U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

RECEIVED 

OCT 1 0 2014 

HEARING DOCKET 

FEDERAL AVIATION ADMINISTRATION, 

FAA Case No. 2010-S0-190295 

Complainant, 

v. FAADocketNo.@01L)- (Jp8d 

MIAMI TECH AIRCRAFT MAINTENANCE, 

INC. 

Respondent. 

----------------------~/ 

ANSWER AND AFFIRMATIVE DEFENSES 

Respondent, MIAMI TECH AIRCRAFT MAINTENANCE, INC. (hereinafter, 

"Respondent"), by and through its undersigned counsel, files this its Answer and Affirmative 

Defenses to the Complaint, and in support hereof states as follows: 

1. Respondent admits that it is the holder of the certificate alleges. All other inferences on 

this allegation are denied. 

2. Respondent admits that its Repair Station manual says what it says. All other allegations 

in this paragraph are denied. 

3. Admitted. 

a. Denied. 

b. Denied. 

4. Denied. 

a. Denied. 

b. Denied. 

1 

GRIFFIN, SERRANO & EWING, P.A. 

BLACKSTONE BUilDING, SIXIH FLOOR, 707 SOUTHEAST 3JID t\VENU£1 

FORT LAUDERDJ\LE, FLORIDA 33316, TELEPHONE (954) 462-4002, FACSIMILE (954) 462-4009 
5. Denied. 

6. Admitted in part and denied in part. 

7. Denies each allegation in this paragraph in that the manual referenced speaks for itself. 

All inferences contained in this paragraph are denied. 

8. Denied. 

9. Denied. 

10. Respondent admits that it provided requisite training to its mechanics; however denies all 

other allegations and inferences raised in this paragraph. 

11. Denied. 

12. Denied. 

a. Denied. 

b. Denied. 

c. Denied. 

13. Omitted from complaint. In an abundance of caution denied. 

14. Denied. 

15. Denied. 

AFFIRMATIVE DEFENSES 

AFFIRMATIVE DEFENSE NO. 1: Respondent states that at all time material it 

used maintenance procedures and techniques approved and required by the Administrator, 

including but not limited to procedures and techniques mandated by the FAA to the part 121 

operator to whom services were being provided. 

2 

GRIFFIN, SERRANO & EWING, P.A. 

BLACKSTONE BCILDING~S1XTH f<I.OOR, 707 SOUTHEAST 3RD AVENUE, 

fORT LAUDERDALE, FLORIDA 33316, TELEPHONE (954) 462-4002,1' ACSIMILE (954) 462-4009 
AFFIRMATIVE DEFENSE NO.2: Respondent states that the services provided 

complied with the procedures and techniques approved, required and mandated to the operator 

by the FAA. 

AFFIRMATIVE DEFENSE NO.3: Respondent states that all servtces 

performed were under the auspice of a 14 CFR 121 certificated operator. 

AFFIRMATIVE DEFENSE NO.4: Respondent states that all inspections, 

signoffs, returns to service, and other final approvals were performed by and/or under the auspice 

of the Part 121 operator who owned and or operated the subject aircraft. 

AFFIRMATIVE DEFENSE NO.5: Respondent states that the Part 121 operator 

provided training and testing in accordance with its Operations Specifications for the 

maintenance being performed. 

AFFIRMATIVE DEFENSE NO.6: Respondent states that the FAA reviewed, 

revised, approved and otherwise ratified the maintenance and inspections techniques provided by 

the Part 121 operator and used by the Respondent in this case. 

AFFIRMATIVE DEFENSE NO.7: Respondent states that the FAA reviewed, 

revised, approved and otherwise ratified the training and testing practices employed in this case. 

Respondent reserves the right to supplement or amend these Affirmative Defenses upon 

further investigation and discovery. 

SUGGESTED LOCATION 

Respondent hereby suggests Miami, Florida as the location for the hearing. 

3 

GRIFFIN, SERRANO & EWING, P.A. 

BLAcKsToNE BuiLDING> SIXTH Fr.ooR, 707 SoUTIIEA.'>T .3RD A VENUE~ 

J70R1' LAUDERDALE, FLORIDA 33316, TELEPHONE (954) 462-4002, fiACS!MJLE (954) 462-4009 
CERTIFICATE OF SERVICE 

WE HEREBY CERTIFY that a true and correct copy of the foregoing was served on 

October 9, 2014 to all parties on the attached service list. 

Federal Aviation Administration 

Office of the Regional Counsel, AS0-7 

Southern Region 

1 701 Columbia A venue 

College Park, GA 30337 

Telephone: (404) 305-5200 

Facsimile: (404) 305-5223 

Hearing Docket clerk 

FAA, AGC-430, Suite 2Wl 000 

Wilbur Wright Building 

800 Independence Avenue, SW 

Washington, DC 20591 

GRIFFIN, SERRANO & EWING, P.A. 

Attorneys for DEFENDANTS 

Blackstone Building, Sixth Floor 

707 Southeast 3'd Avenue 

Fort Lauderdale, Florida 33316 

Phone: (954) 462-4002 

Fax: (954) 462-4009 

Is/ Juan R. Serrano 

Juan R. Serrano 

Florida BarNo. 319510 

Jonathan A. Ewing 

Florida Bar No. 40972 

Service List 

4 

Miami Tech Aircraft Maintenance, Inc. 

c/o Amasvido Rodriguez 

CEO 

P.O. Box 520657 

Miami, Florida 33152 

Miami Tech Aircraft Maintenance, Inc. 

c/o Amasvido Rodriguez 

CEO 

5200 NW 36th Street, 

Building 862 

Miami, Florida 33166 

GRIFFIN, SERRANO & EWING, P.A. 

BLACKSTONE BUILDING~ SIXTH FLOOR, 707 SOVTIIE.A.ST .:)RD A VENUE, 

FORT L'UDERDALE, !'LORIDA 33316, TELEPHONE (954) 462-4002, FACSIMILE (954) 462-4009