To: 12022671293 From: 15147981520 Date: 08/14/15 Time: 12:05 PM Page: 02/06 

In The Matter Of: 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

DOCKET NO. FAA-2014-0119 

SPIRIT AVIONICS, LTD. 

) 

) 

) 

) 

CASE NO. 2012-GL-07-0056 

Respondent. 

SUPPLEMENTAL DECLARATION OF ERIC C. OCHS 

NOW COMES the Declarant, Eric C. Ochs, and for his Supplemental Declaration states as 

follows: 

1. I am over the age of 18, under no disability, competent to testify, and I understand the 

obligations of an oath. 

2. I am currently the CEO of Sprit Avionics, Ltd. and have held this position since its 

creation in 2000. 

3. The brackets and lanyards which are the sul"Uect of the instant matter are components that 

comprise the headliner installation kit referenced on the invoices issued to both Tritex 

and Lane Aviation and attached as Exhibits D and E to Respondent's Motion for 

Decision (hereinafter, the "Invoices"). 

4. The brackets and lanyards in question were purchased and/or fabricated from raw 

materials sourced with funds provided by the FAA. For the first two aircraft identified 

under the contract, both brackets and lanyards were purchased from a vendor. For the 3'" 

through 18'11 aircraft, the lanyards were purchased from a vendor; the brackets were 

fabricated in house by Spirit Avionics using raw materials. All parts and materials, for ali 

aircraft, were purchased with funds from the FAA. 

5. When working on a project with multiple contractors, regardless of whether they are 

members to a joint venture or subcontractors reporting to a prime contractor, it is of 

critical importance to track all money in and all money out. As such, it is a customary 

business practice to issue an invoice for any money that is to be paid for any purpose 

relevant to the business arrangement under that contract. If such documentation were not 

generated, there would be phantom entries in a ledger without any indication of how 

those amounts were obtained. Further, without such a practice in place it would be 

impossible to properly allocate our income to the correct project. 
To: 12022671293 From: 16147981620 Date: 08/14/15 Time: 12:06 PM Page: 03/06 

6. Each of the invoices issued tn both Tritex and Lane Aviation represent one third, 

respectively, of the total miscalculation of the cost to purchase and install the headliner 

installation kit identified in the bid submitted to the FAA. The total cost for the headliner 

installation kits was in the amount of approximately $22,250.73. This represents and 

individual shared loss of approximately $7,416.91 per subcontractor. Thus, the loss due 

to the miscalculation was shared equally by Spirit, Lane Aviation, and Tritex. 

Further Declarant sayeth naught. 

I, Rick Oehs, declare this r:(1day of August, 2015, under penalty of petjury that the nbove 

statements are true and correct. 

~-~-- ') 

Eric C. Ocl~~ ----

Spirit Avionics, Ltd. 
To: 12022671293 From: 16147981620 

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Date: 08/14/15 Time: 12:06 PM Page: 01/06 

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FAA Hearing Docket 

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FAA-2014-0119 

6 

Please find the attached Answer to Complainant's AmendOO Complaint and the Supplemental Affida\<\t of Eric ()chs attachEd. 

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