JOHN ADAMS HODGE and ASSOCIATES, LLC 

Attorneys and Counselors at Law 

Environmental & Aviation Law 

136 Stonemark Lane, Suite 110 

Columbia, S.C. 29210 Mailing Address: 

John Adams Hodge, P.G. 

Sharon A. Hodge 

Telephone 803.783.9001/803.386.1504 

www.johnhodgelaw.com 

Post Office Box 25553 

Columbia, S.C. 29224 

The Honorable j. E. Sullivan 

United States Administrative judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New jersey Avenue, S.E. (El1-310) 

Washington, DC 20590 

December 4, 2014 

HEAFIING DOCKET 

Re: In Re: Renaissance jet Inc., Docket No. FAA-2013-0178; FAA Case No. 2012EA290030 

Dear judge Sullivan: 

Please find enclosed a motion and supporting documentation to dismiss the 

aforementioned case on grounds of mootness. By copy of this letter and enclosures, we are also 

serving counsel for the Administrator with the motion. Please let me know if you have any 

questions. 

Thank you very much for your consideration. 

cc: Zachary Berman, Esquire 

Enclosures 
U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

RECEIVED 

DEC 1 0 2014 

HEARING DOCKET 

) 

) 

Before Judge Sullivan 

In the Matter of Renaissance Jet, Inc. _______________________ ) FAA Case No. 2012EA390030 

Docket No. FAA-2013-0178 

MOTION TO DISMISS ON GROUNDS OF MOOTNESS 

Renaissance Jet, LLC, through its former manager, Mark Palmer ("Palmer"), by and 

through their undersigned counsel, hereby files this Motion to Dismiss the Civil Penalty Action 

brought by the Federal Aviation Administration ("FAA") pursuant to 14 CFR Chapter I, 

Subchapter B, Part 13, Subpart C, Section 13.218. This Motion to Dismiss is based upon 

grounds that both Renaissance Jet, Inc. and its successor Renaissance Jet, LLC are no longer in 

existence. Renaissance Jet, Inc. was dissolved on March 23, 2009 when it was converted to 

another business entity. Renaissance Jet, LLC was administratively dissolved by the North 

Carolina Secretary of State on November 19, 2014. In addition, Renaissance Jet, LLC does not 

possess an Air Taxi Certificate and no longer operates an FAR 135 charter business. Since the 

air carrier and the corporate entity have ceased to exist, the pending action is no longer a 

justiciable controversy as the issues involved have become academic. In support of this motion, 

please find attached a copy of the Articles of Dissolution and the affidavit from Mark Palmer. 

#265238 

Respectfully submitted, 

HODGE ASSOCIATES, LLC. 

By: --~~~~~~~~---------------

Ad msH e 

tonemark Lane (29210) 

P. Box 25553 

Columbia, SC 29224 

0: (803) 783-9001, Ext. 108 
Columbia, South Carolina 

December 4, 2014 

F: (803) 765-1243 

J ohnhodge@johnhodgelaw.com 

ATTORNEYS FOR RENAISSANCE JET, LLC 

2 
RECEiVED 

U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION DEC l 0 20i4 

) BeforeJudgesumvanHEAF!ING DOCKET 

In the Matter of Renaissance Jet, Inc. ) FAA Case No. 2012EA390030 

Docket No. FAA-2013-0178 

AFFIDAVIT OF MARK PALMER 

STATE OF NORTH CAROLINA 

COUNTY OF MECKLENBERG 

I, Mark Palmer, first being duly sworn, do hereby depose and state the following: 

I. My name is Mark Palmer and I am over 21 years of age and I am competent to give this 

affidavit. 

2. I was a manager/member of Renaissance Jet, LLC. 

3. Renaissance Jet, LLC was dissolved by Articles of Dissolution that were filed with the 

office of the North Carolina Secretary of State on November 18,2014. 

4. To the best of my knowledge, Renaissance Jet, LLC was dissolved with no assets and 

liabilities on November 18,2014. 

5. Renaissance Jet, Inc. was dissolved on or about March 23, 2009 when it was converted to 

another business entity, Renaissance Jet LLC. 

6. Renaissance Jet, LLC was formed pursuant to a plan of conversion of Renaissance Jet, 

Inc. 

t sayeth not 
Notary Public for North Carolina 

My commission expires:JIY'J..~ 1z_() 15 

2 
ARTICLES OF DISSOLUTION 

OF 

RENAISSANCE JET LLC 

SOSID: 1054492 

Date Filed: 11/19/2014 11:01:00 AM 

Effective: 11/18/2014 

Elaine F. Marshall 

North Carolina Secretary of State 

C2014 322 00909 

Pursuant to Section 570-6-09 of the North Carolina General Statutes, the undersigned 

limited liability company hereby submits the following Articles of Dissolution for the purpose of 

dissolving the limited liability: 

409919-1 

I. The name of the limited liability company is Renaissance Jet LLC 

2. The North Carolina Secretary of State ID Number is: I 054492. 

3. The limited liability company was dissolved by the unanimous written consent of 

its members and managers, and the effective date of the dissolution is the 181

h day 

ofNovember, 2014. 

This the 181

h day ofNovember, 2014. 

RENAISSANCE JET LLC 

By: X8 AVIATION, LLC, its Manager 

By: c_~vf' Mark Norcross, Member/Manager 
State of North Carolina 

Department of the Secretary of State 

ARTICLES OF ORGANIZATION 

INCLUDING ARTICLES OF CONVERSION 

SOSID: 1054492 

Date Filed: 411712009 4:111:00 PM 

Elaine F. Marshall 

North Carolina Secretary of State 

C200908601047 

Pursuant to Sections 57C-2-21, 57C-9A-OI, and 57C-9A-03 of the General Statutes of North Carolina, the undersigned 

converting business entity does hereby submit these Articles of Organization Including Articles of Conversion for the 

purpose of forming a limited liability company. 

I. The name of the limited liability company is Renaissance Jet LLC. The limited liability company is being formed 

pursuant to a conversion of another business entity. 

2. The name of the converting business entity is Renaissance Jet, Inc. and the organization and internal affairs of the 

converting business entity are governed by the laws of the state or of North Carolina. A plan of conversion has been 

approved by the converting business entity as required by law. 

3. The converting business entity is a domestic corporation. 

4. There shall be no limit on the duration of the limited liability company. 

5. The name and address of each person executing these articles of organization is Robert B. Stroud (organizer), 8541 

Calloway Road, Aberdeen, North Carolina 28315. 

6. The street address and county of the initial registered office of the limited liability company is Robert B. Stroud, 

8541 Calloway Road, Aberdeen, North Carolina 283\5 (Hoke County). 

7. The name of the initial registered agent is Robert B. Stroud. 

8. The limited liability company does not have a principal office. 

9. Except as provided by Section 57C-3-20(a) of the General Statutes of North Carolina, the members of this limited 

liability company shall not be managers by virtue of their status as members. 

\0. No person who is serving, or who was served, as a manager, director or executive of this limited liability company 

shall, except to the extent that the General Statutes of North Carolina prohibit the limitation or elimination of 

liability of managers, directors or executives for breach of applicable duties, be personally liable to this limited 

liability company or to any of its members for monetary damages for breach of duty as a manager, director or 

executive except for liability with respect to (a) acts or omissions that the manager, director or executive knew, at 

the time of the acts or omissions, were clearly in conflict with the interests of this limited liability company, (b) any 

transaction from which the manager, director or executive derived an improper personal benefit or (c) acts or 

omissions occurring prior to the effective date of these Articles of Organization. Improper personal benefit, as used 

herein, shall not include reasonable compensation or other reasonable incidental benefit for or on account of service 

as a manager, director, executive, officer, employee, independent contractor, attorney or consultant of this limited 

liability company. No amendment to or repeal of this provision and no adoption of a provision inconsistent 

herewith shall apply to or have any effect on the liability or alleged liability of any manager, director or executive of 

this limited liability company for or with respect to any acts or omissions of the manager, director or executive 

occurring prior to such amendment, repeal or adoption of an inconsistent provision. The provisions hereof shall not 

be deemed to limit or preclude indemnification of a manager, director or executive by this limited liability company 

for any liability that has not been eliminated by the provisions hereof. 

II. The operating agreement--or any agreement that purports or is alleged to be the operating agreement-of the 

limited liability company, as defined in Section 57C-l-03(16) of the General Statutes ofNorth Carolina, shall be in 

CORPORATIONS DIVISION 

(Revised January 2002) 

P.O. BOX 29622 RALEIGH, NC 27626-0622 

(Form L-OlA) 
.. 

writing and duly executed by all of the members of the limited liability company; provided, however, that, if all of 

the members of the limited liability company fail to refuse to sign an operating agreement, the limited liability 

company shall be operated pursuant to Chapter 57C of the General Statutes of North Carolina. 

12. These articles will be effective upon filing. 

This is the 1:)_ day of March, 2009. 

CORPORATIONS DIVISION 

(Revised January 2002) 

Renaissance Jet, Inc. 

1illrf~ President 

P.O. BOX 29622 

OkGANIZER 

RALEIGH, NC 27626-0622 

(Form L-OlA) 
Corporations Division http ://www.secretary.state.nc. us/Search/RnnSearch 

I of I 

Elaine F Marshall 

Secretary 

North Carolina 

EPARTMENT OFTHE 

SECRETARY oF STATE 

PO Bo< 29622 Raleigh. NC 27626-0622 (919)807-2000 

Search Results (1 - 4) Search: renaissance jet Search Again 

Account 

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Register 

I Entity Name ... !I Sosld l . Type Jl Status Jl Date Formed il Online Annual Report 

lf<en~issance Jet LLC[I10544921Business Corporation IDissolvectJ4!22/200B1200:00!1.M!IFile Report 

I Renaissance Jet LLcJI1054492;1Limited LiabilityCompanyj[i}issolvectil4/17/200912 OO:OOAM 'I File Report 

I Renaissance Jet, Inc. il1 0544921 Business Corporation .......... I Dissolvect[4l22/200812:00:00AM I File Report 

!.Renaissance Jet, Inc .. J1.1.054492'1urnitedliabilityCompanyJI Dissolve_ct]I4/~7/2009 ... 1200:0Q AM.IFileReport 

12/3/2014 11:23 AM 
Corporations Division http:/ /www.secretary.state.nc. us/Search/profcorp/90860 17 

Click Here To: 

Elaine F Marshall 

Secretary 

North Carolina 

DEPARTMENT OFTHE 

SECRETARY oF STATE 

PO Box 29622 Raleigh. NC 27621l-0622 (919)!307-2000 Account 

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------------------------------------------------------

View Document Filings File an Annual Report Print a Pre-Populated Annual Report form 

Amend a Previous Annual Report 

Corporate Names 

Legal: Renaissance Jet LLC 

Prev Legal: Renaissance Jet, Inc. 

Limited Liability Company Information 

Sosld: 1054492 

Status: Dissolved 

Annual Report Status: Not Applicable 

Citizenship: Domestic 

Date Formed: 4/17/2009 

Fiscal Month: December 

State of Incorporation: NC 

Registered Agent: Norcross. Mark 

Corporate Addresses 

Mailing: 15105-D John J. Delaney Dr. PMB 302 

Charlotte, NC 28277-2848 

Reg Mailing: 15105-D John J. Delaney Dr. PMB 302 

Charlotte, NC 28277-2848 

Principal Office: 1560 N Main St Ste 103 

High Point, NC 27262-2742 

Reg Office: 1560 North Main Street Suite 103 

High Point, NC 27262-27 42 

Company Officials 

Manager: Mark Palmer 

15105-D John J. Delaney Dr PMB 302 

Charlotte NC 28277 

Manager: X8 Aviation, LLC 

1560 North Main St. Suite 103 

High Point NC 27262 

I of! 12/3/2014 11:17 AM 
CERTIFICATE OF SERVICE 

I hereby certify that a copy of the foregoing Motion to Dismiss on Grounds of Mootness 

In the Matter of Renaissance Jet, Inc., FAA Case No. 2102EA390030, was mailed this 4th day of 

December, 2014, to: 

Zachary Berman, Esquire 

Office of Regional Counsel, Eastern Region 

Federal Aviation Administration 

1 Aviation Plaza 

Jamaica, N.Y. 11434 

The Honorable J.E. Sullivan 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Dept of Transportation 

1200New Jersey Avenue, S.E. (Ell-310) 

Washington, DC 20590 

The original and a copy were mailed to: 

Federal Aviation Administration 

Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2WIOOO 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, DC 20591 

3