DECLARATION OF JEFFREY SOULE, IN SUPPORT OF OPPOSITION TO MOTION TO ENFORCE AND MODIFY CONSENT JUDGMENT; CASE NO. RG-11-600721

DECLARATION OF JEFFREY SOULE, IN SUPPORT OF OPPOSITION TO MOTION TO ENFORCE AND MODIFY CONSENT JUDGMENT; CASE NO. RG-11-600721 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Attached hereto as Exhibit B is a true and correct copy of the registration details for N17738, which is publicly available at: https://registry.faa.gov/aircraftinquiry/Search/. N17738 is powered by a Continental Motors IO-520 piston engine. 12. I have performed inspections, services, and repairs to N17738 for approximately ten years. During this time, I have found the airplane to be mechanically sound. The GAMI STC SA01967WI on N17738 on November 2, 2024. 13. To the best of my knowledge, Mr. Lambert first purchased and filled N17738 with the GAMI G100UL avgas circa November 2024. Circa December 2024, he informed me that he experienced high exhaust gas temperatures (EGT) while in flight. 14. On an unknown date, I inspected N17738 and observed an injector to be clogged with a chunk of an unknown material, of unknown origin, in it. I also found the spark plugs to be covered in black soot. I subsequently cleaned the injector, removed the chunk, and cleaned it with the use of an ultrasonic injector cleaner; however, this did not remove all of the unknown deposits. I thus had to use a piece of safety wire to scrape the deposits off of the injector. Having to use a piece of safety wire to scrape deposits off of an injector is not a normal occurrence. 15. On an unknown date, Mr. Lambert informed me that he observed two engine cylinders did not function during a pre-flight engine run-up procedure. I again conducted an inspection of the engine and visually observed the Number 2 and Number 4 cylinder injectors to be totally clogged with an unidentified black deposit. I attempted to clean the injector with the use of the ultrasonic injector cleaner, but again this did not work and I was forced to physically scape deposits off of it. In my 27 years as an aircraft mechanic, I have never observed a deposit of this nature, and I am still unsure what this deposit is. 16. On February 11, 2025, Mr. Lambert asked me to again inspect N17738 after he discontinued a flight because of the manner in which the airplane performed. Upon inspection, I observed the spark plugs and the injectors were again covered with the same black deposit. Mr. Lambert was present and observed the maintenance performed on N17738. 17. Also on February 11, 2025, I visually observed that the wing cork gaskets, that seal the wing fuel tank access covers, appeared to leak a brown substance, which stained the wing EXHIBIT A United States Department of Transportation About DOT Our Activities Areas of Focus FAA REGISTRY N-Number Inquiry Results N-NUMBER ENTERED: 7942C AIRCRAFT DESCRIPTION Serial Number 32R-7680069 Status Valid Manufacturer Name PIPER Certificate Issue Date 05/26/2021 Model PA-32R-300 Expiration Date 05/31/2028 Type Aircraft Fixed Wing Single-Engine Type Engine Reciprocating Pending Number Change None Dealer No Date Change Authorized None Mode S Code (base 8 / Oct) 52544602 MFR Year 1975 Mode S Code (Base 16 / Hex) AAC982 Type Registration LLC Fractional Owner NO REGISTERED OWNER Name N4143W LLC Street 110 WORCESTER LOOP City LOS GATOS State CALIFORNIA County SANTA CLARA Zip Code 95030-6322 Country UNITED STATES AIRWORTHINESS 2/18/25, 3:40 PM Aircraft Inquiry https://registry.faa.gov/aircraftinquiry/Search/NNumberResult 1/5 INFORMATION PROVIDED HERE SHOULD NOT BE USED TO DETERMINE THE AIRWORTHINESS OF AN AIRCRAFT. Refer to 14 CFR Parts 39, 43, 91, and FAA Order 8130.2 for airworthiness regulations and guidance. Type Certificate Data Sheet None Type Certificate Holder None Engine Manufacturer LYCOMING Classification Standard Engine Model TI0-540 SER Category Normal A/W Date 12/15/1975 Exception Code No The information contained in this record should be the most current Airworthiness information available in the historical aircraft record. However, this data alone does not provide the basis for a determination regarding the airworthiness of an aircraft or the current aircraft configuration. For specific information, you may request a copy of the aircraft record at https://aircraft.faa.gov/e.gov/ND/ OTHER OWNER NAMES None TEMPORARY CERTIFICATES None FUEL MODIFICATIONS None DEREGISTERED AIRCRAFT Deregistered Aircraft 1 of 1 Aircraft Description Serial Number 382 Certificate Issue Date 11/16/1960 2/18/25, 3:40 PM Aircraft Inquiry https://registry.faa.gov/aircraftinquiry/Search/NNumberResult 2/5 Manufacturer Name DEHAVILLAND Mode S Code (base 8 / oct) 52544602 Model BEAVER DHC-2 Mode S Code (base 16 / hex) AAC982 Year Manufacturer None Cancel Date 12/17/1970 Reason For Cancellation Exported Export To CANADA Type Registration Corporation Aircraft Registration Prior to Deregistration Name WORLD WIDE HELICOPTERS INC Street 272 NAUGATUCK AVE City MILFORD State CONNECTICUT Zip Code 06460 County NEW HAVEN Country UNITED STATES Deregistered Airworthiness Engine Manufacturer None Classification Unknown 2/18/25, 3:40 PM Aircraft Inquiry https://registry.faa.gov/aircraftinquiry/Search/NNumberResult 3/5 Engine Model None Category None A/W Date None Exception Code No Deregistered Other Owner Names None The duration of aircraft registration certificates has been extended up to 7 years. The Registry will be issuing revised certificates in batches based on the former expiration date. For verification purposes, even though the expiration date on the registration certificate may not match the expiration date in the FAA Aircraft Registration database, any registration certificate displaying an expiration date of January 31, 2023 or later is still valid. This applies to all foreign Civil Aviation Authorities or anyone else with a verification need. You are accessing a U.S. Government authorized information system, which includes (1) this computer, (2) this computer network, (3) all computers connected to this network, (4) all devices and storage media attached to this network or to a computer on this network, and (5) all cloud services and hosting environments supporting this information system. This information system is provided for U.S. Government-authorized use only. Unauthorized or improper use of this system may result in disciplinary action, as well as civil and criminal penalties. By logging in and using this information system, you understand and consent to the following: You have no reasonable expectation of privacy regarding communications or data transiting or stored on this information system. At any time, and for any lawful Government purpose, communication between the user and this information system, data transiting to/from the system, or stored on this system is subject to monitoring, interception, and search. 2/18/25, 3:40 PM Aircraft Inquiry https://registry.faa.gov/aircraftinquiry/Search/NNumberResult 4/5 Any communications or data transiting or stored on this information system may be disclosed or used for any lawful Government purpose. 2/18/25, 3:40 PM Aircraft Inquiry https://registry.faa.gov/aircraftinquiry/Search/NNumberResult 5/5 EXHIBIT B United States Department of Transportation About DOT Our Activities Areas of Focus FAA REGISTRY N-Number Inquiry Results N-NUMBER ENTERED: 17738 AIRCRAFT DESCRIPTION Serial Number CE-702 Status Valid Manufacturer Name BEECH Certificate Issue Date 07/07/2015 Model F33A Expiration Date 07/31/2028 Type Aircraft Fixed Wing Single-Engine Type Engine Reciprocating Pending Number Change None Dealer No Date Change Authorized None Mode S Code (base 8 / Oct) 50233020 MFR Year 1977 Mode S Code (Base 16 / Hex) A13610 Type Registration Individual Fractional Owner NO REGISTERED OWNER Name LAMBERT MICHAEL C Street 6178 SPRINGER WAY City SAN JOSE State CALIFORNIA County SANTA CLARA Zip Code 95123-5133 Country UNITED STATES AIRWORTHINESS 2/18/25, 3:41 PM Aircraft Inquiry https://registry.faa.gov/aircraftinquiry/Search/NNumberResult 1/5 INFORMATION PROVIDED HERE SHOULD NOT BE USED TO DETERMINE THE AIRWORTHINESS OF AN AIRCRAFT. Refer to 14 CFR Parts 39, 43, 91, and FAA Order 8130.2 for airworthiness regulations and guidance. Type Certificate Data Sheet None Type Certificate Holder None Engine Manufacturer CONT MOTOR Classification Standard Engine Model IO 520 SERIES Category Utility A/W Date 02/14/1977 Exception Code No The information contained in this record should be the most current Airworthiness information available in the historical aircraft record. However, this data alone does not provide the basis for a determination regarding the airworthiness of an aircraft or the current aircraft configuration. For specific information, you may request a copy of the aircraft record at https://aircraft.faa.gov/e.gov/ND/ OTHER OWNER NAMES None TEMPORARY CERTIFICATES None FUEL MODIFICATIONS None DEREGISTERED AIRCRAFT Deregistered Aircraft 1 of 1 Aircraft Description Serial Number 4582 Certificate Issue Date 10/15/1937 2/18/25, 3:41 PM Aircraft Inquiry https://registry.faa.gov/aircraftinquiry/Search/NNumberResult 2/5 Manufacturer Name WACO Mode S Code (base 8 / oct) 50233020 Model ZGC-7 Mode S Code (base 16 / hex) A13610 Year Manufacturer 1937 Cancel Date 10/26/1937 Reason For Cancellation Cancelled Export To None Type Registration Corporation Aircraft Registration Prior to Deregistration Name E W WIGGINS AIRWAYS INC Street OP BOX 1089 City PROVIDENCE State RHODE ISLAND Zip Code 02907 County PROVIDENCE Country UNITED STATES Deregistered Airworthiness Engine Manufacturer None Classification Unknown 2/18/25, 3:41 PM Aircraft Inquiry https://registry.faa.gov/aircraftinquiry/Search/NNumberResult 3/5 Engine Model None Category None A/W Date None Exception Code No Deregistered Other Owner Names None The duration of aircraft registration certificates has been extended up to 7 years. The Registry will be issuing revised certificates in batches based on the former expiration date. For verification purposes, even though the expiration date on the registration certificate may not match the expiration date in the FAA Aircraft Registration database, any registration certificate displaying an expiration date of January 31, 2023 or later is still valid. This applies to all foreign Civil Aviation Authorities or anyone else with a verification need. You are accessing a U.S. Government authorized information system, which includes (1) this computer, (2) this computer network, (3) all computers connected to this network, (4) all devices and storage media attached to this network or to a computer on this network, and (5) all cloud services and hosting environments supporting this information system. This information system is provided for U.S. Government-authorized use only. Unauthorized or improper use of this system may result in disciplinary action, as well as civil and criminal penalties. By logging in and using this information system, you understand and consent to the following: You have no reasonable expectation of privacy regarding communications or data transiting or stored on this information system. At any time, and for any lawful Government purpose, communication between the user and this information system, data transiting to/from the system, or stored on this system is subject to monitoring, interception, and search. 2/18/25, 3:41 PM Aircraft Inquiry https://registry.faa.gov/aircraftinquiry/Search/NNumberResult 4/5 Any communications or data transiting or stored on this information system may be disclosed or used for any lawful Government purpose. 2/18/25, 3:41 PM Aircraft Inquiry https://registry.faa.gov/aircraftinquiry/Search/NNumberResult 5/5 EXHIBIT C Issue: Initial Page 1 of 2 Communiqué SE-P-006 Single-Engine Piston Communiqué Communiqué SE-P-006 December 19, 2024 ATA 28 – Use of Unleaded Fuels Not Yet Approved by Textron Aviation or Engine Manufacturers Affected Models: All Single Engine Cessna and Beechcraft models that utilize aviation gasoline. Textron Aviation has been working with FAA, fuel manufacturers and distributors, airports, and other Original Equipment Manufacturers for a number of years in an effort to identify, test and certify alternative fuels to replace leaded fuels in order to eliminate lead-based additives from aviation fuel. For example, Textron Aviation has previously approved UL91 and UL94 (manufactured under ASTM D7547) for use in certain Textron Aviation aircraft. As a part of these ongoing efforts, Textron Aviation has been actively involved in and providing technical and in-kind support to both the FAA Piston Engine Aviation Fuels Initiative (PAFI) and in the Eliminate Aviation Gasoline Lead Emissions (EAGLE) programs. Each of these programs seeks to provide comprehensive testing of candidate replacement fuels for engine performance, materials compatibility, and operational safety. Textron Aviation is aware that there are certain aviation fuels that have been granted Supplemental Type Certification (STC) for use in certain aircraft engines through the FAA in a process that is separate and apart from the PAFI and EAGLE programs. For example, the GAMI G100UL fuel received such an STC approval. Because the STC process, unlike the PAFI and EAGLE programs, does not involve broad aviation industry coalition participation, neither Textron Aviation nor its engine suppliers, Lycoming and Continental Motors, have had the opportunity to conduct the type of comprehensive and wide-ranging performance, compatibility and operational testing with respect to that fuel needed to provide a basis for approval of the fuel for use in Textron Aviation’s current and legacy fleet of Cessna and Beechcraft aircraft. Textron Aviation has been made aware that at least one other aircraft OEM has begun more comprehensive testing of GAMI G100UL in their airframes. Textron Aviation has also been made aware of reports indicating that two different OEMs have been advised of reported issues with fuel tank sealant degradation following exposure of those sealants to G100UL. These kinds of reported materials compatibility issues give rise to concerns about the continuing airworthiness of aircraft that may be operated on fuels that have not yet been comprehensively tested by Textron Aviation and/or by its engine suppliers. The continued airworthiness and operational safety of our products and their reliable service to our customers and their passengers is of paramount importance to Textron Aviation. For these reasons, Textron Aviation has not yet approved G100UL for use in its piston engine products. Such approval can only be made by Textron Aviation if the fuel is approved by its engine Issue: Initial Page 2 of 2 Communiqué SE-P-006 suppliers and has also undergone testing to confirm its airframe fuel systems performance, compatibility, and operational safety. Please refer to applicable Textron Aviation approved Owner’s Manuals, Pilot Operating Handbooks, Aircraft Flight Manuals, placards, and Service Bulletins SEB-28-04R1 or MEB-28- 01 (or later revisions) for a listing of fuels that are Textron Aviation approved for use in your aircraft.