JOHN ADAMS HODGE and ASSOCIATES, LLC 

Attorneys and Counselors at Law 

Environmental & Aviation Law 

136 Stonemark Lane, Suite 110 

Columbia, S.C. 29210 Mailing Address: 

John Adams Hodge, P.G. 

Sharon A Hodge 

Telephone 803.783.9001/803.386.1504 Post Office Box 25553 

www.johnhodgelaw.com Columbia, S.C. 29224 

March4, 2014 

CERTIFIED MAIL- RETURN RECEIPT REQUESTED 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, D.C. 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Room 2014 

ATTN: HEARING DOCKET CLERK 

Re: In the Matter of Renaissance Jet, Inc., 2D12EA390U30 l - \ 

Please find enclosed the original and one copy of the Answer in the above-entitled 

action for filing, along with a Certificate of Service. 

Thank you for your assistance. 

Very truly yours, 

~~~~jSA(f 

John Adams Hodge 

cc: Zachary Berman, Esq. 

Hon. ].E. Sullivan 
U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of Renaissance Jet, Inc. 

2012EA390030 

Administrative Law Judge J.E. Sullivan 

ANSWER 

Renaissance Jet, Inc. (RJI), by and through counsel, hereby files its Answer to the Administrator's 

Complaint, and states as follows: 

1. Anything not specifically admitted herein is denied. The Respondent demands strict 

proof of any and all allegations made by the FAA in this matter. 

2. RJI admits the allegations of Roman Numeral I. of the Complaint. 

3. RJI only admits portions of Roman Numeral II of the Complaint as set forth 

hereinbelow. 

4. RJI admits the allegations of paragraphs II., 1 and 2 of the Complaint. 

5. RJI admits only so much of the allegations of paragraph II., 3 that maintenance and 

operation of N241 TR was subject to maintenance procedures and manuals that are 

approved under its Operations Specifications. RJI craves reference to the specific 
documents that speak for themselves. 

6. RJI denies the allegations of paragraphs II., 4 and 5, of the Complaint. 

7. RJI admits the allegations of paragraphs II., 6 and 7 of the Complaint. 

8. RJI denies the allegations of paragraph II., 8 of the Complaint. 

9. RJI admits the allegations of paragraphs II., 9 and 10 of the Complaint. 

10. RJI denies the allegations of paragraphs II, 11 and 12 of the Complaint. 

11. RJI denies the allegations of Roman Numeral III of the Complaint, and where the 

Answer purports to cite particular Federal Aviation Regulations, RJI craves reference 

to the regulation, and thus denies III of the Complaint. 

12. RJI denies the allegations of Roman Numeral IV of the Complaint, and where the 

Answer purports to cite portions of the United States Code, Respondent craves 

reference to the statute, and thus denies IV of the Complaint. 

13. RJI denies the remaining statements or allegations in the Complaint not specifically 

enumerated herein. 

FOR A SECOND DEFENSE 

14. RJI realleges and reasserts each and every response contained in paragraphs 1 

through 13. as if set forth verbatim. 

15. The Flight Management System (FMS) referred to in the Complaint was never 

inoperative. 

2 
16. The aircraft contains no "center malfunction display" as alleged in the Complaint. 

17. The "GPU start of the left engine bogs down right engine while starting" is not a 

discrepancy, but a normal aircraft occurrence. 

18. The condition "AlP trims slow" is not a discrepancy, but a normal aircraft occurrence. 

19. The condition "oxygen needs servicing" was not a discrepancy. The oxygen was 

within limits. 

20. The flight crew ofN241TR was subject to enforcement action by the GSO FSDO as 

a result of their action in writing maintenance items in the aircraft maintenance 

records that were in fact not discrepancies. On information and belief, these airmen 

received warning letters from the FAA regarding their action. 

21. As a result of the aforementioned, the FAA knew or should have known that the 

allegations that the aircraft was operated in an unairworthy condition are incorrect. 

WHEREFORE, having set forth his Answer, Respondent, Renaissance Jet, Inc., prays that the 

Administrative Law Judge (ALJ): 

1. Dismiss the action of the Administrator; 

2. Award Respondent its costs and attorneys fees incurred as a result of defending this 

action; 

3. Grant any and all other relief as the ALJ deems just and proper. 

Respectfully Submitted, 

3 
March 3, 2014 

Hodge & Associates, LLC 

Box 25553 (29224) 

136 Stonemark Lane, Snite 110 

Columbia, SC 29210 

johnhodge@johnhodgelaw.com 

803-386-1504 

fax 803-783-9210 

Attorneys for Renaissance Jet, Inc. 

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CERTIFICATE OF SERVICE 

I hereby certifY that on tins day copies of the foregoing Answer were placed in the United States mail, 

postage prepaid, Certified Mail- Retum Receipt Requested addressed as follows: 

Zachaty Berman, Esq. 

FAA Office of Regional Counsel 

l Aviation Plaza 

Jamaica, :NY 11434 

Federal Aviation AclTinistration (Original a'1d one copy) 

800 Independence Avenue, S.W. 

Washingt011, D.C. 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building-Room 2014 

Hon. J.E. Sullivan 

Administrative Law Judge 

US Deoartment ofTransoortation ~ ~ 

1200New Jersey Avenue, S.E. (Ell-310) 

Washington, DC 20590 

March 4, 2014 

By:~Cl,J~ 

Sharon A. Hodge 

Hodge & Associates, LLC 

Box25553 

Columbia, SC 29224