### UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS

IN THE MATTER OF: AVIONICS MASTERS, INC. FDMS No. FAA-2013-0288 Respondent Tuesday, April 15, 2014

The conference call took place via telephone, pursuant to notice, at 1:30 p.m. BEFORE: THE HONORABLE J.E. SULLIVAN, Administrative Law Judge

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### APPEARANCES: On Behalf of the Complainant: CHRISTOPHER R. STEVENSON, ESQ. of: Federal Aviation Administration, Office of the Regional Counsel, Southern Region, AS0-7 P.O. Box 20636 Atlanta, Georgia 30320

(404) 305-5200 (404) 305-5223 (fax) On Behalf of the Respondent: MOHAMMAD AHMED FARUQUI, ESQ. Aerolaw Offices PLLC 633 SE 3rct Ave, Suite 4R Trial Lawyers Building Fort Lauderdale, Florida 33301 (954) 527-0002 (954) 524-5143 (fax) Also Present: CODY L. SMITH, DOT Staff Attorney

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1 

### P-R-0-C-E-E-D-I-N-G-S 2 1:34 p.m. 3 

### JUDGE SULLIVAN: We're on the 4 

### record in the matter of Avionics Masters, 5 Inc. This is Docket No. FAA-2013-0288. Today 6 

### is Tuesday, April 15, 2014, and the parties 7 

### have convened for a summary judgment motion 8 

### conference. 9 

### Mr. Christopher R. Stevenson, the 10 

### attorney of record for the FAA, is present by 11 

### telephone. Mr. Mohammad Ahmed Faruqui, the 12 

### attorney for the Respondent, is also present 13 

### by telephone. Sitting in as an observer at 14 

### the Office of Hearings is Mr. Cody L. Smith, 15 

### an attorney advisor with this office. 16 

### Good afternoon, everyone. 17 

### MR. FARUQUI: Good afternoon. 18 

### MR. STEVENSON: Good afternoon, 19 Your Honor. 20 JUDGE SULLIVAN: What I'll do is a 21 

### 1ittle bit of housekeepingbefore we jump into 22 specific argumental questioning.

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### 1 I'll note that on March 10, 2014, 2 the FAA filed its Motion for Summary Judgment, 3 

### seeking complete dispositive relief regarding 4 

### both the alleged violations and the proposed 5 

### civil penalty, which in the complaint was 6 listed as $7,150. 7 On March 18, 2014, the Respondent 8 

### filed the Respondent's amended answer and 9 

### affirmative defenses, and this was also the 10 

### same time when the Respondent started to 11 prepare for what his attorney would file. 12 On March 26' 

### 2014, the 13 Respondent's answer opposing the FAA's Motion 14 

### for Summary Judgment was filed. 15 On April 7, 2014, the FAA filed an 16 amendment to its complaint, in which it was 17 listing certain amendments, and we'll talk 18 about that in just a moment. 19 April 7th, 

### that same day, the FAA 20 filed its reply and supportive Motion for 21 Summary Judgment, and earlier today, on April 22 15, 2014, the Respondent filed a second

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### 1 amended answer and affirmative discensus in 2 responded to the FAA's amended complaint, as 3 

### well as a brief response responding to the 4 

### FAA's reply in support of the Motion for 5 

### Summary Judgment. 6 

### So, I think I covered everything 7 

### that's been filed so far. 8 

### Mr. Stevenson, I'll start with 9 

### you, is there anything that I missed, in terms 10 

### of what should be in the court's file today? 11 

### MR. STEVENSON: I don't believe so, 12 

### Your Honor. 13 

### JUDGE SULLIVAN: Okay. And, Mr. 14 

### Faruqui, anything that I may have missed on 15 

### behalf of your client? 16 

### MR. FARUQUI: I 

### don't think 17 anythinghas beenmissed. There is one little 18 housekeepingmatter that I wanted to bring up, 19 which is that one of the digits on the 20 citation of the Chambers case, as we have 21 

### cited, was incorrect. Insteadof 526, Federal 22**2~,** 

### it should have been 524.

NEALR. GROSS (202) 234·4433 COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLANDAVE., N.W. WASHINGTON, D.C. 20005·3701 www.nealrgross.com6 1 JUDGE SULLIVAN: Yes. Before you 2 start to talk about that, essentially, I have 3 a reply filed by the FAA that cites the 4 Chambers case. Did you also cite that in your 5 response? 6 MR. FARUQUI: Yes, in the 7 Respondent'sansweropposingthe Complainant's 8 Motion for Summary Judgment. 9 JUDGE SULLIVAN: Okay. And, what 10 case were you going to refer me to in your 11 materials? 12 MR. FARUQUI: Okay. The material 13 that I filed on March 20th, page one on the 14 bottom, when I cite Chamber v Equitable Life. 15 JUDGE SULLIVAN: Okay. Before you 16 go on, I don't have anything that was filed on 17 March 20th. Can you identify for me the title 18 of what you are talking about, the document 19 you filed? 20 MR. FARUQUI: Yes. It's 21 Respondent's Answer Opposing Complainant's 22 Motion for Summary Judgment.

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### 1 JUDGE SULLIVAN: Okay. That was 2 filed with this office on March 26,2014. 3 MR. FARUQUI: Okay. 4 JUDGE SULLIVAN: And, in looking at 5 that, I see on page one of the eight-page 6 document a citation to Chambers. What do you 7 want to correct on page one of that document? 8 MR. FARUQUI: It states there 226 9 

### F2nd, 338. 

### It is, actually, 224, F2nd, 338. 10 

### JUDGE SULLIVAN: Okay, thank you 11 very much for that correction. 12 

### Okay. Let's talk a little bit 13 about some preliminarymatters in addition to 14 that correction. 15 I have before me FAA Exhibit A as 16 in apple, through I as in igloo, which appear 17 to be documentary evidence. I also have FAA 18 Exhibit J as in jackal, which appears to be 19 testimonial. 20 

### Mr. Faruqui, do you have any 21 objection to the admissibility of these 22 documents, and if so, what objections might

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### you have? 2 MR. FARUQUI: Let me see -- give me 3 one second, Your Honor. 4 

### I don't have an objection to 5 

### Government's Exhibit A. I don't have an 6 

### objection to Government's Exhibit B. No 7 

### objection to C. 

### No objection to D. No 8 

### objection to E, except for the fact that the 9 

### Form 101 

### was not attached to Exhibit E. And, 10 

### we have asserted before in our summary 11 

### judgment argument that form 101 

### should be a 12 

### part of Government's Exhibit E. So, that's 13 

### our main objection to Exhibit E. 14 

### JUDGE SULLIVAN: And, I'm going to 15 

### ask you a little bit about that in just a 16 

### minute. But, why don't we go on with the 17 

### other exhibits. 18 

### MR. FARUQUI: Sure. 19 

### Okay. F, I do not have an 20 

### objection to. G, I do not have an objection 21 

### to. I don't have an objection to H. No 22 objection to I. I don't see an H, but I see

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### 1 a J. 

### 2 JUDGE SULLIVAN: I have Exhibit H, 3 as in ham, and my understanding from what you 4 just said is that you had no objection to it. 5 You also indicatedno objection to 6 an exhibit under the initial I, as in igloo. 7 And, the only other exhibit I have that was 8 submitted by the FAA is an Exhibit J, as in 9 jackal. 10 MR. FARUQUI: Okay. 11 JUDGE SULLIVAN: Do you have 12 MR. FARUQUI: I'm sorry, I must 13 have lost that. 14 

### H, I don't have an objection to. 15 

### I, I don't have an objection to. And J, I 16 don't have an objection to. 17 

### JUDGE SULLIVAN: Okay. Then let's 18 talk a little bit about the partial objection 19 to Exhibit E, and can you show me on Exhibit 20 E, either on page one or on page two of that 21 two-page exhibit, where you are assertingthat 22 there was a page that was missing?

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1 MR. FARUQUI: Okay. The way the 2 Respondent offer it is, they have a Form 101, 3 and that is to be taken together with the work 4 order, when the work order is interpreted. 5 The Respondent has provided Form 6 101 to the Administrator in the discovery, 7 along with the work order. The Form 101 is a 

### s part of the work order, although it's not in 9 the same format as the work order itself. 10 Okay. 11 The Form 101 has its own page 12 numbering system. In this case, the Form 101 13 that was attached to the work order was 15 14 pages, but the page that was relevant to our 15 case was page 13. And, the Administratorknew 16 from the beginning of the investigation about 17 page 13, and its existence, and its relevance 18 to the work order, because in the initial 19 communication by the FAA investigator, they 20 made references to page 13. 21 So

-- 22 JUDGE SULLIVAN: And, you included

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### 1 that in your exhibit materials, and marked it 2 as Exhibit 2. 3 

### MR. FARUQUI: Right. We marked it 4 as Respondent's Exhibit, and all we want is 5 that that Form 101 should be considered as a 6 part of Government's Exhibit E. 7 

### JUDGE SULLIVAN: Okay. So, it's s not so much an admissibilityobjection, as it 9 is to a weight objection, in terms of 10 

### considering the evidence, as I understand it. 11 

### MR. FARUQUI: Well, admissibility 12 is subject to the completeness of the exhibit 13 itself. 14 

### JUDGE SULLIVAN: But, neither of 15 you have submitted a complete exhibit, if, in 16 fact, Exhibit E, as in egg, is 32 

### pages long. 17 Would that be a fair statement? 18 Mr. Faruqui? 19 

### MR. FARUQUI: I don't know. I 20 

### mean, well, their work order is a monthly 21 tabulation of work done. The page that they 22 gave to the Administrator was the page that

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### 12

1 

### was relevant to the investigation, and then 2 page 13 of the Form 101 is the page of the 3 

### Form 101 that is relevant to the 4 investigation. Page 13 of form 101 should be 5 included as a part of this relevant page of 6 the work order. 7 These two together would make a 8 complete Government exhibit. 9 

### I'm not saying that the entire, 10 you know, book of work, you know, that is all 11 the ring making that company does should be 12 part of the exhibit, because then we would all 13 be papered to death, and that's not something 14 the court would want. 15 But, the point that I'm making is 16 that, the Form 101, page 13, completes Exhibit 17 E. 

### 18 JUDGE SULLIVAN: Okay, thank you. 19 Mr. Stevenson, turning to you, in 20 looking at Exhibit E, do you have any response 21 to the Respondent's objection on a partial 22 basis?

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1 

### Mr. Stevenson. Do I still have 2 Mr. Stevenson on the line? 3 

### MR. STEVENSON: Oh, I apologize, 4 Your Honor. I'm here, while you were talking 5 

### I was shuffling some papers around, so I had 6 

### muted my side of the conversation, and I 7 

### forgot that I had hit the mute button. 8 

### JUDGE SULLIVAN: And, just so 9 

### Mr. Stevenson, I would prefer that you don't 10 

### do that in the future, unless I ask you to do 11 

### it. 12 

### MR. STEVENSON: Yes, Your Honor. 13 

### Yes, I 

### do have a 

### response 14 concerning the completeness of this. 15 

### First, I don't know that it goes 16 to the admissibility, but since opposing 17 Counsel mentioned it let me be clear that this 18 Form 101 is not referenced in the letter from 19 

### our inspectors. It is not referenced in 20 Exhibit F, the letter back from Mr. Hunt and 21 

### Avionics Masters, which is Exhibit Gin the 22 attached to the Summary Judgment Motion.

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1 As I believe I indicated in my 2 reply in support of summary judgment, it was 3 posed by the Respondent in discovery. 4 However, there was no indicationas to what it 5 was, and I don't know, maybe other people can, 6 but I find a copy of the form

-- the copy of 7 the one page of the Form 101 that was provided 8 in discovery to be illegible. So, I had no 9 idea what it was until the Respondent retained 10 an attorneywho identifiedwhat that form was, 11 and then at that point I was able to figure it 12 out. 13 I don't think that there's a 14 completeness problem with Exhibit E. I think 15 that there are two different forms, there is 16 the work order and there is a form 101. I 17 don't think that there's a problemwith taking 18 one of those with the other. If there is a 19 problemwith doing only the two pages that are 20 the work order, I mean, the Respondent has 21 submitted that one page of the Form 101, and 22 that can be submitted as its own exhibit, or

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.. N.W. WASHINGTON. D.C. 20005-3701 www.nealrgross.com15 1 part of the same exhibit, to correct any 2 deficiencies in Exhibit E to the FAA's Motion 3 for Summary Judgment. 4 And, I guess there is the 5 potential completeness problem with just 6 having one page of that document. I don't 7 know if there's anything else pertinent on the s other

-- I'm presuming 14 pages of that Form 9 101 that refer to the other-- that I presume 10 relate to the other components that they 11 worked on during that month. 12 JUDGE SULLIVAN: Okay, thank you. 13 I will note the objection and 14 respectfullyoverrule it. I will note that in 15 Exhibit E, as in egg, the FAA has submitted 16 two pages out of what appears to be a 32-page 17 document, if I take as being accurate the 18 informationthat's containedat the top of the 19 two pages on the right-hand side upper corner, 20 which says total pages, and then the number 32 21 follows. 22 I'll also note that the date of

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1 Exhibit E on page one and page two at the top 2 left-handpage is December l, 2011, with page 3 one indicating a second date at the bottom of 4 the page on the right-hand side as December 5 31, 2011. The second page has no date. 6 There's no particular reference in 7 either of these two pages to what has been 8 marked and offered as Respondent's No. 2, 9 which was dated December 22, 2011, and 10 indicates that it's page 13 of 15, 11 Respondent'sExhibit No. 2, offering onlypage 12 13 out of 15 pages. 13 I cannot take as persuasion the 14 Respondent's argument that Exhibit E, as in 15 egg, offered by the FAA, should not be 16 admitted because it's incomplete, when it 17 appears there is no nexus on its face to FAA 18 Exhibit E to Respondent'sExhibit 2, eitherby 19 date or by page. 20 So, I will note the Respondent's 21 objection, and I will respectfully overrule 22 it.

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### 17

1 

### With that, it appears that I will 2 be

-- that I am, essentially, finding that 3 

### Exhibits A through J, with the except of E, 4 

### are admissible without objection, and Exhibit 5 

### E is deemed admissible over the Respondent's 6 

### objection. 7 

### Mr. Stevenson, let's go to you. I 8 

### now have would like to hear from you 9 

### regarding Respondent's 1 

### and 2, 

### as well as 10 

### Respondent's declaration identified as 11 

### Affidavit of Charles Hunt. Do you have any 12 objections to the admissibility of these 13 proffered exhibits. 14 MR. STEVENSON: Let's see, if I 15 so, just to make sure that I am referring to 16 

### the same things, the exhibits that the 17 Respondent submitted, one was Honeywell, some 18 excerpts from a maintenance manual for the 19 Bendix/King gyro, and the second was the page 20 13 of 15 of Form 101. Do I have that correct? 21 JUDGE SULLIVAN: I believe that's 22 how those were identified and marked, yes.

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1 

### MR. STEVENSON: Okay. I do not 2 have any objection to the consideration of 3 those on summary judgment. I do not have an 4 

### objection to the consideration of the 5 

### declaration of Mr. Hunt. 6 

### I will note that I saw references 7 

### in the Respondent's response to the Summary 8 

### Judgment Motion to another affidavit or 9 

### declaration from someone who was a clerk at 10 

### the repair station, and I do not have a copy 11 

### of that declaration. 12 

### JUDGE SULLIVAN: Yes. I'm going to 13 

### be talking a little bit with both of you about 14 

### some things that appear to be missing, but it 15 

### appears that the FAA 

### has no objection to 16 

### Respondent's Exhibits 1 

### and 2, 

### and they are 17 

### hereby deemed admissible, and will be 18 

### considered. 19 The FAA 

### has no objection to the 20 testimonial affidavit submitted and authored 21 

### by a Mr. Hunt, and also it's deemed admissible 22 for purposes of summary judgment.

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### 19

1 

### Now, let's talk a little bit about 2 

### what appears to be some gaps that may or may 3 not have been intentional by the parties. 4 

### Let's talk first, Mr. Stevenson, about the 5 

### proposed penalty. 6 In the documentaryand testimonial 7 

### evidence that you submitted, there is nothing 8 that I could see that addresses your proposed 9 

### penalty amount. And, summary judgment is 10 based solely on evidence, not on argument. 11 So, my question to you is, do you 12 have the ability, if I 

### grant you an 13 opportunity for the record to supplement your 14 materials and provide some evidence that 15 supports your suggestion that, number one, a 16 proposed penalty should be assessed, number 17 two, that the proposed penalty should be in 18 the maximum range, and, number three, that the 19 amount of $7,150 is appropriate? 20 

### MR. STEVENSON: I apologize, Your 21 Honor. 22 I 

### can provide additional

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### supplementationas Your Honor would desire. I 2 

### can do that. I would note, however, that 3 Exhibit 5 to the Administratc:r's Motion for 4 

### Summary Judgment, which consisted of excerpts 5 

### from the FAA 

### Order 2150. 3B, 

### which is the 6 

### published sanction, which includes the 7 

### published sanction guidance from the 8 

### Administrator, does specify that, you know, 9 

### for maintaining or altering an appliance for 10 

### which the repair station is not rated, that 11 

### the civil penalty range called for there is 12 

### the maximum range. 13 

### So, I 

### can supplement, but I 14 

### believe that that particular aspect has been 15 

### submitted in evidence. 16 

### JUDGE SULLIVAN: Why don't we look 17 

### at that very quickly. This is a multi-page 18 

### exhibit. 19 

### MR. STEVENSON: Yes, Your Honor. 20 

### JUDGE SULLIVAN: And, why don't you 21 

### tell us what page you want the court to look 22 

### at.

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### 21 1 MR. STEVENSON: In page B21, 

### which 2 is the last page of the exhibit, and that is 3 page 21 

### of Appendix B to the order, which lS 4 

### why the pagination has a letter in it. And, 5 this page is part of Figure B3B, 

### which 6 concerns repair stations, and paragraph 13 

### of 7 

### that figure says that, "maintaining or 8 altering an airplane, power plant, or power 9 instrument radio or accessories for which the 10 repair station is not rated, civil penalty 11 maximum or, potentially, a suspension or 12 revocation." 13 

### JUDGE SULLIVAN: Okay. So, that's 14 the last page of Exhibit-- let's see, I as in 15 igloo. 16 So, now take me to where it says 17 the range or the maximum. 18 

### MR. STEVENSON: I'm sorry, the 19 place where it says -- where it defines what 20 maximum range is? 21 JUDGE SULLIVAN: Correct. 22 MR. STEVENSON: Okay. If 

### you slip

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### 22 1 back one page in the exhibit, which should be 2 page B5, again

-- which is in Appendix B to 3 FAA Order 2150.3B, Section 4, which is near 4 

### the bottom of that page, talks about a 5 violation committed by an air agency, which 6 includes repair stations for small business 7 concerns, which the Respondent is a small 8 business, not a large business, the maximum 9 range is $7,510 through $11,000. 10 

### JUDGE SULLIVAN: Okay. Now, let me 11 ask you a next question. In all the pages 12 that precede that under Exhibit I, as in 13 igloo, is there any information within those 14 pages that talk about making a decision about 15 going beneath that particularmaximum for any 16 particular mitigating circumstances, or how 17 you -- how you exercise your prosecutorial 18 discretion to utilize a different standard, 19 

### since these are guidelines only? Is there 2

### o anything in the material in I that would 21 address that? 22 MR. STEVENSON: The material in I,

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- using the page number at the bottom, 7-9, 16 under

-- and the first heading on this page is 17 5, Use of the Table of Sanctions, and then B 18 talks about single, first-time inadvertent 19 violations. And then paragraph 3 within that 20 is called, Applying Ranges Within a Sanction 21 Type, and the last sentence of that is, "When 22 determining a specific sanction amount in a

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### 25

1 

### purpose. It's not a mitigating factor that 2 it's your first offense, because the range 3 already presumes that that's the case. 4 

### JUDGE SULLIVAN: And, are you 5 looking again on page 7-9, in say, paragraph 6 2, when you are talking about this, or are you 7 looking at some place else? 8 

### MR. STEVENSON: I am looking at, 9 

### yes, at page 7-9, paragraph 1 paragraph 2, 10 in particular, and also paragraph 1. 11 

### JUDGE SULLIVAN: Okay. And then, 12 just so that you know, yes, I think you do 13 need to supplement your record with some 14 explanation that is in declarative form. 15 

### And, the reason I say that is 16 because this is your evidentiary proof that 17 you have to present to the trier of fact. It 18 is not for the trier of fact to try and guess 19 what you intended, based on this particular 20 exhibit. 21 I 

### also think it's extremely 22 helpful to the Respondent to have that

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### 26 1 information, so the Respondent can respond to 2 it, and have a better understanding of this 3 

### material, to which the Respondent may be 4 

### introduced to for the first time in a motion 5 

### like this. 6 

### So, let me turn to you, Mr. 7 

### Faruqui, for a moment, and then I'm going to 8 

### talk about some deadlines for supplemental 9 

### materials. 10 

### Let's start with the affidavit of 11 a 

### Mr. Hernandez. There was in the 12 Respondent's answer to the Summary Judgment 13 Motion a reference to the filing of an 14 affidavit or declaration from a Raphael 15 Hernandez. And, I'm, specifically, looking at 16 the March 26, 2014, Respondent's Notice of 17 Filing Respondent's Exhibits and Affidavits. 18 Were you aware that that was never 19 filed? 20 

### MR. FARUQUI: Yes, I became aware 21 of it when it came to my realization that the 22 that the client was unable to procure the

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### 27

1 

### executionof the affidavit from the additional 2 

### witness. I did not, I was not able to get 3 direct contact of Mr. Hernandez, and asked the 4 

### client to help me get in touch with Mr. 5 

### Hernandez. 6 

### I have filed the answer and the 7 

### exhibit list in the way that I filed it, in 8 

### order to meet the deadline, because I was 9 

### hired very shortlybefore the deadline, and my 10 

### intention was to then supplement the filing 11 

### upon receipt of Mr. Hernandez's affidavit. 12 

### But, as it turned out, he did not 13 

### execute it on time. 14 

### JUDGE SULLIVAN: Okay. So, you 15 

### don't plan to file it, it sounds like. 16 

### MR. FARUQUI: Well, for the 17 purposes of the summary judgment issue, for 18 now it's withdrawn. 19 JUDGE SULLIVAN: Okay. 20 MR. FARUQUI: Any reference to it, 21 

### and the filing of it. 22 If we have to use it later, you

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### 28 1 know, at a trial or something, well, at that 2 time maybe, you know, of we choose to use Mr. 3 

### Hernandez's testimony rather than an 4 

### affidavit, but that's not somethingthat I can 5 

### decide right now. 6 

### JUDGE SULLIVAN: Okay, thank you. 7 

### MR. FARUQUI: For now it's 8 withdrawn. 9 JUDGE SULLIVAN: Then let me turn 10 

### then to the monetary issue. In your most 11 recent filing, the materials that were filed 12 this morning on April 15, 2014, you had 13 indicateda relief of a reduction of the civil 14 penalty to $935, 

### or in the alternative to 15 eliminate the civil penalty in favor of a 16 remedial action. 17 Do you recall that? 18 MR. FARUQUI: Yes. 19 

### JUDGE SULLIVAN: Okay. I, 20 

### actually, would need for you, in your 21 responsive material to the summary judgment 22 motion, to provide some evidentiary response

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1 to the FAA's material on summary judgment as 2 it is proposing the civil penalty as $7,150. 3 So, what I'm going to do is, I'm 4 going to give the FAA a chance to file a 5 supplemental declaration regarding the 6 proposal of $7,150. 7 I'm also going to give you a 8 supplemental deadline for responding to that 9 material on summary judgment. 10 It's one thing to alternatively 11 plead a different amount. It's another thing 12 to respond evidentially to the material that 13 I have before me, and I know that you know 14 that. 15 We'll be talking about that a 16 little bit more in just a minute. 17 I'm going to turn back to you, Mr. 18 Stevenson, in terms of the amended complaint. 19 In the future, I would respectfullydirect you 20 to file a specific amended complaint when you 21 file this amendment. 22 What I would strongly recommend is

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1 that you file a document that is in the form 2 of a complaint, that is entitled either, 3 amendment to complaint, or amended complaint. 4 And, it should read exactly like your original 5 complaint, with whatever amendments that you 6 are making, either in italics or in bold. 7 And, any strikethroughs you are making, 8 actually, struck through, so that whoever is 9 reading it, either myself or the Respondent, 10 or a member of the public, can hone in exactly 11 on what it is that you are amending, changing, 12 clarifying, explaining, and so forth. 13 The form that you are using, or 14 that you used in this particularcase, I think 15 is insufficient, quite frankly, in part 16 because you are looking at -- let me just take 17 a look at this material-- on page one of the 18 amendment to complaint as its written, it 19 says, "The original complaint is amended and 20 superceded as described below." Section one 21 is unchanged, and then it says, "Some changes 22 have been made in Sections 2 and 3 of the

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### 31 1 complaint, in order to provide additional 2 clarity." And then, it goes on to talk about 3 the new sections. 4 

### Well, I have no idea what the 5 

### changes are that you made, unless either I or 6 a staff person go back and compare word by 7 

### word, line by line, Sections 2 and 3 of the 8 complaint. And, I don't think that was your 9 

### intent, that, generally, isn't the intent of 10 

### anyone making an amendment. The easiest way 11 to amend a document is to prepare the document 12 so that you have the original, and then the 13 amendment with the strikeouts identified 14 clearly in the original, so that it's a fast, 15 

### easy process to review by the court, 16 Respondents, everyone else. 17 

### So, if you have that document in 18 yourpossessionnow, andareusingit, I would 19 direct you to file it with the court and cc 20 the Respondent. If you don't have it now, I 21 think I can accept this, but I'm also going to 22 ask you to state what those changes are in

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### 33

1 

### complaint. Or, you can submit that 2 separately, whatever you think would work 3 pursuant to 14 CFR, I think it's Section 4 

### 13.214. Right, 14 CFR, Section 13.214 talks 5 

### about the amendment and the pleadings, but it 6 

### doesn't give a lot of clear advice about how 7 

### to do that easily. 8 

### So, if you could that, that would 9 

### be great, and we'll talk about a deadline to 10 

### do that as well. 11 

### So, before we get into oral 12 

### argument in depth, because I know the parties 13 

### have been arguing fairly vigorously about a 14 

### variety of different things. As I understand 15 

### the amendment to the complaint, the FAA is 16 

### pleading in the alternative at this point. 17 

### So, essentially, the violations alleged in the 18 

### amendment, talking about Sections 43.5A and 19 

### 43.9A1, are violations pleading the 20 

### alternative. Is that correct, Mr. Stevenson? 21 

### MR. STEVENSON: That's correct, 22 Your Honor.

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1 JUDGE SULLIVAN: Okay. Then what 2 I'd like to do, sir, for purposes today, is 3 talk 

### a little bit about the primary 4 allegations that are before the court in the 5 summary judgment motion, which are violations 6 under 14 CFR Section 145.SA and 14 CFR Section 7 145.201B, as in boy. 8 And, I plan to really focus on the 9 second of those two regulations, that being 14 10 CFR Section 145.201B, which is the more 11 specific of the two regulations that have been 12 charged against the Respondent. 13 In looking at that particular 14 regulation, it says that, "A certified repair 15 station may not maintain or alter any article 16 for which it is not rated.• 17 I want to focus the parties' 18 attention to that particular part of the 19 regulation first and foremost, because from 20 what I read in the regulation they include 21 inspection. So, if I take all of the evidence 22 in a light most favorable to the Respondent,

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1 which I am required to do in a summary 2 judgment motion, I still have what appears to 3 be an agreement by the parties, at least 4 evidence on its face, that the Respondent 5 engaged in an inspection of the gyro that's in 6 dispute in this case. So, I have some basis 7 by inspection before the court of the gyro. 8 Respondent says to me, in his 9 material, this material, that it had the 10 ability to engage in what it calls a "Level 1 11 rudimentary inspection of the gyro." 12 The FAA, through its testimonial 13 witness, Mr. McGlen, says that the Respondent 14 had the limited authorization to engage in 15 some inspection of the auto pilot system, 16 which includes some inspection of the gyro. 17 And, I'm looking at Exhibit, FAA Exhibit J, as 18 in jackal, page two, and, specifically, 19 paragraphs 9 through 11 of Exhibit J. 20 So, my question first to you, Mr. 21 Stevenson, is, if the Respondent could, under 22 its limited authorization, install the gyro as

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1 part of the auto pilot system, remove the gyro 2 as part of the auto pilot system, or perform 3 a functional test of the auto pilot system 4 with the directional gyro installed. Does 5 that mean that before they installed it they 6 can't look at it, they can't inspect it in any 7 shape or form, they simply have to take that 8 auto pilot system and plug it into the 9 aircraft before they can test it or inspect it 10 any way, or does it mean something else? 11 

### MR. STEVENSON: By 

### a legal 12 definitionof inspect, that is exactly what it 13 means. They can inspect it in a colloquial 14 sense, or if there is a prohibitionon picking 15 it up and looking at it, and they may 16 determine that there it may be that it 17 comes in as an obvious flaw, like we know this 18 isn't going to work, and they send it off. 19 That's not the same thing legally as 2

### o performinga formal inspectionand approval of 21 something that we are trying to service. 22 But, as far as, actually,

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1 

### with the naked eye, where do you point me to 2 to support the argument that the Respondent 3 

### violated the regulation by doing what they 4 call their fundamental rudimentary, Level 1 5 

### inspection? 6 

### MR. STEVENSON: 

### By my 7 

### understanding, perhaps, opposingCounsel will 8 

### have to defer it, my understanding of what 9 

### they were saying when they were referring to 10 

### that Level 1' 

### fundamental rudimentary 11 

### inspection, I thought that they were referring 12 

### to the same thing that I was, which is, put it 13 

### in the auto pilot and then turn on the auto 14 

### pilot and see if the auto pilot was working, 15 

### because they are authorized to do an 16 inspection of the auto pilot. 17 If they meant something else, then 18 I don't know what I would point to in the FAR, 19 as I would point to in the adopted inspection, 20 they are doing an inspection other than that, 21 

### an actual inspectionof the gyro. They are not 22 authorized to do things with the gyro. They

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1 

### out, and that, in fact, no repair was done, 2 but that instead only an inspection had 3 occurred. 4 

### In those assumptions, can you 5 

### identify, in the evidence that's presented 6 before the court, where it would say, or where 7 I could find material that's on point, that 8 says that the type of inspectionthat was done 9 on or about December 22, 2011, was part of the 10 

### authorization that your client had, and that 11 it involved the entire auto pilot system, as 12 opposed to just this gyro. 13 

### MR. FARUQUI: Okay. For one thing, 14 in the affidavit of Charles Hunt, I think we 15 have an overview of what they described as 16 what happened there. They state that all they 17 did was a rudimentary, Level 1 functional 18 test, which is to flip the switch on and see 19 if it's doing what it's supposed to do. And, 20 

### that's part of the investigation the 21 inspection of the auto pilot. 22 They had also

-- the Respondent

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### 1 had also said the same thing in its response 2 to the Letter of Investigation, and let me 3 

### double check if that was part of the 4 

### Government's exhibits. 5 

### JUDGE SULLIVAN: It was, but let's 6 

### stay with Mr. Hunt's affidavit for just a 7 

### moment, before we go to a different exhibit. 8 

### MR. FARUQUI: Sure. All right. 9 

### JUDGE SULLIVAN: According to Mr. 10 

### Hunt's affidavit, on page one of the four page 11 

### affidavit, in paragraph three, Mr. Hunt 12 

### identified the gyro very specifically as 13 

### component of the auto pilot. 14 

### And then on page two of the four15 

### page affidavit, he indicates that, in 16 paragraph nine, that the gyro was placed in 17 

### storage. He does not state that the whole 18 auto pilot system was placed in storage. 19 

### And, I'm wondering if there was 20 some type of dis-assembling from the auto 21 

### pilot system that leads him to talk about that 22 so specifically, because if Mr. McGlen's

NEAL R. GROSS (202) 234-4433 COURT REPORTERS ANDTRANSCRIBERS 1323 RHODE ISLANDAVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com42 1 declaration, which was submitted by the FAA 2 under paragraph

-- or, under Exhibit J, is 3 uncontested, and the Respondent agrees that 4 there is only a limitation of system 5 inspection, as Mr. McGlen talks about on page 6 two, paragraph 11, of his declaration, then it 7 would seem to me that we are talking about the 8 gyro as a component that is not separated from 9 any part of the auto pilot system. 10 If Mr. McGlen is incorrect in that 11 assertion, the Respondent needs to show me how 12 he is incorrect. If the Respondent agrees 13 with that assertion, then Mr. Hunt's 14 declaration, or affidavit, appears to be 15 inconsistent with that position. 16 And, I wanted to ask you about 17 that. 18 MR. FARUQUI: I do not know. I 19 would have to ask the client about that, 2

### o because I don't know whether when he's saying 21 the DG was placed in storage, whether he means 22 just the component itself or the entire auto

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### 1 pilot unit. It did not occur to me that that 2 would be a question, at the time that I was 3 

### working with Mr. Hunt on drafting the 4 affidavit. 5 

### JUDGE SULLIVAN: Okay. The reason 6 I ask is because he distinguishes, he being 7 Mr. Hunt, distinguishes, on page one of his 8 affidavit, between the auto pilot system he 9 

### refers to as the auto pilot, and the 10 directional gyro, which he then refers to as 11 a component of the auto pilot. 12 And so, it may be that I'm going 13 to add to your list of supplementalmaterials. 14 You were going to route me to one of the FAA 15 exhibits, and I think it was probably Exhibit 16 G, as in George, the response by Mr. Hunt and 17 his associate to the FAA's allegations, is 18 that correct? 19 MR. FARUQUI: Yes, I believe so. 20 

### JUDGE SULLIVAN: What would you 21 like to tell me about that? 22 MR. FARUQUI: Well, he describes

--

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1 

### theRespondentdescribes, generally, that they 2 performed the services on the KCS-55 in 3 

### connectionwith their limitedair frame rating 4 

### when repairing auto pilot systems. Okay. 5 

### And then, the SSI component is a 6 

### part of their capabilities list, and, 7 

### normally, you know, contract -- anything they 8 are not qualifiedto do service for to try and 9 instrument. 10 

### So, from the start they had said 11 

### consistently that any gyro work that, 12 specifically, needs to be done to the gyro is 13 

### farmed out to Triumph. And then, you know, 14 

### they, generally, add there 8130 to their own 15 

### work order. 16 In the case of the KG-102A, which 17 is the directional gyro subject to this case, 18 that was inadvertently tagged as part of the 19 list of equipment being installed in the 2

### o aircraft. 21 So, you know, he's stating very 22 clearly that all they had was a paperwork

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1 error, you know, it was, in fact, whatever 2 work they were doing they were doing the 3 general work that they are authorizedto do to 4 the auto pilot. 5 So, that's the exhibit that I 6 wanted to go to, because this shows that the 7 Respondent's statements and response to the 8 Administrator has been inconsistent from the 9 beginning. 10 JUDGE SULLIVAN: Okay, thank you 11 very much. 12 Are you familiar, or do you know

- 13

- well, I'm going to withdraw that partial 14 question. Thank you. 15 Mr. Stevenson, turning to you, how 16 much time do you think you would need to 17 provide a supplemental declaration about the 18 amount of money that you are seeking as a 19 proposed penalty, and also an amended 20 complaint? 21 MR. STEVENSON: Well, let me -- let 22 me ask you, if you don't mind me asking you a

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1 

### question to make sure I understand correctly. 2 When you are saying a supplemental 3 

### declaration, do you literally mean a 4 

### declaration, or just 

### a more thorough 5 explanation by a witness, or a more thorough 6 

### explanation by pointing things out in the 7 

### exhibit? 8 

### JUDGE SULLIVAN: Your arguments are 9 

### not admitted or considered as evidence in a 10 

### summary judgment motion. So, I think you 11 

### should be submitting a declaration from a 12 

### witness, explaining why the FAA is proposing 13 this particular sanction, and how it reaches 14 that sanction level. 15 

### I appreciate your argument, but 16 again, the only things that I can consider for 17 

### summary judgment purposes is admissible 18 

### evidence. And, the Respondent needs to be 19 able to respond to that evidence in a timely 20 manner. 21 

### It seems that someone at the FAA, 22 presumptively, made this decision at some

NEAL R. GROSS (202) 234·4433 COURT REPORTERSAND TRANSCRIBERS 1323 RHODE ISLANDAVE.. N.W. WASHINGTON, D.C. 20005·3701 www.nealrgross.com47 1 time, and utilized this sanction guidance as 2 a guide. So, it would be very helpful if you 3 could find that person, or an individual who 4 is capable of making that kind of statement on 5 your client's behalf. 6 MR. STEVENSON: Thank you, Your 7 Honor. 8 I believe I would be able to get 9 that back to you by some time during the week 10 of April 28th. I would normally say something 11 sooner, that I could get something sooner, but 12 I don't think I can get it this week, and as 13 Your Honor is aware we have a hearing all next 14 week in a different case, and so I will not be 15 able to get anything done on this during that 16 week. 17 JUDGE SULLIVAN: Let me just double 18 check our time line for this. Okay. 19 Mr. Faruqui, if you received that 20 declaration on or before the 28th of April, 21 2014, would you be able to submit a response, 22 any type of responsive evidence to that

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### 1 material, on or before May**~?** 2 

### MR. FARUQUI: Let me see, how much 3 

### time difference that would be, about three 4 

### days. 5 

### JUDGE SULLIVAN: Well, I'm looking 6 

### at it, I know that you already had a heads up, 7 

### essentially, because you talked about it. 8 

### MR. FARUQUI: Right. 9 

### JUDGE SULLIVAN: And so, I want to 10 

### make sure that I give you a little bit of time 11 

### to respond, and also a time to come back. We 12 are going set a second conference in the event 13 

### that I have further questions, or we need to 14 

### delve into the alternate pleadings, which we 15 

### haven't talked about at all today. 16 

### MR. FARUQUI: Okay. In my 17 response, am I simply responding to their 18 evidence, and then making arguments, or am I 19 also required to provide evidence that would 20 be in favor of the Respondent? 21 JUDGE SULLIVAN: Yes, essentially, 22 there's a dearth of evidentiary material, in

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1 this court's opinion, about the proposed 2 penalty. I have a motion before me for 3 summaryjudgment that seeks dispositiverelief 4 on all the violations alleged, and on the 5 proposed penalty. 6 MR. FARUQUI: Right. 7 JUDGE SULLIVAN: Currently, I have 8 Exhibit I, as in igloo, giving me a sampling 9 of what appears to be the relevant material 10 that is used by the FAA internally for 11 sanction guidance. 12 I've asked the FAA to provide a 13 supplemental declaration that would be 14 admittedor admissible into evidence about how 15 it reached the $7,150 proposed amount, and why 16 it thinks that it's the most appropriate 17 amount. 18 In response to Exhibit I, the 19 Respondent has not presented any evidence. 20 It's difficult to look at this particular 21 material, if you don't know anything about 22 sanction guidance policies, and figure it out

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1 on your own. 2 So, we went through earlier this 3 afternoon a little primer, I think, about how 4 to look at it and how to read it. 5 The FAA is going to get a deadline 6 for supplementing their material so that 7 there's a declaration in addition to Exhibit 8 I that talks, specifically, about the proposed 9 penalty of $7,150. 10 I want you to be able to respond 11 to that, if you so choose. You may get the 12 material and look at it, and say, well, I 13 don't have any response. Or, you may get the 14 material and look at it, review Exhibit I more 15 thoroughlywith your client, and then say, I'm 16 going to suggest that you submit a declaration 17 or certain documentary material that either 18 agrees with the $7,150 amount or that 19 disagrees with it. 20 And, if we disagree, and we want 21 to seek a penalty such as the

-- I think it 22 was $935 amount that's contained in your

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### 1 second amended answer, then there has to be 2 some explanation as to how you have reached 3 

### that proposed amount in contrast to the 4 

### proposal of $7,150 

### that the FAA is proposing. 5 

### So, ideally, you want to respond 6 

### to the evidence that the FAA is going to 7 

### submit, and that response can also include an 8 

### alternate proposal for a lesser amount, if 9 

### that's what you think you can prove. 10 

### Does that make sense? 11 

### MR. FARUQUI: Yes, it makes sense. 12 

### My concern is that, aside from using the FAA's 13 

### pleadings itself as a piece of evidence, I'm 14 

### concerned that outside of that it would be 15 

### very difficult to procure, for example, an 16 

### expert witness, if they exist, for, you know, 17 

### reading and interpreting the tables in light 18 

### of the evidence. 19 

### JUDGE SULLIVAN: I think I'm 2

### o sorry to interrupt you -- I think it would be 21 

### helpful if you could at least read with your 22 client some of this material in Exhibit I.

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### 52 1 For example, on page 7-4, in paragraph four, 2 there are sections about mitigating or 3 

### aggravating factors and elements. I think 4 that you could look at that and see whether 5 anything is of interest or applicable to your 6 client, in terms of making a response. 7 MR. FARUQUI: Okay. 8 JUDGE SULLIVAN: You certainly can 9 talk to your client about where that proposed 10 amount of $935 comes from, how your client has 11 come to a belief that that's an appropriate 12 amount, and whether or not you have any 13 particular grounds to support that amount. 14 I certainly have had people come 15 before me and just say, you know, I think it 16 shouldbe $600, because that just sounds right 17 to me. And, I don't dispute that that might 18 sound right to them, but that's not the basis 19 upon which I can make ruling, if that makes 20 sense. 21 MR. FARUQUI: Sure. 22 JUDGE SULLIVAN: So, there needs to

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### 1 be some response to the material filed in a 2 summary judgment proceeding. If there's no 3 

### response, I take it as undisputed. 4 

### MR. FARUQUI: Okay. 5 

### JUDGE SULLIVAN: And, your client 6 

### can respond or choose not to respond. But, if 7 

### the client responds, then I would recommend 8 

### the client have some good reasons in support 9 

### of whatever their response is. 10 

### So, let's talk about a time 11 period. If I direct the FAA to file materials 12 and supplement the record by February

-- not 13 February

-- April 29, 2014, and I look at my 14 calendar for a moment, and I say to the 15 Respondent, for example, file supplemental 16 materials no later than May 6, 

### 2014, I can set 17 thismatterbackonmycalendarfor, say, May 18 S'h 

### or May 9'h, 

### which is before our May 16, 

### 19 2014 deadline for exchanging witnesses and 20 exhibits. 21 Mr. Faruqui? 22 MR. FARUQUI: I think I could agree

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1 

### to -- I can agree to May gth. 

### That would be 2 more workable for me. 3 

### JUDGE SULLIVAN: I 'm not talking 4 about May gth 

### for your response, I'm talking 5 

### about resetting the matter on my calendar. 6 

### MR. FARUQUI: Oh, I'm sorry. 7 

### JUDGE SULLIVAN: I was suggesting 8 

### to you that I give you until May 6, 2014, 9 

### which is a week after the FAA files its 10 

### supplemental material, and that I 

### was 11 

### suggestingto the parties that we reconvene on 12 

### May gth 

### or May gth 

### by telephone to answer any 13 

### further questions the court has, and for the 14 

### parties to make a more complete argument on 15 

### behalf of their clients, regardingthis motion 16 

### as a whole. 17 

### MR. FARUQUI: Okay. 18 

### JUDGE SULLIVAN: Okay. Mr. 19 

### Stevenson, let me turn to you. Do you have 20 any black-out times on either May gth 

### or May 21 gth? 

### 22 MR. STEVENSON: No, Your Honor.

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### 55

1 

### JUDGE SULLIVAN: Okay. Mr. 2 Faruqui, do you have any black-out times on 3 

### either May ffh 

### or May Cfh? 4 

### MR. FARUQUI: The only issue with 5 May gth 

### is that on Friday's I skip lunch and 6 

### then go to Friday prayer at 1:30, and then I'm 7 

### back in the office by around 3:00-3:30-ish. 8 

### JUDGE SULLIVAN: Would you have the 9 

### morning open? 10 

### MR. FARUQUI: I have morning open, 11 

### yes. 12 

### JUDGE SULLIVAN: Okay. Maybe we 13 

### can, you know, just make sure that there's no 14 

### interruption in your schedule. 15 

### And, let's try for Fridaymorning. 16 

### What time would you need to leave the office, 17 

### Mr. Faruqui? 18 

### MR. FARUQUI: I leave the office 19 

### for prayer around 1:15. 20 

### JUDGE SULLIVAN: Okay. Well, how 21 

### about if we do this from 9:30 to 11:00 at the 22 latest, would that work for you, Mr.

NEAL R. GROSS (202) 234-4433 COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLANDAVE., N.W WASHINGTON, D.C. 20005-3701 www.nealrgross.com56 

### 1 Stevenson? 2 MR. STEVENSON: Yes, Your Honor. 3 

### JUDGE SULLIVAN: Okay. And, Mr. 4 

### Faruqui? 5 

### MR. FARUQUI: Yes, Your Honor. 6 

### JUDGE SULLIVAN: Okay. So, we'll 7 

### reconvene on Friday, May 9, 2014, 

### at 9:30 8 

### Eastern Time. And then, I will direct the FAA 9 

### to file its supplemental materials no later 10 

### than April 29, 2014, 

### and the Respondent to 11 

### file its materials no later than May 6, 2014, 12 

### and then we can reconvene on May 9, 2014. 13 

### Mr. Faruqui, I'm just going to ask 14 

### you to be prepared to answer this question 15 

### when we return. Your client has given a 16 

### variety of different connotations or 17 

### descriptions to what it did in terms of 18 

### inspection. At some point it says the gyro 19 

### was inspected, other times it was a 

### 20 rudimentary inspection. Other times it talks 21 

### about doing a functional check, and it talks 22 about doing an externalnaked-eyeexamination,

NEAL R. GROSS (202) 234-4433 COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com57 

### 1 or powering it up, or doing a functional test. 2 And, it's really unclear to this court what 3 all that means. 4 And then, I think that's the only 5 thing I would want to point out to the parties 6 at this time. 7 

### So, with that, Mr. Stevenson, is 8 there anything else that we need to address 9 for your client today before we close? 10 MR. STEVENSON: The only thing that 11 I could comment on were some of the matters 12 raised by opposing Counsel when you were 13 asking him some questions, and his comments 14 about what the documents said. I can do that 15 if you'd like, but it sounds like that may be 16 more appropriate for next time. 17 JUDGE SULLIVAN: I think next time 18 would be better. 19 MR. STEVENSON: Okay. 20 JUDGE SULLIVAN: Yes. 21 

### Mr. Faruqui, anything else that 22 you would like to address on behalf of your

NEALR. GROSS (202) 234-4433 COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com58 

### 1 client, before we close? 2 

### MR. FARUQUI: At this time, no. 3 

### JUDGE SULLIVAN: Okay. Then I will 4 

### thank you both very much for your presence 5 today and for your patience. 6 It appears right now our business 7 

### is complete. I'll look forward to the 8 supplemental materials, and I'll issue an 9 order about that no later than tomorrow. 10 

### And, I want to make sure I have 11 

### everybody's fax number. So, let me just 12 double check that before we go off the record. 13 

### Mr. Faruqui, do you have a fax 14 number? I don't seem to have one for you. 15 

### MR. FARUQUI: Yes. 16 

### JUDGE SULLIVAN: Okay. 17 

### MR. FARUQUI: 954

-- 18 

### JUDGE SULLIVAN: 954 19 

### MR. FARUQUI: 524

-- 20 

### JUDGE SULLIVAN:

-- 524 21 MR. FARUQUI:

-- 5143. 22 

### JUDGE SULLIVAN:

-- 5143.

NEAL R. GROSS (202) 234-4433 COURT REPORTERS ANDTRANSCRIBERS 1323 RHODE ISLANDAVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com59

1 

### And, what is your phone number of 2 record, sir? 3 

### MR. FARUQUI: 954-527-0002. 4 

### JUDGE SULLIVAN: Okay. I'll repeat 5 

### that. The telephone is 954-527-0002, is that 6 

### correct? 7 

### MR. FARUQUI: Yes. 8 

### JUDGE SULLIVAN: Okay. Then it 9 

### appears our business today is complete. Thank 10 

### you again, everyone. 11 

### We can go off the record, and I 12 wish you all a good day. 13 

### MR. STEVENSON: Thank you very 14 

### much, Your Honor. 15 

### JUDGE SULLIVAN: Thank you. Bye16 bye. 17 

### (Whereupon, the above-entitled 18 matter was concluded at 2:49p.m.) 19 20 

### 21 22

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## ;68 C E R T I F I C A T E

This is to certify that the foregoing transcript

In the matter of: Avionics Masters, Inc.

Before: DOT Office of Hearings

Date: 04-15-2014

Place: Conference Call

was duly recorded and accurately transcribed under my direction; further, that said transcript is a true and accurate record of the proceedings.

Court Reporter

(202) 2344433 NEAL R. GROSS COURT REPORTERSANDTRANSCRIBERS 1323 RHODE ISLANDAVE., N.W. WASHINGTON, D.C. 20005·3701 www.nealrgross.com