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ORIGINAL 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, DC 

4 In the Matter of, 

Docket No. FAA-2013-0045 

5 WORLDWIDE AIRCRAFT 

SERVICES, INC., Case No. 2009S0150216 

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Respondent. 

_______________________ / 

DATE: 

TIME: 

PLACE: 

REPORTED BY: 

HEARING, VOLUME III 

March 7, 2014 

8:30 a.m. - 12:55 p.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 79 

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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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 

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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 

18 Michael Singleton 

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1 I N D E X (Continued) 

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Direct Cross Redirect Recross 

Witnesses for the Agency: 

Martha Farmer 7 8 

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5 Witnesses for the Respondent: 

Michael Honeycutt 17 42 

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7 Closing by Mr. Vines 52, 70 

Closing by Mr. Honeycutt 63 

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No. 

E X H I B I T S (Continued) 

Description 

(No exhibits were marked.) 

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P R 0 C E E D I N G S 

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 for a third day of 

testimony. All parties previously identified for 

the FAA and the Respondent, Worldwide Aircraft, 

have returned to the hearing room, and our 

witness, Ms. Farmer, has reseated herself in the 

witness chair. 

It is my understanding, from the recess 

that we took last evening, that the FAA had 

finished with its direct examination of Ms. 

Farmer, who is its last witness. We're planning 

to proceed this morning with cross-examination 

from the Respondent. 

Ms. Farmer, you are still under oath. 

Mr. Honeycutt, do you have any 

cross-examination for this witness? 

MR. VINES: Judge, if I could just 

interrupt. 

THE COURT: Mr. Vines. 

MR. VINES: Judge, this morning the 

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Administrator moves to withdraw count two of the 

complaint, that would be paragraphs 9, 10, and 

11, as well as paragraph 128 as in boy, and the 

result of that, we also move to amend the 

sanction downward departure to $6,100. 

THE COURT: Okay. Well, this is a 

little bit of a surprise to the Court. 

MR. VINES: Yes. 

THE COURT: So if I may have you tell 

me a little bit more about that. So let me get 

my sheet of paper here. 

So in looking at the amended complaint, 

I'm on count two and count two paragraphs 9, 10, 

and 11 are withdrawn; is that correct? 

MR. VINES: Yes, Judge. 

THE COURT: Okay. And then tell me 

again what the rest of that was? 

MR. VINES: Happily, Judge. Again, 

under count two, paragraphs 9, 10, and 11 of the 

complaint and under that in paragraph 128 as in 

boy. 

THE COURT: Okay. And then as a 

result, you are amending the proposed penalty of 

$12,375 down to how much? 

MR. VINES: $6,100. 

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THE COURT: Mr. Honeycutt, do you have 

any objection to that motion? 

MR. HONEYCUTT: I have no objection to 

that, your Honor. 

THE COURT: The motion to withdraw 

count two is granted. The motion to strike 

section B on the basis of withdraw is granted. 

The motion to reduce the proposed penalty from 

$12,375 to $6,100 is granted. 

Since there is a new amended penalty, 

did you want to have Ms. Farmer testify about how 

the amended penalty is reached for the remaining 

count or not? 

MR. VINES: I'll be happy to do that, 

Judge. Yes, I would like to do that. 

THE COURT: I think it might be 

helpful. I'm not sure that she would have to say 

very much, but it might be helpful since it is a 

little different from the testimony she presented 

yesterday. 

So why don't we do this, I'll ask you, 

Mr. Vines, to reopen your direct and just have 

Ms. Farmer explain where the amended penalty of 

$6,100 comes from. It doesn't need to be a 

repeat of yesterday, just kind of an explanation 

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of where the FAA started and how it got to 6,100. 

Is that acceptable to you, Mr. 

Honeycutt? 

MR. HONEYCUTT: Yes, your Honor. 

THE COURT: All right. 

Before I turn then to Mr. Vines, Mr. 

Honeycutt, any preliminary matters from the 

Respondent? 

MR. HONEYCUTT: No, ma'am. 

THE COURT: Okay. 

Mr. Vines. 

DIRECT EXAMINATION 

BY MR. VINES: 

Q. Good morning, Ms. Farmer. The Administrator has 

17 moved to reduce the proposed CP from $12,375 to $6,100 

18 which has been granted by the Court, would you please 

19 explain to the Court the general support for the 

20 $6,100 CP in light of count two being removed from the 

21 complaint? 

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A. 

Q. 

A. 

As far as how we figured the amount? 

That's correct. 

Same type as yesterday. We would go to group 

25 three on C-17, B-4. We came up with a moderate, 

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1 middle figure adding 11,000 and the 825 comes to the 

2 middle. I don't have my mathematical, but the one 

3 count would be $5,912.50. We added on minimal for the 

4 aggravating factors and came up with 6,100. 

5 Essentially, we actually cut the current, the original 

6 one, 12,375 in half. 

7 Q. And, in your opinion, the reduced CP to 6,100 

8 reasonably support -- is that supported by the 

9 Administrator's policy and evidence in 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: Yes, your Honor. 

CROSS-EXAMINATION 

BY MR. HONEYCUTT: 

Q. Ms. Farmer, I've got your notes that you used the 

21 other night to go over the violation, the civil 

22 penalty based on the violations that were alleged that 

23 the gentleman prior to you getting involved had come 

24 to those conclusions, did you go through your list 

25 again last night, like the A, B, C mitigating factors? 

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A. 

Q. 

No, I did not. 

You didn't go through the mitigating factors, you 

3 kind of just took a ballpark middle and added a little 

4 bit from the aggregate and came to that $6,000 figure? 

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Q. 

I'm not sure what you mean by (inaudible). 

Well, in this -- you actually took factor A 

THE COURT: And, Mr. Honeycutt, when 

you say in this, we just have a written record, 

nobody is going to watch you on appeal. It looks 

like you are holding up the written notes that 

were distributed yesterday that Ms. Farmer 

prepared? 

MR. HONEYCUTT: Yes, your Honor, that's 

14 correct. 

15 BY MR. HONEYCUTT: 

16 Q. Your notes that you wrote the other night, did 

17 you sit down as in number one, narrative of violation, 

18 an individual (inaudible) deliberate for No. B, C 

19 would be level of experience, you didn't go through 

20 this when you calculated this new figure? 

21 A. This morning? 

22 Q. Yes. 

23 A. No. 

24 Q. The only other thing I would have for Ms. Farmer 

25 is, do you recall sitting through this trial, any of 

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1 the Aviation Safety Inspectors testifying that they 

2 felt the aircraft was unairworthy? 

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Q. 

I do not recall. 

Okay. 

MR. HONEYCUTT: Nothing else, your 

Honor. 

THE COURT: Thank you. 

Mr. Vines, do you have any redirect? 

MR. VINES: No, Judge. 

THE COURT: Okay. 

Ms. Farmer, thank you very much for 

your testimony. It appears to be complete. It 

is my understanding that you may be leaving us 

around noon. You are welcome to do that or leave 

now as you and Mr. Vines see fit. 

Mr. Vines, as I understand it, the FAA 

is now resting its prima fascia case? 

MR. VINES: Yes, Judge. 

THE COURT: Okay. Thank you. 

Mr. Honeycutt, would you like to make 

an opening statement now, or would you like to go 

directly into testimony on your responsive case? 

MR. HONEYCUTT: I'm a little confused. 

I talked to Mr. Bowen, and I'm not sure -- I want 

to do an opening statement, but should I do an 

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opening statement on testimony or go directly to 

cross. Based on that, I'm not sure if that's 

even ~-

THE COURT: Well, you could do an 

opening statement now because this is the 

beginning or your responsive case and you 

reserved it when we first began on Wednesday. 

You don't need to make an opening statement. 

They are not required. 

So you could go directly into 

presenting your witnesses and then simply do a 

closing statement if you wanted to do that. Your 

case has changed obviously because you are only 

looking at one violation instead of two, and the 

amount of the penalty has been decreased. 

So do you want to take five minutes to 

think about what's changing for you in terms of 

your presentation; do you need a few minutes to 

kind of adjust to that? It looked like it might 

have been a surprise. 

MR. HONEYCUTT: It was very surprising, 

your Honor. I need to reevaluate the strategy, 

the game plan. 

THE COURT: Right, well that makes 

sense. Would 10 minutes be enough time? 

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MR. HONEYCUTT: Ten or 15 minutes would 

be okay. It is at your discretion. 

THE COURT: Okay. 

Mr. Vines, do you have any objection to 

a 10-minute recess? 

MR. VINES: No, Judge. 

THE COURT: Okay. Then let's take a 

10-minute recess, and we'll reconvene back at 

9:30. 

We're 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 

15-minutes recess. All parties previously 

identified have returned to the hearing room. 

And, Mr. Honeycutt, I'll turn to you 

first, are you ready to proceed? 

MR. HONEYCUTT: Yes, ma'am. 

THE COURT: Okay. Who would you like 

to call as your first witness? 

MR. HONEYCUTT: I would like to make an 

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opening statement, if I could. 

THE COURT: Very good. Thank you. 

MR. HONEYCUTT: Your Honor, if it 

pleases the Court, I would like to start by 

explaning a little more about Worldwide Aircraft 

Services and what exactly, the operation, that we 

do perform. 

THE COURT: Okay. But before you get 

into a lot of specifics, typically an opening 

statement is a brief summary statement of what 

you are planning to prove. So I want to be sure 

that you understand that what you say now is not 

testimony 

MR. HONEYCUTT: Yes, ma'am. 

THE COURT: it is not evidence, and 

I would not be able to use it as part of my 

consideration. 

So keep that in mind because I know 

that you may be testifying later, and anything 

you say now, if you think it is important for 

your case, would have to be under oath later. 

MR. HONEYCUTT: Yes, ma'am. 

THE COURT: Okay. Go ahead. 

MR. HONEYCUTT: We intend to prove that 

the FAA and the Government has failed to prove 

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that Worldwide Aircraft Services has operated 

outside of its General Operation's Manual in 

contrary to any Federal Regulations. Worldwide 

Aircraft Services is a On-Demand 135 Air Carrier. 

We have a very specific niche within 

that industry, and it is medical repatriation. 

Hence, our name is JET I.C.U. for doing business 

as. JET I.C.U. was founded in 2003, specifically 

for the Medical Transportation Industry. 

Worldwide, as a little explanation, we 

envisioned the company growing and being able to 

do more things, charter management, aircraft 

management, potentially a fix-based operations, 

so therefore we chose the name Worldwide Aircraft 

Services as our parent company, and we chose DBA, 

JET I.C.U, as our medical side. 

JET I.C.U. has been operating for 11 

years with an impeccable record, no blemish on 

our safety. We operate on six continents we have 

issued by the FAA Operation Specifications to 

allow us to pretty much have worldwide 

operations. The only areas of the world we are 

not allowed to go to are active-war zones in Iran 

and that is it pretty much -- and Antarctica 

unfortunately, maybe I can work on that. 

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JET I.C.U. is basically an 

intensive-care unit that operates in 41,000 feet 

at 500 miles an hour with a patient. Usually 

we're picking this patient up outside of the 

United States to bring them back into the 

country. 

We also do a lot of transports for 

Canadian Government for Canadians that are in the 

U.S. and traveling throughout Central America in 

the Caribbean. Due to their socialized health 

care, they are required to have travel assistance 

insurance that will assist them to get back into 

Canada so they can be treated in Canada. 

The case before you, the trip that is 

in question, was a repatriation of a Canadian 

citizen from the Caribbean into Toronto. I plan 

to go through that trip in its entirety and prove 

that we did operate within our Operation 

Specifications. We did follow our General 

Operation's Manuel and did not violate any FAA 

Regulations. 

THE COURT: Thank you. Who would you 

like to call as your first witness? 

MR. HONEYCUTT: I will testify first, 

your Honor. 

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THE COURT: Okay. Do you want to come 

up on the stand, and 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? 

MR. HONEYCUTT: I do, your Honor. 

MICHAEL HONEYCUTT, 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. 

MR. HONEYCUTT: It is Michael 

Honeycutt, H-0-N-E-Y-C-U-T-T. 

THE COURT: Okay. Mr. Honeycutt, would 

you like the Court to ask you a few preliminary 

questions, or are you ready to do your narrative 

statement? 

MR. HONEYCUTT: I would, your Honor, if 

you don't mind. 

THE COURT: Okay. 

DIRECT EXAMINATION 

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1 - - - - -

2 BY THE COURT: 

3 Q. Mr. Honeycutt, you've been serving for the last 

4 two days as the lay representative of Worldwide 

5 Aircraft Services, Inc., can you tell us what your 

6 relationship is with that business entity? 

7 A. I am the president, CEO and 100-percent share 

8 holder of Worldwide Aircraft Services, Incorporated. 

9 Q. And how long have you been the president and CEO 

10 of Worldwide Aircraft Services? 

11 A. President I believe since 2009, vice president 

12 from 2003, inception 'till 2009. Since 2009, 

13 Presidency and CEO. 

14 Q. You made a brief opening statement just a few 

15 minutes ago about the overall function of the company, 

16 would you care to that make that statement under oath? 

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A. 

Q. 

A. 

I would, your Honor. 

Please go ahead. 

As I stated in my open statement, Worldwide 

20 Aircraft Services is a On-Demand 135 Charter Operator. 

21 We currently operate two Learjets on our operation 

22 specifications. At the time, in 2009 of the incident, 

23 we had four Learjets that we operated. The two 

24 primarily that we operated around the world in Eastern 

25 Europe, Africa, Asia, the Pacific realm, and the other 

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1 two were primary for the Caribbean, South America, 

2 Central America, and North America. 

3 Since then, we've revamped our fleet and have 

4 replaced it with one aircraft that we operate with now 

5 in the north end and south end and another aircraft 

6 that we operate globally. 

7 The type of operation we do is extensive in the 

8 fact that we can be airborne from the time we have a 

9 call for a patient who moved and get the approval from 

10 the assistance or insurance company or the family, the 

11 ball starts to where we first have to make sure the 

12 patient is stable for the transport, determine the 

13 destination for that patient, arrange for that 

14 facility where the patient is supposed to come into. 

15 From a medical standpoint on that side, that 

16 starts the ball rolling on the operation side, where 

17 in the world are we going to go. For example, are we 

18 go to go 

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23 

Q. 

A. 

Q. 

A. 

Q. 

I'm sorry, sir, can you slow down a little bit --

I'm sorry. 

-- for the court reporter. 

Sorry. 

So you say you need to arrange for the medical 

24 facility and what else do you need to do for an 

25 individual-medical flight? 

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1 A. The flight is split into two parts, between the 

2 medical department and the aviation side. We commonly 

3 call that dispatching. If we need to have any landing 

4 permission in certain countries outside of the states, 

5 we have to get privileges to fly in foreign air space. 

6 For example, Cuba, we need a permit number to fly over 

7 Cuba or Jamaica. 

8 I'm going to use Jamaica as an example. We can 

9 say our patient is in Kingston, Jamaica and we need to 

10 take that patient to Toronto, once the medical team 

11 gets the assessment and determines the patient is 

12 airworthy and we can transport start, the aviation 

13 side steps in, starts the permitting process for the 

14 overflight, arranging for the handling in customs in 

15 Jamaica, putting the team together from an operation's 

16 side. 

17 In my position as operations, I'll let the 

18 dispatch know who the two pilots are going to be based 

19 on their current status of the current qualified for 

20 the transport. We select the aircraft based on the 

21 same criteria that is airworthy, that it is not 

22 (inaudible), no inspections, or maintenance would be 

23 required. 

24 Once we determine the crew, the aircraft, and the 

25 medical team, they are dispatched into the office, and 

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1 at that point, the trip is airborne, usually two hours 

2 from go. We go down and pick up the patient and 

3 transport that patient in route to Toronto. I can 

4 speak more specifically about the trip in question. 

5 Q. Well, why don't you first finish your overall 

6 explanation of what your company does. You indicated 

7 that you fly in six continents in your opening 

8 statement? 

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12 

A. 

Q. 

A. 

Q. 

Uh-huh. 

Yes? 

Yes. 

Tell us how high you fly, how fast, those 

13 particulars that you mentioned in your opening. 

14 A. Yes, ma'am, our aircraft, the Learjet, the reason 

15 why we pretty much chose the Learjet Industry, is 

16 pretty much the Learjet Industry is for the Medical 

17 Transport Industry. 

18 One of the reasons is durability, its speed, its 

19 range, and its ability to cruise at 41 to 43,000 feet 

20 in the sky with an average of 500 miles an hour. The 

21 two global airplanes have 2,400 nautical, close to a 

22 3000-mile range. It gives us a specific (inaudible) 

23 as well as departing from North America into Europe in 

24 one stop. 

25 Q. And you have mentioned that you are a Medical 

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1 Repatriation Service? 

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4 

A. 

Q. 

A. 

Yes, ma'am. 

What does that mean? 

Medical Repatriation versus Medical Evacuation, a 

5 typical scenario is an evacuation is you are stranded 

6 and you need to get to the quickest medical treatment 

7 available to you, then that's an evacuation. You 

8 would evacuate someone and put them into a treatment 

9 center as close as you could. 

10 Medical Repatriation is you are probably in a 

11 medical facility, but you need a higher level of 

12 treatment or you want to return to your home country 

13 for treatment in your home country. So we'll repatch 

14 you back to your choice of hospital. 

15 Q. The violation in which your company has been 

16 charged in this case, is alleged to have occurred on 

17 or about May 3, 2009? 

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19 

A. 

Q. 

Yes, rna' am. 

Can you tell us what happened on or about May 3, 

20 2009 that you think is important in your defense 

21 against this violation? 

22 A. Yes, ma'am, I can. The trip in question, we got 

23 the call, don't have the exact notes on it, but 

24 typically we'll get the call the day before 

25 MR. VINES: Judge? 

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THE COURT: Yes. 

MR. VINES: I hate to interrupt, but 

3 can you just tell me what exhibits he is 

4 referencing so I can follow along. 

5 BY MR. VINES: 

6 Q. Mr. Honeycutt, are you looking at exhibits right 

7 now? 

8 A. I am, your Honor, I apologize. I'm looking at 

9 Exhibit C-4A and B, the aircraft flight sheet. 

10 Q. Let me take a quick look at that. If you start 

11 to look at a different exhibit, please let us know. 

12 

13 

14 

A. 

Q. 

A. 

Yes, ma'am. 

Go ahead. 

So the trip in question is May 3, 2009. May 2nd 

15 we would have gotten the call from an assistance 

16 company that they had a Canadian on the Island of 

17 Dominica, the Eastern part of the Caribbean, and 

18 wanted to repatriate that patient back into Toronto. 

19 Given the socialized medicine in Canada, a lot of 

20 times we'll experience that they have to have that 

21 patient at the hospital by a certain time or they'll 

22 lose that bed to someone else. So we had to have the 

23 patient into Toronto before 6 p.m. 

24 During the flight planning and figuring the route 

25 of the trip, we realized to do that, to accomplish 

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1 that trip in that time frame, we would have to depart 

2 our base in Brooksville, Florida by 0800 Universal 

3 UGC, which is universal time corrected, which means it 

4 is 4 a.m. local time here on the East Coast. Our 

5 

6 

7 

8 

9 

flight logs run in Universal time because it is 

constant, wherever you are at in the world, you 

have to do the minus or plus. 

So on May 2nd when we got the call and the 

was confirmed, the patient was stable for the 

10 transport, I elected to put Brandon Plasm, the 

just 

trip 

11 Captain, and Eric Price on the trip. We chose N90LJ, 

12 the aircraft. I notified the crew of their departure 

13 and their estimated before preflight. 

14 Since the trip was going to be over 

15 nine-and-a-half hours of flying with three stops, we 

16 were limited under 135 that we have a 10-hour flight 

17 time limitation, and we have 14 hours of duty time to 

18 accomplish that from the time we show up at our 

19 airport to begin our duty day. 

20 Operating outside of the United States in San 

21 Juan, Dominica, and the Bahamas, it is unlike the 

22 United States. As we say, five minutes is really an 

23 hour. So trying to prevent our crew from having a 

24 duty-and-time issue, I elected to put the aircraft 

25 onto the fuel stand, fuel the aircraft for them, do as 

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1 much of the preflight that I could afford them. By 

2 doing that, I reduced their show time by 30 minutes 

3 where the aircraft would be in a ready, alert stance. 

4 So we did that, the crew showed up on duty at 

5 0730 on time, on the sheet there in the middle left. 

6 Captain went about filing the flight plans, getting 

7 the notes, making sure the route of flight and 

8 everything. It was his duty and responsibility to do 

9 that. 

10 As I seen, he went about his duties and 

11 responsibilities of the preflight of the aircraft, 

12 getting it ready for departure. We have, at the 

13 facility we were located at the time, we had a 

14 ground-power unit which is an external unit that has 

15 an umbilical cord that plugs into the aircraft. 

16 It supplies power so you can turn the batteries 

17 and the avionics on and power up the GPS and not 

18 delete the ship's batteries, and at night, you are 

19 using more power at 4 in the morning with having the 

20 lights on, landing lights, testing all the lights. So 

21 it was imperative that the GP be available for him. 

22 This GPU, in particular, had what we call a phase 

23 converter inside the building. We actually had to 

24 send all the power out for the distance that it was 

25 away from the building. We had to shut off that phase 

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1 inverter and turn the GPU off. So Mr. Plas, when he 

2 exited the aircraft, he got back in and departed the 

3 flight. The flight was uneventful. He took off, flew 

4 two-and-a-half hours, landed in San Juan. 

5 Again (inaudible) second of operation. Our team 

6 operates, for lack of a better analogy, like a Nascar 

7 pit crew. Everyone has a position, everyone has a job 

8 to do, and when the (inaudible) they are out the door 

9 and everyone is doing their job and doing it at a pace 

10 that will allow them to get back in and airborne as 

11 quickly as they can, because in the Medical Industry, 

12 they say time is tissue. So time is critical for 

13 every transport. 

14 So upon landing in San Juan, Mr. Plas got out to 

15 outbound customs from San Juan and --

16 Q. And Mr, Honeycutt, I'm going to stop you for a 

17 moment, there has been a variety of different acronyms 

18 or initials for different landing sites. Can you 

19 identify those particular initials for us, the TDPD, 

20 MYAM, and so forth. 

21 A. I can, your Honor. If you look at Exhibit C-4 in 

22 column one, BKV is our Base of Operation, which stands 

23 for Brooksville is the airport code. TJSJ, just 

24 beside that is a four letter IKM code, which is 

25 International Civil Aviation Organization. TJSJ is 

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1 designated to San Juan, Puerto Rico. Line two, you 

2 have TDPD, which is the identifier for Dominica in the 

3 Caribbean. From Dominica we went to MYAM, which is 

4 Marsh Harbour, the Bahamas, and then from Marsh 

5 Harbour into CYYZ is Toronto, Canada Airport. 

6 

7 

Q. 

A. 

Thank you. 

You're welcome. Again, leaving Dominica, I'm 

8 sorry, leaving San Juan we landed in Dominica, and it 

9 looks like we're on the ground for one hour in San 

10 Juan and touched down in Dominica at 1236. The 

11 medical team went to the hospital or the clinic on the 

12 Island of Dominica to retrieve the patient. The crew 

13 went about fueling the aircraft and flight planning 

14 again. 

15 I need to step back, in San Juan and Dominica, 

16 both places, the crew used the ground-power unit at 

17 those locations to power the aircraft while they 

18 fueled the aircraft and loaded the GPS data base for 

19 the next lay. 

20 They departed Dominica a little over an hour and 

21 went to Marsh Harbour. Marsh Harbour was a 

22 three-and-a-half hour flight for them. They touched 

23 down in Marsh Harbour, again exited the aircraft, my 

24 crew did, asked for fuel, the ground power, and 

25 continued to do his flight panning and his 

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1 international customs. 

2 They departed Marsh Harbour at 1806 for Toronto. 

3 Marsh Harbour being the incident in question with the 

4 GPU receptacle, Brandon Plas, the Captain at the time, 

5 called me on his departure from Marsh Harbour and said 

6 that the lineman approached him about the receptacle 

7 for the GPU not going into the GPU receptacle on the 

8 aircraft. 

9 He indicated that he didn't know if it was the 

10 plug that didn't fit right -- I'm sorry, the plug 

11 going in or if that plug had bent, but he informed me 

12 the aircraft was safe for flight. He had done an 

13 inspection of the GPU, and in his opinion, did not 

14 need the GPU for start and elected to proceed on with 

15 the flight without having a ground power connected in 

16 Marsh Harbour due to having the patient on board and 

17 wanting to continue with the trip. 

18 Upon arrival into Toronto, they unloaded the 

19 patient, the patient and the medical team in route to 

20 the hospital. Brandon asked the line serviceman in 

21 Toronto to hook the ground-power unit up to the 

22 aircraft and turn it on to see if he did have, in 

23 fact, a problem with the ground-power unit. 

24 In his statement, you will find that he did not 

25 have a problem. The GPU worked fine. So at that 

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1 point, Mr. P1as went off duty and completed that day's 

2 mission with the only incident being the Marsh 

3 Harbour, pretty much uneventful. When we have any 

4 issues that arise, in our General Operation's Manual, 

5 we do have a form called MX-02. I don't think we have 

6 the actual form with me. 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

MR. HONEYCUTT: Mr. Vines, you don't 

have an exhibit that actually has the form, the 

MX-02? 

THE COURT: Well, you want to ask me if 

I'm willing to let you do that. 

MR. HONEYCUTT: I'm sorry, your Honor. 

THE COURT: I'll ask Mr. Vines to see 

if he has one, but you can continue with your 

testimony. 

MR. HONEYCUTT: Okay. 

17 BY THE COURT: 

18 Q. I want to ask you to back up for a moment, you 

19 may have recalled that there was testimony yesterday 

20 about how many planes that you owned and operated in 

21 the year 2009. 

22 

23 

A. 

Q. 

Yes, ma'am. 

Can you -- you had indicated that in 2009, you 

24 had only four Learjets instead of six, is that your 

25 testimony? 

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1 A. Yes, your Honor. I think there might be a 

2 discrepancy. We have four aircrafts and over six 

3 pilots. 

4 

5 

Q. 

A. 

Okay. 

In the determination that Ms. Farmer was using 

6 that tablet in the C-17 Exhibit, it talks of having 

7 six pilots to only 49 pilots. We, at the time, 

8 operated four aircrafts and I would say six-to-eight 

9 

10 

11 

12 

pilots. I can't give you an exact number. 

Q. Are you one of the pilots? 

A. I am, your Honor. 

Q. Okay. You've heard testimony about how the FAA 

13 believes that Mr. Plas -- or you should have insured 

14 that a mechanical write up occurred after the lineman 

15 in Marsh Harbour advised Mr. Plas that he thought the 

16 GPU had a defect, what is your testimony or response, 

17 if any, to that? 

18 A. My testimony is that, your Honor, the captain of 

19 the aircraft has the ultimate responsibility that the 

20 aircraft is in a safe and airworthy condition. To 

21 that extent, he cannot determine if the aircraft, from 

22 a maintenance standpoint, from a scheduled 

23 maintenance, is in an airworthy condition. The 

24 Director of Maintenance issues an MX-01 is actually 

25 our document. It is the aircraft status sheet. 

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1 On the aircraft status sheet, MX-01, it listed 

2 that aircraft, it lists that that aircraft in 

3 particular, whichever aircraft it be, 90LJ or 

4 whatever, it lists that particular aircraft by serial 

5 number. Inspection items coming due scheduled by 

6 total time on the aircraft, by cycles, which are 

7 landing gear and or date. 

8 So the captain, once it is dispatched out to the 

9 aircraft, he takes what we call the aircraft flight 

10 can which contains the most current MX-01 as the 

11 latest flight log and the captain will then determine 

12 from the last flight, they'll look at the aircraft's 

13 total time in cycles and look at the MX-01 and make 

14 sure that his day's mission of nine-and-a-half hours 

15 will not overfly either that time, that cycle, or that 

16 date that is on the MX-01. 

17 Once that is the Director of Operations 

18 responsibility, to make sure the aircrafts are 

19 compliant on their maintenance cycle. The captain 

20 becomes, at that point, determines if the airplane is 

21 airworthy from his preflight and walk around of the 

22 aircraft. 

23 As I discussed with Mr. Singleton yesterday, it 

24 is confusing when you have the words discrepancy, 

25 irregularity, and damage. As we used the example of 

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1 tires of a discrepancy, one individual may consider a 

2 tire to be bald to the point of not safe for the 

3 flight and would write that up as a discrepancy and 

4 one individual may feel that the tire is of tolerance. 

5 If the individual who feels that the tires are 

6 not tolerant, he should fill out the MX-01, and then 

7 he seeks a maintenance technician, mechanic to come 

8 out and use his reference of materials and that would 

9 be the tire manufacturer of the Airplane Maintenance 

10 Manual to determine of the tire within limits. 

11 That discrepancy interpretation within the 

12 industry has not a black-and-white line that you can 

13 determine. The captain is the one who ultimately 

14 makes the decisions on discrepancies and 

15 irregularities. Our MX-02 form is for the captain to 

16 indicate any irregularity or any discrepancy that he 

17 feels needs to be addressed by the mechanic. 

18 Q. There's been testimony presented by the FAA in 

19 its case in chief that the captain consulted with you, 

20 in particular, about this particular GPU problem and 

21 the FAA's position, as I understand it in its case in 

22 chief, is that the Respondent, your company, is 

23 ultimately responsible, what is your position about 

24 that, if any? 

25 A. When you say that we're ultimately responsible 

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1 for 

2 

3 

Q. 

A. 

For any maintenance problems that arise. 

We are responsible. Again, the captain of the 

4 ship is in command and is ultimately responsible for 

5 his ship and his passengers. As his discretion, he 

6 must determine, with everything available to him, the 

7 Aircraft Flight Manual, the checklist, and that nature 

8 that we use, is the aircraft in an airworthy 

9 condition. 

10 If he does not feel that it is, he then writes a 

11 discrepancy up, and at that point seeks for 

12 maintenance to be done. We do hold our -- we our 

13 responsible for the safety of the flight and the 

14 aircraft. We ultimately hold that responsibility, but 

15 this flight, in particular, we are confident that the 

16 aircraft was in an airworthy condition. 

17 The captain made an assessment of the GPU 

18 receptacle, felt it was not an issue for the start and 

19 continuous of that flight. He didn't need it. Upon 

20 arrival at his destination, he went (inaudible) this 

21 patient once admission from that standpoint and was 

22 completed, he elected to troubleshoot the problem that 

23 he had had in Marsh Harbour, and by having the lineman 

24 plug in the GPU, turn it on, and have a positive 

25 outflow, he concluded that it was a normally operating 

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1 GPU. He couldn't, at that point, determine what the 

2 issue was in the Bahamas, and it was a non issue for 

3 him at that point because the aircraft was operating 

4 functional and normal. 

5 Q. The FAA's case in chief appears to indicate--

6 there's a concern expressed by the FAA that subsequent 

7 repair to the GPU, power unit, and the bracketing 

8 around the power unit indicates that was a problem and 

9 that problem arose quickly, essentially after May 3, 

10 2009 since the repair was performed on May 20, 2009, 

11 what is your position, if any, about that evidence 

12 that was presented? 

13 A. Well I believe that evidence is referenced to the 

14 second count of the complaint, which has now been 

15 withdrawn, that damage had occurred and an entry had 

16 failed to have been done. The question the issue 

17 in count one in question is that they alleged that 

18 there was a discrepancy of the GPU receptacle, and the 

19 captain, at that point, should have filled out an 

20 MX-01 and by failing to fill out, I'm sorry, an MX-02, 

21 by failing to fill out that sheet, that we were in 

22 violation of our General Operation's Manual and 

23 therefore ultimately in violation of 135.23. 

24 Q. Given the fact that you also knew, because of the 

25 conversation you had with Mr. Plas on May 3, 2009 of 

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1 the potential GPU problem, how is it, in your opinion, 

2 that you do not share that responsibility for a 

3 maintenance entry independent of what Captain Plas may 

4 or may not have been? 

5 A. As Director of Operations, I ultimately bear the 

6 responsibility of the whole company. Ultimately, the 

7 overall of the company and as the president as well, 

8 the Director of Maintenance is responsible from the 

9 maintenance side of the house, but more so from a 

10 compliance and continued airworthiness condition of 

11 scheduled maintenance, I do bear responsibility with 

12 Captain Plas, but I was trying to express in the 

13 overview of our company, we're not a typical airline 

14 or a typical 135. 

15 We operate in some pretty far off remote areas. 

16 Captains are doing their own flight planning, their 

17 own meteorology commission. Looking at that, we have 

18 to take into the commission of the runways we're going 

19 to be landing on. For example, Bahamas, a lot of 

20 their runways are made out of coral, not Asphalt, not 

21 smooth runways like we have here in the United States. 

22 Africa has dirt strips in some cases. 

23 There is a lot that goes on in the dispatch, 

24 inside the cockpit with the crew, and on the ground. 

25 So our crews are trained and I'm very proud to say, I 

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1 would put our guys against any airline or military 

2 crew if you give them a spot on the globe and you tell 

3 them to get there, these guys evaluate everything. 

4 An airline captain that comes out to the airport, 

5 he's handed his flight plan. He's handed his route 

6 that has been determined months and years ahead of 

7 time. He walks out and his ship is safe, and he moves 

8 from A to B. A lot of the work is done for him. When 

9 you get a phone call at 2:00 in the morning and you 

10 are asked to go pick up, you know, a patient, there is 

11 a lot of planning and thought that goes into it. 

12 I stand a hundred percent behind Captain Plas, 

13 his decision that the aircraft did not have damage, 

14 did not have a discrepancy, that he had to, at that 

15 point, stop the flight and get an immediate mechanical 

16 interpretation. 

17 That is proven by Captain Plas' actions in 

18 Toronto when he requested the GPU to be plugged in. 

19 He founded that had the GPU worked properly. As Mr. 

20 Singleton's testimony yesterday, he said, ''How would 

21 you test the GPU receptacle that you felt may not be 

22 operating properly'', he said, ''plug in a GPU." 

23 Q. Okay. This GPU problem arose when the crew was 

24 in landing status at Marsh Harbour in the Bahamas? 

25 A. Yes, ma'am. 

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1 Q. And was this particular landing strip in the 

2 continental of the United States or in a different 

3 territory? 

4 A. No, Marsh Harbour is 80 miles northeast of 

5 Nassau. Nassau being 180 off of Fort Lauderdale to 

6 the east. 

7 Q. Is there anything else that you would like to 

8 talk about in terms of the May 3, 2009 incident before 

9 we talk about the penalty that has been proposed? 

10 

11 

A. No, rna' am. I don't believe there is anything 

other than, you know, to continue to go over. I 

12 believe that our crew performed above and beyond and 

13 did an excellent transport. The mission was completed 

14 successfully. He used the General Operation's Manual. 

15 In fact, Mr. Plas called me, but he necessarily 

16 didn't call me. I was in the office at the time, and 

17 I picked up the phone and he is calling back to 

18 dispatch saying we're fueled. We're getting ready to 

19 take off. We'll be in Toronto in two hours and 48 

20 minutes. He would probably say three hours, but I 

21 happened to answer the phone that morning, I believe. 

22 Brandon, just FYI, I had this, not sure its not an 

23 issue because we didn't need it. I'm in route. I'll 

24 let you know when I get to Toronto. 

25 I put that, you know, trust as any airline would 

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1 or air force would put him in their command to 

2 maintain his ship in the most airworthy condition of 

3 his ability. 

4 Q. Let's talk a little bit about the fine. The 

5 proposed fine at this point is $6,100 for the 

6 remaining one violation that is alleged, do you have 

7 anything you would like to talk about in terms of the 

8 FAA's calculation of that proposed fine? 

9 A. Well, I asked Ms. Farmer earlier if she had gone 

10 through the mitigating, aggravating factors in 

11 thinking specifically of only the violation of failure 

12 to follow the general operation procedure. I 

13 personally believe that the $6,000 figure is an 

14 excessive figure. 

15 For an Operator with our ability, our Operation 

16 Specifications issued by the Federal Aviation with an 

17 impeccable record, an unblemished record, your Honor. 

18 This is why I'm here. This is a blemish that I do not 

19 feel that our company has caused and is due a 

20 violation. That's why I'm vigorously defending my 

21 company and our captains. This is not a cover up. 

22 THE COURT: Why don't we do this, I did 

23 

24 

25 

say to you at the end of your first narrative 

that you would have a chance to go and talk to 

your assistant, Mr. Bowen, anything that you need 

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1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

to address. It may be a good time for a quick 

morning recess. 

How much time would you like to have, 

five or 10 minutes? 

MR. HONEYCUTT: Ten, your Honor. 

THE COURT: We'll take a short recess. 

We're off the record at this point. 

(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 eight-minute 

morning recess. All parties previously 

identified have returned to the hearing room, and 

Mr. Honeycutt has reseated himself in the witness 

chair. 

Mr. Honeycutt, you are still under 

oath. 

MR. HONEYCUTT: Yes, ma'am. 

22 BY THE COURT: 

23 Q. Do you have anything, in addition to your 

24 narrative statement, that you would like to add now 

25 before we turn to Mr. Vines for cross-examination? 

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1 A. I would, your Honor. You spoke earlier asking 

2 about the receptacle being replaced. We don't have a 

3 log entry. The aircraft has been returned to that 

4 facility. The owner of the aircraft has the logbooks 

5 now. I could obtain it, but the aircraft went to 

6 Brandis Aircraft who owns the aircraft. Worldwide 

7 leased the aircraft from him, and per our agreement, 

8 they own their own maintenance facility and maintain 

9 Learjets. 

10 When I went into the facility to return the 

11 aircraft for a scheduled, I want to say B check it 

12 was, which is a 600-hour airframe-and-power-plant 

13 check, the owners elected to put a new receptacle in 

14 and add that doubler to beef it up and make it 

15 stronger. 

16 It wasn't, we flew the aircraft to run this 

17 course specifically and it needed a new receptacle. 

18 wanted that to come out. There would be a log entry 

19 reflecting the scheduled maintenance that went along 

20 with that entry, but no log entry was obtained. 

21 Q. When you say there would be a log entry, that 

22 would be by Brandis instead of your company? 

A. Yes, ma'am. 

I 

23 

24 Q. And when was the aircraft returned to Brandis; do 

25 you recall? 

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1 A. Yes, ma'am, in Exhibit C-4C. Again, the 

2 identifying codes at the top, the aircraft left 

3 Brooksville's base, went to-- I don't know offhand, 

4 probably somewhere in Tennessee maybe and then from 

5 there into TAZ, which is Taylorville, Illinois. 

6 Brandis Aircraft facility is in Taylorville, Illinois. 

7 

8 

Q. 

A. 

And this is on C-4C as in cat? 

Yes, that's the exhibit, ma'am. It shows the 

9 flight log for the aircraft for that day ended up 

10 Taylorville, and then if you'll refer to 

11 Q. I'm sorry, can you hold up your C-4C and show me 

12 where it shows that. 

13 A. Yes. 

14 Q. I have C-4E as in egg is what you are showing me; 

15 is that right? 

16 

17 

18 

A. 

Q. 

A. 

I'm sorry, yes. 

Okay, that makes a difference. Thank you. 

Yes, ma'am, and then if you'll refer to the log 

19 entry Exhibit C-10, C-11, your Honor. The maintenance 

20 entry for the addition of the -- or new replacement of 

21 the GPU receptacle and bracket. Then it says filled 

22 in with the doubler. May 20, 2009 is when that was 

23 completed. 

24 Q. But turning back to C-4E as in egg, can you tell 

25 us what date your company returned the leased aircraft 

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1 to Brandis? 

2 A. On May 14, 2009, N90LJ departed Brooksville and 

3 stopped at Juliette, x-ray, November, and then 

4 continued into TAZ, which is Taylorville, Illinois 

5 

6 

Q. 

A. 

Thank you. 

-- for scheduled maintenance. During that 

7 maintenance, Brandis Aircraft elected to replace the 

8 GPU receptacle, mounting bracket, and put a doubler on 

9 to reinforce that GPU receptacle. That was completed 

10 on May 20th, six days after it arrived in Brandis. 

11 Q. Anything else you would like to add to your 

12 narrative? 

13 

14 

A. Just that that was elected by the owner of 

Brandis to do that. It was not requested. It was not 

15 an item that needed to be done there. They chose to 

16 do that at their own discretion as the owner. With 

17 that, I would have nothing else. 

18 

19 

20 

21 

22 

23 

24 

25 

Q. Okay. 

THE COURT: Mr. Vines, do you have any 

cross-examination? 

MR. VINES: Yes, Judge. 

CROSS-EXAMINATION 

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1 BY MR. VINES: 

2 

3 

4 

Q. 

A. 

Q. 

Mr. Honeycutt, do you hold an AP Certificate? 

No. 

What about, to your knowledge, does Captain Plas 

5 hold this certificate? 

6 

7 

A. 

Q. 

No, sir, not at the time of 2009. 

Okay. I want to ask you, you testified earlier, 

8 if a pilot documents a discrepancy in the MX-02 form, 

9 then a mechanic is sought out to inspect the issue, 

10 did I understand your testimony correctly? 

11 A. It is the -- yeah, I would have to read it back 

12 exactly, but the MX-02 is a form that is for the pilot 

13 or first officer to fill out a discrepancy that he has 

14 found with the aircraft. 

15 Q. Okay. And you testified earlier that your 

16 business requires flights to all across the globe, do 

17 you have, I guess mechanics employed by your company 

18 posted at all of these cities your aircrafts fly to? 

19 

20 

A. No, I don't have mechanics posted around the 

world. I have a organization that I work with that 

21 their specialty is, if you were to break down in a 

22 certain part of the world, they have resources at 

23 their disposal. They'll know that you would need an 

24 FAA Certified Mechanic. For example, if you are in 

25 Turkey in Istanbul and you have an incident and an 

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1 issue that you need resolved, that's called 

2 maintenance out away from base. 

3 To do maintenance away from base, you would 

4 ultimately have to have a -- it is very complicated. 

5 You would have to have a FAA Certified Mechanic who 

6 may be a Turkish citizen with a EASA Mechanic Engineer 

7 License, but he would also have to have a FAA issued 

8 certificate or he would have to work for a 145, I 

9 believe. 

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A. 

A Part 145? 

I'm looking to Ms. Farmer for help. 

THE COURT: She can't help you. 

MR. HONEYCUTT: I know, your Honor, I 

apologize. 

It is a designation of a facility 

outside of the United States that has the 

capability and approved by the FAA to work on the 

aircraft. Then, if it is just an individual who 

just has a mechanic license, then we get into the 

issue of, well he has to be on a drug-testing 

program to meet our compliance. It is very 

22 intense when we are outside of the country. 

23 BY MR. VINES: 

24 Q. So let's go through that, you said you contracted 

25 the organization, what organization is that? 

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A. Richard -- I would have to -- Richard Gardner. 

forget the name of the organization. I might be able 

3 to find it in my cell phone. 

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THE COURT: Do you want that 

information? 

MR. VINES: I don't need that 

information, Judge. 

THE COURT: Thank you. 

9 BY MR. VINES: 

10 Q. It is my understanding you work for an 

I 

11 organization so that helps you obtain mechanics if you 

12 are airborne and you are in other cities or other 

13 countries and you need maintenance on these aircrafts, 

14 is that the gist of it? 

15 A. Their organization is a resource that I would 

16 use. As their resources, they know where there's FAA 

17 registered mechanics. Depending on the nature of the 

18 issue, if it is an engine issue, then you may need to 

19 find someone from a different country. 

20 You know, so these guys are basically a resource 

21 that we would call and say this is our issue, and they 

22 will give you options that you may be able to use. 

23 Q. Okay. So for example, you said Turkey, let's say 

24 your aircraft is in Turkey and it breaks down, you 

25 contact Richard Gardner's organization, can you walk 

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1 me through the steps? 

2 A. Well, it is a little more than that. I'll give 

3 you an example. We just went to Iceland, and we had a 

4 flat tire. We blew a tire on departure. Now, at that 

5 point, the captain stops, you know of course stops the 

6 aircraft, the Director of Maintenance -- the captain 

7 will follow his procedures. His procedures, through 

8 his GOM Manual and through his experience, will call 

9 back to operations. 

10 So we have an incident, if we have a patient on 

11 board or a passenger, you know, we have to get 

12 everyone stabilized and secured. Then the captain at 

13 that point assesses the situation, calls back to the 

14 Director of Operations and says I need to speak to the 

15 Director of Maintenance. We have an issue here. 

16 The Director of Operations will be brought into 

17 this situation, and once the situation is secured 

18 where its at and operations working with those people 

19 will determine a fix or an exit strategy for them, 

20 either using resources in a country or -- which I have 

21 elected to do more of, is transport my team to my 

22 medical, my mechanics, Brian and Tony to the 

23 situation, that way I know I'm covered from multiple 

24 angles. 

25 Q. I want to direct your attention to Exhibit C-11, 

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1 which is the maintenance-record entry dated 2009. 

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A. C-11? 

Q. Yes, sir. 

A. Yes, sir, I have it. 

Q. Kurt Handing, do you know Kurt Handing? 

A. Only in passing. I know Kurt works in Brandis. 

I don't know if he still works there. I haven't been 

8 there in about a year. Kurt's specialty was sheet 

9 medal. He worked for --working on Douglas F16's in 

10 St. Louis. He has a specialty in sheet medal. 

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Q. 

A. 

Douglas is an aircraft manufacturer? 

Yes, sir. His background was a fabrication of 

13 that aircraft. 

14 Q. When you said earlier that its become Worldwide's 

15 practice to transport your own maintenance team to 

16 other cities to inspect or work on your aircraft, when 

17 did Worldwide begin that policy? 

18 A. Its been our policy since '07. My business 

19 philosophy in having down this, having flow Learjets 

20 around the world, any time you can take a middleman 

21 out of something that can cause you trouble or slow 

22 something down and maintenance being an issue that we 

23 try to do all ourselves, I don't like to send out, 

24 especially in a foreign country. 

25 You are relying on those people, and I don't 

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1 know, having unable to inspect these facilities, I 

2 haven't had a chance to check their facility, what 

3 type of equipment they are using, is it modern, old, 

4 you know. So a lot of that plays in, but the area and 

5 the situation also plays into account. 

6 If you have a patient on board, you know, now I 

7 have to put a patient in a hospital in a Foreign 

8 country. There is a lot involved. 

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MR. VINES: I don't have anything else, 

Judge. 

THE COURT: Thank you, Mr. Vines. 

Mr. Honeycutt, this is an opportunity 

for you to meet with your assistant and discuss 

things with your assistant and then come back for 

a brief redirect narrative. I'm looking at the 

clock. It looks like we could take another 10 to 

15 minutes, would you prefer 10 or 15 minutes? 

MR. HONEYCUTT: Fifteen would be great, 

your Honor. 

THE COURT: Okay. Then we'll recess 

until 11:00. Did you have a question first? 

MR. HONEYCUTT: I just want to confirm 

that the count of the violation is count one 

only, the tear and the damage is no longer an 

issue, the skin issue, because Brian Fanning I 

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would call to testify specifically, but I would 

not need to do that if we're just talking about 

the failure to document under the Maintenance 

MX-02 form. 

THE COURT: Mr. Vines, would you 

confirm that? 

MR. VINES: Judge, the Agency's count 

referenced in the complaint, the Agency is 

essentially arguing count one, which is 

paragraphs three, four, five, six, seven, eight, 

as well as 12A. The allegations there, I'll read 

them. 

THE COURT: Well you don't need to read 

everything to us. We all can read ourselves, but 

essentially there is a request from the 

Respondent's lay representative as to defining 

the scope. Can you just briefly summarize the 

scope? 

MR. VINES: Sure, Judge. The scope is 

that there was a ground-power-unit receptacle 

that was damaged that was on Aircraft N90LJ that 

the Worldwide General Operation's Manual required 

a documentation of that damage and that the 

flight crew was aware of that damage and did not 

document it. 

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THE COURT: Does that help, Mr. 

Honeycutt? 

MR. HONEYCUTT: Yes, ma'am, it does. 

THE COURT: Okay. Then we can go off 

the record for our 15-minute recess. 

(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 

15-minute recess. All parties previously 

identified have returned to the hearing room, and 

we have two new people in the observers area. 

Mr. Honeycutt, are you planning to 

provide any further narrative testimony after 

cross-examination? 

MR. HONEYCUTT: No, ma'am. 

THE COURT: Okay. Are the two people 

in the observers area part of your responsive 

case? 

MR. HONEYCUTT: They were, your Honor, 

to be called as witnesses, but I'm not going to 

call them. 

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THE COURT: Okay. Are you planning to 

rest your responsive case? 

MR. HONEYCUTT: I am prepared to rest, 

your Honor. 

THE COURT: Okay. So noted. 

Mr. Vines, would you like to make a 

closing argument, if so, are you ready to do so? 

MR. VINES: Judge, I would like to make 

a closing argument. I talked with the Respondent 

on break, and we agreed, if you would oblige us, 

30 minutes to prepare for closing arguments. 

THE COURT: Okay. So it is about 11:05 

now. Do you want to take an early short lunch or 

you want -- how do you want to do that? 

MR. VINES: I would not be opposed to 

that. 

MR. HONEYCUTT: Yeah, that would be 

fine, your Honor. 

THE COURT: Okay. Right now we can 

come back either at noon or 12:15, depending on 

what your pleasure is. 

Mr. Vines. 

MR. VINES: I'll refer to the Court. 

THE COURT: Mr. Honeycutt. 

MR. HONEYCUTT: 12:15 would be good. 

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THE COURT: Okay. Why don't we do that 

and that way you can have a quick bite to eat and 

also prepare your closings. 

With that, we can go off the record, 

and I'll see you back here at 12:15. 

(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 an early lunch 

recess. All parties previously identified have 

returned to the courtroom for presentation of 

closing argument. 

Generally, and we didn't talk about 

this before how much time to take, generally 

people typically take about 20 minutes or so. 

You can take less than that if you want. If you 

go a little over, that's fine to. 

Mr. Vines, are you ready to present 

closing for the FAA? 

MR. VINES: Yes, Judge. 

THE COURT: Okay. You may proceed. 

I should have all the exhibits up on 

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the witness desk. If you need to use them or 

refer to them, they are right here. 

MR. VINES: Judge, the Respondent, 

Worldwide Aircraft Services as amended in 

paragraph two of the complaint which alleges that 

the Respondent was and is currently a holder of 

Air Carrier Certificate No. W50A880L. 

The Agency has shown by the testimony 

of Inspector Kahler, Donahue, and Singleton, as 

well as Worldwide Aircraft owner Mike 

Honeycutt 

THE COURT: I'm sorry, could you speak 

up just a little bit, please. 

MR. VINES: Yes, Judge. The Agency has 

shown by the testimony of Inspector Kahler, 

Donahue, and Singleton, as well as Worldwide 

Aircraft Mike Honeycutt, as well as Exhibit C-3C, 

which is Worldwide's Operation Specifications, 

that the Respondent is authorized to conduct 

operations under Part 135 under Federal Aviation 

Regulations, and therefore subject to the 

Regulations set forth in Part 135, including 

section 135.21A. 

The Respondent has admitted paragraph 

three of the complaint, which states on or about 

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May 3, 2009, Worldwide operated Civil Aircraft 

N90LJ on Learjet 250 on a flight from TDPD, which 

is Dominica to MYAM, Marsh Harbour, under Part 

135 of the Federal Aviation Regulations. 

As to part four of the complaint which 

the Respondent denied, the Agency has shown that 

after the flight referenced in paragraph three of 

the complaint, the flight crew, including 

Mr. Brandon Plas, learned that the 

ground-power-unit receptacle was damaged. 

Specifically Brandon Plas testified 

that he operated the flight from TDPD to MYAM as 

the captain or also referred to as pilot in 

command. During Plas' testimony, he referenced 

Exhibit 8A and 8B. That exhibit is a statement 

that he wrote and signed on June 8, 2009, less 

than one month after the May 3, 2009 flight from 

TDPD to MYAM. 

Captain Plas testified that his 

statement was accurate and correctly documents 

the events that occurred on May 3, 2009. Captain 

Plas' statement states that upon landing in MYAM, 

he noticed the pins inside the GPU receptacle 

were bent which prevented him from plugging the 

GPU into the aircraft. 

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Plas also stated that when he realized 

that he failed to disconnect the GPU unit from 

the aircraft before taxiing the aircraft and 

taking off from Brooksville, Plas stated that he 

contacted the Director of Operations, Mike 

Honeycutt, to inform him of that issue. 

The Respondent has admitted paragraphs 

five and six of the complaint, which references 

the Respondent's General Operation's Manual, 

section E-3 and F-1 of the manual required the 

Respondent to complete an aircraft-discrepancy 

form documenting any mechanical discrepancy or 

irregularity in aircraft discrepancy form MX-02. 

As to what damage constitutes the 

mechanical discrepancy, Inspector Singleton 

testified as an expert in General-Airframe-and 

Power-Plant Maintenance. Inspector Singleton 

testified that any anomaly with the aircraft 

constitutes a discrepancy, including the bent 

prongs inside the GPU receptacle. 

Judge, I point out that Inspector 

Singleton's testimony is consistent with the 

findings in the case of the FAA versus Sundance 

Air, Docket No. FAA-2004-17789. Sundance Air, a 

Part 135 Operator like Worldwide Aircraft, argued 

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that an inoperative aircraft GPS and radar was 

not a major cause of concern and thus not worthy 

of proper log entries. However that argument was 

objected by Administrator Law Judge, Richard 

Goodwin. 

Deciding Administrator B. Hartisan in 

TSP Order EA3997, Judge Goodwin found that, "Any 

deviation from normal functioning of the aircraft 

component, no matter how slight or momentary, 

constitutes a mechanical irregularity. 

Mechanical irregularities require a logbook 

entry. 

Administrative Law Judge Goodwin even 

went on to say even a small worry, warrants a 

record, "The regulations do not distinguish 

between degrees of irregularities. Full and 

accurate record keeping is critical. It is the 

(inaudible) end of safety." 

THE COURT: What page are you quoting 

from from this particular case that you provided 

both the Court and to Mr. Honeycutt on the first 

day of the hearing; do you recall just offhand? 

MR. VINES: Yes, Judge. Page five. 

THE COURT: Thank you so much. 

MR. VINES: Inspector Singleton 

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testified that without proper inspection of the 

GPU receptacle by a mechanic at Marsh Harbour, it 

was unknown as to the extent of the damage 

sustained to the GPU receptacle at the time of 

the aircraft, in this case, N90LJ, landed in 

MYAM. Inspector Singleton testified that at 

worse the damage could cause the insulation 

surrounding the pins to be compromised which in 

turn may cause an electrical current and cause a 

fire. 

Mr. Honeycutt testified that the bent 

prongs of the GPU unit did not constitute a 

discrepancy or an issue with the aircraft. 

However, Judge, the actions of the pilot tell a 

different story. Captain Plas through his 

statement, marked as Exhibit C-8, testified that 

he contacted the Director of Operations, Mike 

Honeycutt to discuss the issue. 

Moreover, Brian Fanning stated in his 

statement, which is marked as Exhibit C-10, that 

he was informed by the pilot in command of the 

flight that damage could have occurred to the GPU 

unit. The Administrator submits that Plas' 

decision to call Mr. Honeycutt on May 3, 2009 

while in Marsh Harbour to discuss the concern, as 

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well as to notify the Chief of Maintenance on or 

about May 7th of 2009, indicates that a 

discrepancy existed with the GPU receptacle on 

May 3, 2009 in marsh Harbour. 

In fact, Mr. Honeycutt stated that 

Mr. Plas disclosed that quote, ''He wasn't sure 

about the issue.'' Mr. Honeycutt testified that 

it was Captain Plas' prerogative to determine 

airworthiness of the aircraft, and therefore 

properly inspect the bent prongs for damage and 

any collateral damage to the GPU unit. 

However, this statement is 

contradictory to another statement made by Mr. 

Honeycutt, that if the pilot documented a 

discrepancy, the mechanic would inspect the 

damage addressed in the pilot's entry. 

If the pilot in command is authorized 

to assess the damage, then why have the 

procedures in paragraphs E-3 and F-1 of 

Worldwide's General Operation's Manual, which 

requires the company mechanic to clear a deferred 

discrepancy. Of note, both Captain Plas and Mr. 

Honeycutt testified that they do not hold an 

Airframe-and-Power-Plant Certificate. 

Additionally, the GPU receptacle was 

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replaced on May 20, 2009. That is Exhibit C-11. 

The Administrator agrees with Mr. Honeycutt's 

testimony that the GPO receptacle was replaced by 

the owner of the aircraft, Brandis. Brandis 

replaced the receptacle because it had a bent 

plug as documented by Brandis employee, Kurt 

Handing, in an e-mail marked as Exhibit C-12. 

Again, this fact supports a finding 

that on May 9, 2009, Captain Plas observed a bent 

prong of the GPO receptacle and that that damage 

constitutes a discrepancy required to be 

documented on an MX-02 form, which is prescribed 

by Worldwide's General Operation's Manual. 

So what is the real reason Captain Plas 

did not document the GPO receptacle damage, the 

bent prongs on Worldwide's MX-02 form. As 

Mr. Honeycutt stated in his testimony ''time is 

tissue.'' Mr. Honeycutt testified about concerns 

with pilot-duty time. Additionally, Mr. 

Honeycutt testified that obtaining a mechanic to 

inspect a discrepancy in a city outside of a 

country is complicated, intense, and sometimes 

requires flying in a mechanic, including his own 

employees to assess the discrepancy. 

Unfortunately, this process takes time. 

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The flight log for May 3, 2009, exhibit 

C-4A, shows a crew-duty time of 14 hours. Had 

Worldwide documented the damage, which required a 

mechanic to inspect the damage, that protocol to 

obtain a mechanic to come in and inspect the 

discrepancy, would chip away at the crew-duty 

time, which, in this case, would have likely 

grounded the flight crew and perhaps prevented 

Worldwide from getting its aircraft and the 

patient on board to the destination to Toronto. 

I would site Federal Aviation Regulation 

135.267C, which addresses pilot duty and 

flight-time limitations. 

The Administrator has also held that a 

Part 135 Operator remains responsible for the 

violations of its employees and responsible for 

the condition of its aircraft. I point to you a 

case in the matter of Alika, A-L-I-K-A, Aviation, 

Docket No. CP97WP0045 and that was issued 

December 21, 1999. Likewise, Worldwide is 

responsible for the actions of its employee, 

Captain Brandon Plas. 

By virtue of the foregoing, Worldwide 

failed to document the discrepancy regarding the 

GPU receptacle, and as a result failed to ensure 

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that its flight personnel failed to use the 

General Operation's Manual when conducting its 

operations which is a violation of Part 135.21A. 

The Administrator also sites the case 

in the matter of American Air Network, Docket No. 

CP04WP0013. There, the Administrator affirmed 

the Department of Transportation Administrative 

Law Judge findings that American Air Network, 

Part 135 Operator violated 135.21A when the 

company failed to follows its own approved 

Aircraft Inspection Program. 

The Agency has proposed a civil penalty 

of $6,100 in the violation of Federal Aviation 

Regulation of 135.21A. This CP is supported by 

the Administrator's Sanction Guide and Policy and 

evidence presented in this case. According to 

the Administrator's Sanction Policy, Table of 

Sanctions, which is referenced as Exhibit C-17, 

specifically pages B-3 and B-4 of that exhibit, 

the Respondent falls into the category of the 

group three carrier. That is because Worldwide 

employed six-to-eight pilots during 2009 pursuant 

to Mr. Honeycutt's testimony. 

Additionally, figure BlJ5 found on page 

B-14 of Exhibit C-17 is applicable to this case. 

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It sites a failure to make a required entry in an 

aircraft log. This figure recommends a CP in the 

range of minimum to maximum. When calculating 

the sanction, it is the Administrator's policy to 

start with the dollar amount in the middle of the 

range and aggravate up or mitigate down. 

I'll refer you to Exhibit C-18, page 

7-9, paragraph 58, reason three. 

THE COURT: I'm sorry, could you start 

again with that citation? 

MR. VINES: Sure. 

THE COURT: C-18, page seven through 

nine. 

MR. VINES: Page 7-9, paragraph 58, 8 

as in boy three. 

THE COURT: Thank you. 

MR. VINES: To determine the middle of 

the range, the Administrator took the minimum 

dollar amount, which according to a group three 

carrier violations covered under 49USC, section 

46301A5A, the minimum amount is $825, and the 

maximum amount of $11,000 and divided by two to 

obtain an average, which is $5,912.50. 

The Administrator aggravated the 

sanction to $6,100 based on the criteria listed 

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in chapter seven of the FAA Order 21538, which is 

marked as Exhibit C-18. 

Judge, these factors include the nature 

of the violation, which is the fact that the 

Respondent is a Part 135 On-Demand Operator. 

Again, the type of certification, which again is 

the same fact that is a part -- that the 

Respondent is a Part 135 Operator, which case law 

and the Agency is held to a higher standard than 

that opposed to say a Part 191 Operator. 

Also, the degree of hazard in this case 

was considered and testified to by Ms. Farmer. 

The other aggravated factor that warrants an 

upward departure from the $5,912.50 average is 

the corrective action taken that was also -- the 

type of correction action taken in this case that 

was also testified by Ms. Farmer, and the fact 

that damage was observed on May 9th, a corrective 

action to that particular issue, which was the 

GPU unit was accomplished until May 20th. 

For those reasons, Judge, the 

Administrator ask that you affirm the complaint 

as amended this morning, as well as the $6,100 

CP. Thank you. 

THE COURT: Thank you very much, 

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Mr. Vines. 

Mr. Honeycutt, do you have any closing 

argument you would like to offer? 

MR. HONEYCUTT: I do, your Honor. 

Thank you. The Government's case in question is 

that did Worldwide Aircraft Services fail to 

follow its Operation's Manual, in particularly 

filling out an MX-02 form, for an alleged 

discrepancy. 

I do want to point out that Inspector 

Singleton, the FAA's expert yesterday under 

direct questioning, I asked Inspector Singleton, 

"Your testimony was that a discrepancy was a hard 

fault or failure.'' Inspector Singleton went on 

to change his definition of discrepancy, that it 

could go for many, many things on an aircraft. 

He also agreed that a pilot, not only 

two different pilots, but that they could have 

two different opinions of a discrepancy, as would 

a certified A-and-P mechanic that did a walk 

around after an aircraft came back to base, one 

mechanic could find a discrepancy while the other 

mechanic would not consider the finding of 

discrepancy. 

A discrepancy falls in the decision of 

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the eyes of the holder, and the captain, as I 

testified, has to make a decision that his ship 

is safe for the intended flight, and ultimately 

under the FAA Regulations, that decision lies 

with the captain. No one else can make that 

decision but the captain. 

Captain Plas, in this incident, had an 

incident in the Bahamas on a mission that he 

informed the Director of Operations when he 

called an hour-and-eight minutes after he landed, 

I believe it was an hour-and-eight minutes after 

he landed in Marsh Harbour, to give us his 

departure time, which was we're getting ready to 

depart. 

If Captain Plas felt that the issue at 

hand that he had was a safety issue, he would 

have called, as our Operation's Manual specifies, 

back to base to the Dispatch Center to talk to 

the Director of Operations and the Director of 

Maintenance about a potential maintenance item. 

Captain Plas did not call to report a maintenance 

item because he did not have an issue with the 

aircraft. 

If captain Plas would have had an issue 

with the aircraft, we have procedures in place to 

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put a patient on an aircraft into a facility that 

comes into our mission profile. Any time a 

patient is put on an aircraft, we have to have 

multiple contingencies and those contingencies 

are multiplied based on the patient's condition. 

So therefore, in preplanning to this particular 

mission that we knew was going to be 14-hour duty 

day and nine-and-a-half hours of flying, we could 

have just as easily brought the aircraft from 

Dominica back to Florida and done a crew change, 

or at the time JET I.C.U. operated three other 

Learjets that are in an I.C.U. configuration. 

As I testified to you, Marsh Harbour is 

roughly 220 miles east of Brooksville, which 

takes a Learjet at doing 420 miles an hour about 

45 minutes from gear up to gear down. So from 

the time Captain Plas touched down and would have 

realized he had a problem, he could have called 

dispatched, informed us, and we could have had an 

aircraft airborne in as little as an hour on the 

ground 45 minutes later from take off. So 

roughly two hours later we could have had a team 

to replace them. 

THE COURT: I'm sorry, Mr. Honeycutt, 

you need to slow down for the court reporter. 

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Thank you. Go ahead. 

MR. HONEYCUTT: I'm sorry. Roughly two 

hours, your Honor, from the call in that we had 

an incident, we could have had a relief team on 

the ground to also relieve the medical team, put 

the patient on the new aircraft. Not having 

anymore issues with duty time because we had a 

new crew dispatched and, in that incidence, we 

could have had our lead chief mechanic, Brian 

Fanning, on the aircraft to do an evaluation of 

the suspected aircraft on the ground. That is a 

scenario that happens, it has happened, and at 

this time did not need to happen because the 

captain made a decision that the aircraft did not 

have an issue. 

Upon arriving in Toronto and 

disembarking the patient and the crew members, 

the captain elected to troubleshoot the said 

potential problem, which was not a problem 

because he asked that the ground-power unit be 

hooked up to the aircraft, turned on, and the 

system worked normal. 

Again, yesterday during my testimony, I 

specifically asked the Government's expert 

witness, how would you check a potential damaged 

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ground-power unit, and his testimony was, I would 

have to plug in the GPU and see if it worked. 

So Captain Plas, having determined that 

the GPU was not a problem, did not have to fill 

out an MX Maintenance Form, MX-02, because 

Captain Plas did not have a discrepancy. Captain 

Plas did not have an irregularity and Captain 

Plas did not have damage. 

That aircraft continued on and did 

several more missions for three days. It ended 

up at a maintenance facility for its scheduled 

routine maintenance, and the owners of that 

aircraft elected to replace that receptacle and 

add a doubler to strengthen it. 

The Government's case is basically 

that, did my captain follow procedure, and as I 

just pointed out, Captain Plas followed the 

General Operation's Manual perfectly. The one 

case that I have in front of us that the 

government sites, Sundance Air is the Respondent 

versus the Federal Aviation Administration. 

This flight, this incident, the 

Sundance was violated for operating under 

135.25A, 135.65C, 135.179A, and I'm not sure if 

the federal codes there, the Code of Federal 

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Regulations or Violations as well, but having 

violated the three of the 135 Regulations 

operating an aircraft without weather born radar, 

which is pretty important when you are operating 

in flying passengers in night and weather without 

a GPS system. Well, they can use their VOR's and 

other estimates, that's not that big a deal. 

They operated 58 flights, apparently violated 

three violations, did it over 44 days, and the 

Administrator felt that the penalty that they 

carne to on page five should not exceed more than 

$5,000. 

The Government wants you to uphold 

their decision that we somehow did not follow our 

Operation's Manual and that we should be assessed 

a penalty for not making a maintenance entry into 

the aircraft log for $6,000. 

Your Honor, the Government has thrown a 

lot of sign-off statements, and there's a lot of 

contradiction in different statements as we have 

found and pointed out. This is not a black and 

white clear case. They intentionally muddied the 

water to try to have a sign off look like we had 

covered up maintenance. 

We have testimony from two of my 

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employees that Paul Kahler, Inspector Kahler, 

carne to our facility 10 days after Inspector 

Frank Schaefer made in his written statement of 

the facts, that he found no damage to the 

aircraft and that the skin around the GPU 

receptacle had original skin and original paint. 

Therefore, the anonymous hot-line complaint that 

the aircraft had the skin peeled back like a 

banana was not true. 

Inspector Kahler contradicts himself in 

his case in point that I was just recently given. 

Your Honor, it is not an exhibit, but if you read 

through the redacted form that I was given --

THE COURT: Well, that's not part of 

the evidence that's been presented to me. So I 

can't consider that. That was just disclosure to 

you. 

MR. HONEYCUTT: I understand, your 

Honor, I apologize. 

We feel that Inspector Kahler had a 

personal vendetta for Worldwide and its 

management for whatever reason. It has not been 

able to discover that reason, but I believe if 

you read through the evidence and look at 

Inspector Kahler's attitude towards the company, 

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it is very apparent that he was bent on finding 

something. Therefore, he would have not come to 

JET I.C.U. 10 days after Frank Schaefer's 

statement and demand that my lead mechanic change 

his statement, write a statement for that matter, 

then change it to what he wanted it to say. 

Your Honor, I rest. At the end of the 

day, JET I.C.U. follows its manual and takes 

pride in our operation. We have an impeccable 

record. This is an attempt by one inspector, I 

believe, to put a blemish on our record. I rest. 

THE COURT: Thank you very much. 

Mr. Vines, anything else from the FAA 

at this point? 

MR. VINES: A quick rebuttal, Judge. 

THE COURT: Okay. 

MR. VINES: The Respondent focused 

heavily on Inspector Singleton's testimony that 

you could plug in the GPU unit into the 

aircraft's receptacle and everything worked and 

that was able to be done and then a test of that 

would prove successful. The Respondent focused 

heavily on the flights that occurred after MYAM 

and flights before the aircraft on MYAM. 

Judge, the Administrator is not focused 

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on those flights. The Administrator is focused 

on the flight that landed in MYAM, and by 

Inspector Singleton's testimony, if he couldn't 

plug in the GPU unit into the receptacle, there 

is something amiss. There is something wrong. 

That is what Inspector Singleton testified to, 

that that's how you perform the test, then by 

virtue of Captain Plas' statement, that test was 

a failure. 

As to the sanction, the Respondent 

referenced Sundance Air, specific to the penalty 

that was set out there, I do agree the facts were 

different. However, possibly with those facts in 

that case are more egregious than the facts we 

have here based on the different violations 

there, but nonetheless, the Judge ultimately 

found that the Respondent in that case did 

demonstrate a financial hardship, and that would 

be the separating factor, the distinguishing 

factor in this case versus that in Sundance Air 

with regard to the specific penalty established 

by the Law Judge. 

As far as the Respondent's reference to 

Inspector Schaefer's statement found at Exhibit 

C-68 as in boy, it is the Administrator's 

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interpretation of Frank Schaefer's statement to 

be completely different than the Respondent's. 

If you read the paragraph of the second 

paragraph on C-68, Judge, Inspector Schaefer said 

that he was notified that the aircraft has 

extensive damage and that the skin was peeled 

back like a banana. If you move on, Inspector 

Schaefer went on to say that he inspected the 

aircraft, specifically aft the fuselage and found 

no such damage. 

It is the Administrator's position that 

the damage Inspector Schaefer is referring to is 

the skin peeled back like a banana. However, as 

he was inspecting it as he continued his 

investigation, he realized that a new receptacle 

and a doubler was installed. 

So this obviously appears that 

Inspector Schaefer inspected this aircraft after 

May 20th, which is when, in fact, the GPU 

receptacle was replaced, as well as the skin was 

corrected pursuant to the maintenance entry 

referenced in Government Exhibit C-11 and C-12. 

As to the vendetta against -- the 

alleged vendetta against the Respondent that the 

inspectors, whether it is Inspector Schaefer or 

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Inspector Kahler had, as the Respondent stated, 

they don't know what that vendetta is. So 

therefore I would argue that no such vendetta 

exists. 

Finally, Judge, the Respondent 

referenced the statement of its employee, Brian 

Fanning, and that Inspector Kahler threatened 

Mr. Fanning with a full investigation unless he 

changed it. I would argue that that allegation 

isn't credible. I would argue that the threat of 

investigation would lead an individual, in this 

case, to convert its story position or story from 

the truth to a falsity. 

Moreover, Inspector Kahler, in his 

testimony, testified that, in fact he did perform 

a full investigation. That's what he does. As 

to the first -- Mr. Fanning testified that he did 

draft an original statement, excuse me, the 

statement that is referenced in Exhibit C-10, 

however why he didn't feel it was important to 

keep that statement, to document and corroborate 

his allegation, that, if true, would seriously 

call into question and severely compromise the 

character and the nature of the FAA's 

investigation. Again, it leads to a conclusion 

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that there was no such original statement. The 

statement that was produced and was signed is, in 

fact, the one that is referenced in Exhibit C-10. 

Again, his story, his allegation of 

this threat, his original document, and that it 

was forced to be changed, it just doesn't pass or 

muster. Perhaps, Judge, his allegation, 

Mr. Fanning's allegation, on behalf of the 

inspector was perhaps concocted to maintain the 

status quo between him, Mr. Fanning, an employee 

of Worldwide, and his employer and supervisor, 

Mr. Honeycutt. That's all I have, Judge. 

THE COURT: Thank you, Mr. Vines. 

Thank you, Mr. Honeycutt, for your 

presentations. I really appreciate both your 

care and thoughtfulness in trying to get all the 

information before the Court. 

Before we close today, I'm going to ask 

you, Mr. Vines, to collect the original exhibits. 

I want to make sure that we have all of them that 

were moved for admission. So can you come up and 

do that now. 

MR. VINES: Sure. 

THE COURT: Once we get that done, 

we'll take care of any remaining matters before 

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we go off the record. 

Just so you know, essentially these are 

decisions that are issued in writing typically. 

A decision will not be issued today orally, it 

will issued in writing. I can't promise you when 

that will be. The court reporter typically has a 

period of time in which to file the transcripts 

of all the proceedings that have occurred and 

then you basically get put in a line of decisions 

that need to be written. 

My staff and I are trying to get 

everything out as fast as possible, but 

unfortunately we're behind. So I will say to you 

that we will get this decision out to you as soon 

as we can. 

Mr. Vines, can you come up to the 

witness chair? I'm going to ask you to make sure 

that all of the following exhibits are there and 

then to hand them to me. 

MR. VINES: Okay. 

THE COURT: C-1. 

MR. VINES: Yes. 

THE COURT: C-2. 

MR. VINES: Judge, it may be best if 

you allow me to arrange --

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THE COURT: Are they all in disarray? 

MR. VINES: Yes, Judge. 

THE COURT: Mr. Honeycutt, while 

Mr. Vines is doing this, do you have any 

questions of the Court before we end up closing? 

MR. HONEYCUTT: No, ma'am. Thank you. 

THE COURT: Okay. 

MR. VINES: Would you like me to paper 

clip some of these? 

THE COURT: If you have some paper 

clips, that would be great. I have some up here 

as well. 

MR. VINES: I'm sorry, I only have one. 

THE COURT: Okay. There should be C-1. 

MR. VINES: Correct. 

THE COURT: C-3A through J. 

MR. VINES: Yes. 

THE COURT: I'm sorry, C-2 as well. 

MR. VINES: Yes. 

THE COURT: C-4A through E as in egg. 

MR. VINES: Okay. 

THE COURT: C-5 was not offered. So 

the next exhibit should be C-6A through B. 

MR. VINES: Thank you. 

THE COURT: C-7A through B. 

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1 MR. VINES: Thank you. 

2 THE COURT: C-8A through B. 

3 MR. VINES: Okay. 

4 THE COURT: C-9. 

5 MR. VINES: Okay. 

6 THE COURT: C-10. 

7 MR. VINES: Yes. 

8 THE COURT: C-11. 

9 MR. VINES: Okay. 

10 THE COURT: C-12. 

11 MR. VINES: Okay. 

12 THE COURT: C-13A through 0 as in 

13 orange. 

14 MR. VINES: Okay. 

15 THE COURT: C-14A. 

16 MR. VINES: Okay. 

17 THE COURT: C-15 and 16 were not 

18 offered. 

19 MR. VINES: Correct. 

20 THE COURT: C-17. 

21 MR. VINES: Okay. 

22 THE COURT: C-18. 

23 MR. VINES: Okay. 

24 THE COURT: C-19A through B was not 

25 offered. Thank you for your assistance, Counsel. 

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So what I'm going to do is, I'm going 

to thank all the people who are still present 

who's testified, Mr. Honeycutt, Mr. Fanning, Ms. 

Farmer, thank you again for your testimony. 

Mr. Honeycutt, if you'll offer the 

Court's thanks to Ms. Aleski who is not present 

today. 

Mr. Vines, if you offer thanks to all 

the witnesses that you called who are not present 

today. I appreciate every-ones efforts. With 

that, I'm going to thank you all, good luck in 

the traffic war in the skies as you are going 

horne. 

We can go off the record. 

(Whereupon, the hearing concluded at 12:55 p.m.) 

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untitled 

1 CERTIFICATE OF REPORTER 

2 STATE OF FLOI\IDA 

3 COUNTY OF HILLSBOROUGH: 

4 

5 I, LAURA MORALES, Court Reporter, 

6 No1:ary Public, certify that I was authQrized 

7 to and did stenographically report the foregoing 

8 proceeding and that the transcript is a true 

9 and complete record of my stenographic notes. 

10 I further certify that I am no1: a 

ll relij.Live, emp1oyee, atto-rney, or counsel of 

12 any of the parties, nor am I a relative or 

13 employee of any of the parties' attorney !lr 

14 counsel connected with the action, nor am I 

15 financially interested in the action. 

16 

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24 

25 

Dated this d0+hof march, 2014 

L~ora]es, ~WL'-f~~h ~~ ~ court R"porter, NotaryPubli c 

Stat.e of Florida at t.arge MY commi s$i on N(). : FF029798 

E)(pires: June 10, 2017