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OST-1996-1023 - Gulf and Caribbean Cargo, Inc. d/b/a Gulf and Caribbean Air d/b/a IFL Group

http://www.flytlc.com/

Silverberg Goldman, Robert Silverberg

OST-96-1023 - Amendment to Its Certificate of Public Convenience and Necessity

December 16, 2003

Motion for Confidential Treatment Pursuant to Rule 12

Gulf & Caribbean and the entities controlling Gulf  & Caribbean, Air Apparent, LLC and Schadrack, LLC, in order to permit the Department to carry out its statutory duty to assess the fitness of the carrier to conduct operations with large aircraft.

Accordingly, Gulf & Caribbean requests confidential treatment for the following information all of which was either submitted with the September 17 or October  21 letters or incorporated by reference therein: (1) Gulf & Caribbean Cargo, Inc. Projected Statement of Operations, Twelve Months Ended March, 2004; (2) Lease Agreement Between IFL Group, Inc. and Gulf & Caribbean Cargo, Inc.; (3) Shadrack, L.L.C. Compiled Financial Statements, Years Ended December 31, 2001 and 2000; (4) Shadrack, L.L.C. Complied Financial Statements, Years Ended December 31, 2000 and 1999; (5) Air Apparent, L.L.C. Balance Sheet, As of March 25, 2003; (6) Shadrack, L.L.C. Compiled Financial Statements, Years Ended December 31, 2002 and 2001. Gulf & Caribbean also requests confidential treatment for  the enclosed Gulf & Caribbean Cargo, Inc. Projected Statement of Operations, Twelve Months Ended November, 2004, which is being submitted to the Department for the first time in response to the Department's October 30 request.

Gulf & Caribbean notes that the Department has indicated that it is disinclined to grant confidential treatment to historic and current financial statements. Accordingly, Gulf & Caribbean does not request confidential treatment for its historic or current financial statements. Gulf & Caribbean does, however, request confidential treatment for the historic and current financial information of Air Apparent, LLC and Schadrack, LLC as these entities are not holders of the certificate that is the subject of the request and merely agreed to permit the Department to consider their detailed financial information in order to facilitate the Department's evaluation of Gulf & Caribbean's fitness to conduct operations with large aircraft.

September 17, 2003

Re: Gulf & Caribbean Cargo

Gulf & Caribbean is currently seeking an amendment of its Operations Specifications adding the Convair-5800 aircraft to the list of aircraft authorized to be operated by it in the conduct of its Part 121 operations and it will submit evidence of same as soon as the amendment is approved by the FAA. As to the updated fitness information, Gulf & Caribbean hereby incorporates by reference the detailed financial information recently submitted by it and Air Apparent in connection with the recent acquisition of Gulf & Caribbean. In addition, Gulf & Caribbean supplements this recent filing by submitting herewith a pro forma income statement for Gulf & Caribbean for twelve months ending March 2004 reflecting all-cargo operations with Convair-580 and Convair-5800 aircraft. These Gulf & Caribbean operations are projected to be profitable.

October 21, 2003

Re: Gulf & Caribbean Cargo

You requested a current balance sheet and income statement for Gulf & Caribbean and they are enclosed hereunder as Exhibit 1. As of August 30, 2003 Gulf & Caribbean had reduced its retained deficit by over $101,300.00 to $350,208.06 and had achieved a net profit of $101,341.34. Gulf & Caribbean expects to be able to further enhance its profit opportunities by operating the slightly larger Convair-5800 aircraft compared to the Convair-580 currently in the Gulf & Caribbean fleet. FAA approval of the addition of the Convair-5800 aircraft to the Gulf & Caribbean operations specifications is expected shortly.

December 16, 2003

Re: Gulf & Caribbean Cargo

The DOT has requested clarification about the steps taken by Gulf & Caribbean to separate itself from the operations of its related company, the Part 125 operator, Contract Air Cargo. The DOT is correct in observing that at the time Gulf & Caribbean was being acquired by the owners of Contract Air Cargo that Gulf & Caribbean would continue to be based in and operated out of Ft. Lauderdale, Florida while Contract Air Cargo is based in Pontiac, Michigan. The DOT is also correct that the Convair-5800 aircraft that is being leased by Gulf & Caribbean from IFL Group, Inc. states that the aircraft will be based at Pontiac, Michigan airport.

In the case of Gulf & Caribbean and Contract Air Cargo, there is no case where a customer that is attracted to Gulf & Caribbean by virtue of any holding out is turned over to Contract Air Cargo. In fact, just the reverse situation applies. If Contract Air Cargo receives a request, unsolicited by it, that it cannot satisfy under the operating limits of Part 125, it may refer the matter to Gulf & Caribbean. Gulf & Caribbean does not refer calls to Contract Air Cargo. Under these tightly controlled circumstances, Gulf & Caribbean does not believe that the possible physical location of the aircraft at the Contract Air Cargo facility has any regulatory significance.

Counsel: Silverberg Goldman, Robert Silverberg, 202-944-3300

OST-96-1023 - Amendment to Its Certificate of Public Convenience and Necessity

December 22, 2003

Re: Form 6410

Further to my letter dated December 16, 2003, enclosed please find an updated OST Form 6410 evidencing insurance coverage for the Convair‑5800 aircraft to be operated by Gulf & Caribbean Cargo, Trio, provided it receives authority from the Department to conduct operations with large aircraft.

Counsel: Silverberg Goldman, Robert Silverberg, 202-944-3300

January 20, 2004

Re: Response of Gulf & Caribbean to Information Request

This is in response to your e-mail to me in my capacity as counsel for Gulf & Caribbean Cargo, Inc. dated January 5, 2004 asking whether as a result of the acquisition of G&C there were any substantial changes in the operations of G&C. In your e-mail you note that G&C aircraft, according to the FAA, have been operating out of Pontiac, Michigan and that this information would indicate that the operations of G&C may have changed since its acquisition in 2003 by Air Apparent.

Counsel: Silverberg Goldman, Robert Silverberg, 202-944-3300, rsilverberg@sgbdc.com

OST-96-1023 - Amendment to Its Certificate of Public Convenience and Necessity

February 24, 2004

Motion for Confidential Treatment Pursuant to Rule 12

Since its September 17, 2003 request, Gulf & Caribbean has on three occasions provided additional information to the Department to enable it to assess the fitness of the carrier to conduct operations with large aircraft. Most recently, by letter dated January 20, 2004, Gulf & Caribbean provided a detailed list of the flights it had conducted between April 2002 and December 2003 using a Convair 580 aircraft leased from the IFL Group, Inc. The detailed flight information, which is the subject of this Motion, was submitted in response to the Department's inquiry concerning whether the carrier had undergone a substantial change in its operations after its acquisition in 2003 by Air Apparent, LLC.

On February 13, 2004, the Department requested that Gulf & Caribbean file the January 20, 2004 letter in the above referenced Docket and submit a Rule 12 motion if Gulf & Caribbean desired confidential treatment for the flight information.

Counsel: Silverberg Goldman, Robert Silverberg, 202-944-3300, rsilverberg@sgbdc.com

OST-96-1023 - Request for Effective Large Aircraft Authority

March 1, 2004

Re: Intent to Reissue Certificate

We have reviewed the information submitted by G&C in support of its fitness to conduct operations with the large aircraft at issue and find, based on this review, that the company appears fit for such operations, subject to restrictions. Further, G&C has submitted evidence that it has obtained the requisite insurance for its large aircraft operations. Therefore, the only outstanding requirement that must be met before we can make G&C's certificate authority effective for large aircraft operations is our receipt of evidence that the FAA has amended the carrier's Operations Specifications to add the aircraft at issue.

The purpose of this letter is to advise you of our intent to reissue G&C's interstate and foreign certificates reflecting. the effectiveness of the large aircraft authority (cargo only) contained therein upon G&C' s receipt of the amended Operations Specifications noted above. However, as is our current practice, we will limit the number of large aircraft authorized to that presented in G&C's September 17, 2003, filing, as this reflects the basis for our fitness determination. Therefore, G&C will not be able to operate more than one large aircraft under the reissued certificate without obtaining further approval from this office. Of course, this aircraft number limitation does not in any way restrict G&C's ability to operate small aircraft. The company is free, and will remain free, to conduct unlimited operations using small aircraft.

By: Air Carrier Fitness, Janet Davis

OST-96-1023 - Certificates of Public Convenience and Necessity, Interstate/Foreign Scheduled Combination

March 9, 2004

Re: Ruling on Request for Confidential Treatment Documents

We agree that the aircraft lease, financial statements for Shadrack and Air Apparent, and detailed list of G&C markets served meet the criteria for confidential treatment and, as a result, we will grant such treatment under Rule 12 to these exhibits in their entirety. Further, while it is generally not the Department's practice to withhold from public disclosure information regarding an applicant's projected income statements, we believe that, in this case, it is appropriate. G&C is an operating air carrier and its projected income statements reflect not only its proposed large aircraft operations, but also its ongoing all‑cargo operations with small aircraft. Further, because its proposed large aircraft operations will not differ markedly from its current operations, release of its projections could place it at a competitive disadvantage. Therefore, we will also grant confidential treatment to the projected income statements submitted on December 16, 2003, pursuant to Rule 12.

By: Air Carrier Fitness Division, Janet Davis

OST-96-1960

July 27, 2004

Re: Family Assistance Plan

Counsel: Silverberg Goldman, Robert Silverberg, 202-944-3300

OST-96-1023 - Amendment to Its Certificate of Public Convenience and Necessity

October 13, 2004

Motion for Confidential Treatment Pursuant to Rule 12

In a letter being filed contemporaneously with this Motion in the above-referenced Docket, the undersigned counsel advised the Department of Gulf & Caribbean's intent, subject to the receipt of all necessary DOT, FAA and other third party approvals, to conduct operations under its certificate of public convenience and necessity with aircraft currently being operated by its affiliated companies, Contract Air Cargo, Inc., a FAR Part 125 operator, and IFL Group, Inc., a FAR Part 135 carrier. In connection with the notification to the Department of Gulf & Caribbean's intent to operate additional aircraft and to enable the Department to assess the financial fitness of the carrier to do so, copies of the most recent financial statements of Gulf & Caribbean and the IFL Group, Inc. are being submitted to the Department under seal with this Motion. Also being submitted to the Department under seal with this Motion is a pro forma balance sheet and income statement for Gulf & Caribbean for the 12 months ended December 31, 2005. Also enclosed is financial information for the ultimate parent of Gulf & Caribbean, Shadrack, LLC, a privately held company.

Counsel: Silverberg Goldman, Robert Silverberg, 202-944-3300, rsilverberg@sgbdc.com

OST-96-1023 - Amendment to Its Certificate of Public Convenience and Necessity

October 13, 2004 | Docketed November 15, 2004

Re: Letter Describing Intent to Exercise Air Transportation Right

Gulf & Caribbean Cargo, Inc. hereby advises the Department of Transportation that, immediately upon receipt of all necessary DOT, FAA and other third party approvals, Gulf & Caribbean will exercise its right to conduct air transportation pursuant to the Gulf & Caribbean certificate of public convenience and necessity (issued pursuant to Order 98-12-15) with the aircraft listed in Attachment A to this letter. The listed aircraft are currently being operated by Gulf & Caribbean affiliated companies, Contract Air Cargo, Inc., a Federal Aviation Regulation Part 125 operator and IFL Group, Inc., a FAR Part 135 carrier.

Counsel: Silverberg Goldman, Robert Silverberg, 202-944-3300

OST-96-1023 - Amendment to Its Certificate of Public Convenience and Necessity

November 17, 2004

Supplemental Submission of Documents Pursuant to Rule 12

In connection with the Air Carrier Fitness Division's review of the issues presented by Gulf & Caribbean's request, the carrier has been requested to submit to the Department additional historic financial information for itself and for the privately held affiliated companies, IFL Group, Inc. and Shadrack, LLC. Gulf & Caribbean is pleased to respond to this request and is submitting the requested financial information under cover of the instant motion.

Counsel: Silverberg Goldman, Robert Silverberg, 202-944-3300, rsilverberg@sgbdc.com

OST-96-1023 - Amendment to Its Certificate of Public Convenience and Necessity

December 1, 2004

Re: Ruling on Motion for Confidential Treatment

Absent extenuating circumstances, it is not the Department’s practice to withhold from public disclosure information regarding an applicant’s current or historical financial condition, pre-operating cost forecasts, proposed operating plans and related statistics, first-year operating cost forecasts, and forecast balance sheets reflecting these forecasts, and G&CC has provided no information that persuades us that we should do so here. When requested, however, the Department will generally grant confidential treatment to information pertaining to a company’s forecast revenues (and related statistics).

Therefore, we will deny confidential treatment to G&CC’s December 31, 2003, financial statements as well as the forecast consolidated G&CC balance sheet at December 31, 2005. We will, however, grant confidential treatment to the Projected CY 2005 Income Statement (Attachment C to your October 13 letter) provided that G&CC place on the public record a first-year forecast of all of the expenses to be incurred (including an explanation as to how such forecast expenses have been derived) in conjunction with the large aircraft operations for which the company is seeking effective certificate authority.

We will also grant confidential treatment to the remaining information for which such treatment is requested. These documents, which pertain to affiliated companies, are similar to those provided previously by G&CC for which confidential treatment was granted and we believe it appropriate to do so here.

By: Patricia Thomas

December 1, 2004

Re: Request for Additional Information

We ask that G&CC provide the information contained in the enclosed Information Request within 21 days of the date of this letter. The original plus 6 copies of your response should be filed in Docket OST-96-1023. Given the changes planned by G&CC, we would not propose to authorize it to commence large aircraft operations until we have received and reviewed the requested material. If G&CC wants to request confidential treatment for any of the information provided in response to this letter, it should use the procedures set out in section 302.12 of our rules. In addition, we remind Gulf & Caribbean that it should promptly provide the Department with any information regarding changes it may undergo in other areas affecting its fitness (i.e., management, operating plans or financial condition, compliance disposition, or ownership) while its request for effective large aircraft authority is under review by the Department.

By: Qwynn Dolmo

OST-96-1023 - Amendment to Its Certificate of Public Convenience and Necessity

December 6, 2004

Re: Additional Information

These documents are being filed in the public Docket in response to the December 1, 2004 letter of Patricia L. Thomas to the undersigned, which denied confidential treatment of these documents. Gulf & Caribbean had previously submitted these documents to the Department under Rule 12 motions for confidential treatment on October 13 and November 17, 2004, respectively.

Counsel: Silverberg Goldman, Robert Silverberg, 202-944-3300, rsilverberg@sgbdc.com

OST-96-1023 - Amendment to Its Certificate of Public Convenience and Necessity

December 14, 2004

Re: Additional Information

This letter is in response to your letter dated December 1, 2004 requesting additional information concerning the operating plans of Gulf & Caribbean Cargo, Inc. in connection with the carrier's request to operate additional large aircraft pursuant to its certificate of public convenience and necessity most recently reissued by Order 98-12-15. The undersigned made this request on behalf of Gulf & Caribbean and provided certain information on the carrier's proposed operations in a letter to the Director of the Air Carrier Fitness Division dated October 13, 2004. On November 17, 2004, the undersigned provided additional historic financial information on Gulf & Caribbean and two affiliated companies, IFL Group, Inc. and Shadrack, LLC. The undersigned is now responding to the specific requests for additional information in your December 1, 2004 letter.

Counsel: Silverberg Goldman, Robert Silverberg, 202-944-3300, rsilverberg@sgbdc.com

December 14, 2004

Motion for Confidential Treatment

By this Motion, Gulf & Caribbean requests confidential treatment for the additional financial information for one of its affiliated companies, Shadrack, LLC, which is being submitted in response to the Department's December 1, 2004 request for additional information. Gulf & Caribbean incorporates by reference the reasons and arguments set forth in its Rule 12 Motion of October 13, 2004  as justification for the request to treat the  enclosed information (filed under seal pursuant to Rule 12) as confidential.

Counsel: Silverberg Goldman, Robert Silverberg, 202-944-3300, rsilverberg@sgbdc.com

OST-96-1023 - Amendment to Its Certificate of Public Convenience and Necessity

December 21, 2004

Re: Two Supplemental Type Certificates

Enclosed please find two Supplemental Type Certificates issued by the FA on December 20, 2004 approving the installation of traffic collision avoidance systems and enhanced ground proximity warning systems required to be installed on Gulf & Caribbean's Convair--5800 aircraft in order to operate the aircraft under Part 121 of the FAR's. Convair model 340/440 aircraft are also commonly known as Convair-5800 aircraft-the aircraft designation used by Gulf & Caribbean and previously used by CAC and referred to in my prior correspondence to the DOT in this matter.

With the issuance of the enclosed STC's, the Convair5800 aircraft are now capable of being added to the Gulf & Caribbean operations specifications. The DOT previously conditionally granted Gulf & Caribbean authority to add one such aircraft to its fleet in accordance with the Department's letter to the undersigned dated March 1, 2004. The authority was made conditional upon the receipt of Gulf & Caribbean's amended operations specifications listing the single Convair-5800 aircraft. This document will be submitted to the Department under separate cover. The addition of the two other Convair-5800 aircraft to Gulf & Caribbean's operations specifications is pending approval from the Department for the carrier to operate more than one additional large aircraft pursuant to its certificate of public convenience and necessity.

Counsel: Silverberg Goldman, Robert Silverberg, 202-944-3300, rsilverberg@sgbdc.com

OST-96-1023 - Amendment to Its Certificate of Public Convenience and Necessity

January 4, 2005

Re: Current Operations Specifications

Enclosed please find the current Operations Specifications of Gulf & Caribbean indicating  that the carrier has been authorized by the FAA to conduct operations under Part 121 of the FAR’s with a single Convair-5800 aircarft.

Counsel: Silverberg Goldman, Robert Silverberg, 202-944-3300, rsilverberg@sgbdc.com

OST-96-1023 - Amendment to Its Certificate of Public Convenience and Necessity

January 6, 2005

Re: Response to Questions from Air Carrier Fitness

This letter is in response to the questions contained in your January 5, 2005 e‑mail regarding the additional information we submitted to the Department on behalf of Gulf & Caribbean Cargo, Inc. on December 14, 2004 to facilitate the Department's review of the carrier's request to operate additional large aircraft pursuant to its certificates of public convenience and necessity most recently reissued by Order 98‑12‑15.

Counsel: Silverberg Goldman, Robert Silverberg, 202-944-3300, rsilverberg@sgbdc.com

OST-96-1023 - Amendment to Its Certificate of Public Convenience and Necessity

January 10, 2005

Re: Clarification of Response to Questions from Air Carrier Fitness

In response to question No. 9 of the Department's December 1, 2004 letter requesting additional information for its review of the fitness of Gulf & Caribbean Cargo, Inc. to operate additional large aircraft, I attached to my December 14, 2004 response pages from the Comerica Bank website indicating that Gulf & Caribbean and its related companies, IFL Group, CAC and Shadrack had certain cash balances in their Comerica Bank accounts.

Specifically, the webpage provided to the Department for the IFL Group showed that the company had an available balance of $5,292,827 in its bank accounts. I also indicated in my December 14 letter that the IFL Group has a $12 million line of credit with Comerica Bank that will be available to Gulf & Caribbean post-consolidation.

Counsel: Silverberg Goldman, Robert Silverberg, 202-944-3300, rsilverberg@sgbdc.com

OST-96-1023 - Amendment to Its Certificate of Public Convenience and Necessity

January 21, 2005

Re: Request for Additional Information

After speaking with Bob, we've determined that the most pressing matter is to get the one large A/C added to the certificate. In reviewing the information that you submitted. I have a few follow up questions.

By: Air Carrier Fitness, Qwynn Dolmo

Gulf & Caribbean Cargo, Inc. d/b/a IFL Group

OST-95-236 - Warsaw Agreement

March 1, 2005

Re: Counterpart to Warsaw Agreement

By: Michael Church

March 8, 2005

Notice of Registration of Trade Name

On March 1, 2005, Gulf & Caribbean Cargo, Inc., a certificated air carrier, requested that the Department register the trade name "IFL Group" for use in certain of its air transportation operations.

By: Randall Bennett

OST-1996-1023

July 12, 2005

Re: Add an Additional B727

Gulf & Caribbean Cargo, Inc. d/b/a IFL Group hereby seeks authority from the Department of Transportation to add one additional Boeing 727 cargo aircraft to its Operations Specifications and conduct operations with said aircraft pursuant to its certificates of public convenience and necessity.

Gulf & Caribbean now seeks authority from the Department to conduct operations under its certificates of public convenience and necessity with a third B-727 aircraft. Gulf & Caribbean requests this authority to enable it to place a third B-727 aircraft on its operations specifications so that the carrier is able to continue to provide service with two B-727 aircraft while one of its other B-727 aircraft is removed from service for a scheduled WCI check. One of the two Gulf & Caribbean B-727 aircraft that are currently on its Operations Specifications is scheduled to undergo a C" check on August 1, 2005 that will require the aircraft to be removed from service for a minimum three-month period. Gulf & Caribbean seeks this additional authority from the Department in order to amend its FAA-issued Operations Specifications to add a third B-727 aircraft to be utilized by the carrier while the other B-727 aircraft undergoes the 'C" check. At no time does Gulf & Caribbean intend to simultaneously conduct operations with three B-727 aircraft and is only seeking the authority requested herein to ensure that it has sufficient capacity to meet the demands of its customers during the three-month period that its other B-727 aircraft will be out of service.

Counsel: Silverberg Goldman, Robert Silverberg

OST-1996-1023 - Amendment to Its Certificate of Public Convenience and Necessity

January 17, 2006

Requesting Authority to Conduct Operations Under Certificate with Three Boeing 727s

By letter dated August 1, 2005, the Department approved a July 12, 2005 request of Gulf & Caribbean for authority to conduct operations under its DOT certificates with a third B-727 aircraft to replace one of the carrier's two other B-727 aircraft that was then scheduled to undergo a "C" check. In its July 12 request, Gulf & Caribbean explained that it did not intend to conduct simultaneous operations with three B-727 aircraft, but was only seeking authority from the Department to enable the carrier to continue to provide service with two B-727 aircraft while one of its other B-727 aircraft was removed from service for a scheduled "C" check.

Gulf & Caribbean now seeks authority from  the Department to conduct simultaneous operations under its DOT certificates with a total of three B-727 aircraft. Gulf & Caribbean has recently experienced a substantial increase in demand from its customers for services with its B-727 aircraft. By granting this request, the Department will help to ensure that Gulf & Caribbean will have sufficient capacity to satisfy the future demands of its customers.

Counsel: Silverberg Goldman, Robert Silverberg, 202-944-3300

Order 2006-1-15
OST-1996-1023 - Amendment to Its Certificate of Public Convenience and Necessity
OST-1996-1071 - Interstate and Overseas Scheduled Air Transportation

Issued and Served January 19, 2006

Order Confirming Oral Actions and Reissuing Certificates - Bookmarked

By this order, we (1) confirm our oral action of January 11. 2005, making the authority of Gulf & Caribbean Cargo, Inc. d/b/a Gulf & Caribbean Air d/b/a IFL Group to operate large aircraft in interstate and foreign scheduled air transportation of property and mail effective on that date, (2) reissue its interstate and foreign scheduled certificates to reflect this authority (3) authorize the carrier to operate up to five large aircraft in all‑cargo operations.

On October 13, 2004, G&CC requested that the Department make its certificate authority effective for large aircraft. G&CC stated that it sought to dissolve an affiliated Part 125 operator, CAC, and transfer two B-727 and three Convair 5800 aircraft previously held by CAC to G&CC. G&CC provided a forecasted income statement based on its first year of all-cargo operations using five large aircraft. G&CC also provided a list of the pre-operating expenses associated with adding the five aircraft to its FAA operating specifications. G&CC stated that it would incur approximately $1.8 million in pre-operating expenses and first year operating expenses of approximately $10,067,000. We found these projections to he reasonable and concluded that G&CC would need access to approximately $4.3 million to meet the requirements of our financial fitness test. On January 5, 2005, G&CC provided third-party verification that it had access to funds in excess of that amount.

By: Todd Homan

OST-1996-1023 - Amendment to Its Certificate of Public Convenience and Necessity

January 25, 2007

Request to Add One Additional Large Cargo Aircraft

Gulf & Caribbean Cargo, Inc. d/b/a IFL Group hereby seeks authority from the Department of Transportation to add one additional large cargo aircraft to its Operations Specifications and conduct operations with the additional large aircraft, pursuant to its certificate of public convenience and necessity.

As you know, Gulf & Caribbean currently possesses authority from the Department to conduct operations under its certificate of public convenience and necessity with a total of six large aircraft. Gulf & Caribbean's certificate authority also allows it to conduct operations with an unlimited number of small aircraft. See Order 2006-1‑15.

Gulf & Caribbean requests this authority to enable it to place a fourth Convair 5800 aircraft on its FAA-issued Operations Specifications so that it is able to continue to provide service with a total of six large aircraft as one of its existing aircraft has recently been removed from service for a "C" check.

Counsel: Silverberg Goldman, Robert Silverberg, 202-944-3300

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