March 26,2015 

FAA 

Ms. Lisa Toscano 

Office of Regional Counsel, A WP-7 

PO Box92007 

Los Angeles, CA 90009-2007 

Ref: Starjet, Inc./ FDMS No. FAA-2014-1115 

Dear Ms. Toscano: 

RECEIVED 

APR 0 1 2015 

HEARING DOCKFT 

We are in receipt of the Motion to Deem Allegation Admitted, dated March 17'h, 2015, and let me 

first dispute the said motion based on the fact that the previous letter from Judge Goodwin's office 

clearly indicated that our reply to the allegations was not due until June 2015. Therefore it appeared 

to us that there is no hurry in the matter at all. 

Having said that, please find the following as an itemized reply to the allegations: 

1. Correct. 

2. Correct, except that the aircraft lc'l questions (Gulfstteam G-1159A N213BA) was removed 

from the air carrier certificate in April2014. 

3. Correct. 

4. Correct, as it pertains to those aircraft that were listed on Ops Spec DOSS, was G-1159A 

N213BA was maintained according to same. 

5. Correct. 

6. Correct, except that Starjet cannot effect the actual changes in the entries on CMP for engine 

times - only CMP analystsatGulfstream can do that, as demonstrated later. Starjet can only 

report flight hours and (landing) cycles to Gulfstream CMP analysts. 

7. Not correct. Starjct (not the Administrator) discovered the discrepancy in the CMP analysts 

inputs that caused the erroneous data, and repeatedly demanded corrections to be made. 

Furthermore, Starjetdid not fail to track total time in service (etc.) as the company had the 

necessary records to determine the same in "hard copy" fo=at as previously presented to 

the Administrator upon inspection of the same. · 

26 WASHINGTON BOULEVARD, 2ND FLOOR • MARINA DEL REY. • CA 90292 • TEL: (310) 301-9325 • (310) 301-1556 • WWW.STARJETINC.COM 
8. Possibly correct, as the data was since corrected by CMP analysts. There is no dispute on the 

fact that the data did reflect errors, yet these errors were discovered and corrections effected 

(again- Starjet cannot change engine times on CMP) by Starjet as later demonstrated via 

emails between the company and Gulfstream. 

9. See previous. 

10. See previous. 

11. See previous. 

12. See previous. 

13. Not correct- the actual engine total times/ cycles were at all times determined and 

communicated to CMP by Starjet's Director of Maintenance Nader Sarkhosh- furthermore 

Mr. Sarkhosh had insured that at no time were any time limits or calendar limits exceeded. 

As explained in the letter to the Administrator dated October 2013, this issue was due to mistakes 

entered by the CMP analysts. Starjet discovered the same, and effected the necessary corrections. 

It is very important to note that the CMP due dates for engines/ APC can only be changed by 

manufacturer's (Gulfstream Aerospace Corp.) analysts. 

The incorrect data by CMP analyst created a mess, but it also taught a good lesson. Therefore, 

Starjet completed a comprehensive audit, identified the root causes for the errors on CMP data for 

N213BA, and the company affected a comprehensive fix as previously explained to the 

Administrator - all this to ensure the same does not occur in the future. 

Once again- as it pertains to the present allegations on G-1159A N213BA, at no time were any 

inspections or time limits exceeded. 

k you for your cooperation. 

PekkaKaru 

President 

Starjet, Inc. 

Call: (310) 301-9325 

peku@starjetinc.com