U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D. C. 

RECEl\lED 

JUN 0 5 2015 

HEARING DOCKET 

IN THE MATTER OF: DOCKET NO. FAA-2014-0807 

PAZ AVIATION, INC. FAA CASE NO. 2011S0190272 

Respondent Judge J.E. Sullivan 

FAA'S NOTICE OF AMENDED COMPLAINT 

and 

FAA'S RESPONSE TO RESPONDENT'S AMENDED MOTION TO DISMISS AND 

MEMORANDUM OF LAW 

Pursuant to Judge Sullivan's Order Setting Motion Conference and Deadlines for 

Supplemental Filings, dated April 23, 2015, the FAA files this Notice of Amended Complaint 

and Response to the Respondent's Amended Motion to Dismiss. 

BACKGROUND 

Between June of 2009 and April of 2011, the Respondent performed maintenance, 

overhauled, and!m tested appwximately forty-eight aircraft parts. 1 (Exhibi:t-1). On onrbuut June 

21, 2011, FAA Aviation Inspector Ernst Biamby inspected multiple work orders of the 

Respondent and as a result, determined the Respondent neither had, nor used, the required tools 

to perform the maintenance, overhaul, and/or testing referenced in the work orders. (Exhibit 2). 

Moreover, Respondent's employee provided a signed statement that he did not properly test an 

1 One of these is parts is a Flight Spoiler Power Control Unit Assembly, part number 65-44561-15, serial number 

8356, as referenced in Respondent's work order number P AZ-25837. 
aircrafi part because of a "lack of tooling."2 (Exhibit 3). The specific testing equipment at issue 

is referenced in Boeing Component Maintenance Manual (CMM) Flight Spoiler Power Unit 

Control Assembly 27-60-41. (Exhibit 1) (Exhibit 4). On or about June 23, 2011, the FAA issued 

a Letter of Investigation ("LOI'') to the Respondent, which notified the Respondent that is was 

under investigation for performing maintenance, overhaul, and/or testing to the forty-eight 

aircraft parts without using the required tools or testing procedures. (Exhibit I). On July 8, 2011, 

the Respondent submitted a response to the LOI. 

On or about May 24, 2012, the FAA issued a Notice of Proposed Civil Penalty 

("Notice"),3 and on April 18, 2013, the parties participated in an informal conference to discuss 

the allegations enumerated in the Notice. At the infonnal conference, the Respondent indicated 

that it would submit additional information in support of its defense that it had and used the 

required tools to maintain, overhaul, and/or test the forty-eight aircraft parts. Almost a year later 

on June 20, 2014, the Respondent submitted said infonnation. (Exhibit 5). Shortly thereafter, the 

FAA issued a Final Notice of Proposed Civil Penalty on September 24, 2014.4 On or about 

October 1, 2014, the Respondent filed a request for a hearing. Six days later, on October 7, 2014, 

the FAA filed its Complaint. 

- - --- ---- - -On-January2-3-,-20-15,theRespondent-filed-its-MemQfandum-ofLaw-aFguingthatthe -

--------

FAA's Complaint should be dismissed based on the equitable doctrine oflaches, to which the 

Agency responded on February 10, 2015. On May 15, 2014, the Respondent filed its Amended 

Motion to Dismiss and Memorandum of Law. 

2 The part referenced by the Respondent's employee is same part referenced in in footnote 1. 3 The Notice of Proposed Civil Penalty references the same allegations and violations contained in the Complaint. 4 The Final Notice of Proposed Civil Penalty references the same allegations and violations contained in the 

Complaint. 

2 
AMENDED COMPLAINT 

Pursuant to 14 C.P.R. Section 13.214(b)(l), the FAA amends the Complaint filed on 

October 7, 2014. The FAA hereby removes allegations contained in subparagraphs 2(26), 2(28-

29) 2(34-48), and seeks a reduced civil penalty in that amount of $28,050. The applicable 

portions are amended to read as follows: 

I. 

On September 24, 2014, Respondent, Paz Aviation, Inc., was advised through a Final 

Notice of Proposed Civil Penalty that the FAA proposed to assess a civil penalty in the amount 

of $44,880. On October 1, 2014, the Agency Attorney received a written request for a hearing 

from the Respondent. 

II. 

1. At all times material herein the Respondent, times material llerein Paz Aviation, Inc. 

(hereafter "Paz"), was and is now the holder of Air Agency Certificate No. XPZR185L 

(Repair Station), authorizing Paz to perform work on Boeing Flight Spoiler Assembly 

components. 

2. On or about the following dates, Paz personnel performed maintenance and returned to 

service the following Boeing Flight Spoiler Power Control Unit Assemblies (hereafter 

"Assemblies"): 

Work Order No. 

1) 29409 

2) 29408 

. . .. . .. ........... .... ..... ... . .. . J)2940'i' -...... -

~) 2gsss 

5) 28554 

6) 28397 

7) 28396 

8) 28171 

9) 28170 

10) 28106 

11) 27884 

12) 27885 

13) 27886 

14) 27868 

15) 27867 

Maintenance Testing Dates 

TEST April25,2011 

TEST April25,2011 

·--- 1"-EgT- - ...................... Ap>~12S,2011-

0VERHAUL (elate unknovm) 

OVERHAUL AprilS, 2011 

OVERHAUL January 26, 2011 

OVERHAUL January 26, 2011 

OVERHAUL January 7, 2011 

OVERHAUL January 7, 2011 

OVERHAUL January 7, 2011 

Return to Service 

April27, 2011 

April27, 2011 

-· April-27-,2011 -· .... - -

-AJffil. 7, 20 II - ---

April14, 2011 

January 26,2011 

January 26, 2011 

January 7, 2011 

January 7, 2011 

January 7, 2011 

OVERHAUL 

OVERHAUL 

OVERHAUL 

OVERHAUL 

OVERHAUL 

November 11, 2010 November 11, 2010 

November 11,2010 November 11,2010 

November 11,2010 November 11, 2010 

November 30,2010 November 30,2010 

November 30, 2010 November 30,2010 

3 
16) 27866 OVERHAUL November 30, 2010 November 30, 2010 

17) 27517 OVERHAUL October 29, 2010 October 29, 201 0 

18) 27516 OVERHAUL October 29, 2010 October 29, 2010 

19) 27160 OVERHAUL September 22,2010 September 27, 2010 

20) 27159 OVERHAUL September 17, 201 0 September 20,2010 

21) 27158 OVERHAUL September 22, 2010 September 27, 2010 

22) 27157 OVERHAUL October 15, 2010 October 15,2010 

23) 27063 OVERHAUL October 26,2010 October 26, 2010 

24) 26477 OVERHAUL June 24, 2010 June 29, 2010 

25) 26476 OVERHAUL (date unlmown) June 29, 2010 

20) 29143 OVERHAUL (date unknewn) May 19,2010 

27) 26027 OVERHAUL November 22, 2010 November 22, 201 0 

28) 2§909 RBI! AIR flqJfil12, 2010 lqJfil12, 2010 

29) 2§908 REPAIR lqJfil12, 2010 i\pfill2, 2010 

30) 25838 OVERHAUL May27, 2010 May27, 2010 

31)25837 OVERHAUL (date unlmown) May27,2010 

32) 25792 OVERHAUL May4,2010 May27, 2010 

33) 25791 OVERHAUL July 28, 2010 July 30,2010 

3 4) 23§90 o:vERHAYL M&Feh23, 2010 M&Feh 23, 2010 

33) 23018 OVERHAYL IlehfU&f)' 24, 2010 IlehfU&f)' 24, 2010 

38) 2301+ 0\'ERHl.YL Apfil 22, 2010 lqJfil30, 2010 

31) 24939 O',l:gRHl,tJL fleeemlleF 9, 2010 JanuE!fj' B, 2010 

38) 24933 OVERHAYL (date unknewn) i'!B'iemBef 23, 2009 

39) 24831 OVeRHAUL l'!evemseF 21, 2009 NevefllseF 18, 2009 

40) 24839 OVERHl~L l'le'<'emBSf 30, 2009 l'Je,,•emllef 18, 2009 

41) 24833 0\l:gRH,A~L l'!evemll ef 3 0, 2009 l'!8'o'emBSf 18, 2009 

42) 24834 Ol,l:gRHAYL l'!e,,•emlleF 30, 2009 l'!e'ieFBsef 18, 2009 

43) 24801 Ol,LERHAYL (date unknewn) Janu&Fy 1, 2010 

4 4) 2433§ 0\lBRHAYL OateseF 22, 2009 OeteseF 23, 2009 

m••m mmmmmmm•••••••4!i) 24340 0\'ERHi\YL Nevemllef 3, 2009 l'!evemlleF 4, 2009 

48) 24013 OVERHltYL Septemllef :8, 2009 Sefltemllef 23, 2009 

41) 23893 0\l:gRHAYL (date unlrnewn) Ju±y 29' 2009 

4 8) 23++3 OVER1JAYL July 3 0, 2009 July 3 0' 2009 

3. The above maintenance was required to be performed in accordance with the data and 

instructions contained in Boeing Component Maintenance Manual (CMM) section 27-60-

41. 

4. Paz recorded some of the above referenced maintenance as "overhauled" in the required 

maintenance documents. 

4 

--- - ---- -------- ---------
5. However, the Assemblies were not properly overhauled in that Paz performed some 

required tests with tools that were not named in the applicable sections of CMM 27-60-41 

or approved as equivalent by the Administrator. 

6. ln addition, the Assemblies were not properly overhauled in that Paz failed entirely to 

perfonn other tests required by the applicable sections of CMM 27-60-41. 

7. ln addition, at the time Paz performed the above-described maintenance and approved the 

Assemblies for return to service, Paz had not performed tests in accord with data 

contained in the applicable sections of CMM 27-60-41 or other equivalent data approved 

by the Administrator. 

8. In addition, Paz employees were unable to explain how tests were performed on 

Assembly PIN 65-44561-15, SIN 8356, which Paz recorded as overhauled on May 27, 

2010, tested on September 27,2010, and repaired on April27, 2011. 

9. At the time Paz perfonned the above-described maintenance to the Assemblies, Paz did 

not have on hand all of the special technical data, equipment, and or facilities required to 

perform the above maintenance. 

10. Paz also failed to follow its accepted Repair Station Manual (RSM) Section 5.3.1, which 

requires Paz to have all the tools necessary to perform the required maintenance, to have 

the shop manager ensure that the equipment necessary was made available on the 

premises, and to verify the equipment, tools, and material needed for a particular job by 

checking the manufacturer's maintenance manual or other FAA-approved technical data. 

11. ln addition, Paz failed to follow RSM Section 5.3.3, which requires Paz to use 

equipment, material, and tools recommended by the manufacturer or equivalent 

equipment, materials, and tools, detennined to be equivalent by the Quality Control 

manager and documented on required Paz forms. 

12. In addition, Paz failed to follow its Quality Control System, Quality Control Manual 

.. . . ..... - SectionlAl, in-thatJ.'.az failedte detect m cure the lack- efpmper-toels and-teelmieal .. ··-· - - -· -

· data, the designation of items-as overhauled when they had not been properly tested, the 

lack of confom1ity to the requirements of Boeing CMM 27-60-41, and the improper 

return to service of items that were not repaired in accord with the requirements of the 

Administrator. 

Ill. 

13. By reason of the foregoing facts and circumstances, Respondent violated the following 

sections of the Federal Aviation Regulations: 

I) Section 43.2(a)(2) in that no person may describe in any required maintenance 

entry or form an aircraft, airframe, aircraft engine, propeller, appliance, or 

component part as being overhauled unless it has been tested in accordance 

5 
with approved standards and technical data, or in accordance with current 

standards and technical data acceptable to the Administrator, which have been 

developed and documented by the holder of the type certificate, supplemental 

type certificate, or a material, part, process, or appliance approval under 

§21.305 of this chapter. 

2) Section 43.13(a) in that each person perfonning maintenance, alteration, or 

preventive maintenance on an aircraft, engine, propeller, or appliance shall 

use the methods, techniques, and practices prescribed in the current 

manufacturer's maintenance manual or Instructions for Continued 

Airworthiness prepared by its manufacturer, or other methods, techniques, and 

practices acceptable to the Administrator, except as noted in 43.16. He shall 

use the tools, equipment, and test apparatus necessary to assure completion of 

the work in accordance with accepted industry practices. If special equipment 

or test apparatus is recommended by the manufacturer involved, he must use 

that equipment or apparatus or its equivalent acceptable to the Administrator. 

3) Section 145.201(b) in that a certificated repair station may not maintain or 

alter any article for which it is not rated, and may not maintain or alter any 

article for which it is rated if it requires special technical data, equipment, or 

facilities that are not available to it. 

4) Section l45.207(a) in that a certificated repair station must prepare and follow 

a repair station manual acceptable to the FAA. 

5) Section 145.211(b) in that repair station personnel must follow the quality 

control system when performing maintenance, preventive maintenance, or 

alterations under the repair station certificate and operation specifications. 

Pursuant to 49 U.S.C. Sections 46301(a)-(d), Respondent is subject to a civil penalty not to 

exceed $11,100 $11,000 for each of the violations alleged. 

·· ····· - - --Under-the-faets-an4£ircurnsffineesoHhis ease,-a-civilpenalty of$ 4 4 , g g 0 $28,0~0-is-apprepriatec 

FAA'S RESPONSE TO RESPONDENT'S AMENDED MOTION TO DISMISS 

1. 49 U.S.C. §46301(d)(7)(C) Does Not Warrant Dismissal of the Amended Complaint 

The Respondent argues that the Complaint, in its entirety, should be dismissed pursuant 

to 49 U.S.C. §4630l(d)(7)(C), which states "[e]xcept for good cause, a civil action involving a 

penalty under this paragraph may not be initiated later than 2 years after the violation occurs." In 

its brief, the Respondent interprets the statute to require that the FAA must file a complaint no 

6 
more than two years after the date of violation. Because the FAA filed the Complaint in this 

matter more than two years after the violations occurred, the Respondent asserts the original 

Complaint, in its entirety, should be dismissed. 

The Respondent inconectly interprets 49 U.S.C. §4630l(d)(7)(C) to the extent that 

Respondent argues that the FAA must file a complaint within two years of the date of violation. 

Rather, 49 U.S.C. §46301(d)(7)(C) requires that the FAA issue a notice ofproposed civil penalty 

within two years of the date of violation. This statute, as well as 14 C.P.R. §13.208(d), 5 are 

known as the "stale complaint" rule. 

In the case of In the Matter of David E. Everson, FAA Order No. 2004-5, *1, *2 

(September 22, 2004), the Respondent moved to dismiss several of the FAA's allegations under 

the stale complaint rule because the FAA filed its notice of proposed civil penalty more than two 

years after the Respondent committed the violations. In her analysis, the FAA Administrator 

cited 49 U.S.C. §46301(d)(7)(C) (and 14 C.P.R. §13.208(d)) for operating as a statute of 

limitations which requires the FAA to issue a notice of proposed civil penalty no later than two 

years after the date of violation. Id. See In the Matter of Royal Avionics Systems, Inc., FAA 

Order No. 2002-6, *1, *3 (April 16, 2002); In the Matter of Nicholas J. Werle, FAA Order No. 

- -9-+-20., ·*h--"4 {May--23, 199'7}- -S imi-larly,--In-the Mater-of-Van-Guard,--FAA-Doeket- No, - - -

CP01S00029, *1, *3, FN3, Chief Administrative Law Judge Ronnie A. Yoder referenced 49 

U.S.C. §46301(d)(7)(C) as a two-year statute of limitations which requires the FAA to issue a 

notice of proposed civil penalty no later than two years after the date of violation. Chief Judge 

5 14 C.F.R. §13.208(d) states: "Instead of filing an answer to the complaint, a respondent may move to dismiss the 

complaint, or that part of the complaint, alleging a violation that occurred on or after August 2, 1990, and more than 

2 years before an agency attorney issued a noticed of proposed civil penalty to the respondent. (I) An administrative 

law judge may not grant the motion and dismiss the complaint or part of the complaint if the administrative law 

judge finds that the agency has shown good cause for any delay in issuing the notice of proposed civil penalty. (2) If 

the agency fails to show good cause for any delay, an administrative law judge may dismiss the complaint, or that 

part of the complaint, alleging a violation that occurred more than 2 years before an agency attorney issued the 

notice of proposed civil penalty to the respondent" (emphasis added). 

7 
Yoder stated the statute codified 14 C.F.R. §13.208(d), and that pursuant to 14 C.F.R. 

§13.16(d),6 

a civil penalty action is "initiated" when the FAA issues notice of proposed civil 

penalty. Id. 

Because the violations alleged in the Amended Complainant occUlTed within two years of 

the Agency issuing its Notice of Proposed Civil Penalty on May 24, 2012, the violations are not 

stale; as a result, the Respondent's motion is due to be denied. 

2. The Respondent Cannot Establish The Affirmative Defense of Laches 

Because the Respondent is asserting the affitmative defense of laches, the Respondent 

bears the burden of proof. In the Matter of John J. Carroll, FAA Order No. 90-21 (August 16, 

1990). In order to prevail on a laches affirmative defense, the Respondent must show that (1) the 

FAA inexcusably delayed in bringing the instant action against the Respondent and (2) that as a 

result of the delay, the Respondent is prejudiced in its defense of the action. !d. Pursuant to the 

applicable statute of limitations, the FAA has five-years from the time the violations occurred to 

commence an action. 28 U.S.C. § 2462. See In the Matter of John J. Carroll. 

As to the first element, the FAA did not delay commencing the action in this matter. 

The FAA issued the Respondent an LOI one month after the FAA became aware of the 

to contain an aircraft part for which the Respondent maintained, overhauled, and/or tested 

without the proper tooling. As a result, the Respondent received both a timely and detailed 

notice of the FAA's allegations. (Exhibit 1). The Administrator has held that "[a]lthough aletter 

of investigation does not satisfy the limitation period set forth in 49 U.S.C. § 46301(d)(7)(C) or 

6 Now 14 C.F.R. §13.16(1), which states: A civil penalty action is initiated by sending a notice of proposed civil 

penalty to the person charged with a violation or to the agent for services for the person nnder 49 U.S.C. 46103. 

(emphasis added). 

8 
m 14 C.F.R. §13.208(d), it does notify a respondent that preserving evidence may become 

necessary." In the Matter of Royal Avionics Systems, Inc., FAA Order No. 2002-6, at *3 

(quoting In the Matter of Nicholas J. Werle, FAA Order No. 97-20, at *3). See 55 Fed. Reg. 

27548, 27556 (1990) ("[T]he notice provided in a letter of investigation reduces the chance that 

the respondent is prejudiced by the delay, especially where legal enforcement action is initiated 

within two years.") 

Additionally, 28 U.S.C. § 2462 imposes a five-year statute of limitations. By virtue of 

the statute, the Respondent was placed on notice that the Administrator had five years from the 

date of a violation to file a complaint. The Agency provided timely and multiple notifications to 

the Respondent. Based on the foregoing, the Respondent has failed to show that the Agency 

inexcusably delayed bringing the instant action against the Respondent. 

With regard to. the second element, the Respondent has not shown that it has been 

prejudiced in its defense of the action. First, the Respondent fails to address the fact that its 

employee admitted that the Respondent did not have proper tooling. (Exhibit 3). This admission 

negates the Respondent's allegation that it is prejudiced in presenting a defense in this matter. 

Second, the Respondent asserts that its engineering consultant, Jack Batista, will testify 

__ thaLhe._assistedin_creating_hlue.prints_fo.r.the.tes.ting. equipmenLrequired to. service the-parts_ _ 

referenced in the Complaint. The Respondent asserts that it expects Batista to testify that the 

privately built testing equipment was equivalent to that required by the manufacturer. However, 

the Respondent states it has been unable to locate Batista, and as result, is prejudiced m 

presenting its defense that it had the proper equipment to service the aircraft parts. 

To the contrary, the FAA submits that Batista's testimony is not dispositive to the issue 

about which he is expected to testify. The Respondent has not indicated why an independent, 

9 
appropriately qualified, engmeer cannot opme that the Respondent's privately built testing 

equipment is equivalent to that required by the manufacturer. 

In the alternative, the Respondent has not submitted any evidence indicating that the 

Respondent conducted a due-diligence search for the witness. Rather, the Respondent has 

offered only a simple allegation that Batista cannot be contacted. Because the Respondent has 

offered nothing more, the Respondent has not shown that it has been prejudiced. 

Next, the Respondent asserts that it is prejudiced because Ledo Industrial Machine Shop 

("Ledo") went out of business after the FAA issued the LOI to the Respondent. The Respondent 

alleges that it shipped its privately built testing equipment to Ledo for the purpose of separating 

two components contained on one stand to two components on two stands. The Respondent 

asserts that Ledo (or an employee of Ledo) will testify about the work performed on the testing 

equipment. However, the Respondent claims that because Ledo is no longer in business, Ledo 

(or an employee ofLedo) is unable to corroborate the Respondent's position. 

First, the Respondent fails to state the period of time that elapsed between the date the 

FAA issued its LOI and the date Ledo ceased operations. This timeline is important to determine 

whether the Respondent had the opportunity to inquire with Ledo prior to the company going out 

..... oLbusiness,_.and_what, _ _iLany,.inquiLytheRespondenLconducte<LSecond,-the.RespondenLhas----

not submitted any evidence to show that the Respondent diligently acted to preserve evidence 

(i.e., a timely inquiry of and/or search for Ledo employees). Finally, the anticipated testimony 

from a Ledo employee will be cumulative; the Respondent, via its employees, is in a position to 

provide the testimony expected of Ledo employees. 

Without more, the Respondent is unable to substantiate that it has been prejudiced. As a 

result, the Respondent has not satisfied its burden. See In the Matter of John J. Carroll 

10 
("Respondent has not alleged the type of prejudice that has been held to support a laches defense: 

that the delay resulted in a loss of evidence or witnesses supporting his position, or that he 

changed his position in a way that would not have occurred by for the delay.") 

Conclusion 

Based on the foregoing, the Respondent has failed establish that dismissal of the 

Amended Complaint is warranted under 49 U.S.C. §46301(d)(7)(C). Similarly, the Respondent 

has failed to establish an affinnative defense of laches, in that the Respondent has not shown that 

(I) the FAA inexcusably delayed in bringing the instant action against the Respondent and that 

(2) the Respondent suffered actual prejudice as a result. Therefore, the Respondent's motion to 

dismiss the Complaint must be denied. 

Respectively submitted this 1""' , day of--'¢'-~-'"""""--'-'""'--1'----~~, 2 015. 

Counsel for Complainant 

11 
CERTIFICATE OF SERVICE 

I hereby certify that the foregoing FAA's Notice of Amended Complaint and FAA's Response to 

Respondent's Amended Motion to Dismiss was sent to the following via Federal Express: 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, D.C. 20591 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2W1 000 

The Honorable J.E. Sullivan 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200New Jersey Avenue, S.E. (E11-310) 

Washington, DC 20590 

Facsimile: (202) 366-7536 

David M. McDonald, Esq. 

McDonald & McDonald 

Attorneys at Law 

P.O. Box 669122-9428 

Miami, FL 33135-2321 

Telephone: (305) 643-5313 

Facsimile: (305) 643-4990 

____________ .Officeof.the.RegionaLCounseL _ 

---------------

Dated 

(Express Mail only) 

12 
U.S. Oepartmen! 

of Transportation 

Federal Aviation 

Administration 

JUN 2 3 2011 

South Florida 

Flight Standards District Office 19 

CERTIFIED MAIL- RETURN RECEIPT 

E!R Number20JJSOJ90272 

Mr Juy Eugene Allen 

Accountable Manager 

PAZ Aviation. Inc. 

7455 West 2"" Court 

Hialeah, Florida 33014 

Dear Mr Allen: 

2895 SW 1451h Avenue, Su11e 120 

M1ramar. Flor1da 33027 

This letter is to inf(Jrm you we are investigating an incident that involve un article 

overhauled by Paz Aviatio.n, Inc. (PAZ), a 14 CFR part 145 Repair Station certilicatc 

#XPZRJ851, which failed during operation. The subject Flight Spoiler Power Control Unit 

Assembly, PIN 65-44561-15, SIN 8356, had the following maintenance pcrrormcd by 

PAZ 

• Work Order PAZ-25837, Overhauled May27, 2010. 

• Work Order PAZ-27429, Tested September 27,2010. 

• Work Order PA/-29145, Repairerl April 27, 2011. 

On June 20, 20 I I, this office VISited PAZ, and interviewed PAZ management and 

employees. Our interview with Mr. Antonio Yanez, the technician who pcrrorrned 

___ maLll_Len.anc_e __ mLthc..s.uhj.e.c.Lactide.,..Le\iealed-hedid.nGl-m;e-the-re~+l-i-r<:>EI--Ie8-1-s-m--lest-

--------------J2Iill'ed urcs.l!JlcL.Inainkna.nrc and a I so_.sJated''lhe ""it wa~-&WEJ---J-()~f-&F-tack---of--------------­

tooling". 

Further investigation revealed PAZ was unable to provide the required Tools and 

Equipment or equivalency of tools used to return this article to service. 

PAZ Work Order log shows the following listed Work Orders could also be atTcctcd. 

I -- -------:--------··---

Work Order Date 

I 29409 04120120 II 

"'2 29408 - f--o4/20120-JJ 

3 29407 04/20120 I I r-- - ------ ----· 

~ 28555 01/2412011 

5 28554 01/24/2011 ----- ------

-

DescriEtion 

Flight Spoiler Power Con 

------·- Assembly 

" 

trol Unit 

Part Nu111_be~r Seri;;i/i 

65-44561-15 I 5307 

--- - ------- 65-4456l:l_5_ 

1

- 4469 

" 

" 

" 

---

65-44561-1 s 4391 

-~~-l---::-:-:--c-::- 8 I 6 9 

65-44561-15 3764 

~ GOVERNMENT 

i EXHIBIT M /1 
~~-----~----~-----------~------

6 28397 

_]__ 28396 

8 28171 

9 28170 

" 

" 

" 

" ---

65-44561-15 

65-44561-15 

65-44561-15 

65-44561-15 

~_'_':'_(__"::':'_~--J-.-~:c:..::~"'-'--"---4-------------- -!----"6):'_--_.4~~01_-15 10 28106 " 

II 

12 

13 !----'-=---

14 

,___12_ -

~-- 17 

18 

19 

27884 

27885 

27886 

27868 

---f---'--"-=.:::.:=-"-'-'::.....t----- --------l----"6 ).__--cj4 5 61~J 5 

65-44561-15 

,, 

-

" 

" ---· ---

65-4451> 1-15 

65-44561-15 

27867 65-44561-15 ___ _"::_'_"_"'_-+-_::_:__=.::__':',_:_:_ __ ------------- ---------1------ 27866 

27517 :.=:.:c::.~_::__+----- -------

27516 

27160 -=:_:__:_~_'_"-1------------- ----- --

65-445(11-15 - -- ·---

65-44561-15 

65-44561-14 

65-44561-15 

-- ·-- -- --

2 

-- -

IOS57 

4421 

40SX 

337,1/\li 

10592 

7452 

9717 

10617 

5412 

10685 

(, I O!J 

4444 

4617 

'J717 

745? 

_::-: _ __j_____,::_Cc_"-'---+-.::o:.::s~ll.:.7/~2-"o'-'l o::.....t------------"------- GS-44561-15 I 10617 

20 27159 

21 27158 --=---

65-44.\o 1-15 

22 !7157 08/17/201Q _______ ·_· --~-=-==:-:-=--~6S-44S61-15 j_ 16So -- 23 27063 08/09/20to .. 65-445ol-15' 7099 -j-::_o_~~_:::__+------ ------------ +-::_::___:__:_:__::_:____:_c:_ i 

~ 26477 06/04/2010 " 65-44561-14 ! -~----------- --

ll ]6J\ 

24(1, 

4635 

9847 

06/03/201 0 -\-.::""~~'_':'___j____ ----------- 25 26476 -

04/26/2010 __ .::__':''__'::''----+-_::__:_:=-=-=-=--+---------- ----

I-=-.__l---~"-'=-'--e-()_4/1 51201 o ~-~!J__ 26143 

27 26027 

65-445(, 1-15 

(,5-44561-15 

65-44561-15 

2_8_ 25909 -- ------

29 25908 

65-44561-15 475'J --------------------+--' 03/31/2010 

03/3 1/20_._1 0"----4--------·' ____ _ 

3 0 2 58 3 8 9_31_._2_"51_._2-"0"1 0='----+ _______ .. ___ _ 

e-21 25837 03/25/2010 +------ _·_'_ -----

32 ___ 25792 ____ 03119/2010 f--------------"----

33 25791 031.__19:-_12"_'0_'1':'0--1------ -- ~ -- -----

__cl_4_ 25560 ()_2117/20 10 -----------

35 25018 12:::1_:c_07:_:_1_::c20::c0:_:-9---1--------"- ------

~ ) so 17 12/07/2009 -------· 

---- ---J-7--- --------2-4-9-5-B-------- ---l---~-/-1:)-J-2-Q.G-9--- ------------------------------------ -------- ----------------- -------f--'--'-'-==:=:'___f------------------- -------------- :J4 l----;M9--'8----+---I--I~±IIj_+±5,1j_2:1J:Ol)J09q===:= --------- _ _:_ ---------- -

3 9 2 4 8 57 I _.I, 1_:_1 "'3/c:2-;-00"-c9'-+-------"---- __ _ 

4252'!6 

7485 

835(1 

I I 1 0 I 

6.111 

0357 

5800 

5608 

&§-44-§6-1--1--5----- -c'i-6-3:'--- -- ----- ----· -6~44-56 - - 9-700+-

65-44561-15 44n 

_4_Q __ 2~~56. II it1gO_O_') __________ '_' _ -+--'6"'-5:_-4'--'4 561_:_1 5_ 3 X 93 , \ ll 

41 24855 11/13/2009 " 1---1----- - - __:__:_:__:_::_:_:c_:_::_-"---1--------

142 24854 11/13/2009 -·------~---+ 

[43~f-__ _?_'!§01 11/09/2009- - ______ .. ______ _ 

' 44 24555 10/06/2009 

~~~--~--~~~--~~--------

: 45 24340 09/0 l/2009 

I 2407~ 07J30/2QQ~-l---- 1

.. 73893 07/06/2009 

~--- -_--~3::.:7_7:::_3 _ __L_0'-'6'-/16/2 __ 0::_0::__9:___]_ ______ ·' __ . _____ _ 

65-44561-15 45(,7 --------· 

7X56 

3077/1 

3156!\ 

6X 71 

114 7-l 

5953 

g)]~ 
_, 

lllis action may be in violation of the Federal Aviation Regulations; this leiter is to inrnrrn 

you that this matter is under investigation by the Federal Aviation Admimstration. We 

wish to otTer you an opportunity to present any evidence or statement you may care to 

make concerning this matter. The evidence or statements should be in surticient detail and 

contain all pertinent facts and any extenuating or mitigating. circumstances, v1hich you 

believe, may. have a bearing on this matter. 

I r you desire to do either of these, the actions should be accomplished within ten (I 0) class 

following receipt of this letter. Any discussion or written statement wJII be given 

consideration in the tina I conclusion of our investigation. However. ir we do not hear \rom 

you within the specified time, our report will be processed without the bcnctit or your 

statemenl. 

Should you have any questions, feel free to contact me at (954) 641-6135 

Sincerely, 

~~~-/F ;¢fnst ll"tmby Jr. 

/Principal r-..1aintcnance Inspector 
SOUTH FLORIDA FLIGHT STANDARDS DISTRICT OFFICE 19 

Ernst Biamby Jr. ·South Florida Miami Flight Standards District Office 19 

August 26, 20 II 

INSPECTOR STATEMENT 

On June 20, 2011, I investigated a complaint received via email with attachments, dated 

June 15,2011, against Paz Aviation, Inc, from ST Aerospace Solutions (Europe). The 

complaint alleges that Paz Aviation, Inc. (PAZ) a 14 CFR part 145 Repair Station 

certificate #XPZRI85L, with Radio Class,1,2,3 and Limited Accessory, Non-Destructive 

Ratings performed maintenance on a Flight Spoiler Power Control Unit Assembly, 

(PCU), PIN 65-44561-15, SIN 8356, which failed during a test flight of an SAS, 737-

400, as stated in the Complaint email. Listed below are the details of the work orders: 

l. Overhauled under Work Order# PAZ-25837, dated May 27,2010. 

2. Tested under Work Order# PAZ-27429, dated September 27,2010. 

3. Repaired under Work Order# PAZ-29345, dated April27, 2011. 

I interviewed PAZ Quality Control Manager Mr. Juan Zamora, Shop Manager Mr. 

Humberto Zamora and Mechanic Mr. Antonio Yanez, who performed maintenance on 

the PCU, and they all confirmed that the PCU was tested prior to retum to service. 

Following this interview PAZ employees could not explain why the PCU failed. I 

·-----·---·--··--------requeste<l--to-se&-the-e<fu·iJlme-nt-M-fc-¥ane-z-used-to-test-the-PE-l:I-:-Mr-Y-an·e-z--sho-weaTITa·----·----- -·-·----·-----

roll-aroum!-<:art located-BR-the shofl floor eolltairung (2) fixtw es/tools "!ric !I he icremmea--·----·-------

as the tools used to test the PCU. These tools are not equivalent to those listed in the 

Boeing Component Maintenance Manual (CMM) ATA 27-60-41, page 101, 110-113, 

121-123, 126. I then requested that PAZ provide the tools, test equipment and equivalent 

substitute as required by the CMM. The Shop Manager Mr. Humberto Zamora could not 

provide any documents to support tooling equivalency. I expressed to PAZ that my 

investigation is to determine what caused this PCU to fail, and if they would provide 

factual information it would save a lot of time investigating this matter. After hearing my 

comment Mr. Yanez revealed be did not use the required tools or test procedures after 

maintenance and he stated "the unit was not tested 100% due to the lack of some tools" 

and he provided a statement. Mr. Juan Zamora attempted to explain that the fixture used 

for testing this PCU was not in the shop because it was being modified, which is contrary 

to Mr. Yanez's account of how the unit was tested. 

~ GOVERNMENT 

i EXHIBIT 

L _ __d 
My review of PAZ equivalency file #374, for the PCU, which was provided by Mr. 

Humberto Zamora, did not contain any equivalency or evidence of the required tools was 

ever obtained by PAZ. I asked Mr. Humberto Zamora, how this article was returned to 

service without being properly tested? His response was that "it was an oversight on my 

part". None of the employees interviewed could explain how this article was tested. I 

collected copies of Work Order# PAZ-25837, Work Order# PAZ-27429, and Work 

Order# P AZ-29345. I informed PAZ management that l would return the next day to 

copy Work Orders for previous PCU, maintained by PAZ 

On June 21, 2011, l returned to PAZ, this time in addition to the above mentioned 

management personnel present wasP AZ Accountable Manager Mr. Jay Allen and 

Consultant Mr. Jack Batista, a proposed future employee who will be handling quality 

control issues. After briefing Mr. Allen of my findings I requested scanned copies of the 

(48) affected Work Orders listed below. 

- :---:----- ------ --- ---·· ----- ---- - ------ ,---, 

--, Work Order Date Description___ ___ Part Number r--"enal # 

I 29409 04120120 I I Flight Spoiler Power Control Uni! 65-44561-15 5307 

2 - Asse!llbly - 29408 04/20/2011 " .. 4469 

3 29407 04/20/2011 .. .. 4391 

4 28555 01/24/2011 ,, " 8169 --- 5 28554 01/24/2011 .. .. 3764 - 6 28397 01111/2011 " " 10857 -

7 28396 0111112011 " " 4421 -----· 8 28171 12/07/2010 .. " 4088 

9 28170 12/07/2010 " " 3374AB 

10 28106 12/01120 I 0 ,, f---

" ------- 10592 - - 1 1 27884 11120/2010 " " 7452 

12 27885 11120/2010 .. " 9717 -

13 27886 1111112010 10617 -----

14 27868 11/02/2010 " " 5432 - 15 27867 11/02/2010 " " 10685 - - -r-o-r-- 278o6 - --- -- n roz12m o -- ,, --

" 6106 

n-r- nsn 0972972010 - ,-, " 4444 ·- 18 27516 09/29/2010 " 

--

" 4617 - ·-----f-----,-, --- 19 27160 08117/2010 " 9717 ------ ---- --·-,-, ---- 20 27159 08/17/2010 " 7452 -=--- 27158 08117/2010 ---- ··:-, -------C---.. ----- 21 10617 

22 27157 08117/2010 " " 1680 

23 27063 08109120 I 0 " " 7099 -

24 26477 06/04/2010 " " 3136A -- ·~----------- ---------,,-- 25 26476 06/03/2010 " ------- 2465 ----··· 1------- 26 26143 04/26/20 I 0 " 4635 -------- ---- -- -- 27 26027 04/15/2010 " " - ------~-----·· - 1--- 9847 --

28 25909 03/31/20 I 0 " .. 4759 

29 25908 03/31/2010 " ,, 425296 --

2 
-

30 25838 03125120 I 0 " " 

31 25837 03/25/2010 " " 

32 25792 03/19/20 I 0 " " 

33 25791 03/19/20 I 0 " " 

34 25560 02/17/2010 ,, " 

35 25018 12/07/2009 " " -

36 25017 12/07/2009 

37 24956 1112512009 " " 

38 24955 11/25/2009 ,, " 

39 24857 11/13/2009 " " 

40 24856 II /13/2009 " " 

·--· 41 24855 11/13/2009 ,, " 

---- -- 42 24854 Ill 13/2009 " " 

43 24801 II /09/2009 " " ------ 44 24555 I 0/06/2009 " " ·-- 45 24340 0910112009 " " 

-

46 24075 07/30/2009 " " '--'--. .. 

~- ---

23893 07/06/2009 " " ---· ·------ .-·. ·--··---,-.--- 48 23773 0611612009 " - -- ·-- - ···----·-- -~---------

While waiting for the digitally scanned copies of the above listed atlected work orders to 

be completed, I returned to the shop tloor for further evaluation of the tools I observed on 

June 20, 2011. Accompanied by PAZ management to the shop tloor, I noticed a new 

Actuator Test Stand and a Test Fixture which were not in the facility on the previous day 

June 20, 2011. Mr Batista proceeded to explain that these Test Stands were just returned 

from being modified. My response to Mr. Batista's explanation, was that Mr Yanez did 

not indicate to us that these tools existed and were available when we requested to see the 

equipment he used to test the PCU. At that time, Mr. Allen became adversarial and 

accused me of threatening Mr Yanez. I promptly intem1pted him and in fanned him that 

no one was threatened and that Mr. Yanez was interviewed m the presence of PAZ 

Management and for him make an untrue accusation is unacceptable. PAZ management 

team Mr. Juan and Mr Humberto Zamora reiterated to Mr. Allen that Mr Yanez was not 

7485 

8356 

1110 I 

6313 

0357 

5800 

5608 

5632 

97084 

4423 

3893AB 

4567 

7856 

3077A 

3156A 

6871 

11474 

-59~~ 8532 

threatened. Mr. Allen attempted to substantiate that the new tools were pre\'IOusly_c>\V_n_e_d ________ _ 

------------aiiCfusea5fVA:Z,-Ilyprovldmfali-ilivoice-ii437:246:-daieJ6672oi26TI:r~~)m Ledo _______ _ 

-----------TnaustnafMachmeS!iOjJ!OfThe-amouniofNoo.oo;-whichshows thatthis -testS!a;:;d---

was newly manufactured. I then informed Mr Allen that there is no evidence that PAZ 

ever owned these tools, since review of the equivalency file #374. does not contain any 

equivalency of any of the required tools. 

I collected the scanned copies of the affected work orders and left the facility. 

On June 22,2011, I received an email from Mr. Juan Zamora to ST Aerospace Solution 

(Europe), requesting the subject PCU, be returned for functional test. 

On June 23, 201 L I sent a letter of Investigation to PAZ. 

3 
I responded to Mr. Zamora's email requesting that upon receiving PCU it be placed in 

quarantine. 

On July 8, 2011, I performed a follow-up inspectiOn for capabilities of randomly 

selected articles listed on PAZ's Capability List for self-evaluation and equivalency of 

tools. The result of this inspection revealed that PAZ did not have the required tools, 

equivalency, self-evaluatiOn and supporting documents. 

The following articles were randomly selected: 

·- Manufacturer Descnfltion PIN 

I Boemg Main Gear Actuator - ~5-17830 

2 -~lflL_ ___ 1----- -~Control Valve _AssemtJ!y__ - -- 65-22958 

3 Boeing ___ 1-------- Flap Transmission ~- --;--,---- 65-26613 --- 4 Boeing _ ___ Spoiler Power Control 65CI6300 -- --

5 Pratt Whitney Pressure Bleed Valve 658385 -·--- 6 Boeing Reservoir Assembly 5936986 ·--· 

Further evaluatiOn of open in-process Work Orders listed below, did not have all the 

required tools, equivalency, self-evaluation and supporting documents. 

--

--

Work Order Dated Manufacturer Description PIN SIN __ 

21234 05/06/3008 Honeywell TurbineAxial Vane 801240-4 071884-23 

29990 06122!20 II Eaton AJC Motor/Pump_ 861556 MX381 529 

I observed on the shop tloor the new Actuator Stand previously seen on June 20,2011, 

except now it is tagged "Do not use- Not complete" confinning that this umt was newly 

purchased. 

I also observed a PCU Test Fixture with uncalibrated Dial Indicators bemg fabricated 

which also confllTIIS PAZ did not have this tool for testing of previous PCU's that were 

returned to service 

On July 12, 2011, I sent a letter infom1ing PAZ, that effective July 8, 2011, prior to 

returning any articles to service, PAZ must demonstrate to the Federal Aviation 

Administration (FAA) and comply With all the requirements of 14 CFR Part 145.215, by 

revising and resubmit an acceptable Capability List. 

On July 15,2011, we received a telephone call from Mr. Batista, confim1ing receipt our 

letter dated July 12, 2011. He informed us that PAZ would comply with our letter and 

that it would take approximately 2 weeks to be in compliance. 

On July 22, 20 II, I performed a follow-up inspection of PAZ, for evaluation of their 

progress with the self evaluation of the articles listed on their capabdities list PAZ was 

in the process of reevaluating all articles. PAZ provided a folder #374, contaming self 

4 
evaluation documents for the PCU. We requested a test demonstration for the PCU, PAZ 

at this time could not perform this test due to Jack of tooling (being modified). 

Paz infonned us that they have not returned any articles to servrce. 

The CPU was returned to PAZ from ST Aerospace Solution (Europe) and we observed 

the shipping container was opened. We questioned why was it open° PAZ responded 

that is how it was sent. 

On August I, 2011, I visited PAZ, to perfonn an evaluation of documents t'or 

equivalency and self evaluation for the Flight Spader Power Control assembly P.N65-

44561-J 5 PAZ could not provide the supporting documents for tools equivalency 

evaluation. 

On August 25, 2011, PAZ, management visited the FSDO, and requested that we review 

the prelimmary equivalency documents for Flight Spoiler Power Control Unit Assembly. 

PIN 65-44561-15. We had no objection to the equivalency documents. PAZ requested 

that we come the facility on August 26, 20 I I, at which time all documents, test 

equipment and testing of the PCU, would be done. 

On August 25, 2011, I retumed a telephone call to the Regional Specialist responsible 

for this case. We discussed of the case and the following was requested: 

I. Insert as an lOP PAZ's Repair Station Manual, policies and procedures, sectiun. 

for Tools Equivalency. 

• Provide a signed Inspector Statement. 

• Further Explain Pictures lOP# 6, 14, 21, 22. 

• Inspector Statement from Inspector Louis Arrazola. 

• Revise and resubmit the Statement of case with all additiOnal lOP's Insert at the 

end. 

On August 26,2011, we received a telephone message from Mr. Batislil, cancelling our 

inspection due to PAZ, not being ready for our inspection. 

________ _ Qp_Augllit.JUOlL lhis_nffi=t>erforrned_a_fu)<>W4lf>-~~f-tet>l-ettmvalency-fur- --- ----- - --

Flight Spoiler Power Control Unit Assy, PIN 65-44561. We rC\'Iewed the equi\'alency 

documents in Book 374, and they were lound acceptable. PAZ satrsfactorily tested a 

Power Control unit. As a result this office will accept PAZ submitted Capabrlity Lrst 

Revision 16, dated August 30, 2011. 

5 
In conclusion this investigation has revealed that PAZ did not have the Tools and 

Equipment and could not have properly tested this PCU, as required by the Boeing 

CMM. 

Ernst 

Ernst Biamby Jr. 

Aviation Safety Inspector 

6 
I Antonio Yanez 

An 

· viati n, Inc. 

iation, Inc 

8]56 W/0 27429, 29345 and 25837 Flight Spoiler 

test the unit I 00% for lack of some tooling 

~GOVER. NMENT 

~ EXHIBIT 

I 3 
65-44561, 65-49580 

1. Testing 

A Tools/Equipment 

rp_aDEfNG' 

COMPONENT MAINTENANCE MANUAL 

TESTING AND FAULT ISOLATION 

NOTE: Equivalent substttutes may be used 

Reference 

COM-5349 

SPL-5346 

SPL-5435 

SPL-5459 

SPL-6874 

SPL-11814 

STD-381 

STD-382 

STD-1238 

STD-2604 

STD-3761 

STD-3913 

STD-4766 

STD-8746 

__ _ _ _:3TQc.11l5L 

STD-11848 

STD-11849 

Descri t1on 

X- Y Recorder/Plotter 

(Pan #: 925E. Supplter 60795) 

(Pan # XY530T. Supplter 72264) 

(Opt Part # 70458, Supplter 28480) 

(Opt Pan # 7090A. Supplter 28480) 

Flow meter - 0-2 gpm 

(Part# 410DME-3R. Supplier 81205) 

Test Equipment- Flight Spoiler Power Control Unit 

(Part# F80224-79. Supplier 81205) 

(Opt Part# F80224-60. Supplier 81205) 

Position Transducer 

(Part#: SS-101. Supplter 00288) 

Gage - Pressure, DiHerential 

Port Assembly- Flight Spoiler Control Unit (F80224--67 is included in 

F80224-79) 

(Pan#: F80224-67. Suppl1er 81205) 

Gauge- HydrauliC Pressure. 0 to 6000 ps1 (41369 kPa) 

Gauge- HydrauliC Pressure. 3000 ps1 (20. 684 kPa) 

Indicator - Dial 

Gauge. Hydraulic Pressure. 0 to 50 ps1 (0 to 344 kPa) 

G;wge - Hydraul1c Pressure. 0 to 3000 ps1 (0 to 20.684 kra) 

Test Stand- Hydtaultc. 0 to 5500 pSI (0 to 37921 kPa), ps1 Increments 

Scale- Spnng, 0 to 50 lbs (0 to 222 N) 

____ G_raduated B_ea_ke_r~_;Jj)Q(;_C: 

_______ Gage~El~.2DOD.cclnw;_ .. ________________ _ 

Dnp Tube- Hydraulic 

Flow Transducer- Hydraulic. 0 to 2 gpm 

B. Consumable Materials 

NOTE: Equivalent substitutes may be used 

Reference Description 

050122 Flutd- HydrauliC. Skydrol 

BOEING Pf10PRIE1AflY Cop~11Qhl' UnputliiOh<e<J War). See Idle 

Specification 

BMSJ-11. Type 

IV or Type V 

27-60-41 

TESTING AND FAULT ISOLATION 

~ GOVERNMENT j EXHIBIT 

A_ 

Page 101 

Jul 01/2010 
65-44561' 65-49580 ~HOEING' 

COMPONENT MAINTENANCE MANUAL 

CYLINDER 

lCRJ 

TEST MANIFOLD 

FB0224- 6 ----

RETURN (A) 

I HIDDEN) 

Flow Curve Test 

Figure 103 

EXTEND 

TEST PORT 

UNIT 

197527~ S00003S636S_ V1 

27-60-41 

TESTING AND FAULT ISOLATION 

Page 110 

Jul 01/2010 BOEING PROPRIETA.AY Copyright i" Uflpublishe<J l"iork See t'\le page lor dela•l~ 
65-44561' 65-49580 ?:1--HDEINC' 

COMPONENT MAINTENANCE MANUAL 

SIMULATOR 

HOLD ARM 

F80224--4 ~ ", 

Pos1tional Accuracy Test 

Figure 104 

FIXTURE F80224-60 

PROTRACTOR 

ASSY 

1975278 S0000356356 V1 

27-60-41 

TESTING AND FAULT ISOLATION 

Page111 

Jul 01/2010 
65-44561' 65-49580 (/l_HDE/NC' 

COMPONENT MAINTENANCE MANUAL 

SIMULATOR 

HOLD ARM 

DIAL INDICATOR 

GLAMPASSY~ 

Output Resolution Check 

Figure 105 

PROTRACTOR 

;J 

197~28dS000035636/ Vl 

27-60-41 

TESTING AND FAUL1 ISOLATION 

Page 112 

Jul 0112010 
65-44561' 65-49580 

POWER 

TENSION 

CYLINDER 

j 

({1_ HOE/'NLr 

COMPONENT MAINTENANCE MANUAL 

DIAL INDICATOR 

& ROO 

POWER 

CONTROL 

UNIT 

PROTRACTOR 

ASSY 

60 

1975296 50000356368 V1 

Hold-Down Check Valve Leakage, Dynam1c Seal/Load, P1slon Stroke Test 

F1gure 106 

27-60-41 

TESTING AND FAULT ISOLATION 

Page 1 13 

Jul 01/2010 
6544561' 65-49580 

THREE WIRE LEADS FROM 

PO~IT!ON TRANSDUCER TO 

X-Y RECORDER 

rp._ooE/NG' 

COMPONENT MAINTENANCE MANUAL 

CYLINDER RETRACT ICR) 

CYLINDER EXTEND ICE) 

IAI 

150796-018 

65-44061 

TEST FIXTURE 

TX150796 

197531550000356370 V1 

Check Valve, Flow Control Valve Test 

F1gure 108 

27-60-41 

TESTING AND FAULT ISOLATION 

Page 121 

Jut 01/2010 
65-44561' 65-49580 (j).-HDEIN&' 

COMPONENT MAINTENANCE MANUAL 

SETTING AND CHECK lNG 

fiXTUI<E, TX 1.50821 --

Rod End Adjustment 

Figure 109 

1975325S0000356371 V1 

27-60-41 

TESTING AND FAULT ISOLATION 

Page t22 

BOEING PROPRIETARY Copr"\)~11 ,- Unpubl,she<J Work See ~lie po;;~ lor dela,rs 

Jul 0112010 
65-44561, 65-49580 

y;l_DDE/N&' 

COMPONENT MAINTENANCE MANUAL 

SIMULATED 

SPOILER PANEL 

LINEAR OUTPUT TRANSDUCER 

TXI50804-J (MOUNTED ON 

ACTUATOR FIXTURES) 

POWER CONTROL 

UNIT. 6S.44561 

LINEAR INPUT POSITION 

TRANSDUCER, TX150804-2 

ROTARY OUTPUT TRANSDUCER MOUNTED 

ON SUPPORT BRACKET !NOT 

ON NEWE A FIXTURES) 

POSITIONAL ACCURACY 

CHECK FIXTURE, 

TX150B04 

Pos111onal Accuracy/Output Resolullon Check 

Figure 110 

-TEST 

INPUT 

1975332 SOOU0356J:'2 V 1 

27-60-41 

TESTING AND FAULT ISOLATION 

Page 123 

BOEING PROPRIETARY- Copynghl {Unpublished Work- Se<> t.tle p~ge lor deia•l3 Jut 0112010 
65-44561, 65-49580 rt1-DDEhVG' 

COMPONENT MAINTENANCE MANUAL 

_.. __ LOADING AND CYCLING 

FIXTURE, TXI50820 

1975J92S0000355375 V1 

Hold-Down Check Valve Leakage, Dynamtc Seal/Load, Ptslon Stroke Test 

Ftgure 113 

27-60-41 

TESTING AND FAULT ISOLATION 

Page 126 

Jut 01/2010 
DAVID C. McDONAL0(1897 1971) 

DAVID McDONALD 

William P. Vines, Esq. 

Federal Aviation Administration 

Office of Regional Counsel 

P 0 Box 20636 

Atlanta, GA 30320 

Re: Paz Aviation, Inc. 

McDONALD & McDONALD 

Attorneys at Law 

Established 1927 

I 393 SW First Street 

Suite 200 

Miami, Florida JJ 135-2321 

TeLEPHONE (305) 643-5313 

fACSIMILE (305) 643-4990 

dmJ!GJ .. H_lcdonaldaJ!orne}_;i_f:.Q!I! 

June 20, 2014 

0 

DAVID M McOONALD• 

PATRICK G McDONALD 

• Board Certif1ed In AvLatJOn La\\ 

Vra fax 404 305-5223 

and 

Email: William.Vines@faa gov 

Notice of Proposed Civil Penalty 

Case No. 2011SOI90272 

Our File No. 12-138 

Dear Mr. Vines: 

My apologies for not getting this to you sooner. Attached is the work order showing the 

equipment was in the shop during the site visit and photos of il back in the shop. 

--------------Please call me to discuss if you have anJ'_g_l]_e,;;ti.onL ________ _ - --------------------------------

Best regards, 

Sincerely. 

McDONALD & McDONALD 

DMMmml 

Attachments as stated 

's/ David M McDonald 

David M. McDonald 

§ GOVERNMENT I EXHIBIT 

a r: 

l? f Ci I \TlJ 

JUN ; 3 ,, : 

(-- '\ ,\ L; J 

:--i ) l r ) ; ' '' r:' 
lrt'-, 

RIAL MACHINE SHOf 

CT 

DENS, FL 33018 

Dale 

Arnoun: 5 
/ 

OICE LJ37211S 

~----:-----~lsHiiiT~--t-, \-. -:---------.:---- :'~ I F\l 1-'\(lt\tl tS~u:.V 'l \/i (\l lirl iJ.f'l1'( ·JL, N'l _\)__,·c:._c!>cFt;:d 

;,-,__::__:::___::::_~::.__-=----;;c--:---:----;--1rci¥""<i""W~;-"-----"'---'==---:=t-----t'-- ' ·----- -- 

0?- ''t 

ER ORDER NO \SOLD BY !TERMS - IF-08 \OAT[ 

IHI,.ED \ 0 "' ~ ::; --, ,; I I OOCRIPTIOH 'PRICE UHil ,t.tr.lOUIO [ C u·{'"o'\ '?-\uciQ C' \H.:: -§-1\N_i:.() ____ _ 

I 

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, 

1, 

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