FILED

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

FLIGHT TEST AVIATION, INC.,

5175 Parkstone Drive, Suite 150

Chantilly, Virginia 20151

Plaintiff,

v.

SCOTT A. BEALE,

c/o ADI Shuttle Group, LLC

6544 Highland Drive

Waterford, Michigan 48327

Defendant.

Alexandria Division

C.A.No.:

2013 FEB-I A <* 05

CLERK US DISTRICT COURT

ALEXANDRIA. VIRGINIA

l:m\/H^Mmf^

JURY DEMAND

COMPLAINT

Flight TestAviation, Inc. ("FTA") hereby files itsComplaint against Scott A. Beale and

alleges as follows.

PARTIES

1. Plaintiff, FlightTestAviation, Inc. ("FTA") is a Delaware corporation whose

principal place of business is at 5175 Parkstone Drive, Suite 150, Chantilly, Virginia 20151.

2. Aerodynamics, Inc. ("ADI") is a Michigan corporation whose principle place of

business is at 6544 Highland Road, Waterford, Michigan.

3. Defendant, Scott A. Beale ("Beale"), is an individual whose is a citizen of the

stateof Georgia, and whose last known address was c/o ADI Shuttle Group, LLC, 6544

Highland Road, Waterford, Michigan 48327. Beale was at all times relevant thereto was the

Chief Executive Officer of ADI.

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Bankof America

Sectionl:-Req"uistor/6rlElnato'r-fnforniation"

RequestorName

JAMES WILLIAM PAQUETTE

Business Name (if applicable)

FLIGHT TEST AVIATION, INC

Address

5175 PARKSTONE DR STE 170

Customer ID T>pc I

VADL

ID#

T63858365

ID#

Funds Transfer Request

and Authorization (FTRA)

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City

CHANTILLY

.,•',' •

Dale Wire lo be Sent

4/25/2012

Telephone #

Slate

VA

Zip

20151

Issue State/Country

VA/USA

Issue Dale

03/23/2010

Expiration Date

01/14/2013

Issue State/Counlry Issue Date Expiration Date

09/2015

Customer IDType 2

BOA BUSI DEBIT CK CARD

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Time

111:33 AM Associate Name

MARIA ANDRADE

Phone and Fax U

703-331-3050

Callback Required ifPhone. Fax orLetter • Yes BIN/A

Call Back Completed by:

/ 571-292-8037

UnitCo((/CC#

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Name/Number ofPerson Contacted

Date

4/25/2012

Date/Time

Section III: Domestic Payment Instructions • • '

-

.'-./'..

Source 0OTC

D Fax D Phone • Letter

Amount of Wire

100,000.00

Account Debit

435026703493

Account Title

FLIGHT TEST AVIATFQN, INC, Overdraft Amount

Debit Account Type (check one)

gJcHKG DSAV DlCA D GL

Stile

VA

Serial B(For ICA'GL) or Repetitive IDS

Available Balance

s 5321,327.93

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USD Amount of Wire

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Country Role Foreign Currency Code Foreign Currency Amount

Debit Account Type (check one)

D CIIKG D SAV D 1CA D GL

Account Debit

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FX Reference ID (If applicable)

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S

Source D OTC

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Account Title

Overdraft Amount Overdraft Approved by (Name & Signature) Date Wire Fee

s_

•££Section V: WfoTnfnrmatioii/V'frff* •

Beneficiarv Name

AERODYNAMICS, INC

W--' rmmje^t'^-M ,-•-.:• - *••< .«•••• v.' ;<fc.V -'.WyiC Beneficiarv Account fl or IBAN (ifBAN. no further

BeneficiaryBank information is requited)

3852546525

Beneficiary Address: Street

Mtt&lffllftlNUL BANK

Bcxft^ir; Bi-i Mirat Street

City

NEW YORK

Citv

NEW YORK

Additional Instructions (Attention To.Phone Advise. Customer Reference. Contact Upon Arrival)

Send Thru Bank/IBK(ifavailable)

State

NY

Country

ABA it or Swift or National ID

026007773

Slate

NY

Country

ABA H or Swift or National ID

Zip

Zip

bena Ihrubanx Address htrcet City Slate Country Zip

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Iauthorize Bank ofAmerica totransfer my funds asset forth inthe inslructions noted herein (including debiting my account ifapplicable), and agree lhat such transfer

offunds issubject to the Bank ofAmerica standard transfer agreement (see page 2ofthis form) and applicable fees. Ifthis isaforeign currency wire transfer, Iaccept

the conversion rate provided inSection IV. or,if norateis entered, therate provided byBank ofAmerica atthetime thewire transfer issent.

Cuslome* SiTMal..r«- Dale ofRequest: / /

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Signature Verification: Type oraccount: 0T3usiness (Required for all) Q Personal (Required ifSlO.OOO ormore unless customer is well-known)

Indicate Method of Signature Verification: Q-Signalure Card D Business Resolution • Posted Check U

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Approval (required field) BAT Approval Authorization It(if applicable/attach approval)

WireEntered by. Name/Signature (aliachBFTscreen prints)

Print: VlG^, ^^A^A. Signature: BFT System Time BFT Scoucncc B

Date of Entry and Verification

/ /

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VerifiedBy (Namc/SignatureT(Atiach Verification ScreenPrint)

Pnnl Signature:

Note: Purpose of Wire must be disclosedif sent to an OFAC blockedcountry - SecOFAC In PRO

95-14-0237NSBW CM-20II

BFT System Time

Case 1:13-cv-00145-AJT-JFA Document 1-4 Filed 02/01/13 Page 1 of 1 PageID# 12
•UfiOOYXAMICS l»C

April 30th, 2012

Mr. Jim Paquette

President

Flight Test Partners, LLC

5175 Parkstone Drive

Suite 150

Chantilly,VA 20151

Joint Venture Agreement between Aerodynamics Inc. and

Flight Test Partners. LLC on N359AD Embraer 145 Regional Jet

Dear Jim:

As a follow up to our recent communication and review of ADI's proposal for the Embraer 145

Regional Jet Joint Venture Project dated April 18th, 2012, please accept the enclosed agreement

terms outlining the key points of our mutual agreement.

Background on Aerodynamics and the Regional Jet J45

Aerodynamics Inc. and its subsidiary Air Shuttle Group, LLC is a leading charter management

Company headquartered in Waterford, MI with multiple operating basis throughout the United

States. ADI is a 53 year old Company proud of its heritage and its flawless safety record since

inception. It's the only certified FAA Air Carrier (Parts 135, 125, 121 and 145) in existence that

has an incident and accident free record meeting the highest industry standards and the recipient

of various third party best practice audits and certifications. These include the following:

Aviation Research Group (ARG/US) Platinum operator for which there are only 93 in the world

out of 2,200 plus certified Air Carriers; Department of Defense (DoD) certification - pending

final review; ISBAO Stage 1 certificated; and a Netjets, a Berkshire Hathaway Company,

approved and preferred vendor. ADI is a qualified operator in this Joint Venture for the

following reasons:

• Impeccable reputation in the industry with a perfect track record in all areas. Flight Test

JV Partner can be confident that their clients will be in good hands with a top tier

Company.

• As a Part 121/135/125 Air Carrier, ADI has a robust infrastructure and management team

required by the FAR's. As such ADI currently has over twenty dedicated professionals

in the management ofour operations department, not including our Technical Services

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The Fauquier Bank Page 1of2

Wire Transfer | International Services | Security Admin | Help | Logoff | WlreXchange®

Tammy Lo«Bwi« ' 5 SL-SLlfe 11*3/12 0*54 AM

=ITs^The Fauquier Bank

Banking and Wealth Management Services

Outgoing Wire Detail

General Information

Wire Sequence Number 7366

Type of Wire: New Wire

Wire Status: Complete

OFAC Status: OFAC Passed

Audit Trail Information

Entered: 05/29/12 10:11 AM by ASHLEY STANTON

NO CALLBACK NECESSARY. WIRE AGREEMENT

ON FILE AS 5005 EXT 10279

Verified: 05/29/12 01:40 PM by Linda Sullivan

Posted: 05/29/12 01:46 PM by Linda Sullivan

Posted: 05/29/12 01:46 PM by System

Forwarded to Fed: 05/29/12 01:46 PM by System

Completed: 05/29/12 01:47 PM by System

Basic Settlement Information

Effective Date: 05/29/12

IMAD: 20120529GMQFMP01006977

OMAD:20120529B6B7IM1C00022705291447FT03

Amount S400.000.00

Wire Fee: $20.00 - DDA-wire transfer fee

Fee Account: Checking 108326701

Sending Financial Institution: 051402259 The Fauquier Bank

Receiving Financial Institution: 026007773 STERLING NYC

Business Function Code: CTR-Customer Transfer

Type Code: 1000-Basic Funds Transfer

Originator Information

Originating Fl Name:

Originator: FLIGHT TEST AVIATION INC

Originator Account 0108326701

Originator Address: 5175 PARKSTONE DRIVE ST 170

CHANTILLYVA 20151

Originator Country: United States

Beneficiary Information

Beneficiary Fl Name:

Beneficiary Fl Account

https://wirexchange.goxroads.contfwx/wreAvp^^ 1402259&wire_... 11 /5/2012

EXHIBIT

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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

ALEXANDRIA DIVISION

Flight Test Aviation, Inc., )

)

Plaintiff, )

)

v. ) Case No.: 1:13-cv-145-AJT/FJA

)

Scott A. Beale. )

)

Defendant. )

ANSWER TO AMENDED COMPLAINT

COMES NOW Defendant, Scott Beale, by counsel, and for his Answer to the 

Complaint filed herein states as follows:

1. Defendant is without information as to Paragraph One.

2. Defendant admits that ADI is a Michigan corporation, but denies all other 

allegations in Paragraph Two that are not expressly admitted.

3. Paragraph Three is denied in part and admitted in part. Defendant is not a citizen 

of Georgia and the address listed is not his address. Defendant admits that he was the CEO of 

ADI at all times relevant thereto, but notes that he was asked to step down by the ADI Board in 

October – November 2012, but has since resumed that position.

4. Defendant denies Paragraph Four. 

5. Defendant denies Paragraph Five, as previously reflected in his Motion to 

Dismiss.

6. Defendant is without information as to Paragraph Six.

7. Upon information and belief, Paragraph Seven is admitted, but it is denied that 

Defendant Beale “acquired” ADI. 

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2

8. Paragraph Eight is denied in part and admitted in part. Defendant admits the 

approximate date of the initial conversation with Paquette, but denies the nature of the request.

Defendant also denies that he stated that any requested cash would be returned in 60 days. 

Defendant admits that an investor dropped out of the EMB-145 project and that on behalf of ADI 

he approached Paquette about partnering with ADI in the prior investor’s place, and further that 

this discussion included the offer of participation in the EMB-145 effort in exchange for 

$500,000. 

9. The first three sentences of Paragraph Nine are denied except that Defendant 

admits that FTA was told that it would not incur, or need to pay, any additional costs or 

expenses. Sentence four is denied in that ADI did have a contract that it was negotiating with 

Rectrix, all of the terms of which were agreed upon, contingent upon the securing of a LaGuardia 

landing slot. Sentence five is denied, but a similar package was prepared. Finally, sentence six is 

denied. 

10. Defendant admits that wire transfer of $100,000 was made, before Exhibit 2 was 

produced, but denies the remaining allegations in Paragraph Ten.

11. Paragraph Eleven is admitted in part, in that the proposed joint venture agreement 

was not executed by either party. However, Defendant denies all other allegations in Paragraph 

Eleven that were not expressly admitted. 

12. Defendant denies making any oral representations, and denies generally the first 

sentence of Paragraph Twelve. As to the proposed agreement, the document speaks for itself. 

Defendant admits that he had conversations with Paquette between April 30, 2012 and May 15, 

2012, but denies the substance as alleged. Moreover, Defendant asserts that most of these 

conversations, if not all, dealt with the Embraer certification process.

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3

13. Defendant admits the provision of funds, as alleged in Paragraph Thirteen, but 

denies all other allegations not expressly admitted.

14. Defendant denies the first sentence of Paragraph Fourteen, as phrased, as Rectrix 

had indicated that it was prepared to move forward with ADI, and was only awaiting the 

Embraer certification and resolution of other minor topics, as is commonly done in that industry, 

but then later reversed its position. Defendant denies sentence two. Sentence three is admitted in 

part and denied in part in that ADI was promised the contract by Rich Cawley of Rectrix, but he 

ultimately reversed his position. 

15. Defendant denies Paragraph Fifteen.

16. Paragraph Sixteen is denied, although Plaintiff’s counsel did make one demand 

for the return of the money. 

17. Paragraph Seventeen is denied.

18. Paragraph Eighteen is admitted. 

19. As to Paragraph Nineteen, Defendant restates his responses to Paragraphs 1-18.

20. Paragraph Twenty is denied.

21. Paragraph Twenty-One is denied; the Code section speaks for itself.

22. Paragraph Twenty-Two is denied; the Code sections speak for themselves.

23. Paragraph Twenty-Three is denied; the Code sections speak for themselves.

24. Paragraph Twenty-Four is denied. 

25. As to Paragraph Twenty-Five, Defendant restates his responses to Paragraphs 1-

18.

26. Paragraph Twenty-Six is denied.

27. Paragraph Twenty-Seven is denied; the Code section speaks for itself.

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28. Paragraph Twenty-Eight is denied; the Code section speaks for itself.

29. Paragraph Twenty-Nine is denied; the Code section speaks for itself.

30. Paragraph Thirty is denied. 

31. Paragraph Thirty-One simply realleges Paragraphs 1-18.

32. Paragraph Thirty-Two is denied. 

33. Defendant denies Paragraph Thirty-Three and demands strict proof thereof.

34. Paragraph Thirty-Four is denied. 

35. Paragraph Thirty-Five is denied.

36. Defendant denies Paragraph Thirty-Six and demands strict proof thereof.

37. Defendant denies Paragraph Thirty-Seven. In fact, when Rectrix began to back 

away from the ADI deal, Paquette was advised and sought other parties to work with on the 

EMB-145 project, such as Easy Jet.

38. Paragraph Thirty-Eight is denied. 

39. Paragraph Thirty-Nine is denied and Defendant demands strict proof thereof. 

Specifically as to sentence two, Defendant notes that industry custom and usage allows for 

agreements to be made and negotiated and then signed later. Furthermore, Paquette was kept 

apprised of the status of the Rectrix negotiations and contract at all times. Additionally, as to 

sentence five, Defendant notes that a copy of the redline contract was, indeed, sent to Paquette.

40. Paragraph Forty introduces this new Count and contains no substantive 

allegations.

41. As to Paragraph Forty-One, Defendant restates his responses to Paragraphs 1-18.

42. Defendant denies Paragraph Forty-Two.

43. Defendant denies Paragraph Forty-Three.

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44. Paragraph Forty-Four is denied. 

45. Paragraph Forty-Five is denied.

46. Paragraph Forty-Six is denied.

47. Paragraph Forty-Seven is denied. In fact, when Rectrix began to back away from 

the ADI deal, Paquette was advised and sought other parties to work with on the EMB-145 

project, such as Easy Jet.

48. Paragraph Forty-Eight is denied.

GROUNDS OF DEFENSE 

49. Defendant incorporates all of the above denials as recited in the Answer.

50. Defendant asserts as a defense the bankruptcy of Aerodynamics, Inc. (hereinafter 

“ADI”).

51. Defendant herein asserts as a defense that at all times he was operating as a 

corporate officer, and Plaintiff seeks to make him responsible, individually, for the acts of a 

corporation, now bankrupt. As Plaintiff has not sought to pierce the corporate veil, Beale 

therefore cannot be held liable for his work performed on behalf of ADI, his principal and 

employer.

52. Defendant asserts as a defense that at all times, Plaintiff, and its principal, James 

Paquette (“Paquette”) was aware and knew of the allegations that he now asserts constitute the 

actions complained of in the Complaint, to the extent that Paquette was aware of the nature of 

any relationship and proposed contract with Retrix, and participated in seeking alternative uses 

for the aircraft, subject to the instant Complaint. 

53. Paquette and FTA, as participants in the aviation industry, were well aware of the 

fact that it is industry custom to discuss and negotiate all of the clauses of a contract, but then 

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6

have the same signed later, when the aircraft in question is certified and prepared for use. This is 

exactly what happened in the present situation. 

54. Defendant further asserts that as to the allegations made under the Virginia 

Securities Act, that the document advanced as a security by the Plaintiff is not a security under 

Virginia Code § 13.1-501, that the acts complained of do not constitute any violation of the 

referenced Act, and that the losses sustained were not a result of any alleged violation of the Act 

as well as that the statements made were not statements of material fact, and the actual facts in 

this case were well known to the Plaintiff, and its principal, Paquette.

55. Defendant further asserts as defenses under the Michigan Uniform Securities Act 

that the document advanced as a security by the Plaintiff is not a security under MCLA § 

440.8102, that the acts complained of do not constitute any violation of the instant Act, and that 

the losses sustained were not a result of any violation of the Act as well as that the statements 

made were not statements of material fact, and the actual facts in this case were well known to 

the Plaintiff, and its principal, Paquette.

56. Defendant further asserts as a defense herein that no fraud was perpetrated upon 

the Plaintiff herein, and, in fact, the principal of Plaintiff, Paquette, was aware at all times of the 

facts of which he now complains.

57. Defendant further asserts that the damages herein are not the result of those acts 

recited in the Complaint.

58. Defendant further asserts that an indispensible party, the bankrupt corporation, 

ADI, is a necessary party to this action, in that Plaintiff seeks discovery against ADI, and seeks 

to substitute Defendant Beale for the liability of that properly incorporated entity. 

59. Defendant asserts as a defense unclean hands.

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7

60. Defendant further alleges defenses of waiver, estoppel, latches, and the active 

participation of the Plaintiff, and its principal, in the acts recited within the Complaint. 

WHEREFORE Defendant, by Counsel, prays that the Plaintiff be denied the relief 

prayed for in its Complaint, that said Complaint be dismissed with prejudice, that Defendant be 

award his attorney’s fees and costs herein, and that he be awarded such further relief as this 

Court deems proper and just.

Respectfully submitted, 

Scott A. Beale, 

by Counsel 

_______________/s/__________________

Jonathan S. Gelber, Esq.

Virginia Bar Number #23992

Attorney for Scott A. Beale 

Law Offices of Jonathan Gelber, PLLC 

100 North Washington Street, Suite 402 

Falls Church, Virginia 22046 

Phone: 703.237.1200 

Fax: 703.237.2775 

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8

CERTIFICATE OF SERVICE

I hereby certify that on this 10th day of June, 2013, I will electronically file the foregoing 

with the Clerk of Court using the CM/ECF system, which will then send a notification of such 

filing (NEF) to the following: 

Joseph S. Luchini, Esq.

Virginia Bar No. 13566

Counsel for Flight Test Aviation, Inc.

Reed Smith LLP

3110 Fairview Park Drive, Suite 1400

Falls Church, Virginia 22042

Gregory J. Sagstetter, Esq. 

Virginia Bar No. 82598

Counsel for Flight Test Aviation, Inc.

Reed Smith LLP

3110 Fairfview Park Drive, Suite 1400

Falls Church, Virginia 22042

___________/s/____________________

Jonathan S. Gelber, Esq.

Virginia Bar Number #23922 

Attorney for Scott A. Beale

Law Offices of Jonathan Gelber, PLLC

100 North Washington Street, Suite 402

Falls Church, Virginia 22046

Phone: 703.237.1200

Fax: 703.237.2775

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