## 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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### 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 

## 2

### 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 STATEMENT1977-78,AttendedAtlantaAreaTechnical School, taking the A&P course. I receivedmyA&P license inthe fall of 1978. 1979, I began working at DeltaAir Lines as a mechanic in the Atlanta hangar. From 1979-1984 I worked inthe overhaul department as a mechanic. I performed sheet metal repairs andmodifications on B-727, DC-8, DC-9, and L-1011 aircraft during block overhauls andheavy "D" checks. These included corrosionrepairs, damage repairs, and modifications to both primary and secondary structure utilizing manufacturers and Delta Structural Repair Manuals, Engineering RepairAuthorizations, and Engineering Orders. From 1982-1984 Iworkedprimarily on Delta's DC-8 rc-engining program, whichinvolvedmaking structural changes needed to convert from Pratt & Whitney JT3 engines to the CFM-56 engine. My primaryjob was performing the structural modifications on the#3 engine position, including removing the original engine pylon, cutting the front sparweb, removing internal and external wing structure, locating new parts using toolingjigs, match drilling holes, and installing the internal and external structure to support the new pylon installation. This entire area involved the fuel tankportion ofthe wet wing, which involved performing leak checks andrepairing any leaks that were noted. In 1985, I transferred to the "Base Maintenance" department, also intheAtlanta hangar. I worked with a crewperforming overnight checks, engine changes, sheet metal repairs, and modifications on all types ofaircraft 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 andAirbus A310. 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 beingphased out. These schools ran from 1to 3 weeks and covered all of the systems onthose aircraft.
In January, 1990, I was promotedto the position ofLeadMechanic (later changed to Lead Technician) in Base Maintenance, which I helduntil myretirement in June, 2012. As a LeadTechnician, my responsibilities included supervising a crew of5-9 technicians, planning and prioritizing workflow on short term (usually overnight) maintenance visits, researching repairs utilizing Structural Repair Manuals, researchingpartsutilizing Illustrated Parts Catalogs, assisting in finding Maintenance Manual references, working with Liaison Engineering to develop repair authorizations, and ensuring that work package and log bookpaperwork was complete and accurate. I also worked on Letter Checkvisits, which generally ran for 5 to I0 days, whichinvolved the above mentioned responsibilities plus evaluating Non-Routine work cards written byour Inspection department during the aircraft visit. During mytime as LeadTechnician I attended a number ofDelta schools covering paperwork, supervisory training, systems troubleshooting, and a number ofcourses targetedat specific aircraft problems. I was also designated as a Taxi Examiner, which involved evaluating other teclmicians proficiency to taxi the different aircraftinthe Delta fleet and signing them offto do so. I also was a parttime instructor, teaching taxi school, utilizing classroom and full motion simulator training to deal with normal and emergency procedures that mightbe encountered during taxi. At the time I retired, I was a qualified Taxi Checker inallthe 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 LeadTechnician onthe Landing Gear Crew. I supervised and developed a crewto be proficient at routine landing gear changes onB-737, MD-88, MD-90, B-757, B-767, and B-

---------- --------777 aircraft. In addition, I worked inDelta's MRO Department, working on customer aircraft. I was responsible for planning work flow and acting as a point ofcontact for the customer representative for the contract being worked. 

### In 1997, I began construction ofa homebuilt aircraft, a Vans RV-6, from a Van's supplied "slowbuild" kit. I worked on this kituntil it's first flight inAugust, 2013. Buildingthe kit involved fabricating parts from raw stock, building supportjigs, riveting, building wet leading edge fuel tanks using Van's supplied sealer, wiring the airplane, and installing all ofits systems. InMay, 200I, I resumed flying lessons after a layoffof21 years, and obtained myPrivate Pilot license inFebruary, 2002. I currently have about 140 hours, not having been very active since July, 2004, whenthe outfitI rented an airplane from went out ofbusiness. In November, 2008, I discovered thatthe LibertyFouodation was basingthe Liberty Belle B-17 at the local airport, Cherokee Couoty (KCNI), for its winter maintenance. I contacting the foundation and offered myvoluoteer services, which were accepted. I hadno prior B-17 experience, buthadbeen a B17 enthusiast since childhood after reading "FlyingFortress"byEdwardJablonski whenI was about 10 years old. I worked uoder the supervision ofTim Bourgoinc, who was the Director ofMaintenance for the LibertyFoundation at that time. I also metCullen Underwood and spent a lot oftime helping him reworkthe electrical system to better match the original configuration and to enhance its reliability. 

### In December, 2009, I spent some time withthe 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 of20I0, I was asked to take on the position of Director ofMaintenance 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 ofUnderwood Mold Co., Tnc. (UMCO) in \Voodstock, Ga. UMCO is a medium sized companythat manufactures injectionmolds, injection molded parts and various other items that need to be manufactured. These include plastic and aluminum and othermetals. 1

### beganvolunteering with The LibertyFoundation in 2oo8. 

## EXPERlE\CE Vice President, UMCO, Woodstock, Ga.- 1999-Current Manage all facets ofthe operation. From new sales lo design ornew projects to day to day operations ofthe plant itself. 1have designed everything from small injection molds to large automation systems. T

### designed and manufactured the newtail wheel for B-r7s that are flying today. T

### have designed and manufactured numerous parts for current and past aircraftprojects. Some of these projects involved welding aluminum. Within ourindustry we are involved with all areas ofmetal rnanufactlll·ing and based on my 

### 27+ 

### years ofexperience, T

### have a strong understanding ofmost all manufacturing techniques and processes for metal and plastic, including welding aluminum and othermetals. The latest project for manufacturing aircraft parts is Cor the XP-82. This aircraft will be the only one ofits 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 AirForce base to see the Blue Ang·els when I was 5years old. That made an impression that was permanent. Since thatpoint 1

### have always been interested in all areas ofaviation. 1began flying at r5 years old and worked through all myratings 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 ofbeing immersed in thilielllllll------· manufacturing world.