maybe trying to do something about it.  I don't know. I have no idea how,
but I would like to get involved.

Tulsa Tribune - a lot of that is ridiculous. And it is so easily
disproven. For instance, I never had a grandfather who lived in
Massachusetts. That's one thing.  Riding in an ambulance to a hospital -
well, there were three people, as well as two people in the room where I
was working as a desk clerk in a motel, trying to raise enough for the rent
while I was flying on my GI bill and so forth. And there were three people
from the hotel, two people in the room and two people in the ambulance, and
they know damn well I didn't follow them in the ambulance.

Other situations - I am going to keep it short - specifically, the
newspaper article leaves a great deal to be desired. Its basic content is
true.

I  have found throughout the entire situation with the FAA, and maybe this
is a little self-centered - in fact it is a little self-centered, but
right now I've got nobody else - and I really wonder how much damage has
been done to me personally, specifically whether or not I deserved it.
People are aware of situations; people are aware of things that may or may
not have happened. And that worries me a great deal. I object to a personal
letter being used in evidence, especially one that was sent to a friend.
And I would appreciate it if the Court would please understand one thing -
there is a great difference here between mental illness and trying to get
yourself out of an unsavable situation.  My fabrications were bouncing down
on me. They were rolling up like the proverbial snowball downhill. And it's
so hard to escape. And it's so hard to deal with it.

And until you have dealt with mental illness, you have never had a fight in
your life like that. Specifically, I didn't know how to stop. I am
beginning to have an inkling. But I am in control when necessary,
specifically when I step inside an airplane.  And nobody will ever believe
I can separate the two. But all I know is through eight parachute
malfunctions, over a thousand jumps which are logged and verified, through
a couple of thousand hours of, flight time, and a total three incidents
requiring some type of emergency or sudden correction, no damage has been
done to an aircraft.  I've not damaged anybody else. And I personally
haven't hurt myself, other than walking into a wingtip.  Airplane problems
- I've never had an airplane problem that wasn't justified - I have made
more than one precautionary landing, simply because the engine was running
weird; didn't call emergency to land it, just to play it safe.  I consider
that to be fairly smart, and something I taught my students - if they had
a problem, come on hack, we'll talk about it, we'll look at it. feel silly,
but don't -

Scuba diving - Larry Brown - I received instruction from a Mr. Bill
Dailey on Route 17 in Ramsey, New Jersey, several years ago. Mr. Dailey is
no longer employed by that same firm. I do know roughly where he is. I
never received my license from Mr. Dailey, having paid for the course;
completed the course and have been on almost a dozen dives since, total.  I
did complete the written exam and so forth. Mr. Dailey has disappeared. And
we know roughly where he is and so forth. I never received a license, but I
did go through the course.  It is not required When I met up with Larry
Brown, I had indicated a desire to be an instructor in that area.  In fact,
he and Conrad were in the process of trying to find me a course. And I
don't know what happened to Larry. I thought he was a good friend.  He may
be my best friend, maybe, by trying to help me. I really don't know.

There were certainly quite a bit - there was certainly quite a bit of
misunderstanding. I'm not a con man. I've had problems. And I'm still going
to have problems and I've got the biggest fight ahead of me that I've ever
had, especially if I'm going to have to do it on the ground.  But let's not
look at this with a malicious intent. I'm not a malicious person - I don't
go around kicking puppy dogs and knocking little girls off door steps or
whatever you want to call it, whatever the case may be.  My problems - in
fact, very often the only control I ever had was simply to avoid somebody
being hurt. And Tulsa came to a very rapid conclusion when I hurt my
parents and my grandfather, which was the ultimate slap in the face.  There
have been - I really question the methods and how this information was
accrued, specifically  the FAA has made several statements with names
wrong, dates wrong, places wrong and so forth.  And that does accumulate
over a period of time.

Just to reiterate one thing- the World Trade Center plaza was cleared.
They had just finished filming "The Wiz" the week before. It was a great
amount of damage done in the plaza; I tried to get in the plaza, frankly,
to get pictures from the bottom looking up. I couldn't. All the doors were
locked, number one. The plaza was barricaded off, number two.  There were
police barricades and everything else. It was barricaded off. I am sure you
can verify this. I know you can verify this, because of the fact that
something I brought up because one of the policemen took this whole thing
as a personal vendetta for about 20 minutes, and I heard a few words I had
not heard before.  I explained to him my research.  There was a great deal
of research done. It was a wrong thing, because it was illegal and because
there was a possibility of hurting people to the extent that my family was
shamed.  I was shamed and I wound up in jail. That was the wrong - well,
landing in jail was not wrong. It was the stunt itself. It was illegal.  -I
did go through a great deal of preparation, Flying in the neighborhood of
the World Trade Center - it is not a restricted area below 1,100 feet, as
long as you are in communication with the heliport nearby.  And you would
be surprised what you can find out in a chopper. We were curious to find
out a few things, in that general area.  The general idea was to drift away
from the Trade Center toward the river; land by the road next to the river
or in the river where a boat was going to be, and disappear.  It was not an
ego stunt.  It was just to do it.

Going back to one other thing - Daniel Webster College, which made so many
charges, and so many things - first of all, several of the letters in here
that Dr. Schultz supposedly sent to me, "Jim, we need your resume, Jim, we
need this, Jim, we need that."  I never got them. In fact, I didn't even
find out I had a mailbox at that place until October 4th. somewhere - 3rd
or 4th - I'm not ever quite sure because I remember something happening
about then.  I never got a great deal of information; in fact, Dr. Schultz,
very few times. I did enjoy quite a bit of support among the students,
partially because of the fact that I was carrying on a bit of a charade,
and partially because of the fact  that  I had hoped to give them
something. I had really wanted to do it. It was my intention to run a safe
and non-profit parachute operation .  I really wanted to teach these kids
to jump. I love it and I like to share something I like.  DWC certainly was
in a large hurry to finish this whole thing up. Under Federal regulations,
the college receiving Federal funds - specifically bank loan funds and so
forth - I was supposed to get a hearing in 10 days, which I never got.
There were quite a few irregularities on the part of DWC, so I certainly
throw very little weight to their testimony because simply I think they are
covering themselves in a lot of respects.  Granted, there is a lot true,
but there is a lot of prejudice in there as well. And they did wind up
paying me for the entire semester. I got almost $800 -$800 or $600 some odd
dollar check from them to my lawyer.  So I'm sure they felt they had goofed
somewhere along the line, when they made that settlement.

Finally, the only thing that I've ever wanted to do - I've talked about
sitting on an airport fence when I was high as a grasshopper, and it is not
kidding.  And I'll still fly, for the rest of my life, in one form or
another. I've got a little ultra light hang glider, and I'll be flying the
hell out of that, and that's about all I can do.

I would appreciate not losing my privileges. Frankly, if I keep my medical
certificate, I will not be going straight back into the air. I will be
staying with the West Bergen Mental Health Center. I will be speaking with
my grandfather and I will be consolidating some cash assets, simply because
the job I have right now is doing fairly well and I am due for a promotion
and and I have no reason to think that I won't get it.  At any rate, my
intention to improve the situation. I have finally taken the big step. I
think the hardest step is to do something that I didn't have to do.  Maybe
that is the key to it, because I am a person motivated simply by what I
have to do. And when I don't have to do something, it doesn't get done,
frankly.

JUDGE CAPPS: What did you do that you didn't have to do?

THE WITNESS: Submit myself for treatment at the West Bergen Mental Health
Center.

JUDGE CAPPS: Okay.

THE WITNESS: They say that the mind is a terrible thing to waste and I
couldn't agree more in this one particular circumstance.  Everything that I
have ever done has been geared to aviation, from model airplanes running on
up to pacing the local - for citations, whatever the case may be.  I have
pulled my ratings pretty much all by myself. The GI did help me out with
some of them; however my benefits were limited.  I have spent a great deal
of money and a great deal of time and a great deal of emotion packed into
this whole line :of process - I have learned a lot about flying, but added
to it some discipline.  Some of them obviously didn't work out too well. I
really believe that at this time I can keep my stuff straight. Sometimes
maybe a mental problem is as hard a monkey to carry as any.

But the fact of the matter is that I do not want to be a social leper. The
fact of the matter is that I am a marked man with a waiver. If I get this
waiver on me, that pretty much rules out any possibility of Federal
employment. I can pretty much rule out any type of airline employment. I
can pretty much rule out just about anything.  Now, frankly my desires are
not with airline employment. I was too much of a teacher. I enjoyed it too
much.  But my options are extremely limited and this leaves me practically
nowhere to go, even if I eventually get it back.  And from the situation
described, it's going to be many years. I really don't know how many years
he says - Dr. Sexton at one time in an interview said six months. That has
long since gone by the wayside. The fact of the matter is that I don't
believe I will be flying for many years.

I don't want to lose that. Even if I can hold just a normal third class, I
don't want to lose it. It is the motivational force in my life. More than
one the funny thing was, about Tulsa, Oklahoma, and coming hack - it was
work with Dr. Dorsey, work with my grandfather, and work on those readings.
And slowly but surely a few things changed.  Not all of them - no. It is a
long, slow process, but they did change. There was change, there was
improvement. Maybe not enough.  I don't want to lose this. This is not a
living, it is a lifestyle, it is a way of life that has been since that
high.  However, I do believe that I am not a danger to anybody. I do
believe that I am not dangerous to myself, at least in an aircraft.  I may
still wind up destroying my own mind. That's a possibility I won't rule
out. The whole point is that I know the problem exists. It has been shoved
up my nose all evening, and for the past year.

And you have never had to do anything until you go to the man you love most
in this world and say "Hey, I've got a problem," especially when he comes
back and says, "you have one hell of a problem."  I want nothing more than
to fly and to know that I've got my stuff straight.  Maybe I can't do both
right now, But, eventually I hope to.  And if this court does rule against
me, I would appreciate one particular courtesy, and that is that the
responsible people will please enable some type of aid or guidance to
enable me to take a place in the so-called normal outside world eventually,
instead of telling me what I can't do or what I did do or what is wrong.
Tell me what I can do to make it right; how to correct the situation.  That
is all I have to say.

JUDGE CAPPS: Ms. Hauselt?  And the record will reflect that this is
rebuttal.  I, say this because I don't usually allow rebuttal. But since
you didn't have any direct argument -

MS. HAUSELT: Your Honor, while I did not make any objections to hearing Mr.
Campbell's closing argument, I would point out that much of his statements
concerning his desire to fly are really irrelevant.  And while he Does have
the sympathy of people involved here, I think that we have to look at the
medical issue.  Throughout his testimony ,and also again in his closing
statement, while he says on the one hand to us that he recognizes the
problem, in the course of cross-examination and in the course of his
questions it is clear that he fails to understand the significance of his
mental illness,  Just - I think one question I asked him, which in
particular capsulizes this failure to understand, is when I inquired of him
concerning his falsification - his application to Nashua Aviation and why
he did not put down anything in regard to his living in Oklahoma; why there
are various discrepancies there.  His response was "Well, I wouldn't have
gotten the job if I put that down." That is the whole point. This is the
person who with the illness he has, is quite capable of manipulating the
systems in which he operates and manipulating the people that he meets.

He attempted to do this with Dr. Powers. He has attempted to do it today.
He has attempted to do it in talking to people on the telephone to get
interviews. He attempted to do it from what you have said, with indirectly
- to you.  This is the type of behavior we are talking about, and this is
again further manifestations of the problem and further indications that
the problem is not understood by him.  But even were we to conclude that he
understands that he has a problem, we have to look at what we have before
us in the record. And I chose to just do a rebuttal. I don't think it is
necessary for me to list all of the acts and all of the behavior that Dr.
Powers detailed in his testimony.  They are a matter of record. The fact
that there may be some minor inconsistencies in what some of the people
said, none of us can prove.

It is a miracle that we have the evidence we have, based on the trail that
had to be traced around the United States.  The interviews that he spoke
of, with the other doctors who interviewed him, I submit to Your Honor that
these doctors simply had a version which Mr. Campbell handed them - a
version he would like them to believe.  And close scrutiny of those reports
shows that those doctors were not aware of Mr. Campbell's complete history.
There is a pattern that appears in the record. It is a pattern of recurring
behavior and that pattern is not something that is likely to change, and I
think even Mr. Campbell's behavior here today is indicative of that
problem.

He has admitted some of the falsehoods; denied others. I think the point is
not whether a little particular fact A is true or false. What we have here
is a pattern.  And all of these parties have not - people who don't know
each other; people who live all over the United States have not come
together in a huge conspiracy to point out that Mr. Campbell has a problem.
These incidents are things which Mr. Campbell must take responsibility for,
and I think his testimony indicates that he is not clearly ready to do
that.  That is why I say that it is clear that his personality disorder
persists and is severe and does manifest itself in these behaviors which
Dr. Powers set forth.

On the issue of Mr. Campbell's operation of an aircraft, we are talking
about medical qualifications, And they are numerous - as Dr. Pakull
relates -things in the file which indicate that Mr. Campbell has poor
judgment.  But there are also indications that he has poor judgment with
regard to his own personal safety and with regard to the safety of others.
You do not open - or hold yourself out as a person who can operate a
parachute club when you are not currently certified by the U.S. Parachute
Association.  You do not sign in an emergency chute when you are not a
parachute rigger, you do not put down on an application that you are a
parachute rigger, when you are not.  These are the kinds of behaviors that
show us that this person in an airplane simply cannot be trusted.  His
judgment is just inadequate.

Mr. Campbell is not just here because he attempted to jump off the World
Trade Center. While that event is one of many and while it points out the
pattern of behavior we are talking again about a variety of incidents.  We
are talking about an incident which is one of many. Mr. Campbell said, I
believe, that there are two questions here - his mental illness versus an
unsolvable situation that he spoke of - and referring to this unsolvable
situation, saying that that is why he felt the necessity to fabricate all
these stories.  The unsolvable situation was kind of snowballing as the
effect of all these stories that he was trying to get away from.  Well, the
fact that he would interpose those two things as separate things is again
an indication he does not understand that those fabrications are an
integral part of his mental illness.

It is not two separate things. So your Honor, I would submit to you that
the evidence is overwhelming.  There is no medical evidence from Mr.
Campbell. He is simply someone that in good faith we cannot put in the air
and cannot allow to be instructing other people in the air.  And I would
ask Your Honor to uphold the Administrator's order of revocation.

INITIAL DECISION AND ORDER

JOYCE CAPPS,- Administrative Law Judge:

This is a proceeding under the Federal Aviation Act of 1958, as amended,
wherein James Richard Campbell, Respondent herein, has appealed the
Emergency Order of revocation dated April 11, 1980, which has been filed
herein as the Complaint.

The Administrator is alleging that Respondent, due to an established
medical history and clinical diagnosis of a personality disorder that is
severe enough to have repeatedly manifested itself by overt acts, is not
qualified for an airman's medical certificate under sections 67.13, 67.15
and 67.17 (d) (1) (i) (a) and Sections 67.13, 67.15, and 67.17(d)(1) (ii)
of the Federal Aviat,ion regulations,

After due notice to the parties, this matter was heard on November 18, 1980
in New York, New York, at which time the Administrator was represented by
Sharon Hauselt, Esquire, and Respondent elected to procede pro se.

There has been a lot of evidence presented by the Government:-in
furtherance of establishing its claim in this case. Said evidence came in
the form of testimony by Sandra Ann Taylor, an aviation safety inspector in
the Portland, Maine, General Aviation District Office, who testified as to
the results of a rather extensive investigation conducted by here in
connection with this case.  There has testimony from two well-qualified and
Board-certified psychiatrists, Dr. Thomas R. Powers from San Francisco and
Dr. Barton Pakull from Washington, D.C.

There is little doubt in my mind, from the evidence that has been presented
in this case, and in many instances from the Respondent's own admissions
and testimony, that there is sufficient overt acts to convince me that they
were the result of a personality disorder which the two psychiatrists who
testified agreed the Respondent now has - and has seemed to have for quite
a while.

The Respondent first bit of what I would call rather unusual or bizarre
behavior did occur when he made the very foolish attempt to parachute off
the top of the World Trade Center.  I say this was foolish, despite the
testimony of the Respondent of the precautionary measures that had been
taken for several months prior to the jump itself.  He should be commended
for taking some of the safety precautions he did take. On the other hand,
it disturbs me that such an action was so long in the planning stages, and
it was something that the Respondent obviously at the young age of just 21
wanted to do.  He has said it wasn't to prove a point or to get any
attention or anything of that sort. It was just something he wanted to do,
and he thought at the time it could be performed safely, both to himself
and to others.  He has testified that the area or the landing site was in a
closed-off area. That testimony is uncontradicted. I don't know whether
that is true or not, but I am going to give the Respondent the benefit of
the doubt.  Despite that fact, though, even if it were cleared off, it was
still not in my opinion constitute, a safe jump, without having first
secured the permission of the management of the World Trade Center, to let
them know that such a feat was going to be attempted.  I do not think it
was safe without having first notified the FAA of the attempted feat, in
order to make sure that no special authorizations were required by the FAA
under the particular circumstances that this jump was going to he made.  It
may be that the FAA would have still considered this a congested area, just
due to the close proximity of buildings and structures in the very confined
area of the World Trade Center.  That was the first instance of an overt
act that I think establishes this mental condition of a personality
disorder,

Then we turn to his time in Tulsa, Oklahoma, where for three months he
posed as a medical doctor. I have not heard any type of satisfactory
explanation or reason for doing this, and I can't find that it is anything
other than a manifestation of the disease he is suffering from.  Some of
the characteristics of the disease were exhaustively testified to by Dr.
Pakull and Dr. Powers. Some of the characteristics of what Dr. Powers
diagnosed as a mixed personality disorder with narcissistic and borderline
features are such things as an inappropriate and intense anger shown by the
Respondent on occasion, unpredictable actions, some instances of transient
psychosis even, where he would be completely out of touch with reality.

Such a person suffering from this mixed personality disorder would have
illusions of grandeur, is the way I've always heard it. Dr. Powers said it.
was a grandiose sense of self importance and of one's own image of himself
as being an unique person.  Such a person constantly is seeking attention
and admiration. A lot of the instances of overt acts in this case
illustrate and give credence to many of these different characteristics
that have been cited.  I think we've got a lot of examples in the evidence
where in various way - either through applications for employment of in
statements to fellow employees or an employer or even during the conduct or
his teaching- the Respondent alleged certain things that simply were not
true.

For instance, he claimed that he had taught ground school for AOPA, which
is Aircraft Owners Pilots Association, when in fact he never did.  He - I
think this grandiose behavior would be exemplified be keeping the Japan Air
Lines pilot uniform beyond the term of his employment, and going back to a
prior place of employment and telling certain people there about these
Falcon jets he was flying.  This seems to be more wishful thinking that I
think perhaps the Respondent was hoping would be true, and it wasn't true
at the time.  But it sounded good and it made him look good in front of his
friends and former co-employees,

Another characteristic of the personality disorder syndrome would be the
ability of the Respondent to manipulate others, many times through very
devious devices - either by outright lies, by charm itself, by some time
intimidation.  I think he did intimidate Dr. Schultz at the Daniel Webster
College, or at least he tried to, in order to effect something he very much
wanted, thereby evidencing another characteristic of the disorder - and
that is a failure or refusal to recognize that others have rights, and to
appreciate the rights or others.  Some or these untruths that were told by
the Respondent, I think were very serious - this business of saying he was
an FAA certified parachute rigger, and that he wanted to form this
parachuting club or some sort of parachute organization at the Daniel
Webster College at the time he had lost his certification by the U.S.
Parachute Association.  And yet he continued to lead others to think that
he was still certified by that association, which is the real pinnacle of
parachute jumping. I mean, it s really something to be certified by that
organization and whether it was true or not at the time, at least we find
it recognized that that was a "status symbol," at least among parachutists,
to belong there.

I think another serious action on the part of the Respondent was that
three-month period of posing as a doctor.  One can look back on it, and
think it was rather amusing that here a guy that looks so young, fooled so
many people, which really illustrates just how persuasive the Respondent
can be when he wants to be, and when he wants to make a certain impression
on others and at the same time build up his own self-image and buttress his
own ego - which obviously the Respondent, because of his personality
disorder, must have.  This evidences a lack of responsibility on the part
of this Respondent, as did saying he -was a certified instructor with the
U.S. Parachute Association.  This misled people, who he in turn still
wanted to put their trust in him. It's a bad circle that was started by the
Respondent - a circle that can lead to no good.  I think we have no
evidence here of any actual harm being done to anyone by any of the
masquerades, machinations or any other manifestation of grandiose conduct
on the part of the Respondent.  But I think that is just because we have
been rather lucky. I think as a result of his personality disorder the
Respondent, as testified to by both Dr. Powers and Dr. Pakull, has and will
in the future - at least for the next two years and somewhat beyond -
exercised poor judgment.  He has shown a lack of impulse control, feels
little guilt or willingness to assume responsibilities for his own acts,
and would prefer placing that blame on something else or someone else,
rather than accept the responsibility himself.

I agree with the Government counsel that it is irrelevant to hear closing
argument from a Respondent where he mentions how much he loves flying and
what a jolt it would be to lose his right to fly.  I agree - that is
irrelevant But whenever I hear the argument, it just makes my job as a
judge that much harder, because there is nothing in the world that I hate
worse than issuing the type of order that I am going to issue here.

I have no alternative with the evidence - or the overwhelming evidence
that I have heard today - but to affirm the Emergency order of Revocation
that has been filed in this case, and to hold that Respondent is not
medically qualified to exercise the privileges of any class of airman
medical certificate now or for the next two years, due to the fact that he
does have a personality disorder that makes him unable to safely perform
those duties at the present time or within the next two years.

Therefore he is disqualified for airman medical certification under the
sections of the Federal Aviation regulations herein before cited.  It is
therefore ordered that any airman certificate held by the Respondent is
hereby revoked.

Entered this 18th day of November, 1980, in New York, New York.

JOYCE CAPPS, Administrative Law Judge
Edited on December 15, 1980

JUDGE CAPPS: All right. Off the record.

(Discussion off the record.)

JUDGE CAPPS: Back on the record.

Mr. Campbell, I am handing you a copy of the appeal proceedings that you
can pursue. I am giving it to you in writing now, and that will be attached
to the decision when it is sent to you.  But I am handing that to you now,
because there is a time limitation attached to this.  All right. There
being nothing further before me, we stand adjourned.

(Whereupon the hearing in the above-entitled matter was closed.)

                                 APPEAL

Any party to this proceeding may appeal this initial decision or order by
filing with the Board a notice of appeal within 10 days after this date.
Such appeal must be perfected within 40 day after this date by filing with
the Board a brief in support of such appeal. Appeals may be dismissed by
the Board in cases where a party fails to perfect its appeal by the timely
filing of the brief. Attention is directed to Sections 821.43, 821.47, and
821.48 of the Board's rules of Practice in Air Safety Proceedings for
further information regarding appeals. An original and four copies of each
document must be filed with the National Transportation Safety Board,
Docket Section (LJ-10), Waterfront Center, 1010 Wisconsin, Ave., NW, Suite
301, Washington, D.C. 20007, as provided in Section 821.7 of the Board's
Rules, with copies served upon the other party. The timely filing of an
appeal herein shall stay the order in this initial decision.


SERVICE:

James R. Campbell
41 Stone Fence Road
Oakland, NJ 07436


Sharon Hauselt. Esq.
Enforcement &  Proceedings Branch, AGC-250
Federal Aviation Administration
800 Independence Ave., SW
Washington, D.C. 20591


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Updated 08-24-99