### March 26,2015 

## FAA Ms. Lisa Toscano Office ofRegional Counsel, AWP-7 PO Box92007 LosAngeles, CA 90009-2007 

### Ref: Starjet, Inc./ FDMS 

### No. FAA-2014-1115 Dear Ms. Toscano: 

# RECEIVED APR 012015 

## HEARING DOCKFT

We are inreceipt ofthe Motion to DeemAllegation Admitted, datedMarch 17'h, 2015, andlet me first dispute the said motionbased on the fact thattheprevious letter fromJudge Goodwin's office clearly indicated that ourreply to the allegations was not due untilJune 2015. Thereforeit appeared to us thatthere is no hurry in the matter at all. Having said that, please find the following as an itemizedreply to the allegations: 1. 

### Correct. 2. Correct, except thatthe aircraftlc'l questions (Gulfstteam G-1159A N213BA) was removed from the air carrier certificate inApril2014. 3. Correct. 4. Correct, as itpertains to those aircraft thatwere listed on Ops Spec DOSS, was G-1159A N213BA was maintained accordingto same. 5. Correct. 6. Correct, except that Starjet cannoteffect 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 

### (notthe Administrator) discovered the discrepancy in the CMP analysts inputs thatcaused the erroneous data, andrepeatedly demanded corrections to be made. Furthermore, Starjetdidnot fail to track total time in service (etc.) as the companyhad the necessary records to determine the samein "hard copy" fo=at as previously presented to the Administrator uponinspection ofthe same. ·

26 WASHINGTON BOULEVARD, 2ND FLOOR • MARINA DEL REY. • CA 90292 • TEL: (310) 301-9325 • (310) 301-1556 • WWW.STARJETINC.COM8. Possibly correct, as the data was since correctedby 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 ofMaintenance Nader Sarkhosh- furthermore Mr. Sarkhosh hadinsured 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 enteredby the CMP analysts. Starjet discovered the same, and effected the necessary corrections. Itis very importantto note that the CMP due dates for engines/ APC can only be changedby manufacturer's (Gulfstream Aerospace Corp.) analysts. Theincorrect databy CMP analyst created a mess, butit also taught a goodlesson. 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 occurin the future. Once again- as it pertains to thepresent 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