# Exhibit 28

### TO: Angiej@santarosa.fl.gov FROM: MiltonAviation Partners LLC

Ref: Thependinglease agreementbetween SRBOCC and MiltonAviation Partners concerning the establishment ofa second Fixed-Base Operator (FBO) at PeterPrince Airport. The proposed lease terms currentlybeing consideredhave been agreedto withthe exception ofthe disposition ofthe "Fuel Farm" thatis ownedby SantaRosa County. Background: The current "FuelFarm" located onPeterPrince Airport was constructed withfunds provided on a 50%-50% share basis between SantaRosa county and the state ofFloridaDOT. A lease between SantaRosa county and AviationManagement Services (AMS), the current FBO, does not include the SRC "Fuel Farm" as partofthe current lease. Since SRC has allowed AMS the use ofthe county owned "FuelFarm" on afree gratis basis ( other than flowage fees) the county mustprovidefor the same accommodationfor any other existing orproposed FBO. This requirement arises from the grant assurances stipulated inthe following: GRANTAGREEMENT Between SRCBOCC and the FAA dated August 19, 2011 ,currentlyunder constructionto use as and example. ProjectNumber3-12-0052-010-2010 Part ofthe terms and conditions ofaccepting AirportImprovementProgram (AlP) grants .fromthe Federal AviationAdministration (FAA) states as follows: Paragraph22 c ofthese terms states: "EachFBO atthe airport shallbe subjectto the samerates, fees rentals, and other charges as are uniformly applicable to all otherFBOs makingthe same or similaruses ofsuch airport and utilizingthe same or similarfacilities In considerationofthe foregoing, the following solutionsto the "FuelFarm"issue are offered: I. SRC may elect to exercise its optionto assume full and complete control and operation ofthe "FuelFarm". This wouldrequire countypersonnel to operate and maintainthe equipment, and provide trainedpersonnel for dispensing offuel. 2. Openthe "Fuel Farm" to abiddingprocess. Requestproposals for bid for use and operationofthe "Fuel "Farm" on a competitivebasis. Bidders would offer aper annum amount and apercentage flowage fee to be paidto the county. The winning ofthe bidprocess would not precludethe losing bidder from supplying his/her ownfueling facility andpaying flowage fees.

### 3. Propose ajointoperation where two FBO's share the "Fuel Farm". Each FBO would be responsible for purchasing his/her own fuel supply for the "Fuel Farm". Flowage generatedby each FBO could be trackedby each FBO having his/herunique fuel card. Each gallon offuel couldthus betrackedto each individual FBO. Also, proposethat airport flowage fees bepaidon delivery of fuel from the bulk distributor. Simplytake the number ofgallons deliveredto that particularFBO and multiplybytheflowage rate andremit result to SRC

. Inthis way, a deliveryinvoice and check for flowage couldbe submittedto SRC. This wouldeliminatethe current gallonby gallontracking and remittanceto SRC. 4. The countyprovide athirdtankfor 10011 fuel, move the fuel farm to a central location. EachFBO wouldpurchase fuel trucks to service its customers. The countycouldbringthe fuel farm to currentFAA requirements. 5. There wouldbeno costincurredbythe countybecause all improvements atthe airport are generatedby revenues from leases and grants. 6. 

### MiltonAviationPartners LLC has consulted withMr. 

### BillFarris ofthe FAAADO regardingthe"Fuel Farm" question. He advised thatFAA 5190.6B, "Airport Compliance" and the aforementioned stipulations 

### inthe Grant Assurancesbefollowed 

### in theresolution ofthis question. Mr. Farris maybe contacted atthe address and telephone numberbelow. MR. BILL FARRIS Program Manager Orlando, AirportDistrict Office 5950 HazeltineNational Drive, Suite 400 Orlando, FL 32822 Telephone: 407-812-6331, Ext 125

Regards MiltonAviationPartners LLC Archie Collum SeniorPartnerAngie Jones



### from: archcollum@aol.com [mailto:archcollum@aol.com] 

### Sent: Tuesday, March 15, 2011 7:04PM 

### To: Angie Jones 

### Subject: Re: FBO Lease Angie, Fuel is one ofthe most profitable ofall FBO operations, 10,000 gal per month will gross about $10,000.00 in profits which would cover most ofthe fixed costs ofthe FBO. Without fuel sales and the costs of a fuel farm ($200,000.00) the margin of profitfrom other activities is minimal. In order to offset the loss of revenue we would like to have the following changes made in the lease. pg 4 lease space reviewed every 5 years add, the county to add 15 parking places on the east ramp at no charge as they have done for AMS for the past 10 years. article 4 pg 

### 6 #2 General aviation facility to be reduced in size to 1200sf #3 delete article 

### 7 pg 

### 9 #1 delete #3 delete #4 delete pg 10 delete #15 

### Ifwe provide the fuel facility no flowage fees. Wewould like to maintain the grounds on the east side ofthe runway on a schedule and standards set by the county. The costs are not addressed and unless the county can provide these services at a reasonable cost we prefer to responsible. Archie
-----Original Message----- From: Angie Jones <angiej@santarosa.fl.gov> To: 'archcollum@aol.com' <archcollum@aol.com> Cc: Commissioner Cole <Commcole@santarosa.fl.gov>; HunterWalker <HunterW@santarosa.fl.gov> Sent: Fri, Mar 11, 2011 1:05 pm Subject: RE: FBO Lease

Mr. Collum: Thank you for your patience as county staff has worked on the FBO lease. The latest generation ofthat document is attached. You will notice that it is substantially like the last draft, with 2 major exceptions: 1) all reference to fuel/fuel farm/flowage fees, etc. has been removed; and 2) the square footage cost has been reduced by about half. As you can imagine, the question of how to deal with the fuel farm has been the hold-up in recent days. The current fuel farm is located on AMS's leasehold property, and AMS manages that facility pursuant to our existing arrangement. As Ithink everyone acknowledges, there is no need for two fuel farms (nor funds for such), so our goal has been to offer you a fair arrangement in spite ofyour lack ofsuch facilities. To that end, we reduced the rental fees. As always, this draft is meant as a discussion item, and I would invite you to call me after you've have time to review it. Your suggestions are welcome and I look forward to working with you. Have a nice weekend. Angie Jones Santa Rosa County Attorney 623-1857

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### Ryan P. Hatler From: Angie Jones Sent: To: Wednesday, March 23, 2011 4:30 PM Tammy Simmons Subject: RE: FBO lease

Not sure.

From: Tammy Simmons 

### Sent: Wednesday, March 23, 2011 3:58 PM To: Angie Jones 

### Subject: RE: FBO lease What did we do to improve it, sweep the dirt? He must be talking about the old parking area that is of no use to AMS now. ???

From: Angie Jones 

### Sent: Wednesday, March 23, 2011 3:51 PM To: Tammy Simmons; Hunter Walker; Roger Blaylock 

### Subject: RE: FBO lease As to parking, Roger told me that we have not given AMS parking as Mr. Collum describes, though we have improved the public park.lng atthe airport.

From: Tammy Simmons 

### Sent: Wednesday, March 23, 2011 3:50PM To: Angie Jones; Hunter Walker; Roger Blaylock 

### Subject: RE: FBO lease

• Currently the parking utilized by the FBO is a dirt parking area; is that area included in their lease?, ifso, couldn't he have the same. • Lease withAMS states "each third anniversary". The lease fee we get from AMS is $341.12 a month. Don't know if he is asking for three years orfive years, it can never go down based on consumer index, only up. so if he is asking for 5 it gives him a 2 year grace period on each segment (3 or 5). • 3000 or 1200 sq. ft.? Originally he stated 3000; my thought is do we want this large of a building should the business not be successful? At the November 17, 2010, Aviation Advisory Committee, Mapoles stated that a year ago Jack Edwards Airport allowed a second FBO which ended up going out of business, now they have a continued problem of individuals wanting to come in as a second FBO to sell gas, leading to both FBO's never able to make a decent living. • Same comment above as far as them building the third building • The services under Article 7 are already being provided by AMS; only time I think this will become a problem is if AMS folds. As far as the grass issue, I do not believe we need to split the mowing in half. It will look bad, grass neat on one side and tall on other, clear line drawn in the grass where it meets. Whatwould the cost to the county be ifwe had to provide them a fuel farm or change the lease we currently have with AMS? The biggest saving we could offerto them as a trade offwould be to not make them build the three facilities according to their original proposal and allow them to downsize per their request and should have no effect on us. (

From: Angie Jones 

### Sent: Wednesday, March 23, 2011 1:24PM 1To: Hunter Walker; Roger u1aylock; Tammy Simmons 

### Subject: FBO lease I meant to send this to everyone last week; not sure if it went through. The highlighted portions are Mr. Collum's requested deletions. Would appreciate input.
AJJ

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### Ryan P. Hatler From: Sent: 

### To: Subject: Angie Jones Thursday, March 24,2011 8:16AM Hunter Walker; Roger Blaylock; Tammy Simmons FW: FBO Lease



### From: archcollum@aol.com [mailto:archcollum@aol.com] 

### Sent: Wednesday, March 23, 2011 6:29PM 

### To: Angie Jones 

### Subject: Re: FBO Lease Angie, We are going to focus on maintenance of aircraft and specialized flight training. We are not sure how long we will be without a fuel source and can not depend on the fuel profits to support the operation. I have spoke with other partners and we feel like underthese circumstances our posted hours will be the norm. Monday thru Friday SAM to 5PM and on Saturday SAM until noon. Thanks You. Archie Collum -----Original Message----- From: Angie Jones <angiej@santarosa.fl.gov> To: 'archcollum@aol.com' <archcollum@aol.com> Cc: Hunter Walker <HunterW@santarosa.fl.gov>; Roger Blaylock <RoqerB@santarosa.fl.gov> Sent: Wed, Mar 23, 2011 3:52 pm Subject: RE: FBO Lease Mr. Collum: You asked that I strike the paragraph regarding hours/days ofoperation. What hours/days do you propose to operate? Thanks. AJJ Angie Jones Santa Rosa County Attorney



### From: archcollum@aol.com [mailto:archcollum@aol.com] 

### Sent: Wednesday, March 16, 2011 11:26 AM 

### To: Angie Jones 

### Subject: Re: FBO Lease Thank You Archie

-----Original Message----- From: Angie Jones <anqiej@santarosa.fl.gov> To: 'archcollum@aol.com' <archcollum@aol.com> Cc: Hunter Walker <HunterW@santarosa.fl.gov>; Roger Blaylock <RogerB@santarosa.fl.gov> Sent: Wed, Mar 16, 2011 9:09am Subject: RE: FBO Lease Thank you for your response. I'll to review your requests, discuss with our staff and get back to you. 1

### Ryan P. Hatler From: Sent: To: Subject: Tammy Simmons Monday, June 27,2011 5:05PM Angie Jones 

### FW Attachments: tenantsurveyresults.doc; 2010 tenant survey.doc; 08031 OFBO Recission.doc; 11171OEX1.pdf; Spreadsheet AMSvsMiltonAviationPartners.doc; 11021OArchieCollum FBO agreement.htm; Draltfbo-lease i.doc; Proposal

- Milton Aviation Partners.pdf; RFPFixedBaseOperator092110.pdf

Here are the documents I sent earlier again, which includes the exhibit from the 11117110 pdf. Kelly sent me your request to her. I do the minutes and have the original minutes here.

From: Tammy Simmons 

### Sent: Monday, May 23, 2011 2:04 PM To: Angie Jones 

### Cc: Merry Beth Andrews Subject: Attached are the documents I have in relation to public records request dated 5/18111 from Clark Partington Hart etc on case style Aviation Management Services, Inc. v Milton Aviation Partners, LLC. I have the DVD's ofthe two meeting as requested, I will give these to Merry Beth. The cost per DVD is $10. The survey is the compiled results: I have the individual responses ifyou need; about 100 pages. Tammy 

### C. Simmons, Administrative Services Manager Santa Rosa County BOCC 6495 Caroline Street, Suite J Milton, Florida 32570 (850) 983-1858 (850) 983-1861 (fax) tammys@santarosa.fl.gov http:l/www.santarosa.fl.gov/

Florida has a very broad Public Records Law. Virtually all written communications to or from Santa Rosa County Personnel are public records available to the public and media upon request. E-mail sent or received on the county system will be considered public and will only be withheld from disclosure ifdeemed confidential pursuant to State Law.

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