Attempt to Distinguish from Jackson and Vallentgoed
To support argument that the Maintenance History shows that the instrument was taken "out of service", for "consistently low cal. checks" and as a result "requires calibration". Can the matter not be distinguished from Vallentgoed where the maintenance log revealed that the instrument was taken out of service for routine maintenance and periodic re-calibration?
To support argument that the Maintenance History reveals that the instrument was taken out of service for a specific problem. Can the matter not be distinguished from Jackson para 135?
To suggest that there is a problem with the CFS / ATC approach to assessing accuracy and precision if this instrument needed to be taken out of service - the instrument passed the CFS / ATC criteria and yet was taken out of service for some mysterious reason.
To suggest that full documentation of the mysterious reason should be the subject matter of an O'Connor order.