Federal Aviation 

Administration 

Memorandum 

Date: September 17, 2009 

To: Anne Hanley, AGC-710, Part 16 Docket Administration 

cc: Deandra Brooks, AGO-1 (with attachments) 

From: Raymond Veatch, Attorney, AGC-610 /h 

Prepared by: Raymond Veatch (202-267-9676) 

Subject: Johnson v. Goldsboro Wayne Airport Authority, Docket No. 16-08-11 

Anne, 

Attached please find the original and three copies of a document to be filed in the Johnson v. 

Goldsboro Wayne Airport Authority case, Docket No. 16-08-11: 

Letter dated September 8, 2009, fi-om W. Harrell Everett, Jr., Esq., attorney for the 

Respondent addressed to Jonathan Cross, Esq., Office of the Chief Counsel, FAA, 

containing two attachments: 1) copy of the minutes of a special meeting of the GWAA 

dated August 10, 2009, 2) copy of a letter dated September 8, 2009, from W. Harrell 

Everett, Jr., Esq., attorney for the Respondent addressed to Glenn A. Barfield, Esq. 

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EVERETT, WOMBLE, LAWRENCE & BROWN, I 

Attorneys at Law 

507 B Spence Avenue 

W. Harrell Everett, Jr. Drawer 10809 

James D. Womble, Jr. Goldsboro, NC 27532-0809 

Ronald T. Lawrence, II 

Darrell K. Brown Email 

Justin L. Minshew heverett@goldsboronclawyers.co 

DW 

SEP 1 6 2009 

Telephone 

(9W»'51?I^7«?NMENTAL 

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(919) 751-2598 

September 8, 2009 

Mr. Jonathan W. Cross 

Federal Aviation Authority 

Office of the Chief Counsel 

ATTN: FAA Part 16 Airport Proc. Docket 

AGC-610 Federal Aviation Administration 

800 Independence Ave., SW 

Washington, DC 20591 

Re: Delbert Johnson d/b/a Two Dogs Aviation vs, 

Airport Authority Docket No. 16-08-11 

Goldsboro Wayne 

Dear Mr. Cross: 

On August 13, 2009 a supplemental response to Mr. Barfield's 

letter of July 27, 2009 was forwarded to you, including the 

following documents: 

1) Affidavit of Otto H. Keesling 

2) Newspaper article from the Goldsboro News Argus, dated 

July 14, 2009 

3) Airport Management Agreement between Goldsboro Wayne 

Airport Authority and Wayne County 

4) Lease Agreement between Goldsboro Wayne Airport Authority 

and Wayne County 

5) Fixed Base Operation Agreement between Goldsboro Wayne 

Airport Authority and Wayne County 

6) Letter from James A. Steele, Manager of SIG Aviation, LLC 

to Cleve Wilkins terminating SIG Aviation's relationship with 

Goldsboro Wayne Airport Authority as Airport Manager and Fixed Base 

Operator 

7) Letter dated August 5, 2009 from W. Lee Smith, III to 

Otto Keesling, Chairman of the Goldsboro Wayne Airport Authority 

requesting a waiver of requirements of Section 8 of its Rules and 

Regulations 

F:\WP10\OBSgwaa\cross johnsonltS.wpd 
I am also providing you with a supplemental response to Mr, 

Barfield's letter of September 3, 2009. 

I am enclosing a copy of the minutes of a special meeting of 

the Goldsboro Wayne Airport Authority on August 10, 2009 where the 

Goldsboro Wayne Airport Authority approved a waiver of the 

requirements of Section 8 of the Airport's Rules and Regulations to 

provide services other than fuel for Wayne County. 

The Goldsboro Wayne Airport Authority has never nor is it 

legally required to advertise and accept bids for the position of 

Airport Manager. 

It was the position of the Goldsboro Wayne Airport Authority 

that it was in the best interest of the citizens of Wayne County 

and the surrounding area to allow Wayne County to act as Airport 

Manager. 

Yours very truly, 

EVERETT, WOMBLE, LAWRENCE & BROWN,LLP 

0^}U^'^, ^ 

W. Harrell Everett, Jr, 

WHEJr:obb 

Enclosures 

copy: Otto Keesling 

Glenn Barfield 

Pablo Nuesch 

F:\WP10\OB\gwaa\cross johnsonltS.wpd 
GOLDSBORO-WAYNE AIRPORT AUTHORITY 

August 10,2009 

A special called meeting of the Goldsboro-Wayne Airport Authority was held on Monday, 

August 10,2009, at 6:00 p.m. at the airport conference room to discuss the documents from Wayne 

County concerning the airport. 

Board Members Present: Otto Keesling, Ken Banks, Ronald Prince, James L. Maxwell, Jr., 

and Paul King. (The Chair declared a quorum present.) 

Consultants and Guests Present: Harrell Everett. 

Otto Keesling, Chairman, called the meeting to order and stated that the purposes of this 

meeting was to review the documents provided by the County of Wayne and to approve waivers for 

certain services, as amended. 

Ken Banks moved (1) to approve the revised Airport Management Agreement, Lease 

Agreement, and Fixed Base Operation Agreement between the Authority and Wayne County, which 

documents have been revised to include the changes noted in the minutes of the Authority of August 

3, 2009, (2) to direct the Chairman and the Secretary to sign these documents, and (3) to waive the 

requirement in Section 8 of the airport's rules and regulations for the Coimty to provide services 

other than fuel. The motion was seconded by Paul King and vmanimously approved. 

Ron Prince moved to approve the waiver to allow SIG Aviation, LLC to continue to provide 

charter service, which motion was seconded by Jim Maxwell and unanimously approved. 

There being no further business to come before the Authority, the meeting was adjourned. 

The next regular meeting will be held on Thursday, August 27,2009. 

Respectfully submitted. 

James L. Maxwell, III, Secretary 

C:\MyFiles\gwaaAug 10,2009 special meeting minutes.wpd 
EVERETT, WOMBLE, LAWRENCE & BROWN, L.L.P . 

Attorneys at Law 

507 B Spence Avenue 

W. Harrell Everett, Jr. Drawer 10809 Telephone 

James D. Womble, Jr. Goldsboro, NC 27532-0809 (919) 778-6707 

Ronald T. Lawrence, II Fax 

Darrell K. Brown Email (919) 751-2598 

Justin L. Minshew heverett@goldsboronclawyers.co 

September 8, 2009 

Mr. Glenn Barfield 

Haithcock, Bafield, Hulse & Kinsey PLLC 

Attorneys at Law 

231 East Walnut Street 

Post Office Drawer 7 

Goldsboro, NC 27533-0007 

Re: Johnson v. The Goldboro-Wayne Airport Authority 

Wayne Co. File No.: 09 CVS 1362 

Dear Glenn: 

This is to acknowledge receipt of your letter of September 3"*. 

It would be appreciated if you would specifically respond to my letter of August 18, 2(X)9 

as it relates to public records. 

Further, it is my opinion that whether or not I am disqualified to act as counsel for my 

client would be a decision for the presiding Judge at the trial of this matter. 

Yours very truly, 

EVERETT, WOMBLE, LAWRENCE & BROWN.LLP 

^^i/tJCi.J ^ 

W. Harrell Everett, Jr. 

WHEJr:obb 

F; \WP10\OB\gwaa\barfield delbert johnsonlt6.wpd