THE IMPACT OF MISSING, LOST OR STOLEN

AIRCRAFT LOGBOOOKS

By: Elizabeth A. Vasseur-Browne1

I. INTRODUCTION

Captain Chesley “Sully” Sullenberger’s final task before exiting the US Airways

Airbus minutes after ditching into the Hudson River was to collect the aircraft’s

maintenance logbooks.2 Indeed this experienced airline captain knew there would be an

accident investigation as to its cause, in spite of the fact that a flock of Canadian geese

clearly caused the double engine failure.3 He did not doubt the FAA and NTSB

investigators would still want to review the aircraft’s maintenance logbooks to aid in their

accident investigation. These records would show how the aircraft had been maintained,

compliance with airworthiness directives, number of airframe and engine hours, damage

history--if any, among many other factors. Being able to verify this historical

information was important not only in the cases of US Airways Flight 447 and other

accidents, but in most cases it is extremely important and valuable to aircraft owners and

operators.4

This article discusses the impact on aircraft owners, operators and finance

companies when aircraft logbooks are lost, destroyed, stolen, held in lieu of payment or

otherwise unavailable. It also discusses what to do when an owner or operator is unable

1
Ms. Elizabeth Vasseur-Browne is an attorney with Cooling & Herbers, P.C., a Kansas City law firm. She
focuses her law practice on aviation and insurance defense matters and FAA enforcement actions. She is a
licensed pilot and served in the United States Air Force.
2
Sullenberger, Chesley. Interview with Katie Couric. “Miracle on the Hudson.” Sixty Minutes. CBS.
WCBS, New York, 8 February 2009.
3
Id.
4
For the purposes of this article aircraft logbooks include the aircraft’s engine, propeller, airframe,
accessory and any other logbook required to be maintained pursuant to federal code and is applicable to
both fixed wing and rotorcraft. The cases cited in this article will focus on issues related to aircraft
logbooks.

1
to regain possession of his/her aircraft logbooks and how unavailable logbooks can affect

the value of aircraft. It is important however to keep in mind that the impact of missing

aircraft logbooks will differ from case to case.

II. FEDERAL AVIATION REGULATIONS

Registered aircraft owners and operators are required to maintain maintenance

records in accordance with 14 C.F.R. § 91.417. Although the FAA has strict regulations

as to the type and length of time maintenance records must be maintained, generally, they

do not mandate the actual format or forms that are to be used.

“While keeping such records in the actual maintenance logbook of

the aircraft might facilitate their being kept and readily available
… the regulations do not require it. The aircraft owner may
determine what is used as a maintenance record for his or her
aircraft.” Office of the Chief Counsel, Request for Interpretation
of 14 C.F.R. §§ 43.11 and 91.417, dated (8.15.2008).

The records themselves do not need to, and arguably should not be, stored on the

aircraft, but must be produced for inspection in a reasonable amount of time when

requested by the FAA, NTSB or law enforcement.5 See 14 C.F.R. § 91.417:

“(c) The owner or operator shall make all maintenance records

required to be kept by this section available for inspection by the
Administrator or any authorized representative of the National
Transportation Safety Board (NTSB). In addition, the owner or
operator shall present Form 337 described in paragraph (d) of this
section for inspection upon request of any law enforcement
officer.” (Emphasis added).

When an aircraft owner or operator fails to produce his/her aircraft logbooks in a

reasonable amount of time pursuant to 14 C.F.R. § 91.417, the FAA can initiate an

5 See FAA Advisory Circular Number 43-9C, (AC No. 43-9C) Maintenance Records; published on June 8,
1998.

2
enforcement action, as was the case in United States v. Intercon Leasing, Inc.6 In

Intercon Leasing, Inc., the FAA suspended the airworthiness certificate of a Douglas

DCA aircraft.7 Intercon was the registered owner of the aircraft and Jerry Harvey was the

president of Intercon.8 After the FAA suspended the airworthiness certificate, the FAA

demanded, inter alia, the aircraft maintenance records.9 Intercon never surrendered the

records and later sold the aircraft.10 The FAA initiated an enforcement action against

both Intercon and Harvey for a number of FAR violations, including their failure to

provide the FAA with the aircraft maintenance records pursuant to 14 C.F.R. § 91.417,11

and assessed a civil penalty of $1,000 a day from the time the FAA demanded the records

until the aircraft was sold, totaling $1,950,000.12 Intercon and Harvey appealed to the

United States District Court, Southern District of Florida, which upheld the penalties and

ordered them to pay close to two million dollars.13

In another case, Administrator v. Robbins,14 Robbins was the owner/pilot of a

Piper aircraft who received a six month suspension of his airman’s certificate for

operating his aircraft without aircraft logbooks and without a current annual inspection.15

The FAA initially sought a 365-day suspension and Robbins appealed the suspension to

the NTSB.16 At his hearing Robbins testified that his aircraft logbooks had been stolen

6 United States v. Intercon Leasing, Inc., 617 F. Supp. 323, 328-329 (S.D. Fla. 1985).
7 Id. at 325.
8
Id. at 324.
9
Id.
10
Id. at 329.
11
The violation cited in the decision was 14 C.F.R. § 91.173 which has since been re-codified as 14 C.F.R.
91.417. Hinson v. Ira Donald Farrington, NTSB Order No. EA-4171, 1994 WL 239001 * 7 (May 12,
1994).
12
Id. at 329.
13
Id. at 330.
14
Administrator v. Robbins, 4 N.T.S.B. 807 (1983).
15
Id. at 810.
16
Id. at 807.

3
and when he took the aircraft to Pelican Aviation, a repair/inspection facility, for its

hundred hour inspection, he also requested they reconstruct the aircraft logbooks and

perform an annual inspection; he also testified that when he picked-up the aircraft, he was

told the aircraft was “legal to fly.”17

During the hearing, the FAA called a representative from Pelican to testify who

ultimately denied Robbins ever requested Pelican perform an annual inspection or to

reconstruct the aircraft logbooks.18 He further testified that an annual inspection could

not be performed without the aircraft’s logbooks.19 Judge Capps, the NTSB

administrative law judge, did not find Robbins’ testimony credible and held he violated a

number of FARs including 14 C.F.R. § 91.417, but he reduced the suspension to six

months.20 Robbins appealed to the full NTSB board which upheld the six month

suspension and in their decision wrote, “…the fact remains that respondent operated the

plane for months without any logbooks.”21

III. THE FAA DOES NOT HAVE AUTHORITY TO

COMPEL A PARTY TO DELIVER AIRCRAFT
LOGBOOKS TO AN AIRCRAFT OWNER,
BUT CAN IMPOSE SANCTIONS IN LIMITED
CIRCUMSTANCES

Although the FAA requires detailed maintenance records be maintained for each

aircraft and the FAA and the NTSB have the authority to request these records be

produced in a reasonable amount of time for inspection, the FAA does not have the

authority to compel one party to deliver such records to another party--this is a matter of

17
Id. at 808.
18
Id. at 809.
19
Id.
20
Id. at 810.
21
Id. This six month suspension also included a violation of 14. C.F.R. § 91.169(a).

4
state law, which will be discussed later in this article. However, the FAA can impose

sanctions in limited situations, such as when a seller of a U.S. registered aircraft refuses

or fails to deliver maintenance records to an aircraft purchaser, at the time of sale. See 14

C.F.R. § 91.419:

“Transfer of maintenance records.

Any owner or operator who sells a U.S.-registered aircraft shall
transfer to the purchaser, at the time of sale, … records of that
aircraft …”

A case that illustrates this point of law is Administrator v. Seaquest Expeditions,

Inc.,22 where the FAA sought a $65,000 civil penalty against a seller of a Hughes 269A

helicopter for violating 14 C.F.R. § 91.419.23 In Seaquest Expeditions, after the sales

transaction was complete, the seller, Seaquest Expeditions, repeatedly promised to

deliver the aircraft logbooks to the buyer; after five months of failing to do so, the buyer

complained to the FAA who initiated this enforcement action and sought a $65,000 civil

penalty.24 The FAA assessed a separate § 91.419 violation for each day Seaquest

Expeditions failed to deliver the aircraft logbooks to the buyer.25 Seaquest Expeditions

appealed to the Department of Transportation which upheld the violations but reduced the

sanction to $25,000. In his decision, Judge Goodwin wrote:

“…the record of an aircraft’s maintenance history is as integral to

its safe, responsible, and legal use as any component … Lacking
such records, conversely, an aircraft’s airworthiness can not be
established … [a] helicopter without the records, is effectively
useless … It can not be operated.”26

22
Administrator v. Seaquest Expeditions, Inc., Docket No. CP04NM0006, 2006 WL728859, (D.O.T).
23
Id. at * 1.
24
Id. at *1 and * 3.
25
Id. at * 4.
26
Id. at * 4.

5
 In the end, although Seaquest Expeditions received a substantial civil penalty, the

FAA lacked the power and authority to compel Seaquest Expeditions to actually deliver

the aircraft logbooks to the aircraft purchaser.

When a party in possession of the aircraft logbooks refuses to turn them over to

the aircraft owner, the owner has two legal remedies: 1) file a lawsuit and sue the party

in possession for specific performance. If the lawsuit is successful, a court may order the

party holding the logbooks to turn them over to the aircraft owner or; 2) file a lawsuit for

money damages which could include, but not be limited to, the diminished value of the

aircraft, the cost to recreate the logbooks or both. Diminution of value and the cost to

recreate aircraft logbooks are discussed later in this article. Neither remedy is ideal if you

take into account the costs associated with lawsuits, in terms of money, time, and the

emotional impact litigation has on parties.

IV. MISSING AIRCRAFT LOGBOOKS CAN AFFECT

THE FUTURE SALE OR VALUE OF THE
AIRCRAFT

The case of United States of America v. Strum27 is an interesting criminal case

where Strum, the owner of an Aero Commander aircraft was convicted of extortion for

refusing to surrender the aircraft’s logbooks to the bank after the bank foreclosed on the

aircraft.28 Strum, had fallen behind on the aircraft’s loan payments--the loan was secured

by other collateral including the aircraft logbooks.29 Strum did eventually catch up on the

late payments, but, when the bank learned that another bank was considering placing a

lien on Strum's Aero Commander because Strum was in default with that bank on a

27
United States v. Strum, 870 F.2d 769 (1ST Cir.1989).
28
Id. at 769-770.
29
Id. at 770.

6
different aircraft, the bank repossessed the Aero Commander. For reasons not explained,

the bank did not take possession of the aircraft logbooks.30

The bank tried to auction the aircraft but the auction did not produce what the

bank considered to be fair market value, thus the bank took possession of the aircraft. 31

The bank later learned that “the low valuation was directly related to the unavailability of

the plane’s logbooks.”32 When the bank attempted to get the aircraft logbooks from

Strum, the United States government alleged Strum tried to extort money from the bank

in exchange for the logbooks.33 Strum told the bank, “I don’t know where the books are

right now, but I can get them for you for a price.”34 He made other such comments and

was subsequently prosecuted and convicted under the Hobbs Act for extortion.35 The

Court in Strum discussed how the missing logbook affected the value of the aircraft.

Strum’s conviction was later overturned and, unfortunately for the bank, so long

as Strum withheld the logbooks, it was unable to sell the aircraft despite the time, effort

and financial resources the bank incurred trying to get what lawfully belonged to it.36

In Corporate Wings, Inc. v. King,37 the aircraft owner (bank)38 and its aircraft

broker (King) were original plaintiffs in the underlying lawsuit where they sued

30
Id.
31
Id.
32
Id.
33
Id.
34
Id.
35
Id.
36
Another interesting case is Gasho v. United State of America where Customs and Border Agents seized a
DC3 for not having the proper registration number. The aircraft was being sold to a Canadian buyer and
the FAA had authorized removal of the serial number and a onetime flight to the US/Canadian border.
Border agents were unable to contact the FAA official that authorized this flight, became suspicious and
seized the aircraft. The owners were later arrested for refusing to deliver the aircraft logbooks to the
agents, but these charges were ultimately dropped. The Gashos subsequently filed a Federal Tort Claims
Act lawsuit against the agents for false arrest, inter alia. See Gasho v. United States of America, 39 F.3d
1420 (9th Cir. 1994).
37
Corporate Wings, Inc. v. King, 767 S.W.2d 485 (Tex. Civ. App. 1989).
38
While this appeal was pending the owner settled with Corporate Wing and was dismissed.

7
Corporate Wings for wrongfully withholding their aircraft logbooks.39 Corporate Wings

performed aviation related services for the subject aircraft and submitted a bill to the

bank for $35,047.84 for some inspection and demonstrating services Corporate Wings

performed.40 The bank disputed and refused to pay the bill and in-turn, Corporate Wings

refused to return the aircraft to the bank.41 The parties eventually reached an agreement:

Corporate Wings reduced its bill and returned the aircraft to the bank, but for three

months did not return the aircraft logbooks.42 During this time the bank and its broker

made repeated requests for the return of the logbooks, but a Corporate Wings manager,

still upset about not being paid in-full, maintained he did not know where the logbooks

were, but for $15,000 he would look for them.43 Also, during this three month dispute,

the owner/broker lost the sale of this aircraft to a potential Canadian purchaser because

the bank did not have possession of the aircraft logbooks.44

The bank filed a lawsuit alleging the missing logbooks affected the sale of the

aircraft; the court agreed and in its decision wrote, “[b]ecause log books contain records

of federally-required maintenance, they are critical to the sale of an aircraft.”45 And for

Corporate Wings’ misconduct, the court awarded the bank $53,545 in actual damages and

$50,000 in exemplary damages,46 and for the broker $1,057 in actual damages and

$15,000 in exemplary damages.47

39
Id. at 486-487.
40
Id.
41
Id.
42
Id. at 487.
43
Id.
44
Id.
45
Id.
46
“Exemplary damages serve to punish the wrongdoer and to provide an example to other potential
wrongdoers.” Id. at 488 (citations omitted).
47
Id. at 489.

8
 Corporate Wings appealed arguing the exemplary damages were excessive,

however the appellate court upheld the trial court’s decision holding Corporate Wings’

actions were intentional, malicious and wanton because 1) they knew the importance of

the logbooks; 2) they knew the sale was pending; 3) they sent a proposal to the owner and

broker stating they would be willing to look for the books for $15,000; 4) the owner

requested the logbooks be returned several times, and 5) the logbooks were found in a

Corporate Wings manager’s office.48 See also, Raytheon Aircraft Credit Corporation v.

Starship Enterprises, Inc. and Aircraft Crew Management, Inc,49 where the court ordered

Aircraft Crew Management, Inc. to return the aircraft logbooks to Raytheon after Starship

Enterprises, Inc defaulted on loan payments.

V. AN AIRCRAFT PURCHASER NEEDS THE AIRCRAFT

LOGBOOKS TO ASCERTAIN OR CONFIRM THE
MAINTENANCE STATUS OF THE AIRCRAFT

When aircraft logbooks are properly maintained they will show 1) the aircraft’s

maintenance history; 2) the total airframe, engine and propeller time; 3) compliance with

airworthiness directives, and 4) the aircraft’s damage history, if any. A savvy aircraft

purchaser or finance company will want to verify these facts before entering into any

sales transaction because the best way, and (in most cases) the only way to do so is to

review the aircraft logbooks.

a. Maintenance History

In Filmer Aviation, Inc. v. Nashville Jet Sales, Inc. v. ST Equipment Company,

et al,50 ST Equipment was finding it difficult to sell its MU-2 twin turbo-prop aircraft

48
Id. at 487.
49
Starship Enterprises, Inc. and Aircraft Crew Management, Inc., 1998 WL 166582, (D.Kan. 1998).
50
Filmer Aviation, Inc. v. Nashville Jet Sales, Inc. v. ST Equipment Company, et al, 1992 WL 368671
(Tenn.Ct.App.1992).

9
because they had lost the aircraft logbooks.51 Nashville Jet Sales was willing to purchase

the aircraft without the logbooks as soon as they found a buyer--Nashville Jet Sales was

planning to do a back-to-back transaction, meaning they would purchase the aircraft and

then immediately sell it.52 Filmer Aviation, Inc, agreed to purchase the aircraft without

the aircraft logbooks from Nashville Jet Sales, so long as it was provided some

assurances or warranty as to the condition of the aircraft such as compliance with

airworthiness directives (ADs).53

Nashville Jet Sales communicated this to ST Equipment and in order to save the

sale, ST Equipment drafted and signed a statement assuring that the aircraft complied

with all ADs at the time of sale. With these assurances, Filmer purchased the aircraft.54

However, just two months later, the FAA inspected the aircraft and found that the

available maintenance records were insufficient to enable the FAA to certify that the

engines were in compliance with the ADs.55 Filmer sued Nashville Jet Sales for the costs

it incurred to bring the aircraft in compliance with the ADs. Nashville Jet Sales filed a

third-party claim against St Equipment for indemnification and attorneys fees.

The trial court found that Nashville Jet Sales breached its warranty to Filmer but

held that Nashville Jet Sales was entitled to indemnity and recovery of attorney’s fees

from ST Equipment.56 On appeal the court upheld the breach of warranty claims in favor

of Filmer, but reversed the trial court’s decision to award indemnity and attorney’s fees to

Nashville Jet Sales.57 The court also noted that had the aircraft logbooks been available,

51
Id. at * 1.
52
Id.
53
Id.
54
Id. at * 2.
55
Id.
56
Id.
57
Id. at * 7.

10
the aircraft would have been worth $230,000, but since they were missing, the best price

ST Equipment could get was $130,000.58

It is important to note that nothing in this case suggested that either Nashville Jet

Sales or ST Equipment knew there was a problem with the ADs, they simply wanted to

sell the aircraft and did not have the aircraft logbooks to verify its maintenance status.

Had the aircraft logbooks been available to Nashville Jet Sales, then to Filmer, the parties

would have been able to determine whether or not the ADs had been complied with prior

to the sale of the aircraft and a lawsuit would have been unnecessary.

b. Damage History

Another reason aircraft logbooks are important is that they should provide the

aircraft’s damage history. Knowing whether an aircraft has sustained damage in the past,

in many cases, can affect the value of an aircraft as determined on a case-by-case basis.

For example, missing aircraft logbooks for a five year old business jet that in fact has no

damage history will have far greater implications than missing aircraft logbooks for a

thirty year old, two seater-single engine aircraft. But in either case, missing logbooks can

and will affect the aircraft’s overall value. This next case illustrates that even if you get a

signed document stating the aircraft has had no known damage, you may not be able to

rely on such a statement, absent some proof such as the aircraft logbooks.

When you get to the heart of Corporate Air, et al., v. Edwards Jet Center, et al.,59

you can see this is really a breach of contract case even though the parties allege just

about every possible legal theory against one another. For the purposes of this article,

this case illustrates the importance of the aircraft logbooks and what can happen if an

58
Id. at FN 1.
59
Corporate Air, et al., v. Edwards Jet Center, et al., 345 Mont. 336, 190 P.3d 1111 (2008).

11
aircraft purchaser does not receive and inspect the logbooks prior to signing a purchase

agreement.60

Edwards Jet Center, the buyer of two Beechcraft King Air 200 aircraft, signed an

agreement to purchase the two aircraft from Corporate Air.61 Edwards Jet Center alleged

that they had not been provided the aircraft logbooks until after they signed the purchase

agreement; prior to that they were only provided specification sheets which indicated

there was “No Known Damage History” but the spec sheets also indicated they were

“subject to verification upon inspection.”62 Not long after signing the purchase agreement

Edwards Jet Center inspected the aircraft logbooks which indicated that one of the

aircraft did in fact have damage history and after translating the logbook for the other

aircraft from French and Hebrew to English, Edwards Jet Center learned that a five year

period was missing. Not surprisingly, upon discovering the damage history Edwards Jet

Center was no longer interested in purchasing either aircraft and it formally rejected the

sale. Thereafter, Edwards Jet Center sued for breach of contract and a litany of other

claims.63

The court granted summary judgment in favor of Corporate Air and awarded

damages, costs and attorney’s fees.64 Both parties appealed up to the Montana Supreme

Court who reversed and remanded the case back to the trial court finding summary

60
The following passage is directly from this Montana Supreme Court opinion:

“The parties' extensive and often petty wrangling, both before and after the
instant action was commenced, has resulted in a factual and procedural history
that, at this point, can fairly be characterized as labyrinthine. … It seems that
every conceivable claim and counterclaim has been alleged...” Corporate Air v.
Edwards Jet Ctr., 2008 MT 283, 345 Mont. 336, 339, 190 P.3d 1111, 1115.

61
Id. at 342.
62
Id.
63
Id. at 344.
64
Id. at 345.

12
judgment was improper.65 However, for the purposes of this article only, it is not really

important which party prevailed because in the end, one should consider the time, energy

and financial resources both parties expended simply because the seller did not provide

the buyer with the logbooks before the purchase agreement and the buyer did not insist

on their inspection before signing the purchase agreement.

VI. LOST, STOLEN OR DESTROYED LOGBOOKS

MAY BE COVERD UNDER THE AIRCRAFT'S
INSURANCE POLICY.

Lost or destroyed logbooks may be covered under the aircraft’s insurance policy.

However, whether or not coverage exists will depend on the language of the policy and,

if the logbooks are not specifically covered under the policy, an insurer can deny

coverage and a court may have to decide whether coverage exists. The court will

review/interpret the policy and make a determination under the laws of the applicable

jurisdiction as to whether or not coverage exists.

In Union Planters National Bank v. American Home Assurance Company,66 an

aircraft was seized by the federal government in Puerto Rico as an instrument of drug

trafficking.67 Inexplicably, when the aircraft was returned, the seats and the logbooks

were missing.68 The bank that financed the aircraft made a claim under an all risk policy

but the insurer denied the claim; thereafter the bank filed its lawsuit against the insurer.69

The court found the missing logbooks (and seats) were covered under the all risks

policy because the fact they were missing was an unexplained event, not specifically

65
Id. at 358.
66
Union Planters National Bank v. American Home Assurance Company, 2002 WL 1308344 (Tenn. Ct.
App. 2002).
67
Id. at * 2.
68
Id.
69
Id. at * 3.

13
excluded under the policy and further, because there was no wrongdoing by the insured.70

Conversely in Eagle Aviation, Inc. v. General Insurance Company of America,71 the

Court agreed with an insurer that denied coverage in a claim for stolen logbooks because

the definition of “aircraft” as defined in the policy did not include its logbooks.72

So, whether or not logbooks are covered under an aircraft insurance policy will

depend on the language of the policy and if it’s not clear if the logbooks are covered, then

it can be up to a court to decide. An aircraft owner should discuss this with his/her

insurance agent or broker and specifically request the aircraft logbooks be covered under

the policy.

VII. WHAT AN AIRCRAFT OWNER CAN DO IF

HIS/HER AIRCRAFT LOGBOOKS ARE
GONE FOREVER

Aircraft owners and operators can protect their aircraft logbooks by maintaining

the original copy in a safe place away from the aircraft. If however, the owner needs to

recreate his/her logbooks, there are vendors that specialize in this service. If the owner

plans to recreate the logbook he/she should review Advisory Circular 43-9C---FAA June

8, 1998, titled, Lost or Destroyed Records. AC 43-9C provides guidance on how to

reconstruct aircraft records.

But whether the owner recreates the logbooks on his/her own or if he/she hires a

company that specializes in this service, to recoup these expenses from a third-party,

there must be accurate records of these costs and expenses. The final case in this article

70
Id. at * 8.
71
Eagle Aviation, Inc. v. General Insurance Company of America, 679 So.2d 1069 (Ala. Civ. App. 1996).
72
“Aircraft ’ means the airplane or rotorcraft described herein and shall include the engines, propellers,
rotor blades, tools and repair equipment therein which are standard for the make and type of the aircraft,
and operating and navigation instruments and radio equipment usually attached to the aircraft, including
parts temporarily detached and not replaced by other similar parts.” Id. at 1070.

14
took place in California state court, Ford & Vlahos v. ITT Commercial Finance Corp.73

In this case the aircraft finance company, ITT Commercial Finance, repossessed a C-130

aircraft from the aircraft owner, Ford. ITT alleged that after repossessing the aircraft,

they had to clean and paint the aircraft and reconstruct the aircraft logbooks.74 ITT

alleged the cost to perform these tasks was approximately $400,000—but Ford’s expert

testified that many of ITT’s documents offered to prove this claim were suspect and that

some were even forged.75 The court believed Ford’s expert and awarded ITT only

$83,000 of the $400,000 requested.76

VIII. CONCLUSION

Aircraft logbooks are valuable assets that must be safeguarded to protect the value

of the aircraft and to avoid FAA enforcement actions. Civil remedies are available if a

party refuses to give an aircraft owner his/her logbooks or if a party misrepresents the

condition of the aircraft to a buyer, but these remedies are expensive and time consuming.

An aircraft purchaser should never sign a purchase agreement unless he/she has a

contingency to allow termination of the contact in the event the purchaser cannot obtain

and review the logbooks or until he/she has received them and has had an opportunity to

have a qualified aircraft mechanic review them for the aircraft's maintenance status and

damage history. Aircraft owners should also review their insurance coverage and discuss

with their agents whether specific language can be added to the aircraft’s insurance

policy to cover the loss of aircraft logbooks.

73
Ford & Vlahos v. ITT Commercial Fin. Corp., 18 Cal. App. 4th 1107, 23 Cal. Rptr. 2d 175, 179 (Cal.
Ct. App. 1993) review granted and opinion superseded sub nom. Ford & Vlahos v. ITT Commercial Credit
Corp., 864 P.2d 1036 (Cal. 1993) and rev'd, 8 Cal. 4th 1220, 885 P.2d 877 (1994). The reviewing court did
not specifically discus the expense of recreating the logbooks.
74
Id. at 184-185.
75
Id.
76
Id.

15