## 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 FederalAviation Administration 800 IndependenceAvenue, S.W. Washington, D.C. 20591 Attn: Hearing Docket Clerk, AGC-430 WilburWright Building- Room 2014 ATTN: HEARING DOCKET CLERK Re: In the Matter ofRenaissance Jet, Inc., 2D12EA390U30 

### l - \ Please find enclosed the original and one copy oftheAnswer in the above-entitled action for filing, along with a Certificate ofService. Thankyou for your assistance. Very trulyyours,

# ~~~~jSA(f John Adams Hodge

cc: Zachary Berman, Esq. Hon. ].E. SullivanU.S. DEPARTMENT OFTRANSPORTATION FEDERAL AVIATIONADMINISTRATION OFFICE OFHEARINGS

WASHINGTON, D.C.

In the Matter ofRenaissance Jet, Inc. 2012EA390030 Administrative LawJudge 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 proofofany and all allegations madebythe FAAinthis matter.
2. RJI admits the allegations ofRomanNumeral I. ofthe Complaint.
3. RJI only admits portions of Roman Numeral II of the Complaint as set forth hereinbelow.
4. RJI admits the allegations ofparagraphs II., 1 and 2 ofthe Complaint.
5. RJI admits only so much ofthe allegations ofparagraph II., 3 that maintenance and operation ofN241TR was subject to maintenance procedures and manuals that are approved under its Operations Specifications. RJI craves reference to the specificdocuments that speak for themselves.
6. RJI denies the allegations ofparagraphs II., 4 and 5, ofthe Complaint.
7. RJI admits the allegations ofparagraphs II., 6 and 7 ofthe Complaint.
8. RJI denies the allegations ofparagraph II., 8 ofthe Complaint.
9. RJI admits the allegations ofparagraphs II., 9 and 10 ofthe Complaint.
10. RJI denies the allegations ofparagraphs II, 11 and 12 ofthe 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 ofthe 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 ofthe Complaint.
13. RJI denies the remaining statements or allegations in the Complaint not specifically enumerated herein. FORA SECOND DEFENSE 14. RJI realleges and reasserts each and every response contained in paragraphs 1 through 13. as ifset forth verbatim. 15. The Flight Management System (FMS) referred to in the Complaint was never inoperative.

216. The aircraft contains no "centermalfunction display" as alleged inthe 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 ofthe Administrator; 2. Award Respondent its costs and attorneys fees incurred as a result ofdefending this action; 3. Grant any and all other reliefas the ALJ deemsjust and proper. Respectfully Submitted,

3March 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.

4

### CERTIFICATEOF SERVICE I hereby certifY that on tins day copies ofthe foregoing Answerwere placed in the United States

### mail, postageprepaid, CertifiedMail- RetumReceiptRequested addressed as follows: Zachaty Berman, Esq. FAA Office ofRegional Counsel l 

### AviationPlaza Jamaica, :NY 11434 Federal AviationAclTinistration (Original a'1d 

### one copy) 800 IndependenceAvenue, S.W. Washingt011, D.C. 20591 Attn: Hearing Docket Clerk, AGC-430 WilburWrightBuilding-Room 2014 Hon. J.E. Sullivan Administrative LawJudge US Deoartment ofTransoortation**~ ~**  

### 1200NewJersey Avenue, S.E. (Ell-310) Washington, DC 20590 March 4, 2014

# By:~Cl,J~ Sharon A. Hodge Hodge & Associates, LLC Box25553 Columbia, SC 29224