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ORIGINAL 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, DC 

4 In the Matter of, 

5 WORLDWIDE AIRCRAFT 

SERVICES, INC., 

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Docket No. FAA-2013-0045 

Case No. 2009S0150216 

Respondent. 

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__________________________ / 

DATE: 

TIME: 

PLACE: 

REPORTED BY: 

HEARING, VOLUME II 

March 6, 2014 

8:30a.m. - 4:35p.m. 

George E. Edgecomb Courthouse 

800 East Twiggs Street, Room 53A 

Tampa, Florida 33602 

Laura Morales, FPR 

Notary Public, State of Florida at 

Large 

Pages 1 to 198 

20 The above-entitled cause came on for hearing 

21 before the Honorable J.E. Sullivan, Administrative 

22 Law Judge, pursuant to notice. 

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25 
Hearing 

Worldwide Aircraft Services, Inc. 

1 APPEARANCES: 

2 U.S. DEPARTMENT OF TRANSPORTATION 

J.E. SULLIVAN U.S. ADMINISTRATIVE LAW JUDGE 

3 1200 New Jersey Avenue, S.E. (Ell-310) 

Washington, DC 20590 

4 Phone: 202-366-6941 

5 

6 APPEARANCES FOR THE AGENCY 

7 OFFICE OF THE REGIONAL COUNSEL SOUTHERN REGION 

BY: WILLIAM VINES, ESQUIRE 

8 P.O. Box 20636 

Atlanta, Georgia 30320 

9 Phone: 404-305-5200 

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11 APPEARANCES FOR THE RESPONDENT 

12 WORLDWIDE AIRCRAFT SERVICES, INC. 

BY: MICHAEL HONEYCUTT 

13 2561 Rescue Way 

Brooksville, Florida 34604 

14 Phone: 352-796-2540 

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16 ALSO PRESENT: 

17 Paul Bowen 

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I N D E X (Continued) 

Direct Cross Redirect 

Witnesses for the Agency: 

Robert Donahue 15 26 

Michael Singleton 62 108 132 

Martha Farmer 152 

Witnesses for the Respondent: 

Lisa Aleski 145 149 151 

E X H I B I T S (Continued) 

No. 

C-7A, B 

Description 

Inspector Statement of Fact 

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3/6/2014 

Recross 

137 

Page 

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P R 0 C E E D I N G S 

THE COURT: We're on the record in the 

matter of Worldwide Aircraft Services, Inc. This 

is Docket No. FAA-2013-0045. We've reconvened on 

Thursday, March 6, 2014 for a second day of 

hearing in this case. 

The FAA is still represented by 

Mr. Vines who is seated at the counsel table with 

his assistant, Ms. farmer. The Respondent is 

represented by its president and owner, Mr. 

Honeycutt, who is assisted at counsel table by 

Mr. Bowen. 

Also present in the hearing room is 

Mr. Donahue, the witness, who was on the stand 

when we recessed yesterday evening, as well as 

Mr. Singleton who has been listening to the 

testimony in these proceedings since their 

inception. 

Mr. Vines, we had a very brief 

conversation with all parties present prior to 

going on the record, and let's recap what 

information was shared. 

As I understand it, you and Ms. Farmer 

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met with Mr. Honeycutt after the Court formally 

recessed yesterday, and there was a one-hour 

interview informally regarding Ms. Farmer's 

testimony. 

MR. VINES: Judge, the parties did 

meet. The Respondent did discuss or was afforded 

the opportunity to ask Ms. Farmer any questions 

that he had. As the Court granted them an hour 

to do so, I believe it took 15 to 20 minutes of 

that hour to meet and discuss Ms. Farmer's 

testimony with her. 

THE COURT: Okay. And then did you 

have a chance to share Mr. Donahue's testimony 

regarding his investigation once he stopped his 

meeting with Mr. Honeycutt and was talking about 

doing further investigation that had not been in 

his notes? 

MR. VINES: No, Judge, we did not. The 

reason for that is, first of all, the Respondent 

did not request to have that discussion. Second 

of all, it is the Administrator's position that 

the Administrator will not seek any further 

testimony from Inspector Donahue other than 

what's already been presented at this time or up 

until this point regarding his investigation to 

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the event as to how the GPU unit was destroyed. 

THE COURT: And is it your position 

then that that is not information that Ms. Farmer 

will be utilizing? 

MR. VINES: Yes, Judge. 

THE COURT: Okay. 

Mr. Honeycutt, do you have any 

housekeeping matters to address? 

MR. HONEYCUTT: Your Honor, just Mr. 

Singleton, requesting to be able to interview Mr. 

Singleton prior to his testimony. 

THE COURT: Okay. And let me ask you 

this, do you have any comment or response to 

Mr. Vines' statement that Mr. Donahue's testimony 

will not be presented regarding the further 

investigation he did and that type of testimony 

will not be utilized or information will not be 

utilized by Ms. Farmer regarding the assessment 

of the fine, is that satisfactory to you? 

MR. HONEYCUTT: It is, your Honor. 

THE COURT: Okay. So noted. 

Mr. Vines, do you have any objection to 

the motion in limine for a preliminary informal 

meeting by Mr. Honeycutt with your witness, Mr. 

Singleton, before he takes the stand? 

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MR. VINES: Yes, Judge. Number one, 

the Administrator does recognize that originally 

Mr. Schaefer was scheduled to testify regarding 

the information that was disclosed in the 

Administrator's exchange of exhibits and notice 

of witnesses. 

After that, the Administrator 

substituted the, excuse me, Inspector Schaefer's 

testimony with Mr. Singleton. Inspector 

Singleton is expected to testify to the same 

information that was anticipated to -- the 

Administrator anticipated to elicit from 

Inspector Schaefer. 

During that time, the Respondent did 

not seek to discuss any testimony or request 

further information from Mr. Schaefer. As a 

result, the Respondent did not request to oppose 

Mr. Schaefer and because of that, since Inspector 

Singleton's testimony is expected to be along the 

same line as Inspector Schaefer's, the 

Administrator asks that you deny the Respondent's 

motion. 

THE COURT: How is the FAA harmed by an 

informal interview of Mr. Singleton? 

MR. VINES: Judge, what mainly comes to 

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mind is the time restraint we have today, also to 

any interview I would like to participate in, and 

as a result, that would take me away from 

continuing to prep and prepare for the proceeding 

today. That is how it would harm the 

Administrator, Judge. 

THE COURT: Mr. Honeycutt, any 

response? 

MR. HONEYCUTT: Yes, ma'am. We knew 

that Mr. Schaefer was going to testify. We knew 

his background and what was expected from his 

testimony. We know nothing of Mr. Singleton's 

knowledge of this case. 

We also feel that Mr. Singleton sat 

through this case and has heard other testimony, 

and we don't know what conclusions he's drawn 

from that. Therefore, we feel that we would 

request the ability to interview Mr. Singleton 

and prepare ourself for his expected testimony. 

THE COURT: Let's talk about time, 

because I think time is of the essence as 

Mr. Vines has mentioned. 

MR. VINES: Judge, before you -- can I 

respond to his point? 

THE COURT: Yes. 

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MR. VINES: First of all, Inspector 

Singleton's resume was provided to the 

Respondent, so they are familiar with his 

background. 

As for the testimony, again I've 

already gone through that, but more importantly, 

Judge, the Respondent has the ability to 

cross-examine Mr. Singleton. 

Furthermore, Mr. Singleton, like the 

Respondent said, has been in this courtroom to 

listen to testimony and so has the Respondent. 

So based on that, Judge, again I do not feel that 

the motion should be granted. 

THE COURT: Okay. Thank you. Let's 

talk about time for just a moment because that's 

part of the Court's consideration in this 

request. 

I have talked briefly with the 

Courthouse staff. There is a possibility that 

this room could be available tomorrow. I've also 

checked my travel arrangements, and there's a 

potential for me to move some other things on my 

calendar and stay for tomorrow. 

I don't know if it is possible for 

Mr. Vines to stay for the full day, whether we 

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have the court reporter for the full day, and 

whether the witnesses could be available. It 

would seem to me that it would be far more 

efficacious for all of us if we could finish the 

trial this week as opposed to corning back and 

bifurcating it. 

So I wanted to check in with all of you 

to see if that is a possibility. If it is, I 

will affirm travel plans and see if the Court can 

be available for the whole day. Officer Brian is 

working on that and then report back to you as 

soon as possible, probably within the morning 

period of time. 

Mr. Vines, starting with you, I know 

you are traveling from out of town. You had 

mentioned to me yesterday that you were scheduled 

to fly out in the afternoon tomorrow, is it 

possible for you to extend your trip? 

MR. VINES: Judge, may I have a few 

moments, please? 

THE COURT: Sure. 

MR. VINES: Judge, I should be 

available all day tomorrow. As far as Ms. 

Farmer, she will only be available through lunch 

tomorrow. So she would probably have to leave 

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before lunch tomorrow. 

THE COURT: Well, hopefully you will be 

done with your case in chief today. 

MR. VINES: Correct. 

THE COURT: I'm really concerned about 

the Respondent's response time. So if you're 

done by noon today, that gives the Respondent 

equal time to present responsive testimony which 

he should have the right to do. 

Mr. Honeycutt, let's turn to you, would 

you be available for all day tomorrow and would 

your witnesses? 

MR. HONEYCUTT: Yes, ma'am, your Honor, 

I will be available tomorrow. The witnesses I 

need to check with, but, in particular, Ms. 

Aleski, she is a mother of two and her husband 

works two jobs. Today, for example, she needed 

to have a babysitter all day because we don't 

know exactly when I can call her. 

THE COURT: Right. 

MR. HONEYCUTT: So that could be an 

issue, but me and the majority of my witnesses 

will be available tomorrow. 

THE COURT: Okay. Thank you. Will you 

let me know some time this morning about Ms. 

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Aleski. It is possible that we can take her 

testimony this afternoon, I think, you know, kind 

of take her first as opposed to last so that she 

doesn't have to be inconvenienced tomorrow. 

Madam court reporter, I know we had 

talked yesterday about the morning time, could 

you check and see if you might be available or 

someone else from the company for the whole day? 

THE COURT REPORTER: Yes. 

THE COURT: I'll note that the court 

reporter said that she will check as well. 

What I'm going to do is, I'm going to 

reserve ruling on your motion until I can find 

out whether we have the whole day available, and 

then I'll make a ruling on that motion in limine, 

Mr. Honeycutt, because in terms of the motion, 

part of that for the Court's concern is just the 

time, whether we have the time to allow you to do 

that. 

So, Mr. Vines, anything else we need to 

address before you leap back into your case in 

chief? 

MR. VINES: Judge, yes. As I recall, 

we were on cross-examination of Inspector 

Donahue. 

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THE COURT: Correct. 

MR. VINES: The Court left open the 

Administrator's motion to admit Exhibit C-7A and 

C-78. 

THE COURT: Correct. 

MR. VINES: So at this time, I would 

move to admit that motion or renew to admit that 

exhibit. 

THE COURT: Are you finished then with 

Mr. Donahue's testimony in full? 

MR. VINES: I will likely, as a 

result -- no, I'm not. 

THE COURT: Okay. 

We had essentially, as I understand it, 

we have saved the portion of his testimony 

regarding whether he had gone over to American, 

what else he had done over there in his 

investigation for today, because you had asserted 

that that was going to be part of the evidence 

that Ms. Farmer was going to rely upon in terms 

of her testimony regarding the proposed civil 

penalty. As a result, we left into 

cross-examination of Mr. Donahue on all of the 

other remaining matters. 

If you're withdrawing the testimony 

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from Mr. Donahue about his further investigation, 

I'm a little unclear as to what you're talking 

about now in terms of further direct testimony 

from him, what are you talking about? 

MR. VINES: Well, I would likely have 

redirect based on --

THE COURT: Okay. So this is just 

redirect of the cross? 

MR. VINES: Yes, Judge. 

THE COURT: Okay. Well that's fine. 

Mr. Honeycutt, are you ready to proceed 

with your cross-examination of Mr. Donahue? 

MR. HONEYCUTT: Yes, ma'am. 

THE COURT: Mr. Donahue, I see you are 

in the courtroom, could you please re approach 

and come up to the witness stand. 

THE WITNESS: Yes, ma'am. 

MR. VINES: Judge, for the record, are 

you denying my motion to admit Exhibit C-7A and 

B? 

THE COURT: I'm sorry. I'm going to 

reserve that until the redirect is over just 

because of what we talked about yesterday. 

Mr. Donahue, you were previously sworn 

yesterday, and you are still under oath. 

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THE WITNESS: Yes, ma'am. 

THE COURT: Thank you very much. 

Mr. Honeycutt, do you have any further 

cross-examination of this witness? 

MR. HONEYCUTT: Yes, ma'am. 

CROSS-EXAMINATION 

BY MR. HONEYCUTT: 

Q. Mr. Donahue, the personal notes you had yesterday 

11 of Mr. Price, do you have that with you? 

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A. I do. 

MR. HONEYCUTT: May I see that, your 

Honor? 

THE COURT: Were those not shared with 

you yesterday? 

MR. HONEYCUTT: I was going to read 

from it. I don't have it memorized in front of 

me. I was going to read the statement of 

Mr. Price. 

THE COURT: Do you have those notes 

with you, Mr. Donahue? 

THE WITNESS: Yes, I do. 

THE COURT: Can you produce them for 

Mr. Honeycutt? 

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THE WITNESS: Yes, ma'am. 

THE COURT: I'll note that Mr. Donahue 

is leaving the witness chair in order to obtain 

his notes and provide a copy of the pertinent 

notes that he took regarding a conversation that 

he had with Mr. Price that was discussed briefly 

today. 

Mr. Donahue has reseated himself in the 

witness chair, and I believe he is going to 

provide those notes to Mr. Honeycutt. 

THE WITNESS: I have the notes, your 

Honor. 

THE COURT: Okay. The notes are 

available. 

Mr. Honeycutt, will you approach the 

witness and obtain those. 

MR. HONEYCUTT: Yes. 

THE COURT: I'll note Mr. Honeycutt has 

19 been handed a copy of some notes. 

20 Mr. Honeycutt, you are welcome to 

21 continue your cross-examination. 

22 BY MR. HONEYCUTT: 

23 Q. Mr. Donahue, these inspector statement of facts, 

24 it is your statement, referencing your conversation 

25 with Eric Price, the First Officer? 

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A. 

Q. 

That's correct. 

You asked Mr. -- No. 5 here on your statement, I 

3 asked if he felt any unusual control pressure in 

4 excessive power requirements for the taxi or tugging 

5 on the aircraft during taxi or take off. He 

6 responded, no unusual feelings. I asked if he thought 

7 GPU had been still attached during the taxi or take 

8 off, he said, ''No, it did not feel any different." 

9 THE COURT: I'm going to stop you, do 

10 you have a question of this witness regarding 

11 those notes so far? 

12 BY MR. HONEYCUTT: 

13 Q. The statement is, does he feel that Mr. Price was 

14 telling the truth and was honest and cooperative with 

15 him? 

16 A. It is my belief that he was clear in his intent, 

17 and he was honest and forthright in his response. 

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THE COURT: You may proceed. 

MR. HONEYCUTT: Again, this statement 

is that in Marsh Harbour he was not informed of 

any issue with the GPU, nor was he informed of 

the conversation between me and Mr. Plas, and 

then he asked for a detailed statement. 

So that was my question for him, your 

Honor, for this witness. 

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THE COURT: Well, did you want this 

witness to confirm that latter portion of what 

you just read? If so, you need to address that 

4 to Mr. Donahue. 

5 BY MR. HONEYCUTT: 

6 Q. So it also your testimony, Mr. Donahue, that this 

7 is a true statement from Mr. Plas and that you feel 

8 that he was honest in the statement of not being 

9 informed of the GPU incident or receptacle in Marsh 

10 Harbour? 

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A. Yes, I do. 

THE COURT: Thank you. 

13 BY MR. HONEYCUTT: 

14 Q. Mr. Donahue, do you happen to have, in your file 

15 or in the EIR, the GPU, any pictures of the GPU in 

16 reference to the alleged incident? 

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A. I do. 

MR. HONEYCUTT: May I see those, your 

Honor? Can I direct the witness to present 

those? 

THE COURT: Yes, you may ask if he can 

22 produce them. 

23 BY MR. HONEYCUTT: 

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Q. 

A. 

Can you produce them for us? 

I can. 

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Q. Would you, please. 

THE COURT: Do you have them with you, 

Mr. Donahue? 

THE WITNESS: I do. 

THE COURT: Please produce them, 

please. 

THE WITNESS: I have them, your Honor. 

THE COURT: Thank you. 

Mr. Honeycutt, there appears to be 

pictures that are available for you. 

MR. HONEYCUTT: May I approach? 

THE COURT: You may. 

MR. HONEYCUTT: Thank you. 

THE COURT: I'll note that Mr. Donahue 

15 has handed Mr. Honeycutt some materials, and Mr. 

16 Honeycutt is now reviewing it. 

17 BY MR. HONEYCUTT: 

18 Q. Mr. Donahue, this document that I'm reading, it 

19 looks like an Aviation Ground Equipment Corporation 

20 Manual referenced in a Hobart Ground Power Unit, you 

21 would agree with that? 

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A. 

Q. 

Correct. 

And is it your testimony that this is the type of 

24 equipment that is alleged to have been attached to 

25 90LJ during the alleged departure with it attached? 

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A. 

Q. 

I do. 

And if I'm reading this correctly, you have 

3 highlighted on this the weight of the DFS400 Model to 

4 be 728 pounds? 

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6 

A. 

Q. 

That would be what the statistics show on that. 

Again, your testimony based on the Hobart piece 

7 of equipment or this data sheet on the piece of 

8 equipment sheet, is that the alleged equipment that 

9 was attached to the aircraft that was taxied out and 

10 apparently taken off with weighs approximately, based 

11 on this piece of paper, 728 pounds? 

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A. I did not have that document at the time that I 

did the investigations. I estimated the weight at 

different than 700. In fact, I only used 

15 approximately 200-to-300 pounds in my initial estimate 

16 of the weight of the device as I did not know the type 

17 nor design. 

18 The research, subsequent to the investigation, 

19 revealed that document, and then it was presented to 

20 you, as I recall, but I have no documentation to that 

21 effect, that I did bring that to your attention, and 

22 it was confirmed that this was similar equipment that 

23 was used, specifically addressed by you, that it was 

24 on wheels. 

25 I noted that to your attention, and you confirmed 

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1 to me yes, that is the similar equipment. It did not 

2 specify the make and model. 

3 Q. The two pieces of equipment that is referenced 

4 here is a 15KVA Portable Configuration and a 30KVA 

5 Stationary Configuration and the weight again on the 

6 15K is 728 pounds and a 30K, which would be 

7 stationary, would be 1,124 pounds. 

8 So it is your testimony that the unit that was 

9 allegedly attached to the aircraft that taxied out 

10 with it attached and took off with it attached is in 

11 the category of somewhere over 700 pounds? 

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A. That would be a fair assessment. 

THE COURT: Just so we're clear, 

there's been an agreement that there was a GPU 

attached. So it is not an allegation at this 

point? 

MR. HONEYCUTT: No. 

THE COURT: It is my understanding that 

that was part of the admissions. 

MR. HONEYCUTT: The allegation, your 

Honor, of taxied out and taking off. 

THE COURT: Okay. 

MR. HONEYCUTT: There is no dispute of 

the aircraft using the initial GPU for start. 

THE COURT: Okay. Thank you. 

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MR. HONEYCUTT: I'll give this back to 

the witness, your Honor. 

THE COURT: You may. Thank you. 

4 I'll note that Mr. Honeycutt is 

5 approaching the witness again with the pictures 

6 of the GPU. 

7 BY MR. HONEYCUTT: 

8 Q. Also, Mr. Donahue, the hot-line complaint, I'd 

9 like to go over that, do you have notes on the 

10 hot-line complaint? 

11 A. Can you be more specific? 

12 Q. How did the hot-line complaint come to you, how 

13 were you notified of the allegations alleged during 

14 the hot-line complaint, is it a written statement, an 

15 e-mail, a phone call, a hand-written note, how do you 

16 get the information? 

17 A. Initially, information arrives at the office in 

18 two manners, one a phone conversation. At that time, 

19 the inspector that received the phone communication 

20 pulls out an office form and completes it. The color 

21 is green. 

22 Once the information is taken down as accurately 

23 as portrayed with as much information as possible, the 

24 inspector then would submit this information directly 

25 to the front-line manager. 

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1 The front-line manager would then make the 

2 assignment going to the administrative-staff assistant 

3 up front who would make the appropriate assignment to 

4 an inspector for review. The property or the --

5 sometimes the complaint comes in in writing, and it is 

6 sometimes either anonymous or with a name behind it. 

7 In that case, the inspector is not directly 

8 involved, it goes directly to management. The 

9 front-line manager would make a selection of an 

10 appropriate inspector. The documentation would then 

11 be forwarded to the administrative-staff assistant in 

12 front for logging in and given to the inspector for 

13 the reviews. 

14 Q. Can you get specific to this hot-line complaint, 

15 how did it come into the office? 

16 

17 

A. This specific one came in in a verbal form on a 

green sheet. It was assigned to me with a yellow 

18 sheet, which is the actual office assistant document 

19 that is provided to the inspector. 

20 The information contained in there was nothing 

21 more than a allegation about a aircraft had taxied 

22 from a ramp with a GPO, ground-power unit attached, 

23 taxied and departed the aircraft, the actual runway 

24 with it still attached. That was the information I 

25 used to facilitate this. 

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1 Q. The green sheet, do you have a copy of the green 

2 sheet? 

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A. 

Q. 

A. 

Q. 

A. 

Q. 

A. 

I do not. 

Do you have a copy of your yellow sheet? 

I do not. 

Is that in a file somewhere? 

It was. 

What file would that be in? 

The office file systems, there is a mandatory 

10 purge of two years. 

11 Q. Office file. Would it be transferred into the 

12 EIR file? 

13 A. No, it was not an enforcement case from my end, 

14 it was strictly an --

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Q. 

A. 

Q. 

Investigation? 

-- evaluation and investigation of the situation. 

Again, yesterday you said your testimony was, I 

18 believe was that your conclusion that you believe the 

19 aircraft taxied out and took off with the GPU 

20 attached? 

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A. 

Q. 

That is correct. 

Okay. During your investigation when you came to 

23 Worldwide JET I.C.U. 's hangar, base of operation with 

24 Mr. Schaefer, did you see 90LJ? 

25 A. I did not. 

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Q. 

A. 

Q. 

You didn't? 

Not that I recall. 

Okay. And so you can't testify to Mr. Schaefer, 

4 but did Mr. Schaefer make a statement to you that he 

5 saw 90LJ? 

6 A. The topic did not come up between Mr. Schaefer 

7 and myself. 

8 Q. So it is your testimony that you've never seen 

9 any damage on 90LJ? 

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A. 

Q. 

I did not physically see the aircraft. 

So therefore you did not see any damage to the 

12 aircraft? 

13 A. If I did not see the aircraft, I would not be 

14 able to make an assessment of damage. 

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Q. I just want to be clear. I'm not trying to be 

facetious, I apologize. I just wanted to make sure 

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MR. HONEYCUTT: I don't think I have 

anything else for Mr. Donahue. 

THE COURT: Thank you, Mr. Honeycutt. 

Mr. Vines, any redirect? 

MR. VINES: Judge, just one question 

for Mr. Donahue. 

- - -

REDIRECT EXAMINATION 

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2 BY MR. VINES: 

3 Q. I wanted to ask if you recall or if you are able 

4 to testify how many aircrafts the Respondent had on 

5 the Certificate in the year 2009 that the Respondent 

6 was authorized to use in 2009? 

7 A. In the --

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MR. HONEYCUTT: Objection, that is 

beyond the scope of relevance. 

THE COURT: There's been an objection 

that it is beyond the scope. Do you have a 

response? 

MR. VINES: Judge, the Respondent was 

asking about this particular aircraft or N90LJ. 

So I was just following up with the inspector as 

to how many, including the N90LJ, were listed on 

the Respondent's Certificate for use under Part 

135 Operations. 

THE COURT: Thank you. The objection 

is sustained on both grounds. It is beyond the 

scope, and there is no relevance at this point. 

There's been a renewed request for a 

motion of the FAA to move to admit Exhibit C-7A 

and B. 

Mr. Honeycutt, any response? 

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MR. HONEYCUTT: One second, your Honor. 

No objection to the admittance, your Honor. 

THE COURT: Exhibit C-7A and B is 

hereby admitted. 

(Whereupon, the documents were marked as C-7A 

and C-7B for identification and admitted into 

evidence.) 

THE COURT: Mr. Donahue, thank you very 

much for your testimony. 

complete. 

It appears to be 

THE WITNESS: Thank you, your Honor. 

MR. VINES: Judge, for clarification, I 

just want to make sure that you entered into the 

record C-7A and C-78 were admitted. I' rn not sure 

what you said. 

THE COURT: Yes, I just admitted 

Exhibit C-7A and B because you had moved to admit 

the evidence again this morning, and I reserved 

it until the conclusion of Mr. Donahue's case. 

So, Mr. Donahue, thank you, and you are 

hereby excused. 

THE WITNESS: Thank you, your Honor. 

THE COURT: Mr. Vines. 

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MR. VINES: The Administrator calls 

Inspector Michael Singleton. 

THE COURT: Okay. Since Mr. Singleton 

is next on the list, it looks like I need to take 

a quick break, and, Mr. Honeycutt, if you could 

check in with Ms. Aleski please about her 

availability either this afternoon and or 

potentially tomorrow morning. 

Then I'll check in with the officer 

regarding the potential of having the courtroom 

for tomorrow day, and I'll also check with the 

court reporter, and then I'll be able to make a 

ruling on the Respondent's motion for a brief 

informal discussion with Mr. Singleton. So why 

don't we take a 10-minute recess and reconvene 

back in 10 minutes. 

We can go off the record at this time. 

(Whereupon, a brief recess was taken.) 

THE COURT: We're back on the record in 

the matter of Worldwide Aircraft Services, Inc. 

This is Docket No. FAA-2013-0045. 

We've reconvened after approximately a 

10-minute recess. All parties previously 

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identified have returned to the hearing room. 

I'm going to start with you, Mr. 

Honeycutt, have you had a chance to talk with 

your witnesses and is everybody available 

tomorrow if needed? 

MR. HONEYCUTT: Ms. Aleski would not be 

available tomorrow, only today, but the other 

witnesses will be available. 

THE COURT: Okay. Great. 

So it looks like we have a potential 

for coming into the Court tomorrow. Officer 

Brian advised me during the brief break that the 

courtroom would be available to us. 

Madam court reporter, I need to check 

with you, what is your availability? 

THE COURT REPORTER: I'm available. 

THE COURT: The court reporter is also 

available. So we have a little bit of time. 

I'm going to grant the Respondent's 

motion for a brief time to interview Mr. 

Singleton before going on the record. I'm not 

going to grant a full hour. I don't think we 

have that amount of time, but 30 minutes I think 

would be helpful. I don't see that it is a 

prejudice to the FAA. 

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I understand, Mr. Vines, that having a 

chance to do preparation is a preferred use of 

your time, but your a seasoned attorney from what 

I gather, and I think you have the ability to 

roll with a little bit of flexibility in this 

matter. 

So I will note that it is about 9:25 

now. I'll grant up to 30 minutes for a brief 

interview. 

Mr. Vines, you are welcome to be 

present during Mr. Singleton's interview with Mr. 

Honeycutt. 

Mr. Honeycutt, you are welcome to have 

your assistant with you as Mr. Vines may have 

his. 

Then that will take us to 10:00, and 

what I'll do is I'll recess until 10:00, and you 

can have about a five-minute break after the 

30-minute recess so that you can make a phone 

call, use the restroom, or what have you before 

Mr. Singleton gets on the stand. 

Anything else we need to address from 

the FAA at this point in time? 

MR. VINES: No, Judge. 

THE COURT: Mr. Honeycutt. 

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MR. HONEYCUTT: No, your Honor. 

THE COURT: Okay. We can go off the 

record at this time. 

(Whereupon, a brief recess was taken.) 

THE COURT: We're back on the record in 

the matter of Worldwide Aircraft Services, Inc. 

This is Docket No. FAA-2013-0045. All parties 

previously identified have returned to the 

hearing room. 

And my first question would be to you, 

Mr. Vines, are you ready to proceed with Mr. 

Singleton's testimony? 

MR. VINES: Yes, Judge. 

THE COURT: Mr. Honeycutt are you ready 

to proceed as well? 

MR. HONEYCUTT: Your Honor, we would 

like to ask for a continuance. 

THE COURT: Of what? 

MR. HONEYCUTT: Of this case, the 

trial, for the fact that Mr. Singleton, in our 

discussion, admitted that he used the complete 

EIR file to come to his conclusions, and 

therefore, I have not seen the complete EIR file. 

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I feel I am not able to properly 

prepare to cross-examine Mr. Singleton, as well 

as Ms. Farmer. After our conversations 

yesterday, she too admitted that the complete 

file was used for her conclusions. 

THE COURT: I just need to make some 

notes. 

MR. HONEYCUTT: Yes, your Honor. 

THE COURT: In your informal 

discussions with Mr. Singleton and or with Ms. 

Farmer, Mr. Honeycutt, what portions of the EIR 

file did you find from them that were relevant to 

their opinions that you do not have and need to 

have in order to adequately prepare? 

MR. HONEYCUTT: They did not get into 

excessive detail of what part of the file that 

they used that I have not been privy to. 

Ms. Farmer insinuated yesterday that 

Mr. Hoban, I believe it was her prior, was the 

one who came to the conclusion to the violation 

and that it was excessively higher than it was 

than the current $12,000 proposed violation, 

leading me to believe that there is even more 

extensive information in the EIR that Mr. 

Singleton and herself were privy to that I have 

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not been able to review. 

THE COURT: So essentially you heard 

from Ms. Farmer that the originally proposed 

civil penalty internally at the FAA was higher 

than the 12,000 some odd dollars that you are 

currently facing now? 

MR. HONEYCUTT: Yes, ma'am. 

THE COURT: Okay. And because of that, 

you believe there's information in the EIR that 

would help you prepare to address the 12,000 and 

some odd dollar civil penalty? 

MR. HONEYCUTT: Yes, ma'am. 

THE COURT: I'm a little confused as to 

what it is that you are looking for other than a 

complete disclosure of the EIR at mid trial. 

MR. HONEYCUTT: Well, I can't answer 

the question of what is in the file that I can 

extract to be able to prepare myself to 

cross-examine and defend that these conclusions 

that these two expert witnesses have come to, 

based on that information that I have not been 

given. 

THE COURT: Okay. And as you know, 

we've had some discussions prior to the trial 

beginning impart because the Court's concern that 

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you had failed to conduct any discovery in a 

timely manner that would have resulted in you 

being more prepared, more informed, and more 

comfortable in proceeding with the trial. 

The problem that this court has with a 

motion to continue mid trial, is that it appears 

to raise the same argument that you made after 

your discovery period was completely over. 

I'm wondering what it is now that 

distinguishes this motion that you're making now 

from the motion that you made before the trial 

started which the Court denied. Can you kind of 

distinguish for me what is different in this 

motion, if anything? 

MR. HONEYCUTT: The two expert 

witnesses that the FAA is calling was not prior 

discussed. 

THE COURT: So essentially these two 

people that came in, I think it was two weeks 

ago? 

MR. HONEYCUTT: Yes, ma'am, your Honor. 

THE COURT: Okay. 

Mr. Vines, any response to this motion? 

MR. HONEYCUTT: Judge, I believe the 

motion is premature. While I was present with 

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the Respondent and his interview of Ms. Farmer 

and Inspector Singleton, they both did state that 

they relied on the unredacted EIR, I do believe, 

Judge, that it is anticipated that you will hear 

from the witnesses shortly, specifically what 

they relied on. 

I would propose to the Court that the 

evidence they heard today, including statements 

from witnesses, as well as documents that have 

been admitted into evidence, will be relied upon 

to draw their conclusions, used by them to form 

their conclusions, if any conclusions are 

requested of these particular witnesses. 

So I think, based on that, whether or 

not the Respondent has access so based on 

that, the Respondent's access to the EIR -- the 

Respondent has not shown that access to the 

EIR -- so therefore the Respondent has not shown 

that his access to the EIR would be able to 

sufficiently prepare him for the testimony that 

Ms. Farmer and Mr. Singleton are about to give. 

THE COURT: Okay. So as I understand 

it from your argument, you are saying that the 

undisclosed portions of the EIR, which is short 

for the Enforcement Investigative Report, are not 

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apart of what either Mr. Singleton or Ms. Farmer 

will rely upon in testimony in describing what 

they did, how they did it, and what conclusions 

they've reached? 

MR. VINES: Yes, Judge. 

THE COURT: Mr. Honeycutt, any 

response? 

MR. HONEYCUTT: How am I to know that, 

your Honor, without having the complete file and 

both, Ms. Farmer and Mr. Singleton, specifically 

said their conclusions were based on the complete 

file. 

MR. VINES: Judge, if I can respond to 

that? 

THE COURT: You may. 

MR. VINES: During the interviews by 

the Respondent of the Administrator's two 

witnesses, the Respondent failed to ask either 

witness what specifically from the unredacted EIR 

they relied upon. 

Moreover, as a result, the Respondent 

has not made any showing that a particular 

statement from the EIR is what is being relied 

upon by these witnesses. 

THE COURT: Well why don't we cure that 

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right now. 

What I would not like to do is have to 

continue this entire trial if, in fact, there is 

a (inaudible) cure. If there is some portion of 

the investigative report that these witnesses, 

that the FAA plans to call this morning have 

relied upon, then what I would like to do is give 

Mr. Honeycutt one more chance to inquire about 

that so that he can become a little bit better 

informed, and then we can try and proceed today. 

So I'm going to reserve ruling on your 

motion for a continuance. I will give you 

another 20 minutes. You are welcome to talk to 

both Mr. Singleton and Ms. Farmer about that 

particular area of interest that you have. Find 

out if, in fact, that there's anything that you 

do not already know that they have relied upon to 

reach conclusions that they plan to testify to, 

and then I will come back on the bench and find 

out whether you have been satisfied with that 

particular second interview. 

So it is now 10:10. Let's try and 

reconvene here back at 10:30, and I'll look 

forward to hearing from you at that point about 

your progress. 

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We can go off the record. 

(Whereupon, a brief recess was taken.) 

THE COURT: We're back on the record in 

the matter of Worldwide Aircraft Services, Inc. 

This is Docket No. FAA-2013-0045. We've 

reconvened after approximately a 20-minute recess 

in the morning. 

Mr. Honeycutt, have you had a chance 

to -- I'm sorry, all parties previously 

identified have returned to the hearing room. 

Mr. Honeycutt, have you had a chance to 

have a second interview with Mr. Singleton and 

Ms. Farmer? 

MR. HONEYCUTT: Yes, ma'am, I have. 

Again, I feel prejudice in the fact that they 

both again state that they used the complete file 

to come to their conclusions. 

THE COURT: So you did not find out 

anything in terms of specifics from them during 

your second interview as to what portions of the 

file they thought were relevant to their 

conclusions that you have not seen? 

MR. HONEYCUTT: I asked Mr. Singleton 

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to take the complete EIR file that Mr. Vines had 

and go through that file and if he would point 

out anything that he used to make a conclusion. 

Mr. Vines refused to let him do that, gave him 

the exhibits that he had and asked him to come to 

a conclusion of what he did not see in that file. 

Again, he brought up a case of 

statement, and he said, ''he believed there were 

several, two in particular, case of statements in 

that file.'' It was not in the exhibits. 

Therefore, I asked him, ''Did he use part of that 

of determining his conclusions'', and he said, 

''Yes'', your Honor. 

THE COURT: Okay. Thank you. 

Mr. Vines. 

MR. VINES: Yes, Judge, I would 

respond, the witness, Mr. Singleton, was also 

asked to go through the exhibits that have been 

made part of this record today and was asked if 

he considered any of those and he said he did, 

and he went through and pointed out each of those 

exhibits. 

I also asked him, have you-- that he's 

confirmed that he's been in court, that he has 

heard the testimony. I asked him, "Is there 

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anything outside of these exhibits, as well as 

the testimony that you've heard, that you are 

going to rely on to form the basis of any 

conclusion that you may proffer today'', and his 

answer was an unequivocal no. 

So I believe that, at least with regard 

to Inspector Singleton, two points; one, the 

motion should be denied, and the alternative, if, 

your Honor, feels that the motion should be 

granted, I would ask that you hold your decision, 

allow Mr. Singleton to testify, and if there is 

anything that comes up in his testimony that the 

Respondent finds was not disclosed to him, then 

at that point, your Honor, can make the ruling as 

to Mr. Singleton. 

THE COURT: And what about Ms. Farmer? 

MR. VINES: Same set of circumstances, 

Judge. Ms. Farmer -- I asked Ms. Farmer, during 

this interview that the Respondent conducted of 

Ms. Farmer, I asked her, ''Have you been in the 

courtroom today'' and she said, ''Yes.'' I said, 

''Have you heard the testimony from the 

witnesses'', she said, ''Yes.'' I asked her in 

addition to that I said, "You are familiar with 

the exhibits of this case", and she said, "I am.'' 

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I said, ''Are you planning to use the exhibits in 

the testimony you've heard today as part of your 

testimony in forming any conclusions that you may 

offer'', and she said, ''Yes.'' 

I also asked her, ''Is there anything 

outside of the exhibits, as well as the testimony 

that you've heard today that you intend to use as 

part of your testimony to form any conclusions'', 

and her response was an unequivocal no. 

So for the same reason, Judge, I would 

ask that you deny the Respondent's motion, and 

the alternative, allow the testimony to hold your 

finding and allow Ms. Farmer to take the stand, 

testify, and if the Respondent hears anything 

that Ms. Farmer testifies to that he has not been 

made aware of that, then based on that, then you 

can make a ruling at that point, Judge. 

THE COURT: Let me ask you a question, 

Mr. Vines, I know that this issue is not a new 

issue to this particular case. There has been, 

since early January 2014, an interest expressed 

by the Respondent for a complete unredacted copy 

of the Enforcement Investigative Report, and you 

have opposed that request on multiple occasions. 

In terms of the dispute which involves 

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the portions of the EIR which you have not 

disclosed, how much of that would fall under the 

argument of work product or any other type of 

protection, or is it simply a matter of that 

there is a lot of bulkiness in the EIR that you 

don't want to disclose, tell me a little bit more 

about what it is that's in the EIR that has not 

yet been addressed by testimony and exhibits. 

MR. VINES: Judge, it is work product 

and the deliberative of process. 

THE COURT: By whom? 

MR. VINES: By employees of the Agency. 

THE COURT: And when you say work 

product and deliberate process, is it essentially 

a combination of e-mails, phone call records, 

meetings, reports, is that what we're talking 

about, conversations with counsel, or is it 

something else like photographs, physical 

evidence, that kind of thing, can you give me a 

better sense of what you're trying to protect? 

MR. VINES: Judge, it is opinions made 

by the employees of the Agency. It is really 

opinions based on -- it is opinions formed and 

conclusions that are made. That, Judge, is 

protected. 

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We would argue that if that was to be 

turned over, that would quell the Agency's 

ability to engage in conversations with regard to 

whether violations were committed, Agency's 

theory of the case at a hearing. 

Those type of things have long been 

protected, and as a result we'd argue, Judge, 

that those should not be turned over. Again, to 

add to that, it is very clear the direction of 

the Agency's case. 

THE COURT: In this particular case you 

are saying? 

MR. VINES: Yes, it is a very civil 

case. It is very clear. A, was there damage and 

B, should it have been reported. That's what 

we're talking about. The testimony that has been 

elicited or will be elicited goes straight to 

that. 

So therefore based on the deliberate 

nature, the opinions contained in parts of the 

EIR, we believe that it is protected and should 

not be turned over. 

Moreover, Judge, again I'm repeating 

myself, but the Agency's theory of the case has 

been presented, has been disclosed to the 

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Respondent. He is aware of the nature of the 

Agency's action when we filed the complaint. 

MR. HONEYCUTT: Your Honor 

THE COURT: I am not ready to hear from 

you yet. Thank you. 

Do you have a copy of the unredacted 

EIR in front of you? 

MR. VINES: I do, Judge. 

THE COURT: What I'm going to do is ask 

you to give it to me, and I'm going to do an 

in-chamber's review very quickly. I think I can 

perhaps address this in a way that will be 

helpful to all parties. 

I'll note that Officer Brian is handing 

me a file that Mr. Vines has just handed him. 

Can you tell me, is all of this 

material that you just handed me, the EIR or is 

some of it your personal notes because I don't 

want to look at your personal notes. 

MR. VINES: Judge, there are documents 

in that folder that are addition to the EIR, the 

official EIR. Moreover, there have been 

documents removed from the EIR that have been 

presented as exhibits in this case. 

THE COURT: Okay. So as I'm looking at 

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this file that is before me, essentially all of 

the material is, as I'm holding it up, it is on 

this one side of the file? 

MR. VINES: Yes. 

THE COURT: Some of it appears to be 

documentation that was submitted as part of the 

litigation in this case which would not be in the 

EIR necessarily, would it? 

MR. VINES: Repeat your question, 

Judge. 

THE COURT: The very top document in 

this particular file that has just been handed to 

me, is a document that was filed jointly by the 

parties in the litigation before me which would 

not be the EIR, would it? 

MR. VINES: May I approach, Judge? 

THE COURT: Sure. I'm really only 

interested in the EIR at this point. Thank you. 

I'll hand that back to you. 

MR. VINES: Judge, may I approach? 

THE COURT: You may. 

MR. VINES: I'll represent what is the 

EIR with several documents that are not included 

in that and those documents that are not included 

have been removed from the file and have been 

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admitted as exhibits in this trial and or they 

weren't admitted, they have been disclosed as far 

as potential exhibits that the Agency would move 

to admit. 

THE COURT: Okay. 

MR. VINES: Moreover, Judge, I did 

reference deliberative process and opinions 

formed by Agency employees. In addition, what I 

did leave out, is information concerning airmen 

which does contain privacy information which we 

do not disclose due to regulations that the FAA 

is subject to, and those would particularly 

include airmen information regarding addresses, 

date of birth, Social Security numbers, that 

which we do not disclose. 

THE COURT: Okay. 

It is 10:45 right now. I'm going to 

take a few minutes to look at this, and then I'll 

come back and make a statement about this, Mr. 

Honeycutt. 

We can go off the record. 

(Whereupon, a brief recess was taken.) 

THE COURT: We're back on the record in 

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the matter of Worldwide Aircraft Services, Inc. 

This is Docket No. FAA-2013-0045. All parties 

previously identified have returned to the 

hearing room after approximately a 17-minute 

recess during which time the Court took the 

original Enforcement Investigative Report, 

otherwise known as an EIR and reviewed it in 

chambers. 

Mr. Honeycutt, just so that you know, 

essentially what I've done is I've done an 

in-chambers review based on your motion for a 

continuance to see if there is anything in the 

EIR upon court review that could be disclosable. 

This is exactly the same thing that I would do 

have you made this motion six months ago. 

I've reviewed the EIR. There is some 

disclosable information, not a lot, most of it 

actually has already been provided in this trial, 

either in exhibits or by testimonial form. 

The portion that is disclosable starts 

out at a statement of factors affecting sanction. 

It is a two-and-a-half page document. There is a 

section that would be stricken that indicates a 

recommendation that would be internal, that would 

not be disclosable. As Mr. Vines has already 

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said, that is work product. That is privileged, 

but the rest is, in this Court's opinion, 

disclosable, and I want to see if the FAA would 

like to come up, and I'll show you exactly what 

I'm talking about so that if you have an 

objection or further argument you can make it 

before I go forward. I made a copy. What I'm 

talking about, and I'm going to say this loud 

enough so you can hear me, but you can't see it. 

Mr. Vines is in front of the bench. 

What I'm showing Mr. Vines is the 

two-and-a-half page document that was in the EIR 

that I believe was disclosable. This is the 

first page, the second page, and the third page. 

What I think needs to be stricken as 

protected work product is this information 

starting with I recommend, this material to the 

very bottom would be stricken because that's an 

internal recommendation that should not be 

disclosed in this Court's opinion. 

Is there anything else in this document 

that you think would be covered by privilege or 

work product? 

MR. VINES: May I just look at the 

original, Judge? 

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THE COURT: Yes. 

MR. VINES: Thank you. Yes, Judge, I 

would object in paragraph two, the second entry, 

I would argue that that is, in fact, opinion, and 

it is not a fact. Therefore, it should not be 

disclosed. 

THE COURT: You're talking about page 

one, paragraph two? 

MR. VINES: Yes. 

THE COURT: So you would recommend 

striking paragraph two in its entirety? 

MR. VINES: Yes, Judge. 

THE COURT: Anything else? 

MR. VINES: I would also argue the 

fifth paragraph down on the same page, I would 

also argue that that is the opinion. That is the 

inspector who prepared this particular document. 

That is his opinion. 

THE COURT: Anything else? 

MR. VINES: Yes, Judge. I would also 

argue on page two, the second paragraph, that is 

also opinion. That is not a fact. That is 

debatable. 

THE COURT: Anything else? 

MR. VINES: I would also argue under 

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section three on page two, the first -- as far 

as -- I'll move on, Judge. 

I would also argue under page two, 

Roman Numeral III, third paragraph, I'd also 

argue that that paragraph is opinion and 

speculation. 

THE COURT: Anything else? 

MR. VINES: I would also argue Roman 

Numeral III on page two, the second to the last 

paragraph, that would be opinion prepared by this 

specific employee who prepared this document. 

THE COURT: Which paragraph is that, 

sir? 

MR. VINES: The second to the last 

paragraph on the fourth paragraph under Roman 

Numeral III. 

THE COURT: Thank you. Go ahead. 

MR. VINES: As well as the fifth 

paragraph under Roman Numeral III. As to page 

three, I would argue that the first paragraph is 

opinion. 

THE COURT: Go ahead. 

MR. VINES: And I would also present 

that the final, the last paragraph as you 

referred to earlier on page three, Judge, should 

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also be redacted. 

THE COURT: Okay. Thank you. 

MR. VINES: Judge, may I hold onto this 

EIR? 

THE COURT: Yes, I took a copy of the 

three pages that we just discussed. 

In terms of your objections on page 

one, they are noted and respectfully overruled. 

In terms of your objections on page two, the 

Court would agree with you that the fourth 

paragraph under paragraph three should be 

stricken, the statement of the investigator under 

the fourth paragraph, not the fourth paragraph 

heading, and the Court will so note that. 

In addition, I would also agree and 

sustain your objection to page two, the fifth 

paragraph, regarding the actual opinion that is 

listed. That opinion statement will be stricken 

as being an internal recommendation. 

The Court again will agree and sustain 

your objection on page three, specifically to the 

last paragraph as being an internal 

recommendation that is work product. All other 

objections are respectfully noted and overruled. 

What I'm going to do is strike out then, those 

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materials that the Court has just ruled on. I'll 

ask the officer then to make a copy. 

I will give you, Mr. Vines, the three 

page document which has the original strikes so 

that if there is any bleeding through, you have 

that copy and not the Respondent. 

Mr. Honeycutt, I'll then give you a 

copy that has the strikes that have been copied 

so that there is no bleed through. 

What I will do is I will give you folks 

about another five minutes just to look through 

this material. It is fairly easy to read, and 

then I will come back out and hear any further 

argument if there is any regarding the 

Respondent's motion to continue. 

So with that, I'm going to take about a 

15-minute recess. In five minutes, you folks 

will get this strike out with a copy. You'll 

have 10 minutes to look through it. I'll come 

back on the bench at 11:30. 

We can go off the record. 

(Whereupon, a brief recess was taken.) 

THE COURT: We're back on the record in 

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the matter of Worldwide Aircraft Services, Inc. 

This is Docket No. FAA-2013-0045. 

We've reconvened after another morning 

recess. All parties have had a chance to review 

the two-and-a-half page document that was 

distributed to them during the recess, which was 

the document that the Court ruled after an 

in-chambers review was disclosable to the 

Respondent. 

Mr. Honeycutt, do you have anything 

else that you would like to add to your motion to 

continue or any other motion that you would like 

to make at this time having received this 

document? 

MR. HONEYCUTT: Yes, ma'am, your Honor, 

in light of this, I feel that the government 

waived its right to privilege by giving the 

complete file unredacted to the expert witnesses, 

therefore not allowing me to have the right to 

have the complete file. 

THE COURT: How is that, in your 

opinion, because both of these witnesses are FAA 

employees? 

MR. HONEYCUTT: And they are called as 

expert witnesses after the fact of discovery and 

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everything. Neither one of them had any prior 

knowledge to this prior to February of this year. 

THE COURT: How do you distinguish this 

type of scenario from any other scenario when 

employees participate in internal decision making 

and assistance? 

MR. HONEYCUTT: Well, an expert witness 

I believe, your Honor, would come in and 

formulate his own conclusions just based off the 

evidence. These two expert witnesses have seen 

the opinions of other FAA personnel, therefore I 

feel if they want the expert witness to come to 

their own conclusions, they would have given the 

expert witness the redacted file that I have 

received. 

So I would ask the Court if we don't go 

for a continuance, then I would ask for these 

expert witnesses to be excluded. 

THE COURT: Okay. 

Mr. Vines, any response to the renewed 

motion for continuance and the new motion for 

exclusion? 

MR. VINES: As to the motion for 

continuance, I would just reiterate what I stated 

earlier about the original proposal allowing the 

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witnesses to testify and to reserve your decision 

about what these witnesses will testify. As for 

the exclusion, Judge, it is without merit. As I 

said before, the witnesses are expected to 

testify to the conclusion they have drawn based 

on evidence they have heard today. 

If Mr. Honeycutt wants to cross-examine 

the witnesses as to any other evidence that they 

have considered outside what they've testified 

to, he can, and then we can go from there. The 

Court can go from there as to what type of ruling 

the Court should make with regard to the 

Respondent's motion. 

THE COURT: Mr. Honeycutt, these are 

your motions, do you have any final argument you 

would like to make? 

MR. HONEYCUTT: I would, your Honor. I 

would like to request that I can see Ms. Farrner 1 s 

notes that she has taken. She revealed earlier 

today that she made notes from last night and 

yesterday. 

THE COURT: Well that's a different 

motion. 

MR. HONEYCUTT: Okay. 

THE COURT: I want to know if you have 

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a response to Mr. Vines' arguments objecting to 

your motions to continue and to exclude. 

MR. HONEYCUTT: The objection to 

continue on with my motion, your Honor, is again, 

if I would have had this information prior to 

Mr. Kahler's testimony, I might have had a few 

extra questions for Mr. Kahler, specifically into 

his opinions, which has been redacted. 

Mitigating and aggravating factors I would have 

asked. Again, the expert witness who relies upon 

mitigating and aggravating factors have seen Mr. 

Kahler's opinion. 

So therefore not having given this 

information that I requested on multiple 

occasions and the FAA has continuously fought to 

not allow me have my due rights, my due process, 

that is on the motion of continuance. 

Again on the experts, I believe an 

expert is to formulate his own conclusions based 

on evidence, and the file contains these 

individuals' opinions and not the strict 

evidence. Therefore, I think they are tainted. 

Therefore, I don't feel like I'm going to get a 

due process, a fair trial. 

THE COURT: Okay. Thank you very much. 

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In terms of your renewed motion to continue, that 

is respectfully denied. You have indicated that 

this is material that you have repeatedly 

requested over a period of time. This court and 

the record respectfully note that that is not the 

case. As we had discussed earlier in the Court's 

decision in pre-hearing status outline, you 

basically did not conduct any discovery at all. 

Now, I understand there may have been 

reasons for that, but there are consequences to a 

failure to engage in the discovery process as you 

are learning now. It may be a very painful 

lesson, but it is a less nonetheless. 

This court has tried to cure the 

failure to engage ln discovery by providing you 

with some limited time to talk informally with 

new witnesses that were listed most recently by 

the FAA. And the Court has also tried to cure 

your interest in the undisclosed portions of the 

EIR that would have been granted to you had 

discovery been conducted in a more timely 

fashion. 

There is no question that Mr. Kahler's 

testimony has already been provided prior to this 

particular document being given to you, however 

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that does not mean that you cannot utilize this 

document in many different ways during the 

complete of the FAA's case in chief or during 

your own responsive case. 

I don't believe there is sufficient 

grounds to grant a continuance, particularly 

given the fact that we're halfway through the 

trial at this point. I do think that you have 

had some disadvantages by not conducting 

discovery, but those are disadvantages that you 

chose for yourself, whether ignorantly or not. 

Secondly, in terms of your motion to 

exclude, I will deny that. These witnesses have 

been identified prior to their hearing. You have 

had a chance to discuss briefly with them the 

scope of their testimony. You will have a chance 

to engage in full cross-examination of both of 

them. 

In addition, you have also listed a 

variety of different witnesses that you plan to 

call, hopefully both this afternoon and tomorrow 

in which you can address each and every topic of 

the factors effecting sanctions that is contained 

in the two-and-a-half page document that was just 

provided to you and to counsel with work 

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privileged information deleted. 

This particular information should not 

be new impart because you have had so much time 

to prepare and impart because the material upon 

which it is based is available to the public and 

has been for years. 

Again, that leads us back to the 

question of whether you knew about it, how long 

you've been taking to prepare for this case. It 

may be, and the Court doesn't know and is not 

inquiring, it may be that you did not start to 

fully prepare for this case until a few days ago. 

If that is the case then that's an 

individual Respondent's choice, or a litigant's 

choice that has consequences. It may be that you 

have been preparing for this case for two years, 

I don't know, but in any event, the Court has 

tried to the best of its ability, within the time 

frame, to give you as much information as 

possible so that you can have a meaningful 

process in this court today before this court. 

If you go away from the litigation 

feeling that you have been disadvantaged, that is 

unfortunate because this court strives to make 

sure that the equation between disputing 

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litigants is fully balanced. There is a limit to 

what the Court can do. Of course, I have no 

control over your perceptions of what happens. 

can only say that at this point I don't have a 

basis in this court's opinion to grant your 

motion to exclude. 

So with that, you had asked before the 

last recess if the Court would make sure to 

retain an original copy of the two-and-a-half 

page document that was just disclosed to you. 

I 

The Court has made an original copy and I'll keep 

it in the Court's private file. We do and my 

office keeps records for quite some time so if 

the case goes up on appeal upon its request, then 

the Court has it available. 

With that, any other motions from you, 

Mr. Vines? 

MR. VINES: No, Judge. 

THE COURT: Mr. Honeycutt. 

MR. HONEYCUTT: No, ma'am. 

THE COURT: Okay. It is 

quarter-to-noon, does everyone have the energy to 

go forward for at least 45 minutes? 

MR. VINES: Yes. 

MR. HONEYCUTT: Yes. 

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THE COURT: Let's continue then, Mr. 

Vines, are you planning to call Mr. Singleton? 

MR. VINES: Yes, Judge. 

THE COURT: Mr. Singleton, if you would 

approach the bench. 

THE WITNESS: Yes, ma'am. 

THE COURT: Before you sit down, please 

raise your right hand. Do you swear to tell the 

truth and nothing but the truth in this 

proceeding? 

THE WITNESS: Yes, ma'am. 

MICHAEL SINGLETON, after having been 

duly sworn, was examined and testified as 

follows: 

THE COURT: Please take a seat. When 

you are comfortable, please state your name and 

spell your last name for the record. 

THE WITNESS: Michael Singleton, 

S-I-N-G-L-E-T-0-N. 

THE COURT: Thank you. 

Mr. Vines, you may inquire. 

DIRECT EXAMINATION 

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2 BY MR. VINES: 

3 Q. Mr. Singleton, good morning. Where do you 

4 currently work? 

5 A. Federal Aviation Administration Tampa Flight 

6 Standard District Office. 

7 

8 

9 

10 

11 

Q. 

A. 

Q. 

A. 

Q. 

And what is your title there? 

Aviation Safety Inspector. 

How long have you held this position? 

Six years. 

And as an Aviation Safety Inspector, what 

12 particular focus do you -- what particular field do 

13 you focus on? 

14 A. I'm a Maintenance Inspector. 

15 Q. And as a Maintenance Inspector, what are your 

16 duties with the FAA? 

17 A. Well, the duties are broad. I provide oversight 

18 to Part 145 Repair Stations, Part 135 Air Operators, 

19 Part 91 Air Operators, Airframe-and-Power-Plant 

20 Mechanics Part 65. 

21 I also currently oversee Department 47 Airframe 

22 and Power Plant and School where the mechanics are 

23 trained, accident-and-incident investigation. There 

24 are numerous collateral duties that go beyond the 

25 oversight of our position. 

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1 Q. I don't know if you mentioned, but are you 

2 familiar with Part 137? 

3 

4 

5 

6 

A. 

Q. 

A. 

Q. 

Yes. 

What is part 137? 

Agricultural spraying. 

Do you have any oversight of companies or 

7 Certificate holders operating Part 137? 

8 

9 

10 

A. 

Q. 

A. 

11 load. 

12 Q. 

I currently do not. 

Okay. 

I have had in the past as with 133, external 

And when you talk about Part 145 Repair Stations, 

13 could you educate the judge as to what exactly that is 

14 or those are? 

15 A. Yes, a Part 145 Repair Station is either where an 

16 air carrier or general aviation, in basic terms, 

17 brings their aircraft for repair and or overhaul. A 

18 Part 145 Repair Station can also be more essentialized 

19 where they just overhaul engines or particles of an 

20 aircraft, not the entire aircraft. 

21 Q. How many -- are you able to provide an average of 

22 how many repair stations you are in charge of 

23 overseeing on a yearly basis? 

24 A. I currently have oversight on I believe seven 

25 repair stations. 

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1 Q. And you testified earlier about oversight on Part 

2 135 Operations, will you talk in detail about the 

3 types of work you do with Part 135 Operators? 

4 A. Yes, I currently oversee, I believe it is four, 

5 possibly five, but I think it is four Part 135 

6 Operators. In the oversight of Part 135 Operators, 

7 one of the basic duties is to add aircraft. 

8 In adding the aircraft, we perform conformity 

9 inspection to ensure the aircraft meets its type 

10 certificate, which is the instructions by which the 

11 aircraft was manufactured, make sure that they still 

12 meet those requirements. We inspect the aircraft 

13 logbooks, the maintenance aircraft logbooks, to ensure 

14 that all required maintenance has been complied with 

15 in accordance with the Air Operator's Manuals and or 

16 if it is adding an aircraft in accordance with the 

17 FAR's as they are adding the aircraft. 

18 

19 

Q. 

A. 

When you say add aircraft, what does that mean? 

It is when a Part 135 Operator requires an 

20 additional aircraft before or prior flying for 

21 compensation or higher, it has to be inspected by the 

22 FAA in order to add it to the Air Operator's 

23 Certificate to operate. 

24 Q. And with regard to-- let's talk about the 

25 Operations Specification, do you know what they are? 

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1 

2 

3 

A. 

Q. 

A. 

Yes. 

What are Operation Specifications? 

They are additional limitations placed on an 

4 Operator or an Air Agency in addition to the Federal 

5 Aviation Regulations, generally limitations or 

6 restrictions beyond the regulations. 

7 

8 

9 

10 

11 

12 

MR. VINES: Exhibits, Judge, I believe 

we left those with you last night. 

THE COURT: The exhibits are right 

here, Mr. Vines. I'm going to hand them in bulk 

to the witness. He can have them faced down on 

the desk. They are in chronological order. 

13 BY MR. VINES: 

14 Q. Do the Operations Specifications include 

15 information about the certain type of aircraft, the 

16 Part 135 Carrier may use under its Certificate? 

17 

18 

19 

A. 

Q. 

A. 

Yes. 

Describe that, please. 

There's an aircraft listing in, I believe it is 

20 paragraphs B85, that is the aircraft listing that the 

21 particular air operator currently operates or is 

22 authorized to operate. 

23 Q. And are -- do you know if the -- in order for a 

24 Part 135 Carrier Operator of a particular aircraft, is 

25 that aircraft required to be listed on the carrier's 

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1 list of operations? 

2 

3 

A. 

Q. 

Yes, sir. 

If you'll take a look through the exhibits. I 

4 want to direct your attention to Exhibit 3A through 

5 3J? 

6 

7 

8 

9 

A. 

Q. 

A. 

Q. 

Excuse me, is that C-3 through J? 

Yes. 

Thank you. 

Inspector, what did you believe those documents 

10 to be? 

11 A. The Operator Specifications for Worldwide 

12 Aircraft Services, Certificate No. W50 Alpha. 

13 Q. So would that be an example of Operation 

14 Specifications for the Court's understanding? 

15 

16 

17 

18 

A. 

Q. 

A. 

Q. 

Yes. 

Or part of the operator 

Commercial, yes. 

You mentioned that you do have oversight of Part 

19 135 Operators, as a FAA Inspector, have you received 

20 any training in that position? 

21 

22 

23 

A. 

Q. 

A. 

Yes. 

Please describe the training you received. 

The training for a new inspector -- when I came 

24 on we were sent to the FAA Academy in Oklahoma City 

25 for approximately two months. In that training, it 

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1 included formal classroom training of air operators 

2 under Part 135 are part of the formal classroom 

3 training. 

4 

5 

Q. 

A. 

What about Part 145 Repair Stations? 

Yes, Part 145 Repair Station oversight is part of 

6 it, the accident-and-incident investigation is part of 

7 it, compliance and enforcement is part of it, 

8 automation tools, numerous databases that I could bore 

9 you with acronyms, but numerous tools or training that 

10 the government uses, that the FAA uses. 

11 Q. And you received that training when you began 

12 with the FAA? 

13 

14 

A. 

Q. 

Correct. 

Have you received any additional training since 

15 working with the FAA? 

16 

17 

18 

A. 

Q. 

A. 

Yes. 

What is that? 

We have an on-the-job training program that is 

19 mandated by the FAA, which is to be accomplished 

20 between approximately one year and 18 months -- your 

21 first year of 18 months to deploy. 

22 In the OJT process, you are given real-world 

23 experience and real-world training to back up the 

24 formal classroom in training in Certification of Air 

25 Agencies, Certification of Operators, inspection of 

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1 aircraft, inspection techniques, investigative 

2 techniques for accidents, incidences, and occurrences 

3 in all realms of the oversight that we have that I 

4 mentioned. 

5 Q. And you received that formal OJT, on-the-job 

6 training? 

7 

8 

9 

10 

11 

A. 

Q. 

A. 

Q. 

A. 

Yes, sir. 

And have you been trained by the FAA since then? 

Yes, sir. 

What is that? 

We have recurrent training approximately two to 

12 three classes a year where we are either sent to 

13 Oklahoma City or to contract training provider to the 

14 FAA to broaden our knowledge base on more unique 

15 items. 

16 Some of the repetitive training is required 

17 training by the government, annual training within the 

18 more unique training events, like I said, are -- we 

19 will travel to a company that trains us in things. 

20 Q. And that training, is that focused on maintenance 

21 issues or is it more administrative training, training 

22 toward administrative tasks? 

23 A. We have annual required training that is 

24 administrative, but the training that we travel to 

25 Oklahoma City or to a contract-training provider is 

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1 maintenance, it is more maintenance related. 

2 Q. And when you say maintenance, what does that 

3 mean? 

4 A. Maintenance is the repair servicing overhaul 

5 maintaining of an aircraft to its typed design or to 

6 its allowable modified state. 

7 

8 

9 

10 

11 

12 

Q. 

A. 

Q. 

A. 

Q. 

A. 

So this would include repairing engines? 

Yes. 

Working on maintaining the fuselage? 

Yes. 

What is the fuselage? 

It is main structure or main body of the aircraft 

13 as it were. 

14 Q. Would this also cover perhaps maintaining, 

15 fixing, or repairing equipment in the cockpit? 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

A. 

Q. 

A. 

Q. 

A. 

Q. 

A. 

Q. 

A. 

Q. 

Yes. 

Working on the tail of the aircraft? 

Yes. 

Okay. Prior to the FAA, where were you employed? 

I was employed with JetBlue Airways. 

What was your title there? 

I was the Manager of Maintenance Training. 

How long were you at JetBlue? 

I believe I was at JetBlue for four years. 

And did you hold that title for the four years 

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1 you worked there? 

2 

3 

A. 

Q. 

I did, yes. 

What were your duties as the manager of 

4 Maintenance Training? 

5 A. To design and develop (inaudible) 320 

6 maintenance-training courses and 190 

7 maintenance-training courses, as well as the Building 

8 Trading Department as the airline was quite young when 

9 I joined them and growing rapidly. 

10 Q. So you were hired to -- okay. You mentioned 

11 earlier in your testimony that with the FAA, you 

12 oversee a Part 145 School, a Part 147 School? 

13 

14 

15 

A. 

Q. 

A. 

Yes, that's correct. 

Part 147 School, what is that? 

That is an Airframe-and-Power-Plant-Mechanic 

16 School, authorized by the FAA to train mechanics for 

17 their Airframe-and-Power-Plant Certificate. 

18 Q. Did you do anything similar while you were at 

19 JetBlue? 

20 A. Yes, we worked in cooperation with the Aviation 

21 High School in Queens, New York, which was the local 

22 A-and-P School to us to develop an intern program for 

23 mechanics so we could grow mechanics the way we wanted 

24 them. 

25 Q. And prior to that, where were you employed? 

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1 A. I worked at Timco Aviation Services in Lake City, 

2 Florida for approximately one year. 

3 

4 

Q. 

A. 

What is JetBlue? 

JetBlue Airways is a Part 121 Air Carrier. 

5 an airline. 

It is 

6 Q. Thank you. Going back to the Timco Aviation, how 

7 long were you there? 

8 

9 

10 

A. 

Q. 

A. 

I was there for approximately one year. 

What is Timco Aviation Services? 

Timco is for Part 145 Repair Station for a large 

11 Part 121 Aircraft overhaul. 

12 Q. And, if you could, briefly summarize Part 121, 

13 what is the Part 121 that the Federal Aviations 

14 regulate? 

15 A. Part 121 is the rule that governs large air 

16 carrier or airlines in the U.S. 

17 Q. And you said you were at Timco Aviation for one 

18 year, what did you do there, what were your duties? 

19 A. My primary duty was the supervisor of maintenance 

20 planning. In that, I planned heavy maintenance 

21 visits, as well as non-routine maintenance visits at 

22 the time for airlines. Additional duties were to act 

23 as a mechanic where needed and also in the managers, 

24 the hanger manager 

25 THE COURT: I'm sorry, the court 

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1 

2 

3 

reporter would like you to repeat that last part. 

THE WITNESS: Yes, ma'am. I would fill 

in for the hangar manager when he wasn't there. 

4 BY MR. VINES: 

5 

6 

7 

8 

9 

10 

Q. While you were at Timco Aviation, did 

any in-training at that station as part of 

employment? 

A. Yes, I did. 

Q. And what is that? 

A. There is a required training for all 

you receive 

your 

known 

11 employees to a Part 145 Repair Station to become 

12 familiar with their manual process, a Repair Station 

13 Manual and Quality Manuals. So we have training for 

14 that, as well as what's referred to Environmental 

15 Training or any special training unique to that 

16 environment like the hangar or their particular 

17 equipment that they use. 

18 Q. Again, going back to your employment at JetBlue 

19 when you were the manager of training, did you receive 

20 any training as the manager of training? 

21 

22 

23 

A. 

Q. 

A. 

I did. 

What type of training did you receive at JetBlue? 

I went through A-320, which is a month-long 

24 school in Miami. I went through an E-190 School, a 

25 Maintenance School, which was provided by Swiss 

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1 Aviation Training. 

2 As a maintenance-training manager, the training 

3 department at JetBlue believed in leadership training 

4 and bettering us as instructors and managers, so he 

5 sent us to NYU to attend several, I guess training 

6 courses, psychology courses, education courses. 

7 Q. And you mentioned training on the A-320, what's 

8 an A-320? 

9 A. It's an Airbus Aircraft that holds approximately 

10 320 people. 

11 Q. And you said that you had an indoctrination class 

12 of one month, would you describe to the Court about 

13 what that indoctrination included? 

14 A. Yes, the indoc courses cover all systems on the 

15 aircraft, electrical, hydraulic, automatic, and 

16 mechanical systems in order to better prepare a 

17 mechanic to work on that aircraft. It is quite an 

18 in-depth course. 

19 

20 

21 

Q. You mentioned the E-190, what is an E-190? 

A. E-190 is the model of the aircraft. It is a 

100-person aircraft manufactured in Brazil. JetBlue, 

22 at the time, was the launch customer in the U.S., 

23 which means that they were the first ones that you see 

24 in the U.S. and that airline becomes a launch customer 

25 which means that we have provided all the training for 

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1 maintenance, for flight, for anything outside 

2 obviously the Typed Certificate. We really hadn't to 

3 come up with how to maintain the aircraft though. 

4 Q. Was that similar in what you received with the 

5 indoctrination class with an A-320? 

6 

7 

A. 

Q. 

Yes, similar, much harder, but similar. 

Okay. Prior to your employment at Timco, where 

8 were you employed? 

9 

10 

11 

12 

13 

14 

A. 

Q. 

A. 

Q. 

A. 

I worked for United Airlines. 

How long were you at United? 

I believe for five years. 

And what were your duties at United Airlines? 

I started as a mechanic in the Indianapolis 

Facility. In that job I was responsible, as part of 

15 the overhaul crew, to completely, well as much as you 

16 can, disassemble the aircraft, inspect the aircraft, 

17 make any necessary repairs or restoration to the 

18 aircraft, put it all back together, and hope it works. 

19 

20 

Q. 

A. 

And what type of aircraft were you overhauling? 

The facility held numerous, my specialty was 757 

21 and 767. 

22 Q. Did you receive any training while working at 

23 United Airlines? 

24 A. Yes, numerous classes on the 757, 767 Aircraft 

25 systems, including auto-pilot engines, avionics and 

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1 structural repairs. 

2 

3 

Q. 

A. 

When you say avionics, what are avionics? 

It is aircraft electronics. It is sort of an all 

4 encompassing term to describe really the end user, 

5 which is what the pilots will see in the cockpit, the 

6 displays they look at, the radios, the instrumentation 

7 is referred to as avionics. 

8 Q. You've been in the courtroom for this proceeding; 

9 is that correct? 

10 

11 

12 

13 

14 

15 

A. 

Q. 

A. 

Q. 

A. 

Q. 

Yes, sir. 

Have you heard the loosen term GPU? 

Yes. 

What is a GPU? 

A ground-power unit. 

And you also heard testimony that there is a GPU 

16 receptacle attached to an aircraft with tail No. 

17 N90LJ; is that correct? 

18 

19 

A. 

Q. 

Yes. 

Okay. Does the GPU receptacle, does that fall 

20 under the avionics category, or what category would 

21 that fall under? 

22 

23 

24 

25 

A. It is probably aircraft electrical system. 

THE COURT: Counsel, are you asking for 

this witness to be qualified as an expert? 

MR. VINES: Yes, Judge. 

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1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

Honeycutt? 

THE COURT: Any objection, Mr. 

MR. HONEYCUTT: Expert on what grounds? 

MR. VINES: Airframe-and-Power-Plant 

Maintenance. 

MR. HONEYCUTT: We have no objection to 

his expertise and his background as a mechanic. 

THE COURT: Thank you. 

I'll find that you are so qualified, 

sir. 

You may continue. 

MR. VINES: Judge, I do want to hold 

13 one more question that goes to his background. 

14 BY MR. VINES: 

15 Q. Do you hold an A-and-P Certificate? 

16 A. Yes. 

17 Q. How long have you held that certificate? 

18 A. Since 1986. 

19 Q. You've heard testimony during this hearing about 

20 an aircraft with the No. N90LJ which you confirmed 

21 earlier in your testimony. Have you also heard 

22 testimony about the ground-power unit receptacle 

23 associated with this aircraft? 

24 

25 

A. 

Q. 

Yes, sir. 

There's also been testimony that this aircraft 

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1 operated and has been admitted to by the Respondent 

2 that N90LJ was operating on the flight from Airport 

3 Code TDPD to MYAM on May 3, 2009. Have you heard that 

4 testimony? 

A. Yes. 

Q. Okay. I want to direct your attention to Exhibit 

5 

6 

7 C-8A and C-8B as in boy. If you'll take a look at 

8 this document, please. 

9 

10 

11 

12 

A. 

Q. 

A. 

Q. 

Okay. 

Did you have a chance to review that document? 

Yes, sir. 

There was testimony based on this exhibit that 

13 upon arriving at the Bahamas, Airport Code MYAM, the 

14 pilot in command of this aircraft, also known as 

15 Captain Brandon Plas, discovered that there were bent 

16 pins inside the GPU receptacle. Have you heard that 

17 testimony? 

18 

19 

A. 

Q. 

20 is? 

21 

22 

23 

A. 

Q. 

A. 

Yes. 

First of all, do you know what a GPU receptacle 

Yes. 

What is a GPU receptacle? 

It is a point on the aircraft where a 

24 ground-power unit can be attached to the aircraft to 

25 provide electrical power to the aircraft. 

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1 

2 

3 

Q. 

A. 

Q. 

That electrical power is provided by a cord? 

It is, yes. 

What is the purpose of the GPU unit and the GPU 

4 receptacle, why do aircrafts have a GPU receptacle and 

5 why is it used? 

6 A. Aircrafts have a ground-power unit receptacle to 

7 power the aircraft via an external source of the 

8 aircraft. When the aircraft is in flight, it 

9 generates its own power. On the ground, you want some 

10 source of external power. So the ground-power unit in 

11 many makes and models provides electrical power to an 

12 aircraft. 

13 Q. Specifically what is that power used for, what 

14 does that aircraft use the power for? 

15 A. Use the power to power up the avionics, in 

16 general, power up the avionics to do pre-flight 

17 planning, and then it is also used to start the engine 

18 to relieve the load on the aircraft-battery system. 

19 Q. Can you describe what a GPU receptacle looks 

20 like? 

21 A. On an aircraft like this, a GPU receptacle is 

22 sort of oval in shape, I guess would be the best 

23 description. It is probably three-and-a-half inches 

24 wide about an inch tall with three pins, two large 

25 pins and one smaller pin inside the receptacle. 

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1 

2 

3 

Q. 

A. 

Q. 

And you discussed earlier the GPU cord? 

Yeah. 

How does that cord attach to or into the 

4 receptacle? 

5 A. The cord is generally made of a very heavy duty 

6 rubber to insulate the wires and the pins. When you 

7 plug it into the aircraft, it encompasses the pins to 

8 provide insulation. The cords are usually designed in 

9 such a way that far enough into the socket where they 

10 grab the pins but also externally on the outer 

11 diameter of that plug, it provides a friction fit into 

12 the aircraft to hold it in. 

13 Q. So is it fair to say you are essentially taking 

14 the cord, the end of that cord and inserting it into 

15 the receptacle and into that cord (inaudible) the 

16 receptacle with the rubber squeezes into that 

17 receptacle? 

18 

19 

A. 

Q. 

20 to? 

21 

22 

A. 

Q. 

Yes. 

And that provides the friction that you referred 

Yes. 

I'm going to take your attention to Exhibit C-13A 

23 through C-130. 

24 

25 

A. 

Q. 

Okay. 

Have you had a chance to review this document? 

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1 

2 

3 

A. 

Q. 

A. 

Yes, I have. 

What does this document appear to be? 

It appears to be the General Operations Manual 

4 for Worldwide. 

5 Q. And the testimony at this hearing, it was 

6 presented that this was the General Operations Manual 

7 in effect to the time of the event that occurred on or 

8 

9 

10 

about May 3, 2009. Did you hear that testimony? 

A. I did, yes. 

Q. I want to direct your attention to paragraph E-3 

11 of the exhibit which is found on C-13M as in Mike. 

12 Take a moment to read paragraph E. 

13 

14 

15 

A. 

Q. 

A. 

I've reviewed it. 

What is your understanding of that paragraph? 

That paragraph is a description of a procedure 

16 for this Operator to record maintenance discrepancies. 

17 Q. And that references what type of discrepancies 

18 must be recorded, correct? 

19 A. Mechanical discrepancy is what is stated in the 

20 paragraph. 

21 Q. Now you testified earlier that you were aware of 

22 testimony that from Captain Plas that he discovered on 

23 May 3rd that the prongs inside the GPU receptacle were 

24 bent, would you consider the bent prongs inside the 

25 GPU unit to constitute a mechanical discrepancy or 

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1 irregularity? 

A. Yes. 

Q. Why? 

A. If it is bent, it no longer meets its typed 

2 

3 

4 

5 

6 

design. The pins are designed to be straight. 

Q. When you say type design, what you are referring 

7 to? 

8 A. I'm referring to the Type Certificate of the 

9 aircraft. Again, it's an instruction from the 

10 manufacturer of the aircraft that describes the 

11 appropriate configuration. 

12 Q. We don't have the type design -- do you know what 

13 a Typed Certificate data sheet is? 

14 

15 

16 

A. 

Q. 

A. 

Yes. 

What is that? 

As I just stated, it is the manufacturer's 

17 basically the manufacturer's conformity of the 

18 aircraft or as the aircraft was released from the 

19 manufacturer, it lists allowable engine models to be 

20 installed, allowable tolerances of flight controls, 

21 fuel capacities, oil capacities, flight-maneuver 

22 ability, or maneuvering speeds and limitations, weight 

23 of the aircraft, weight limitations, including 

24 over-weight limitations. Generally, it has a few 

25 pages of manufacturer's notes that go beyond the 

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1 normal type design to cover any unusual use of the 

2 aircraft. 

3 Q. And what specifically -- why are you able to form 

4 the conclusion that the bent prongs don't conform to 

5 this aircraft type of design? 

6 

7 

A. The type design -- a GPU plug is as straight into 

receptacles. So if you have a bent pin or curved pin, 

8 it is not going fit into a straight receptacle. The 

9 limitations of a bend wouldn't be in the typed data 

10 sheet, they would be in an Aircraft Maintenance Manual 

11 provided by the manufacturer. 

12 Q. Do you agree or disagree that these prongs are 

13 part of the electrical system within that GPU 

14 receptacle? 

15 

16 

17 

A. I agree with that statement. 

THE COURT: I'm sorry, Mr. Vines, I did 

not hear your question. Could you repeat that, 

18 please? 

19 BY MR. VINES: 

20 Q. Do you agree or disagree that the prongs inside 

21 the GPU receptacle constitute an intricate part of the 

22 electrical system? 

23 

24 

25 

A. I agree that they do. 

THE COURT: Thank you. 

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1 BY MR. VINES: 

2 

3 

Q. 

A. 

And why is that? 

Without the pins, there would be no way to 

4 transfer the electrical power from the GPO to the 

5 aircraft electrical system. 

6 Q. Do you have any concern with -- what concern, if 

7 any, do you have with the observation of bent pins 

8 inside the GPO receptacle? 

9 A. A concern that I would have would be what damage 

10 has gone beyond the pins or behind the pins internal 

11 to the aircraft. 

12 

13 

14 

Q. And why is that a concern to you? 

A. Normally pins of this size are mounted in an 

insulator block or an insulation block. I would 

15 personally be concerned if you bent the pin in the 

16 insulation block, could it be cracked internal to the 

17 aircraft or internal to the plug assembly itself, 

18 thereby degrading the insulation qualities of it. 

19 Q. Again, pushing forward if, the insulation was 

20 degraded, does that cause a concern specific to that? 

21 A. Yes, my concern would be that if the insulation 

22 is degraded, that electrical parking can occur to the 

23 pins to the closest point of medal, closest ground 

24 point it is called or (inaudible) the plug or from the 

25 damage spot to the plug. 

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2 

Q. 

A. 

And is that significant? 

It could be. It could be a source of a fire. It 

3 is weighing risk. 

4 Q. You heard testimony that the pilot, Captain 

5 Brandon Plas, by way of his statement in Exhibit C-BA 

6 and C-BB, did not document the bent prongs inside the 

7 GPU in an aircraft maintenance discrepancy form; is 

8 that correct? 

9 

10 

A. 

Q. 

That is correct. 

And Mr. Plas also testified to, by way of his 

11 statement, that he didn't make any documentation to 

12 the damage of the prongs, is that your understanding 

13 according to his statement? 

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A. 

Q. 

Yes. 

Would you expect the pilot to have made 

16 documentation of damage to those prongs? 

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A. 

Q. 

A. 

Yes. 

Why? 

It is required in the General Operations Manual 

MR. HONEYCUTT: Your Honor, we object. 

It is beyond his scope of expertise. I mean, he 

is asking him to reference what a pilot would do 

versus his expertise as a mechanic and an A and 

P. So we ask that Brandon P1as' statement stays 

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as what it is and 

THE COURT: There's been an objection. 

MR. HONEYCUTT: -- the witness to 

testify what Brandon should have or what have 

done. 

THE COURT: There's been an objection 

that this testimony and inquiry goes beyond this 

witness' expertise. Do you have a response? 

MR. VINES: I disagree with that, 

Judge. Mr. Singleton is a Maintenance Inspector 

and has been qualified as an expert in 

General-Aircraft-and-Power-Plant Maintenance. 

Again, it is purview as to whether the 

maintenance issue, the discrepancy that Mr. 

Singleton testified to, should have been 

documented. 

MR. HONEYCUTT: I think he can ask the 

question in a different manner than what the 

pilot would have done or should have done. He 

can speak to his expertise on the maintenance 

side not necessarily bringing in to what a pilot 

should be doing. So I object to that question. 

THE COURT: Thank you. I'm just going 

to take a look at my notes for a moment. I'm 

going to sustain the objection at this point. 

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1 I'm going to ask you, Mr. Vines, you 

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can either ask the question in a different way or 

you can expand on this witness' testimony about 

the work he is performing and has performed as a 

Maintenance Inspector for the FAA. 

My notes indicate that he testified 

that part of his work involved inspecting 

maintenance logbooks in accordance with Operator 

10 

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13 

Manuals and the Federal Aviation Regulations. 

don't have notes that he has a specific 

qualification to talk about the documentation a 

pilot would provide as opposed to mechanic. 

If that is, in fact the case, I would 

14 like to know about it and I can revisit this 

15 issue. 

16 BY MR. VINES: 

17 Q. You testified earlier, Inspector, that you do 

I 

18 review manuals of Part 135 Certificate Holder Manuals 

19 for compliance with general maintenance to the 

20 aircraft, is that my understanding? 

21 

22 

A. 

Q. 

Yes, sir. 

And as part of that duty, have you come across in 

23 your past manuals with Part 135 Operators requiring 

24 pilots to make maintenance entries or discrepancies 

25 irregularities into maintenance logs? 

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1 A. Yes, it is required for a Maintenance Inspector 

2 to look at the Maintenance Program that a Part 135 

3 Operator has. 

4 Q. And in your experience, have you come across 

5 situations where pilots, in fact, are required by the 

6 Certificate Holder's Manual to document maintenance 

7 irregularities or maintenance discrepancies 

8 (inaudible) for pilots to make those entries? 

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A. Yes. 

MR. VINES: Based on that, Judge, I 

would ask to have the witness answer my original 

question. I'd be happy to repeat it. 

THE COURT: Mr. Honeycutt, do you still 

have that objection? 

MR. HONEYCUTT: No objection. He can 

continue on. 

THE COURT: The objection has been 

noted -- I'm sorry, are you withdrawing the 

objection or you simply want a ruling? 

MR. HONEYCUTT: A ruling. 

THE COURT: The objection is noted and 

respectfully overruled at this point given the 

additional testimony of this witness. 

Folks, I see it is now 12:30, and I'm 

sure everyone is starting to fade from lack of 

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food. 

Mr. Singleton, I'm going to thank you 

very much at this point for your testimony. 

We're going to take a lunch recess. As you are 

no doubt aware at this point, please do not 

discuss your testimony with anyone besides 

counsel and Mr. Honeycutt if they are both 

present with you or obviously your FAA's witness, 

the FAA can discuss testimony yet to come. 

Mr. Vines, how much time would you like 

to take for lunch, is one hour still sufficient? 

Did you have any trouble getting back into the 

Courthouse yesterday? 

MR. VINES: I am okay with a 30-minute 

lunch break. 

THE COURT: You want a 30-minute lunch 

break? 

MR. VINES: I am okay with 30 minutes, 

your Honor. 

THE COURT: I appreciate your 

vigorousness, but this court generally has some 

difficulty with 30 minutes. 

Mr. Honeycutt, what is your preference? 

MR. HONEYCUTT: An hour would be okay. 

THE COURT: Okay. Thank you, 

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Mr. Vines, for that offer, but I think the rest 

of us need a restored restoration. We'll come 

back here at 1:30 exactly. 

Please come up to the witness stand, 

and we'll get started at that time. 

We can go off the record. 

(Whereupon, a brief recess was taken.) 

THE COURT: We're back on the record in 

the matter of Worldwide Aircraft Services, Inc. 

This is Docket No. FAA-2013-0045. 

We've reconvened after a one-hour lunch 

recess. All parties previously identified have 

returned to the hearing room. Mr. Singleton has 

reseated himself in the witness chair. 

Sir, you are still under oath. 

THE WITNESS: Yes, ma'am. 

THE COURT: Mr. Vines, before we 

continue, I just note that you've taken your 

jacket off, is it hot in here or did you --

MR. VINES: I'm sorry, I'm thinking 

we're still on our lunch break. 

THE COURT: You are okay? 

MR. VINES: Yes. 

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THE COURT: All right. 

Mr. Vines has put on his jacket and 

looks like we're ready to proceed. 

Unless, Mr. Vines, do you have any 

preliminary matters? 

MR. VINES: No, Judge. 

THE COURT: Mr. Honeycutt? 

MR. HONEYCUTT: No, your Honor. 

THE COURT: Mr. Honeycutt, I should 

mention that we did talk about having you have 

Ms. Aleski testify this afternoon. So I would 

ask that you be sure to have her appear by 3:00 

today so that we can get her in no matter what. 

MR. HONEYCUTT: She is here, your 

Honor. 

THE COURT: Excellent. Thank you. 

Mr. Vines, before we recessed for 

lunch, you were in the middle of your direct 

examination with Mr. Singleton, would you care to 

continue? 

MR. VINES: Yes, Judge, I will pick up 

where I left off. There was a question that I 

asked that, your Honor, didn't allow to 

ultimately be answered by the witness, so I will 

rephrase that question. 

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1 BY MR. VINES: 

2 Q. Inspector Singleton, would you expect Brandon 

3 Plas, who is an employee of Worldwide Aircraft, to 

4 have documented the damage he observed to the GPU 

5 receptacle, that being the bent prongs, in the 

6 companies aircraft-discrepancy form? 

7 

8 

9 

A. 

Q. 

A. 

Yes, I would have expected that. 

Why is that? 

It is -- it is directly in the Worldwide 

10 Aircraft's General Operations Manual in paragraph E-36 

11 that the pilot should do that. 

12 Q. What if I take your attention to paragraph F-1, 

13 which is found on Exhibit C-13N as in Nancy. 

14 

15 

16 

17 

18 

19 

20 

A. 

Q. 

Yes. 

In your opinion, would that also be applicable to 

THE COURT: I'm sorry, would you speak 

up, please. Was that C-13N as in Nancy or C-130 

as in orange? 

MR. VINES: I'll repeat that. 

21 BY MR. VINES: 

22 Q. If you'll take a look at paragraph F-1, 

23 Worldwide's General Operations Manual, have you had 

24 the chance to look at that paragraph? 

25 A. Yes, I have. 

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1 Q. In your opinion, would you also find that 

2 applicable to the issue involving the bent prongs and 

3 the GPU receptacle? 

4 

5 

6 

7 

8 

9 

10 

11 

A. 

BY 

Q. 

A. 

Yes. 

THE COURT: I'm sorry, which paragraph 

was that, please? 

MR. VINES: F-1. 

THE COURT: Thank you. 

MR. VINES: 

Why do you find that applicable? 

This paragraph also states that the pilot is 

12 required to report any mechanical irregularities. 

13 Q. I believe you testified earlier that you believed 

14 that the bent prongs constituted a mechanical 

15 discrepancy. There is obviously a term that is also 

16 included in the General Operations Manual by the term 

17 of Mechanical Irregularity, do you differentiate 

18 between those two terms? 

19 A. I don't have a textbook definition. I could make 

20 an assumption of what is maybe the spirit of the 

21 language. 

22 

23 

24 

25 

Q. 

A. 

Okay. 

An irregularity is something that the pilot --

MR. HONEYCUTT: Your Honor, we object 

to the witness' assumption of what irregularity 

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means if we don't have a definition. 

THE COURT: There's an objection 

raised. Mr. Vines, do you have a response? 

MR. VINES: The witness has been 

qualified as an expert in general maintenance. I 

would ask, based on that, of his experience, he 

can testify or opine as to what specifically that 

term means and how it is used in the industry, 

Judge. 

THE COURT: I'll sustain the objection 

in terms of the form of the question and strike 

the answer that has currently been provided to 

that question. This witness can certainly 

testify as to whether he knows if there is such a 

distinction in his own experience and training. 

This witness can certainly testify as 

to whether he has had any types of real-time 

experiences regarding the distinction. He can 

testify about any number of things, but I would 

agree with the Respondent that speculation is 

beyond the scope of the witness' testimony. 

MR. VINES: I'm happily rephrase, your 

23 Honor. 

24 BY MR. VINES: 

25 Q. Have you, in your experience as a Maintenance 

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1 Inspector, come across the term mechanical discrepancy 

2 or mechanical irregularity? 

3 

4 

A. 

Q. 

Yes. 

Based on those terms, are you able to abide a 

5 definition as they are used in the Maintenance 

6 Industry? 

7 

8 

9 

A. 

Q. 

A. 

Yes. 

What would those be? 

An irregularity, in my experience, is a fault 

10 generally seen on an electronic-display system, maybe 

11 a fault that comes and goes or anything that is not a 

12 hard fault, which means a light comes on and stays on. 

13 An irregularity, for example, one is a light 

14 would blink, went out, and hasn't come back on for the 

15 duration of a flight or a flight cycle. 

16 A discrepancy, in my experience, is a harden 

17 fault, something you can point to and see as a 

18 discrepancy system operating improperly for example. 

19 Q. Would you characterize the bent prong, GPU 

20 receptacle as a mechanical irregularity, mechanical 

21 discrepancy, or both? 

22 A. I could characterize it as a aircraft 

23 discrepancy. 

24 

25 

Q. I would direct your attention to Exhibit C-10 

that's been admitted into evidence. Please take a 

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1 minute to review this document. 

2 

3 

4 

A. 

Q. 

A. 

Okay. 

What is your understanding of this document? 

My understanding of the document is it appears to 

5 be a statement from Brian Fanning, the Chief of 

6 Maintenance, from JET I.C.U. to Frank Schaefer 

7 describing an issue with the GPU receptacle and the 

8 skin around it. 

9 Q. And there's a particular portion of that 

10 statement that addresses a small amount of damage to 

11 the non-structural section of the fuselage skin, I 

12 would like to talk with you about that issue for a 

13 minute. First of all, did you consider that as part 

14 of your testimony today? 

15 

16 

A. 

Q. 

Yes, I did. 

And what exactly is when the Chief of 

17 Maintenance, Brian Fanning, refers to the statement 

18 non-structural section of the fuselage skin, in your 

19 experience, what is a non-structural section versus a 

20 structural section of the aircraft? 

21 A. A structural section or what is referred to as 

22 primary structure of an aircraft is the structure that 

23 takes up or bears the load of the aircraft in flight 

24 in its entirety, and non-structural or the proper term 

25 is secondary structure, that structural parts that 

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1 maybe support a device or support a lighter component 

2 of the aircraft. Without it, it does not make up the 

3 structural section of the airplane. 

4 Q. Can you provide some examples of the secondary 

5 structure or non-structural section of the aircraft or 

6 fuselage skin in this case? 

7 A. Brackets that would hold a component on such as a 

8 hydraulic (inaudible) or, in this case, perhaps the 

9 GPO plug assembly is what's held to the aircraft as 

10 nonstructural. 

11 Q. And I believe you testified earlier what the 

12 fuselage meant in your experience; is that correct? 

13 

14 

A. 

Q. 

I did, yes. 

What about skin of the aircraft, can you describe 

15 what a mechanic would refer to as skin of the 

16 aircraft? 

17 A. The skin of the aircraft is the outer most medal 

18 structure of the aircraft that provides the structural 

19 integrity or the shape of the aircraft. It provides 

20 all of the structural integrity of the aircraft. 

21 Q. I want to direct your attention now to Exhibit 

22 C-11. Please take a moment to look over that, please. 

23 A. Okay. 

24 Q. What is your understanding of this document? 

25 A. This appears to be a maintenance-record entry for 

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1 N90LJ concerning a replacement of the GPU receptacle, 

2 brackets, and a skin repair. 

3 Q. You talked earlier that part of your duties with 

4 the FAA is to review maintenance entries for aircraft; 

5 is that correct? 

6 

7 

A. 

Q. 

Yes. 

So it is it fair to say you've seen this type of 

8 document before? 

9 

10 

A. 

Q. 

Yes. 

And if you would, in your experience as a 

11 mechanic, would you please describe to the Court, 

12 we'll start with paragraph one, what you interpret 

13 this document to be specifically in paragraph one as a 

14 mechanic. 

15 A. As I stated before, this document is a 

16 maintenance-record-log entry form for N90LJ. Number 

17 one, paragraph one, indicates that a GPU receptacle 

18 was replaced on the aircraft as a component. 

19 Q. And the description where it reads P4/N, can you 

20 describe what that means in paragraph one? 

21 A. Yes, that indicates a part number of this 

22 component. Manufacturers provide what's called 

23 illustrated parts list or illustrated parts of break 

24 down, which identifies each and every piece of the 

25 aircraft by part number. 

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1 When something has to be replaced, this manual is 

2 referred to so the appropriate or correct part can be 

3 ordered for that aircraft. This indicates to me that 

4 part No. MS3506-1 was the receptacle that was 

5 replaced. 

6 Q. I want to focus on the term replaced at this 

7 time, is there an industry definition outside the 

8 general layperson's understanding of the term 

9 replaced? 

10 A. Replaced is removing of the old one and 

11 installing of a new one. 

12 Q. I'll direct your attention to paragraph two of 

13 Exhibit C-11. Would you please provide your 

14 interpretation as to what occurred in paragraph two? 

15 A. It appears that they replaced the GPU mounting 

16 brackets also showing part numbers, a replacing of a 

17 receptacle is in paragraph one. In some cases when 

18 you replace a component, you have to replace 

19 surrounding brackets with it. This may have been the 

20 case on this one. 

21 

22 

Q. 

A. 

And what purpose do the brackets serve? 

The brackets support the GPU receptacle in its 

23 mounted position. 

24 

25 

Q. 

A. 

As to paragraph three, same question. 

Paragraph three indicates to me that there was 

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1 skin damage to the aircraft, and it was reworked or 

2 repaired, which really are interchangeable terms, an 

3 area aft and below of the GPU receptacle. It appears 

4 they installed 2024-TJ, 40,000 doubler and filler. 

5 Those numbers indicate the type and the hardness of 

6 the aluminum skin that was replaced. They did it per 

7 20/30 series SRM, Chapter 50-40-02 and 51-70-02. 

8 

9 

Q. 

A. 

And what is that referring to? 

That is a Manufacturer's Structural Repair 

10 Manual. 

11 Q. So is it fair to say in the aircraft-maintenance 

12 arena, maintenance is usually performed pursuant to 

13 some type of manufacturer's instructions? 

14 

15 

A. 

Q. 

Yes, it is required. 

I want to ask you now based on the Exhibit C-10, 

16 the statement of Chief of Maintenance, Brian Fanning, 

17 in concert with Exhibit C-11, which is the 

18 maintenance-record entry-- actually I'll withdraw 

19 that. I'll direct your attention to Exhibit C-12. 

20 Have you seen this document before? 

21 

22 

23 

A. 

Q. 

A. 

Yes. 

What is your understanding of this document? 

This document appears to be a statement regarding 

24 the previous maintenance-log entry on Exhibit C-11. 

25 This seems to be a more descriptive narrative of that 

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1 maintenance-log entry. 

2 Q. Is there any specific portion of C-12 that you 

3 considered as part of your testimony today? 

4 

5 

6 

A. 

Q. 

A. 

Yes. 

What is that? 

The more descriptive narrative indicates that 

7 there was a bent plug in the GPU box assembly and that 

8 there's approximately a half-inch damaged area to the 

9 aircraft skin. It goes on to describe how they 

10 repaired that, how this mechanic repaired that area. 

11 Q. When you say this Exhibit C-12 references a GPU 

12 assembly, is that the same thing as a receptacle or is 

13 that something completely different? 

14 A. The GPU box assembly that is indicated on this 

15 statement, it is the same as a GPU receptacle. 

16 Q. Based on Exhibit C-10, as well as the other 

17 information that you considered including C-11 and 

18 Exhibit C-12, are you able to draw a conclusion as to 

19 whether, again from Exhibit C-10, small amount of 

20 damage to the non-structural section of the fuselage 

21 skin, that was reportedly found on N90LJ, does that 

22 constitute a failure or malfunction of the airframe? 

23 

24 

25 

MR. HONEYCUTT: Your Honor, objection. 

He is leading the witness. 

THE COURT: Your objection is noted. 

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1 It is sustained. 

2 BY MR. VINES: 

3 Q. What, if any, conclusion have you drawn regarding 

4 whether a small amount of damage to the non-structural 

5 section of the fuselage skin just aft of the GPU 

6 receptacle on N90LJ constitutes a failure or 

7 malfunction of the airframe? 

8 

9 

10 

11 

12 

A. 

Q. 

A. 

Q. 

I'm not sure I understand the question. 

Sure. I'll repeat it. 

Sorry. 

What conclusion, if any, have you drawn -- I'll 

repeat it as to whether a small amount of damage to 

13 the fuselage skin --

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MR. HONEYCUTT: Again, your Honor, I 

think he is leading with the damage and the small 

amount. 

THE COURT: I think your objection is 

premature. I'll wait until the question is 

completed. 

Mr. Vines, please proceed. 

And, Mr. Witness, there may be an 

objection at the end of this question, so if you 

could wait. 

Mr. Vines. 

MR. VINES: Sure. 

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1 BY MR. VINES: 

2 Q. What, if any, conclusion have you drawn regarding 

3 whether a small amount of damage to the non-structural 

4 skin of the fuselage on N90LJ that is reported by 

5 Brian Fanning on C-10, would constitute a failure on 

6 the function of the airframe? 

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THE WITNESS: Can I answer? 

THE COURT: You may answer. 

THE WITNESS: The conclusion I've drawn 

from --

MR. HONEYCUTT: Your Honor, I thought 

we were waiting for -- I'm sorry, I didn't know 

if you were -- did you rule? 

THE COURT: I said your objection was 

premature 

MR. HONEYCUTT: Oh, okay. 

THE COURT: because there hadn't 

been a complete answer or question provided, and 

then I directed the witness to wait for a moment 

to see if you were going to object once you heard 

the whole question. We didn't hear any objection 

so the witness started to answer and then I'm 

hearing from you --

MR. HONEYCUTT: I'm objecting, your 

Honor, I didn't hear the part of waiting to see 

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if Mr. Honeycutt objects. 

THE COURT: And what lS the basis of 

your objection? 

MR. HONEYCUTT: Again, I feel like he 

is leading the witness. 

THE COURT: Your objection is noted and 

it is overruled. The question Incorporated what, 

if any, conclusions did you draw. So this 

witness can answer that question in a narrative 

form however he sees fit. 

Do you remember the question, sir? 

THE WITNESS: Yes, ma'am. 

THE COURT: You may answer. 

THE WITNESS: The conclusions that I 

draw reviewing Exhibit C-10, 11, and 12 are that 

there was damage to the GPU receptacle in an area 

of skin on the aircraft. Almost regardless of 

Mr. Fanning's statement of no damage to the pins, 

it appears that the GPU receptacle, its mounting 

brackets, and the skin was, in fact, repaired and 

21 appears to be properly documented in the 

22 air-maintenance log. 

23 BY MR. HONEYCUTT: 

24 Q. What was documented in the aircraft-maintenance 

25 log? 

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2 

A. 

Q. 

The repair of the aircraft. 

Do you have any opinion, if any, any as to 

3 whether the damage of the skin that was reported by 

4 Brian Fanning constitutes a failure or malfunction of 

5 the airframe? 

6 A. I do. I believe that it constitutes damage to 

7 the airframe. 

8 Q. Specifically, I want to direct your attention to 

9 two terms, and that is a failure or malfunction of the 

10 airframe. What opinion, if any, do you have regarding 

ll whether the tear in the aircraft skin, what about 

12 Brian Fanning constitutes a failure or malfunction of 

13 the airframe? 

14 A. I don't believe it constitutes failure or 

15 malfunction. 

16 

17 

Q. 

A. 

Why is that? 

A failure or malfunction, those terms are used 

18 where it would be -- a failure of the airframe is 

19 something that happened to wear or overloading of a 

20 component. A malfunction is perhaps a system failure. 

21 Q. So it is your belief that it just constitutes 

22 damage? 

23 

24 

A. 

Q. 

Yes. 

I want to move on now to a matter that's been 

25 discussed in prior testimony. Again, you sat through 

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1 the proceedings in this case, and there was testimony 

2 that the Aircraft N90LJ had departed from Brooksville 

3 Airport on May 3, 2009 with a GPU unit attached to the 

4 aircraft, is that familiar to you? 

5 

6 

A. 

Q. 

Yes. 

And are you -- do you have any opinion -- what, 

7 if any, opinion do you have regarding whether or not 

8 that action, again taxiing and taking off this 

9 aircraft with the GPU unit attached and how it relates 

10 to the damage, and I'll be more specific, the bent 

11 prongs and a tear in the aircraft skin, do you have 

12 any opinion of how those two could be related? 

13 

14 

15 

A. 

Q. 

A. 

Yes. 

And what would that be? 

I believe the two are directly related. Damage 

16 is generally caused by an external source, not meaning 

17 GPU, but an external force on the airplane. 

18 If you have a GPU attached, then the damage that 

19 was observed or stated in some of the statements here 

20 and that I've heard in testimony, would be consistent 

21 with a GPU being left attached to the aircraft. 

22 Q. You've also heard testimony, as you've been in 

23 court, from testimony from Brian Fanning, Chief of 

24 Maintenance for the Respondent, he testified that --

25 I'll withdraw that. 

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1 Let me take your attention back to Exhibit C-11, 

2 please. There was testimony from Brian Fanning, Chief 

3 of Maintenance for the Respondent, that the 

4 maintenance that is referenced in paragraph C-11 

5 constitutes an improvement. Do you recall hearing 

6 that testimony? 

7 

8 

A. 

Q. 

I do. 

Okay. What, if any -- let me ask you, do you 

9 agree or disagree with Mr. Fanning's testimony? 

10 

11 

12 

A. 

Q. 

A. 

I disagree. 

Why is that? 

Improvements to an aircraft skin are not allowed 

13 unless you have a field approval or if there is a 

14 supplemental-type certificate, referred to as a STC. 

15 There has to be a reason for the improvement. It is 

16 generally not just part of a repair. 

17 Q. So if I understand you correctly, your testimony 

18 was that the maintenance reference in paragraph three 

19 of Exhibit C-11 was a repair, not an improvement? 

20 

21 

A. 

Q. 

Correct. 

You testified that you've been with the FAA for 

22 awhile, for six years, how long have you been -- and 

23 obviously you received your AP in 1986? 

24 

25 

A. 

Q. 

Correct. 

So going on approximately 30 years that you 

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1 worked in the Aviation Industry? 

2 

3 

4 

5 

A. 

Q. 

A. 

Q. 

Yes. 

Specifically in maintenance? 

Yes. 

What, if any, opinion do you have of the need or 

6 the requirement that damage or mechanical 

7 irregularities or mechanical discrepancies be 

8 documented in aircraft-maintenance logs? 

9 A. It is the only -- documentation is the only 

10 vehicle that maintenance has to repair an aircraft if 

11 there is damage or an irregularity. Without 

12 documentation, we don't know that there is anything 

13 wrong. 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

MR. VINES: Your Honor, I am finished 

with my direct at this time. 

THE COURT: Thank you. 

Mr. Singleton, before we go into cross, 

do you need any water? 

THE WITNESS: No, ma'am. I'm okay. 

THE COURT: Mr. Honeycutt, are you 

ready for your cross-examination? 

MR. HONEYCUTT: May I have five 

minutes, your Honor? 

THE COURT: You may. 

Maybe we can take a quick recess for 

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everyone's comfort. So a five-minutes recess. 

Please be back in the witness chair. 

We can go off the record. 

(Whereupon, a brief recess was taken.) 

THE COURT: We're back on the record in 

the matter of Worldwide Aircraft Services, Inc. 

This is Docket No. FAA-2013-0045. 

We've reconvened after approximately a 

five-minute recess. All parties previously 

identified have returned to the hearing room, and 

the witness, Mr. Singleton, has reseated himself 

in the witness chair. 

Sir, you are still under oath. 

THE WITNESS: Yes, ma'am. 

THE COURT: Mr. Honeycutt, do you have 

any cross-examination? 

MR. HONEYCUTT: I do, your Honor. 

20 Thank you. 

21 - - - - -

22 CROSS-EXAMINATION 

23 - - - - -

24 BY MR. HONEYCUTT: 

25 Q. Mr. Singleton, I misplaced your resume. 

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2 

3 

4 

MR. HONEYCUTT: Do you have his resume? 

MR. VINES: It is marked as an exhibit. 

MR. HONEYCUTT: I'm sorry, I have it. 

THE COURT: Very good. 

5 BY MR. HONEYCUTT: 

6 Q. Mr. Singleton, I studied your resume. You have a 

7 lot of experience and most of your experience in 

8 maintenance looks to be as a 121 Air Carrier type of 

9 mechanic which is accordant with mostly Airlines? 

10 

11 

A. 

Q. 

Yes, sir. 

I did see on your resume, that's why I'm asking, 

12 have you worked for a company or been around an 

13 aircraft similar to what JET I.C.U. Worldwide operate 

14 in the fact of mid size, small jet? 

15 

16 

A. 

Q. 

No, sir, I've never been employed by them. 

But an airplane is an airplane, I agree with 

17 that, right? 

18 

19 

20 

THE COURT: I'm sorry, you need to 

answer yes or no. 

THE WITNESS: Yes. 

21 BY MR. HONEYCUTT: 

22 

23 

Q. I want to go over the damage and the malfunction 

part of your testimony earlier with Mr. Vines. Damage 

24 is not a discrepancy -- a discrepancy is a hard fault 

25 or a failure, for example, discrepancy being something 

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1 that is not curable, it is continuous; is that 

2 correct? 

3 

4 

A. 

Q. 

Yes, sir. 

So a discrepancy maintains itself as not working 

5 properly? 

6 

7 

A. 

Q. 

Yes, sir, I agree with that. 

And a malfunction, as you said, is something more 

8 of a anomaly that may happen, may never go away, it 

9 may never be repeated? 

10 A. No, sir, I believe I stated that irregularity 

11 could be an intermittent fault, not a malfunction. 

12 Q. So again, an irregularity is something that may 

13 happen but never duplicated again? 

14 

15 

A. 

Q. 

That's correct, sir. 

And then a malfunction is between a discrepancy, 

16 which is a continuous hard fault and an irregularity? 

17 A. No, I would say a malfunction is a failing 

18 system. 

19 Q. So I'm sorry, discrepancy and malfunction 

20 constitute it is not working properly? 

21 

22 

23 

24 

A. 

Q. 

A. 

Q. 

Correct. 

Okay. And an irregularity may come and go? 

Yes. 

All right. In your 121 background, have you 

25 served as a line mechanic on a station, for example, 

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1 you know, for an airline based at an out station or at 

2 the main base? 

3 

4 

A. 

Q. 

Yes, I have. 

Have you ever seen an aircraft in your time as a 

5 line mechanic with a dent or any type of skin anomaly? 

6 

7 

A. 

Q. 

Yes, numerous times. 

Were those aircrafts considered airworthy or 

8 unairworthy? 

9 A. The discrepancies were written up, inspected, and 

10 then the aircraft was returned to service. 

11 

12 

Q. 

A. 

With a dent remaining? 

Yes, sir, if the dent was within the allowable 

13 tolerance of the maintenance manual, yes. 

14 Q. So the aircraft manufacturer or the manufacturer 

15 would have that in its maintenance manual, a 

16 tolerance, if you were to come across a dent, it would 

17 say your tolerance is certain size, certain height, 

18 certain depth? 

19 

20 

A. 

Q. 

Yes, sir. 

And if it is not beyond that, it is considered to 

21 be airworthy, non structural, non damaging? 

22 

23 

A. 

Q. 

That's correct, or they would have a reinspect 

I agree that they would have a continued 

24 inspection program at that point, but there is a 

25 tolerance level that the manufacturer 

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2 

3 

4 

5 

6 

A. 

Q. 

Yes, sir. 

-- puts out and makes money? 

THE COURT: And there was a continue of 

that question, I'll need an answer to that part. 

THE WITNESS: Yes, ma'am. 

THE COURT: Thank you. 

7 BY MR. HONEYCUTT: 

8 Q. Are you familiar with the Learjet Maintenance 

9 Manual in that aircraft family, Learjet being LR Jet 

10 which goes from a Lear 23 all the way to a Lear 55? 

11 

12 

A. 

Q. 

I'm familiar with it just in my FAA experience. 

Just having seen it, but not having used it on a 

13 daily basis or been involved in that type of 

14 maintenance with that type of manual 

15 

16 

17 

18 

A. 

Q. 

A. 

Q. 

That's correct. 

-- for a Learjet? 

Correct. 

So you can't testify if there is in that manual a 

19 tolerance for a dent or something of that nature on 

20 that skin without reviewing that manual? 

21 

22 

A. 

Q. 

No, sir, I can't. 

Have you reviewed that manual for the incident in 

23 question for 90LJ? 

24 

25 

A. 

Q. 

No, Slr. 

Okay. Do you know if Inspector Schaefer did, in 

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1 your investigation and reviewing of the EIR in 

2 speaking with Inspector Schaefer, do you know if he 

3 reviewed that? 

4 A. No, sir, I don't know. 

5 Q. And therefore the Learjet typed-data sheet that 

6 we talked about earlier, earlier when you talked about 

7 an aircraft typed-data sheet and also I believe an 

8 Inspector Donahue brought that up, as well as Kahler, 

9 that the aircraft is certified with a typed-data sheet 

10 and all that is listed on that typed-data sheet? 

11 

12 

13 

14 

A. 

Q. 

A. 

Q. 

No, sir, not all the equipment. 

Not all the equipment? 

No, sir. 

Well the equipment -- well, you mean supplemental 

15 types, anything other than what was originally 

16 designed on the typed-data sheet, anything added to 

17 the data sheet would be considered a supplemental 

18 typed data, correct? 

19 A. Yes, sir. However, the typed-data sheet, which 

20 you started alluding to is the basic aircraft, it 

21 doesn't include avionic instrumentation, things of 

22 that nature, it is more of the airframe and engines. 

23 Q. Okay. Well we can move into the components is 

24 where I was going, because certain components of the 

25 aircraft are not manufactured by the manufacturer of 

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1 the airframe, for example, an engine is usually 

2 manufactured by another company than a Learjet 

3 assessment or lulling for example; is that correct? 

4 

5 

A. 

Q. 

Yes, sir. 

And is it common in the industry for that company 

6 that would thus use a GPU receptacle, if there is a 

7 company that makes the GPU receptacle, would it set 

8 its on tolerances or would Learjet set the tolerance 

9 for that? 

10 

11 

A. 

Q. 

Learjet would set the tolerance for that. 

Learjet would set the tolerance to what the 

12 (inaudible) would be able to be tolerant to? 

13 

14 

A. 

Q. 

Yes, sir. 

Okay. Does Learjet set a tolerance on the 

15 General Electric CJ610 engine fan blaze? 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

MR. VINES: Objection, relevancy. 

MR. HONEYCUTT: The relevance, your 

Honor, is that it goes to the aircraft. 

the typed-data sheet as the engine is 

It is on 

manufactured by General Electric. It is on the 

Learjet CJ610, and it is listed on a Learjet 

typed-data sheet. 

I'm asking the witness, in his opinion, 

the blade tolerances if you have a crack or a 

dent in the blade, would you refer to Learjet or 

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would you refer to the GE Manual to determine 

what tolerances that blade would have. 

THE COURT: As I understand it, you are 

trying to discover the scope of this witness' 

expertise? 

MR. HONEYCUTT: No, ma'am, the point 

I'm trying to prove is that certain points and 

components of the airplane have its own 

tolerances by its own manufacturer, therefore not 

listed on the typed-data sheet. You would have 

to go to that specific manufacturer to determine 

the tolerance. 

THE COURT: I'm going to sustain the 

objection. Since I think you can address that 

question far more directly with this witness, 

rather than going through a variety of different 

parts of the Learjet that have no relevance with 

this particular case. 

MR. HONEYCUTT: Okay. 

THE COURT: You are welcome to inquire 

21 on this particular topic, but in a more direct 

22 way, if you would be so kind. 

23 BY MR. HONEYCUTT: 

24 Q. Mr. Singleton, would you be able to tell me, we 

25 talked about the bent plug, and it is your testimony 

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1 that the bent plug is considered to be a damaged plug? 

2 

3 

4 

5 

A. 

Q. 

A. 

Q. 

Yes, that is correct. 

And what constitutes the damage to the plug? 

It is no longer in its original configuration. 

And there I'm asking how would you determine the 

6 original and if there was a tolerance to that? 

7 A. If there was a tolerance, it would be in the 

8 Learjet Maintenance Manual. 

9 Q. Okay. So we would have to go to the Maintenance 

10 Manual to determine if there was a tolerance? 

11 

12 

A. 

Q. 

Yes, sir. 

Okay. How would you determine if it functioned 

13 properly? 

14 A. You would have to plug the GPU into the 

15 receptacle to see if it functioned properly. 

16 Q. And that function being turn the GPU on and if 

17 the aircraft received the power from the GPU, then the 

18 plug would function properly, the receptacle would be 

19 therefore 

20 

21 

22 

23 

24 

A. Yes. 

Q. -- operating as it is designed to operate? 

A. Yes. 

Q. Thank you. I'm going to direct you back to --

you stated that I want to go over that skin damage 

25 was not considered to be a discrepancy or malfunction, 

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1 correct? 

2 

3 

A. 

Q. 

I'm not sure I understand 

The alleged damage of the skin, the repair that 

4 Mr. Vines referenced is in Exhibit C-11 --

5 

6 

A. 

Q. 

Yes, sir. 

-- I think it was your testimony that it was not 

7 a discrepancy or not a discrepancy or alleged skin 

8 damage was not a discrepancy or malfunction. 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

MR. VINES: I'm going to object, Judge. 

The question is compounded, and moreover, the 

Respondent referring to C-11 regarding the 

alleged skin damage, I don't see -- it just goes 

to mischaracterization. I don't see in C-11 that 

there was skin damage, rather it is in C-10. 

THE COURT: There's been an objection. 

Do you have a response? 

MR. HONEYCUTT: I can rephrase, your 

Honor. 

THE COURT: The objection is noted and 

respectfully rendered moved. The question is 

21 withdrawn, and you are welcome to rephrase. 

22 BY MR. HONEYCUTT: 

23 Q. Mr. Singleton, if you'll look at Exhibit C-11, in 

24 your expert testimony, the maintenance-log entry that 

25 goes in the permanent aircraft-maintenance log, and as 

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1 we've discussed, can you determine from number one, 

2 replace GPU receptacle PNMS3506-l, if that is a 

3 Learjet part or if that's an outside manufacturer 

4 part? 

5 

6 

7 

8 

A. 

Q. 

A. 

Q. 

I can't determine that. 

You would have to look that up? 

Yes, sir. 

All right. Number three, if I read this 

9 correctly, rework the area aft, below the GPU 

10 receptacle, installed as you said, 2024-T3.04 doubler, 

11 which is the size of aluminum, type of aluminum, and 

12 filler, per the 2030 Series SRM Chapter 51, would you 

13 be able to see that if someone had made that, as you 

14 said a repair, would you be able to see that if you 

15 were to inspect the aircraft? 

16 

17 

18 

19 

A. 

Q. 

A. 

Q. 

Yes, sir. 

It would be obvious to you? 

Yes, sir. 

Also you talked about it not being an additive, 

20 what was Brian's statement that he used, an 

21 enhancement --

22 

23 

24 

25 

MR. HONEYCUTT: I forget, your Honor. 

THE COURT: If I recall, and Mr. Vines 

can chime in, I believe there was an assertion 

that it was an improvement. 

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5 

MR. HONEYCUTT: Improvement. Thank 

you, your Honor. 

THE COURT: Mr. Vines, would you agree 

to that? 

MR. VINES: Yes, Judge. 

6 BY MR. HONEYCUTT: 

7 Q. I believe you testified that that would not be an 

8 improvement, number three, the adding the 2024-T3 

9 doubler? 

10 

11 

A. 

Q. 

That's correct. 

But I believe this is the Learjet Series 

12 Maintenance Manual that we're referencing 2030 Series 

13 SRM? 

14 

15 

A. 

Q. 

Yes. 

Would that be a repair? I'm confused, could you 

16 explain to me what that Chapter 51-40-02 and 51-70-02, 

17 what would be classified in that manual? 

18 A. I'm not familiar with the chapters in the manual. 

19 The manual however is industry standard for 

20 manufacturers as a structural-repair manual. Every 

21 manufacturer comes up with how to fix their airplane, 

22 and those are instructions, chapters in the manual 

23 alluding to the instructions for that repair. 

24 Q. And it is a repair, it would not be considered an 

25 improvement or anything else? 

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1 

2 

A. 

Q. 

No, sir. 

Referring to Exhibit C-12, Mr. Handing's 

3 statement, this is a statement that's made after the 

4 log entry on Exhibit C-11, which was dated May 20th. 

5 This is a statement from, allegedly from Mr. Handing 

6 to Mr. Schaefer, dated June 17th. It talks about 

7 removing a bent GPU plug and box assembly. 

8 It says removed approximately a half-inch damaged 

9 skin from lower aft corner. Then it says fabricated 

10 installed doubler T3-2040 with an approximate size of 

11 

12 

four-and-a-half inches by six-and-a-half. It was slid 

through the skin and riveted to the SR109784SF. Is it 

13 your testimony that that was what's in the 51-40-02? 

14 

15 

16 

17 

A. 

Q. 

A. 

Q. 

Yes, sir. 

That procedure would be there? 

Yes, sir. 

All right. Mr. Schaefer's testimony, which I 

18 believe you said you spoke with Mr. Schaefer during 

19 our earlier discussions, C-6A and C-68. C-68, if you 

20 would --

21 

22 

23 

24 

A. 

Q. 

A. 

Q. 

Looking for it right now, sir. 

Okay. 

Okay. 

C-68, the second paragraph, the hot-line 

25 complaint stated the aircraft was taken to Brandis 

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1 Aircraft, located in Taylorville, IL. The aircraft 

2 has extensive damage and the skin peeled back like a 

3 banana. Inspector Schaefer inspected the aircraft, 

4 specifically the aft fuselage section and found no 

5 such damage. Do you believe that to be a true 

6 statement from Mr. Schaefer? 

7 

8 

A. 

Q. 

Yes, sir, as it is in his statement. 

It appeared a new GPU receptacle and doubler was 

9 installed. The surrounding panels were original as 

10 was the paint. 

11 THE COURT: Is there a question? 

12 BY MR. HONEYCUTT: 

13 Q. The question would be, we said earlier that Mr. 

14 Singleton would be able to spot the damaged-repaired 

15 area, and I'm curious, is his opinion of why Mr. 

16 Schaefer says he finds, specifically the aft fuselage 

17 section found no such damage. 

18 

19 

20 

21 

22 

23 

24 

25 

MR. VINES: I would object to the 

mischaracterization of Mr. Schaefer's statement. 

His statement says ''the aircraft has extensive 

damage and the skin peeled back like a banana", 

which the Respondent just quoted. 

Again, the Respondent quoted as to the 

following sentence from Inspector Schaefer's 

testimony, "Inspector Schaefer inspected the 

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aircraft, specifically the fuselage section and 

found no such damage.'' I would argue that the 

Respondent's characterization with the question, 

how is it that Mr. Schaefer reported or was told 

of the skin pulled back like a banana but no such 

damage was found, I would argue that contrary to 

the Respondent's insinuation that it was 

Inspector Schaefer who inspected the aircraft, 

but when he inspected the aircraft he didn't see 

any damage, because as you see in the paragraph, 

it had been repaired. So I object to the 

characterization of the Respondent's question. 

THE COURT: Thank you for that 

objection. I'm going to make a ruling without 

hearing a response. I'm going to sustain the 

objection, but not on the basis in which it is 

phrased, I'm going to sustain the question on the 

grounds that it is an unclear question. 

I heard something completely different 

from what Mr. Vines heard. I think I know what 

you were asking, but I think it would be helpful 

if you could rephrase the question so it is a 

little less confusion to those of us who are 

listening. 

MR. HONEYCUTT: Yes, ma'am. 

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7 

THE COURT: As I understand it, you are 

trying to ask this witness a question about how 

it is that this inspector would not see a repair 

if a repair could be noticed after it was done. 

It might be better if you phrase it in simplistic 

terms, if you can, maybe a couple questions. 

MR. HONEYCUTT: Okay. 

8 BY MR. HONEYCUTT: 

9 Q. It is your testimony earlier, Mr. Singleton, that 

10 after a repair of the type that is described in 

11 Exhibit C-12 and C-11, that it would be visible to 

12 you; is that correct? 

13 

14 

A. 

Q. 

I believe it would, yes, sir. 

And it is your testimony that Mr. Schaefer, in 

15 his written statement, that you concur that Mr. 

16 Schaefer makes in his statement that he inspected the 

17 aircraft and it appeared a new GPU doubler was 

18 installed and the surrounding panels were original as 

19 was the paint? 

20 

21 

22 

23 

24 

25 

MR. VINES: Again, I object to the 

characterization. 

THE COURT: Your objection is noted and 

respectfully overruled. I'm looking at Exhibit 

C-68, and it appears the question reflects what 

the statement says. It speaks for itself. 

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2 

3 

4 

5 

The document has been admitted into 

evidence. Do you have a question of this witness 

regarding his opinion about what this says? 

MR. HONEYCUTT: No, your Honor. 

THE COURT: Okay. Thank you. 

6 BY MR. HONEYCUTT: 

7 Q. Referring to Brian Fanning's statement on Exhibit 

8 C-10, Brian, in his statement, says that he inspected 

9 the aircraft after it returned and found external skin 

10 Frame 26, small amount of damage to the non-structural 

11 section of the fuselage skin, you don't see anywhere 

12 in there that talks about a tear or open to the skin? 

13 

14 

15 

16 

17 

18 

MR. VINES: Objection, Judge, the 

document speaks for itself. 

THE COURT: Objection is noted and 

respectfully overruled. 

This witness can answer. 

THE WITNESS: I don't see anywhere 

19 where it specifically notes a tear. 

20 BY MR. HONEYCUTT: 

21 Q. Thank you. Again, back to the Lear model 

22 Aircraft design, having worked mostly in the airline 

23 industry or larger-aircraft industry, do you know 

24 where the receptacle is on a Learjet, the Model Series 

25 in question, 90LJ25? 

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1 

2 

A. 

Q. 

It is on the right-hand aft section fuselage. 

Do you know if it is accessible any way from the 

3 inside? 

4 

5 

A. 

Q. 

I don't know that, sir. 

Are you familiar with what lS commonly called a 

6 term as the Hell Hole Access Panel? 

7 

8 

A. 

Q. 

Yes, sir. 

Can you describe to the Court what that access 

9 panel allows you to do as a mechanic or a pilot? 

10 A. Yes, sir, that panel allows you to inspect 

11 internally the aft section of the aircraft, multiple 

12 aircraft models, generally hold either aircraft engine 

13 (inaudible) engine hydraulic reservoirs, parts of the 

14 pneumatic system, the internal site as there are 

15 external power receptacles. 

16 Aft on the aircraft, you can see the inside of 

17 that power receptacle where the wires run from it to a 

18 Power Distribution System. In the case of some 

19 aircraft, you can see the tail flight control 

20 mechanisms in the area. 

21 Q. So you agree that by accessing that access panel 

22 into the rear of the aircraft, you would have the 

23 ability to inspect the backside of the receptacle box 

24 of the ground-power receptacle, as well as the wires 

25 that lead from the prongs to the electrical system? 

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1 

2 

3 

A. 

Q. 

Yes, sir. 

Thank you. Mr. Schaefer's statement--

MR. HONEYCUTT: I strike that, your 

4 Honor. 

5 BY MR. HONEYCUTT: 

6 Q. In any of your investigations and your studying 

7 of EIR, did anyone talk about questioning anyone in 

8 Marsh Harbour about this incident at MYAM? 

9 A. I believe there is one statement from a pilot 

10 that talks about, one of the pilots, I'm sorry, that 

11 talks about noting, a ground-crew member noting damage 

12 on the GPU receptacle. 

13 Q. So the pilot's statement, but nowhere else in the 

14 investigative file is there any mention of discussing 

15 this incident with anyone at the Marsh Harbour 

16 Airport? 

17 

18 

19 

20 

A. I don't recall seeing anything. 

Q. And would you agree looking at Brandon Plas, his 

statement -- let's move to Eric Price, C-9. If you'll 

review that one. I'll give you a minute to look over 

21 that. 

22 

23 

A. 

Q. 

Okay, sir. 

Anywhere in that statement does Mr. Price talk 

24 about anyone accessing the, access of area behind the 

25 fuselage and inspecting the receptacle that allegedly 

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1 

2 

3 

4 

5 

may 

A. 

Q. 

A. 

Q. 

have had damaged? 

Are you talking 

Yeah. 

No, sir, I don't 

And would it be 

about internally? 

see anything that says that. 

fair to say that you would agree 

6 that Mr. Plas, in his statement, it doesn't speak of 

7 being in the access area to inspect that receptacle? 

8 

9 

10 

11 

12 

13 

14 

A. That's correct. 

THE COURT: Just so we have a clear 

record, the Plas statement which you referenced 

is Exhibit C-8A and B; is that correct? 

MR. HONEYCUTT: Yes, ma'am, your Honor. 

THE COURT: Thank you very much. 

MR. HONEYCUTT: I apologize. 

15 BY MR. HONEYCUTT: 

16 Q. You also mentioned during your testimony earlier, 

17 I may be confusing with our discussion earlier or your 

18 testimony, that the pilot does a pre-flight inspection 

19 of the aircraft and the pilot of command ultimately 

20 has the determination if the aircraft is in an 

21 airworthy condition from physical aircraft, not 

22 necessarily maintenance required inspected items? 

23 A. The pilot has the diligence to verify maintenance 

24 records prior to accepting the aircraft. Once they 

25 accept the aircraft, then they (inaudible) 

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1 determinations made by a pilot and or co-pilot 

2 preflight and walk around the aircraft. 

3 Q. So in your testimony, a pilot has -- let me 

4 rephrase it -- a pilot has a determination -- it is 

5 his responsibility to determine whether the aircraft 

6 is in airworthy condition? 

7 A. Yes, sir. 

8 Q. I'm golng to the GOM Manual. Please go to E-3, 

9 which is exhibit C-13M. 

A. Okay. 

Q. Basically it says --

10 

11 

12 MR. HONEYCUTT: And I'll summarize, if 

13 that's all right, your Honor. 

14 BY MR. HONEYCUTT: 

15 Q. Basically a pilot in discovering a discrepancy 

16 will complete the MX-01 and contact the Director of 

17 Maintenance to have the mechanic to complete either a 

18 repair or an inspection inside the aircraft and assign 

19 it back as airworthy. Does that summarize that 

20 statement? 

21 

22 

A. 

Q. 

Yes, I believe it does. 

I just wanted to reiterate that your discrepancy 

23 is a hard fault? 

24 A. Can I clarify that a little bit, what I'm 

25 testifying to as a discrepancy? 

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1 

2 

Q. 

A. 

Yeah. 

A discrepancy is anything that can be written. A 

3 maintenance discrepancy is anything wrong with the 

4 airplane, whether it is a hard fault or intermittent. 

5 The word discrepancy is an anomaly with the aircraft 

6 that needs to be written up. 

7 Q. Okay. I understand what you're saying, but I was 

8 confused because that's why I specifically asked you 

9 earlier about discrepancy and your quote is ''a hard 

10 fault or failure", and that's where now we're going to 

11 say a discrepancy has multiple things that could be 

12 wrong, multiple definitions or are we going to stick 

13 with and say, "hard fault or failure"? 

14 A. I apologize for not having it in clearer context. 

15 As I was defining discrepancy, relative can be defined 

16 an irregularity at your request. There was another 

17 word you were using also, discrepancy or mechanical 

18 irregularity. A discrepancy is anything wrong to an 

19 airplane to a burnt out lightbulb or the engine not 

20 working. 

21 

22 

23 

24 

25 

Q. Okay. Can we go back to Mr. Plas' statement? 

MR. HONEYCUTT: Your Honor, if I may 

just quickly summarize it, if that is okay. It 

is Exhibit C-8A and B. 

THE COURT: Thank you. 

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1 BY MR. HONEYCUTT: 

2 Q. So basically Mr. Plas talks about, during his 

3 statement, leaving his base in Brooksville flying to 

4 TJSJ, which is San Juan, Puerto Rico to TDPD, which is 

5 the island of Dominica to MYAM, which is Marsh Harbour 

6 into the Bahamas on into Toronto, which is CYYZ. 

7 References departed in the morning and the bottom 

8 of the first page, 90 landed in San Juan for a fuel 

9 stop. Upon arriving in TJSJ, a GPU was connected and 

10 the aircraft was fueled both by a lineman. The fuel 

11 stop was normal, and the flight departed San Juan at 

12 1142z bound for TDPD where passengers would be picked 

13 up. 

14 Later on the next page, he goes on to say that 90 

15 landed in Dominica at 1236, and again had a lineman 

16 hook up the GPU and fueled the aircraft. Ninety 

17 parted Dominica at 1:48 with a passenger on board in 

18 route to Toronto with another fuel stop in Marsh 

19 Harbour. The flight again was normal and uneventful. 

20 Then we get into the paragraph where it says 

21 after landing in Marsh Harbour again requested to 

22 connect the GPU and fuel. This point he goes into 

23 that he was approached by the lineman and said he had 

24 problems plugging in the GPU. He attempted it and 

25 looked in and realized the bent plugs, I think he says 

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1 here or the pins were bent and that was not allowing 

2 the GPU plug. He calls the Director of Operations to 

3 discuss it and moves on. 

4 In Marsh Harbour, he departed at 1806 for Toronto 

5 and arrived. In the very last paragraph after the 

6 passenger was on his way, the PIC requested a GPU be 

7 plugged into the aircraft to see if the same problem 

8 would arise. The GPU plugged into the aircraft and 

9 worked fine. The aircraft was secured and the PIC and 

10 SIC went off duty. 

11 I asked you earlier in your testimony that how 

12 would you test a GPU receptacle to determine if it was 

13 functioning properly and I believe 

14 

15 

A. 

Q. 

Yes, sir. 

-- you said plug in the GPU and see if the 

16 aircraft would receive power? 

17 

18 

A. 

Q. 

Yes. 

And by doing so, you would come to the conclusion 

19 that the GPU receptacle was working? 

20 

21 

22 

23 

24 

25 

A. Yes. 

MR. HONEYCUTT: No more questions, your 

Honor. 

THE COURT: Thank you, Mr. Honeycutt. 

Mr. Vines, do you have anymore redirect 

for this witness? 

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1 

2 

3 

MR. VINES: Yes, Judge. 

REDIRECT EXAMINATION 

4 

5 

6 

BY MR. VINES: 

Q. As to the testimony that was elicited from you 

7 about the GPU receptacle not working, what is your 

8 opinion as to whether the GPU was working when the 

9 aircraft landed in MYAM on May 3, 2009? 

10 A. It would be my opinion that the pins were -- if 

11 they I'm sorry, when they landed in MYAM? 

12 Q. Yes. 

13 A. Okay. 

14 Q. I'm referencing Government Exhibit e-BB, it would 

15 be the third paragraph, which begins after landing in 

16 MYAM. 

17 A. In paragraph B the lineman-- I'm sorry, the PIC 

18 tried to plug in the GPU and noted that pins were 

19 bent. 

20 Q. And the pilot went on to say that because of the 

21 bent pins, it was not allowing the GPU plugged? 

22 

23 

A. 

Q. 

Correct. 

So from your testimony earlier, how would you 

24 characterize the status of the GPU at MYAM, was it not 

25 working or was it working? 

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1 

2 

3 

4 

5 

6 

A. 

Q. 

A. 

Q. 

A. 

Q. 

It was not working. 

Why wasn't it working? 

The pins were bent. 

Which therefore prevented what? 

The power applied to the aircraft via a GPU. 

Specifically the cord being inserted into the 

7 receptacle? 

8 

9 

A. 

Q. 

Correct. 

You testified earlier that a co-pilot has to 

10 determine whether an aircraft is airworthy, could you 

11 provide some more context to that, is it solely the 

12 pilot's responsibility to determine if the aircraft is 

13 airworthy? 

14 A. When a pilot takes an aircraft for flight, they 

15 have a responsibility to check the maintenance logbook 

16 prior to the flight, and then follow their operating 

17 handbook to do a walk around preflight and any company 

18 index or manuals, which would either further that walk 

19 around before preflight, and they make a determination 

20 if the aircraft is safe for flight. 

21 Airworthy is a generalized term that could be 

22 made about maintenance. It could be made by the 

23 pilots. It truly is a generalized statement. The 

24 pilots ensure, prior to flight, that the aircraft is 

25 safe for flight. Prior to the safe for flight is 

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1 verifying that the airplane has been signed off from 

2 maintenance as airworthy. 

3 Q. And in this particular case, if a discrepancy was 

4 found that you testified to earlier and if that 

5 discrepancy wasn't documented in an aircraft logbook, 

6 would a mechanic, would a mechanic know -- without 

7 that entry, would a mechanic know whether or not there 

8 was an issue with the aircraft? 

9 

10 

A. 

Q. 

No. 

You were testifying earlier that you were trying 

11 to explain the differences between an irregularity and 

12 discrepancy, and it is my understanding your testimony 

13 also involved to what constituted a malfunction. You 

14 were trying to clarify that. Could you please 

15 explain, clarify for me and for the record, what your 

16 testimony is regarding your understanding of or, at 

17 least your understanding in the realm of the 

18 maintenance industry, what is a malfunction versus a 

19 discrepancy versus an irregularity, if there is a 

20 distinction between the three? 

21 A. Yes, I believe there is a distinction between the 

22 three. A discrepancy, as I stated before, to the best 

23 of my knowledge, is any anomaly with the aircraft, 

24 anything that is broken or not working properly, not 

25 working, something of an electric pump of some sort is 

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1 an example. It can be running, but it is not making 

2 the appropriate pressure, that is a discrepancy. Yes, 

3 it is working, but it is not working to its full limit 

4 or capacity. It is a discrepancy. A burnt out light 

5 bulb in the cockpit can be a discrepancy, a worn tire 

6 can be a discrepancy. 

7 An irregularity, to the best of my understanding, 

8 is something that maybe not broken, but is something 

9 that needs to be further inspected to determine its 

10 airworthiness. Then there was a third? 

11 Q. The third term you were asked to discuss was 

12 malfunction. 

13 A. A malfunction, again the way I understand a 

14 malfunction, a malfunction is a more generalized term 

15 toward a system on the aircraft. Again, going back to 

16 let's say the electrical power, if you attempt to 

17 apply electrical power to the aircraft by turning on 

18 an electrical switch in the cockpit and you turn the 

19 switch to on and no electrical power comes on, the 

20 electrical-power system is malfunctioning. We don't 

21 know why. It would be written as a discrepancy in the 

22 aircraft-maintenance logs. 

23 Q. So would it be fair to say that discrepancy, 

24 irregularity, and malfunction are varying degrees of 

25 concern, is there a sliding scale for these three 

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1 terms? 

2 A. I think they carry equal weight. They all have 

3 to be inspected. The determination is made on whether 

4 or not the system or item, whatever was written up, is 

5 valid or not. 

6 Q. By inspected, who would be performing that I 

7 inspection? 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

A. Maintenance personnel, a mechanic. 

MR. VINES: Nothing further, Judge. 

THE COURT: Thank you. 

MR. HONEYCUTT: Your Honor, may I 

redirect or recross? 

THE COURT: You want to recross on the 

redirect? 

MR. HONEYCUTT: I just have a few 

questions. 

THE COURT: You are welcome to recross 

based on the redirect. You are limited to the 

scope of redirect. 

MR. HONEYCUTT: I know. 

THE COURT: You may continue. 

RECROSS-EXAMINATION 

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1 BY MR. HONEYCUTT: 

2 Q. A mechanic, we talked about earlier at a line 

3 station, as an airline, is he not -- do those 

4 mechanics not walk around the me aircraft, you know, 

5 in the day flights or in between scheduled flights and 

6 do, what they call, I believe it is a mind check, I'm 

7 not sure of the terminology that the airlines use, but 

8 basically an airplane comes in and does a mechanic 

9 walk around the aircraft? 

10 

11 

A. 

Q. 

Yes, sir, normally. 

Would you feel that a mechanic could determine if 

12 there was a tear in the skin? 

13 MR. VINES: Objection, Judge, that is 

14 outside the scope. 

15 BY MR. HONEYCUTT: 

16 Q. Talk about determining the safety of the flight 

17 and who determines the safety of the flight or if the 

18 aircraft was airworthy, you said a mechanic would have 

19 to sign it off as to determine if it was airworthy but 

20 on the go, I'm asking could a mechanic determine if a 

21 whole, a tear, or a dent, could he observe that? 

22 

23 

24 

25 

THE COURT: It is beyond the scope, 

Mr. Vines, but I'm going to allow the question 

because I think that this witness won't be around 

tomorrow. 

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1 So you may answer the question. 

2 BY MR. HONEYCUTT: 

3 Q. So mechanic doing a walk around on the flight, 

4 would he be able to tell that if there was a whole, a 

5 dent, or a tear in the skin? 

6 A. Yes, if the mechanic saw damage, they would write 

7 it up in Maintenance Manual for it. 

8 Q. Again, back to the pilot issue of determining the 

9 airworthiness of the airplane, we stated that the 

10 pilot in command checks the maintenance records that 

11 is available when the flight comes in and that tells 

12 him the cycles, dates, and time for the next scheduled 

13 maintenance, that determines to the pilot that the 

14 airplane is airworthy and is due for maintenance, 

15 correct? 

16 

17 

A. 

Q. 

Correct. 

Than the pilot does a pre-flight inspection to 

18 determine that the physical aircraft is airworthy? 

19 A. Correct, and in some cases as you've stated 

20 before, in addition to a mechanic doing a walk around, 

21 that does not alleviate the pilot's responsibility for 

22 a walk around. 

23 Q. No, no, the pilot does have to do a walk around. 

24 Thank you for that. You brought up the aspect of worn 

25 tires, I believe I heard. 

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A. Yes, sir. 

Q. And talking about a discrepancy, a worn tire 

1 

2 

3 could be a discrepancy. In your professional opinion, 

4 would one mechanic or one pilot have two different 

5 opinions of worn tires, being one saying that's too 

6 worn and unsafe and another possibly saying that that 

7 is okay, it still has tread? 

8 MR. VINES: I would object to that. I 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

believe the witness or the Respondent is calling 

on the witness to speculate as to what others 

would or would not do. 

THE COURT: I'm going to stop you. 

Your objection is noted and respectfully 

overruled. This is actually in the scope of 

recross given the example that this witness 

previously gave. 

You are welcome to answer as you see 

fit. 

THE WITNESS: Yes, ma'am. 

20 BY MR. HONEYCUTT: 

21 Q. Again, my question is, do you feel, as a 

22 professional in the industry, that you can have two 

23 individuals look at the same tire and one feels that 

24 the tire was worn behind its safely level and another 

25 one feels that it was within the safety level? 

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1 A. Yes, I believe that there could be two different 

2 opinions, which is why Maintenance Manuals with limits 

3 exist. 

4 Q. But a pilot or a mechanic standing there, in your 

5 opinion, that felt that it was within the safety 

6 level, he would not then write that up, would he and 

7 ask for a second opinion if he felt that the tire was 

8 safe, would that be your statement? 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

MR. VINES: Objection, same reason, 

Judge. 

THE COURT: Your objection is noted and 

respectfully overruled. 

You may answer as you see fit. 

THE WITNESS: Yes, ma'am. 

I believe that the statement you made 

is correct. I think that you can have two 

different people with two different opinions. If 

one person says that visually they think the tire 

is within limits, it would not be written up. 

20 BY MR. HONEYCUTT: 

21 Q. And the individual that would find the tire to 

22 be, unairworthy, in his opinion, would write it up on 

23 a discrepancy form as we discussed like Worldwide has 

24 MX-02, what would be the process that a mechanic would 

25 do once that MX-02 was given to him? 

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1 A. I don't know your company process, sir, but I'll 

2 speak to general maintenance. When a mechanic 

3 receives a discrepancy form, the first thing you do is 

4 pull up that Maintenance Manual with those limits and 

5 go out and determine whether that item is within 

6 limits or out of limits. If it is out, you continue 

7 on with the corrective action, which in that case, you 

8 would change the tire. 

9 Q. As the mechanic, you would probably use the Tire 

10 Manufacturer's Maintenance Manual to determine the 

11 thread requirement and the thickness of that, correct? 

12 A. Generally they would use an Aircraft Maintenance 

13 Manual. 

14 

15 

16 

Q. 

A. 

Q. 

Okay, but they would use the manual --

Yes, sir. 

-- and so they would out and determine -- has 

17 there been an instance where a discrepancy tire worn, 

18 a mechanic carne out and said, in your opinion, have 

19 you found this in the past that the tire meets 

20 recommendations, safety continue? 

21 

22 

23 

24 

25 

MR. VINES: I would object to the form 

of the question, Judge. 

MR. HONEYCUTT: He is an expert 

witness. I'm asking his opinion as an expert 

witness within the industry. 

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1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

THE COURT: There's been an objection, 

and Mr. Vines has an objection as he sees fit 

just as you have done. 

MR. HONEYCUTT: Yes, your Honor, I 

apologize. 

THE COURT: As I understand it, 

Mr. Vines, what is the basis of your objection, 

please? 

MR. VINES: Vague and unclear, Judge. 

THE COURT: Your objection is noted and 

respectfully sustained. You are welcome to try 

12 and ask the question in a clearer manner. 

13 BY MR. HONEYCUTT: 

14 Q. In your past experience, have you seen a 

15 discrepancy written up with a corrective action 

16 stating, found to be within tolerable limits? 

17 

18 

19 

20 

21 

22 

23 

24 

25 

A. 

Q. 

Yes, sir. 

Thank you. 

MR. HONEYCUTT: I have nothing else, 

your Honor. 

THE COURT: Thank you. 

Based on the recross, do you have any 

final redirect? 

MR. VINES: No, Judge, I do not. 

THE COURT: Okay. Thank you. 

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2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

Thank you, Mr. Singleton, for your 

testimony. It appears to be complete. You are 

hereby excused. 

THE WITNESS: Thank you. 

THE COURT: Folks, it is 3:00. We're 

going to run until 5 today. 

Mr. Vines, I know that Ms. Farmer may 

be your next witness, but I also have Ms. Aleski 

whose presence is needed before 5. Would you be 

willing to entertain in taking her out of order 

at this point? 

MR. VINES: Yes, Judge, that's fine. 

THE COURT: Mr. Honeycutt, would you be 

willing to put Ms. Aleski on the stand now? 

We'll take her out of order since she can't come 

back tomorrow. 

MR. HONEYCUTT: Yes, ma'am. 

THE COURT: Okay. Do you want to take 

five minutes to --

MR. HONEYCUTT: She is probably in the 

cafeteria. Can I have more like 15? 

THE COURT: How about 10? 

MR. HONEYCUTT: Okay. I'll hustle. 

THE COURT: We'll reconvene back here 

in 10 minutes. 

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2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

We're off the record at this time. 

(Whereupon, a brief recess was taken.) 

THE COURT: We're back on the record in 

the matter of Worldwide Aircraft Services, Inc. 

This is Docket No. FAA-2013-0045. 

We've reconvened after a short recess 

so that Mr. Honeycutt could get Ms. Aleski from 

the cafeteria. There's been an agreement by the 

parties to take her testimony out of order 

because of her unavailability tomorrow. 

So Ms. Aleski, if you could come up to 

the witness stand, please. Before you sit down, 

I'll ask you to raise your right hand. Do you 

swear to tell the truth and nothing but the truth 

in this proceeding? 

THE WITNESS: Yes, I do. 

THE COURT: You'll have to speak up. 

THE WITNESS: Yes, I do. 

LISA ALESKI, after having been duly 

sworn, was examined and testified as follows: 

THE COURT: Thank you. Please take a 

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2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

seat. When you are comfortable, please state 

your name and spell your last name for the 

record. 

THE WITNESS: Lisa Aleski, A-L-E-S-K-I. 

THE COURT: Mr. Honeycutt, you may 

inquire. 

MR. HONEYCUTT: Thank you, your Honor. 

I'm not sure if the speaker works so 

just keep 

THE COURT: The court reporter is 

listening. She can tell. If there is any 

problem, we'll let you know. 

MR. HONEYCUTT: Okay. 

14 - - - - -

15 DIRECT EXAMINATION 

16 - - - - -

17 BY MR. HONEYCUTT: 

18 Q. Lisa, can you tell me how long you've worked at 

19 JET I.C.U? 

20 A. I've worked over six years at JET I.C.U from 

21 November 2007. 

22 Q. And your position at JET I.C.U. from then to now 

23 has been 

24 

25 

A. 

Q. 

Administrative assistant. 

And, in particular, you work, your main duties 

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1 are what? 

2 

3 

A. 

Q. 

Office duties. 

And you assist more -- do you not assist me 

4 pretty much in and out on a daily basis? 

A. Correct. 

MR. VINES: Objection, leading. 

146 

3/6/2014 

5 

6 

7 

8 

9 

THE COURT: It is leading, but it is a 

10 

11 

12 

preliminary question. I'll overrule the 

objection, and I'll allow the question and answer 

to stand. 

You may continue. 

MR. HONEYCUTT: Thank you. I 'rn sorry, 

13 your Honor. 

14 BY MR. HONEYCUTT: 

15 Q. Lisa, I'd like to show you Exhibit C-10, is it on 

16 that desk? If you look on the bottom right-hand 

17 corner there, is it labeled Government Exhibit C-10? 

18 We're looking for C-10. 

19 

20 

21 

22 

A. 

Q. 

A. 

Q. 

It seems to be jumping. 

Do you recognize that document? 

I do. 

Could you tell me how you recognize that 

23 document? 

24 A. I recognize this document because I had typed it 

25 for Brian Fanning. 

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1 Q. You typed the document for Brian Fanning, 

2 correct? 

3 

4 

A. 

Q. 

Correct. 

Do you recall June 16, 2009, the day in question, 

5 that the document was written and signed or typed by 

6 you and signed by Brian Fanning? 

7 

8 

A. 

Q. 

I do. 

Was Inspector Paul Kahler, do you know Paul 

9 Kahler FAA Inspector, are you familiar with him? 

10 

11 

12 

13 

A. 

Q. 

A. 

Q. 

I am familiar with him. 

Was Paul Kahler at JET I.C.U. on June 16th? 

Yes. 

Can you just give a brief summary of how the 

14 document came to exist in your opinion and personal 

15 knowledge? 

16 A. Brian said, "Lisa, I need you to take this up for 

17 me, which was on like a legal pad with his 

18 handwriting. So I did as I was told. I typed the 

19 letter and handed it back to Mr. Fanning. 

20 Q. Okay. So Brian gave you a legal pad, like a 

21 legal pad, it was handwritten and you typed it up? 

22 

23 

A. 

Q. 

Collect. 

And after typing it, you printed it and gave it 

24 to Brian? 

25 A. Yes. 

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1 Q. What happened after that, was that the end of 

2 that? 

3 A. Shortly thereafter, there was some changes to the 

4 document that he needed it retyped. So I did as I was 

5 told and retyped it. 

6 

7 

8 

Q. 

A. 

Q. 

Who asked for the changes? 

Brian asked me. 

And did Brian have any comments reference to that 

9 changes? 

10 A. He seemed to be a little upset that there were 

11 changes to this letter. 

12 

13 

14 

15 

16 

Q. 

A. 

Q. 

A. 

Q. 

You don't remember the original letter? 

I don't. 

You don't know what the content was? 

My hands are automatic sometimes. 

Do you have any recollection of Paul Kahler and 

17 his visits to JET I.C.U. around this time as him being 

18 there on a daily basis? 

19 A. Was he at the office on a daily basis? 

20 Q. Did you see Inspector Kahler during the months of 

21 May, June and July; do you recall? 

22 

23 

A. 

Q. 

I recall June 16, 2009. I recall his visit. 

Okay. Do you recall any other time around there 

24 that he had come on multiple occasions, maybe? 

25 A. I saw him once before, I don't recall specific 

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1 dates. 

Q. That's fine. I don't expect you to. 

A. Okay. 

2 

3 

4 

5 

6 

7 

8 

9 

MR. HONEYCUTT: That's all I have for 

Ms. Aleski. 

THE COURT: Okay. 

Mr. Vines, do you have any 

cross-examination? 

MR. VINES: Yes, Judge. 

10 - - -

11 CROSS-EXAMINATION 

12 - - - - -

13 BY MR. VINES: 

Q. You said you remember June 16' 

A. Yes. 

Q. And you said Inspector Kahler 

A. Yes. 

14 

15 

16 

17 

18 

19 

Q. Do you know what he was there 

A. I guess to ask some questions. 

20 specific. 

2009? 

was there? 

for? 

I don't know 

21 Q. And looking at Exhibit C-10 that is in front of 

22 you, are you saying that this is the original document 

23 and then after this was typed there was another 

24 document that you typed? 

25 A. This was the final document. 

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1 Q. And you said that Brian, I assume you are 

2 referring to Brian Fanning --

3 

4 

A. 

Q. 

Uh-huh. 

seemed to be upset, did he articulate anything 

5 to you? 

6 A. I don't recall verbatim. I just remember him 

7 being like, I can't believe this or something to that, 

8 that you need to make this change. 

9 

10 

11 

Q. 

A. 

Q. 

But he didn't provide context? 

As far as what? 

He didn't provide context as to what changes he 

12 was upset about making? 

13 

14 

15 

16 

A. 

Q. 

A. 

Q. 

I can't recall exact words. 

Did you see Mr. Fanning sign the statement? 

Did he sign this? 

Did he sign the statement that is referenced in 

17 Exhibit C-10? 

18 

19 

20 

21 

22 

23 

24 

A. 

Q. 

A. 

Q. 

see 

A. 

Q. 

It looks like he did, yes. 

Do you work with Mr. Fanning as well? 

In the same office, yes. 

Do you have an occasion of working with him to 

his signature? 

I've seen his signature on occasion, yes. 

The signature on document C-10, does that look 

25 like his signature? 

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1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

A. Yes. 

MR. VINES: Thank you, Judge. 

THE COURT: Do you have any redirect 

based on the cross? 

MR. HONEYCUTT: Yes. 

REDIRECT EXAMINATION 

BY MR. HONEYCUTT: 

Q. The only question I have is, Lisa, did you see 

11 Brian give the letter to Paul Kahler once you finished 

12 the final version and gave it back to him? 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

A. 

Q. 

I don't recall physically seeing, no. 

Okay. 

MR. HONEYCUTT: That's it. 

MR. PLAINTIFF: Okay. 

Ms. Aleski, it is my understanding that 

you've been waiting a while and had a babysitter 

today. Thank you very much for your assistance. 

It appears your testimony is complete, and you 

are here by excused. Thank you. 

THE WITNESS: Thank you. 

THE COURT: Mr. Vines, are you planning 

to call another witness at this point? 

MR. VINES: Yes, Judge, Ms. Farmer. 

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THE COURT: Ms. Farmer, if you care to 

approach the witness box, and before you are 

seated, please raise your right hand. Do you 

swear to tell the truth and nothing but the truth 

in this proceeding? 

THE WITNESS: I do. 

MARTHA FARMER, after having been duly 

sworn, was examined and testified as follows: 

THE COURT: Please take a seat. When 

you are comfortable, please state your name and 

spell your last name for the record. 

THE WITNESS: Martha Farmer, 

F-A-R-M-E-R. 

THE COURT: Thank you. 

Counsel, you may inquire. 

DIRECT EXAMINATION 

BY MR. VINES: 

Q. 

A. 

Q. 

A. 

Ms. Farmer, where are you employed? 

Federal Aviation Administration. 

What do you do for the FAA? 

I'm a Regional Specialist in the Southern Region. 

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1 

2 

Q. 

A. 

What is the Southern Region? 

It is the Regional Office located in Atlanta, 

3 Georgia. Well, it is close to it, College Park. 

4 

5 

6 

7 

Q. 

A. 

Q. 

A. 

How long have you been with the Agency? 

Nineteen years. 

And what is your current title? 

Well, my title is Aviation Safety Inspector for 

8 Airworthiness, but I hold a position in the Region as 

9 a Regional Specialist. 

10 Q. And as a Regional Specialist, how long have you 

11 been in that position? 

12 

13 

14 

15 

16 

17 

A. Approximately nine years. 

Q. And what are your duties in that position? 

A. I am currently a point of contact to the 125 

Repair Stations in EASA. I also review enforcement 

cases. I field questions from the FSDO in the 

Southern Region. I work with headquarters on issues. 

18 I answer questions on IAs, on 135s, it goes on. 

19 

20 

21 

22 

23 

THE COURT: Counsel, just so that we 

have the record complete, several of the 

witnesses referred to FSDOs, could you ask this 

witness to explain what that manes? 

MR. VINES: Yes. 

24 BY MR. VINES: 

25 Q. Have you heard the term FSDO, spelled F-S-D-0? 

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1 A. Yes, it stands for Flight Standard District 

2 Office. 

3 Q. Tell me a little more about FSDO, what purpose do 

4 they serve? 

5 A. They are the offices that individuals like 

6 Inspector Singleton, Inspector Kahler, Inspector 

7 Donahue are all located in. We have several in 

8 Florida. We have one in Georgia. I mean, I'm just 

9 talking about some of them, but they are all over each 

10 state. That's where the inspectors in the field are 

11 

12 

13 

primarily station at. If that makes sense. 

Q. And you mentioned EASA? 

A. Yeah, it stands for European Aviation Safety 

14 Authority, I think it stands for. 

15 Q. And you also stated that you reviewed 

16 enforcement-investigative reports? 

17 

18 

A. 

Q. 

Yes. 

Why do you review enforcement-investigative 

19 reports? 

20 A. We actually do two types. We review legal cases 

21 by the personnel, the 230 Branch, that is the branch I 

22 work in. Before they go up to legal, we review them 

23 for content, evidence, correct rules to ensure that 

24 they are sufficient before they go up to our legal 

25 department. 

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1 Administrative actions I review for the same 

2 type, but they are not sent up to the legal 

3 department. 

4 Q. What's an administrative action? 

5 A. Are cases that don't rise to the level of a legal 

6 case, whether it be a civil penalty, revocation, that 

7 type. 

8 Q. And civil penalty, that would be against an 

9 airman, air carrier, or air agency? 

10 

11 

A. 

Q. 

Correct. 

And revocation would be revocation of an airline 

12 certificate? 

13 

14 

A. 

Q. 

Or an Air Carrier Certificate or repair station. 

So basically your review of the EIR, do you 

15 consider that just a qualify control review; is that a 

16 fair statement? 

17 

18 

A. 

Q. 

Yeah, I would say that is fair. 

Prior to working as a Regional Specialist, where 

19 did you work? 

20 A. I was a Principle Maintenance Inspector at the 

21 Atlanta FSDO. 

22 

23 

24 

25 

THE COURT: I'm sorry, what was the 

title again, please? 

THE WITNESS: Principle Maintenance 

Inspector for Airworthiness. 

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1 THE COURT: Thank you. 

2 BY MR. VINES: 

3 

4 

5 

Q. 

A. 

Q. 

And how long were you in that position? 

For approximately 10 years. 

What were your duties as a Principle Maintenance 

6 Inspector at the Atlanta FSDO? 

7 A. I'll keep it short. I was responsible for 

8 oversight of 135 Air Carriers, 145 Repair Stations, 

9 Inspection Authorize Mechanics, IAs, 147 Schools, 

10 Designees OARs, designees just means it's another 

11 title 137, 141 Schools, Pilot Schools. 

12 Q. And you said oversight of Part 137, what is a 

13 137? 

14 A. It is a -- I'm having a moment --Agricultural 

15 Operators. 

16 

17 

Q. 

A. 

You also mentioned IAs? 

Inspection to Authorize Mechanics. I was 

18 responsible for reviewing 337s, going out and doing 

19 inspections with them, helping them with any questions 

20 that they have. 

21 

22 

Q. 

A. 

Do you hold any FAA Certificates? 

I do. I hold an Airframe-and-Power Plant 

23 Mechanic's license. 

24 Q. As part of reviewing EIRs, is it the 

25 Regional Specialist -- if a Regional Specialist is 

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1 reviewing EIRs as part of his or her job duties, is it 

2 also their responsibility to propose a civil penalty? 

3 A. For a sanction recommendation, it could be beyond 

4 a civil penalty. 

5 

6 

7 

Q. 

A. 

Q. 

So a sanction recommendation? 

Uh-huh. 

In this particular case, did you prepare a 

8 sanction recommendation prior to the hearing in this 

9 case? 

10 

11 

12 

13 

14 

15 

16 

A. 

Q. 

A. 

Q. 

A. 

Q. 

A. 

No, I did not. 

I want to direct your attention to Exhibit C-17. 

Okay. 

Do you recognize this document? 

Yes, I do. 

How do you recognize this document? 

It is Appendix B. In Order 2153B, it is part of 

17 our guidance on how we review enforcement cases. 

18 Q. And does this index of the order of 2153B 

19 specifically address sanctions? 

20 

21 

A. 

Q. 

Yes, it is a Table of Sanctions. 

As part of the Administrator's case in chief, it 

22 is our duty to explain to the Court support for the 

23 proposed CP that the Administrator has proposed in 

24 this particular case, it is $12,375. 

25 I want to start first with this Exhibit C-17 and 

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1 ask you if there is any information, in this 

2 particular document, that would educate the Court as 

3 to how the Administrator's proposed CP is reasonable 

4 in this case. 

5 A. Okay. The first thing we have to determine is 

6 what group they are characterized in. What group it 

7 is characterized in. This first page on C-17, B-1, 

8 B-2, B-3, B-4, there is four pages on each one helps 

9 us to determine that. 

10 So if you go to paragraph that is on page B-3, 

11 there is a classification of air carrying air 

12 operators. There is group one, group two, group 

13 three, and group four. Within each one of those, it 

14 gives you a definition on how to determine what group 

15 it is. 

16 Q. In order to determine what group, you said -- I'm 

17 sorry, to clarify 

18 

19 

A. 

Q. 

20 is? 

21 A. 

Okay. 

-- you said in order to determine what group it 

What group an air carrier would fall under in a 

22 certain category. For instance, like Delta Airlines 

23 could fall into group one, because it says each 

24 carrier operating under 121 and 135 with an annual 

25 operating revenue, but I think that is a 100 million 

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1 or more. Operating revenue is determined by reference 

2 to DOT's Air Carrier Industry. So they may fall under 

3 that, but each one of those is defined for us to 

4 determine what group that air carrier falls under, the 

5 Operator. 

6 Q. Okay. In this particular case having heard 

7 testimony that the Respondent is authorized to operate 

8 under Part 135, is there is specific group that is 

9 applicable to this particular case? 

10 A. From the testimony that I heard, it would fall 

11 under group three. Worldwide would fall under group 

12 three. 

13 

14 

Q. 

A. 

And why is that? 

Because under the definition it shows that each 

15 Air Carrier Commercial Operator operating under Part 

16 135 with six-to-49 pilots, which I heard they had six 

17 pilots at the time of the occurrence or six-to-24 

18 aircrafts. 

19 Q. Okay. So for that reason, the group three would 

20 be appropriate 

21 

22 

23 

24 

A. 

Q. 

A. 

Q. 

Right. 

-- to the case? 

Yes. 

And after determining that it is group three on 

25 page B-3 which is found on Exhibit C-17, what would be 

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1 the next step in determining? 

2 A. Then we have to determine where it falls under in 

3 the next section, which is on the civil-penalty 

4 ranges, it kind of goes from B-3 to B-4, you have to 

5 search on each one of these groups, and for group 

6 three, for the ones that we defined, they would fall 

7 under where it says minimum 825 to a maximum CP range 

8 of 11,000. 

9 

10 

Q. 

A. 

Okay. 

So that's right under the group two. It is the 

11 first one under group two. 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

Q. 

A. 

Q. 

I'm sorry, group two or group three? 

The first group three under group two. 

Okay. 

THE COURT: I'm sorry, I'm now lost. 

You are on B-4? 

THE WITNESS: B-4. 

THE COURT: Which is page one of C-17? 

THE WITNESS: Yes, ma'am. 

THE COURT: And you just identified the 

Respondent as identified as group three 

classification? 

THE WITNESS: Yes, ma'am. 

THE COURT: So in terms of the second 

step, you are looking at the civil-penalty range; 

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2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

is that correct? 

THE WITNESS: Yes, ma'am. 

THE COURT: And that starts on B-2 

under civil-penalty range and then moves into B-4 

THE WITNESS: Yes. 

THE COURT: or how are you looking 

at this? I'm confused. 

THE WITNESS: I know because he has 

four pages on here. So you can start out, if I 

can show you here. If you start here, it would 

be one and then B-2. 

THE COURT: Got it. 

THE WITNESS: And then you are going to 

come down to B-3 and because they fall under 

group three, then you have to keep going down and 

go from B-3 over to B-4 and find group three. 

They fall under the 49USC46301A5A, not the A or 

B. So they fall under the first group three. 

THE COURT: Thank you, Mr. Vines, for 

21 allowing the Court to inquire. 

22 You are welcome to continue. 

23 BY MR. VINES: 

24 Q. And under group three you mentioned earlier that 

25 it provides a minimum range, moderate range, and 

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1 maximum range? 

2 

3 

A. 

Q. 

Yes. 

What was the next step in determining what range 

4 this particular violation fits into? 

5 

6 

A. Well we have to go into -- it's got to be on page 

B-14 of C-17. It would fall under BlJ5, failure to 

7 make a required entry in aircraft log. The 

8 civil-penalty range for that is minimum to maximum. 

9 Q. And why, in your opinion, is the BlJ5 figure 

10 appropriate? 

11 A. According to the rules that are sited in the 

12 complaint, the issues surrounds that the Worldwide did 

13 not make a required entry into the aircraft log. 

14 Q. Now armed with that information referenced in 

15 figure BlJ5, page B-14 of Exhibit C-17, what is the 

16 next step? 

17 A. Well once we determined that, the FAA, once we 

18 know where the range is, we normally typically start 

19 in the mid range of a civil penalty. So we start in 

20 the middle and we aggravate up and we mitigate down. 

21 So I would come up to the group three, and I would add 

22 the 11,000 plus the 825 --

23 

24 

25 

THE COURT: I'm sorry, I need to take a 

note for a moment. 

THE WITNESS: Okay. 

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12 

13 

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17 

18 

19 

BY 

Q. 

THE COURT: So essentially, Counsel, 

just so I know, we're back on B-4, page one of 

C-17, looking at the ranges; is that correct? 

MR. VINES: That's correct. 

THE COURT: Okay. 

Please continue. 

THE WITNESS: So I would add the 

11,000, that's the max range along with the 

minimum range and divide that in half. That 

gives me the middle range of group three. 

THE COURT: I'm sorry, you need to 

specify, you said 11,000 and which amount would 

you take from the minimum range? 

THE WITNESS: The 825' the lowest 

amount. 

THE COURT: I see. Thank you. 

THE WITNESS: Yes. 

MR. VINES: 

Do you need a calculator to make that 

20 calculation? 

21 A. That might help. I do have some referenced, if 

22 you don't mind, I do have it written down right there 

23 in front of you. 

24 

25 

Q. 

A. 

Here? 

Look next to my bottle of water. 

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2 

3 

4 

5 

6 

7 

8 

9 

THE COURT: I'll note that Mr. Vines is 

walking towards the witness. 

Can you show that to Mr. Honeycutt 

first? 

MR. VINES: Yes, Judge, I just want to 

confirm with the witness that this is the correct 

document. 

THE WITNESS: Yes, this is it. 

MR. HONEYCUTT: Thank you so much. 

10 BY MR. VINES: 

11 Q. I'm going to show you the notes that you had 

12 made. My question earlier was, what was the 

13 calculation after adding the 11,000 to the 825, and 

14 then you said you divided that by two, what was your 

15 calculation? 

16 A. Right, that mid range that adds up to that 

17 calculates to $5,912.50. 

18 

19 

20 

21 

22 

23 

24 

25 

THE COURT: I'm sorry, could you say 

that again, please. 

THE WITNESS: $5,912.50. 

THE COURT: I'm so sorry to ask this, 

Counsel, but I'm looking at B-4 on C-17 under 

group two, the maximum I have is 8,250 to 11,000. 

THE WITNESS: It is group three. 

THE COURT: I see. Thank you very 

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1 

2 

3 

4 

5 

much. That makes a big difference. 

I'll note that Ms. Farmer answered 

instead of Mr. Vines. I appreciate that. 

THE WITNESS: Sorry. 

THE COURT: Mr. Vines, go ahead. 

6 BY MR. VINES: 

7 Q. After making that calculation and coming up to 

8 the sum of $5,912.50, what is the next step in the 

9 calculation? 

10 

11 

A. We would multiply that by the number of rules 

sited. So at this point, number two, so that would 

12 add up to $11,825. 

13 Q. Now you testified earlier that the 

14 Administrator's policy is to start in the mid range 

15 and aggravate up and then mitigate down, did you 

16 consider -- let me back up -- I want to direct your 

17 attention to Exhibit C-18. 

18 

19 

20 

21 

22 

23 

24 

A. 

Q. 

A. 

Q. 

A. 

Q. 

A. 

Okay. 

Do you recognize this document? 

Yes, I do. 

What is it? 

It is chapter seven of the Order 21538. 

And what does chapter seven discuss? 

It is our Sanction Guidance Policies. 

25 us to determine the appropriate sanction. 

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1 Q. Okay. Does this particular chapter include the 

2 Administrator's policy on what the Administrator 

3 considers aggravating or mitigating factors? 

4 

5 

A. 

Q. 

Yes, it does. 

And did you consider any of these factors with 

6 regard to the CP that's proposed at $12,375? 

7 

8 

A. 

Q. 

Yes, I did. 

Let's start with the first factor. What nature 

9 of the violation would you consider this? 

10 A. In case you want to know, it is on page 7-4 is 

11 where we're going to start on C-18. 

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MR. HONEYCUTT: Your Honor? 

THE COURT: Yes. 

MR. HONEYCUTT: Objection, she is 

reading from the -- basically from the manual. 

THE COURT: Why is that a problem? 

MR. HONEYCUTT: Off her personal notes. 

THE COURT: And why is that a problem 

if we're looking at C-18? 

MR. HONEYCUTT: It was brought up 

earlier today that the notes that she is reading 

off of, she had come to the conclusion last 

night. Again, we didn't have the ability to see 

them just recently. 

MR. VINES: I don't know anything about 

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what your informal discussion resulted ln. That 

was not put before the Court. I'm not quite sure 

what the objection is yet. The proposed civil 

penalty is $12,375. This witness has just 

testified to the method by which she approaches 

recommending civil penalties or reviewing them. 

She is pointing the Court to Exhibit 

C-18 at this point to explain mitigating 

circumstances. So are you saying that she is not 

using Exhibit C-18? 

MR. HONEYCUTT: No, ma'am, I am not 

saying that. 

THE COURT: What are you saying? 

MR. HONEYCUTT: The notes are the 

issue. We would like to have had the notes prior 

to today. We asked earlier for the notes and 

Mr. Vines would not -- I'm confusing when we were 

off record if I objected. 

THE COURT: So essentially when you had 

your interview with Ms. Farmer yesterday, you 

wanted the notes, you asked for them, and they 

didn't give them to you? 

MR. HONEYCUTT: Today we didn't know 

about the notes because she made them last night. 

THE COURT: Okay. And the first time 

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you saw the notes was just a few minutes ago? 

MR. HONEYCUTT: I physically saw them, 

yes, ma'am. 

THE COURT: Okay. And now that you've 

seen the notes, you are objecting that she use 

the notes as part of her testimony? 

MR. HONEYCUTT: Yes, ma'am. 

THE COURT: Okay. 

Any response, Mr. Vines? 

MR. VINES: Again, as I responded to 

several times throughout this hearing, Ms. Farmer 

has made some notes regarding her testimony 

today. The Respondent has had the opportunity to 

look at them just now because Ms. Farmer just 

looked at them to refresh her recollection. 

I have also provided to this court that 

the Respondent was expected to testify regarding 

evidence she has heard today throughout this 

hearing as well and the admission of exhibits 

that have been admitted. 

THE COURT: Well can you focus on 

having her utilize notes that were not provided 

prior to just a few moments ago as part of her 

testimony? 

MR. VINES: Again, Judge, if the using 

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of the notes on the witness stand through the 

course or using them to refresh her recollection, 

could you -- both or one or the other? 

THE COURT: Both. 

MR. VINES: Judge, if the witness needs 

the notes to refresh her recollection, that is 

part of putting on a case. 

THE COURT: Well sometimes it and 

sometimes it isn't. 

MR. VINES: I do understand that having 

notes on the witness stand during the witness' 

testimony is not normal. So I have no objection 

to removing those notes, and Ms. Farmer can 

testify from her memory, and if she needs to 

reference her notes to refresh her recollection, 

I'll be okay with that, Judge. 

THE COURT: Okay. 

MR. HONEYCUTT: Your Honor, may I? 

THE COURT: Yes. 

MR. HONEYCUTT: To clarify, you know, I 

felt that Ms. Farmer relied on someone else's 

decision. The case she just got February lOth 

was brought to her, I believe. So the civil 

penalty has been out there since the original 

complaint and the proposed civil penalty back two 

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years ago. 

So I'm trying to understand how it got 

to this point. We asked the FAA, you know, to 

give us all the information so we can understand 

on how they carne to these conclusions. Ms. 

Farmer made a comment yesterday that Mr. Hubbert 

had the case prior to her getting on board in 

February. 

So she last night reviewed the case 

again, made some personal notes so she could 

testify and now she is testifying, and we still 

don't know how she got to her conclusion. 

THE COURT: I understand. Thank you 

for your objection. 

I'll sustain the objection at this 

time. There's been no particular basis for a 

need to refresh recollection. There simply was 

an offer to utilize the notes to help explain 

things. 

Ms. Farmer, if you could, just put your 

notes here face down and then we'll address this 

as need be during your direct or cross-exam 

testimony. 

So essentially, let's go back to 

Exhibit C-18, page 7-4 under 4A. 

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1 Mr. Vines. 

2 BY MR. VINES: 

3 Q. So as I was asking you, Inspector Farmer, did 

4 you, in preparation for your testimony today, 

5 reference the first mitigating factor found on 

6 paragraph 4A on page 7-4 on Exhibit C-18? 

7 

8 

A. 

Q. 

I reviewed it, yes, I did. 

And did you review that in the context of the 

9 evidence that you've heard throughout this hearing of 

10 the exhibits that have been entered into evidence? 

11 

12 

A. 

Q. 

The exhibits and testimony, yes. 

Did you review this particular mitigating or 

13 aggravating factor in the context information that is 

14 not included in the testimony or the exhibits during 

15 this trial? 

16 

17 

A. 

Q. 

No. 

And I'll ask you the same question for each of 

18 the mitigating factors -- for the mitigating factor 

19 contained in 4B, what would your answer be? 

20 

21 

A. 

Q. 

Say that one more time. 

What information did you use in reviewing 

22 mitigating factor found in chapter 48? 

23 

24 

25 

A. 

Q. 

A. 

Chapter 48? 

Excuse me, chapter seven, paragraph 4B. 

The testimony and the exhibits. 

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Q. 

A. 

Q. 

The testimony of the hearing that you heard? 

Yes. 

As well as the exhibits that have been admitted 

4 into evidence? 

5 

6 

A. 

Q. 

Yes. 

Did you consider anything outside this trial 

7 hearing? 

8 

9 

A. 

Q. 

No. 

I'll ask you the same question for chapter seven, 

10 paragraph 4C, did you consider any information 

11 extraneous to this hearing? 

12 

13 

A. 

Q. 

No, sir. 

I'll ask you the same question for paragraph 40, 

14 did you consider any information extraneous to this 

15 hearing in consulting mitigating or aggravating factor 

16 for 40? 

17 

18 

A. 

Q. 

No. 

Same question for paragraph 4E, in reviewing 

19 paragraph 4E, did you review or consider any 

20 information extraneous to this hearing? 

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22 

A. 

Q. 

No. 

Same question for paragraph 4F, did you review 

23 paragraph 4F? 

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25 

A. 

Q. 

Yes, I read it. 

For your testimony today? 

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Q. 

Yes. 

Did you consider any other information extraneous 

3 to the information presented here at the hearing 

4 including testimony and exhibits presented for 

5 purposed of reviewing paragraph 4F? 

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A. No? 

THE COURT: Counsel, I noticed that in 

Exhibit C-18, there is multiple more paragraphs, 

is it possible for you to simply create a 

question that incorporates all of the paragraphs 

instead of going through one at a time --

MR. VINES: Yes, Judge. 

THE COURT: -- just for purposes of 

time. 

MR. VINES: Yes, Judge. 

16 BY MR. VINES: 

17 Q. Ms. Farmer, I will ask again, as far as chapter 

18 seven, paragraph 4A through 4L, in preparation for 

19 your testimony today, did you review those paragraphs? 

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21 

A. 

Q. 

Say that one more time. 

In preparation for your testimony today, did you 

22 review paragraphs 4A through 4L? 

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24 

A. 

Q. 

Yes, I reviewed them. 

Okay. And when reviewing them, did you consider 

25 any information that as extraneous of this hearing? 

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Q. 

No. 

Of this hearing, I mean the testimony that has 

3 been presented, as well as the exhibits that have been 

4 admitted into evidence? 

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6 

A. 

Q. 

No. 

It is my understanding that you have been present 

7 through the start of this hearing, correct? 

8 

9 

A. 

Q. 

Yes. 

So with regard to paragraph 4A, chapter seven, 

10 Exhibit C-18 

11 

12 

A. 

Q. 

Okay. 

-- what information, if any, did you consider ln 

13 your analysis of paragraph 4A? 

14 A. Okay. So I mean there are 13 factors included in 

15 this. You have to take each one individually. The 

16 first one is the nature of the violation. So we have 

17 to determine do they fall into this factor. There are 

18 three elements in here that are discussed and 

19 operational, nonoperational, careless, or reckless and 

20 violation of law with any special mitigating or 

21 aggravating factors. 

22 So the one that comes to mind and makes the 

23 violation is they are a 135 On-Demand Operator. They 

24 are held to a higher degree, so there is an 

25 operational factor when it comes to the nature of the 

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1 violation. 

2 Q. When you say held to a higher degree, what do you 

3 mean by that? 

4 A. For our safety because they carry personnel. 

5 They carry our people. They are compensated. 

6 Q. Would you consider that fact an aggravating 

7 mitigating factor or neither? 

8 A. I don't. I consider that -- I'm not sure. 

9 That's why I have my notes. 

10 Q. Let me ask you this, if you were to look at your 

11 notes, would that refresh your recollection? 

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MR. VINES: Your Honor, may I present 

the notes to Ms. Farmer for review? 

THE COURT: Mr. Honeycutt? 

MR. HONEYCUTT: I object. We just got 

it, and I didn't have time to review it, but I'll 

leave it to your discretion. 

THE COURT: I know that no one here has 

a good-working knowledge of the Courthouse 

itself, but I'm going to ask this question 

anyway, is there -- do either of you know of a 

copy machine that is close by? 

I see that there is a hand raised, two 

hands raised. 

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What I'm going to do is this, it seems 

to me that we can eliminate some of these 

problems by just making these notes available so 

that the Respondent and the witness can utilize 

them simultaneously. 

Do you have any objection to that, 

Mr. Vines? 

MR. VINES: No, Judge. 

THE COURT: Then what I'm going to do 

is ask the officer to make a copy, three copies 

would be great. There is a front side and back 

side. 

While you do that, I'll ask Ms. Farmer 

to stay on the witness stand and take a rest 

while we address some housekeeping matters since 

we only have an hour left. 

So the Court will be recesslng at 5 

today. We've all had a very busy day. I think 

we all need a break. The question is whether we 

should come back at 8:30 tomorrow morning? 

Mr. Vines, I'll turn to you first. 

MR. VINES: No objection. 

THE COURT: Mr. Honeycutt. 

MR. HONEYCUTT: 9 a.m. I think would be 

sufficient for me, your Honor. I don't have, as 

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you saw with the last witness, in-depth 

testimony, and we live far away. 

THE COURT: Okay. You understand that 

if we start at 9, we do have to end at 5. 

MR. HONEYCUTT: Yes, your Honor. 

THE COURT: Okay. 

MR. HONEYCUTT: My testimony, my 

examination of my witnesses are not going to take 

'til lunch. 

THE COURT: Okay. Well one never knows 

what cross-examination, you know, what length, 

but I'm happy to start at 9 if that is more 

convenient to you. It looks like we will finish 

up tomorrow. 

MR. HONEYCUTT: Yes, ma'am. 

THE COURT: But if we don't, we will 

address in the afternoon the question of what to 

do if there is some lingering matter that needs 

to be taken care of. 

If we run out of time and the parties 

do not have a chance to do closing arguments and 

want to do that, we can always do those by 

telephone after everyone gets back to their 

respective workplaces. 

If there is an interest in filing a 

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post-hearing brief, we can set dates and 

deadlines for that. I don't necessarily need to 

have them in every case, and I may not need to 

have it in this case, but I just want to let you 

know that that is a possibility if you want it. 

Is there anything else that we can talk 

about just in terms of addressing party needs 

before we get the copies back before continued 

testimony? 

THE COURT: I'll start with you, 

Mr. Vines. 

MR. VINES: Judge, as you are aware, 

the Administrator had Mr. Singleton testify, I 

would ask that he be allowed to remain in the 

courtroom for any rebuttal testimony that may be 

needed tomorrow. He left the Court today to take 

care of some matters, but I would ask that he be 

able to sit in court tomorrow for purposes of 

rebuttal. 

THE COURT: Okay. Well, he has already 

been granted leave to sit in the courtroom, but 

I'll turn to Mr. Honeycutt. 

Mr. Honeycutt, do you have any 

objection to that? 

MR. HONEYCUTT: No, your Honor. 

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THE COURT: So noted and your motion 

for continued presence of the expert, in the 

event that rebuttal is needed, is granted. 

MR. VINES: Thank you, Judge. 

THE COURT: Mr. Honeycutt, any other 

matters that we need to address for you? 

MR. HONEYCUTT: If I testify, your 

Honor, I'm not sure how to ask myself questions 

or do I just make my statement as like a closing 

statement? 

THE COURT: Typically what I do with 

people who are representing themselves is I give 

you a couple different options on how to do that. 

You can make a narrative statement and then be 

subjected to cross-examination. 

You can ask me to ask you some 

preliminary questions that lead into a narrative 

statement to warm you up, if you will. For 

example, I would ask you what your name is, who 

you work for, those kind of things that give you 

a chance to relax a little bit. 

That is typically what I would do. You 

can either get on the stand and do a 

full-narrative statement and then do cross, 

experience cross and then take some notes as you 

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are being asked questions, and then give a 

narrative rebuttal to that cross or you can ask 

me to kind of get your wheels moving a little 

bit. 

I cannot act as your surrogate counsel. 

That is the disadvantage, of course, of 

representing yourself, but there have been people 

who have done it. Do you have any alternate 

option to offer to the Court? 

MR. HONEYCUTT: If the Court willingly, 

could Mr. Bowen ask me questions? 

THE COURT: Well, I certainly would 

entertain that motion. I'll turn to Mr. Vines to 

see if he has any objection. 

The only problem with that is that Mr. 

Bowen then becomes co-counsel which has not been 

his role in this proceeding. 

Mr. Vines, do you want to think about 

that, or do you have a response? 

MR. VINES: Judge, I would object to 

anyone directing Mr. Honeycutt. Mr. Honeycutt at 

this date and time has listed himself as the 

representative and because of that, I would ask 

that he be limited to the options that you just 

discuss with him. 

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THE COURT: Just so I know, what harm 

do you think your client experiences if Mr. 

Honeycutt is offered some help from his 

assistant? 

MR. VINES: Again, the harm would be 

strategy, and Mr. Honeycutt would have counsel to 

steer him where he needs to go. So it is more 

from a strategy standpoint, Judge. 

THE COURT: Okay. 

I have copies of the notes. I'll ask 

both Mr. Vines and Mr. Honeycutt to come up and 

get your copy. I'm handing to Ms. Farmer her 

original copies. So everyone has a copy. 

With this distribution, I will deny the 

Respondent's motion of objecting about not having 

a copy. 

In terms of allowing Mr. Bowen to 

assume representational status, I'm going to 

think about that for a little bit. That is 

somewhat of an unusual request actually after you 

appeared on your own behalf, Mr. Honeycutt, 

through the whole process, although it is not the 

first time I've had this request. So let me 

think about it for a minute as I listen to this 

inquiry. 

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1 Mr. Vines, I'm going to ask you to pick 

2 up where you left off on direct and proceed 

3 please. 

4 BY MR. VINES: 

5 Q. My question to you is, as to this particular 

6 aggravating or mitigating factor which is referred to 

7 in paragraph 4A of chapter seven, 21538, which is 

8 found in Exhibit C-18, do you have any opinions as to 

9 whether this factor constitutes an aggravating factor, 

10 mitigating factor, or neither? 

11 A. It could be an aggravating factor. I did note 

12 aggravating on there because of them not being a 91. 

13 They are a 135 Operator, and they are held by 

14 standards. 

15 Q. And you mentioned about not being a 91, what is a 

16 91? 

17 A. It is just your basic pilot with one pilot, one 

18 airplane and possibly no passengers in it. So it 

19 wouldn't be as a serious violation. 

20 Q. Part 91, does that allow operations to carry 

21 passengers for compensation? 

22 

23 

A. 

Q. 

No. 

Let's move on to the second factor found in 

24 paragraph 4B as in boy, which is whether the violation 

25 was deliberate or not deliberate. Did you consider 

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1 this factor in your analysis? 

2 

3 

THE COURT: I'm sorry, could you speak 

up? We're having a little trouble hearing you. 

4 BY MR. VINES: 

5 

6 

Q. 

A. 

Did you consider this factor in your analysis? 

I considered, but if there is no evidence to 

7 support that there were any inadvertent or deliberate 

8 acts. 

9 Q. So based on that finding, is this particular 

10 factor considered aggravating, mitigating, or neither? 

11 

12 

A. 

Q. 

Neither. 

Move on to the third, which is found in paragraph 

13 4C, Certificate holders (inaudible) experience, did 

14 you consider this? 

15 A. I did consider this as an aggravation, because of 

16 their experience as a 135 Operator, again they are 

17 held to a higher standard. They carry personnel. 

18 They were in business for several years. So I did 

19 consider this as an aggravating factor. 

20 Q. It seems as though we're seeing some of the same 

21 facts fall into these different aggravating or 

22 mitigating categories, is that common or is that 

23 unheard of? 

24 A. No, it is common to have some of the same items 

25 that follow through your 13 factors. 

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1 Q. Okay. Moving on to paragraph 4D of the exhibit, 

2 attitude of the violator, what, if any, did you get 

3 from this factor? 

4 A. I felt as though that their attitude has been 

5 acceptable, and they have complied with a request by 

6 the FAA in gathering documents and records. I didn't 

7 consider it. 

8 Q. Okay. Did you consider that a mitigating factor? 

9 A. It's a norm for the Operator to work with the 

10 FAA, so it is kind of a null and void as far as I'm 

11 

12 

concerned. It is a norm that they should comply. 

Q. And that norm is referenced in that particular 

13 paragraph, which is 4D of Exhibit C-18? 

14 A. It is a norm. Yes, a good compliance attitude is 

15 the norm and doesn't warrant a reduction in sanction. 

16 Q. Thank you. The next factor, paragraph 4E, create 

17 a hazard, did you consider this factor in your 

18 analysis? 

19 A. I did. Again, my one concern is they are a 135, 

20 and they are held to a higher standard. The other 

21 issue that I had was the delay of the inspection after 

22 the occurrence by the Operator. It took, I believe 

23 from the exhibits, May 3rd to May 9th, for maintenance 

24 to review, to look at the aircraft and make some sort 

25 of an inspection. I felt that that was a hazard. 

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2 

Q. 

A. 

And the delay, why is that concerning? 

I think in the discussion that you got in the 

3 testimony I heard from Inspector Singleton, there 

4 could have been some extenuating issues concerning the 

5 GPU receptacle and not knowing the depth of the damage 

6 done to the aircraft, I feel as though it should have 

7 been looked at right away to determine what is the --

8 damage -- was the damage to the aircraft intolerant 

9 and was there actually an issue with the receptacle. 

10 I felt as though it should have been done immediately. 

11 Q. As a result of those facts, would you consider 

12 this particular factor an aggravating, mitigating 

13 or 

14 

15 

A. 

Q. 

I would consider it aggravating. 

Moving on to paragraph 4F, did you consider this 

16 factor? 

17 

18 

19 

20 

A. 

Q. 

A. 

No, I did not. This does not apply. 

The next factor, paragraph 4G, the certificate. 

Again, I did consider this as a aggravating 

factor. It relates again to the kind of operation, 

21 and they were operating as a 135 On-Demand Air 

22 Carrier. 

23 

24 

Q. 

A. 

The next factor, paragraph 4H --

Violation history, I did not consider this as a 

25 factor. 

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1 Q. Would you go into more detail, did you consider 

2 this a mitigating or aggravating? 

3 A. No, a violation -- they talk about a violation 

4 free history is a norm and therefore, it is not a 

5 mitigating factor. 

6 

7 

8 

9 

Q. Paragraph 4I. 

A. No, decision of law is not one that we do. That 

is legal. I do not consult that. 

Q. What about paragraph 4J, moving on to paragraph 

10 4J. 

11 

12 

A. I don't have any -- that is not considered either 

from the Regional standpoint. I don't make the 

13 decisions on that. 

14 

15 

Q. 

A. 

Paragraph 4K. 

K was not considered. It says right in here, in 

16 the order, the goal may not be achieved however 

17 because in here it made a subjective nature of the 

18 size. Each case is different. We look at each case 

19 on its own merit. So the consistency is not something 

20 I would compare from one case to another. 

21 

22 

23 

24 

Q. 

A. 

Q. 

A. 

Paragraph 4L. 

Four L --

Did you consider this factor? 

No, I did not consider this. Though it was not 

25 reported in a voluntary manner as far as our voluntary 

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1 programs in the FAA, it wasn't something that the FAA 

2 

3 

found out beforehand. I mean, they found it. They 

discovered it. They fixed it eventually. It was not 

4 something that the FAA got involved with until the 

5 investigation, so I did not consider this. 

6 

7 

Q. 

A. 

And the last paragraph. 

Corrective action, I did consider it, even though 

8 it was corrected, I believe it was not corrected in a 

9 timely manner. I think it was May 20th, I believe and 

10 one of the exhibits that the maintenance was finally 

11 or the airplane was finally repaired. So it did take 

12 awhile for the corrective action, though they did 

13 complete it. 

14 Q. I just want to clarify, you used several pronouns 

15 when you were talking about on May 20th the airplane 

16 was repaired and there was a delay, a delay from what? 

17 

18 

A. So May 3rd the incident occurred, on May 9th it 

was looked at. I think I heard some testimony about 

19 it being deferred, but I don't have any record to know 

20 how or it was deferred, and then to know that there 

21 were flights that continued until May 9th. Then 

22 May 20th, the maintenance was finally completed on it. 

23 I believe there is a lapse on the corrective action. 

24 

25 

Q. 

A. 

Let me take your attention to Exhibit C-10. 

Okay. I got it, C-10. 

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2 

3 

Q. 

A. 

Q. 

What is your understanding of this document? 

This is the one that was just discussed actually. 

Again, you were discussing dates and specifically 

4 when the aircraft was looked at 

5 

6 

A. 

Q. 

Uh-huh. 

-- does this document help in your time line as 

7 to the corrective action involved in paragraph 4M as 

8 in Mike? 

9 A. It does, but at this time, the aircraft still 

10 hadn't been -- I mean, this was written on June 16, 

11 2009 after the aircraft was repaired. So on May 7th 

12 the aircraft returned and was looked at, but there was 

13 no log entry made at that time either. So I'm not 

14 sure what they determined. 

15 Q. Okay. 

16 A. Except that, after the inspection, the receptacle 

17 internal, external skin surfaces aft of the Frame 26, 

18 they found some damage to the non-structural section, 

19 but nothing was written up and or corrected. 

20 Q. Okay. And do you recall the date that that was 

21 corrected? 

22 

23 

A. 

Q. 

I'd have to--

Let me direct your is there a document where 

24 that is referenced? 

25 A. Yes, there is -- C-11. 

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Q. Okay. 

A. This is where they completed the following items 

and replaced the GPU receptacle. It is dated May 

4 20th. This is a maintenance-record entry for N90LJ. 

5 They replaced the GPU mounting brackets and reworked 

6 the area aft, below the GPU receptacle. So that's 

7 when the corrective action was completed. 

8 

9 

Q. Now you also mentioned that the aircraft was used 

in several flights. I want to direct you attention to 

10 Exhibits C-4A through C-48. 

11 

12 

13 

14 

15 

A. 

Q. 

A. 

Q. 

A. 

Yes. 

Take a look at those. 

Okay. 

What do you understand those documents to be? 

These are the flights that were conducted on 

16 May 3rd, May 6th, May 7th, May 12th, and May 14th. 

17 Q. Are these the flights that you were referring to 

18 earlier? 

19 A. Yes, these were the flights where the airplane 

20 continued to fly with the damage to the aircraft skin 

21 and the bent GPU receptacle. 

22 Q. Again, going back to paragraph 4M, did you 

23 consider this an aggravating or mitigating factor? 

24 

25 

A. 

Q. 

Aggravating. 

Why would you consider it aggravating? 

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1 A. Because the corrective action wasn't done in a 

2 timely manner. 

3 Q. Okay. Any additional concerns that you feel were 

4 aggravating or mitigating testimony that you heard 

5 over the course of this hearing? 

6 A. From the exhibits that I reviewed and the 

7 testimony that I've heard, and I think I mentioned it 

8 before in here, one of the aggravating factors to me 

9 is that personnel of Worldwide did not make the entry, 

10 that's one of the big issues that I have, into the 

11 log. 

12 Neither the PIC and he, according to their GOM, 

13 is required to make an entry when he finds a 

14 maintenance discrepancy, and the Chief of Maintenance, 

15 even after he reviewed the aircraft, did not make an 

16 entry into the logbook. To me, that's an aggravating 

17 factor. 

18 Q. Okay. Now, these aggravating factors that you 

19 discussed, were those included as part of the CP --

20 let me go back. I'll rephrase. Earlier you testified 

21 that the starting or the middle range of the CP was 

22 $11, 825? 

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25 

A. 

Q. 

A. 

Yes. 

However the proposed sanction is $12,375. 

Yes. 

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So there's an obvious difference there? 

Yes, so I added on, well we added on the $550 for 

3 an aggravating factor. 

4 Q. In your opinion, this proposed CP of $12,375, is 

5 a reasonable CP in light of the FAA Sanction Policy 

6 and the facts of this case? 

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A. Yes. 

MR. VINES: That's all I have, Judge. 

THE COURT: Thank you. 

Mr. Honeycutt, do you have any 

cross-examination? 

MR. HONEYCUTT: Your Honor, I would 

like to ask if we could cross Ms. Farmer in the 

morning. I don't mean to cut it short, but I 

feel like I haven't got the notes down, that I 

could not prepare myself in five minutes for 

cross. 

THE COURT: Mr. Vines. 

MR. VINES: Again, I would object. 

Final arguments are often repetitive, but 

nonetheless, the Respondent has been on notice of 

the exhibits in C-17 and C-18 which is the 

Administrator's policy. 

Again, Ms. Farmer has testified only to 

the evidence that we've heard in this case, 

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nothing extraneous. Again, no surprise should be 

to the Respondent, and therefore, I would object 

to continuing this case, in addition to the time 

that we have left in this hearing to accommodate 

all of the witnesses. 

THE COURT: Okay. Just so that I'm 

clear, it appears that Ms. Farmer is your last 

witness; is that correct? 

MR. VINES: That's correct. 

THE COURT: Mr. Honeycutt. 

MR. HONEYCUTT: With all due respect, 

Mr. Vines felt that this would be a one-day 

trial, and he's had two days. He's used two 

days, and I've asked to go home 30 minutes early 

to review information that was given to me 15 

minutes ago. 

THE COURT: And as I understand it, you 

are willing to accept the short end of the stick 

in terms of time since we only have one day left, 

and you feel comfortable, from your previous 

argument made to me, that you'll be able to get 

everything ln that you need to get in in one day 

tomorrow? 

MR. HONEYCUTT: I do, your Honor. I 

don't feel my witnesses will be in that as depth 

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as the government's. 

THE COURT: Okay. Then I will accept 

your assertion. I will grant your request for 

recess at this time. 

It is my understanding from Mr. Vines 

in an earlier conversation that Ms. Farmer is 

available 'til noon tomorrow. I shall look 

forward to seeing you tomorrow. 

Ms. Farmer, when you come back into the 

courtroom tomorrow morning, you are welcome to 

come back up on the witness chair. 

Mr. Vines, as I understand it, you are 

resting your case at the conclusion of Ms. 

Farmer's testimony? 

MR. VINES: Judge, if I can have, since 

we do have some extra time 

THE COURT: Yes. 

MR. VINES: -- to go through my file. 

THE COURT: You don't have any other 

witnesses, correct? 

MR. VINES: That is correct. 

THE COURT: Okay. Thank you. 

Madam court reporter, did you have 

something to address with me? I thought I heard 

something. 

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THE COURT REPORTER: No, I just 

hiccupped. 

THE COURT: That is obviously not 

something of substance. 

THE COURT REPORTER: No. 

THE COURT: Mr. Honeycutt, in terms of 

your motion of assistance from Mr. Bowen, I'm 

going to deny that particular motion, but I'm 

going to grant you some relief. You have 

basically chosen to represent the company 

yourself all throughout these proceedings. 

So I think it makes more sense to this 

court to continue that process, but I would 

acknowledge and accept that Mr. Bowen has been a 

great resource to you. So what I'm going to do 

is this, I'm going to ask you to get on the stand 

when it is time for you to testify. You can do a 

narrative statement, however short or long as you 

choose. 

At the conclusion of your narrative 

statement before cross-examination begins, I'll 

give you a recess to consult with Mr. Bowen to 

see if there is anything that you missed, and you 

can go back on the stand to add anything if you 

want. We'll do the same thing with cross. 

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During cross, if you need a moment to 

consult with Mr. Bowen, I'll give you an 

opportunity do that. At the end of cross, I'll 

give you another chance to consult with Mr. Bowen 

about anything you would like to add to whatever 

redirect testimony and narrative you'd like to 

make so that you still have access to him in the 

same way that you've had access to him so far. 

I'm not quite sure how do I want to 

say this -- absent Mr. Bowen who has previously 

identified himself as counsel, an attorney, 

absent Mr. Bowen actually putting in a Notice of 

Appearance and substituting in for you, I'm not 

sure that any other solution is viable to the 

Court at this point. 

But you are certainly welcome to 

consider that option as well, but at that point 

Mr. Bowen needs to be of counsel as opposed to 

simply an assistant if he is going to actively 

speak for you. 

With that, Mr. Vines, is there anything 

else that you would like to address for your 

client today? 

MR. VINES: Judge, only with response 

to the protocol for the morning, it is my 

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understanding, so that I'm clear, Judge, that as 

I, representing the Administrator, conduct 

cross-examination on Mr. Honeycutt, it is my 

understanding that you are going to allow him to 

take breaks during that cross-examination to 

consult with his attorney? 

THE COURT: He doesn't have an attorney 

right now 

MR. VINES: I'm sorry, I didn't--

THE COURT: -- he simply has a friend 

at the counsel table with him. What I'm saying 

is that I'm going to give him some access to his 

assistant because he is a Pro-say Respondent. 

So he can get up on the stand, he can 

make his narrative, but before I allow cross, he 

can meet and discuss very briefly with Mr. Bowen 

if there is something that the two of them 

gathered think they might have missed, he can add 

to his narrative before your cross-examination 

begins. 

Once you have crossed Mr. Honeycutt, he 

can then meet with Mr. Bowen again, discuss any 

kind of redirect that he wants to make, and then 

get back on the stand and add to his narrative 

statement answering what he can, any 

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cross-examination issues that came up for him. 

So I want to make sure that Mr. 

Honeycutt still has access to his assistant the 

same way he has had access to him throughout this 

trial. Does that help you? 

MR. VINES: Yes, Judge, it does. 

THE COURT: I'm not intending that once 

8 you ask a question that Mr. Honeycutt consult, 

9 that would not be allowed for any witness, and I 

10 don't think Mr. Honeycutt has asked for that any 

11 way. 

12 So with that, our business is complete. 

13 I wish you all a good evening and a good dinner. 

14 We can go off the record at this time. 

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Untitled 

1 CERTlFICATE OF REPORTER 

2 STATE OF FLORIDA 

3 COUNIY OF HILLSBOROUGH: 

4 

5 I, LAURA MORALES, Court Reporter, 

6 Nol:ary Public, certify that I was authorized 

7 1:0 and did stenographically report the foregoing 

8 prot:ee:dirtg and that ·the transcript is a t·rue 

9 and complete record of 11JY stenographic notes. 

10 I further certify that I am not a 

11 relat:iv·e, employee, attorney, or couns·el of 

12- ariy of the parties, nor -arrf I a relative or 

13 emp:loyee of any -of the parties 7 attorney o.r 

14 c:ounse·l connected with the aCtion, nor am _I 

15 financially interested in the action. 

16 

17 

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25 

Dated this JO+hof march, 2014 

La~AYJwt· ~ court Reporter, Notary; ·P:ublic 

State of Flori.da at Large 

My Commission. No. : FF029798 

Expires: JUne 10, 2017