U.S. DEPARTMENT OF TRANSPORTATION 

Office of Hearings 

Washington, D. C. 

The Liberty Foundation, Inc. RECEIVED 

FAA DOCKET NO. 2012-0477 

(EIR 2011-GL-03-0070) 

(Civil Penalty Action) 

Hon. J. E. Sullivan, Administrative Law Judge 

APR - 8 2014 

HEARING DOCKET 

RESPONDENT'S COMPLIANCE WITH PARAGRAPH 1 OF 

ORDER GRANTING RELIEF, ETC. 

Respondent, The Liberty Foundation (TLF), by and through its undersigned 

attorney, herewith complies with paragraph 1 of the Court's Order Granting Relief, But 

Denying The FAA's Motion To Exclude Testimony. 

Attached hereto as Exhibit A is Rodney Schneider's detailed summary of his 

specialized experience, knowledge, skill, training, and education that supports the 

expert opinions in his Summary Judgment Declaration. 

Attached hereto as Exhibit B is Cullen Underwood's detailed summary of his 

specialized experience, knowledge, skill, training, and education that supports the 

expert opinions in his Summary Judgment Declaration. 

STUART A. GOLDSTEIN, P. A 

7300 North Kendall Drive, Suite 380, Miami,FL 33156 1 T: (305) 670"1222 F: (305) 400-0685 EMAIL: STUARTGOLDSTEINPA@ATT.NET 
Respectfully submitted, 

STUART A. GOLDSTEIN, P. A. 

7300 North Kendall Drive, Suite 380 

Miami, FL 33156 

Tel: (305) 670-1222 

Fax: (305) 670-7065 

Email: stuartgoldsteinpa@att.net 

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By:-"'~.Li-ii'"·' 'lilli;i,lli!Jici '-'1·4.1~· _;c">:::'Yf:::_v·'!JCY:cv'"W····""!_o___::·""-.;t'------

Stuart A. Goldstein 

Attorney for Respondent 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that the foregoing has been served on this 2nd day of April 

2014, as set forth below: 

Christopher R. Stevenson, Esq. 

Office of the Regional Counsel 

Federal Aviation Administration 

P. 0. Box 20636 

Atlanta, GA 30320 

By Facsimile (404) 305-5223 

and regular U. S. Mail 

and that an original and one copy was served upon: 

Hearing Docket Clerk, AGC-430 

Wilbur Wright Building, Suite 2W1 000 

Federal Aviation Administration, 

Washington, D. C. 20591 

STUART A. GOLDSTEIN, p_ A 

7300 North Kendall Drive, Suite 380, Miami,Fl 33156 

T: (305) 670-1222 F: (305) 400-0685 EMAIL: STUARTGOLDSTEINPA®ATT.NET 

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and that a copy was served upon: 

Honorable J. E. Sullivan 

Office of Hearings, M-20 

U. S. Department of Transportation 

1200 New Jersey Avenue, S. E. (E11-31 0) 

Washington, D. C. 20590 

By Facsimile: (202) 366-7536 

and regular U. S. Mail 

STUART A. GOLDSTEIN, P. A. 

7300 North Kendall Drive, Suite 380, Miami,FL 33156 

T: {305) 670-1222 F: (305) 400-0685 EMAIL: STUARTGOLDSTEINPA@ATT.NET 

3 
EXHIBIT A 

RODNEY SCHNEIDER STATEMENT 
1977-78, Attended Atlanta Area Technical School, taking the A&P course. I received my A&P license 

in the fall of 1978. 

1979, I began working at Delta Air Lines as a mechanic in the Atlanta hangar. From 1979-1984 I 

worked in the overhaul department as a mechanic. I performed sheet metal repairs and modifications 

on B-727, DC-8, DC-9, and L-1011 aircraft during block overhauls and heavy "D" checks. These 

included corrosion repairs, damage repairs, and modifications to both primary and secondary structure 

utilizing manufacturers and Delta Structural Repair Manuals, Engineering Repair Authorizations, and 

Engineering Orders. 

From 1982-1984 I worked primarily on Delta's DC-8 rc-engining program, which involved making 

structural changes needed to convert from Pratt & Whitney JT3 engines to the CFM-56 engine. My 

primary job was performing the structural modifications on the #3 engine position, including removing 

the original engine pylon, cutting the front spar web, removing internal and external wing structure, 

locating new parts using tooling jigs, match drilling holes, and installing the internal and external 

structure to support the new pylon installation. This entire area involved the fuel tank portion of the 

wet wing, which involved performing leak checks and repairing any leaks that were noted. 

In 1985, I transferred to the "Base Maintenance" department, also in the Atlanta hangar. I worked with 

a crew performing overnight checks, engine changes, sheet metal repairs, and modifications on all 

types of aircraft in the Delta fleet, to include B-727, B-737, B-757, B-767, DC-8, DC-9, MD-88, 

LlOll, DC-10, MD-11 and Airbus A31 0. I also performed letter checks on LlOll aircraft. In addition, 

I was qualified to taxi all the above mentioned aircraft types except the DC-8. 

Between 1979 and 1990, I attended aircraft initial schools on all the previously mentioned aircraft 

except the DC-8, which was being phased out. These schools ran from 1 to 3 weeks and covered all of 

the systems on those aircraft. 

In January, 1990, I was promoted to the position of Lead Mechanic (later changed to Lead Technician) 

in Base Maintenance, which I held until my retirement in June, 2012. As a Lead Technician, my 

responsibilities included supervising a crew of 5-9 technicians, planning and prioritizing workflow on 

short term (usually overnight) maintenance visits, researching repairs utilizing Structural Repair 

Manuals, researching parts utilizing Illustrated Parts Catalogs, assisting in finding Maintenance Manual 

references, working with Liaison Engineering to develop repair authorizations, and ensuring that work 

package and log book paperwork was complete and accurate. I also worked on Letter Check visits, 

which generally ran for 5 to I 0 days, which involved the above mentioned responsibilities plus 

evaluating Non-Routine work cards written by our Inspection department during the aircraft visit. 

During my time as Lead Technician I attended a number of Delta schools covering paperwork, 

supervisory training, systems troubleshooting, and a number of courses targeted at specific aircraft 

problems. I was also designated as a Taxi Examiner, which involved evaluating other teclmicians 

proficiency to taxi the different aircraft in the Delta fleet and signing them off to do so. I also was a 

part time instructor, teaching taxi school, utilizing classroom and full motion simulator training to deal 

with normal and emergency procedures that might be encountered during taxi. At the time I retired, I 

was a qualified Taxi Checker in all the aircraft types in the Delta fleet, B-737, B-747, B-757, B-767, B777, DC-9, MD-88, MD-90, A-320, andA-330. 

In 2009, I took a position as Lead Technician on the Landing Gear Crew. I supervised and developed a 

crew to be proficient at routine landing gear changes on B-737, MD-88, MD-90, B-757, B-767, and B-

---------- --------
777 aircraft. In addition, I worked in Delta's MRO Department, working on customer aircraft. I was 

responsible for planning work flow and acting as a point of contact for the customer representative for 

the contract being worked. 

In 1997, I began construction of a homebuilt aircraft, a Vans RV-6, from a Van's supplied "slow build" 

kit. I worked on this kit until it's first flight in August, 2013. Building the kit involved fabricating parts 

from raw stock, building support jigs, riveting, building wet leading edge fuel tanks using Van's 

supplied sealer, wiring the airplane, and installing all of its systems. 

In May, 200 I, I resumed flying lessons after a layoff of 21 years, and obtained my Private Pilot license 

in February, 2002. I currently have about 140 hours, not having been very active since July, 2004, 

when the outfit I rented an airplane from went out of business. 

In November, 2008, I discovered that the Liberty Fouodation was basing the Liberty Belle B-17 at the 

local airport, Cherokee Couoty (KCNI), for its winter maintenance. I contacting the foundation and 

offered my voluoteer services, which were accepted. I had no prior B-17 experience, but had been a B17 enthusiast since childhood after reading "Flying Fortress" by Edward Jablonski when I was about 10 

years old. I worked uoder the supervision of Tim Bourgoinc, who was the Director of Maintenance for 

the Liberty Foundation at that time. I also met Cullen Underwood and spent a lot of time helping him 

rework the electrical system to better match the original configuration and to enhance its reliability. In 

December, 2009, I spent some time with the airplane in Albuquerque, NM, assisting with an engine 

change, main tire replacement, carb installation, and miscellaneous other work. I assisted with work on 

the airplane several times over the next year. In the fall of 20 I 0, I was asked to take on the position of 

Director of Maintenance after Tim Bourgoine resigned. 
EXHIBIT B 

CULLEN UNDERWOOD STATEMENt 
PROFILE 

Cullen Underwood 

5og Sackman Falls Ct. 

Canton, Ga. 3()114 

cullenunderwood@grnail.corn 

T'rn Vice President of Underwood Mold Co., Tnc. (UMCO) in \Voodstock, Ga. 

UMCO is a medium sized company that manufactures injection molds, 

injection molded parts and various other items that need to be manufactured. 

These include plastic and aluminum and other metals. 1 began volunteering 

with The Liberty Foundation in 2oo8. 

EXPERlE\CE 

Vice President, UMCO, Woodstock, Ga.- 1999-Current 

Manage all facets of the operation. From new sales lo design or new projects to 

day to day operations of the plant itself. 1 have designed everything from small 

injection molds to large automation systems. T designed and manufactured the 

new tail wheel for B-r7s that are flying today. T have designed and 

manufactured numerous parts for current and past aircraft projects. Some of 

these projects involved welding aluminum. 

Within our industry we are involved with all areas of metal rnanufactlll·ing and 

based on my 27+ years of experience, T have a strong understanding of most all 

manufacturing techniques and processes for metal and plastic, including 

welding aluminum and other metals. 

The latest project for manufacturing aircraft parts is Cor the XP-82. This 

aircraft will be the only one of its kind flying in the wor"ld. 

UMCO has manufactured components for the F -22 and the C-5 for Lockheed 

Marlin. 

My flying background began when rny mother· and father· took me to an airshow 

at Dobbins Air Force base to see the Blue Ang·els when I was 5 years old. That 

made an impression that was permanent. Since that point 1 have always been 

interested in all areas of aviation. 

1 began flying at r5 years old and worked through all my ratings over the years. 

1 currently hold an ATP, Commercial, Instrumcut rating with type ratings in 

the B-r7 and P-/jo. 

EDUCATlO~ 

Kennesaw State University 

SKILLS 

My set or skills has been obtained through 27 years of being immersed in thilielllllll------· 

manufacturing world.