U.S. Department 

of Transportation 

Federal Aviation 

Administration 

In Reply Refer To: ACE-7 

Office of Regional Counsel 

901 Locust, Room 506 

Kansas City, MO 64106~2641 

Area Code: 816-329-3766 

CERTIFIED MAIL- RETURN RECEIPT REQUESTED 

Certified Mail Receipt Nos. 70142870000128893345,70142870000128893321,70142870000128893338 

July 16, 2015 

Hearing Docket 

Federal Aviation Administration 

800 Independence Avenue S W 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building, Suite 2W1000 

Re: In the Matter of Jet Midwest Technik 

Case No. 20 14CE050039 

RECEIVED 

JUL Z 1 Z015 

HEARING DOCKET 

Enclosed herewith please find an amended complaint in the above-referenced proceeding. 

Sincerely, 

A. Lester Haizlip 

Senior Enforcement Attorney 

Enclosures 

cc: Patrick Kraus 

Gregory S.Wynton, Esq. 
U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

In the Matter of: 

Jet Midwest Technik, Inc. 

Served: July 16, 2015 

FAA Docket No. FAA-2015-0637 

FAA Case No. 20I4CE050039 

Judge Not Assigned 

AMENDED COMPLAINT 

The Federal Aviation Administration (FAA), by counsel, hereby files its Amended 

Complaint, pursuant to Rule 208 of the Rules of Practice (14 C.F.R. 13.208), and states as 

follows: 

I. 

I. On January 5, 2015, Respondent Jet Midwest Technik, Inc. was advised through a 

Notice of Proposed Civil Penalty that the FAA proposed to assess a civil penalty in the amount 

of $50,000. On April 6, 2015, Respondent submitted a written request for a hearing. 

II. 

1. At all times hereinafter mentioned JMTI was the holder of Air Agency Certificate 

Number Certificate No. 5JMJR702B authorized to function as an approved repair station under 

Part 145 of the Federal Aviation Regulations (FAR). 

2. On or about July 21, 2014, JMTI's accessory overhaul shop repaired and inspected 

56 B/E Aerospace seats under Work Order (WO) 100085-0858, with associated FAA Form 

813 0-3 airworthiness approval tag. 

3. Incident to the noted inspections, JMTI indicated on FAA Form 8I30-3 that the 

repairs and inspections were completed using B/E Aerospace component maintenance manual 

(CMM), chapter 25, revision 1, dated May 09/03. 

4. During routine surveillance conducted on August 26, 2014, by personnel from the 
2 

Flight Standards District Office, Kansas City, Missouri, it was discovered that JMTI did not have 

a current capability list showing the seats in question were eligible to be repaired and inspected 

by JMTI. 

5. JMTI's Repair Station and Quality Control Manual, Section 4.8, Capability List, states 

that JMTI may only perform maintenance on articles which are on JMT's capability list. 

6. The surveillance disclosed the cover page of the subject WO, associated with FAA 

Form 8130-3, had a block marked "yes" to indicate that the article is on the capabilities list 

when, in fact, the B/E Aerospace seats had not been added to the airframe component capability 

list at the time the maintenance work identified herein was performed. 

7. Based on the foregoing, JMTI illegally repaired, inspected, and returned to service 56 

seats when it was not rated or authorized to perform such maintenance. 

8. The 56 seats in question were subsequently installed in two Boeing 767 aircraft 

operated by Dynamic Airways. 

III. 

1. By reason of the foregoing facts and circumstances, Respondent violated the following 

sections of the Federal Aviation Regulations: 

a. Section 145.20l(a), when JMTI failed to perform maintenance in accordance with 

part 43. 

b. Section 145.201(b), when JMTI maintained an article for which it is not rated. 

c. Section 145.201 (c)(!), when JMTI approved for return to service an article when 

the maintenance was not performed in accordance with data acceptable to the Administrator. 
e. Section 145.207(a), when JMTI failed to follow procedures in their repair station 

manual for adding articles to their capability list before maintaining such articles. 

2. Pursuant to Title 49 U.S.C. 46301, Respondent is subject to a civil penalty not to exceed 

$11,000 for each ofthe violations alleged. 

3. Under the facts and circumstances of this case, a civil penalty of$40,000 is appropriate. 

WHEREFORE, the Agency, by counsel, respectfully requests that the Administrative 

Law Judge enter an order that Respondent be assessed a civil penalty in the amount of$40,000. 

Dated this 16th day of July, 2015. 

Respectfully submitted, 

A. Lester Haizlip 

Regional Counsel 

Attorney for Complainant 

Federal Aviation Administration 

901 Locust St., Room 506 

Kansas City, MO 64106-2641 

816-329-3765; Fax (816) 329-3771 

3 
Jet Midwest Technik, Inc., FAA Case No. 2014CE050039 

CERTIFICATE OF SERVICE 

I hereby certify that I have this date placed in the United States mail, certified, return 

receipt requested, a copy of the Administrator's Amended Complaint, addressed to: 

Mr. Patrick Kraus, President 

Jet Midwest Technik, Inc. 

9200 NW 112'h Street 

Kansas City, MO 64153 

Gregory S. Winton, Esq. 

The Aviation Law Firm 

1997 Annapolis Exchange Parkway 

Suite 300 

Annapolis, MD 21401 

In addition, I hereby certify that I have this date placed in the United States mail, 

certified, return receipt requested, the original and one copy, addressed to: 

Federal Aviation Administration 

800 Independence Avenue, SW. 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building, Suite 2W1000 

Dated this 161

h day ofJuly, 2015. 

t1t~vA. f-<1. !M/'-"'""' 

Alisa Gause 

Paralegal Specialist 

4