U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

Federal Aviation Administration 

Complainant, 

vs. 

AVIONICS MASTERS, INC. 

Respondent 

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) 

) 

) 

) 

) 

) 

) 

) 

_________________________) 

Docket No. FAA-2013-0288 

Judge J.E. Sullivan 

FAA Case. No. 2~(;;';i: IV ED 

MAY 1 2 2014 

HEARING DOCKET 

AFFIDAVIT OF CHARLES HUNT PER COURT ORDER SERVED APRIL 16,2014 

THE AFFIANT, being duly sworn, says: 

My name is CHARLES HUNT, I am above 18 years of age, I am competent to testify 

and I state these facts based on my personal knowledge. 

1. This affidavit is pursuant to Paragraph 4 of Judge Sullivan's Order Setting Deadline 

for Filing Amended Complaint and Supplemental Materials. The Court's question 

on Paragraph 4 is with respect to the scope of Avionics Masters Inc's "inspection 

of the Gyro in its response to the FAA's motion for summary judgment on the 

primary alleged violations of 14 C.F.R. §145.5(a) and 145.201 (b)." 

2. The terms used in Respondent's previous pleadings and affidavits- "inspection", 

"Level 1 inspection," "functional test," "rudimentary functional test," "functional 

check," "rudimentary functional check," and "rudimentary external naked eye 

examinations"- all mean the same thing, specifically, that a basic inspection was 

performed as explained below, and consistent with Avionics Masters' operations 

specifications and capability list. None of the above phrases mean "repair." 

W6051415/K-43186 Page 1 of 5 
3. Background: The KFC-200 Auto Pilot is not by itself a standalone unit contained 

in a box. Rather it is system that consists of several sub-systems and components. 

The Auto Pilot and its subsystem, the KCS-55A Compass System, are comprised 

of many individual components and is therefore not referred to as a Unit which 

could be stored in a Box by itself. Avionics Masters maintains an inventory of all the 

units that comprise the systems. The FAR also states that functional checks of a 

system can be performed in the aircraft or on the bench using the test harnesses. 

Avionics Masters is authorized to perform functional checks either in an aircraft or 

on a test bench. 

4. We are using the dictionary definition of the term "inspected" to mean that the unit 

was looked at with the naked eye and found to have no physical defects. The 

definition offunctional check is powering up the complete system and observing the 

manufacturer's stated operational characteristics. In the case of this KG-102A 

Remote Gyro, it's purpose is to provide stabilized heading information to the KI525A display instrument for the purpose of providing the human pilot with directional 

information. The control for this system allows the human pilot to use it as an 

uncorrected Directional Gyro or as a slaved or corrected heading display. The 

system also provides steering control to the Auto Pilot for the purpose of allowing 

the human pilot to select a heading to be followed by the aircraft as set by the 

human pilot. Therefore, the Compass System is an independent subsystem of the 

Auto Pilot and can be functionally checked in and of itself. 

5. Avionics Masters has all the required manuals and test harnesses in order to 

perform a functional evaluation of the Compass system which includes the KGW6051415/K-43186 Page 2 of 5 
1 02A Remote Heading gyro reference unit. This is how Avionics Masters performed 

the functional system test defined as a Level One functional test of the KG-102A 

unit to determine that it performed to the specified characteristics as defined in the 

Manufacturer's detailed operating specifications. There is no part of this functional 

performance check that requires opening up or disassembling any part of the KG102A unit. Therefore, nothing that could be construed as maintenance was 

performed in conjunction with this functional check. 

6. The KG-1 02A was treated as a single unit after its functionality was confirmed and 

was assigned an FAA form 8130. It was entered into the Avionics Masters stock 

system to be held with other Components of the KFC-200 Auto Pilot system and the 

KCS-55A Compass System which were then available for final check and 

incorporation into an aircraft which may have a defective Auto Pilot or Compass 

System component in the course of trouble shooting its on board system. All these 

operations are approved as detailed in the Avionics Masters Operational 

Specifications provided as documentation as issued by the FAA Administrator. 

Some of the functionally tested units have failed re-inspection after being removed 

from stock for final checks. The unit in question is one of the units which failed upon 

this recheck and was on the test bench to be routed for repairs by Velocity 

Aerospace facility that performs contracted repair work to these units for Avionics 

Masters. 

7. At all times Avionics Masters conforms to the Policies and Procedures defined in the 

FAA Approved Shop Manual and adheres to the FAA Approved Capabilities List. 

Avionics Masters does not perform Maintenance or Tests to any unit that is not 

W6051415/K-43186 Page 3 of 5 
05/05/2014 10:25 9544915279 AIJINICS HASTERS 

within its capabilities list or for which Avionics Masiers does not have the 

Manufacturer's manuals and proper test equipment. 

FURTHER AFFIANT SAYE:TH NAUGIH: 

STATE. OF FLORIDA 

~ COUNTY OF BROWARD ) 

BEFORE ME, the undersigned authorilly, personally appeared CHARLES HUNT, 

known to me to be the person who executed the foregoing instrument In my presence, or 

produced his Florida Driver's License as proolf of idantification. · 

~-t:L- " WITNESS my hand and official seal, thl:v_-dayof May ,2014 in the County and 

State aforesaid. · 

PAGE 01/01 

,. ,-r··::~:_:;........ TAMMY S, Wft!TMIER. /fs ~t>-:.~. NO;Iary PubUc ~ Stata at flocfda ;;: . .. ~ 

S • • • • f My Comm. Expire~ Sep 1 o, 2014 

\:(~ ~~ Commission ;,. EE 21'137 

, ~ .. ~" .. ,?f,f,\••''' Bond!!~ Ttlrough NaHonal Nolary As5n. 

CERTIFICATE OF SE;RYfE , '. , r _ · I Jt~a1, hv;y jt ~ I HEREBY CERTIFY that I have on tt1is date, (;riaay,'M!JY lo!, 21il14, served 'uil( 

foregoing to the following parties using the balow·da~cribad methods: 

W6051416/K~J186 

Original and one copy via Regular U.S. mail and fax: 

Federal Aviation Administration 

BOO Independence Avenue, S.W. 

Attention: Hearing Docket Clerk, AGC-430 

Page 4 or 5 

Received Time May 5. 10 28AM 
Wilbur Wright Building- Suite 2W1000 

Washington, D.C. 20591 

Fax: 1-202-493-5123 

One copy via Regular U.S. mail only: 

Honorable Judge J.E. Sullivan 

Office of Hearings, M-20 

U.S. Department of Transportation 

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

Washington, D.C. 20590 

One copy via Regular U.S. mail, fax, and email: 

c/o Christopher R. Stevenson, Attorney 

Office of the Regional Counsel, Southern Region 

Federal Aviation Administration 

P.O. Box 20636 

Atlanta, GA 30320 

Email: chris.stevenson@faa.gov 

Fax: 1-404-305-5223 

One courtesy copy via email only: 

Charles L. Hunt, Jr. 

Vincent Sorentino 

Avionics Master, Inc. 

1001 West Cypress Creek Road, Suite 309 

Fort Lauderdale, FL 33309 

Email: Chadhunt@aol.com 

Page 5 of 5 

Counsel for espondent 

Mohammad Ahmed Faruqui, ESQ. 

Aerolaw Offices PLLC 

Florida Bar# 20875 

633 SE 3'd Ave, Suite 4R 

Trial Lawyers Building 

Fort Lauderdale, FL 33301 

Designated Emails for Service: 

Mohammad@Aerolaw.info 

Barbarad@Aerolaw. info