If the answers you've given to my questions are correct as a matter of fact - and I don't doubt you consider them to be correct as a matter of fact - it inexorably follows in my view that even on CASA's view of the regulatory requirements MFT was the only flying school whose operations were actually authorised by the AOC held by ACN 119 046 285 in October 2018! So how CASA managed to include MFT on the list in the October 2018 letter is anyone's guess.
I still can't get my head around how a company you set up (and, I would have thought, controlled) managed to sack you as an employee. I'm assuming there was an internal change such that you weren't the CEO or somehow didn't make any of the employee hire/fire decisions? In any event, I hope by now you realise exactly what CASA will continue to argue:
McHeyzer didn't 'direct' anyone to do anything but, even if that's wrong, the 'direction' was given to APTA and McHeyzer was off on a frolic of his own. Your argument is therefore (according to CASA) with APTA and McHeyzer.
In relation to the "closure of APTA after CASA had approved that structure for all time and on every occasion" I note that, strictly speaking - which is how I reckon CASA will speak - CASA did not close APTA. CASA actually invited APTA to provide evidence as to the way in which APTA would exercise effective control over a bunch of activities being carried out at 'alliance' 'bases' by personnel of whom APTA had no legal control, using premises and facilities over which APTA had no legal control and using aircraft of which APTA was not the registered operator. That was the point of the White email regurgitating the LARP opinion in 2019. But that task was practically impossible for APTA to complete, given the time and cost constraints on APTA at the time - which constraints were and are not a bother to CASA.
The approval of additional 'alliance' 'bases' on every occasion is the elephant in the room. The problem for APTA and CASA is that two wrongs don't make a right. The related problem for APTA and you is that CASA never admits it makes mistakes.
The initial approvals by CASA of additional 'alliance' 'bases' without first having required the kinds of evidence which CASA subsequently required as described in the While email regurgitating LARP opinion in 2019 was, in my view, a massive f*ckup by CASA. That's because the initial approvals encouraged ATPA - and in my view reasonably - to believe that approvals of further 'alliance' 'bases' in like circumstances to previously approved 'alliance' 'bases' would be granted on the production of like evidence.
That's why, in my view, CASA's falling over backwards to try to convince the Ombudsman and others that CASA was not aware of the detail of the APTA 'structure' - i.e. the legal relationship between the APTA AOC holder and those with legal control over the people, premises and aircraft at the 'alliance' 'bases' - until 'later'. But even if it is true in fact that CASA did not become aware of those details until 'later', CASA was on constructive notice of them and its job was to find out about them before granting each variation covering each new 'base' from the start.
CASA should have made very clear to APTA, from the start of the 'alliance' 'base' concept, the time-consuming and costly requirements that were instead sprung on APTA years later. But having not done so from the start, CASA could not continue making the same mistake by continuing to grant variations to cover more and more people, premises and aircraft - and therefore operations - over which APTA had not established legal and effective control. But rather than admitting that and making amends by working with APTA to try to bridge the gap - which gap, as I've said, could have been bridged with some fairly simple deeds of agreement and some governance in APTA for securing compliance with the deeds - CASA must maintain the pretence that it never makes mistakes.