Free Post Trial Brief - District Court of Federal Claims - federal

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UNITED STATES COURT OF FEDERAL CLAIMS

INNOVAIR AVIATION, LTD.,

Plaintiff,

UNITED STATES,

Defendant.

) ) ) ) ) ) ) ) )

Docket No.:

96-408C

Pages: Place: Date:

1 through 207 Washington, D.C. October 17, 2007

HERITAGE REPORTING CORPORATION Official Reporters 1220 L Street, N.W., Suite 600 Washington, D.C. 20005-4018 ¯ (202) 628-4888 [email protected]

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WILSON - DIRECT 1 2 3 4 Q Whitney since it came out. BY MR. COBB: Specifically, what engine is it that the

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converted DC-3 uses? A USAC. I got up to where we started talking to

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Q

In fact, let me just clarify that, or ask

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you to clarify it. You referred to USAC as a precursor to Basler. There was actually no corporate relationship between USAC and Basler. Is that correct? A Q Not at that time. So when you say "precursor," to what are you

referring? A Well, I'm referring to the fact that they

did the basic conversion with a Dash 45 engine. We had a Dash 67 generating a lot more horsepower. They were very short of money, and, in the final analysis, they got a supplemental-type certificate but for one aircraft only. They did not complete the documentation, the engineering, and the drawings that were necessary to get a multiple-type certificate, and the company basically collapsed. They had sold that one aircraft to an Alaskan operator. Heritage Reporting Corporation (202) 628-4888

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WILSON - DIRECT 1 2 3 4 there? A

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Yes. They were working on this conversion

of the regular DC-3 to a turbo DC-3 with PT-645 engines, and, as I mentioned, they finally did get a single-type, supplemental-type certificate for that

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aircraft. During that time -Q There was a restriction. When you say

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"single," without going into too much regulatory jargon, there is a significant restriction that applies there. Is that correct? A Right. Q A What is that? It may not be replicated. It can't be duplicated. Right? It cannot be, according to the FAA. So it can only apply to that single plane. You could fly that single plane. And what, if anything, did you do with USAC? That was the next project after LearFan.

Q
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Q
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Brian and I were familiar with that aircraft, the DC3, and I suggested to Brian that if this is a successful project, maybe we should become the distributors for Asia for the USAC product. So Brian visited them a number of times, I believe, and started to negotiate with them an Asian distributorship. Heritage Reporting Corporation (202) 628-4888

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WILSON - DIRECT 1 2 3 4 Q A How did that conclude?

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Well, it concluded with the company folding

its business because they were really underfinanced, and one of their engineers, Mr. Lillibridge, who was really the chief engineer, said he was going to move on elsewhere. So they got the single supplementaltype certificate. Q And what, if anything, did you do in

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response to their demise? A Well, the aircraft, as I mentioned earlier,

were sold to an Alaskan operator. It was a green plane, a "green plane" meaning it was basically an unfinished aircraft, and it needed to have the interior fitted, a quick-conversion, seats-to-cargo interior. It needed to be painted. It needed to be instrumented. So it was sent to Basler to be completed, and then I went to see it while it was at Basler, and I talked to Mr. Basler at that time. Q A Had you met him previously? No. Had you ever heard of him before? My research, through my magazines, indicated that he was an operator of DC-3's in the United States.

Q

Q

Did he do DC-3 conversions or make DC-3 kits Heritage Reporting Corporation (202) 628-4888

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WILSON - CROSS 1 2

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them first, and get the electronics later. So we'll stand in recess until 3:15. MR. COBB: Thank you, Your Honor. THE CLERK: All rise. (Whereupon, a short recess was taken.) THE CLERK: Al! rise. The United States Court of Federal Claims is now in session, the Honorable Loren A. Smith presiding. THE COURT: MR. COBB: THE COURT: Please be seated. Thank you, Your Honor. Okay, Mr. Wilson, do you want to

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return to .the bench? Of course, you're still under oath, and we'll allow the Government to cross examine. MS. FLOYD: Thank you. CROSS-EXAMINATION BY MS. FLOYD: Q A Q Good afternoon, Mr. Wilson. Good afternoon, Ms. Floyd. I wasn't clear in your direct testimony

whether you have ever had an interest in Innovair Aviation, Limited? A I was a shareholder in BTC, and my brother

was a shareholder in Innovair. So we always called it the Wilson/Carmichael combination. Q Okay, so were you ever a Director of

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WILSON - CROSS 1 2 Innovair? A No, I was a Director of BTC. Have you ever spearheaded a start-up

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Q
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corporation? Yes, I have. And what was that? The kind of things that I've spearheaded,

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Q
A

for example, have been Medtronics' idea to build the world's most modern manufacturing facility for making pacemakers and implantable electronically programmable devices in Switzerland, where I negotiated with the ¯ Swiss Government the tax arrangements for the company. I was the first employee in the company. Then I assembled a team of manufacturing people, design engineers, builders, and built that company to what it is today, with a company of about 800 people in Switzerland, exporting about a billion and a half dollars of products per annum. Q Have you ever headed a small business? I have worked for major corporations all my life.

Q
A Q

Prior to your involvement with the BTC

Innovair Program, did you ever sell an airplane? I did not. Did you make a decision that this BT-67

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some work for the Red Cross. He had aircraft in Mozambique, and he was also an aviation broker. Q And there's a reference in that first

paragraph to the Dornea. A Q the BT-67? A Q A No. Why is that? It was a fairly small and relatively Yes. Did you view the Dornea as a competitor of

expensive aircraft, and it was not widely available. Q Did you ask him why he was having trouble

selling the Dornea to Zimbabwe Air Force? A Q No. Further on down the page in the third

paragraph, it references an inquiry into the developments with AMI. Can you identify who AMI is? A Yes, AMI was a company in Waco, Texas, that

had -- I'm trying to get this right -- that was manufacturing turbo DC-3, and the license had gone to South Africa during the sanction years when the U.S. was not able to sell aircraft down to South Africa. Somehow, the license got down to South Africa, and they had converted a number of planes in the South African Air Force. Heritage Reporting Corporation (202) 628-4888

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WILSON - CROSS 1 2 3 4 5 6 7 8 9 I0 II 12 13 14 15 16 17 Q

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So was AMI a competitor of BTC and Innovair

in terms of the conversion? A It had not been seen, Ms. Lloyd, anywhere

out of South Africa. The license seems to have been exclusively to convert the aircraft in South Africa with a PT 6. I don't remember if it was a 45 or a 65. It was quite a different aircraft from ours. I could talk about that, if you'd like, and it was only in South Africa. Q So they never competed with Basler turbo

conversions or Innovair in any other territory? A Q Not during this timeframe. Did they compete at any other time with

Basler turbo conversions and Innovair? A They, I think, attempted to get the company

going, but did not get the company going in the U.S. to manufacture U.S. aircraft for U.S. sales and international sales. These are only the South African ones, and some of them after the war in South Africa ended and independence was achieved, have drifted back to t~e U.S., and some of them are floating around here in the U.S. market. Q How many converted DC-3s did AMI

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manufacture? A I'm not sure. But I understand it was Heritage Reporting Corporation (202) 628-4888

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something in the region of a dozen to 15 in South Africa. Q Exhibit 8. correct? A Q Correct. I'd like to have you turn to page 2 of Joint I'd like to have you turn to Tab 5 of Joint This is a document that you prepared,

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Exhibit 8, and read under the item that says, "Report." It says, "After the Bankruptcy of Air Queensland, the DC-3s lay dormant for six months." Do you know why Air Queensland went bankrupt? A Q No. Further on down the page, it says -- and

we're again at JX-8, page 2, it says, "The new company is slowly rebuilding their business, and the aircraft are operating about 20 hours a month." Is 20 hours a month a significant amount of air operation time for a cargo plane, cargo entity? A For one aircraft, it would be a reasonable

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amount of time. Q A How many DC-3s were there in Queensland? He advised me that it had five in CANZ,

which I'm not sure if it's in Queensland or the Northern Territory, but it's near Queensland, and two were in the Sydney area. Heritage Reporting Corporation (202) 628-4888

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WILSON - CROSS 1 2 3 4 5 6 7 8 9 i0 ii 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q the tab. (Laughter.) THE COURT: Thank you. BY MS. FLOYD: one. MS. FLOYD : page 4. THE COURT: again, the tab? MS. FLOYD: THE COURT: MS. FLOYD: THE COURT: Sorry, what was the exhibit Q

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So with seven aircraft, DC-3s, would 20

hours a month be a high volume business? A It would not be high volume business. Okay, I'd like to have you turn to JX-8,

The same exhibit, Your Honor. Which one? JX-8, page 4. Okay, we're just on the same

Fortunately, I didn't move off

I'd like to have you direct ybur attention

to the top paragraph. It says, and I'm going to read it into the record, "Thinks Australian CAA approval will be tough; refer to problems experienced by Parker and Haviland in certifying Beach 1900 Commodore." A Q A Excuse me, it's Harker Dehaviland. Sorry. It's one brand name.

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WILSON - CROSS 1 2 3 4 Q Thank you for your correction. Can you

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identify what the CAA is? A Australia. Q And what does the Civil Aviation Authority It's the Civil Aviation Authority of

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in Australia do? A It has a similar role to the FAA in

approving and certifying aircraft that are to be operated in its country. Q So if you were to sell DC-3s in Australia,

this suggests that you would had to have CAA approval. Is that correct?. A Q That is correct. Did you obtain that kind of an approva! for

any DC-3 sales in Australia? A No, we didn't. But on the other hand, we

never had the opportunity after the seizure. Q Australia? A From the time before the STC, up until the How !ong did you try to sell planes in

time of the seizer, we had had contacts with them. But we were focused on the STC to begin with, and financing there afterwards. We thought it would be a very good market. Q Well, does Joint Exhibit 8 reference an Heritage Reporting Corporation (202) 628-4888

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WILSON - CROSS

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A

And if this Canadian plane -- and the Dash-8

is a Canadian plane as well -- had been partially financed or fully financed by the Canadians, could we get financing from Pratt & Whitney of Canada for the engine portion of what we would be selling to them, to defray the cash expense or the foreign exchange that Kenya needed to buy an aircraft such as the Turbo-3? Q in Kenya? A We were not. For what period of time did you market in Were you suocessful at selling any airplanes

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Q
Kenya? A

We continued to market there. I can't

recall if Cliff made another trip down there. Cliff did die some time after 1989. I don't exactly remember when he had cancer, and he died a few years later. I don't remember when. So when he died, did you stop marketing in

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Kenya? A

We did not have a direct sales agent in

Kenya at that time. But we were still looking for that opportunity, and after 1991, we did not feel we had the right to be able to be offering this product anywhere.

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Q

But if you'll note the first page of JX-7, Heritage Reporting Corporation (202-) 628-4888

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the date of that is what? A Q February the 17th to the 22nd of 1989. So you started marketing in Kenya as early

as February of 1989, correct? A Q Correct. And you didn't make any sales as of July of

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1991. Is that correct? A Q Correct. Referring back to page 2 of Joint Exhibit 7,

it references at the bottom of the paragraph, it says, "Wilson a'nd CB." Is that referring to yourself and to Mr. Burnett? A Q I believe so. And it says you were looking for added

contacts, both Zaire and Chad. Did you try to market in Zaire and Chad, as well? A I remember some contacts for Chad. I don't

remember for the detail, but not for Zaire. Q Further on in that sentence, it says both

are recipients of U.S. military aid. A Q Yes. If a plane had been purchased by Chad or

Zaire with U.S. military aid, would that have been considered to be an Innovair sale or a Basler turbo conversion sale? Heritage Reporting Corporation (202) 628-4888

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course, Zimbabwe did not pay for this with cash. They paid for it with promissory notes to sell things to China in reverse. Q However, it indicated that it was a billion

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dollars worth of aircraft. How many aircraft would that be for MIG-29s? A Q I don't know. So did you conclude from this that there was

no market for the BT-67s, as a result of this sale? A Q A Absolutely not. And why not? Because there was the civilian operations --

there was that operator in Zimbabwe that was working in Mozambique. To be honest, the Air Force did not like the thought of having MIG-29s at all. They wanted Western aircraft, all right? But this is what Zimbabwe could afford at this time. Q Force. A time. We did not make sales in Zimbabwe at that But you'll notice that this was not long before So you made no sales in Zimbabwe to the Air

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the seizure. Q A Q In January of 1991? Right. And when did you start marketing in

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WILSON - CROSS 1 2 Zimbabwe? A was 1989.

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The first time I made that trip, I think it

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Q

Okay, I'd like to have you turn to Tab 14,

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which is PX-191. Bear with me just a minute. THE COURT: MS. FLOYD: THE COURT: MS. FLOYD: THE COURT: MS. FLOYD: couldn't find it. BY MS. FLOYD: Q Now, Lonrho PLC, who was this person again? I'm trying to recall who he exactly was within the Lonrho organization. But, I mentioned earlier that Lonrho was a company that had been run by Tiny Rowland and was a company with a very strong business in Africa and with distributorships for many different types of businesses, including aircraft, automobiles. He was trading in minerals as well, back and forth. It's a°public company in London. Q Were you seeking an investment from Lonrho What was that tab again? Tab 14. Fourteen, I'm sorry? Yes, Tab 14. PX-767 PX-76, I'm sorry. That's why I

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to assist Basler Turbo Conversions or Innovair? A I don't think so. I think I was looking for Heritage Reporting Corporation (202) 628-4888

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WILSON - CROSS 1 2 3 4 reference to Freddy Laker. A Q Yes.

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Did you, in fact, get an introduction to

Freddy Laker? A Q I did not. And I'd like to have you turn to Defendant's

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Exhibit 38, which I think I, also, need to provide to
yOU ¯

(The document referred to was marked for identification as Defendant's Exhibit No. 38.) (Discussion off the record.) THE COURT: Sharon, can you see if -- talk to the builder and get the air turned back on? It seems they've turned it off somehow. It's getting hot again. MR. COBB: THE COURT: Thank you, Your Honor. Maybe, by turning off that

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computer, we turned off the air. With these new systems, it's hard to tell. MS. FLOYD: We're looking at Defendant's Exhibit 38. Has everybody found a copy? Defendant's Exhibit 38 is a memorandum from Jim Eckes to yourself, Mr. Wilson. And did Mr. Eckes regularly provide you with updates about his trips and investigations into Heritage Reporting Corporation (202) 628-4888

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possible Basler Turbo Conversions sales? A Yes. He was not an agent 6f ours and we did

not pay him anything. But, he was a very interested party. And as you can see in here, he had proposed that he become, let's say, general agent overseeing all activities or maintaining contact and market research for a commission. We did not appoint him as a commissioned agent in Asia. Q But in answer to my question, he regularly

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sent you reports such as this one, is that correct? A He maintained regular contact with me, let's

put it that way. Q And did he send you reports on the Indo-

Suisse letterhead? A He did. Did you keep those documents in the Innovair records? A at today. MS. FLOYD: Okay. I'd like to move Defendant's Exhibit 38 into evidence, please. MR. COBB: We welcome it, Your Honor. THE COURT: Okay. It will be admitted. Yes, and some of them we've already looked

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THE COURT: 6 7 8 9 i0 II 12 13 14 15 16 17 agent?

(The document referred to, previously identified as Defendant's Exhibit No. 38, was received in evidence.) He never became a commissioned

THE WITNESS: He never became an agent. He was introduced to us by Mr. McDonalds and he's an aviation expert. He maintained contact and tried to find ways to introduce us to business and to become an agent. We never appointed him as an agent. THE COURT: Did he ever bring business to you? Did he ever bring -THE WITNESS: He had a tremendous number of ideas, right, that we tried to follow-up on. THE COURT: Okay. BY MS. FLOYD: Q Okay. Looking at the map that's on the

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easel over there, that's Exhibit No. 308, if he is not an agent, why is Mr. Eckes portrayed as being a representative of Innovair on this map? A None of us got any commission for the

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marketing that we were doing. He had great influence there. And, in fact, I think if he had actually brought us business, we would have been obliged to

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WILSON - CROSS 1 2 3 4 recognize his contribution. Q

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But, you never had an agreement with him; is

that correct? A We did not have an agreement with him, no. THE COURT: Is he the green -THE WITNESS: He is the red co!or, right. So, you see him in Indonesia, Pakistan, and I believe it's in Taiwan as well. And he had some contacts in China. He introduced us to people in China. BY MS. FLOYD: Q I'd like to have you turn to page two of

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Defendant's Exhibit 38 and !ook at the second full paragraph that begins 'however.' It says, 'however, there is great need to coordinate activities in Asia and to get maximum value from the Pratt-Whitney demo aircraft as well as to select people in Asia who have the ability to market the Turbo DC-3 in their countries. There are some problems to overcome, such as the perception in Asia that the airframe is very old.' Did you have difficulty in convincing potential buyers in Asia to purchase the DC-3, because the airframe was very "old? A When people saw the converted aircraft that

went out to Asia, it created a great deal of excitement. We did not get objections from people, Heritage Reporting Corporation (202) 628-4888

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WILSON - CROSS 1 2 3 4 A repeated. I can't answer it, if I don't have it

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Q

Okay. I'd like to have you turn to the

paragraph further on down the page. It says, 'however, to undertake this type of work without any financial support, I would need extensive assistance from Basler descriptive and extensive sales literature, the availability o~ demo aircraft, technical people to come to Asia on a regular basis, a key person in the home office, who would answer all memo, et cetera, and work for me, and the normal backup support and decisionmaking are all required to market an aircraft of this type.' Did you provide that kind of backup support for Mr. Eckes? A No, we did not, because we did not appoint

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him an agent. Q A Did you appoint anybody else an agent? I didn't appoint in Asia anybody else as the

agent, except UTC, which had the whole Pacific Basin as their exclusive territory after we signed the arrangement with them. Q agreement? A Q That is correct. And the date of that was July 25, 1991; is You're talking about the distributor

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WILSON - CROSS of people in this industry, who have had great 2 projects for the conversion or manufacture of aircraft, who have come to Asia to market these

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aircraft and then have failed. Memories out here are long and we must show everyone that we intend to be here for many years.' And what efforts did you make in that regard? A Well, we did not appoint Jim and there was a

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nice fishing trip for him, to get us to appoint him a commissioned agent for two percent. But, I think that we answered the question, getting an outstanding distributor for the long-term, when we appointed UTC in 1991. There isn't a finer company in the aviation business or not many that are finer than that. And they had the exclusive territory for Asia-Pacific, plus an order with us for 35 aircraft manufactured in Taiwan. Q I'd like to have you turn to Tab 7, please,

and that's back in the black binder that was -A Q My binder or your binder? It was in the black binder that was

presented to you by Innovair's counsel. A Okay. THE COURT: What was the tab number again? MS. FLOYD: It's Tab No. 7, but it's Joint Heritage Reporting Corporation (202) 628-4888

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MS. FLOYD: Right, and I'm reading 'Bob Dodd,' first paragraph -- third paragraph. MR. COBB: THE COURT: MS. FLOYD: Third paragraph. Third paragraph. Do you see that now?

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THE COURT: Or Mr. Cobb go up and check the documents. (Discussion off the record.) BY MS. FLOYD: Q yet? A Q I have. Sorry about the delay. And, again, we're back to Joint Exhibit 15, Okay. Have you had a chance to look" at it

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'Bob Dodd felt that it would be much better to convert the aircraft in the U.S. There's a great shortage of technical staff in Zimbabwe;' is that correct? Is that what -- did you have any conversations with Mr. Dodd about this problem with shortage of technical staff in Zimbabwe? A Yes. Mr. Dodd was the acting general

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manager of an airfreight airline that had good capabilities in Zimbabwe. And around about that time, there were many political problems in Zimbabwe and people were beginning to immigrate out of the country. So, there was -- he was still running an operation Heritage Reporting Corporation (202) 628-4888

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