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lnnovair Aviation, Ltd. v. United States Case No. 96-408C Exhibit 191
A0822
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INNOVAIR AVIATION LIMITED
Fax No. 44-71-606-2285 Mr. I.W. Therkelsen Lonrho Plc Cheapside House 138 Cheapside London I0 June 1990 Your Ref : IWT/JW
Dear fan,
I hope the additional information provided in our conversation last week was helpful. As soon as the business plan with attendant financial data is available I will courier a set to you. I should stress that equity participation is of key inuerest to move the program forward with speed and appropriate financial strength. We could guarantee Lonrho majority control if required. In the meantime, I am enclosing features from Aviation International News, Business and Commercial Aviation and Air Transport World on the Turbo-67 program. Finally, may I ask that you provide an introduction to Freddie Laker. We discussed his possible involvement in the program. If he lives in the States perhaps we could ask him for his assesment? Many thanks. Sincerely, C000731 Barry W. Wilson
45 Dunin Lmne Sk~llman. N.J. 08558 Tel. (609) 466-2439 Fax (609) 734.9018
USA 7405 Ha~'enr~ursl Pla~;e Van Nuy~. CA 91406 7el. (818) 782-8856 Fax (818) 782-9733
Inlemational 918 ChlP, a Hong Kong Cily Tower III Ts~msnatsui. Kowloon Hong Kong
A0823
Case 1:96-cv-00408-LAS
Document 158-25
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~'.y 1. 1990
An ar#st'~ mndenng of Cessna's "[.ta#ed, W~lli~rns/RolL~.Royce FJ44.powerad C~a~onJef shows ~ aircraft's C~labOn lamity resemblance. With ~t=t flight of tim proto~jpe sef tot May 1991. the company i~ k)gging oro~r~ tor the now $2.4gf-milhon Iwm a! rne ram of five or six per month.
CitationJet, FJ44 engine tests to begin this month
b.V Tom ~n~n$on Development of the CimdonJ~t, Ce~sna's new WLIIiam~/Rolls-Royc¢ FJ44-powered ~jet ~odu~ at the Nadon~ Busin~ ~r~fi ~sodadon Conv~fion in At~, Ga., b onfining apa=. ~ough ~e pr~ to~e b not due to fly umi] n~ May, one of ~e o~ Ci~ion 5~ ~t t~t ~r~ft, Nf01CC, h= ~ fitted ~ ~ FJ~ on its left side ~d is =x~ed to ~gin ~ght testing the Chine ~ly thi~ month. ~ ~gh~ of the aau~ Citatio~et en~n~g protot~ begin ne~ May, ~g qu~ti~ (including yound h~dHng), ~ound ~b~tion. s~bi~ty ~d ~nwol, s~ds ~d ch~a~¢~stics, Right ch=a=~=, ~d ~ne water mg¢~ion. A second ~r~aft, d~ ~ a "prepro" ["pro," for pr~umion]. "~ll ~so be built in the ~n~dng ex~nment~ ~. u~k¢ ~ Clarion V, wh=e we were able to ~e a Ci~on I! ~d ~pt at, ~=e ~ no~g =i~l~ to the Ciu~onJ~ on the ~ne so the proto~ ~B ~ve to ~ b~l from ~p~ ~ H~phrey, C~sna's dir¢~or of pubic ~ "pr~ro," scheduled to make i~ first ~t in Nov~ !~1, ~U ~ ~ for f~cfion ~d re~abi~gy checks, autopilot develop
don V, we'd ~ventuaJly sel] the prepro air-
craft," Humphrey said. Ce~na i~ a.~embling a spedal te,~m ~mp~ of ~r=~mdv~ from produa ~g, ~~g cn~g, pr~u~ sup~n, ~d ~ compl~io~ ccnt¢r to condue s~l~ous ¢~n¢¢ring work on t~w=iBht ~d deign for m~nt~n=bi]ity con~p~ ~d ~o~," Pr¢5~ p¢rfo~ sp¢~ for th¢ T~, t~ Ci=do~= =~ for = m~ ~s¢ s~d, = ~ ~ng= ~th four
3,070 Ib of usabi¢ fu=L ~ effid¢nW ~d ~fo~ promis¢d for the CitationJet resuh from the combina. don of ~ FJ~ ~ ~d a natu~ ~ow ~L~ ~g ~at C~ma ~ms k the first on a co.orate jet. "~e primaw of the ]~n~-flow ~rfoil is reduced d~g w~ch tr~dates ~to an additional 10 to knou ~e ~p~ ~th the same av~lable thrust," C~s~ said. Although si~l~ in size to the Citation ~ Ci~do~et b ~ to ~= 30 kt later with ne~ly 14 ~r~t less thrust. In t~s of rang~, the ~nefi~ of th~ NLV wing plus the improved spedfic fuel onmmption of th~
C000732
A0824
Case 1:96-cv-00408-LAS
Document 158-25
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Page 4 of 44
Midland Park, N J, May 1, 19~4)
Aviation |ntem#tlonal Nr~s
Basler gets DC-3 t-prop production permission
overhead cockpit hatch is replaced with a tinted skylight. The PT6A-6"/Rs allow the Bailer DC-3 a Following award of FAA supplemm~a] type codification in February, Baster Turbine Con- 13,000-ft singic-cngine ceiling at gross weight vcrsiom has begun production modification and 23,000.ft maximum altitude with both and turbine re-engining of Doushs DC-3s a~ "~nes o~ (airline-type professional oxits O~hkosh, Wig. facility. The company, an YE~ syst=~ for the non-pressurized transport offspring ofDC-3 op~ator Ba~ler Airlln= and are available as an option). Cruise sp~d has Flight Service, is ac'.Jveiy marketing the mod- been increased ~o 205 la. With standard fuel, two 200-gal tanks in each wins, the turbine emotion oF the 55-year-old transport desig~ to co~ercia] operators and govcrn]ncnts DC-3's IFR range is around 1,000 nmL For operators desiring more range, however, throughout the world and a~ press time hm:l Basler c~ install two more 200-gai tanks in sold six of the ~7..9-million pscksge~, The conversion includes r~lac~mmt of the the outboard sections of each wins, effectiveDC-2's original radial piston ~ngines {mo~ ly doublin~ fuel capacity and, thus, range. For opt'ames brin~in~ their own a~rframes commoniy the t,200-hp Pratt and Whimey R1830) with Pran and Whimey of Canada w the company, Ba.rdcr sells the basic converPT6A-87R turboprops, each rated at 1,424 sion for $2..9 million, h also markets converted shp. In the Ba.der installation, however, the DC-2s for $3 million, not including options. engines are flat.rated at 1,281 thp (up to Its customers include Air Colombia, which will 99-deg F at sea level) or 1,220 shp for max- rec~v~ the first modified DC-2 in June; the imum continuous op~'ation (to llg-deg F). U.S. Air Force Miliu~y A.ssistanc= Command, The engines a~ equipped with five-bladed which has purchased two aircraft on behalf of the El Salvadoran government; and PZL of l-lar.zell propell~rs. The gas turbines, which w~igh less than the Poland, which has ordered thr~ of the planes DC-3's piston pow--r~lants, yield a claimed to support a fl~'q of agricu]turai aircraft based 13,000-lb useful load in the modified airplane, in Africa. Three more converted DC-3s will or about a 5,000-1b increa.~, even though the b¢ prepared for Be.sler Airlines to service a airplane's gross w~ight has be~n boosted only Federal E..-'press contract, and the U.S. Army will l~ase a turbine DC-3 this year for 1.850 Ib to 2~,750 lb. But Bailer doesn't stop there. According to ~va]uation. In April, 12 DC-3 s.irfram~s were undergothe firm's president and founder, Warren Bat=, the ~nv~smn r,~res~nts almost a total ing convarsion at Bailer's new "/~,~:X)-sq-f| remanufac~ure of the original airplane. The production faci]hy at Oshkosh's Wittman airframe is su'ipped and inspectS, outboard Field. Basler czn provide kits for field conversion sections of the wings are reinforced, and the fuselage strmched six f~t ahead of the wins of DC-]s; however, the only locations outside In coml~--nsate for the lighter PT6A engines Wisconsin that the company is currently conwithout bailasting the nose. A by.produ= of fidering for the modification proj¢cl are in the fuselage r.xt~nsion is a $5-1~rc~n~t increa.se Poland and Taiwan. "This is mor~ than just a r~sofit," Baslcr said. "A typical conversion in cabin volume. Other improv~m~mt include ¯ moderuiz~- is vary involved, requiring upwards of ~.500 ~on of the DC-:~ ocker with n~w innnun~nts, individual pans. Consequently, we're very avionics, and switches. AJJ instruments ~re in- careful whom we lic~ns= it to. We're impressed ternally illuminated and s~qtch panels are with PZL's operation, for example, and th~,ll backIit. The aircraft is eqmpped with an el~- cventuaily bc doing their own conversions in tricai]y h~ated wmdshidd and the leaky Poland with our kits."
C00073.3
A0825
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Document 158-25
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Page 5 of 44
W.SS. T~ Ch~ 12 million p&.~.~'lge~ in "89, down a~lt 17-/,. Target/or thi~ 13.5 rr~l~n
Latin America report
l'rlnlbrllll I~l VASP hav~
7h~ ffrst 747, a ~ s~:mff, lm b~n ml~d. lU~ mt~'~n~ lmme t= U~ Museum of
pone ~o V~ and 11~ s~.~r ~rBra~l~ ,..;r4z.ansport ind'u~'y,
S~e Br~l I~ a nmv Pm~ ajr.u'ansport body (DA~) appem VASP aped for righl~ into route a,ophcabon by T~I for Mmmi. Eax::h of these c~rne~ ~ ~o, ~ile V~P ~
5% retained by tt~e govemme~ of required to make a down paymerit of at least Z:220 million. The
Equipment
Cargo
$74~ mflSon.
Africa/Middle East report
~rlcan ~Mdlne~ convnrted ~ ol:~ons o~ the MD-11 to fi~ ~e~, F~ del~ ~ ~ul~ ~ ~le ~mlr ~ ~p~ ~e ~~ of ~ a~m~ FoYer 1~ ~ ~ M~81~. ~ ~ of d~r~m ~ ~ ~ f~ ~ of ~
~7-~, 19 spare engines ~ BRNF Uquida~g DHL Al~zy= order~ =x 727~ ~m ~R Rna~ ~. dun~ W A~, page ~, ~ ~en~~ ~r Eum~ Cha=~ G~m~ ~ Manag,~ D~r~ R~ L~ were trans~.
Bot~warm will take over most of mr spac~ m "91, w~t an area corttroI center k~Jted m Gab~m:~e. It w~ll ta~e over horn control center in
A~m~ru ha~ ~g~ed a coopem.
C000734
~v~O ki' Trenszx~ Wc~d 11
A0826
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Document 158-25
Filed 03/03/2008
Page 6 of 44
AmPLANES
USED TURBOJET/TURBOFAN
C~at)on ,S/II CEOS.550 S3.808.023 (198~) S~N 147-1.59 ~3.7.50.395 Falco~ 10 AD MY-1D $3.2OO.0O0 (1980) S/N 171-181 Falcon 100 DA-100 $4.700,000 (1989) ~N'A $,4.700.000
2 P&W JT1SD-4B 2-500 Ibm. ea. 3,0(X) 2+7/9
AR TFE'731-2-1C 3.230 Ibs. 2+7FJ 18.740 11.200 7.540 5.910 18.740 12.013 6,727 5,912 28.660 17,613 11,047 9,170 0.86 370 N~A 6~ 0.870 367 202 8.8 0.87 387 191 8.3 4.54 1.170 410 WA N/A N,'A N~A WA N/A N/A N~A N,/A 1,~1~ 415 0.3~ '1.965 409 WA 1.7~5" 374 02.I 1.530 4:01 0.34 1.5S4 406 N/A
FAR 25.197884
FAR 25,
GTEC "r'FE 7312.1C
, 431 1.0~0 410 410 1,6~5 3~)
FAR 25, 19~9"73
Falcon 20 AD MY-20F $8.1B&790 (19~4) ,S/N 464-483 $4~--00.000 Falcon 200 DA-200 $8,000.000' (1988) 3~,l N/A S7.450.000
Lear/el LR-25D ~N?..375.000 (1986)" S/N 365-367 $2.414.000 Lear]el LR-25G $2.625.000 | 1986)" S~N 370-372 $2,714.000 Gu~lsZream Ill G-1159A $15.000.000 # 1986) SxN 485-491 $16.000.000 D~amo~ IA MU-300 $2.957.500 (1985) S/N A076-AlY31 $1,950.000 Dlamor~ II MU-300-10 $3.175.0(X) |1985) StN AI001-A1008 $2.400.000 Weslwm~l 1 IA-1124 $3.595.000 (1987| ~ 429-up $2.50O.OOO
2 GE CFT00-2D2 4,500 Ibs. 3.000 2 + 9110
N/A N/A
CAR 4b, 1970 ¯ Seats tug.
2 GTEC AFT-6A-4C 5.200 Ibs. ea. OC 2 ÷8~10 2 GE CJ610-8A 2.900 Ibs. eL 5.000 2 ~" 7:10 2 GE CJ~10-~A 2.950 Ibs. ~. 5.000 2 - 7/I0
2 RR .S~ey MK511-8 11,40Q IbS. eL 2 ÷ 14119 2 P&W JTtSD-4D 2`500 las 3.000 2 .~ 7~9 2 P&W J'f150,-5 2-9
32.000 18.512 3.988 10.584
15,5~0 ~591 6.909 &5~4 16.800 8.~16 7.984 6.594 70.200 37.800 :~..400 2&300 '14.7'00 9 640 $.060 4.26O 15 .B.,,~ 9 rZ5 S.g2S 4.904 Z3.000 13.000 10.0(X) 8,7~0
0.864 378 209 8.3
0,81 354] 200 94 0.81 350 200 94 0.1LS0 340 2:20 9.5 0 785 320 200 91 0.7B5 320 200 9.1 0.765 360 250 9.0
429 1,484 410
437 1.459 410 437 1,230 410 458 2.935 450 422 1.156 350 446 1.296 370 424 1.320 410
460 1.914 370
448 1,.5"71 410 48~ 1.600 410 488 4.016 390 EUA N/A N~A NIA WA WA 436 1.489 390
2-633" 408 0.26
1.437 411 O.2~ 1.799 422 0.31 4,119 437 0.15 1.262" 377 0.39 1.593" 376 0.39 2.350" 390 0.30
N~A
1,014 411 0.26 1.343 415 0.28 3,728 437 0.15 WA N/A N~A N;A WA N/A 2.550 392 0.31
CAR 4b, 1982 ¯ Four I:~tssengers.
FAR 25. 19~ 75 *B.'CA e~t~to.
FAR 25. 196~83 "B,'CA estimate.
FAR 25, 1967.'79 "R'CA i~stlmale.
FAR 9'5. 1981/85 "Seats lufl.
2GTEC TFE'/3; .3-1G 3.71;X) I=s. OC 2'* 7710 2 GTEC TFL~I-~-1G 3.700 I:=. eL OC 2 + 7110 2 AR TFE'/31-3RoID 3,7{X) ~. ~a 2 .~ 8/NA
CAR 4B~FAR 25. 196,4/B0 "Ex~cupve payload. CAR 41>'FAR 25, 1964,'80
Westw~nd 2 IA-II24A $.4.342.OOO (19~8)
2:).&~O 13.250 10,4~0 9.540
24,000 14.100 9.900 8.58~
0.80 ¯ 365 250 g.o
O.B3 350 N/A B.8
424 1.252 410
4.41 1.2:23 410
436 1,408 ~
WA WA WA
2.535" 396 0..31
2,734 407 0.34
2.675 397 0.32
2.407 407 0.34
Sabrehner NA-265-65 $5,100,000 (1982) 465-50--465-76 $3,100.0~0
CAR 4B, 1958
C000735
BUS,heSS & Commerciol hwo1~onl Moy I~;~) 9~
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Document 158-25
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Page 7 of 44
MODIFICATIONS_
Whether general aviation airm-aR production levels are at ebb or flow in the United States. there is one facet of the community that seems to continue to progress inexorably along its own course--the modification business. This entrepreneurial line of tivity, while not necessarily peculiar to aviation, is most visible here probably because the field of aeronautics is
so closely regulated. Individual principals in modification work come and go, but in our ongoing efforts to determine who is offering whet servic~ to enhance the appearance, comfort and perform~ce of private ~ we h~_ve ./'o...u~. d.a certain degree of national stability m the magnitude of ~ act~vRy. Like an amoeba, the modification industr~
may ~ake different forms as it fills shifting needs and niches, without appreciably varying in its overall This year, for example, our listin~ contains seven companies that are in cluded for the first time (although. s~me, like Valpar, have been well known for engineering and redesign c~ntributions for decades). On the other hand, six companies have been d~p~_p~,, from our listing bemuse, the~ couldn t be reached, or they've shifle~ the directi'on of their services, or ~ause they ihdicated that their modification programs have been sos. pendecL It also should be noted the! some companies among the long-tim. ere have added to their list of offered In contacting providers o[ medification senrices, B/CA learned that two factors are expected to impact heavily on anticipated business volume dur. Lug the next twelve months. First, exert or high-quality used aircraft over the past few years (a result decreased new-unit production} caused the market value of equipment to appreciate subst ly. Some authorities place that, as much as 20 percent across board in the past year alone. Man~ modification specialists therefore be lieve that aircraft owners will loom more carefully at enhancing the ap pearance and capability of thei; existing machines as opposed to trad. ing up. Conversely, some service provides believe that growing preoccupatior with the issue oi" aging aircraft cook serve to depress their business activi ty. Where complete teardowns am more thorough inspection for corrosion, fatigue and other agin| phenomena are required, increase costs for services will result, they con. tend. Some noted, too, that fewer new modifications will be certifiable be cause ofthe increasing restrictivene~ of interpretation of STC criteria b] FAA inspectors. By and large, however, the modi~ cation business appe~ to be health~ and capable of capitalizing on techni ca] advancements for as long as air cr~t owners continue to yearn forju~ a little more performance, venience or comfort from t
Basl*r Turbo Convsrsion's Turbo-67R is a sl~tched v~r~a~ of the Do~la$ D¢;-3 that has b@en mnglne, d with Pratl & Whitney FTbA-67R turboprops.
Sabrsilner Corp~rt~tton offers 30,0OG- and 40,000-ho~r IIf~ sxt~nsion progroms for its Sabr~ 40, 60 and 75A a|rcrcfll.
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Innovair Aviation, Ltd. v. United States Case No. 96-408C Exhibit 212
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GLOBAL AIRFINANCE GROUP October 1& 1991
Mr. Fred B. Johnsbn Manager Commercial Offset ProgTams United Technologies Pratt & Whitney 400 Main Street East Hartford, Connecticut 06108
Dear Fred:
In accordancx: with our telephone conversation, I cnclo~c the following; 1. A draft statement of principles with regard to the relationship between Pratt & Whimey and Global A.irfinanee; A set of lease structures at $60,000 and $70,000 monthly rental and for aircraft costs of $3,000,000 and $3,500,000; and 3. A form of operating lease used for Indonesian transactions.
Please note that the lease structures are based upon one set of financing assumptions, other financing structures are poss~le and would modify the resulting lease structure and cash flows but not drastically. We should discuss this in more detail later. Ray and I look forward to talking further with you and moving this project forward. Best regards.
Sincerely,
Stuart M. Warren
sMW:If Enclosures
Ios Angclc£ Cahfornta 90067-60
/7c3
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Lease Structure; Equity Investor Return: Interest rate on Debt: Repayment of Debt: Transactional Costs: Lease Management Fee: Lease Payment:
Leveraged operating lease 15% cash on cash 9% per annum Full Amortization over 6 years $12S,O001~or~t 3% of monthly' lease payment $60,000/$70,000 monthly in advance
Financing
Debt finance Equity required: Total financing: Transaction costs: Aircraft s~les price:
$2700,000
425.000 3,125.000
$,3,150,000
475.000 3.625.000
~.ooo,ooo
~.soo.ooo
Ill
pu~cha.~o Ocean Schedule Aircraft Sales Price: Monthly lease payment:
24 month FPPO Termination Value
.~3 M~lion ~;60,000 ~;70,000
2,600,000 2,225.000 2,200,000 1082.5,000 1,700.000 1.325.000 2,30D,000 2,025,000 1,700,000 1,425,D00 1,100,000 825.000 3,200,000 2,875,000 3,000,000 2,475,0D0 2,6D0,000 2,075,000 2,900,000 2,675,000 2,500,000 2,075,000 2,000,OOO 1,475,000
(e) (c)
,96 month FPPO Termination Value 48 month FPPO Termination Value
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STATEMF~'T OF PRINCIPLF--~
Global Airfinance Group would form a new entiB, Global Turbo DC-3 (hereafter referred to as Global) to be the leasing vehicle for Turbo DC-3 aircraft. Global management will structure, lea~ and financing in consultation with UTC/P&W and will market aircraft in coordination with UTC/P&W. Global will bc rc~pons~Ic for lras~ administration; UTC/P&W will be available for technical consultation especially with regard to such matters as engine maintenance and overhaul.
t
With regard to the first 15-2.0 aircraft, that is, until the market is established, UTC/P&W will provide a guarantee of the lease par.gage., i.e. protection against
lessee default and termination value deficiency. In case of default or l~se maturity, could elect to buyout UTC/P&W position by m~ting UTC/P&W's guarantees and
Global and UTC/P&W will cooperate in re.marketing and will be ineentivi~ed to sucw.essfu]ly re-market the aircraft. One approach would be to structure a 120 day
joint re-marketing period and if the aircraft wasn't placed during the period, Global if Global does not so deer, UTC/P&W could m-market the aircraft and foreclose Global's participation in future profits, with re.spect to the specific transaction. Global and UTC/P&W will share in profits pursuant to a fee agreement rather than UTC/P&W having a direct equity position in Global along the following lines:
UTC/P&W will retain for itself all benefits of (i) its marketing agreements with Basler, and (ii) its manufacturing and modification activities. Global will receive (i) a nominal initiation fee plus reimbursement of costs associated with structuring leases and financing to be paid out of equity, (ii) a lease management fee paid out of the rental stream equal to $2,000 per aircraft per month.
UTC/P&W will share equally with Global:
i.
ii.
100% of the profits on sale of the aircraft; and 100% of the incentive rent (i.e., the rent available in excess of debt service and equity return).
d.
Return to Equity will be targeted at 15% per annum c.ash on cash.
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If Global generates new customers for th= aircraft in I.FFC/P&W's territory or worldwide., Global will first present the transaction to UTC/P&W as one for inclusion in this program. If not accepted for th= program by UTC/P&W, Global's parent may nevertheless procr.ed to place th= aircraft ind=pcndcntly and will retain any marketing fees unless the placement is within UTC/P&W's . exclusiv= tcrritory in which case marketing fe.~.s nevertheless will b~ shared.
Global and UTC/P&W will jointly share information and coordinate and jointly ~ngag~ in marketing efforts for their mutual benefit. It is our d~irc that Global and UTC/P&W both be motivated and inc~ntivised to work together to mutual benefit.
The structure of the foregoing may be either in the form of a formal joint venture agreement and/or in the form of one or more related consulting, guarante~ and fc~ agrccmcnts.
2
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d LU
1.8
O
O
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Description of Chart Turbo DC-3 Leasing Strategy (Activities by time sequence) UTC and BTC develop working agreements. Two, two party agreements: - BTC-UTC/P&W - Innovair-UTC/P&W o Distributorship Agreement BTC-UTC/P&W o
So
side agreement for Indonesia sale of 5 aircraft
UTC and Global Air Finance establish separate company to lease aircraft to Indonesian customer (and future customers). Principals UTC would guarantee lease package and would share in lease profits with Global Air France. UT/GAF company completes lease w~th Bouraq Indonesia for 5 aircraft. Three year lease with customer commitment to purchase aircraft at the end of three years.
Do
UT/GAF places order for 4 aircraft with BFS. Upon completion, delivery to Bouraq via UT/GAF lease company ist quarter 1992. A separate agreement between BTC and UTC/UPA t~at provides UTC/UPA a mod kit (less engines) and up to 4 DC-3 airframes in lieu of any marketing fees for the initial 4 aircraft procured at BFS/BTC. UPA will take mod kit and i airframe from E above and convert 5th aircraft for sale to UT/GAF. This aircraft will be 5th aircraft on UT/GAF lease contract with Bouraq.
A0835
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Page 15 of 44
Innovair Aviation, Ltd. v. United States Case No. 96-408C Exhibit 247
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DC-3 0~ Sugary
where did the 810.0 M number come from? North Burstein has developed a spreadsheet analysis that indicates $iO. 0 M in working capital could support 12 A/C per year schedule. The tooling costs are about $60 - 80,000 so no large capital outlays are involved¯ Since it's just working capital the risk is low. We can slowdown, speed-up or get out a lot easier.
O
Are ROC investors available? On my trip to Taiwan, last month, my discussions with the China Development Corporation are encouraging. They have expressed interest and are willing to locate R0C Government and private money- Air Asia investment uncertain, but not necessary at this ¯ stage. If P&W invests 2 Mil then we are looking at 8 Mil from ROC.
o
where do we stand with offset credit approval? The concept of converting DC-3 in Taiwan was approved by the CASID for Douglas proposal. R0C (CASID) still hold that approval open for us. I estimatet/~.at they would cap offset credit at $25 - 30 Mil regardless of total benefits identified. They want to save credits for other projeots. If we do 36 aircraft we will make $i - 2 Mil in addition to offset credit. Where's the market?who are the buyers? See Dan Lord's package. There are over 200 DC-3's operating in the Pacific Rim. We would expect do to at least 50 conversions over 4 years. We are trying to determine ROC Air Force interest through Red Edwards (Sikorsky). We think someone (likeAmbrous Young) would be interested in leasing 5 - I0 DC-3's as a solid business deal. We had talked to Fed Ex (they are a current DC-3 turbo user) to determine their interest in the Pacific Rim. My guess is Fed Ex would take 5 - 10 aircraft 18 - 28 months from now, if available. Biggest near term requirement is to. convert one DC-3 to serve as a demonstrator and a marketing tool. Orders will be hard to come by without a real product to test.
o
A0837
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select a four man P&W retiree management team to partner with Don Douglas (not DIG) Don would provide marketing rights and in return would receive 4% (I/5 of P&W's 20% ) equity position after 36 conversions. Problem - cuts out rest of DIG select 4 - 5 man P&W retiree Management~team~" Don Douglas/DIG. to work with
DIG could get a straight marketing commission, but no equity position. Problem - Commission rate drains escrow that buys P&W out of JV. Select 4 - 5 man retiree management team and obtain mark?ring rights straight from Bnsler. NeW concept, without DIG or Don Douglas Problem - Don Douglas would scream"foul".
Recommendation
Select option A. Let Don resolve problem with DIG internally. Don would be satisfied, and we could effectively work around him to make it successful.
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~anaqement Team Alternatives DC-3 Conversion Pr~!ram
Our initial thrust was to work with Douglas International Group (DIG) to provide the day to day management of implementing a conversion program at Air Asia. Based on 6 - 9 months of working with DIG we don't believe DIG can handle this project. Additionally, Air Asia lacks strong management which compounds our problem. The attachment provides some alternatives to strengthen our position to insure proper, timely implementation. Obviously its a sensitive area. Brian Carmicheal (Basler partner) has the same concerns and would support whatever P&W decided to do. Don Douglas must be satisfied with our role for him or there will be some "missile" to Art. DIG knows of our concern and says they would attempt to identify people to calm our concerhs. Nothing yet. Ohr current approach is to identify recent retirees to form a management team to implement the Gonversion =ffo~. Action is underway and candidates have been identified and initial contact being made to sort this issue out. The plan is to blend our retiree management team with Don Douglas to form a suitable mix of the right.skills.
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~uT-out ApprOach DC-~ p&W objective is to provide a solid start-up of DC-3 oonversions in Taiwan. Consistent with this approach we would take a minimum equity position to show our involvement and then position ourselves to transfer our equity position tot he in-place management team once 36 aircraft are converted. P&W would identify 5 retirees to manage the day-to-day operations with the approval of the Board of Directors. Through a side agreement these 5 individuals would receive 20% of Douglas Conversions (all of P&W's equity) once 36 aircraft have been delivered. An escrow would be established to hold out commissions and a pro rata share of P&W earnings that would be allocated to the management team. Payment would be made to P&W on an annual basis up to P&W's 2 Mil initial investment plus interest. Upon repayment to P&W of roughly $2.5 Milthen P&W's equity would be transferred to individuals on the management team.
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A0847
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PRELIMINARY
A0848
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Innovair Aviation, Ltd. v. United States Case No. 96-408C
Exhibit 274
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TEL No.
Sep 28,92 I0:01 P.OI
L W. MARSHALL SEP 2 8 1992
BASLER TURBO CONVERSIONS, INC.
DATE: TO: FAX: FROM: Dear Fred,
September 28, 1992 Fred Johnson United Technologies (203)565-2898 Tom Weigt
This is in response to your question on supplying the BT-67 aircraft for Greece. We would like to proceed along the following lines: 8asler will sell the contract aircraft and related spares directly to the client. From our vantage point, no other agents are required. If commissions are required, they should be paid by UTC. A minimum of 12 aircraft are required for the contract of which at least the first two would be produced in..Oshkosh.
A minimum of (2) Bas.ler pe,r.sonn.eLwill b'~ ibn the. customer site for each" co~ut.r~n{ly ~?0~J~ i~'i~-~&f.t.::.T~e.~e:pei'sonnel are required to insure product c6nformity to.sp, ecification. We would provide personriel for at least (2) con£.urrent aircraft and any additional will be subject to staff availability. All costs of Basler personnel will be paid by the client.
A minimum of 8 client technicians will need to complete Basler on site training in Oshkosh for each concurrently produced aircraft. That is, if (2) aircraft are produced concurrently, then 16 client technicians will need to be qualified by Basler. Classroom training will be chargeable. On the job training will be free of charge except for travel and living e.xpenses which will be the client responsibility.
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TEL No.
Sep 28,92 10:02 P.02
All manufactured paris and component assemblies for the conversion will be supplied by Basler including those which are required for optional features (at Basler's discretion). Tl~e customer conversion facility' will be subjecl to initial approval by Basler's inspection personnel as well as to on going operational audits during the conversion period. Converted BT-67 aircraft will be for the use of the client only for a period of 7 years, i.e., no resales during that period outside of the nation of Greece. Pricing structures will be similar to those which we discussed in the past, that is based on market list prices. These will serve as outline points for dlscusslon which we are prepared to pursue at your convenience.
President
TRW/pv
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PX 315A
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IN THE UNITED STATES COURT OF FEDERAL CLAIMS
Innovair Aviation Limited. Plaintiff,
VS.
Case No. 96-408C
United States of America, Defendant.
Supplemental Report of. Cobb & ~,ssociates, Ltd.
Cobb & Associates, Ltd., a professional corporation, has been retained by Hogan & Hartson L.L.P. to assist representation of Innovair Aviation Limited (Innovair) in the abox~e matter. Arthur H. Cobb has had primary re~l~onsibility for this engagement and is expected to offer testimony at trial.
PX305
A0852
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INTRODUCTION In the Report of Cobb & Associates, Ltd., dated May 1, 2007 (the May Report), Cobb & Associates, Ltd. presents the preliminary analysis of the lost expectancy interest value of the Innovair-Basler Turbo Conversions, Inc. Technology License Agreement (TLA.) The preliminary analysis estimated Innovair's lost expectancy interest value of the TLA through approximately June 2~, 1998, not ineludlng pre-judgment interest, totaling approximately $36,000,000, based on sales of 90 units. The preliminary analysis included alternative representative estimates of Innovair's lost expectancy value, based on a potential of 130 units and a minimum of 50 units. The preliminary analysis and the opinions to be expressed and basis and reasons therefor were set forth in the Report of Cobb & Associates, Ltd., dated May 1,200"J (the May Report) and Arthur H. Cobb was deposed on June 19, 2007. The preliminary analysis included identifying 1) the availability of DC-3/C-47 airframes, 2) analyzing the market for Turbo-67 aircraft and parts and spares (including the general economy, aircraft markets, aircraft industry, Turbo-67 distribution [including by United Technologies Corporation,] DC-3/C-47 conversion competition and competitive aircraft,) 3) marketing of the Turbo-67 (including Turbo-67 sales by Basler,) 4) establishing a damage period and 5) estimating lost sales, incremental expenses and lost profits and, thereby, lost expectancy interest value.
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Hogan & Hartson L.L.P. has requested that we provide an analysis and calculation of the lost expectancy interest value (including calculation of sales, cost of goods sold, marketing expenses and general and administrative expenses) limited to sales under, and pursuant to the terms of, the July 25, 1991 Distributor Agreement between Irmovair andUnited Technologies Corporation (the Distributor Agreement). Such information is set forth in this Supplemental Report, which should be read in conjunction with the May Report. The lost expectancy interest value of the TLA through June 1998, not including prejudgment interest, related to Innovair conducting business limited to the minimum annual sales requirement of five kits and/or converted-aireraf~ pursuant to the terms of the Distributor Agreement, is estimated to total approximately $17,700,000,
3
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MINIMUM SALES UNDER THE UNITED TECHNOLOGIES CORPORATION DISTRIBUTOR AGREEMENT The 1991 Distributor Agreement called for United Technologies Corporation (UTC) to "meet a minimum annual sales requirement of five kits and/or converted aircraft" (Distributor Agreement § 5.9) for each year of the seven year agreement, a total of thirty-five kits and/or aircraft. UTC had the option of paying Irmovair its annual "net profit on the five kits less the number actually ordered" rather.than making the required sales. (Distributor Agreement §-6.7) The initial term of the Agreement ended on June 23, 1998. Sales Prices Sales prices for conversion kit sales by Innovair to UTC are calculated based on the Distributor Agreement. The Distributor Agreement sets forth that the first two conversion kits purchased thr. ough United Technologies would be purchased without dngines at a price of $1,133,000 per kit and additional conversion kits would be purchased with two turboprop engines at a price of $2,025,000 per kit. (Distributor Agreement § 5.2.1(a)) The Distributor Agreement provided a formula for increases in conversion ldt prices for subsequent years, summarized as follows: "Adiustment - Future Year Prices: (I) The fixed prices for 1991 shall be adjusted for subsequent calendar years ... in accordance with the following adjustment procedure:. (a) Adiustment Dates. The future calendar year adjustments shall be made on January I, and if the percent Primary Cost Component ("PCC") increase described below is greater than 2% as of July 1, a second adjustment shall be made on Jul~ 1. (b) Primary Cost Components. The Primary Cost Components for the conversion kits are: Engines, propellers, nacelles, cowlings and labor.
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(c) Percent PCC Increase. The Percent PCC Increase shall be determined by the ratio, converted to percent, of the sum of all increases of the Primary Cost Components in (b) to the sum of the costs of all items in the PCC categories as of the previous pricing date. (d) Conversion Kit Price Adiustment: The conversion kit pricb adjustment shall be the Percent PCC Increase from (c) above times the current kit price .... "(Distributor Agreement § 5.2.1 (b)) The Distributor Agreement granted UTC most favored customer provisions.
Cost of Goods Sold
Cost of goods sold are estimated based on purchase of conversion kits from Basler, and purchase of engines and propellers directly from vendors. Cost of goods sold for one conversion kit, based on the lnnovair Five Year Business Plan 1990-1994, the Deloitte & Touche Projection as of May 16, 1990 and United Teelmologies engine invoices, are estimated ~ follows:
Engines Prol~llers Conversion Kit Third-party Manu/'actur¢ Paw Malcrial and Fabricated Pans Direel Labor and Overhead Ba$1er 20 Perc~nl Markup Total Conversion Kil Tolal Percent Increase UTC Units UTC Cost of Goods ~ 4.6% 5 $ 6~40,000 $ Year I 750,000 36,000 240,000 80,000 65,000 77,000 462.000 Year 2 786,000 37.000 Year 3 800,000 38,00~ Year 4 821,000 39,000 Year 5 833,~00 39.000 Yea~ 6 849,000 40,000 Y~r 7 857,001) 41.0~0
482,000 1~05,000 2.1 5 6.525,0~
494,000 I ..332,000 ~ 2.4
504.000 ~ I. I
507,000
521.000 1,410,000
528.000 1,426,000
2.2
I./
5 5 5 5 5 6,660,000 6,820,000 6,895,000 7,050,000 7.130,000
The Distiibutor Agreement sets forth the first two conversion kits purchased by United that Technologies would be purchased without engines, reducing Year 1 UTC Cost of Goods to $4,740,000 ($6,240,000 - $750,000 - $750,000).
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Engine costs for Year 1 are estimated to total $750,000, or $375,000 per engine. United Technologies invoices indicate the cost of one engine in the range of $365,547 to $374,289. The Business Plan and the Deloitte. Projection included $724,000, or $362,000 for-each engine. Conversion kit costs include a Basler 20 Percent Markup. Cost of goods sold have been increased for inflation estimated as follows:
Year ! to' Year 2 Engines Propellers Conversion Kits 4.83% 3.82 4.34 Year 2 to Year 3 !.70 2.48 2.48 Year 3 to Year 4 2.63 2. I 1 2, ! 1 Year 4 to Year 5 1.47 0.77 0,46 Year 5 to Year 6 1.90 0.53 2.8 ! Year 6 to Year 7 1.05 3.24 !
Source: U.S, Department of Labor Bureau of Labor Statistics
Sellinl~ and Marketing Expenses Under the Distributor Agreement, Irmovair was to pay UTC a 10 percent commission on each unit. (Distributor Agreement § 5.2.1 (a)) If Innovair conducted business based on only UTC minimum annual sales, Innovair would not be expected to have incurred expenses for demonstration aircraft, demonstration flights, airshows, marketing manager, assistant marketing man&ger, advertising, travel costs and distributor costs. General and Administrative Expenses In order to carry out sales to UTC under the Distributor Agreement, Innovair would incur general and administrative expenses. General and Administrative expenses would be expected to have included expenses related to management, purchasing, maintenance of relationships with UTC and administration of annual sales of 5 kits and/or converted aircraft to UTC. Certain estimated General and Administrative expenses would be reduced, if Innovair conducted business based on only UTC minimum annual sales. Irmovair would not be expected to have incurred expenses for an assistant accountant and product liability insurance.
6
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President, Accountant and Secretary Salaries, bonuses, housing allowance and benefits for Innovair's President, Accountant and Secretary are estimated based on information in the Deloitte Projection. Benefits are estimated to total 25 percent of salaries. (The Deloitte Projection includes estimates of other allowances and benefits for management and administrative personnel of 15 percent of salaries.) Estimated management and administrative salaries and benefits for year one are summarized as follows:
President $ 150,000
37,500
Salary and Bonus
Benefits
AccOuntant 50,000
12,500
Secreta~ 30,000
7,500
Total
$ 187r500
,, 621500
, 371500
Management and administrative salaries and benefits have been increased fo} inflation. Inventory Holding Costs Irmovair would have incurred costs related to. maintenance of an "inventory of those spare parts that are low usage, high unit cost and have a long delivery lead time." (Distributor Agreement § 5.8) Inventory costs would have been recovered in the pricing structure oflhe sale of spare parts. Office. Innovair is a Hong Kong corporation and planned to maintain offices in Hong Kong. Office start-up and moving expenses are estimated to total $25,000 in year one. (The Deloitte Projection set forth estimated costs of establishing the Hong Kong office of $10,000.) Innovair's office rent is estimated to total $5,000 per month or $60,000 per year for years one, two and three, based on the Deloitte Projection, and to increase to $5,000 per month or $72,000 per year for years four, five, six and seven.
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General Office and Business General office and business expenses are estimated to be $45,000 for year one and to increase with general inflation thereafter. General office and business expenses are estimated to include costs for brochures and similar materials. (The Deloitte Projection set forth general office and business expenses of $43,000 per year.) Legal and Audit Irmovair's legal and audit fees are estimated to total $25,000 in year one,. reflecting limited operations, and to increase with general inflation thereafter. (The Deloitte Projection set forth legal and audit fees of $34,000 per year.) Travel and Entertainment Irmovair planned that administrative personnel would incur travel and entertainment expenses estimated to total $25,000 in year one and to increase with general inflation thereafter. General Inflation General and Administrative Expense general inflation is estimated as follows:
Yearlto Year2to Year 2 Year 3 General Inflation 9.30% 8.50 Year3to Year 4 8.10 Year4to Year 5 8.70 YearSto Year 6 6.00 Year6to Year 7 5.70
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SUMMARY
The lost expectancy interest value of the TLA through June 1998, not including prejudgment interest, related to Innovair conducting business limited to the minimum annual sales requirement of five kits and/or converted aircraft pursuant to the terms of the Distributor Agreement, is estimated to total approximately $17,700,000, summarized (in thousands of dollars) as follows:
Year I 1991.1992 UTC Units without Engines Sales Pric~ Units with Engines Sales Pricx UTC Sales Percent'Increase Cost of Goods Gross Margin Selling and Ma~eting ~ses General/Administrative Expenses President Accountant Seereta~ Office General Office and Business Legal ~,nd Audil Fees Travel ~d Ente~inment Tot~l GenerallAdmini~ro, tive Total Exl~nses Estimated Lost Value Year 2 1992-1993 Year 3 1993-1994 Year 4 1994-1995 Year 5 1995-1996 Year 6 1996-1997. Year 7 1997-......_~199._.~ To~l
2 i,133 J 2,025 2,118 $ 11,341 10,590 4.6"~ 4,740 3,601 1~34 188 63 38 85 45 25 25 469 1,303 $ 2,298
6,525 4,065 1,059
2.163 !0,$15 2.1
6,660 4,155 1,082
2,215 11,075 2.4
6,820 4,255 1,108
2,239 I 1,195 13
6,895 4,300 1,120
2,288 11,440 2.2
7,050 4,390 1.144
2,313 11,565 I.l
7,130 4,435 1,157
75,021
45,820 29,201 7,504
~05 69 42 60 49 27 27 480 1,539 2,526
"222 75 '45 .60 53 30 30 514 1,596 2,559
' 240 81 49 72 58 32 32 563 1,671 2,584
261 88 53 72 63 35 35 606 1,726 2j74
277 93 56 72 66 37 37 639 1,783 2,607
293 9~ 59 72 70 39 39 671
3,942
I,~2~ 11,446 2,607 $ 17355
Arthur H. Cobb September 17, 2007
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