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

In The Matter Of: U.S. DEPARTMENTOF TRANSPORTATION OFFICEOFHEARINGS

WASHINGTON,D.C. DOCKETNO. FAA-2014-0119 SPIRITAVIONICS, LTD. ) ) ) ) CASENO. 2012-GL-07-0056 Respondent. SUPPLEMENTAL DECLARATION OFERIC C. OCHS NOW COMESthe Declarant, Eric C. Ochs, and for his Supplemental Declaration states as follows: 1. I am overthe age of 18, under no disability, competent to testify, and I understand the obligationsofan 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"Uectofthe instantmatter 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 bySpiritAvionics usingrawmaterials. All parts and materials, for ali aircraft, were purchased with funds from theFAA. 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 relevantto the business arrangement under that contract. Ifsuch documentation were not generated, there would be phantom entries in a ledger without any indication ofhow those amounts were obtained. Further, without such a practice in place it would be impossibleto properlyallocate our incometo the correctproject.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, ofthe total miscalculation ofthe cost to purchase and install the headliner installationkit 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 ofapproximately $7,416.91 per subcontractor. Thus, the loss due tothe miscalculation was shared equally by Spirit, Lane Aviation, and Tritex. FurtherDeclarantsayethnaught. I, Rick Oehs, declare this 

## r:(1 day of August, 2015, under penalty of petjury that the nbove statements are trueand correct.

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

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12022671293 FAA Hearing Docket
16147981620 Patrick Mom
FAA-2014-0119 6

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

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