1 2 3 

# ORIGINAL

U.S. DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS

WASHINGTON, DC

4 In theMatter of, 5 WORLDWIDE AIRCRAFT SERVICES, INC., 6 

### Docket No. FAA-2013-0045 Case No. 2009S0150216 Respondent. 7 8 9 

### 10 11 

### 12 13 14 15 16 17 

### 18 19 

## __________________________/

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. 23 24 25

### Hearing WorldwideAircraftServices,Inc.

1 APPEARANCES: 2 U.S. DEPARTMENT OF TRANSPORTATION J.E. SULLIVAN U.S. ADMINISTRATIVE LAW JUDGE 3 1200 New JerseyAvenue, 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 10 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 15 16 ALSO PRESENT: 17 Paul Bowen 18 

### 19 20 21 22 23 24 25



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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 22 23 24 25 I N DE X (Continued) Direct Cross Redirect Witnesses for theAgency: 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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Recross

137

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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 22 23 24 25 P R 0 CE E D I N GS

THE COURT: We're on the record in the matter ofWorldwide 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 representedby 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 verybrief 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 housekeepingmatters to address? MR. HONEYCUTT: Your Honor, justMr. Singleton, requesting to be able to interview Mr. Singletonprior to his testimony. THE COURT: Okay. And letme 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 investigationhe did and that type of testimony will not be utilized or information will not be utilizedbyMs. Farmer regarding the assessment of the fine, is that satisfactoryto 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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, excuseme, Inspector Schaefer's testimonywith 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 fromMr. 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 interviewMr. 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 courtroomto listen to testimony and so has the Respondent. So based on that, Judge, again I do not feel that themotion 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 couldbe available tomorrow. I've also checkedmy travel arrangements, and there's a potential for me to move some other things onmy calendar and stay for tomorrow. I don't know if it is possible for Mr. Vines to stay for the full day, whether we

For

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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 22 23 24 25 have the court reporter for the full day, and whether the witnesses couldbe 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 affirmtravel 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 shouldbe available all day tomorrow. As far as Ms. Farmer, she will onlybe available through lunch tomorrow. So she would probably have to leave



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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 22 23 24 25 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 couldbe an issue, but me and themajority 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 toAmerican, 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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### 21 22 23 24 25 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 likelyhave 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 denyingmymotion 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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1 2 3 4 5 6 7 8 9 10 THE WITNESS: Yes, ma'am. THE COURT: Thank you verymuch. 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? 12 13 14 15 16 17 18 19 20 21 22 23 24 25 

### 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 

### 17 18 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 hadwith 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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1 2 A. Q. That's correct. You askedMr.

-- No. 5 here on your statement, I 3 asked ifhe felt any unusual control pressure in 4 excessivepower 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 hadbeen 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 andwas 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. 18 19 20 21 22 23 24 25 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 conversationbetweenme 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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1 2 3 THE COURT: Well, did you want this witness to confirm that latterportion of what youjust 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? 11 12 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? 17 18 19 20 21 

### 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: 

### 24 25 Q. A. Can you produce them for us? I can.



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1 2 3 4 5 6 7 8 9 10 11 12 13 

### 14 Q. Would you, please. THE COURT: Do you have themwith 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 tobe pictures that are available for you. MR. HONEYCUTT: May I approach? THE COURT: Youmay. MR. HONEYCUTT: Thank you. THE COURT: I'll note that Mr. Donahue 15 has handedMr. 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 anAviation Ground Equipment Corporation 20 Manual referenced in a Hobart Ground Power Unit, you 21 would agree with that? 22 23 A. Q. Correct. And is it your testimony that this is the type of 24 equipment that is alleged to have been attachedto 25 90LJduring the alleged departure with it attached?



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1 2 

### A. Q. 

### I do. And ifI'mreading this correctly, you have 3 highlighted on this the weight of the DFS400 Model to 4 be 728 pounds? 5 6 

### A. Q. 

### That wouldbe 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 ofpaper, 728 pounds? 12 13 14 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 inmy 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, andthen it was presented to 20 you, as I recall, but I have no documentation to that 21 effect, that I didbring that to your attention, and 22 it was confirmedthat this was similar equipment that 23 was used, specifically addressedby you, that itwas 24 on wheels. 25 I noted that to your attention, and you confirmed



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### 3/6/2014

1 to me yes, that is the similar equipment. It did not 2 specify the make andmodel. 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 wouldbe 7 stationary, wouldbe 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? 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. That wouldbe 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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1 2 3 

### MR. HONEYCUTT: I'll give this back to the witness, your Honor. THE COURT: Youmay. Thank you. 4 I'll note thatMr. Honeycutt is 5 approaching the witness againwith 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 youbemore specific? 12 Q. 

### How didthe hot-line complaint come to you, how 13 were you notifiedof 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 twomanners, one a phone conversation. At that time, 19 the inspectorthat 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 portrayedwith as much information as possible, the 24 inspector thenwould submit this information directly 25 to the front-line manager.



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1 The front-line manager would thenmake the 2 assignment goingto the administrative-staff assistant 3 up front who wouldmake 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 tomanagement. The 9 front-line manager wouldmake a selection of an 10 appropriate inspector. The documentationwould 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 assignedtome 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 departedthe 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? 3 4 5 6 7 8 9 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 frommy end, 14 it was strictly an -- 15 16 17 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? 21 22 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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1 2 3 Q. A. Q. You didn't? Not that I recall. Okay. And so you can't testify toMr. Schaefer, 4 but did Mr. Schaefermake a statement to you that he 5 saw 90LJ? 6 A. The topic did not come up betweenMr. Schaefer 7 andmyself. 8 Q. So it is your testimony that you've never seen 9 any damage on 90LJ? 10 11 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. 15 16 Q. I just want to be clear. I'mnot trying to be facetious, I apologize. I just wanted to make sure 17 you didn't see damage. 18 19 20 21 22 23 24 25 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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1 2 BY MR. VINES: 3 Q. I wanted to ask ifyou recall or if you are able 4 to testifyhowmany 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

-- 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 orN90LJ. So I was just following up with the inspector as to howmany, 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 Bbecause you hadmoved to admit the evidence again this morning, and I reserved it until the conclusion ofMr. 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 quickbreak, and, Mr. Honeycutt, if you could check in withMs. Aleski please about her availability either this afternoon and or potentially tomorrowmorning. 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 ofWorldwide 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 likewe have a potential for coming into the Court tomorrow. Officer Brian advisedme during the brief break that the courtroomwould 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 littlebit of time. I'm going to grant the Respondent's motion for a brief time to interviewMr. Singletonbefore going on the record. I'mnot 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 interviewwith 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 canmake 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 

### 17 18 19 20 21 22 23 24 25 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 recordin the matter ofWorldwide Aircraft Services, Inc. This is Docket No. FAA-2013-0045. All parties previously identifiedhave returned to the hearing room. Andmy first question wouldbe to you, Mr. Vines, are you ready to proceedwithMr. 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 themthat were relevant to their opinions that you do not have and need to have in order to adequatelyprepare? MR. HONEYCUTT: They did not get into excessive detail of what part of the file that they used that I have not beenprivy to. Ms. Farmer insinuatedyesterday that Mr. Hoban, I believe it was her prior, was the

one who came to the conclusion to the violation and that it was excessivelyhigher than it was than the current $12,000 proposed violation, leadingme tobelieve that there is evenmore extensive information in the EIR that Mr. Singleton and herself were privyto that I have



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 not been able to review. THE COURT: So essentially you heard from Ms. Farmer that the originallyproposed 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 you had failed to conduct any discovery in a timelymanner that would have resulted in you beingmore prepared, more informed, andmore comfortable inproceeding with the trial. The problem that this court has with a motion to continuemid trial, is that it appears to raise the same argument that you made after your discovery period was completely over. I'mwondering what it is now that distinguishes this motion that you'remaking now from the motion that youmade 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 callingwas 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the Respondent and his interview ofMs. 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, specificallywhat they relied on. I wouldpropose 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, usedby themto 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 wouldbe able to sufficientlyprepare him for the testimony that Ms. Farmer andMr. 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 

### 17 18 19 20 21 22 23 24 25 apart of what either Mr. Singleton orMs. Farmer will rely upon in testimony in describing what they did, how they did it, andwhat 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 reliedupon. 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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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1 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 can go off the record.

(Whereupon, a brief recess was taken.)

THE COURT: We're back on the record in the matter ofWorldwide 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 identifiedhave 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 himto 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 believedthere were several, two in particular, case of statements in that file.'' It was not in the exhibits. Therefore, I askedhim, ''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 saidhe 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 askedhim, "Is there



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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 22 23 24 25 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 shouldbe denied, and the alternative, if, your Honor, feels that the motion shouldbe 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, canmake the ruling as to Mr. Singleton. THE COURT: And what about Ms. Farmer? MR. VINES: Same set of circumstances, Judge. Ms. Farmer

-- I askedMs. Farmer, during this interview that the Respondent conducted of Ms. Farmer, I asked her, ''Have you been in the courtroomtoday'' 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 allowMs. 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the portions of the EIR which you have not disclosed, how much of that would fall under the argument of workproduct 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, tellme 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 workproduct and the deliberative of process. THE COURT: Bywhom? MR. VINES: By employees of the Agency. THE COURT: And when you saywork 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 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 would argue that if that was to be turned over, that would quell the Agency's abilityto engage in conversations with regard to whether violations were committed, Agency's theory of the case at a hearing. Those type of things have longbeen 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 inparts of the EIR, we believe that it is protected and should not be turned over. Moreover, Judge, again I'mrepeating myself, but the Agency's theory of the case has beenpresented, has been disclosed to the



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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 22 23 24 25 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 

### tome, 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 handedme, 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 this file that is before me, essentially all of the material is, as I'mholding 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 justbeen handed to me, is a document that was filed jointlyby the parties in the litigationbeforeme which would not be the EIR, would it? MR. VINES: May I approach, Judge? THE COURT: Sure. I'mreally only interested in the EIR at this point. Thank you. I'll hand that backto you. MR. VINES: Judge, may I approach? THE COURT: You may. MR. VINES: I'll represent what is the EIRwith several documents that are not included in that and those documents that are not included have been removed fromthe file and have been



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 admitted as exhibits in this trial and or they weren't admitted, they have been disclosed as far

as potential exhibits that the Agency wouldmove to admit. THE COURT: Okay. MR. VINES: Moreover, Judge, I did reference deliberativeprocess and opinions formed byAgency 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the matter ofWorldwide Aircraft Services, Inc. This is Docket No. FAA-2013-0045. All parties previously identifiedhave returned to the hearing room after approximately a 17-minute

recess during which time the Court tookthe 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 reviewbased on your motion for a continuance to see if there is anything in the EIR upon court review that couldbe disclosable. This is exactly the same thing that I would do have youmade this motion sixmonths ago. I've reviewed the EIR. There is some disclosable information, not a lot, most of it actually has alreadybeenprovided in this trial, either in exhibits orby 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 wouldbe stricken that indicates a recommendation that wouldbe internal, that would not be disclosable. As Mr. Vines has already



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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 22 23 24 25 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 exactlywhat I'mtalking about so that if you have an objection or further argument you canmake 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 hearme, 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 secondpage, and the thirdpage. What I think needs to be stricken as protectedwork product is this information startingwith I recommend, this material to the verybottomwouldbe stricken because that's an internal recommendation that shouldnot be disclosed in this Court's opinion. Is there anything else in this document that you think would be coveredbyprivilege or work product? MR. VINES: May I just look at the original, Judge?



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### 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 onpage three, Judge, should



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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 22 23 24 25 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'mgoing to do is strike out then, those



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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 22 23 24 25 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 andnot the Respondent. Mr. Honeycutt, I'll then give you a copy that has the strikes that have been copied

so that there is no bleedthrough. What I will do is I will give you folks about another five minutes just to lookthrough thismaterial. 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'reback on the record in



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### 53 

### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 

### 10 11 

### 12 13 

### 14 15 16 17 18 19 

### 20 21 22 23 24 25 the matter ofWorldwide Aircraft Services, Inc. This is Docket No. FAA-2013-0045. We've reconvened after anothermorning

recess. All parties have had a chance to review the two-and-a-halfpage document that was distributed to themduring the recess, which was the document that the Court ruled after an in-chambers reviewwas disclosable to the Respondent. Mr. Honeycutt, do youhave anything else that you would like to add to yourmotion to continue or any othermotion that you would like tomake 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 allowingme to have the right to have the complete file. THE COURT: How is that, in your opinion, becauseboth of these witnesses are FAA employees?MR. HONEYCUTT: And they are called as expert witnesses afterthe fact of discovery and

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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 everything. Neither one of themhad 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 decisionmaking and assistance? MR. HONEYCUTT: Well, an expert witness I believe, your Honor, would come in and formulate his own conclusions justbased off the evidence. These two expert witnesses have seen the opinions of other FAA personnel, therefore I feel if theywant 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 newmotion for exclusion?MR. VINES: As to the motion for continuance, I wouldjust reiteratewhat I stated earlier about the original proposal allowing the

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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 saidbefore, the witnesses are expected to testify to the conclusion they have drawn based

on evidence they have heard today. IfMr. 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 shouldmake 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 1s 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 a response to Mr. Vines' arguments objecting to your motions to continue and to exclude. MR. HONEYCUTT: The objection to continue on withmy motion, your Honor, is again, if I would have had this informationprior 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 verymuch.



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 In terms of your renewedmotion 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 discoveryprocess 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 listedmost recently by the FAA. And the Court has also tried to cure your interest in the undisclosedportions 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 identifiedprior to their hearing. You have had a chance to discuss briefly with themthe 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



### For

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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 maybe 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 

### 19 20 21 22 23 24 25 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 askedbefore the last recess if the Court wouldmake 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 andmy 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 nothingbut 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, youmay inquire.

DIRECT EXAMINATION



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 BY MR. VINES: 3 Q. Mr. Singleton, goodmorning. Where do you 4 currentlywork? 5 A. FederalAviationAdministration 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? A. I'm a Maintenance Inspector. 14 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 Q. 

### I don't know if youmentioned, but are you 2 familiar with Part 137? 3 4 5 6 A. Q. A. Q. 

### Yes. What ispart 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 exactlythat is 14 or those are? 15 A. 

### Yes, a Part 145 Repair Station is either where an 16 air carrier or general aviation, inbasic terms, 17 brings their aircraft for repair and or overhaul. A 18 Part 145 Repair Station can also be more essentialized 19 where theyjust 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 howmany repair stations you are in charge of 23 overseeing on a yearlybasis? 24 A. I 

### currentlyhave oversight on I 

### believe seven 25 repair stations.



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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 performconformity 9 inspection to ensure the aircraft meets its type 10 certificate, which is the instructions bywhich 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 requiredmaintenance has been compliedwith 15 in accordance with theAir Operator'sManuals 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 thatmean? It is when a Part 135 Operator requires an 20 additional aircraftbefore or prior flying for 21 compensation orhigher, it has to be inspectedby 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 A. Q. A. Yes. What are Operation Specifications? They are additional limitations placedon 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 inbulk 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 Carriermay 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 currentlyoperates or is 22 authorizedto 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 classroomtraining 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 couldbore 9 you with acronyms, but numerous tools or training that 10 the government uses, that the FAA uses. 11 Q. And you receivedthat trainingwhen 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 programthat is 19 mandatedby 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-worldtraining to backup the 24 formal classroomin training in Certification ofAir 25 Agencies, Certification of Operators, inspection of



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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 receivedthat formal OJT, on-the-job 6 training? 7 8 9 10 11 A. Q. A. Q. A. Yes, sir. And have you been trainedby 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 trainingprovider to the 14 FAA to broaden our knowledge base on more unique 15 items. 16 Some of the repetitive training is required 17 trainingbythe 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 onmaintenance 21 issues or is itmore 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-trainingprovider is



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### 3/6/2014

1 maintenance, it is more maintenance related. 2 Q. And when you saymaintenance, 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 onmaintaining 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 ofMaintenance 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 themanager 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 youngwhen 9 I joinedthem and growing rapidly. 10 Q. So you were hiredto

-- okay. Youmentioned 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, authorizedby the FAA to trainmechanics for 17 theirAirframe-and-Power-Plant Certificate. 18 Q. Did you do anything similar while you were at 19 JetBlue? 20 A. 

### Yes, we worked in cooperationwith the Aviation 21 High School in Queens, New York, whichwas the local 22 A-and-P School to us to develop an internprogram for 23 mechanics sowe could growmechanics theway we wanted 24 them. 25 Q. 

### Andprior to that, where were you employed?



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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 121Aircraft 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 heavymaintenance 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 hangermanager 25 THE COURT: I'm sorry, the court



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 reporter would like you to repeat that last part. THE WITNESS: Yes, ma'am. I would fill in for the hangarmanager 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 Stationto become 12 familiar with theirmanual process, a Repair Station 13 Manual and QualityManuals. 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 themanager of training, did you receive 20 any training as themanager of training? 21 22 23 A. Q. A. I did. What type of training didyou receive at JetBlue? I went through A-320, which is a month-long 24 school inMiami. I went through an E-190 School, a 25 Maintenance School, which was providedby Swiss



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 Aviation Training. 2 As a maintenance-trainingmanager, the training 3 department at JetBlue believed in leadership training 4 andbettering us as instructors andmanagers, so he 5 sent us to NYU to attend several, I guess training 6 courses, psychology courses, education courses. 7 Q. And youmentioned training on the A-320, what's 8 anA-320? 9 A. It's anAirbus Aircraft that holds approximately 10 320 people. 11 Q. And you saidthat 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 betterprepare a 17 mechanic to work on that aircraft. It is quite an 18 in-depth course. 19 20 21 Q. Youmentionedthe E-190, what is an E-190? 

### A. E-190 is the model of the aircraft. It is a 100-person aircraftmanufactured in Brazil. JetBlue, 22 at the time, was the launch customer inthe 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 whichmeans that we have provided all the training for

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1 maintenance, for flight, for anything outside 2 obviouslythe Typed Certificate. We really hadn't to 3 come up withhow to maintain the aircraft though. 4 Q. Was that similar in what you received with the 5 indoctrination class with anA-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 UnitedAirlines. How long were you at United? I believe for five years. Andwhat were your duties at UnitedAirlines? 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 specialtywas 757 21 and 767. 22 Q. Did you receive any training while working at 23 UnitedAirlines? 24 A. Yes, numerous classes on the 757, 767 Aircraft 25 systems, including auto-pilot engines, avionics and



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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 termGPU? 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 categorywould 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. Youmay 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 anA-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. N90LJwhich you confirmed 21 earlier in your testimony. Have you also heard 22 testimony about the ground-power unit receptacle 23 associatedwith this aircraft? 24 25 

### A. Q. Yes, sir. There's also been testimony that this aircraft



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 operated and has been admitted to by the Respondent 2 that N90LJwas operating on the flight fromAirport 3 Code TDPD toMYAM onMay 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 inboy. 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 testimonybased on this exhibit that 13 upon arriving at the Bahamas, Airport CodeMYAM, 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 electricalpower is providedby 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 itused? 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 manymakes andmodels provides electricalpower to an 12 aircraft. 13 Q. Specificallywhat 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 wouldbe 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 generallymade of a veryheavy 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 essentiallytaking 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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 inMike. 12 Take a moment to readparagraph 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 recordmaintenance 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 longermeets its typed 2 3 4 5 6 

### design. The pins are designed tobe straight. Q. 

### When you say type design, what you are referring 7 to? 8 A. 

### I'mreferring to the Type Certificate of the 9 aircraft. Again, it's an instruction fromthe 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 basicallythe manufacturer's conformityof the 18 aircraft or as the aircraft was released from the 19 manufacturer, it lists allowable enginemodels to be 20 installed, allowable tolerances of flight controls, 21 fuel capacities, oil capacities, flight-maneuver 22 ability, ormaneuvering speeds and limitations, weight 23 of the aircraft, weight limitations, including 24 over-weight limitations. Generally, it has a few 25 pages ofmanufacturer's notes that go beyondthe



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 normal type design to cover anyunusual use of the 2 aircraft. 3 

### Q. Andwhat specifically

-- why are you able to form 4 the conclusion that the bent prongs don't conformto 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 curvedpin, 8 it is not going fit into a straight receptacle. The 9 limitations of a bendwouldn't be in the typed data 10 sheet, theywouldbe in an Aircraft Maintenance Manual 11 providedby themanufacturer. 12 Q. Do you agree or disagree that these prongs are 13 part of the electrical systemwithin 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 BY MR. VINES: 2 3 Q. A. And why is that? Without the pins, there wouldbe 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 ofbent 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 insulatorblock or an insulation block. I would 15 personallybe concerned if you bent the pin in the 16 insulationblock, 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 Q. A. And is that significant? It couldbe. It couldbe 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 yourunderstanding 13 according to his statement? 14 15 A. Q. Yes. Would you expect the pilot to havemade 16 documentation of damage to those prongs? 17 18 19 20 21 22 23 24 25 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 Aand P. So we askthat Brandon P1as' statement stays



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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 22 23 24 25 as what it is and THE COURT: There's been an objection. MR. HONEYCUTT:

-- the witness to testifywhat Brandon should have orwhat 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 thinkhe can ask the question in a different manner than what the pilot would have done or shouldhave done. He

can speakto his expertise on the maintenance side not necessarilybringing in to what a pilot shouldbe doing. So I object to that question. THE COURT: Thank you. I'mjust going to take a look atmy notes for a moment. I'm going to sustain the objection at this point.



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

I'm going to ask you, Mr. Vines, you 1 2 3 4 5 6 7 8 9 can either ask the question in a different way or you can expand on this witness' testimony about the workhe 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 11 12 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 reviewmanuals 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 makemaintenance entries or discrepancies 25 irregularities into maintenance logs?



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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 requiredby the 6 Certificate Holder's Manual to document maintenance 7 irregularities or maintenance discrepancies 8 (inaudible) for pilots to make those entries? 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. MR. VINES: Based on that, Judge, I would ask to have the witness answermy original question. I'dbe 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



### For

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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 

### 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 

### 18 19 20 21 

### 22 23 

### 24 25 food. Mr. Singleton, I'm going to thank you verymuch 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 difficultywith 30 minutes. Mr. Honeycutt, what is your preference? MR. HONEYCUTT: An hour wouldbe okay. THE COURT: Okay. Thank you,



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 lunchbreak. THE COURT: You are okay? MR. VINES: Yes.



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 preliminarymatters? 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 ultimatelybe answered by the witness, so I will rephrase that question.



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 BY MR. VINES: 2 Q. Inspector Singleton, would you expect Brandon 3 Plas, who is an employee ofWorldwide 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 inparagraph 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.



### For

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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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, whichparagraph

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 anymechanical irregularities. 13 Q. I believe you testifiedearlier that you believed 14 that the bent prongs constituted a mechanical 15 discrepancy. There is obviously a termthat is also 16 included in the General Operations Manual by the term 17 ofMechanical Irregularity, do you differentiate 18 between those two terms? 19 A. I don't have a textbook definition. I couldmake 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 ofwhat irregularity



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 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 specificallythat termmeans 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 currentlybeen 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'mhappily rephrase, your 23 Honor. 24 BY MR. VINES: 25 Q. Have you, in your experience as a Maintenance



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 Inspector, come across the termmechanical discrepancy 2 ormechanical irregularity? 3 4 A. Q. Yes. Based on those terms, are you able to abide a 5 definition as they are used in theMaintenance 6 Industry? 7 8 9 A. Q. A. Yes. What would those be? An irregularity, inmy 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, inmy experience, is a harden 17 fault, something you canpoint 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, orboth? 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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 particularportion 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 testimonytoday? 15 16 A. Q. Yes, I did. Andwhat 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 sectionversus a 20 structural section of the aircraft? 21 A. A structural section or what is referredto 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 youprovide 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 wouldhold a component on such as a 8 hydraulic (inaudible) or, in this case, perhaps the 9 

### GPO plug assembly is what's heldto the aircraft as 10 nonstructural. 11 Q. 

### And I believe you testified earlierwhat 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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### Hearing WorldwideAircraftServices,Inc. 

### 3/6/2014

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 reviewmaintenance 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 statedbefore, 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 descriptionwhere it reads P4/N, can you 20 describe what thatmeans inparagraph one? 21 A. Yes, that indicates a part number of this 22 component. Manufacturers provide what's called 23 illustratedparts list or illustratedparts ofbreak 24 down, which identifies each and everypiece of the 25 aircraft bypart number.

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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 When something has to be replaced, this manual is 2 referredto so the appropriate or correct part canbe 3 ordered for that aircraft. This indicates tome that 4 partNo. 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 industrydefinition 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. Wouldyoupleaseprovide your 14 interpretation as to what occurredinparagraph two? 15 A. 

### It appears that they replacedthe GPU mounting 16 brackets also showingpart numbers, a replacing of a 17 

### receptacle is inparagraph one. In some cases when 18 you replace a component, you have to replace 19 surroundingbrackets with it. This mayhave been the 20 case on this one. 21 

### 22 Q. 

### A. 

### Andwhat purpose do the brackets serve? The brackets support the GPU receptacle in its 23 mountedposition. 24 25 Q. A. 

### As to paragraph three, same question. Paragraph three indicates tome that there was



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 skin damage to the aircraft, and it was reworked or 2 repaired, which really are interchangeable terms, an 3 area aft andbelow 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 usuallyperformedpursuant to 13 some type ofmanufacturer'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 ofMaintenance, Brian Fanning, 17 in concert with Exhibit C-11, which is the 18 maintenance-record entry-- actually I'llwithdraw 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 It is sustained. 2 BY MR. VINES: 3 

### Q. What, if any, conclusionhave you drawn regarding 4 whether a small amount of damage to the non-structural 5 section of the fuselage skinjust 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

-- 14 15 16 17 18 19 20 21 22 23 24 25 MR. HONEYCUTT: Again, your Honor, I thinkhe is leadingwith 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 maybe an objection at the end of this question, so if you couldwait. Mr. Vines. MR. VINES: Sure.

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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 BY MR. VINES: 2 Q. What, if any, conclusionhave you drawn regarding 3 whether a small amount of damage to the non-structural 

### 4 skin of the fuselage on N90LJ that is reportedby 5 Brian Fanning on C-10, would constitute a failure on 6 the function of the airframe? 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE WITNESS: Can I answer? THE COURT: Youmay 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 saidyour objection was premature MR. HONEYCUTT: Oh, okay. THE COURT: because there hadn't been a complete answer or questionprovided, 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 ifMr. Honeycutt objects. THE COURT: And what lS thebasis 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: Youmay 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 skinwas, in fact, repaired and 21 appears tobe 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 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 inthe 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. Amalfunction 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 tomove on now to a matter that's been 25 discussed in prior testimony. Again, you sat through



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 the proceedings in this case, and there was testimony 2 that theAircraft N90LJhad departed fromBrooksville 3 Airport onMay 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 andhow it relates 10 to the damage, and I'llbe more specific, the bent 11 prongs and a tear in the aircraft skin, do youhave 12 any opinion ofhow those two couldbe related? 13 14 

### 15 A. Q. A. 

### Yes. And what would that be? I believe the two are directlyrelated. Damage 16 is generally causedby an external source, notmeaning 17 GPU, but an external force on the airplane. 18 Ifyouhave 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, wouldbe consistent 21 with a GPU being left attached to the aircraft. 22 Q. 

### You've also heard testimony, as you'vebeen in 23 court, fromtestimony fromBrian Fanning, Chief of 24 Maintenance for the Respondent, he testified that

-- 25 I'llwithdraw that.



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1 

### Let me take your attentionback 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 -- letme 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 generallynot just part of a repair. 17 Q. So if I understand you correctly, your testimony 18 was that themaintenance reference in paragraphthree 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. Specificallyinmaintenance? Yes. What, if any, opinion do you have of the need or 6 the requirement that damage ormechanical 7 irregularities ormechanical 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'mokay. THE COURT: Mr. Honeycutt, are you ready for your cross-examination? MR. HONEYCUTT: May I have five minutes, your Honor? THE COURT: Youmay. Maybe we can take a quick recess for



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 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 identifiedhave 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 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 andmost of your experience in 8 maintenance looks to be as a 121 Air Carrier type of 9 mechanic which is accordant with mostlyAirlines? 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 ofmid size, small jet? 15 16 A. Q. No, sir, I've never been employedby 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 withMr. Vines. Damage 24 is not a discrepancy

-- a discrepancy is a hard fault 25 or a failure, for example, discrepancybeing 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 discrepancymaintains itself as not working 5 properly? 6 7 A. Q. Yes, sir, I agree with that. And a malfunction, as you said, is somethingmore 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 couldbe 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 andmalfunction 20 constitute it is not working properly? 21 22 23 24 A. Q. A. Q. Correct. Okay. And an irregularitymay come and go? Yes. All right. In your 121 background, have you 25 served as a linemechanic 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 inspectionprogram at that point, but there is a 25 tolerance level that the manufacturer



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 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 inmy 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 your investigation and reviewing of the EIR in 2 speaking with Inspector Schaefer, do you know ifhe 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 certifiedwith a typed-data sheet 10 and all that is listedon 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, youmean supplemental 15 types, anything other than what was originally 16 designed on the typed-data sheet, anything added to 17 the data sheet wouldbe 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 canmove into the components is 24 where I was going, because certain components of the 25 aircraft are not manufacturedby themanufacturer of



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1 the airframe, for example, an engine is usually 2 manufacturedby 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, ifthere is a 7 company thatmakes the GPU receptacle, would it set 8 

### its on tolerances orwould 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) wouldbe able to be tolerant to? 13 14 

### A. Q. 

### Yes, sir. Okay. Does Learjet set a tolerance on the 15 General Electric CJ610 engine fanblaze? 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

manufacturedby 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 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'mtrying to prove is that certainpoints and components of the airplane have its own tolerances by its ownmanufacturer, therefore not listed on the typed-data sheet. You would have to go to that specificmanufacturer 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 goingthrough a varietyof 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 wouldbe so kind. 23 BY MR. HONEYCUTT: 24 Q. Mr. Singleton, would you be able to tellme, 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 LearjetMaintenance 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 wouldbe 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 youback to

-- you statedthat 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 renderedmoved. 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 we've discussed, can you determine from number one, 2 replace GPU receptacle PNMS3506-l, ifthat 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 wouldhave to lookthat up? Yes, sir. All right. Number three, if I readthis 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 hadmade that, as you 14 said a repair, would you be able to see that ifyou 15 were to inspect the aircraft? 16 17 18 19 A. Q. A. Q. Yes, sir. 

### It wouldbe 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, andMr. Vines

can chime in, I believe there was an assertion that it was an improvement.



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1 2 3 4 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 MaintenanceManual 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 tome what that Chapter 51-40-02 and 51-70-02, 17 what wouldbe classified in thatmanual? 18 A. I'mnot familiar with the chapters in themanual. 19 Themanual however is industry standard for 20 manufacturers as a structural-repairmanual. 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 onExhibit C-11, which was datedMay 20th. 5 This is a statement from, allegedly fromMr. Handing 6 

### to Mr. Schaefer, dated June 17th. It talks about 7 removing a bent GPU plug andbox assembly. 8 It says removed approximatelya half-inch damaged 9 skin from lower aft corner. Then it says fabricated 10 installeddoubler T3-2040 with an approximate size of 11 

### 12 four-and-a-half inchesby six-and-a-half. It was slid through the skin and riveted to the SR109784SF. Is it 13 your testimonythat that was what's inthe 51-40-02? 14 15 16 17 A. Q. A. Q. Yes, sir. 

### That procedure wouldbe there? Yes, sir. 

### All right. Mr. Schaefer's testimony, which I 18 believe you saidyou spoke with Mr. Schaefer during 19 our earlier discussions, C-6A andC-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 secondparagraph, the hot-line 25 complaint statedthe aircraft was taken to Brandis



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 Aircraft, located in Taylorville, IL. The aircraft 2 has extensive damage and the skin peeledback 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 fromMr. 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 surroundingpanels were original as 10 was the paint. 11 THE COURT: Is there a question? 12 BY MR. HONEYCUTT: 13 Q. The question wouldbe, we said earlier that Mr. 14 Singletonwouldbe able to spot the damaged-repaired 15 area, and I'mcurious, 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 ofMr. Schaefer's statement. His statement says ''the aircraft has extensive damage and the skin peeledback 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 pulledback 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'mgoing 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 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 couldbe noticed after it was done. Itmight 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 wouldbe visible to 12 you; is that correct? 13 14 A. Q. I believe itwould, yes, sir. And it is your testimony that Mr. Schaefer, in 15 his written statement, that you concur that Mr. 16 Schaefer makes inhis statement that he inspected the 17 aircraft and it appeared a new GPU doubler was 18 installed and the surroundingpanels 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 respectfullyoverruled. I'mlooking at Exhibit C-68, and it appears the question reflects what the statement says. It speaks for itself.



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 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 specificallynotes a tear. 20 BY MR. HONEYCUTT: 21 Q. Thank you. Again, back to the Learmodel 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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 atMYAM? 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-crewmember noting damage 

### 12 on the GPU receptacle. 13 Q. So the pilot's statement, but nowhere else in the 14 investigative file is there anymention 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

For

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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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 verymuch. 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 thepilot 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 necessarilymaintenance required inspected items? 23 A. The pilot has the diligence to verifymaintenance 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 andwalk around the aircraft. 3 Q. 

### So in your testimony, a pilot has

-- letme 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'mgolng 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 themechanic 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 clarifythat a little bit, what I'm 25 testifying to as a discrepancy?



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 Q. A. Yeah. Adiscrepancy is anything that canbe 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 confusedbecause 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 canbe defined 16 an irregularity at your request. There was another 17 word you were using also, discrepancy or mechanical 18 irregularity. Adiscrepancy 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 BY MR. HONEYCUTT: 2 Q. 

### So basicallyMr. 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, andthe 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 hookup 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 againwas normal anduneventful. 20 Thenwe get into the paragraph where it says 21 after landing inMarsh Harbour again requested to 22 connect the GPU and fuel. This point he goes into 23 that he was approachedbythe lineman and saidhe 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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 andmoves on. 4 InMarsh 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 ifthe 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 wouldyou test a GPU receptacle to determine if itwas 13 functioning properly and I believe 14 15 

### A. Q. Yes, sir.



### -- you saidplug in the GPU and see if the 16 aircraft would receive power? 17 

### 18 A. Q. Yes. Andby 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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 inMYAM onMay 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'mreferencing Government Exhibit e-BB, it would 15 be the third paragraph, which begins after landing in 16 MYAM. 17 A. Inparagraph 

### Bthe lineman-- I'm sorry, the PIC 18 triedto 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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 cordbeing 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 solelythe 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 theymake a determination 20 if the aircraft is safe for flight. 21 Airworthy is a generalized term that couldbe 22 made about maintenance. It couldbe 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 verifyingthat the airplane has been signed off from 2 maintenance as airworthy. 3 Q. 

### And in this particular case, if a discrepancywas 4 found that you testifiedto 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 earlierthat youwere trying 11 to explain the differences between an irregularity and 12 discrepancy, and it ismy understanding your testimony 13 also involvedto what constituteda malfunction. You 14 were trying to clarifythat. Could youplease 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 discrepancyversus an irregularity, if there is a 20 distinctionbetween the three? 21 A. Yes, I believe there is a distinctionbetween the 22 three. Adiscrepancy, as I statedbefore, to the best 23 ofmy knowledge, is any anomalywith the aircraft, 24 anything that isbroken or not working properly, not 25 working, something of an electricpump of some sort is



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1 

### an example. It canbe 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. Aburnt out light 5 bulb inthe cockpit canbe a discrepancy, a worn tire 6 canbe a discrepancy. 7 An irregularity, to the best ofmy 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 termyou were asked to discuss was 12 malfunction. 13 A. 

### Amalfunction, again the way I understanda 14 malfunction, a malfunction is a more generalizedterm 15 toward a systemon the aircraft. Again, goingback to 16 let's say the electricalpower, 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 systemis malfunctioning. We don't 21 know why. It wouldbe written as a discrepancy in the 22 aircraft-maintenance logs. 23 Q. 

### So would itbe fair to saythat discrepancy, 24 irregularity, andmalfunction are varying degrees of 25 concern, is there a sliding scale for these three



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 terms? 2 A. I think they carry equal weight. They all have 3 to be inspected. The determination is made onwhether 4 or not the system or item, whatever was written up, is 5 valid or not. 6 Q. By inspected, who wouldbe 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: Youmay continue.

RECROSS-EXAMINATION



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 BY MR. HONEYCUTT: 2 Q. Amechanic, we talked about earlier at a line 3 station, as an airline, is he not

-- do those 4 mechanics not walk around theme 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 coulddetermine 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 airworthybut 20 on the go, I'm asking could a mechanic determine if a 21 whole, a tear, or a dent, couldhe 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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 inMaintenance Manual for it. 8 Q. Again, backto thepilot issue of determiningthe 9 airworthiness of the airplane, we statedthat 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 thepilot 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 thephysical 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 thepilot'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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

A. Yes, sir. 

### Q. And talking about a discrepancy, a worn tire 1 2 3 couldbe 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? MR. VINES: I would object to that. I 8 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 A. Yes, I believe that there couldbe two different 2 opinions, which is whyMaintenance 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 youmade 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 A. I don't know your companyprocess, 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 wouldprobably use the Tire 10 Manufacturer's Maintenance Manual to determine the 11 thread requirement and the thickness of that, correct? 12 A. Generally theywould use an AircraftMaintenance 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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 clearermanner. 13 BY MR. HONEYCUTT: 14 Q. In your past experience, have you seen a 15 discrepancywritten 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 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. Farmermay be your next witness, but I also have Ms. Aleski whose presence is neededbefore 5. Would yoube willingto entertain in takingher out of order at thispoint? MR. VINES: Yes, Judge, that's fine. THE COURT: Mr. Honeycutt, would you be willingto put Ms. Aleski on the standnow? We'll take her out of order since she can't come back tomorrow. MR. HONEYCUTT: Yes, ma'am. THE COURT: Okay. Do youwant 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'llhustle. THE COURT: We'll reconvene backhere in 10minutes.



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 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 ofWorldwide 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.

LISAALESKI, after having been duly sworn, was examined and testified as follows:

THE COURT: Thank you. Please take a



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 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: LisaAleski, A-L-E-S-K-I. THE COURT: Mr. Honeycutt, youmay inquire. MR. HONEYCUTT: Thank you, your Honor. I'mnot 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 tellme 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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### Hearing WorldwideAircraftServices,Inc.

1 are what? 2 3 A. Q. 

### Office duties. And you assist more -- do you not assist me 4 prettymuch in and out on a dailybasis? 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 allowthe question and answer to stand. Youmay continue. MR. HONEYCUTT: Thank you. I'rn sorry, 

### 13 yourHonor. 14 BY MR. HONEYCUTT: 15 Q. 

### Lisa, I'dlike to show you Exhibit C-10, is it on 16 that desk? If you look on the bottomright-hand 17 corner there, is it labeledGovernment Exhibit C-10? 18 We're looking for C-10. 19 20 21 22 A. 

### Q. A. Q. 

### It seems tobe jumping. Do you recognize that document? I 

### do. Couldyou 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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 typedby 6 you and signedby 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 youjust 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 needyou 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 backtoMr. Fanning. 20 Q. Okay. So Brian gave you a legal pad, like a 21 legal pad, itwas 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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 askedme. 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 knowwhat 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 himbeing 18 there on a dailybasis? 19 A. Was he at the office on a dailybasis? 20 Q. Didyou 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 onmultiple occasions, maybe? 25 

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



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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 verymuch 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 AviationAdministration. What do you do for the FAA? I'm a Regional Specialist in the Southern Region.



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 Q. A. What is the Southern Region? It is the Regional Office located inAtlanta, 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. Andwhat 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. Andwhat 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 

### A. Yes, it stands for Flight Standard District 2 Office. 3 Q. 

### Tellme a littlemore 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'mjust 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 youmentioned EASA? A. Yeah, it stands for EuropeanAviation Safety 14 Authority, I think it stands for. 15 Q. 

### And you also statedthat 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

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 itbe a civilpenalty, revocation, that 7 type. 8 Q. And civilpenalty, that wouldbe against an 9 airman, air carrier, or air agency? 10 11 A. Q. Correct. And revocation wouldbe revocation of an airline 12 certificate? 13 14 A. Q. Or an Air Carrier Certificate or repair station. Sobasically 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. Andhow 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 InspectionAuthorize Mechanics, IAs, 147 Schools, 10 Designees OARs, designees justmeans 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'mhaving 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 withthem, helping them with any questions 20 that theyhave. 21 22 Q. A. Do you hold any FAA Certificates? I do. I hold anAirframe-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 couldbe 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 explainto the Court support for the 23 proposed CP that the Administratorhas 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 characterizedin. What group it 7 is characterized in. This first page onC-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 onpage 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 saidin 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 ormore. Operating revenue is determinedby reference 2 to DOT's Air Carrier Industry. So theymay 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 wouldbe



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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'mnow 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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1 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 thenmoves 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 andbecause 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 youmentioned earlier that 25 itprovides a minimum range, moderate range, and



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1 maximumrange? 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 onpage 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 minimumto 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 notmake 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 themid range of a civilpenalty. So we start in 20 the middle and we aggravate up andwe 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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1 2 3 4 5 6 7 8 9 

### 10 11 12 13 14 15 16 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 themax range along with the minimumrange 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 andwhich 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 tomake 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? Looknext to my bottle of water.



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1 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 confirmwith the witness that this is the correct document. THE WITNESS: Yes, this is it. MR. HONEYCUTT: Thank you somuch. 10 BY MR. VINES: 11 Q. I'mgoing to show you the notes that you had 12 made. My question earlier was, what was the 13 calculationafter 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'mlooking 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. Aftermaking 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 wouldmultiply 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 thenmitigate 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 theAdministrator 3 considers aggravating ormitigating 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. 12 13 14 15 16 17 18 19 20 

### 21 22 

### 23 24 25 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 ifwe're looking at C-18? MR. HONEYCUTT: It was brought up earlier todaythat the notes that she is reading off of, she had come to the conclusion last night. Again, we didn't have the abilityto see themjustrecently. MR. VINES: I don't know anything about



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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 22 23 24 25 what your informal discussion resulted ln. That

was not put before the Court. I'mnot 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 explainmitigating 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 interviewwith Ms. Farmer yesterday, you wanted the notes, you asked for them, and they didn't give them to you? MR. HONEYCUTT: Todaywe didn't know about the notes because she made them last night. THE COURT: Okay. And the first time



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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 22 23 24 25 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 themjust now becauseMs. Farmer just looked at themto 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 tojust a few moments ago as part of her testimony?MR. VINES: Again, Judge, if the using



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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 22 23 24 25 of the notes on the witness stand through the

course or using themto 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 ofputting 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, andMs. Farmer can testify from her memory, and if she needs to reference her notes to refresh her recollection, I'llbe okaywith that, Judge. THE COURT: Okay. MR. HONEYCUTT: Your Honor, may I? THE COURT: Yes. MR. HONEYCUTT: To clarify, you know, I felt thatMs. Farmer relied on someone else's decision. The case she just got February lOth

was brought to her, I believe. So the civil penaltyhas been out there since the original complaint and the proposed civil penaltyback two



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 years ago.So I'mtrying 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 andthen we'll address this

as needbe 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 Mr. Vines. 2 BY MR. VINES: 3 Q. So as I was asking you, Inspector Farmer, did 4 you, inpreparation for your testimonytoday, 5 reference the first mitigating factor found on 6 paragraph 4A onpage 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 particularmitigating or 13 aggravating factor in the context information that is 14 not included inthe 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 answerbe? 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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1 2 3 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 consultingmitigating 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? 21 22 

### A. Q. No. Same question for paragraph 4F, did you review 23 paragraph 4F? 24 25 

### A. Q. Yes, I read it. For your testimony today?



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 A. Q. Yes. Did you consider any other information extraneous 3 to the information presentedhere at the hearing 

### 4 including testimony and exhibits presented for 5 purposed of reviewing paragraph 4F? 6 7 8 9 10 11 12 13 14 15 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, inpreparation for 19 your testimony today, did you review those paragraphs? 20 21 A. Q. Say that one more time. In preparation for your testimony today, did you 22 review paragraphs 4A through 4L? 23 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 A. Q. No. Of this hearing, I mean the testimony that has 3 beenpresented, as well as the exhibits that have been 4 admitted into evidence? 5 6 A. Q. No. It is my understanding that you havebeenpresent 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 ofparagraph 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 andmakes the 23 violation is they are a 135 On-Demand Operator. They 24 are heldto a higher degree, so there is an 25 operational factor when it comes to the nature of the

For

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1 violation. 2 Q. When you sayheld to a higher degree, what do you 3 mean by that? 4 A. For our safetybecause they carrypersonnel. 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'mnot 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? 12 13 14 15 16 17 18 19 20 21 22 23 24 25 

### A. Yes, it would. 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 copymachine that is close by? I see that there is a hand raised, two hands raised.



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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 22 23 24 25 What I'm going to do is this, it seems to me that we can eliminate some of these problems byjust 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 wouldbe 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 tomorrowmorning? Mr. Vines, I'll turn to you first. MR. VINES: No objection. THE COURT: Mr. Honeycutt. MR. HONEYCUTT: 9 a.m. I thinkwould be sufficient for me, your Honor. I don't have, as



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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 22 23 24 25 you saw with the last witness, in-depth testimony, and we live far away. THE COURT: Okay. You understand that ifwe 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'mhappy 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 ifwe 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 post-hearingbrief, 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 hadMr. 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: So noted and your motion for continuedpresence 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'mnot sure how to askmyself questions

or do I just make my statement as like a closing statement?THE COURT: Typicallywhat I do with people who are representing themselves is I give you a couple different options on how to do that. You canmake a narrative statement and then be subjected to cross-examination. You can askme 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 

### 24 25 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, couldMr. Bowen askme questions? THE COURT: Well, I certainly would entertain that motion. I'll turn to Mr. Vines to

see if he has any objection. The onlyproblemwith 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 listedhimself as the representative andbecause of that, I would ask that he be limited to the options that you just discuss with him.



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 wouldbe strategy, andMr. 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 andMr. Honeycutt to come up and get your copy. I'mhanding 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 andproceed 3 please. 4 BY MR. VINES: 5 Q. My question to you is, as to this particular 6 aggravating ormitigating factor which is referredto 7 inparagraph 4A of chapter seven, 21538, which is 8 found inExhibit 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 couldbe 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 heldby 14 standards. 15 Q. And youmentioned about not being a 91, what is a 16 91? A. It is just your basic pilot with one pilot, one 17 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 inboy, 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 heldto a higher standard. They carrypersonnel. 18 Theywere inbusiness 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 throughyour 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 compliedwith a request by 6 the FAA in gathering documents and records. I didn't 7 consider it. 8 Q. Okay. Didyou 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 thatparticular 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 toMay 9th, for maintenance 24 to review, to look at the aircraft andmake some sort 25 of an inspection. I felt that that was a hazard.



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1 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 andwas 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 Q. Would you go intomore 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'tmake the 13 decisions on that. 14 15 Q. 

### A. Paragraph 4K. Kwas not considered. It says right in here, in 16 the order, the goal may not be achievedhowever 17 because in here itmade 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 voluntarymanner 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 timelymanner. 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 youwere 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, onMay 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. Letme take your attention to Exhibit C-10. Okay. I got it, C-10.



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 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 inMike? 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 onMay 7th 12 the aircraft returned and was looked at, but there was 13 no log entrymade at that time either. So I'mnot 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-- Letme direct your is there a document where 24 that is referenced? 25 A. Yes, there is

-- C-11.

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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 Q. Okay. A. This is where they completed the following items and replaced the GPU receptacle. It is datedMay 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, andMay 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 continuedto 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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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 

### A. Because the corrective action wasn't done in a 2 timelymanner. 3 Q. Okay. Any additional concerns that you feel were 4 aggravating ormitigating testimony that you heard 5 over the course of this hearing? 6 A. Fromthe 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 tome 9 is that personnel ofWorldwide 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 ofMaintenance, 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 letme go back. I'll rephrase. Earlier you testified 21 that the starting or the middle range of the CP was 22 $11,825? 23 24 25 

### A. 

### Q. A. Yes. However the proposed sanction is $12,375. Yes.



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 Q. A. 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? 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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'tmean to cut it short, but I feel like I haven't got the notes down, that I couldnot preparemyself 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 onlyto the evidence that we've heard in this case,



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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 nothing extraneous. Again, no surprise shouldbe to the Respondent, and therefore, I would object to continuing this case, in addition to the time that we have left inthis hearingto 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 wouldbe 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 fromMr. 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 tomorrowmorning, 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 withme? I thought I heard something.

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### Hearing WorldwideAircraftServices,Inc. 3/6/2014

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 fromMr. Bowen, I'm going to deny that particularmotion, 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 thatMr. 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-examinationbegins, I'll give you a recess to consult withMr. Bowen to

see if there is anything that youmissed, 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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'mnot quite sure how do I want to say this

-- absent Mr. Bowen who has previously identifiedhimself as counsel, an attorney, absent Mr. Bowen actuallyputting 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 certainlywelcome 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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 simplyhas 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-sayRespondent. So he can get up on the stand, he can make his narrative, but before I allow cross, he

can meet and discuss verybrieflywith Mr. Bowen if there is something that the two of them gathered think theymight have missed, he can add to his narrative before your cross-examination begins. Once you have crossedMr. Honeycutt, he

can thenmeet withMr. 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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1 2 3 4 5 6 7 cross-examination issues that came up for him. So I want tomake 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'mnot 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 thinkMr. 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. 15

- - - - - 16 (Whereupon, the hearing concluded at 4:35p.m.) 

### 17

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### 19 20 21 22 23 24 25



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# I Untitled 1 CERTlFICATE OFREPORTER 2 STATEOF FLORIDA 3 COUNIYOFHILLSBOROUGH: 4 5 I, LAURAMORALES, CourtReporter, 6 Nol:aryPublic, certifythatI was authorized 7 1:0anddidstenographicallyreporttheforegoing 8 prot:ee:dirtg andthat·thetranscriptisa t·rue 9 and completerecordof11JYstenographicnotes. 10 I furthercertifythatI amnota 11 relat:iv·e, employee, attorney, orcouns·el of 12- ariyoftheparties,nor-arrfI a relativeor 13 emp:loyeeofany-oftheparties7 attorneyo.r 14 c:ounse·l connectedwiththeaCtion,noram_I 15 financially interestedintheaction. 16 17 18 19 20 21 22 23 24 25 DatedthisJO+hofmarch, 2014

# La~AYJwt·**~** courtReporter, Notary;·P:ublic StateofFlori.daatLarge MyCommission.No.: FF029798 Expires: JUne 10, 2017