MEMORANDUM OPINION
SCOTT, District Judge.
These consolidated cases arise from the failure of an international airline to prevent the use of its aircraft to smuggle narcotics into the United States. ARCA Airlines, Ltda. ("ARCA") contests the assessment of penalties by the United States Customs Service ("Customs") under 19 U.S.C. § 1584(a)(2). Customs imposed the penalties after discovering cocaine on board two ARCA aircraft flown from Bogota, Colombia...
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