FAA PART 16 AIRPORT PROCEEDINGS DOCKET 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Docket No. 16-08-05 

ALCA, Inc., Cylinder Shop, Inc., 

Suncoast Aviation, Aircraft Parts 

and National Aviation, 

Complainants, 

vs. 

Miami-Dade County, Florida 

Respondent. 

/ 

" ' J 

NOTICE OF FILING 

Respondent, Miami-Dade County, files its supplement to Exhibit L to its A^Swer4cifc£ 

Complainants' Part 16 Complaint served on Friday, September 19,2008. The Declaration^ 

Maria Anon, Exhibit L, excluded the attachments. 

Respectfully submitted, 

R.A. CUEVAS, JR. 

MIAMI-DADE COUNTY ATTORNEY 

By: _ 

DAVfliMuMyRRAY 

Sistant Coxmty Attorney 

Florida Bar No. 0291330 

Email: dmmurrav(Slmiami-airport.com 

OFFICE OF COUNTY ATTORNEY, MIAMI-DADE COUNTY, FLORIDA 
Thomas P. Abbott 

Assistant County Attorney 

Florida Bar No. 102920 

Email: tabbott@miami-airport.com 

Aviation Division 

P. O. Box 025504 

Miami, Florida 33102-5504 

Telephone No. (305) 876-7040 

Facsimile No. (305)876-7294 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and correct copy of the foregoing was sent on 

September 24, 2008, to: 

Via U.S.P.S. 

Office of the Chief Counsel 

Attn: FAA Part 16 Airport Proceedings 

Docket, AGC-610 

Room 925, Federal Aviation Administration 

800 Independence Ave., SW 

Washington, D.C. 20591 

Via U.S.P.S. and Electronic Mail 

Jennifer Trock, Esq. 

Pillsbury Winthrop Shaw Pittman 

2300 N Street, NW 

Washington, DC 20037-1122 

Email: iennifer.trockfgtpillsburvlaw.com 

Counsel for AA Acquisitions, LLC 

LLP 

Via U.S.P.S. and Electronic Mail 

Michael A. Pizzi, Jr., Esq. 

15271 N.W. 60 Avenue 

Suite 206A 

Miami Lakes, FL 33014 

Telefacsimile: 305.231.2123 

Email: mpizziir@.vahoo.com 

Counsel for Complainants 

By: 

MURRAY 

S P. ABBOTT 

OFFICE OF COUNTY ATTORNEY, MIAMI-DADE COUNTY, FLORIDA 
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OFFICE OF COUNTY ATTORNEY. MIAMI-DADE COUNTY. FLORIDA 
Declaration of Maria Anon 
FAA PART 16 AIRPORT PROOCEDINGS DOCKET 

FEDERAL AVUTION ADMINISTRATION 

WASHINGrON,DC 

Docket No. IfihOS^ 

ALCA, Inc., Cylindn: Shop, Inc., 

Suncoast Aviation, Aircraft Parts 

and National AviatJon, 

Complainuits, 

vs. 

Miami-Dade County, Florida 

Respondent 

DECLARATION OF MARIA A^ON IN SUPPORT 

OF RESPONDENT. MIAMI-DADE COUNTY^S. 

ANSWER AND INCORPORATED MOTION TO DISMISS 

STATE OF FLORIDA ) 

COUNTY OF MIAMI-DADE ) 

I, Maria Afion, honeby swear or affirm under oadi the following: 

1. I am a Property Manager for Miami-Dade County's C'County") Aviatirai 

Department ("MDAD")* I have served in that capacity for five yeais. Prior to this position, I 

was a Senior Agent for Tmainal Operations at Miami loternational Airport for seven years. 

2. My duties as Property Manager for MDAD include leasing activities and 

management of properties for Miami-Dade County's Goieral Aviation Airports (Opa-locka, 

Kendall-Tamiami, Homestead General, and Dade-Collier Training and Transition Airport). 

3. I fir^ came in direct contact with the CcMnplainants in this matter in or around late 

2003, when I began my duties as a Property Mana ^ for MDAD. I am personally fiamiliar with 

the Complainants' leaseholds, business operations and rental rates. To my knowledge, all of the 

Complainants' leases at the time of assignment to AA required payment of $.15 per square foot 

of land. 
4. In or around Octoba 2004,1 began discussing the renewal oflfae lease agreement 

for the Cylinder Shop wiUi Wayman Luy, the own^. The negotiations over the terms of the 

renewal lease, which was in draft form, were on-going because the parties could not agree on die 

language. 

5. In or around the beginning of 2005,1 had to incorporate language to con^ly with 

MDAD's proposed minimum standards for the General Aviation Airports into die draft of the 

renewal lease to indude the specific use pertaining to die C^inder Shop's operations, i.e. 

measurements, ftcility requirements, hours of activity, etc. 

6. Sometime during these negotiations, Mr. Luy raised the idea of constructing a 

hangar &cility on his existing leasdiold in order to comply widi MDAD's proposed minimum 

standards. During the discussions of this new construction, I requested diat Mr. Luy provide me 

with a business plan, a preliminary sdiematic of the hangar fisicility and information regarding his 

financial abilities to obtain the fimds necessary to proceed with devdopment 

7. Attached is a copy of an e-mail chain dated June 3,2005 fix)m Mr. Luy to 

myself. In the first part of the e-mail, dated June 1,2005, Mx. Lay references a ''new lease," 

which, to my knowledge, referred to the draft of the renewal lease that I bad sent to him 

incorporating the new language regarding specific use. In the second part of the e-mail, dated 

June 2,2005,1 responded back to Mr. Luy stating that we needed to meet to discuss die renewal 

lease, and asking about the business plan requested in regards to a proposed sqMirate 

development lease for Mr. Luy's planned construction of the hangar. I moitioned the possibility 

of a "10-15 year lease" for this new devdopmoit in order to remain consistent witii MDAD's 

development aiteria that die length of any development lease agreement match the size of the 

intended investment to be made by the developer. 

8. To date, MDAD has never received any of die itons requested fipom Mr. Luy and 

the Cylinder Shop necessary to proceed with development lease agreement. 

Under penalties of perjury, I dedare that I have read the foregoing dedaration and the 

facts stated in it are true. 

Mariaf Ailon, AfSant 
ATTACHMENT TO DECLARATION OF MARIA AJ^ON 
Page 1 of 1 

Anon,Maria (Aviation) 

From: Wayman Luy [wluy@wayman.net] 

Sent. Friday, June 03,200510:50 AM 

To: Maria Anon 

Subfect: Re: lease 

Hi Maria. 

Tuesday ill be fine to meet in order to discuss the lease. Coutd We have a sample business in plan. We would 

lilcfi to know how it should be presented. 

Regards, 

Wayman 

Original Message 

Flam: Maria Anon 

To: Wsymap Luy 

Sent: Thursday, June 02,2005 4:31 PM 

Subject: RE: lease 

hfello Wayman, 

How are you doing? W^ definitely need to discuss the lease. I changed a few things, however, i could 

not make changes to all of the Items we previously discussed. I woukJ like to meet and provide yoi/with 

an explanatkMi. 

Do you have your business plan ready? Last time we spoke, you and Rosa were going to put something 

tbgefiier to present us. This would be a peifect opportuni^ since you already met Greg Owens. Manager 

Business Oevetopment, and be able to discuss 10-15 year lease. Let me know if you and I can 

meet Tuesday next week. 

—-Original Message— 

From; Wayman Luy [mailto:wluy@wayman.net] 

Senb Wednesday, June 01,2005 4:17 PM 

To: Maria Anon 

Subjecb lease 

Hi Maria, 

Thank you for giving us the new lease. We've noted that the measurement and prices of the properiy 

werechanged. However, none of the other points we disottsed were changed. CouW we set up an 

appointment to discuss ttte lease. 

Thanks 

Wayman Luy 

Wayman Aviation Servk:es 

Opa Locka Airport - Mianti, FL 

p 305 685 6468 

f 305 685 6449 

wtW<g»yaYman,pet 

http://www.waymgn.net 

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9/17/2008