W. TrMOTHY HAITHCOCK 

GLENN A. BARFIELD 

B. GEOFFREY HULSE 

REBECCA B. KrNSEY 

WORTH T. HAITHCOCK II 

HAITHCOCK, BARFIELD, HULSE & KINSEY, PLLC 

ATTORNEYS AT LAW 

231 EAST WALNU T STREET 

POST OFFIC E DRAWE R 7 

GOLDSBORO, NORTH CAROLINA 27533-0007 

TELEPHON E (919) 735-6420 

FAX (919) 734-6296 

haithcock@hbhklaw.com 

barfield@hbhklaw.com 

hulse@hbhklaw.com 

kinsey@hbhklaw.eom 

worth h@hbhklaw.eom 

March 2, 2009 

Mr. Jonathan Cross 

Federal Aviation Authority 

Office of the Chief Counsel 

Attn: FAA Part 16 Airport Proceedings Docket 

AGC-610 Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Re: Delbert Johnso n d/b/ a Two Dogs Aviation v. 

Goldsboro-Wayne Airport Authority, Docket No. 16-08-11 

Dear Mr. Cross: 

Enclosed please find the Complainant's Reply to the Respondent's 

Answer and Motion to Dismiss in the above referenced Part 16 

proceeding. Please let me know if you find any aspect of this filing 

incomplete or procedurally insufficient. 

With warmest regards, 

HAIT KINSEY, PLLC 

r-,7 

GAB/gb 

Cc: Harrell Everett 

Pablo Nuesch 
BEFORE THE FEDERAL AVIATION ADMINISTRATION 

DELBERT JOHNSON 

d/b/a TWO DOGS AVIATION, 

Complainant, 

vs. 

GOLDSBORO-WAYNE 

AIRPORT AUTHORITY, 

Respondent. 

REPLY 

iECEnW i 

AIRPORTS/ENVIRONMENTAL 

I UW.AGC-600 • 

In his Complaint docketed December 3, 2008, Delbert Johnson asserted that the 

Goldsboro-Wayne Airport Authority ("the GWAA") has failed to comply with 49 USCS § 

47107 et seq., federally mandated grant assurances, and FAA Orders by the following conduct: 

A. Granting SIG Aviation, LLC ("SIG") an exclusive right to sell aviation fuels at the 

Goldsboro-Wayne Airport ("the airport"); and 

B. Failing to negotiate with Johnson on reasonable terms for the lease of space on which to 

operate a self-service avgas fuel facility, resulting in the perpetuation of SIG's monopoly, and in 

economic discrimination against Johnson; and 

C. Imposing unjust and discriminatory conditions on Johnson's proposed FBO operation; and 

D. Failing to make the airport as self-sustaining as possible under the circumstances, by 

excessive payments to SIG for airport management. 

E. Improperly creating and maintaining a conflict of interest by engaging SIG as the Airport 

Manager, allowing SIG to grant itself waivers and other concessions as an FBO. 

F. Allowing diversion of airport revenues to a board member by illegally paying that member 

for services to the GWAA; and 

G. Allowing diversion of airport revenues by illegally making payments on an illegally obtained 

loan; 
On January 26, 2009 the GWAA filed its Answer and Motion to Dismiss, together with a 

Memorandum in Support of its Motion. Complainant Johnson files this Reply Memorandum 

pursuant to 14 CFR sect. 16.23(e). 

I. SIG'S FUEL MQNOPLOY, AND THE GWAA's REFUSAL TO ALLOW JOHNSON'S 

APPLICATION FOR A COMPETING SERVICE (A-C, E above) 

The GWAA has granted SIG an exclusive fuel sales monopoly by refusing to negotiate 

with Johnson in good faith on reasonable terms, and by imposing unjust and discriminatory 

conditions on Johnson's proposed self-service avgas business. By statute and FAA regulation, 

the GWAA may not grant or permit an 

"exclusive right for the use of the airport by any person providing, or intending to provide, 

aeronautical services to the public. For purposes of this paragraph, the providing of the services 

at an airport by a single fixed-based operator shall not be construed as an exclusive right if both 

of the following apply: a. It would be unreasonably costly, burdensome, or impractical for more 

than one fixed-based operator to provide such services, and b. If allowing more than one fixedbased operator to provide such services would require the reduction of space leased pursuant to 

an existing agreement between such single fixed-based operator and such airport." (Grant 

Assurance 23) 

The GWAA does not dispute that SIG is the only FBO currently allowed by the GWAA 

to sell aviation fuel on the airport. Nor does it contend that it has denied Mr. Johnson's 

application to operate a competing fuel sales business for either of the reasons set out in 

subsections (a) or (b) above. It argues four reasons why SIG's monopoly on fiiel sales does not 

constitute an impermissible exclusive right. 

The GWAA first argues that the FBO contract between SIG and the GWAA includes 

boilerplate language specifying that SIG's franchise is "nonexclusive", and made subject to the 

grant assurances given by the GWAA to the FAA. The GWAA does not seriously contend 

however that this language would excuse its actual noncompliance with those assurances. 
Next the GWAA argues that it has not granted SIG an exclusive right because (1) it 

"ultimately granted" Complainant's application, so its initial denial on economic pretext is not 

evidence of an intent to protect SIG, (2) the conditions it imposed, including site approval and 

Fire Marshal approval, were reasonable, and (3) its waiver of the same conditions for SIG was 

justified. Complainant addresses these arguments in turn. 

Initial Denial was Pretext. 

The GWAA argues that its initial denial, on supposed economic grounds, did not show an 

intent to protect SIG's exclusive fuel franchise. The evidence however is to the contrary. Most 

importantly, the GWAA's initial stated reliance on economic grounds was clearly pretextual. 

First, Jim Steele stated, in public at least, that the Complainant's proposed self service 

avgas operation would have no significant effect on SIG's business. (Answer, 119) The GWAA 

then admits that it did not imdertake any economic analysis before denying the application on 

economic grounds. It claims however that it did obtain some economic information and opinion 

before making its decision - a chart showing historical fuel sales, and a letter from the president 

of Eastern Aviation Insurance Services. (Answer, Tf 21, 25, Answer, Exhibits F and R.) 

Curiously, while Exhibit F is purported to be the fuel sales chart the GWAA reviewed in May 

2007, it shows fuel sales through November 2008. 

The letter from Eastern Aviation Insurance Services is even more troubling. It is 

presented here as an independent disinterested opinion, its author stating "I believe it would be 

potentially the single largest mistake the Authority could make should they decide to allow nonbranded fuel storage/sales to be permitted at the airport". However, the author is not at all 

disinterested. The company's Chairman and CEO is Buddy Stallings, who is also the principal in 

Eastern Aviation Fuels, Inc. - the supplier of the "branded" Shell fuel sold by SIG. (Reply 
Exhibits A, B, C). It is little wonder that Eastern Aviation would discourage allowing a 

competitor to sell avgas at the airport, and it is telling that the GWAA failed to disclose that 

relationship to the FAA. 

As telling is the email GWAA Board member Otto Keesling sent Complainant, 

apparently by mistake, in April 2007. (Reply Exhibit D). Mr. Keesling intended the message for 

Jim Steele, SIG's manager (and through SIG, the GWAA's airport manager). Mr. Keesling 

notes that Complainant Johnson was asking for a meeting regarding his application, and states 

"He (Johnson) is starting to arouse my competitive spirit." Mr. Johnson was applying to 

compete with SIG, not the GWAA; Mr. Keesling's comment indicates his alliance with the 

interests of SIG. 

Taken together, this evidence shows that the GWAA's initial reliance on supposed 

economic problems was a mere pretext - as does its subsequent abandonment of that position. 

The real reason Complainant was denied was that SIG, despite Steele's public comments, did not 

want a competitor for fuel sales. And as shown by its other activities, the GWAA had ceded 

operation of the airport to SIG. 

Reasonableness of Conditions for "Approval" 

A, Site Approval 

The GWAA inexplicably claims that "As of the date of this Answer, Complainant has not 

yet sought approval for a specific site at the airport in which to conduct his self-fueling 

business." (Answer, Tf 25). The GWAA then refers to the affidavit of Cleveland Wilkins, 
Answer Exhibit A, where at ^ 19 he states, "To the best of my knowledge, Mr. Johnson has yet 

to seek approval for a site...". These statements are simply false. 

Mr. Johnson's original application. Complaint Exhibit A, included an aerial photograph 

of the airport on which the proposed site is denoted as "SELF-SERVE HERE". In his 

presentation to the Board on May 15, 2007, Mr. Johnson noted that "Location was talked about 

with Mr. Keesling prior to proposal", and that the GWAA's independent civil engineer. Trey 

Gurley, was assessing the proposed site. (Complaint Exhibit A, p. 2, Section (c)(ii)). Airport 

Manager Jim Steele had emailed Mr. Johnson on April 24, 2007 to tell him the site review had 

been referred to Mr. Gurley. (Reply Exhibit E). Mr. Gurley and Mr. Johnson corresponded by 

email on May 9-10, 2007 regarding the site, at which time Mr. Johnson described the site and the 

installation in detail. Mr. Gurley confirmed that he understood the site proposed. (Reply Exhibit 

F) 

Thereafter on May24/30, 2007 the GWAA denied Mr. Johnson's application based on the 

supposed economic concerns, with no suggestion that the proposed site was an issue. (Complaint 

Exhs. C, D). Later, on October 24, 2007, the GWAA's attorney wrote Mr. Johnson's attorney 

informing him that the Board "no longer objects" to the application on economic grounds, and 

that the application would be approved "subject to the approval of the site at the Airport by the 

Authority and assurances that the self-service facility meets the State and County safety 

requirements." (Complaint Exh. K) Again, there was no suggestion that the GWAA was in any 

respect uncertain of what site had been proposed by Mr. Johnson. 

On November 26, 2007 Mr. Johnson emailed the GWAA's attorney, and pointed out that 

Mr. Keesling and Mr. Gurley had both reviewed the site, with neither presenting any objection. 

(Reply Exh. G) GWAA's attorney then wrote Mr. Johnson's attorney on December 6, 2007 
stating that "Mr. Keesling advised me, as Chairman of the Buildings and Grounds Committee, 

that he had not approved a specific site in conjunction with the Authority's Engineer, Trey 

Gurley." (Complaint Exh. L) Again, there was no suggestion that either Mr. Keesling or Mr. 

Gurley was uncertain of the site which Mr. Johnson had proposed, and neither could have been. 

To say now that Mr. Johnson "never sought" site approval is disingenuous at best. The 

GWAA has simply refused to communicate its approval or disapproval of the site Mr. Johnson 

proposed. And as Mr. Johnson pointed out in his email of November 26, 2007, "The only way 

the fire marshal will approve the equipment is to know where it will be installed...[0]f course 

this hurdle requires that the board acknowledge that the proposed, studied, and engineered site is 

approved and then I will obtain fire marshal approval in short order." (Reply Exh. G) 

B. The GWAA's refusal to negotiate in good faith. 

FAA Order 5190.6A, Section 4-14 (c) provides in relevant part: 

"If adequate space is available on the airport, and if the airport owner is not providing the 

service, it is obligated to negotiate on reasonable terms for the lease of space needed by those 

activities offering flight services to the public, or support services to other flight operators, to the 

extent that there may be a public need for such services. A willingness by the tenant to lease the 

space and invest in the facilities required by reasonable standards shall be construed as 

establishing the need of the public for the services proposed to be offered." 

The GWAA "approval" communicated on October 24, 2007 (Complain Exh. K) stated 

that Complainant would be required to comply with "specifically the requirements of Section 8" 

of the Authority's Rules and Regulations. These are set out at Complaint Exhibit M, pp. 6-10. 

They include in subsection B the following: 

"Fixed base operators providing sale of aviation petroleum products shall also be required to 

meet the minimum standards and offer the services listed in Sections 8.1. [including light line 

maintenance], 8.J. [including comprehensive repair, maintenance, and storage, facilities and 

services], 8.K. [flight training], and 8.L. [Aircraft Charter and Taxi Service]." 

On November 1, 2007, Mr. Johnson's counsel responded: 
"Certainly so far as the requirements of Section 8 would have any rational application to [the 

proposed self-service operation], my clients are prepared to comply with those. However it is 

obvious that many of those requirements have no application whatsoever to the type of facility 

proposed by my clients. We would certainly expect the Authority to waive the inapplicable 

requirements, as it has done for the entity with whom my clients' operation would compete. 

Mr. Johnson has communicated his proposal in that regard to Mr. Steele, in his capacity as 

the Airport Manager. We will expect the Authority to negotiate the details of this arrangement 

in good faith. (Complaint Exhibit N, emphasis added) 

As the GWAA has admitted, it had already "waived" the requirements of subsections 8.1, 

J, and K for SIG. (GWAA Memorandum, p 26). There are actually no formal waivers, and 

neither SIG's 2002 nor 2007 FBO contracts reflect such waivers. It is perhaps more accurate to 

say that the GWAA has allowed SIG (in its role as Airport Manager) to "waive" whatever 

requirements it prefers not to meet. For example, SIG recently decided to "waive" for itself the 

only Section 8.B. fuel seller requirement it had ever met, provision of charter/air taxi services. 

(Reply Exhibit H). (Mr. Johnson by contrast still meets at least one of the requirements, 

provision of flight training.) 

Despite having "waived" the requirements for SIG, the GWAA responded on December 

6, 2007 by stating again that Complainant would have to "meet the requirements of Section 8". 

(Complaint Exh. L) There was no suggestion that the GWAA was "willing to consider similar 

waivers for the Complainant's proposed business", despite the GWAA's present claim to such 

reasonableness. (GWAA Memorandum p. 26, Answer Exh. A) 

Nonetheless, the GWAA now claims it would indeed have been willing to negotiate such 

waivers, if only Mr. Johnson had not "presented a list of outrageous and unreasonable demands" 

unrelated to the Section 8 requirements. (GWAA Memorandum p. 27), The GWAA's evidence 

of these purported demands is the third hand hearsay report of the GWAA Board Chair, Cleve 

Wilkins. (Answer Exh. A). However, while Mr. Johnson certainly believes that the GWAA 

7 
Board has many sins for which to answer, he insisted that the negotiation for approval of his selfservice avgas facility be entirely separate from those other matters. Reply Exhibit I is a copy of 

correspondence between the parties' respective attorneys (by e-mail on November 8, 2007 and 

US Mail on November 9, 2007), following the meeting referenced by Mr. Wilkins in his 

affidavit. Because the GWAA so thoroughly misrepresents this aspect of the matter, the text is 

reprinted in full below. 

Harrell, 

I have been thinking about your indication that these matters can only be settled globally. You 

will recall that I urged the AA to assess and negotiate each dispute separately. I want to speak 

further to that issue. 

There are essentially five areas of dispute, and the Johnson's legal remedies are different for 

each of those matters. 

As to the self-service avgas proposal, on failure to agree the Johnsons' remedy would be a 

complaint to the FAA contending theAA has illegally granted and protected an exclusive right 

for SIG to sell aviation fuels, and separately at some point an action against SIG and the AA 

contending anti-trust and unfair trade practices, seeking money damages. 

As to SIG's conflicts of interest and diversion of revenue, on failure to agree the Johnsons 

could file a separate FAA complaint, but not likely a legal action, and there would be no 

damages to recover separate from the avgas monopoly. 

As to the Public Records, on failure to agree the Johnsons' could bring a statutory action 

seeking compliance and legal expenses, but not damages. 

As to the non-approved loan, on failure to agree the Johnson's could seek injunctive relief and 

on behalf of the AA seek recovery of improper payments from BB&T and reimbursement from 

the individual Board members. They could make a claim for legal expenses, but not damages. 

As to Ken's receipt of payments, on failure to agree the Johnson's again could seek injunctive 

relief and on behalf of the AA seek reimbursement of improper payments from Ken, and could 

make a claim for legal expenses, but not damages. 

Therefore the only matter in which the Johnsons could seek money damages would be 

ultimate denial of their FBO application; otherwise they could only seek, in money, 

reimbursement of legal expenses. If we conditioned settlement of any of the other matters on 

settlement of the avgas proposal, it might be construed as seeking (avgas)money in exchange 

for an agreement to refrain from reporting the Board's non-compliance with statutory duties. 
This is especially troubling as it relates to the loan and the payments to Ken, because violation 

of the relevant statutes constitute criminal offenses. The Johnsons have suggested that the 

Board be re-vamped and procedures implemented to prevent conflicts of interest and to ensure 

the Board's independence from any private influence, and to bring complete transparency to 

the AA's financial operations. It seems to me that that is the only legitimate demand they 

could make as consideration for their forbearance from litigation as to the loan or 

reimbursement from Ken (which I would hope he would make in any event). 

For these and other reasons, I believe the AA and the Johnsons must work toward resolution 

of these issues separately, with the Johnson's forbearance in each case being exchanged for 

AA action in that respective case. 

Warmest regards, 

Glenn 

HAITHCOCK, BARFIELD, HULSE & KINSEY, PLLC 

GLENN A. BARFIELD 

919-735-6420 (phone) 

919-734-6296 (fax) 

barfield(a)hbhklaw.com 

The GWAA now states that after receiving this message it "concluded that good faith 

negotiations for a suitable accommodation of Complainant's proposed business was not realistic 

and simply restated its conditional offer." It is frankly difficult to understand how GWAA's 

Chairman was able to sign his name to that statement. 

The GWAA has never offered to negotiate any waiver of any Section 8 requirement, 

despite enforcing none of those requirements against SIG. 

C. GWAA ' s refusal to grant Complainant waivers equivalent to those granted SIG is unjust, 

unreasonable, and constitutes impermissible economic discrimination. 

Grant Assurance 22 provides in relevant part: 

"22. Economic Nondiscrimination. 

a. [The Sponsor] will make the airport available as an airport for public use on reasonable terms 

and without unjust discrimination to all types, kinds and classes of aeronautical activities, 

including commercial aeronautical activities offering services to the public at the airport. ... 
c. Each fixed-based operator at the airport shall be subject to the same rates, fees, rentals, and 

other charges as are uniformly applicable to all other fixed-based operators making the same or 

similar uses of such airport and utilizing the same or similar facilities. ... 

h. The sponsor may establish such reasonable, and not unjustly discriminatory, conditions to be 

met by all users of the airport as may be necessary for the safe and efficient operation of the 

airport." 

FAA Order 5190.6A, Section 3-12 provides in relevant part: 

"A prudent airport management should establish minimum standards to be met by all who would 

engage in a commercial aeronautical enterprise at the airport. It is the prerogative of the airport 

owner to impose conditions on users of the airport to ensure its safe and efficient operation. Such 

conditions must, however, be fair, equal and not unjustly discriminatory. That is to say, they 

must be relevant to the proposed activity, reasonably attainable, and uniformly applied." 

FAA Order 5190.6A, Section 3-17 provides in relevant part: 

"Manipulating the standards solely to protect he interest of an existing tenant is incompatible 

with this objective. A standard which a tenant operator is required to meet must be uniformly 

applicable to all operators seeking the same franchise privileges". 

The GWAA argues that the conditions it would impose on Mr. Johnson's business are 

reasonable. First it contends it was reasonable to require site approval and Fire Marshal safety 

assurances. However as noted above, the GWAA has refused to approve (or disapprove) the site 

proposed, and now pretends Mr. Johnson never sought approval of a site. Without site approval 

there can be no Fire Marshal assurances. Thus while these conditions themselves are certainly 

reasonable, the GWAA has unreasonably prevented Mr. Johnson from meeting them. 

The GWAA argues next that requiring an FBO selling aviation fuel to provide other 

"bundled" aeronautical services is not a per se violation of the Grant Assurance obligations, and 

that such requirements are common. Complainant does not contend a per se violation, and 

recognizes that in appropriate circumstances, a Sponsor may require an FBO fuel seller to offer 

other services. However, a Sponsor cannot unjustly discriminate against one FBO and in favor 

10 
of another, by requiring one to provide the additional services while "waiving" that requirement 

for the other, especially where the result is to protect the other FBO's monopoly in fuel sales. 

The GWAA explains that it waived for SIG three of the four Section 8.B. fuel seller 

requirements (provision of light line maintenance (Section 8.1), aircraft maintenance (Section 

8.J.), and flight training (Section 8.K.) because other entities were supplying these services on 

the airport. (As noted above, SIG has since ceased providing the fourth required service, 

charter/air taxi.) However the GWAA does not explain why the same reasons do not apply to the 

waivers requested by Mr. Johnson. (Answer, p. 26) 

Indeed the GWAA acknowledges that it was required to "consider" the waivers requested 

by Mr. Johnson, and attempts to avoid its obligation by now claiming it was Mr. Johnson who 

would hot negotiate. (Answer p. 26-27) As noted above, that claim is not merely inaccurate. It 

is knowingly false, and is made here by the GWAA in evident bad faith. 

The GWAA states "[t]he Complainant, however, appears to refuse to accept that, if he is 

going to offer for sale aviation fuel at the Airport (self-service or full-service) he must provide 

other aeronautical services along with his fiieling business." (Answer, p.26) Section 8.B. lists 

those four services. As of the date of this Reply, Mr. Johnson offers one of the four, flight 

training. SIG offers none. The GWAA has unjustly and arbitrarily imposed conditions on 

Complainant, not imposed on the competing FBO. 

II. GWAA has ceded complete control of the airport to SIG, allowing SIG to use its position as 

Airport Manager to maintain its monopoly on fuel sales, while also failing to make the airport as 

self-sustaining as possible under the circumstances, by grossly over paying SIG for airport 

management. (D and E above). 

The Complainant contends, and GWAA denies, that the GWAA has improperly granted 

SIG exclusive rights and created an impermissible conflict of interest by the combination of 

11 
contracts it has entered into with SIG, which include an FBO contract currently granting SIG an 

exclusive right to sell aviation fiiel, a Lease contract granting SIG the right to lease/sublease 

virtually all the hangars at the airport, and a management contract appointing SIG as Airport 

Manager with the power and obligation to enforce the Airport Rules and Regulations (all with 

twenty year terms). The GWAA responds by pointing out that despite its stewardship of nearly 

four million dollars in public assets, it has chosen to have no employees, and that it thus needs to 

contract with one of its commercial tenants for management services. But, it notes, this is not per 

se prohibited by FAA regulations and guidelines. (Answer pp. 28-29). 

The GWAA puts great stock in its assertion that the Management, Lease, and FBO 

contracts are "separate". (Answer p. 29). In fact the contracts are not at all separate; rather they 

each explicitly incorporate the others. The FBO contract (Complaint Exh. R) provides that "this 

[FBO] Agreement and the Lease Agreement are expressly conditioned upon each other." 

(Section 18). The Lease Agreement (Complaint Exh. T) provides that "SIG is only leasing the 

Premises for the purpose of providing the FBO services." (page 1). And the Airport Management 

Agreement (Complaint Exh. S) provides that it automatically terminates upon the termination of 

either the FBO or Lease Agreements.(Section 10 (b)). 

Thus while there are three "separate" documents, they are together a single 

comprehensive contract through which SIG is given complete and comprehensive control of the 

entire Airport operation. With very limited exceptions involving a few privately owned hangars, 

any other party wishing to operate a commercial aeronautical activity on the airport must do so 

as a subtenant of SIG, while being subject to SIG's authority as Airport Manager. Not 

surprisingly, as the GWAA acknowledges, SIG has no competition for any commercial service it 

actually provides. And as noted in Part I above, SIG as Airport Manager has elected not to 

12 
enforce against itself any of the Section 8 fuel seller requirements with which the GWAA now 

insists Complainant must comply (most recently exempting itself from the requirement that it 

provide charter and air taxi service). 

SIG's manager and the GWAA's Chairman insist in self-serving affidavits that these 

contracts were negotiated "at arms length,", but the GWAA can produce no documentation of 

any negotiations, proposals, offers, or counteroffers. Instead it claims that the negotiations were 

done "in person" between Mr. Steele and two Board members, resulting in three twenty year 

contracts being produced whole and complete, without the creation of any notes, drafts or 

revisions. (Complaint Exhibit L) This is the case even though the "negotiations" occurred after 

the Complainant through counsel had earlier notified the GWAA that he believed the similar 

2002 contracts violated both the conflict of interest and fair market value provisions of Part Six 

of FAA Order 5190.6A. (Complaint Exhibit E). 

And, because the 2007 contracts call for payments to SIG in excess of $500,00.00 over 

the twenty year term of the contract. Local Government Commission approval was required -

but like the 2005 loan referenced in the Complaint, SIG's contracts were never even submitted to 

the LGC. It is difficult to tell whether the parties were negotiating at arm's length when all the 

alleged negotiations were done in the dead dark. 

The GWAA contends that its arrangement with SIG arrangement does not violate the 

self-sustainability rule, because it is not required to "maximize" its income, and it insists that it 

gets its money's worth from SIG. Complainant recognizes that an airport sponsor is afforded 

considerable discretion in making business decisions, but even the GWAA admits it is required 

to "make appropriate business decisions that would make the airport as self-sustaining as 

circumstances would permit". (Answer p. 38) While the contracts with SIG may not have been 

13 
subject to any statutory requirement for public bidding, neither has the GWAA explained how it 

determined what rate of payment was appropriate. It has however provided an apt comparison, 

which shows the degree to which SIG is overpaid in the current contracts. 

From 2000 to 2003 the GWAA paid the prior Airport Manager $27,000.00 per year. 

(Answer p 42, Answer Exh. Q) For that price, the Manager provided all the services SIG now 

provides, including management of the hangars and collection of rents. In addition however, the 

prior Manager also provided all labor and equipment for grass cutting and ditch maintenance, a 

duty omitted from the SIG Airport Management contract. In 2007 that job was budgeted at 

$21,500.00. 

The parties agree that SIG's total compensation for management, including the net 

revenue it collects from the Lease contract, is over $56,000.00 per year. Thus for the services 

the prior Manager provided for $27,00.00 per year, including grounds maintenance, the GWAA 

now pays nearly $80,000.00 per year. The GWAA claims that SIG "makes available six different 

employees who provide the required management services". (Answer p. 29). However as the 

GWAA acknowledges, these are SIG employees whose primary duties are related either to SIG's 

FBO business, or the piloting and maintenance of SIG's ovra corporate jet (SIG Aviation LLC is 

a subsidiary of Strickland Insurance Group, Inc.)(Answer Exh. A, Reply Exhs. J, K). Thus there 

is no employee with full time responsibility for airport management, and as reflected in 

Complaint Appendix Exh. CC, all significant repair and maintenance is contracted out at the 

GWAA's expense. And as admitted by the GWAA (Answer p. 45) the Airport Manager does not 

even keep and maintain any of the GWAA's public records, requiring its outside counsel to 

perform this ministerial task. It is evident that this arrangement is economically inappropriate. 

14 
Ill Violation of North Carolina Statutory Law. 

Generally speaking, Complainant does not disagree that violations of State law are not 

subject to correction by way of a Part 16 complaint. However where the violations consist of 

illegally paying airport revenues to third parties in violation of state criminal law, and the 

subsequent failure of the Sponsor to take steps to recover the illegal payments, the violations 

impact the ability of the airport to be self-sustaining, and divert the airport's revenues to an 

illegal purpose. 

The GWAA admits that it made at least $6,000.00 in payments to a Board member, in 

violation of a state conflict of interest statute making such payments a criminal offense, and that 

it did so regularly for over three years. It claims to have been unaware of the statute, which is 

perhaps a worse offense, given that it is a criminal statute embodying the most basic ethical 

standard of public service on a governmental board. 

Moreover, the GWAA falsely states that "[a]s soon as the GWAA and Mr. Banks [the 

Board Treasurer] became aware of the problems created by [the illegal payments], Mr. Banks 

immediately ceased performing those services and reimbursed the GWAA...". (Answer p 43). 

In fact both the Treasurer and the GWAA counsel had had their attention called to the statute by 

September 2007, but Mr. Banks continued accepting payments though November 7, 2007 - and 

did not reimburse the GWAA until June 26, 2008 when criminal prosecution was threatened. 

(Reply Exhs. L, M) 

Conclusion 

The Answer of Respondent GWAA includes a number of demonstrably false and 

misleading representations, and fails entirely to present grounds for dismissal of the Complaint. 

15 
The Respondent's Motion to Dismiss should be denied, and the FAA should grant Complainant 

the relief he seeks. 

Respectfiilly submitted this the 2"'' day of March, 2009. 

HAITHCOe-K, BATIFIELD, HULSE^taNSEY, PLLC 

Glenn A. Barfiek 

State Bar No. v^fio 

Attorney for Cognplainant 

Post Office Drawer 7 

Goldsboro, NC 27533-0007 

Telephone: 919-735-6420 

Facsimile: 919-734-6296 

E-mail: barfield(5)hbh&]daw.com 

16 
BEFORE THE FEDERAL AVIATION ADMINISTRATION 

DELBERT JOHNSON 

d/b/a TWO DOGS AVLVTION, 

Complainant, 

vs. 

GOLDSBORO-WAYNE 

AIRPORT AUTHORITY, 

Respondent. 

CERTIFICATE OF SERVICE 

I hereby certify that on March 2, 2009,1 served a copy of the foregoing Reply on the 

following parties to this action by depositing a copy hereof, postage prepaid, in the United States 

Mail, addressed as follows: 

Federal Aviation Authority 

Office of the Chief Counsel 

Attn: FAA Part 16 Airport Proceedings Docket 

AGC-610 Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Cleave Wilkins, Chairman 

Goldsboro-Wayne Airport Authority 

240 Aviation Road 

Pikeville, North Carolina 27863 

Pablo O. Nuesch 

Elaine C. Lippmann 

Spiegel & McDiarmid, LLP 

1333 New Hampshire Ave., N.W. 

Washington, DC 20005 

Respectfully submitted this the 2nd day of March 2009_> 

HAITHCOCK/BARHELD, HUi 

By: 

Glerm A. Barfield 

State Bar No. 13770 

Attorney for Complainant 

Post Office Drawer 7 

Goldsboro, NC 27533-0007 

Telephone: 919-735-6420 

Facsimile: 919-734-6296 

E-mail: barfield@hbhklaw.com 

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Del Johnson 

From: 

Sent: 

To: 

Subject: 

Follow Up Flag: 

Flag Status: 

oh789(gbellsouth.net 

Tuesday, April 24, 2007 9:03 AM 

Del Johnson 

Re: AVGAS 

Follow up 

Red 

Jim: 

Del Johnson called me last evening and ask if I could meet with him today and I advised 

him that I would not be in Goldsboro until Friday. He sounded upset and I told him to 

contact either you or Cleve as we had received some information at the conference about 

fuels. 

He is starting to arouse my competitive spirit. I am against additional refueling 

facilities for the reason discussed at the Conference. Our airport will not support an 

additional facility. I don't believe the amount of money he would have to spend on 

preparing a location. We don't have office space and we don't need another flight school 

as well. 

I am available on e-mail and cell phone. 

Regards, 

Otto 

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From: "Del Johnson" <del@deljohnson.com> 

Date: 2007/04/23 Mon PM 05:31:26 EST 

To: <jsteele@stricklandinsgroup.com> 

CC: "'Cyndi Johnson'" <cyndi@webhostnc.com>, 

<oh7 8 9@bellsouth.net> 

Subject: AVGAS 

Mr. Steele, 

I spoke with Mr. Otto Keesling today. He stated that I needed to talk 

with you about information you found out last week at the airport 

manager's conference regarding self-serve avgas. Please advise what 

this information is. 

He also stated that Gurley Engineering was working on this project, 

but I am not certain with what information since I haven't been 

contacted about it -- again, please advise'. 

Is there an airport authority meeting this Thursday and/or has another 

meeting been scheduled? 

I requested the airport master plan a while ago. 

find a copy? Can I get one? 

Did you happen to 
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> Thanks for the help, 

Del Johnson 
Del Johnson 

From: 

Sent: 

To: 

Subject: 

Jim Steele [Jim_Steele@StrlcklandlnsGroup.com] 

Tuesday, April 24, 2007 10:05 PM 

del@deljohnson.com 

GWW info 

Del , 

After I sent your e-mail, I realized that I missed one question. Trey Gurley, the Airport 

Engineer, was asked by the Authority to review your plans for the AVGAS with respect to 

location and the Airport Layout Plan. 

Trey should have contacted you. I'll try to contact him tomorrow after my simulator and 

have him call you. 

Also, I just received an e-mail stating that May 15 was the proposed date of the special 

meeting of the Authority. Once a date has been determined it will be published in the 

newspaper. I'll let you know personally. 

Jim Steele 

SIG Aviation, LLC 

919-734-7630 

(Cell)919-922-5989 

(Fax)919-731-2802 

This e-mail has been scanned for security and content. 
Del Johnson 

From: Trey Gurley [gurleyenginc@nc.rr.com] 

Sent: Thursday, May 10, 2007 8:30 AM 

To: 'Del Johnson' 

Subject: RE: Self-serve AVGAS at GWW 

That is the same location I was told. I need to find out if that is suitable per FAA rules and 

regulations for the type equipment you are proposing. 

GURLEY 

HNCINKmNGINC 

D.E. "Trey" Gurley, III, PE 

Gurley Engineering, Inc. 

P.O. Box 10806 

Goldsboro, NC 27532 

(919) 581-8055 phone 

(919) 581-8045 fax 

gurleyenginc(S)nc.rr.com 

Original Message 

From: Del Johnson [mailto:del@deljohnson.com] 

Sent: Thursday, May 10, 2007 8:20 AM 

To: gurieyenginc@nc.rr.com 

Subject: RE: Self-sen/e AVGAS at GWW 

Here is the location I requested from the board. I believe it is clear of the clear zone, although I haven't 

been able to get a map from anyone. 

The parl<ing area is unused in that area, offers aircraft tiedowns, and is well clear of the corporate hangar 

and new hangar. 

-Del 

From: Trey Gurley [mailto:gurleyenginc@nc.rr.com] 

Sent: Thursday, May 10, 2007 7:30 AM 

To: 'Del Johnson' 

Cc: Jim Steele; Dain Riley; Otto Keesling 

Subject: RE: Seif-setve AVGAS at GWW 

Del, 

Do you have any drawings or specifications in print that you could mail or fax or email? 

Is the tank enclosed by walls and roof or is just a tank on a cradle? 

Thanks 
GURLEY 

KNGlNERfNGINC 

D.E. "Trey" Gurley, III, PE 

Gurley Engineering, Inc. 

P.O. Box 10806 

Goldsboro, NC 27532 

(919) 581-8055 phone 

(919) 581-8045 fax 

gurleyenginc@nc.rr.com 

Original Message 

From: Del Johnson [maiito:del@deljohnson.com] 

Sent: Wednesday, May 09, 2007 7:01 PM 

To: gurleyenginc@nc.rr.com 

Cc: 'Cyndi Johnson' 

Subject: Self-serve AVGAS at GWW 

My apologies for not getting this done sooner. 

The dimensions of the installation will be 10 feet high by 12 feet wide by 38 feet in length. The 

front of the installation would need to connect to a taxiway and the entire structure should be 

greater than 50' from any building. Power and telephone lines would connect near the front. 

Additionally there would be 4" steel posts near the front corners protecting the pump and 

dispensing unit. 

Where did the airport authority have you looking for installation? 

Do you have a copy of the clear zone? If so, can 1 get a copy? 

Is there any other information you need from me? 

Thanks, 

~ Del Johnson 

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Page 1 of 3 

Glenn Barfield 

From: harrell Everett [heverett@ewf-law.com] 

Sent: Monday, November 26, 2007 3:24 PM 

To: Del Johnson 

Cc: 'Glenn Barfield'; 'Cyndi Johnson'; ken@kenbankscpa.com; Oh789@bellsouth.net 

Subject: Re: Continued negotiations for self-serve avgas 

Mr. Johnson: 

Due to other commitments and Thanksgiving, I have not had time to respond to the parts of your e-m^ils 

which call for a response. 

A. 11-20 e-mail 

1. I am the attorney for the GWAA. Mr. Banks arranged the loan with BB&T and BB&T 

Governmental Finance Section handled the loan. 

2. Yes 

3. No. I do not represent SIG Aviation. 

4. I had nothing to do with the negotiations. I prepared the contract based on the information given me 

5. The performance standards that SIG Aviation is held to as Airport Manager is based on the terms of 

its contract. If there are specific complaints over SIG Aviation's performance, then the Board will deal 

with the complaints. 

6. Office hours of the Airport Manager are posted. 8 to 8 except Thanksgiving and Christmas and is on 

call other times. 

7. No answer. 

8. As I advised you, I have recommended that the Rules and Regulations be reviewed by an outside 3rd 

party and updated. Section 8 states the requirements. 

9. Your flight school was approved subject to the GWAA receiving an insurance certificate naming the 

GWAA as an additional insured. Your attorney stated that you would provide this. I requested this of 

your wife and she said you did not have to provide it since you were overseas on military duty. I believe 

Two Dogs Aviation is a legal entity. 

10. No answer required. 

11. All 3 flight schools were contacted to provide the insurance certificate information. 

12. How would GWAA know if there was compliance unless it saw the certificate.? 

13. The GWAA did give verbal waivers. You have raised a good point and these waivers should be in 

writing or noted in the minutes. 
Page 2 of3 

14. I will have a copy of minutes mailed to you after the minutes axe approved by the Board. Other than 

the minutes, you need to request any additional documents that you want to either read or have copies. 

As to the general ledger, I believe that Mr. Barfield reviewed or copied it at Mr. Banks' office. If not let 

me know and i will have mr. Banks provide a disc or copies. 

15. $0.25 per page is a standard charge by many pubUc entities. 

16. There was no request for my billing records. If you want copies for what period and there will be a 

$0.25 per page charge. 

17.1 will contact Mr. Banks and try to retrieve a copy of the Eastern Aviation document and send it to 

Glenn? 

KEN: DO YOU HAVE THIS LETTER? IF SO PLEASE FAX IT TO ME. 

18. No Answer. 

B. 11-26 email 

1. I believe I responded to your 11 -20 e-mail on this matter. 

2. I have no knowledge that Mr. Kessling approve a site or that Trey Gurley approved a site. A site can 

only be approved by the Board itself 

The Fire Marshall, Brian Taylor, advised me that he could not approve the site or your contemplated 

operation until he visited the approved site and had details of your equipment and operation. 

3. As far as I know, any rent discussions are premature and would be negotiated with you after your 

request was approved. 

4. I have no answer. I suppose you could ask the Board. 

Finally, Mr. Johnson, I have tried to respond to your various e-mails and gather public records and 

answers for your attorney and you. Since it is only about 2 weeks before the next Board meeting, I 

would suggest that your wife make any other request to the Board itself. I will advise Mr. Wilkins of 

this possibility upon hearing from you. 

Harrell Everett 

At 04:13 PM 11/25/2007, Del Johnson wrote: 

Your October 24* letter states that my self-serve avgas proposal approval is based on three things: 

1. Meeting Section 8 of the airport rules 

2. Subject to approval of the site 

3. Assurances from the county fire marshal that the equipment meets applicable safety standards 
Page 3 of 3 

I have spent a considerable time addressing the first issue and am awaiting your and SIG Aviation LLC's (as 

airport manager, not FBO ) replies to my requests. When are you going to reply? Since the first issue is 

already adequately discussed from my point of view, although not adequately answered, I would like to 

address the second and third issues. Additionally, the GWAA has still not discussed rent. 

Otto Keesling, as the building and grounds committee, approved the site. In the original discussions presenting 

the proposal and any discussions since, the board has never presented any objection to the site. The site has 

even been approved by Trey Gurley working as the engineer to ensure it meets FAA clear zone requirements. 

Did the board forget it didn't have any objection to the site, that the building and grounds committee approved 

the site, and that the engineer approved the site - or is this a new requirement? 

The only way the fire marshal will approve the equipment is to know where it will be installed - he stated he 

need a 50 foot distance from any non-related building. Per my presentation at the Special Meeting held May 

15, 2007, the equipment meets all state and local requirements as far as the fire marshal is concerned; 

however, he needs to know the distance to any buildings to give final approval. Of course, this hurdle requkes 

that the board acknowledge that the proposed, studied, and engineered site is approved and then I will obtain 

fire marshal approval in short order. 

Additionally, you left out a discussion of rent for using airport property. Although SIG is charged $0.02 per 

gallon fiiel flowage fee, well below market value, they are also given the tanks, pumps, plumbing, electricity, 

maintenance, and repairs as part of their fee - clearly this arrangement wouldn't apply to me unless the 

GWAA were willing to provide the same benefits. More likely, the GWAA would fall back to its agreement 

with tenants who improve the land that such improvements would cover the costs of rent for 20 years - this 

would be the exact same deal that Otto Keesling and others are under for private hangars. In these hangar 

deals at lease expiration, the permanent part stays (concrete), but the removable portion (hangar) may be sold; 

I expect the same would apply for avgas. -• • 

Also I noted that the board had 2 members negotiate with SIG Aviation LLC for their two contracts worth 

millions, but I have not had the board assign a single person to work with me in eight months. In fact, every 

step of the negotiation process has required a full board meeting only furthering the delay; why one standard 

for SIG Aviation and a different standard for me? Would you please let me know who these folks will be; I 

have waited long enough to get this started and any additional delay is unacceptable. 

Thanks for the all the help. 

Sincerely, 

— Del Johnson 
Del Johnson 

From: Jim Steele [Jim_Steele/SIG.SIG@StricklandlnsGroup.com] 

Sent: Sunday, February 22, 2009 12:49 PM 

To: Del Johnson 

Subject: Re: Aircraft charter 

Del 

Technically, we're still on a 135 certificate. However, with the aircraft for sale we decided to stop flying 

charter. Thus we allowed our pilot currency (for charter only) to lapse. Because of the difficulty in 

selling the aircraft we are considering flying some charter. Not sure how soon we'll be legal. 

Do you have a charter requirement? If so, I'd be happy to explain how pricing works. It may vary 

slightly from company to company but most models are similar. Just let me know how I can help. 

Jim 

PS - I'm in town until Wednesday. Flying after that until Sat. 

From: "Del Johnson" [del@deljohnson.com] 

Sent: 02/22/2009 11:24 AM EST 

To: '"Jim Steele'" <Jim_Steele/SIG.SIG(@StricklandInsGroup.com> 

Subject: RE: Aircraft charter 

Jim, 

Thanks for the quick reply. 

1 thought y'all were part 135, did you lose your certificate? How did you conduct charter operations before? 

Thanks, 

-Del 

From: Jim Steele [mailto:Jim_Steele/SIG.SIG@StricklandInsGroup.com] 

Sent: Saturday, February 21, 2009 12:44 PM 

To: Del Johnson 

Subject: Re: Aircraft charter 

Del 

At the moment, we are not able to fly charter. Be happy to explain charter options and perhaps some recommendations 

(depending on your needs). Just for info, we do allow dogs but not everyone does. If you need to call, I'll be on my cell most 

of the weekend (922-5989). Let me know if I can help. Have a great weekend. 

Jim 
From: "Del Johnson" [del(^deljohnson.com] 

Sent: 02/21/2009 10:54 AM EST 

To: Jim Steele 

Subject: Aircraft charter 

Jim, 

How much to charter the Citation? Can you explain the pricing structure and what advance notice you would 

need? Any other restrictions or things we would need to know? Do you have a contract? What do you require for 

a passenger manifest? Are dogs allowed? 

Thanks, 

-Del 

This (;-mai . l has been scanned for security and content. 

This i ;-mail has been scanned for security and content. 

This i ;-mail has been scanned for security and content. 

This £ ;-mail has been scanned for security and content. 
Glenn Barfield 

From: Glenn Barfield [barfield@hbhklaw.com] 

Sent: Thursday, November 08, 2007 5:17 PM 

To; 'Harrell Everett' 

Cc: 'Del Johnson'; 'Cyndi Johnson' 

Subject: RE: Johnson Vs. GWAA etal 

Harrell, 

I have been thinking about your indication that these matters can only be settled 

globally. You will recall that I urged the AA to assess and negotiate each dispute 

separately. I want to speak further to that issue. 

There are essentially five areas of dispute, and the Johnson's legal remedies are 

different for each of those matters. 

As to the self-service avgas proposal, on failure to agree the Johnsons' remedy would be a 

complaint to the FAA contending the AA has illegally granted and protected an exclusive 

right for SIG to sell aviation fuels, and separately at some point an action against SIG 

and the AA contending anti-trust and unfair trade practices, seeking money damages. 

As to SIG's conflicts of interest and diversion of revenue, on failure to agree the 

Johnsons could file a separate FAA complaint, but not likely a legal action, and there 

would be no damages to recover separate from the avgas monopoly. 

As to the Public Records, on failure to agree the Johnsons' could bring a statutory action 

seeking compliance and legal expenses, but not damages. 

As to the non-approved loan, on failure to agree the Johnson's could seek injunctive 

relief and on behalf of the AA seek recovery of improper payments from BB&T and 

reimbursement from the individual Board members. They could make a claim for legal 

expenses, but not damages. 

As to Ken's receipt of payments, on failure to agree the Johnson's again could seek 

injunctive relief and on behalf of the AA seek reimbursement of improper payments from • 

Ken, and could make a claim for legal expenses, but not damages. 

Therefore the only matter in which the Johnsons could seek money damages would be ultimate 

denial of their FBO application; otherwise they could only seek, in money, reimbursement 

of legal expenses. If we conditioned settlement of any of the other matters on settlement 

of the avgas proposal, it might be construed as seeking (avgas)money in exchange for an 

agreement to refrain from reporting the Board's non-compliance with statutory duties. 

This is especially troubling as it relates to the loan and the payments to Ken, because 

violation of the relevant statutes constitute criminal offenses. The Johnsons have 

suggested that the Board be re-vamped and procedures implemented to prevent conflicts of 

interest and to ensure the Board's independence from any private influence, and to bring 

complete transparency to the AA's financial operations. It seems to me that that is the 

only legitimate demand they could make as consideration for their forbearance from 

litigation as to the loan or reimbursement from Ken (which I would hope he would make in 

any event). 

For these and other reasons, I believe the AA and the Johnsons must work toward resolution 

of these issues separately, with the Johnson's forbearance in each case being exchanged 

for AA action in that respective case. 

Warmest regards, 

Glenn 

HAITHCOCK, BARFIELD, HULSE & KINSEY, PLLC GLENN A. BARFIELD 919-735-6420 (phone) 

919-734-6296 (fax) 

barfield@hbhklaw.com 
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Original Message i 

From: Harrell Everett [mailto:heverett@ewf-law.com] i 

Sent: Thursday, November 08, 2007 11:25 AM \ 

To: Glenn Barfield ! 

Cc: clevewilkins@netzero.net t 

Subject: Johnson Vs. GWAA etal • 

Glenn: ; 

Following our meeting yesterday, I conferred with Mr. Wilkins, Chairman of the GWAA, and 

reported to him your clients demands. I advised him that in light of the various demands 

that had not been previously stated that it would be necessary for the GWAA to have a 

Special Meeting and to then go in closed session to discuss a matter of "pending 

litigation" or conduct the closed session as a part of the December 6 next meeting. 

Mr. Wilkins has not advised me in that regard as of now. Of course, it is necessary to 

poll the members and determine when they are available to meet for the special meeting and 

the 4 8 hour notice of the special meeting must be given. 

As a result, I will be in touch with you after the closed session of the GWAA and iwill 

advise you-of the date as soon as I know. 

I will be faxing to you today the letter from the Dept. of Treasurer, dated 6-7-07 ias well 

as a memo of the results of the negotiations over the Airport Manager's Contract, Lease 

Agreement, FBO Agreement and Corporate Hangar Lease between the GWAA committee composed of 

Ken Banks and Otto Kessling and SIG Aviation, LLC represented by Jim Steele. 

Harrell 
W. TIMOTHY HAITHCOCK 

GLENN A. BARFIELD 

B. GEOFFREY HULSE 

REBECCA B. KINSEY 

WORTH T. HAITHCOCK II 

HAITHCOCK, BARFIELD, HULSE & KINSEY, PLLC 

ATTORNEYS AT LAW 

231 EAST WALNU T STREET 

POST OFFIC E DRAWER 7 

COLDSBORO, NORTH CAROLINA 27533-0007 

TELEPHON E (9f9) 735-6420 

FAX (9 19) 734-6296 

haithcock@hbhMlaw.com 

barfield@hbhklaw.com 

hulse@hbhkiaw.com 

klnsey@hbhklaw.com 

worthh@hbhklaw.com 

November 9, 2007 

Mr. W. Harrell Everett, Jr. 

Everett, Womble, Lawrence & Brown, L.L.P. 

Drawer 10809 

507 B Spence Avenue 

Goldsboro, North Carolina 27532-0809 

Re: Goldsboro-Wayiie Airport Authority 

Dear Harrell: 

I have been thinking about your indication that these matters can 

only be settled globally. You will recall that I urged the AA to assess 

and negotiate each dispute separately. I want to speak further to that 

issue. 

There are essentially five areas of dispute, and the Johnson's legal 

remedies are different for each of those matters. 

As to the self-service avgas proposal, on failure to agree the Johnsons' 

remedy would be a complaint to the FAA contending the AA has 

illegally granted and protected an exclusive right for SIG to sell 

aviation fuels, and separately at some point an action against SIG and 

the AA contending anti-trust and unfair trade practices, seeking 

money damages. 

As to SIG's conflicts of interest and diversion of revenue, on failure to 

agree the Johnsons could file a separate FAA complaint, but not likely 

a legal action, and there would be no damages to recover separate 

from the avgas monopoly. 
Mr. W. Harrell Everett, Jr. 

November 9, 2007 

Page 2 

As to the PubHc Records, on failure to agree the Johnsons' could bring 

a statutory action seeking compliance and legal expenses, but not 

damages. 

As to the non-approved loan, on failure to agree the Johnson's could 

seek injunctive relief and on behalf of the AA seek recovery of 

improper payments from BB&T.and reimbursement from the 

individual Board members. They could make a claim for legal 

expenses, but not damages. 

As to Ken's receipt of payments, on failure to agree the Johnson's 

again could seek injunctive relief and on behalf of the AA seek 

reimbursement of improper payments from Ken, arid could make a 

claim for legal expenses, but not damages. 

Therefore the only matter in which the Johnsons could seek money 

damages would be ultimate denial of their FBO application; otherwise 

they could only seek, in money, reimbursement of legal expenses. If 

we conditioned settlement of any of the other matters on settlement 

of the avgas proposal, it might be construed as seeking (avgas)money 

in exchange for an agreement to refrain from reporting the Board's 

non-compliance with statutory duties. 

This is especially troubling as it relates to the loan and the payments 

to Ken, because violation of the relevant statutes constitute criminal 

offenses. The Johnsons have suggested that the Board be re-vamped 

and procedures implemented to prevent conflicts of interest and to 

ensure the Board's independence from any private influence, and to 

bring complete transparency to the AA's financial operations. It 

seems to me that that is the only legitimate demand they could make 
Mr. W. Harrell Everett, Jr. 

November 9, 2007 

Page 2 

as consideration for their forbearance from litigation as to the loan or 

reimbursement from Ken (which I would hope he would make in any 

event). 

For these and other reasons, I believe the AA and the Johnsons must 

work toward resolution of these issues separately, with the Johnson's 

forbearance in each case being exchanged for AA action in that 

respective case. 

With warmest regards, 

HAITHCOCK, BARFIELD5 HULSE & KINSEY, PLLC 

By: Glenn A. B 

GAB/11 
SIG Aviation Home Page 1 of 1 

Airport Information 

Goldsboro/Wayne 

Municipal Airport 

FAA ID: KGWW 

Elevation: 134' MSL 

Variation: 08'W 

AWOS: 118.97 

AWOS Phone: 919.731.4473 

':ix/ 

SIG Aviation, LLC 

240 Aviation Road 

Pikeville, NC 27863 

919-734-7630 

— I—I^^T^*!!! ^ •"••I.IM-V I I I<PN^ | lll—_|M|.l»ll..—IM-^HMM^^Vl -Jl lUl-ll t t • 

WELCOME TO SIG AVIATION... 

SIG Aviation Aviation, LLC, was founded in 2001 as tlie aviiatio a n 

division of Striclcland Insurance Group, Goldsboro, NC. We 

are conveniently located at the Goldsboro/Wayne County 

Municipal Airport (KGWW) 55 miles southeast of Raleigh. We 

are a full service FBO with a wide range of available services 

including fuel service (lOOLL, Jet A), dedicated corporate 

service and interactive passenger service 

O u r Mission.. . 

SIG Aviation exists to be a leader in the aviation industry 

through a focused approach to customer service in the areas 

of Corporate Travel, Aircraft Management and Fixed Base 

Operations. We achieve this goal through a continual 

commitment to safety, efficiency and flexibility without 

compromising "...that personal touch." 

Current Weathe r 

Goldsboro , NC 

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Feels Like: 30°F 

Humidity: 97% 

Wind:Nat8mph 

Enter city/zip 

Vacation Pianner 

Airport Delays 

Sporting Events 

Today in Wealhe 

Strickian d Insuranc e 

Group , Inc . 

Strickland Insurance 

Group,Inc is a recognized 

leader and provider of 

specialty line property and 

casualty insurance products 

and services. 

O u r Staff... 

Our well-trained staff is very courteous and knowledgeable. 

We go far beyond the expected to ensure your experience is 

rated #1 . We commit to providing courteous, professional 

service for everyone from the larger corporate jet to the 

smallest general aviation aircraft. 

Contac t Us... 

We welcome your input. If you have questions, concerns or 

would like more information, feel free to contact us. Our 

staff is ready to serve you from 8 a.m. until 8 p.m. Monday 

thru Sunday (closed Thanksgiving Day and Christmas Day). 

Phone: 919-734-7630 

Fax: 919-731-2802 

For more information click here 

As of 12/16/2008 

100LL = $3.54/gallo n 

Jet A = $3.7 9 / gallon 

Prices include all taxes 

Volume Discount Available 

Shel l Aviatio n 

Subject to change without notice 

Merry Christmas & 

Have a blessed 2009! 

EMERGENCY CONTACT: 919-922-5983 

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http://www.sigaviation.com/ 3/2/2009 
SIG Personnel EXHmjT Page 1 of2 

HOME ^ SERVICES j ^ PERSONNEL ^ AIRPORT INFO j ^ 

iii.^^aa>'.iit^ifkia6&»i!Si>>if:AaatMwi;feaj^^ 

IG Aviation Personnel 

Jim Steele, Airport Manager and Chief Pilot 

Jim is Vice President of Aviation for Strickfand Insurance Group, 

Inc. and manager of the Goldsboro-Wayne Municipai Airport. A 

retired Colonel, he spent 22 years in the United States Air Force 

serving in a variety of command and staff positions. Jim Is an ATPrated pilot with over 7,000 hours of jet time in various USAF and 

corporate aircraft. 

He is actively involved in the National Business Aviation Association 

(NBAA) where he serves on the Corporate Aviation Management 

Committee. With a Master's Degree in both Management and 

Education, and over 33 years in aviation, Jim brings a wealth of 

experience to our organization. 

T o m Kimbrough , FBO Manager/ Line Captain 

Tom took over management of the FBO in January 2005. He is a graduate of 

LeTourneau University, an A&P mechanic and an Airline Transport rated Pilot with 

over 5,000 hours of flight time. 

He and his family have called Goldsboro home since 2002. 

Doug Lancaster, Line supervisor 

Doug came to KGWW after retiring from 21 years of service in the United States 

Air Force. His last assignment as Production Superintendent gave him the 

service-related experience that he shares with SIG Aviation and our customers. 

Doug maintains the highest possible standards through annual Eastern Aviation 

Line Training and NATA Line Supervisor certification. 

T o m Gushing , Line Technician 

Tom retired from the U.S.A.F. after serving for over 20 years in the Strategic Air 

Command (SAC) He provided flight line maintenance as a Production Supervisor 

on KC-135 Tankers, B-52 Bombers, and B-IB Bombers. 

Tom joined SIG Aviation in September of 2003. The extensive military training he 

received enables him to insure all FBO and Flightline duties are conducted in a 

safe and timely manner. 

http://www.sigaviation.coni/Personnel/personnel.htnil 3/2/2009 
SIG Personnel Page 2 of2 

Chip Felver, Une Technician 

Chip is the newest member of the SIG Aviation team. He recently retired from 

the United States Air Force with 20 years in aircraft maintenance. His six years 

as a Maintenance Operations Coordinator adds to the wealth of aviation 

knowledge and experience already in place at the Goldsboro-Wayne County 

Airport. 

Chip has been a resident of Goldsboro since 1999 with his wife Tammy and son 

Trey. 

Darren Wilson, une capta in 

Darren started his flying career in 1984 at KPWA (Wiley Post Airport, OKC, OK). 

He served as an Instructor Pilot and Check Airman at Embry Riddle Aeronautical 

University, Daytona Campus, in the 90's before extending his aviation career to 

the Part 121 world where he gained valuable experience that he now shares with 

our corporate flight department. 

He and his family have lived in the Goldsboro area since 2005. 

.©2008 SIG Aviation, LLC. All Rights Reserved 

http://www.sigaviation.com/Personnel/personneI.html 3/2/2009 
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Glenn Barfield 

Page 1 of 1 

From: Del Johnson [del@deljohnson.com] 

Sent: Wednesday, April 02, 2008 9:18 AM 

To: lyoung@ncdoj.gov 

Cc: c.branson.vickory@nccourts.org; 'Glenn Barfield'; 'Cyndi Johnson' 

Subject: Fraud committed by Goldsboro Wayne Airport Authority 

Attachments: Complaint.pdf 

Mr. Young, 

The Goldsboro Wayne Airport Authority (GWAA) has committed fraud with both state and federal money. They 

have even gone so far as to document their fraud very dearly. The local district attomey, Mr. Branson Vickory 

(cc'd), stated to my attorney, Mr. Glenn Barfield, that he was forwarding the matter to the SBI for further 

investigation, but has not provided any additional information that such action has been taken. 

In a nutshell, the GWAA: 

1. Obtained a loan that exceeded their limits without Local Government Commission approval 

2. Provided fraudulent documents to the Local Government Commission for approval 

3. Other crimes that have been committed are documented in the complaint my attorney has filed with the 

FAA (attached). 

4. Will not release the independent financial audit - we believe other crimes have been committed, but cannot 

get the documents from them. 

5. Illegally pay a board member, Mr. Ken Banks, to be their CPA. 

Please let us know if the local district attorney has indeed forwarded this to you and if there is any additional 

documentation we can provide to assist you. The state and local community will lose over $500,000 if this fraud 

and illegal activity goes unchecked. 

My attorney is Mr. Glenn Barfield and you may speak with him or me at any time regarding this. 

We are meeting with an FBI agent investigating this next week and may be able to save some time and effort if 

you would like us to explain it to your agents, along with evidence, at the same time. 

Thanks for any assistance, 

- Del Johnson 
IIBIT 

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About Us: 

Eastern Aviation Insurance Services, LLC, was 

founded in 2004 by Terry Britt and Robert L. 

"Buddy" Stallings, III . 

Buddy, our Chairman and CEO, founded Eastern 

Aviation Fuels in 1975 in New Bern , North 

Carolina . For over a quarter century, Eastern has 

been exclusively dedicated to the aviation 

industry. Serving aviation is Eastern's only 

business. Eastern Aviation Fuels is the exclusive 

marketer of Shell Aviation Fuel in the US . 

Terry, our President, has been involved in the 

aviation industry for over twenty years. A private 

pilot since 1982, Terry has his instrument ticket as 

well as his multi-engine rating. He is a past 

Chairman of the Gwinnett County Airport 

Authority, the third busiest airport in Georgia . He 

also served as Vice-President and General 

Manager of Hawthorne Gwinnett, a FBO now 

owned by Landmark Aviation. He currently serves 

on the Board of Directors of the Georgia Business 

Aviation Assoc. ("GBAA"), has written articles for 

several aviation magazines and speaks regularly to 

organizations such as the National Aviation 

Transportation Assoc. ("NATA"). He is happy to 

make himself available to any organization as a 

speaker. 

Terry's aviation insurance experience includes 

Sales Manager for Insuramerica Aviation and 

Branch Manager for NationAir Insurance Agencies 

in Atlanta . As a firm believer in education Terry 

has earned three professional designations. The 

Certified Insurance Counselors ("CIC) designation 

is one of the most prestigious in the industry. It is 

comprised of five seperate sections with a 

demanding essay test for each section. The 

Certified Professional Insurance Agent ("CPIA") 

designation is comprised of three parts and sets 

the Professional Agent apart from the rest. The 

third designation earned by Terry is the Certified 

Aviation Insurance Professional ("CAIP"), the only 

designation attainable in the aviation insurance 

industry. Only about one percent of the agents 

who work in the aviation insurance industry have 

earned the rare CAIP designation. 

Cindy Rozar, long time associate of Terry's, is our 

Vice-President. Cindy has been in the insurance 

industry for over twenty years and in aviation 

insurance for the past eight. Her areas of expertise 

include customer service, property insurance, 

workers compensation and business auto 

• r 

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coverages. She is experienced in group health 

insurance as well as all areas of aviation 

insurance. She also holds the CPIA designation. 

Terry's dedication to the aviation insurance 

industry and vast experience in the aviation 

industry give us a unique perspective as to the 

needs of our clients. With Cindy's help and the 

support of Buddy and Eastern Aviation Fuels we 

feel our agency brings more to the table than a 

typical agency, aviation specific or not. Whether 

you represent a large corporate flight department, 

a FBO of any size, a manufacturer, a flight school 

with 1 to 100 aircraft, a private aircraft owner or 

anyone involved in the aviation industry, we 

understand the challenges you face. Our promise 

to you is: 

To be your advocate 

To always be accessible to you 

To offer you the best insurance value available 

To provide you a level of service unparalleled in 

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"We want your business, will earn it and always 

appreciate it." 

Eastern Aviation Insurance Services, LLC 

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Corporate History 

Robert L. "Buddy" Stallings, 111, founded Eastern Aviation Fuels in 1975 in New Bern, North Carolina. For 

over a quarter century, Eastern has been exclusively dedicated to the aviation industry. Serving aviation is 

Eastern's only business. 

Over the years, Eastern has aligned itself strategically with major oil companies to bring its FBO custonners 

secure supply, clean, high-quality fuel, and a professional image. 

Eastern Aviation Fuels growth is, in part, accountable to its aggressive acquisition initiatives. Consolidation 

through acquisition of many distributors in the Southeastern and Mid-Atlantic states, coupled with superior 

customer service and attention to detail has made Eastern Aviation Fuels the largest distributor of aviation 

fuel products in the Eastern United States. Currently, the company's dealer network has grown to well over 

350 FBOs and also serves many airiines, corporate flight departments, helicopter operators, and aerial 

applicators. 

A professional "flying" aviation sales staff assures top-notch, highly personalized customer service and a 

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Eastern Aviation Fuels' attention to its customers is unmatched anywhere in the aviation industry. Our 

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.Services^Ho.me.l Corp_orate | Passenger j Pilot 

iFuel Services 

With precise attention to detail, SIG Aviation provides a complete 

offering of fuel and line services including: 

• Fuel Type: lOOLL and Jet A 

• Fuel Brand: Shell Aero 

• Line Staff trained to NATA Standards 

• Fueling Hours: 8 AM to 8 PM / 7 Days a week 

• Aircraft Parking: Lighted Ramp and Hangars 

• Ground Power Unit 

• Aircraft towing up to 28,000 lbs. max. 

B Shel! Aviation 

saws SIO .-\vi.ilior,, LLC. .Ail Riglili Rescr.v'd 

http://www.sigaviation.com/Services/fuel_services.html 3/2/2009 
Del Johnson 

From: 

Sent: 

To: 

Subject: 

Follow Up Flag: 

Flag Status: 

oh789@bellsouth.net 

Tuesday, April 24, 2007 9:03 AM 

Del Johnson 

Re; AVGAS 

Follow up 

Red 

Jim: 

Del Johnson called me last evening and ask if I could meet with him today and I advised 

him that I would not be in Goldsboro until Friday. He sounded upset and I told him to 

contact either you or Cleve as we had received some information at the conference about 

fuels . 

He is starting to arouse my competitive spirit. I am against additional refueling 

facilities for the reason discussed at the Conference. Our airport will not support an 

additional facility. I don't believe the amount of money he would have to spend on 

preparing a location. We don't have office space and we don't need another flight school 

as well. 

I am available on e-mail and cell phone. 

Regards, 

Otto 

From: "Del Johnson" <del(3del Johnson. com> 

Date: 2007/04/23 Mon PM 05:31:26 EST 

To: < j Steele (3 stricklandinsgroup. com> 

CC: "'Cyndi Johnson'" <cyndi@webhostnc.com>, 

<oh7 8 9(abellsouth.net> 

Subject: AVGAS 

Mr. Steele, 

I spoke with Mr. Otto Keesling today. He stated that I needed to talk 

with you about information you found out last week at the airport 

manager's conference regarding self-serve avgas. Please advise what 

this information is. 

He also stated that Gurley Engineering was working on this project, 

but I am not certain with what information since I haven't been 

contacted about it -- again, please advise. 

Is there an airport authority meeting this Thursday and/or has another 

meeting been scheduled? 

I requested the airport master plan a while ago. Did you happen to 

find a copy? Can I get one? 
> 

> Thanks for the help, 

> 

> -- Del Johnson 

> 

> 

> 

> 

> 

> 

> 
Del Johnson 

From: 

Sent; 

To: 

Subject: 

Jim Steele [Jim_Steele{@StricklandlnsGroup.com] 

Tuesday, April 24, 2007 10;05 PM 

del@deljohnson.com 

GWW Info 

Del , 

After I sent your e-mail, I realized that I missed one question. Trey Gurley, the Airport 

Engineer, was asked by the Authority to review your plans for the AVGAS with respect to 

location and the Airport Layout Plan. 

Trey should have contacted you. I'll try to contact him tomorrow after my simulator and 

have him call you. 

Also, I just received an e-mail stating that May 15 was the proposed date of the special 

meeting of the Authority. Once a date has been determined it will be published in the 

newspaper. I'll let you know personally. 

Jim Steele 

SIG Aviation, LLC 

919-734-7630 

(Cell)919-922-598 9 

(Fax)919-731-2802 

This e-mail has been scanned for security and content. 
Del Johnson 

From: Trey Gurley [gurleyenginc@nc.rr.com] 

Sent: Thursday, May 10, 2007 8:30 AM 

To: 'Del Johnson' 

Subject: RE: Self-serve AVGAS at GWW 

That is the same location I was told. I need to find out if that is suitable per FAA rules and 

regulations for the type equipment you are proposing. 

GURLEY 

FKGINKfflNGINC 

D.E. "Trey" Gurley, III, PE 

Gurley Engineering, Inc. 

P.O. Box 10806 

Goldsboro, NC 27532 

(919) 581-8055 phone 

(919) 581-8045 fax 

gurleyenginc@.nc.rr.com 

Original Message 

From: Del Johnson [mailto:del@deljohnson.com] 

Sent: Thursday, May 10, 2007 8:20 AM 

To: gurleyenginc@nc.rr.com 

Subject: RE: Self-sen/e AVGAS at GWW 

Here is the location I requested from the board. I believe it is clear of the clear zone, although I haven't 

been able to get a map from anyone. 

The parl<ing area is unused in that area, offers aircraft tiedowns, and is well clear of the corporate hangar 

and new hangar. 

-Del 

From: Trey Gurley [mailto:gurleyenginc@nc.rr.com] 

Sent: Thursday, May 10, 2007 7:30 AM 

To: 'Del Johnson' 

Cc: Jim Steele; Dain Riley; Otto Keesling 

Subject: RE: Self-serve AVGAS at GWW 

Del, 

Do you have any drawings or specifications in print that you could mail or fax or email? 

Is the tank enclosed by walls and roof or is just a tank on a cradle? 

Thanks 
GURLEY 

K\(MER[^CilXC 

D.E. "Trey" Gurley, III, PE 

Gurley Engineering, Inc. 

P.O. Box 10806 

Goldsboro, NC 27532 

(919) 581-8055 phone 

(919) 581-8045 fax 

gurleyenginc@nc.rr.com 

Original Message 

From: Del Johnson [mailto:del@deljohnson.com] 

Sent: Wednesday, May 09, 2007 7:01 PM 

To: gurleyenginc@nc.rr.com 

Cc: 'Cyndi Johnson' 

Subject: Self-serve AVGAS at GWW 

My apologies for not getting this done sooner. 

The dimensions of the installation will be 10 feet high by 12 feet wide by 38 feet in length. The 

front of the installation would need to connect to a taxiway and the entire structure should be 

greater than 50' from any building. Power and telephone lines would connect near the front. 

Additionally there would be 4" steel posts near the front corners protecting the pump and 

dispensing unit. 

Where did the airport authority have you looking for installation? 

Do you have a copy of the clear zone? If so, can I get a copy? 

Is there any other information you need from me? 

Thanks, 

- Del Johnson 

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Page 1 of 3 

Glenn Barfield 

From: harrell Everett [heverett@ewf-law.com] 

Sent: Monday, November 26, 2007 3:24 PM 

To: Del Johnson 

Cc: 'Glenn Barfield'; 'Cyndi Johnson'; ken@kenbankscpa.com; Oh789@bellsouth.net 

Subject: Re: Continued negotiations for self-serve avgas 

Mr. Johnson: 

Due to other commitments and Thanksgiving, I have not had time to respond to the parts of your e-mails 

which call for a response. 

A. 11-20 e-mail 

1. I am the attorney for the GWAA. Mr. Banks arranged the loan with BB&T and BB&T 

Governmental Finance Section handled the loan. 

2. Yes 

3. No. I do not represent SIG Aviation. 

4. I had nothing to do with the negotiations. I prepared the contract based on the information given me 

5. The performance standards that SIG Aviation is held to as Airport Manager is based on the terms of 

its contract. If there are specific complaints over SIG Aviation's performance, then the Board will deal 

with the complaints. 

6. Office hours of the Airport Manager are posted. 8 to 8 except Thanksgiving and Christmas and is on 

call other times. 

7. No answer. 

8. As I advised you, I have recommended that the Rules and Regulations be reviewed by an outside 3rd 

party and updated. Section 8 states the requirements. 

9. Your flight school was approved subject to the GWAA receiving an insurance certificate naming the 

GWAA as an additional insured. Your attorney stated that you would provide this. I requested this of 

your wife and she said you did not have to provide it since you were overseas on military duty. I believe 

Two Dogs Aviation is a legal entity. 

10. No answer required. 

11. All 3 flight schools were contacted to provide the insurance certificate information. 

12. How would GWAA know if there was compliance unless it saw the certificate.? 

13. The GWAA did give verbal waivers. You have raised a good point and these waivers should be in 

writing or noted in the minutes. 
Page 2 of 3 

14.1 will have a copy of minutes mailed to you after the minutes are approved by the Board. Other than 

the minutes, you need to request any additional documents that you want to either read or have copies. 

As to the general ledger, I believe that Mr. Barfield reviewed or copied it at Mr. Banks' office. If not let 

me know and i will have mr. Banks provide a disc or copies. 

15. $0.25 per page is a standard charge by many public entities. 

16. There was no request for my billing records. If you want copies for what period and there will be a 

$0.25 per page charge. 

17. I will contact Mr. Banks and try to retrieve a copy of the Eastern Aviation document and send it to 

Glenn? 

KEN: DO YOU HAVE THIS LETTER? IF SO PLEASE FAX IT TO ME. 

18. No Answer. 

B. 11-26 email 

1. I believe I responded to your 11 -20 e-mail on this matter. 

2. I have no knowledge that Mr. Kessling approve a site or that Trey Gurley approved a site. A site can 

only be approved by the Board itself 

The Fire Marshall, Brian Taylor, advised me that he could not approve the site or your contemplated 

operation until he visited the approved site and had details of your equipment and operation. 

3. As far as I know, any rent discussions are premature and would be negotiated with you after your 

request was approved. 

4. I have no answer. I suppose you could ask the Board. 

Finally, Mr. Johnson, I have tried to respond to your various e-mails and gather public records and 

answers for your attomey and you. Since it is only about 2 weeks before the next Board meeting, I 

would suggest that your wife make any other request to the Board itself I will advise Mr. Wilkins of 

this possibility upon hearing from you. 

Harrell Everett 

At 04:13 PM 11/25/2007, Del Johnson wrote: 

Your October 24* letter states that my self-serve avgas proposal approval is based on three things; 

1. Meeting Section 8 of the airport rules 

2. Subject to approval of the site 

3. Assurances from the county fire marshal that the equipment meets applicable safety standards 
Page 3 of 3 

I have spent a considerable time addressing the first issue and am awaiting your and SIG Aviation LLC's (as 

airport manager, not FBO ) replies to my requests. When are you going to reply? Since the furst issue is 

already adequately discussed from my point of view, although not adequately answered, I would like to 

address the second and third issues. Additionally, the GWAA has still not discussed rent. 

Otto Keesling, as the building and grounds committee, approved the site. In the original discussions presenting 

the proposal and any discussions since, the board has never presented any objection to the site. The site has 

even been approved by Trey Gurley working as the engineer to ensure it meets FAA clear zone requirements. 

Did the board forget it didn't have any objection to the site, that the building and grounds committee approved 

the site, and that the engineer approved the site - or is this a new requirement? 

The only way the fire marshal will approve the equipment is to know where it will be installed - he stated he 

need a 50 foot distance from any non-related building. Per my presentation at the Special Meeting held May 

15, 2007, the equipment meets all state and local requirements as far as the fire marshal is concerned; 

however, he needs to know the distance to any buildings to give final approval. Of course, this hurdle requu-es 

that the board acknowledge that the proposed, studied, and engineered site is approved and then I will obtain 

fire marshal approval in short order. 

Additionally, you left out a discussion of rent for using airport property. Although SIG is charged $0.02 per 

gallon fiiel flowage fee, well below market value, they are also given the tanks, pumps, plumbing, electricity, 

maintenance, and repairs as part of their fee - clearly this arrangement wouldn't apply to me unless the 

GWAA were willing to provide the same benefits. More likely, the GWAA would fall back to its agreement 

with tenants who improve the land that such improvements would cover the costs of rent for 20 years - this 

would be the exact same deal that Otto Keesling and others are under for private hangars. In these hangar 

deals at lease expiration, the permanent part stays (concrete), but the removable portion (hangar) may be sold; 

I expect the same would apply for avgas. 

Also I noted that the board had 2 members negotiate with SIG Aviation LLC for their two contracts worth 

millions, but I have not had the board assign a single person to work with me in eight months. In fact, every 

step of the negotiation process has required a full board meeting only flirthering the delay; why one standard 

for SIG Aviation and a different standard for me? Would you please let me know who these folks will be; I 

have waited long enough to get this started and any additional delay is imacceptable. 

Thanks for the all the help. 

Sincerely, 

- Del Johnson 
Del Johnson 

From: Jim Steele [Jim_Steele/SIG.SIG@StricklandlnsGroup.com] 

Sent: Sunday, February 22, 2009 12:49 PM 

To: Del Johnson 

Subject: Re: Aircraft charter 

Del 

Technically, we're still on a 135 certificate. However, with the aircraft for sale we decided to stop flying 

charter. Thus we allowed our pilot currency (for charter only) to lapse. Because of the difficulty in 

selling the aircraft we are considering flying some charter. Not sure how soon we'll be legal. 

Do you have a charter requirement? If so, I'd be happy to explain how pricing works. It may vary 

slightly from company to company but most models are similar. Just let me know how I can help. 

Jim 

PS - I'm in town until Wednesday. Flying after that until Sat. 

From: "Del Johnson" [del(^deljohnson.com] 

Sent: 02/22/2009 11:24 AM EST 

To: '"Jim Steele'" <Jim_Steele/SIG.SIG(^StricklandInsGroup.com> 

Subject: RE: Aircraft charter 

Jim, 

Thanks for the quick reply. 

I thought y'all were part 135, did you lose your certificate? How did you conduct charter operations before? 

Thanks, 

-Del 

From: Jim Steele [mailto:Jim_Steele/SIG.SIG@StricklandInsGroup.com] 

Sent: Saturday, February 21, 2009 12:44 PM 

To: Del Johnson 

Subject: Re: Aircraft charter 

Del 

At the moment, we are not able to fly charter. Be happy to explain charter options and perhaps some recommendations 

(depending on your needs). Just for info, we do allow dogs but not everyone does. If you need to call, I'll be on my cell most 

of the weekend (922-5989). Let me know if I can help. Have a great weekend. 

Jim 
From: "Del Johnson" [del(^deljohnson.com] 

Sent: 02/21/2009 10:54 AM EST 

To: Jim Steele 

Subject: Aircraft charter 

Jim, 

How much to charter the Citation? Can you explain the pricing structure and what advance notice you would 

need? Any other restrictions or things we would need to know? Do you have a contract? What do you require for 

a passenger manifest? Are dogs allowed? 

Thanks, 

-Del 

Thise ;-mail has been scarmed for security and content. 

Thise ,-mail has been scarmed for security and content. 

Thise -mail has been scanned for security and content. 

This e -mail has been scanned for security and content. 
Glenn Barfield 

From: 

Sent; 

To: 

Cc: 

Subject: 

Glenn Barfield [barfield@hbhklaw.com] 

Thursday, November 08, 2007 5:17 PM 

'Harrell Everett' 

'Del Johnson'; 'Cyndi Johnson' 

RE: Johnson Vs. GW/\A etal 

Harrell, 

I have been, thinking about your indication that these matters can only be settled 

globally. You will recall that I urged the AA to assess and negotiate each dispute 

separately. I want to speak further to that issue. 

There are essentially five areas of dispute, and the Johnson's legal remedies are 

different for each of those matters. 

As to the self-service avgas proposal, on failure to agree the Johnsons' remedy would be a 

complaint to the FAA contending the AA has illegally granted and protected an exclusive 

right for SIG to sell aviation fuels, and separately at some point an action against SIG 

and the AA contending anti-trust and unfair trade practices, seeking money damages. 

As to SIG's conflicts of interest and diversion of revenue, on failure to agree the 

Johnsons could file a separate FAA complaint, but not likely a legal action, and there 

would be no damages to recover separate from the avgas monopoly. 

As to the Public Records, on failure to agree the Johnsons' 

seeking compliance and legal expenses, but not damages. 

could bring a statutory action 

As to the non-approved loan, on failure to agree the Johnson's could seek injunctive 

relief and on behalf of the AA seek recovery of improper payments from BB&T and 

reimbursement from the individual Board members. They could make a claim for legal 

expenses, but not damages. 

As to Ken's receipt of payments, on failure to agree the Johnson's again could seek 

injunctive relief and on behalf of the AA seek reimbursement of improper payments from 

Ken, and could make a claim for legal expenses, but not damages. 

Therefore the only matter in which the Johnsons could seek money damages would be ultimate 

denial of their FBO application; otherwise they could only seek, in money, reimbursement 

of legal expenses. If we conditioned settlement of any of the other matters on settlement 

of the avgas proposal, it might be construed as seeking (avgas)money in exchange for an 

agreement to refrain from reporting the Board's non-compliance with statutory duties. 

This is especially troubling as it relates to the loan and the payments to Ken, because 

violation of the relevant statutes constitute criminal offenses. The Johnsons have 

suggested that the Board be re-vamped and procedures implemented to prevent conflicts of 

interest and to ensure the Board's independence from any private influence, and to bring 

complete transparency to the AA's financial operations. It seems to me that that is the 

only legitimate demand they could make as consideration for their forbearance from 

litigation as to the loan or reimbursement from Ken (which I would hope he would make in 

any event). 

For these and other reasons, I believe the AA and the Johnsons must work toward resolution 

of these issues separately, with.the Johnson's forbearance in each case being exchanged 

for AA action in that respective case. 

Warmest regards. 

Glenn 

HAITHCOCK, BARFIELD, HULSE & KINSEY, PLLC GLENN A. 

919-734-6296 (fax) 

barfield@hbhklaw.com 

BARFIELD 919-735-6420 (phone) 
CONFIDENTIALITY NOTICE: This electronic mail transmission has been sent by a lawyer. It 

may contain information that is confidential, privileged, proprietary, or otherwise 

legally exempt from disclosure. If you are not the intended recipient, you are hereby 

notified tht you are not authorized to read, print, retain, copy or disseminate this 

message, any part of it, or any attachments. If you have received this message in error, 

please delete this message and any attachments from your system without reading the 

content and notify the sender immediately of the inadvertent transmission. There is no 

intent on the part of the sender to waive any privilege, including the attorney-client 

privilege, that may attach to this communication. Thank you for your cooperation. 

Original Message 

From: Harrell Everett [mailto:heverett@ewf-law.com] 

Sent: Thursday, November 08, 2007 11:25 AM 

To: Glenn Barfield 

Cc: clevewilkins@netzero.net 

Subject: Johnson Vs. GWAA etal 

Glenn: 

Following our meeting yesterday, I conferred with Mr. Wilkins, Chairman of the GWAA, and 

reported to him your clients demands. I advised him that in light of the various demands 

that had not been previously stated that it would be necessary for the GWAA to have a 

Special Meeting and to then go in closed session to discuss a matter of "pending 

litigation" or conduct the closed session as a part of the December 6 next meeting. 

Mr. Wilkins has not advised me in that regard as of now. Of course, it is necessary to 

poll the members and determine when they are available to meet for the special meeting and 

the 4 8 hour notice of the special meeting must be given. 

As a result, I will be in touch with you after the closed session of the GWAA and will 

advise you of the date as soon as I know. 

I will be faxing to you today the letter from the Dept. of Treasurer, dated 6-7-07 as well 

as a memo of the results of the negotiations over the Airport Manager's Contract, Lease 

Agreement, FBO Agreement and Corporate Hangar Lease between the GWAA committee composed of 

Ken Banks and Otto Kessling and SIG Aviation, LLC represented by Jim Steele. 

Harrell 
W. TIMOTHY HAITHCOCK 

GLENN A. BARFIELD 

B. GEOFFREY HULSE 

REBECCA B. KINSEY 

WORTH T. HAITHCOCK II 

HAITHCOCK, BARFIELD, HULSE & KINSEY, PLLC 

ATTORNEYS AT LAW 

231 EAST WALNU T STREET 

POST OFFICE DRAWER 7 

GOLDSBORO, NORTH CAROLINA 27533-0007 

TELEPHON E (919) 735-6420 

FAX (9 19) 734-6296 

haithcock@hbhklaw.com 

barfield@hbhklaw.com 

hulse@hbhklaw.com 

kinsey@hbhklaw.com 

worthh@hbhklaw.com 

November 9, 2007 

Mr. W. Harrell Everett, Jr. 

Everett, Womble, Lawrence & Brown, L.L.P. 

Drawer 10809 

507 B Spence Avenue 

Goldsboro, North Carolina 27532-0809 

Re: Goldsboro-Wayne Airport Authority 

Dear Harrell: 

I have been thinking about your indication that these matters can 

only be settled globally. You will recall that I urged the AA to assess 

and negotiate each dispute separately. I want to speak further to that 

issue. 

There are essentially five areas of dispute, and the Johnson's legal 

remedies are different for each of those matters. 

As to the self-service avgas proposal, on failure to agree the Johnsons' 

remedy would be a complaint to the FAA contending the AA has 

illegally granted and protected an exclusive right for SIG to sell 

aviation fuels, and separately at some point an action against SIG and 

the AA contending anti-trust and unfair trade practices, seeking 

money damages. 

As to SIG's conflicts of interest and diversion of revenue, on failure to 

agree the Johnsons could file a separate FAA complaint, but not likely 

a legal action, and there would be no damages to recover separate 

from the avgas monopoly. 
Mr. W. Harrell Everett, Jr. 

November 9, 2007 

Page 2 

As to the Public Records, on failure to agree the Johnsons' could bring 

a statutory action seeking compliance and legal expenses, but not 

damages. 

As to the non-approved loan, on failure to agree the Johnson's could 

seek injunctive relief and on behalf of the AA seek recovery of 

improper payments from BB&T and reimbursement from the 

individual Board members. They could make a claim for legal 

expenses, but not damages. 

As to Ken's receipt of pa5mients, on failure to agree the Johnson's 

again could seek injunctive relief and on behalf of the AA seek 

reimbursement of improper payments from Ken, and could make a 

claim for legal expenses, but not damages. 

Therefore the only matter in which the Johnsons could seek money 

damages would be ultimate denial of their FBO application; otherwise 

they could only seek, in money, reimbursement of legal expenses. If 

we conditioned settlement of any of the other matters on settlement 

of the avgas proposal, it might be construed as seeking (avgas)money 

in exchange for an agreement to refrain from reporting the Board's 

non-compliance with statutory duties. 

This is especially troubling as it relates to the loan and the payments 

to Ken, because violation of the relevant statutes constitute criminal 

offenses. The Johnsons have suggested that the Board be re-vamped 

and procedures implemented to prevent conflicts of interest and to 

ensure the Board's independence from any private influence, and to 

bring complete transparency to the AA's financial operations. It 

seems to me that that is the only legitimate demand they could make 
Mr. W. Harrell Everett, Jr. 

November 9, 2007 

Page 2 

as consideration for their forbearance from litigation as to the loan or 

reimbursement from Ken (which I would hope he would make in any 

event). 

For these and other reasons, I believe the AA and the Johnsons must 

work toward resolution of these issues separately, with the Johnson's 

forbearance in each case being exchanged for AA action in that 

respective case. 

With warmest regards, 

HAITHCOCK, BAJRFIEL]>9 HULSE & KINSEY, PLLC 

By: Glenn A. B 

GAB/11 
SIG Aviation Home Page 1 of 1 

Airport Information 

Goldsboro/Wayne 

Municipal Airport 

FAA ID: KGWW 

Elevation: 134' MSL 

Variation: 08'W 

AWOS: 118.97 

AWOS Phone: 919.731.4473 

,0-7 

SIG Aviation, LLC 

240 Aviation Road 

Pikeville, NC 27863 

919-734-7630 

WELCOME TO SI G AVIATION.. . 

SIG Aviation, LLC, was founded in 2001 as the aviation 

division of Strickland Insurance Group, Goldsboro, NC. We 

are conveniently located at the Goldsboro/Wayne County 

Municipal Airport (KGWW) 55 miles southeast of Raleigh. We 

are a full service FBO with a wide range of available services 

including fuel service (lOOLL, Jet A), dedicated corporate 

service and interactive passenger service 

O u r Mission... 

SIG Aviation exists to be a leader in the aviation industry 

through a focused approach to customer service in the areas 

of Corporate Travel, Aircraft Management and Fixed Base 

Operations. We achieve this goal through a continual 

commitment to safety, efficiency and flexibility without 

compromising "...that personal touch." 

Current Weather 

Goldsboro, NC 

1^6; 'L'"i6 lO cay iorecas 

- J - 3 6 °F 

Rain Shower 

Feels Like: 30°F 

Humidity: 97% 

Wind: N at 8 mph 

Enter city/zip 

VacaticR Planner 

Airport Dsiays 

Sporting Events 

Today in Weather 

Strickland Insuranc e 

Group, Inc . 

Strickland Insurance 

Group,Inc is a recognized 

leader and provider of 

specialty line property and 

casualty insurance products 

and services. 

O u r Staff... 

Our well-trained staff is very courteous and knowledgeable. 

We go far beyond the expected to ensure your experience is 

rated #1 . We commit to providing courteous, professional 

service for everyone from the larger corporate jet to the 

smallest general aviation aircraft. 

Contac t Us... 

We welcome your input. If you have questions, concerns or 

would like more information, feel free to contact us. Our 

staff is ready to serve you from 8 a.m. until 8 p.m. Monday 

thru Sunday (closed Thanksgiving Day and Christmas Day). 

Phone: 919-734-7630 

Fax: 919-731-2802 

For more information click here 

As of 12/16/2008 

lOOLL = $3.54/gallo n 

Jet A = $3.79 / gallon 

Prices include all taxes 

Volume Discount Available 

Shell Aviation 

Subject to change without notice 

Merry Christmas & 

Have a blessed 2009! 

EMERGENCY CONTACT: 919-922-5983 

©2008 SIG Aviation, LLC. All Riglits Reserved 

http://www.sigaviation.coni/ 3/2/2009 
SIG Personnel EXhiJBIT 

HOME SERVICES ^ PERSONNEL J ^ AIRPORTINFOJ^ SIG OPS 

Page 1 of2 

&i,Si;fffiiss^Mss!ajtejSiS5aiaaatM&asEfe'«ti^^^ 

SIG Aviation Personnel 

J i m Steele, Airport Manager and Chief Pilot 

Jim is Vice President of Aviation for Strickland Insurance Group, 

Inc. and manager of the Goldsboro-Wayne .Municipal Airport. A 

retired Colonel, he spent 22 years in the United States Air Force 

serving in a variety of command and staff positions. Jim is an ATPrated pilot with over 7,000 hours of jet time in various USAF and 

corporate aircraft. 

He is actively involved in the National Business Aviation Association 

(NBAA) where he serves on the Corporate Aviation Management 

Committee. With a Master's Degree in both Management and 

Education, and over 33 years in aviation, Jim brings a wealth of 

experience to our organization. 

T o m Kimbrough , FBO Manager/ Une Captain 

Tom took over management of the FBO in January 2005. He is a graduate of 

LeTourneau University, an A&P mechanic and an Airline Transport rated Pilot with 

over 5,000 hours of flight time. 

He and his family have called Goldsboro home since 2002. 

Dou g Lancaster, Une supervisor 

Doug came to KGWW after retiring from 21 years of service in the United States 

Air Force. His last assignment as Production Superintendent gave him the 

service-related experience that he shares with SIG Aviation and our customers. 

Doug maintains the highest possible standards through annual Eastern Aviation 

Line Training and NATA Line Supervisor certification. 

T o m Cuslling , Une Technician 

Tom retired from the U.S.A.F. after serving for over 20 years in the Strategic Air 

Command (SAC) He provided flight line maintenance as a Production Supervisor 

on KC-135 Tankers, B-52 Bombers, and B-IB Bombers. 

Tom joined SIG Aviation in September of 2003. The extensive military training he 

received enables him to insure all FBO and Flightline duties are conducted in a 

safe and timely manner. 

http://www.sigaviation.com/Personnel/personnel.html 3/2/2009 
SIG Personnel Page 2 of2 

Chi p Felver, Line Technician 

Chip is the newest member of the SIG Aviation team. He recently retired from 

the United States Air Force with 20 years in aircraft maintenance. His six years 

as a Maintenance Operations Coordinator adds to the wealth of aviation 

knowledge and experience already in place at the Goldsboro-Wayne County 

Airport. 

Chip has been a resident of Goldsboro since 1999 with his wife Tammy and son 

Trey. 

Darren Wilson, une captain 

Darren started his flying career in 1984 at KPWA (Wiley Post Airport, OKC, OK). 

He served as an Instructor Pilot and Check Airman at Embry Riddle Aeronautical 

University, Daytona Campus, in the 90's before extending his aviation career to 

the Part 121 world where he gained valuable experience that he now shares with 

our corporate flight department. 

He and his family have lived in the Goldsboro area since 2005. 

©2008 SIG Aviation, LLC. Ail Rights Resen/ed 

http://www.sigaviation.com/Personnel/personnel.html 3/2/2009 
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Glenn Barfield 

EXIH^IT 

Page 1 of 1 

From: Del Johnson [del@deljohnson.com] 

Sent: Wednesday, April 02, 2008 9:18 AM 

To: lyoung@ncdoj.gov 

Cc: c.branson.vickory@nccourts.org; 'Glenn Barfield'; 'Cyndi Johnson' 

Subject: Fraud committed by Goldsboro Wayne Airport Authority 

Attachments: Complaint.pdf 

Mr. Young, 

The Goldsboro Wayne Airport Authority (GWAA) has committed fraud with both state and federal money. They 

have even gone so far as to document their fraud very clearly. The local district attorney, Mr Branson Vicl<ory 

(cc'd), stated to my attorney, Mr Glenn Barfield, that he was forwarding the matter to the SBI for further 

investigation, but has not provided any additional information that such action has been taken. 

In a nutshell, the GWAA: 

1. Obtained a loan that exceeded their limits without Local Government Commission approval 

2. Provided fraudulent documents to the Local Government Commission for approval 

3. Other crimes that have been committed are documented in the complaint my-attorney has filed with the 

F/VA (attached). 

4. Will not release the independent financial audit - we believe other crimes have been committed, but cannot 

get the documents from them. 

5. Illegally pay a board member, Mr Ken Banks, to be their CPA. 

Please let us know if the local district attorney has indeed forwarded this to you and if there is any additional 

documentation we can provide to assist you. The state and local community will lose over $500,000 if this fraud 

and illegal activity goes unchecked. 

My attorney is Mr. Glenn Barfield and you may speak with him or me at any time regarding this. 

We are meeting with an FBI agent investigating this next week and may be able to save some time and effort if 

you would like us to explain it to your agents, along with evidence, at the same time. 

Thanks for any assistance, 

- Del Johnson 
11/30/07 

Date Reference T 

Goldsboro - Wayne Airport Authority 

General Ledger 

Beginning 

Description Balance 

2048000 BB&T #5290289590 24,621.80 

11/30/07 1 

11/07/07 2 

11/13/07 2 

11/21/07 2 

11/30/07 11 

11/30/07 12 

Cash Disbursements 

DEPOSIT 

DEPOSIT 

DEPOSIT 

BB&T GOVT FINANCIAL 

SERVICE CHARGE 

_ 

Current 

Amount 

(23,254.86) 

5,300.00 

2,410.32 

39,285.00 

(5,023.41) 

(5.00) 

18,712.05 

1286 

Page 1 

YTD 

Balance 

43,333.85 

2049000 BB&T #5294497309 73,457.58 

11/30/07 13 TO RECORD INTEREST INCOME ON BB&T 5294497309 

2300000 Accounts Receivable 

3200000 Buildings 

3205000 Improvements 

3205100 Land Improvements 

3210000 New Executive hanger 

3240000 Furniture & equipment 

11/07/07 1659 JIM STEELE - REIMB FOR TERMINAL RENOVATIONS 

11/07/07 1660 TOM KIMBROUGH - REIMB FOR TERMINAL 

RENOVATION 

3250000 Land 

3254000 WCC Maint Hanger/Local Project 

3255000 New Taxiway Project 

3260000 Projects Under Construction 

3262000 #36244.31.1.1(Apron Lighting) 

15.10 

329.00 

1,948,774.79 

47,059.77 

1,934,379.56 

19,528.24 

1,024,278.00 

375,411.00 

146,759.00 

1,800.00 

12,443.92 

55,502.30 

15.10 

0.00 

0.00 

0.00 

0.00 

0.00 

298.89 

975.26 

1,274.15 

0.00 

0.00 

0.00 

0.00 

0.00 

73,472.68 

329.00 

1,948,774.79 

47,059.77 

1,934,379.56 

19,528.24 

1,025,552.15 

375,411.00 

146,759.00 

1,800.00 

12,443.92 

55,502.30 
11/30/07 Goldsboro - Wayne Airport Authority 

General Ledger 

Date Reference T Description 

3262500 #36237.22.1.I(T/WALP update.Sec.Gate) 

3262600 # 36237.22.4.1(Apron Lighting/Design,Beacon) 

3262700 # 36237.22.3.1(T-Hanger & WCC taxilane,Acess Road 

11/01/07 1652 THE LPA GROUP OF NC, PA 

3262900 #36237.22.5.1(Pending name) 

3280000 Intangible Assets 

3290000 Security Projects 

3300000 Accumulated Depreciation 

3310000 Accumulated Amortization 

4010000 Accounts Payable - operations 

4300000 N/P - BB&T short term portion 

5030000 N/P - BB&T 

11/30/07 11 BB&T GOVT FINANCIAL 

5568000 Contributed Capital 

5570000 Fund Balance - operations 

6001000 Income - Co. operations 

11/21/07 2 DEPOSIT 

6002100 Income - Co. Cap. project 

Beginning 

Balance 

11,895.73 

(45,208.37) 

25,017.84 

15,546.98 

98,101.86 

14,940.00 

(1,905,970.01) 

(6,889.46) 

(701.11) 

(41,127.00) 

(395,007.59) 

(2,119,109.35) 

(1,306,340.85) 

(37,477.50) 

(4,320.17) 

Current 

Amount 

0.00 

0.00 

2,800.00 

2,800.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

3,696.93 

3,696.93 

0.00 

0.00 

(37,477.50) 

(37,477.50) 

1286 

Page 2 

YTD 

Balance 

11,895.73 

(45,208.37) 

27,817.84 

15,546.98 

98,101.86 

14,940.00 

(1,905,970.01) 

(6,889.46) 

(701.11) 

(41,127.00) 

(391,310.66) 

(2,119,109.35) 

(1,306,340.85) 

(74,955.00) 
11/30/07 Goldsboro - Wayne Airport Authority 

General Ledger 

Date Reference T Description 

6002100 Income - Co. Cap. project (cont.) 

6004000 Income-Rent 

11/07/07 2 DEPOSIT 

11/13/07 2 DEPOSIT 

11/13/07 2 DEPOSIT 

11/13/07 2 DEPOSIT 

11/21/07 2 DEPOSIT 

11/21/07 2 DEPOSIT 

6005000 Income-Other 

6020000 Income - Interest (BB&T) 

11/30/07 13 TO RECORD INTEREST INCOME ON BB&T 5294497309 

6070000 SIG Aviation fuel flow 

11/13/07 2" DEPOSIT 

6308000 Meeting cost 

6309000 Legal 

11/21/07 1664 EVERETT, WOMBLE, LAWRENCE & BROWN 

This is for October. 1 no longer 

Beginning 

Balance 

(27,119.25) 

(53.25) 

(64.92) 

(1,303.07) 

357.40 _ 

4,088.33 

receive compensation for the write-up 

6309100 Accounting & audit .., ,.,.,^ , t--- .services 

11/07/07 1658 - KMNET H E., BANKS' 

11/21/07 1663 PITIARD, PERRY & CRONE 

6311000 Airport manager 

11/01/07 1648 SIG AVIATION, LLC 

6311200 Grass cutting contract 

11/01/07 1649 DWIGHT PERRY 

6313000 Bank Charges 

11/30/07 12 SERVICE CHARGE 

6322000 Dues & subscriptions 

4,420.00 

8,400.01 

4,000.00 

36.00 

160.00 _ 

Current 

Amount 

0.00 

(5,300.00) 

(250.00) 

(800.00) 

(1,000.00) 

(800.00) 

(1,007.50) 

(9,157.50) 

0.00 

(15.10) 

(15.10) 

(360.32) 

(360.32) 

0.00 

5,253.00 

5,253.00 

' "~ 

130.00 

4,000.00 

4,130.00 

2,500.00 

2,500.00 

1,000.00 

1,000.00 

5.00 

5.00 

0.00 

1286 

Pages 

YID 

Balance 

(4,320.17) 

(36,276.75) 

(53.25) 

(80.02) 

(1,663.39) 

357.40 

9,341.33 

8,550.00 

10,900.01 

5,000.00 

41.00 

160.00 
11/30/07 Goldsboro - Wayne Airport Authority 

General Ledger 

Beginning 

Date Reference T Description Balance 

6330000 Heat, lights, & water 2,828.38 

11/01/07 1650 PROGRESS ENERGY 

11/07/07 1654 WASTE INDUSTRIES 

11/21/07 1662 PROGRESS ENERGY 

11/27/07 1667 PROGRESS ENERGY 

6334000 Insurance 14,991.00 

6336000 Interest expense 5,574.88 

11/30/07 11 BB&T GOVT FINANCIAL 

6341000 Miscellaneous (83.05) 

11/27/07 1668 VOID 

6345000 Postage, copies & supplies . 273.11 

6349000 Pest control 260.00 

6357000 Repairs & maintenance 4,003 69 

11/07/07 1656 JACKSON & SONS 

11/07/07 1657 DAVIS REPAIR SERVICE 

11/21/07 1665 JACKSON & SONS 

11/27/07 1666 BUCK'S FIRE EXTINGUISHER 

11/27/07 1669 THALES ATM, INC 

6357100 NDB & localizer maint. contra 2,040.00 

11/01/07 1651 DEAN KENNEDY 

6363000 Secretarial expense 1,200.00 

11/01/07 1647 BARBARA HUFF 

6364000 Sewage contract 1,085.85 

11/07/07 1653 TOWN OF FREMONT 

6367000 Telephone & telegraph 651.72 

11/07/07 1655 AT&T 

11/21/07 1661 AT&T 

Current 

Amount 

153.80 

117.03 

398.51 

154.23 

823.57 

0.00 

1,326.48 

1,326.48 

0.00 

0.00 

0.00 

0.00 

826.00 

951.34 

112.00 

251.41 

1,980.00 

4,120.75 

585.00 

585.00 

300.00 

300.00 

305.50 

305.50 

50.63 

112.26 

162.89 

1286 

Page 4 

YTD 

Balance 

3,651.95 

14,991.00 

6,901.36 

(83.05) 

273.11 

260.00 

8,124.44 

2,625.00 

1,500.00 

1,391.35 

814.61 
11/30/07 Goldsboro - Wayne Airport Authority 

General Ledger 

1286 

Page 5 

Date Reference T Description 

Beginning 

Balance 

Current 

Amount 

YTD 

Balance 

6371000 Capital outlay 6,557.21 

0.00 6,557.21 

Current Profit/(Loss) 26,498.23 YTD Profit/(Loss) 35,991.86 

Number of Transactions 42 

The General Ledger is in balance 0.00