U.S. DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS FEDERAL AVIATION ADMINISTRATION Federal Aviation Administration Complainant, vs. AVIONICS MASTERS, INC. Respondent ) ) ) ) ) ) ) ) ) 

### _________________________) Docket No. FAA-2013-0288 Judge J.E. Sullivan FAA Case. No.

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# IVED MAY 1 22014 

## HEARING DOCKET

AFFIDAVIT OF CHARLES HUNT PER COURT ORDER SERVED APRIL 16,2014 THE AFFIANT, being duly sworn, says: My name is CHARLES HUNT, Iam above 18years ofage, Iam competenttotestify and I state these facts based on my personal knowledge. 1. This affidavit is pursuantto Paragraph 4 ofJudge Sullivan's OrderSetting Deadline for Filing Amended Complaint and Supplemental Materials. The Court's question
on Paragraph 4 is with respect to the scope ofAvionics 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 ofthe above phrases mean "repair."

W6051415/K-43186 Page 1 of 53. Background: The KFC-200 Auto Pilot is not by itself a standalone unit contained in a box. Rather it is system thatconsists ofseveral 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 inventoryofall 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 atest bench. 4. We are using the dictionary definition ofthe term "inspected" to mean thatthe unit
was looked at with the naked eye and found to have no physical defects. The definition offunctional check is powering up the completesystem and observingthe 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 KI525Adisplayinstrumentforthe purposeofprovidingthe human pilotwith 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 Pilotfor 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 ofthe 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 5102A Remote Heading gyro reference unit. This is howAvionics Masters performed the functional system test defined as a Level One functional test of the KG-102A unitto determinethat it performed to the specified characteristics as defined in the Manufacturer's detailed operating specifications. There is no part ofthis functional performance check that requires opening up or disassembling any part ofthe KG102A unit. Therefore, nothing that could be construed as maintenance was performed in conjunction with this functional check. 6. The KG-1 02Awas treated as a single unit after its functionalitywas confirmed and
was assigned an FAA form 8130. It was entered into the Avionics Masters stock systemto be heldwith otherComponents ofthe KFC-200Auto Pilotsystem 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 oftrouble shooting its onboard system. All these operations are approved as detailed in the Avionics Masters Operational Specifications provided as documentation as issued by the FAA Administrator. Some ofthe functionallytested units have failed re-inspection after being removed from stockforfinal checks. The unit in question is one ofthe unitswhich 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. AtalltimesAvionics Mastersconformstothe Policiesand Proceduresdefined inthe FAAApproved Shop Manual and adheres to the FAA Approved Capabilities List. Avionics Masters does not perform Maintenance or Tests to any unit that is not

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within its capabilities list or for which Avionics Masiers does not have the Manufacturer's manuals and propertest 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 ofidantification. ·**~-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. 

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### '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 28AMWilbur 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 ofTransportation 1200 New JerseyAvenue, S.E. (E11-310) Washington, D.C. 20590
One copyvia Regular U.S. mail, fax, and email: c/o Christopher R. Stevenson, Attorney Office ofthe 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 MohammadAhmed 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