EASTMAN & ASSOCIATES, LLC 

Haslachstrasse 39 

79868 Feldberg-Falkau 

GERMANY 

ATTORNEYS AT LAW 

POST OFFICE Box 180 

CHARLESTON, SOUTH CAROLINA 29402 

USA 

ROBERT G. EASTMAN 

AoMilTED IN DE, FL, GA, MD, NJ, PA, & SC 

March 6, 2014 

Electronic Mail (9-AWA-AGC-Part 16@faa.gov) 

Office of the Chief Counsel 

ATIN: FAA Part 16 Docket Clerk 

ACC-600 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

PHONE: (843) 329-9657 

FAX: (843) 723-0005 

robertgeastman@msn.com 

Re: Skydive Myrtle Beach, Inc., v. Horry County Dep't of Airports, et. a/. 

Part 16 Complaint filed February 24, 2014- Amended Pleadings 

Dear Sir/Madame: 

I represent the Complainant, Skydive Myrtle Beach, Inc. (SDMB), with regard to 

its Complaint against Respondent, Harry County Department of Airports (HCDA) filed 

on or about February 24, 2014 (Complaint). A copy of this letter is also being provided 

to counsel for HCDA. 

In response to Respondent's motion to dismiss without prejudice the Complaint, 

Complainant moves to amend its Complaint as follows: 

1. Complainant, SDMB, reincorporates and realleges each of the allegations 

identified in its Complaint as fully as if repeated herein verbatim. 

2. On or about, February 14, 2014, at SDMBs request, SDMB met with 

HCDA, its agents and North Myrtle Beach Grand Strand Airport (CRE) Air Traffic 

Control tower, Robinson Aviation, Inc., (ATC), (Meeting) in a good faith effort to resolve 

the discriminatory conduct identified in its Complaint. 

3. At the Meeting, positive feedback between and with CRE ATC resulted in 

identifying the cause of communication issues with CRE ATC and SDMB. 

4. On or about February 17 and 19, 2014, communication between CRE 

ATC and SDMB continued forward with respect to developing procedures and working 

on a new Letter of Agreement (LOA). 

140305.sdmb.hcdcatty.apauth. faa.ltr. final 
Office of the Chief Counsel 

March 6, 2014 

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5. CRE ATC is a non-government entity contracted to run CRE ATC by 

Respondent HCDA. 

6. Since February 21 , 2014, all communications from SDMB to CRE ATC 

and HCDA remain unanswered or ignored. 

7. Communications with HCDA have been met by continued discrimination, 

including but not limited to HDCAs continuing: 

a. failure to apply fuel discounts to SDMB (as with other similarly 

situated tenants) (ongoing); 

b. failure to respond to SDMBs communications (ongoing); and 

c. disruption with SDMBs mail and parcel delivery (March 3,4, 2014). 

8. SDMB certifies pursuant to 14 CFR § 16.21 (b): 

a. SDMB "has made substantial good faith efforts to discuss and 

resolve the disputed matter informally prior to the filing of [this C]omplaint" or 

since September 2014. See id. § 16.21(b)(1); and 

b. "There is no reasonable prospect for practical and timely resolution 

of the dispute." See id. § 16.21 (b)(2). 

9. SDMB believes that dismissal of its Complaint, without prejudice, will 

embolden Respondents to continue or increase discriminatory conduct against SDMB. 

10. SDMB respectfully requests the Federal Aviation Administration (FAA) to 

deny Respondents request to dismiss its Complaint. 

SDMB welcomes the Entry of Appearance and looks forward to resolving these 

matters. It has in the past and continues to work in good faith. Unfortunately, even 

after filing its formal Complaint and Civil Action, HCDA continues its pattern of 

discriminatory behavior and conduct through its agents or employees. At present, it 

appears that its employer, HCDA, has directed CRE ATC to no longer communicate 

with SDMB. 

Pursuant to 14 CFR § 16(h)(3), the persons designated to receive electronic 

pleadings are myself at robertgeastman@msn.com . 

140305.sdmb.hcdcatty.apauth. faa.ltr. fi nal 
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March 6, 2014 

Page 3 

Thank you for your attention to this matter. Should you have any questions, 

please do not hesitate to contact me. 

Encl.: () 

cc: Aaron Holly (via email) 

RGE/fub 

140305.sdmb.hcdcatty.apauth. faa.ltr. final 
Office of the Chief Counsel 

March 6, 2014 

Page4 

CERTIFICATE OF SERVICE 

I hereby certify that I have this day served the foregoing letter regarding Skydive 

Myrtle Beach, Inc.'s Part 16 Complaint on the following persons by electronic mail in 

accordance with 14 CFR § 16.13(h): 

Office of the Chief Counsel 

ATIN: FAA Part 16 Docket Clerk 

AGC-600 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

9-AWA-AGC-Part 16@faa.gov 

Dated: March 6, 2014 

140305.sdmb.hcdcatty.apauth. faa.ltr. final 

David Banner, Esquire 

Jeffrey Blease, Esquire 

Jaclyn Piltch 

Foley & Lardner LLP 

111 Huntington Avenue 

Boston MA 02199 

dbannard@foley.com 

jblease@foley. com 

jpiltch@foley.com 

Counsel for Harry County Oep't 

of Airports, et. a/ 

@f/~