Mr. Damon Walker 

Air Carrier Fitness Division 

Department of Transportation 

1200 New Jersey Avenue., S.W. 

Washington, D.C. 20590 

Re· Application of Dynamic Airways, LLC. Docket DOT· 

OST·2014-0069 .. Response to Information Request 

Dear Mr. Walker: 

This will respond to your email to me dated January 22, 2015, requesting a few additional 

items to complete the fitness showing by Dynamic Airways in support of its pending application 

for scheduled certificate authority. 

1. A letter from Kenneth Wooley and Paul Kraus. attesting that they are prepared to 

increase their commitment to provide capital to Dynamic up to $18 million, is attached 

as Exhibit 1. 

2. A profit and loss statement for the 12-month period ending November 2014 is attached 

as Exhibit 2. 

3. Regarding the compliance information for Mr. John Mullin and Mr. Dennis Conner, as 

required by section 201.3(1), (m), (o), (p) and (q), Dynamic states as follows: there are 

no outstanding judgments or pending actions against either Mr. Mullin or Mr. Conner; 

nor are there any investigations, enforcement actions or formal complaints by the 

Department, including the FAA, pending against either of them or any relevant 

corporation; nor have there been any charges of unfair or deceptive or anticompetitive 

business practices, or of fraud, felony or antitrust violation brought against either of 

them, or any relevant corporation. in the last 10 years; nor has either of them, or any 

relevant corporation, experienced an aircraft accident or incident in the past year, or 

previously and which is still under investigation. Mr. Conner is a U.S. citizen; Mr. 

Mullins is a Canadian citizen. 

4. Attached as Exhibits 3 and 4 are revised forecast income statements (assuming a fiveaircraft fleet and an expanded fleet, respectively), amended to show the calculation on 

which revenue projections previously submitted are based. A word of explanation on 

this point is in order. The specific revenue elements contained in section 204.3(t)(2) 

are not all applicable to Dynamic's particular business model - at least for the 

operations contemplated in this forecast. For its cargo service to South America, the 

carrier is being paid a guaranteed rate per hour under an agreement with 21 Air/Solar 

16271 Street, NW Suite 1100 Washington, D.C. 20006 

202.912.4800 800.540.1355 202.861 .1905 Fox cozen.com 
p

y 

p

g

, 

y

p

hourly rate. With scheduled authority, the carrier will be able to sell any individual 

seats available, as well as sell the transportation to US-originating passengers. 

However, the forecasts are based on the guarantee arrangement in place with the 

Chinese entities; additional passengers booked would simply be extra revenue. And 

while the JFK-Georgetown flights are sold directly by Dynamic, the carrier has 

calculated its costs and revenues on a block-hour basis, based on historic 

performance, which is the method with which it is most familiar. For this reason, 

estimates of numbers of passengers and tons of cargo would simply be conjecture, 

and would not be relevant to how Dynamic has estimated its revenue. 

5. DA2 is no longer an owner of Dynamic Airways. On October 9, 2014, DA2 sold its 

ownership interest, in equal amounts, to Mr. Woolley and Mr. Kraus, making them 

each 50 percent owners of the carrier. 

6. Attached as Exhibit 5 is a copy of the complaint filed in Rambarran v. Dynamic 

Airways, LLC, 14-c-v-10138-CS-PED. As we indicated in our previous letter, the 

carrier considers this complaint to be without merit, and it is defending the matter 

vigorously. 

7. The list of key personnel that you provided is correct, except for the following: 

Herman Gillis is no longer with Dynamic. The new Director of Operations is Mr. Don 

Dodson. Supporting information on Mr. Dodson is contained below, and his resume 

is attached as Exhibit 6. 

The position of Comptroller has been abolished; those functions are now subsumed 

under the Chief Financial Officer. The position of V.P. Operations has also been 

abolished, and those functions are now subsumed under the Director of Operations. 

Mr. Dodson is a citizen of the United States. There are no outstanding judgments or 

pending actions against him; nor are there any investigations, enforcement actions or formal 

complaints by the Department, including the FAA, pending against him or any relevant 

corporation: nor have there been any charges of unfair or deceptive or anticompetitive business 

practices, or of fraud, felony or antitrust violation brought against him, or any relevant 

corporation, in the last 10 years; nor has Mr. Dodson, or any relevant corporation, experienced 

an aircraft accident or incident in the past year, or previously and which is still under 

investigation. 
Cc. Ms Lauralyn Remo 

Docket OST-2014-0069 

MWA:dmp 

Mark W. Atwood 

Counsel for Dynamic Airways, LLC 
ivlr. Damon Walker 

A1r Carrier Fitness Di\'ision 

Dcpru1ment of Transportation 

1200 1\:cw Jersey Ave., SE 

Washin~ton, DC 205()0 

Rc: financial guarantee for scheduled authority 

lJear Mr. Walker: 

By letter submitted with our Amended Application dated October 10. 20 14, we provided 

assurances of the availability of$15 million to fund the startup and first year of Dynamic 's 

scheduled passenger services. 

In light of the changed service propo~; , the required amount hac; been recalculated as 

S 18 million: $100,000 for stati~m expenses, $35,000 for regulatory costs. S 1.57 million !or 

proving nms. $10.8 million lor three months' operating expense, nnd $5.46 million to rectify 

negutiw working capital. 

We therefore confirm that we will personally lonn or invest, through various entities we 

individunlly own, $18 million to guanmtee Dynamic's ability to meet the three-month limu1cial 

litncss test. 

Sincerely. 

~~ 

Paul Kraus 

----·--------------------------J 
Expense 

2500 · Other Expenses 

5010 ·Sales Commissions 

5020 · Jet Asia Partner 

5037 · Guyana Contract Labor 

5038 • Labor • Other 

5039 · Contract Labor • Other 

5040 · Payroll Tax Exp 

5045 · Payroll Tax Exp • FUTA 

5055 ·Insurance. Health/Disability 

5056 · Insurance • Dental 

5057 · Insurance • Life 5060 • Insurance -Workers Comp 

5063 · Employee Medical Costs 

5065 ·Employee Uniforms 

5070 · Retirement Plan Contrlb & Match 5080 · Employee Housing • Rent 5082 • Employee Housing - Phone/Utlllt 

5095 · Employee Benefits· Mise 

5120 · Supplies. Non-Aircraft 

5125 · lnfllght Supplies 

5130 ·Tools Expense 

5140 • Pilot Expenses 

5190 ·Office Supplies 

5195 ·Computer Supplies 

5204 · Maintenance Expense 

5205 • R&M • Consumable AC Supplies 

5210 • R&M ·Parts, Overhaul, etc. 

2.240.916.19 20,124 00 

2,285.825 81 

247.600 00 

7,191.942 03 

1,706,376 68 

910 272 25 

5.431 16 

487,35111 

517 43 

14664 

26.941 00 

5.326 03 

38 366 90 

181 .44 

11 504 75 

1 521 52 

8 997 57 

13 366 49 

212.154 32 

22.017 10 

75.663 02 

67.195.93 

10,982 70 170,404 72 

157,317.49 

1.938.376 06 
5275 · R&M ·Vehicles & Trailers 

5280 · R&M • Buildings 

5282 · R&M ·Grounds 5290 · R&M ·Office Equipment 5293 · Flight Dispatch Software 

5294 · Computer Support Agreements 

5295 • Flight Safety Software 

5310 • AJC Fuel 

5329 • Other Fuel 

5310 • AJC Fuel· Other 

Total5310 · AJC Fuel 

5330 • Shipping 

5331 ·Postage 5350 · Insurance· Aviation 

5360 · Insurance· Vehicles 

5410 · Depreciation. Vehicles 

5415 ·Depreciation ·Shop Equipment 

5420 • Depreciation· Office Equipment 

5500 · Airfare 

2,795 49 

5,049 04 

974 88 

093 

207.328 95 

152.139 13 

9 254 69 8.107 425 27 86 816 42 

12 821 197 99 

2101543968 

322 844.57 

1 183 09 

518,768 11 

1.151.29 

914.15 

1,871 .88 

65.660.15 
5501 ·Airfare- Passenger Rebooklngs 

5510 ·Travel- Per Diem- Meals 

551 0-01 · Pilots Per Diem 551 0-02 • FA Per Diem 551 0-03 • MX Per Diem 

5510-05 ·Other Per Diem 

5510 · Travel - Per Diem -Meals -Other 

Total5510 ·Travel- Per Diem- Meals 

5515 • Travel - Lodging 

5515-01 • Pilots 

5515-02 ·FA 

5515-03 • Mx 5515-04 • Mgmt 5515-05 · Others 5515-06 • Passengers 5515-07 • Hajj 

5515 • Travel - Lodging -Other 

Total5515 ·Travel- Lodging 

5520 • Travel - Other 5545 • Meals & Entertainment 

5550 • Telephone/Internet Exponso 5555 ·Telecommunications/Coli Phones 5570 • Utilities 

5600 · Advance Deposit 5610 ·Vehicle Fuel 

5620 • Vehicle Rental 5630 • Landing Fees 

5631 ·Air Bridge Charge 

5632 ·Ground Handling 

5633 ·Parking· Aircraft 

5635 · Airway Charges 

5650 · Catering 

5651 ·Foes 5650 · Catering - Other 

Total 5650 ·Catering 

30,167 20 

6.760 00 

60.675 29 

2.410 00 25.390 55 

362.664 75 

456.100 59 

17.622 83 

443 54 

6.261 64 

29.097 24 

25.564 67 

22.161 92 

264,610 40 

636.666 51 

1,004,466.75 146.661 24 

20 297 43 

33.309 93 309,620 30 36 636 19 

20 000 00 

34 027 52 

84 953 88 

370 565 78 

2.768 87 

3.413.485 36 

22 991 02 

306177 69 

1264935 

459 713 36 472 362 71 
5700 · Dues & Fees 

5701 ·Membership Fee 

5705 · Visas/Work Permits/Fees 

5710 · Subscriptions & Manuals 

5715 · Fines/Penalties 5720 · Bank Charges 

5721 • Merchant Processing Fees 

5740 ·General Advertising 

5745 ·Printer Fees 

5750 · Professional Fees 

5751 · Legal Fees 

5755 ·Consulting Fees 

5756 · Flight Planning 

5757 · Overflight 

5775 · Sales/Use Tax 

5776 · Import Tax 

5800 • Training 5810 ·Employment Advertising 

5815 • Employment Recruiting Costs 

5820 ·Employee Moving Expenses 

5990 • Miscellaneous Ellpense 

6100 ·Aircraft Lease 

6105 ·Engine Reserve 

6400 · Airframe Lease 6600 · Payroll Expenses 

7050 • Passenger Fees • USA 

7051 · Passenger Fees 

7055 ·Passenger Fees· CNMI 

7056 ·Passenger Foes · GUAM 

7060 ·Passenger Foes . CHINA 

Total Expense 

Not Ordinary Income 

Other Income/Expense Other Income 

7410 ·Gain/Loss- Asset Dispositions 

Total Other Income 

December 2013 throuah November 2014 

D"ec '13- Nov 14 Net ( lthcr lnwmc 

I X ()(,;!,II,.; 611 

69,917.31 

10.000 00 

41 ,762.46 

257.844 22 2,197.37 

45,152.46 

911 ,920 53 93,901 .54 

22.656.44 242.305 25 

426,789.70 491 ,324 61 

56.434 .45 5,330 95 

9 684 81 

484.333 31 

1.865 00 

25,900 77 

24.603 65 

1,084.329 62 

829,989 50 

698.95100 

13,414.46 116.595 23 

65,052.65 

127,695 42 

34.697 96 

150 372 28 

55.626,355.58 

(18,660,155 52) 

2 010 08 2 010 08 

16 00 

96.00 
REVENUE 

Cargo/Passenger AC a Mo . 

Cargo . Passenger 

TOTAL REVENUE 

EXPENSE2 

lease Payments' 

Admon & Operations Mgmt• 

Floght Crew Labors 

AJC Mainlenance6 

Traonmg & Staff Developmene 

Fhght Operations Oospatch8 

Aorcralt lnsurance9 

Jet Fuel ~ 

Airport. Statoon. Landong Fees" 

CatenngJPassenger Expense'' 

Crew Travel Expenditures'

1 

F acohtiesJOfficefAdmon Expense 

Professoonal Fees ~ 

Communocatoons Systems '

6 

TOTAL EXPENSE 

NET INCOME 

on thousands 

CARGO 

Number of Atrcraft 

Hours Per AC 

Operating Fee 

Exp Retmbursement 

Passenger 

Number of Aircraft 

Hours Pet AC 

Rev/Hr 

Scheduled Gross Rev 

Dynamic Airways 

Projected Income Statement 

December 2014- November 2015 

(Five Aircraft Fleet) 

in thousands 

2015 

DEC JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV 

2/3 2/3 2/3 2/3 2/3 2/3 2/3 2/3 2/3 2/3 2/3 2/3 

2,101 2,101 2,101 2,101 2,101 2.101 2 101 2,101 2,101 2.101 2.101 2,101 

4,589 4,569 4,589 4,569 4,589 4,569 4.569 4.589 4 589 4,569 4,569 4,589 

6,690 6,690 6,690 6,690 6,690 6,690 6,690 6,690 6,690 6,690 6,690 __ 6,690 

176 176 176 176 176 176 176 176 176 176 176 176 

187 187 192 192 197 197 207 207 207 207 207 207 

311 311 311 311 311 311 311 311 311 311 311 311 

650 650 650 650 650 650 650 650 650 650 650 650 

157 10 21 136 - - 112 10 5 10 11 . 98 39 36 36 36 36 96 37 37 37 37 37 

144 143 140 144 143 144 143 144 144 143 144 143 

3,057 3,057 3,057 3,057 3,057 3,057 3,057 3,057 3,057 3,057 3,057 3 057 

353 352 559 626 628 626 628 628 626 628 628 626 

158 153 155 158 158 158 158 160 161 161 161 161 

93 93 93 152 152 152 152 219 219 219 219 219 

71 71 71 71 71 71 71 71 71 71 71 71 

22 22 22 22 22 22 22 22 22 22 22 22 

17 16 16 17 16 16 17 17 17 16 17 17 

5,494 5,279 5,498 5,750 5,616 5,618 5,799 5,708 5,704 5,708 5,710 5,698 

1,195 1,411 1,192 939 1,073 1,072 890 982 986 981 979 992 

Revenue assumptions basis of calculations 

DEC JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV 

31 30 28 31 30 31 30 31 31 30 31 30 

Cargo Cargo Cargo Cargo Cargo Cargo Cargo Cargo Cargo Cargo Cargo Cargo 

s 200 2 2 2 2 2 2 2 2 2 2 2 

$ 160.00 160 160 160 160 160 160 160 160 160 160 160 

50,000 50,000 50000 50,000 50,000 50,000 50,000 50,000 50,000 50,000 50,000 50,000 

2.001 2,001 2.001 2.001 2,001 2,001 2,001 2,001 2,001 2,001 2,001 2,001 

Passenger Passenger Passenger Passenger Passenger Passenger Passenger Passenger Passenger Passenger Passenger Passenger 

3 3 3 3 3 3 3 3 3 3 3 3 

115 115 115 115 115 115 115 115 115 115 115 115 

13,300 13.300 13,300 13.300 13.300 13,300 13,300 13,300 13,300 13,300 13,300 13 300 

4.589 4.589 4,589 4,589 4,589 4,589 4,589 4.589 4,589 4,589 4,589 4 589 

Total 

25.212 

55062 

80,274 

2.112 

2,369 

3 731 

7 799 

470 

562 

1,716 

36,662 

6,919 

1,903 

1.985 

846 

264 

200 

67,583 

12,692 

m 

>< ::1: 

-

ca 

=i 

w 
FOOTNOTES 

Cargo Aercraft @ 6 Pilots and one Mechanic per AC as contracted 

2 cargo/3 passenger aercraft 

3 Revenue only power by the hour lease payments for Cargo Passenger aercraft leases are deferred long term liability 

Salanes for Operateons Management Personnel & Contractors 

Average of 3 0 pilot crews & 14 night attendants per operational aercraf1 monthly 

6 Heavy Checks. en gene mx . LLP's reserved at S700 per block hour and AC rotables. expendables. line mx are reserved at 5300 per block hour 

Pilot. Flight Attendant. Mamtenance. Loadmaster Despatcher Haz Mat. Security & TSA Recurrent Traimng for all personnel 

Fhght Operations Despatchers Flight Plannmg, Flight Track1ng. Aerport Performance Data 

~ Monthly premeum cost on monthly encrease from 5 to t 0 aercraft coverage on an annualized bases 

"' lnternateonal fuel @ 1 450 gallons per hour @ 53 07 per gallon per block f11ght hour 

" Assumes 1 land•ng for 5 flight hours charter and scheduled flights Cargo fuel IS a pass thru 

'

2 Catenng and drmkSisnacks expenses for passengers aM crew for all fl:ghts 

·~ All scheduled crews one home rotat1on monthly Includes all ground transport for f11ght crews 

14 Covers teased Facilities. Storage, Ut1hlles. oH1ce expenses. payroll serv1ces. bank charges. postage, shepp•ng, and m•scellaneous expenditures 

~ Marketing, eng•neering, tech meat. accounting. legal. and av1at1on profeSSIOnal consultants 

"" Telephones. company-w1de cell phones. mternet serv1ces. and a1rcraf1 commumcation systems 
REVENUE 

Cargo/Scheduled AC a Mo 

Cargo ' 

$ Gheduled 

TOTAL REVENUE 

EXPENSE2 

Lease Payments' 

Admon & Operat•ons Mgmt' 

H ghl Crew Labor' 

AJC Maintenance• 

Tra•nong & Staff Development' 

Flight Operations Dispatch• 

Aorcraft lnsurance• 

Jet Fuel" 

Allpof1, Stat1011, Landlllg. Fees" 

Caterong/Passenger Expense 'l 

Crew Travel Expendotures" 

FacohtoesJOfftce/Admin Expense,. 

Professoonal Fees '

5 

Communications Systems .. 

TOTAL EXPENSE 

NET INCOME 

•n thousands 

CARGO 

Number of Atrcraft 

Hours PerAC 

Operating Fee 

ElCp Recmbursement 

Passenger 

Number of Atrcraft 

Hours PerAC 

Rev/Hr 

Scheduled Gross Rev 

Dynamic Airways 

Projected Income Statement 

December 2014- November 2015 

(Expanded Fleet) 

In thousands 

2015 

DEC JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV 

2/3 2/3 2/3 2/3 2/3 2/4 2/4 2/5 2/5 2/6 2/6 2/7 

2,101 2,101 2,101 2,101 2,101 2,101 2,101 2,101 2,101 2,101 2,101 2,101 

4.589 4.589 4,589 7,714 7,714 7,714 7,714 11 ,638 11.638 16,359 16,359 21 ,879 

6,690 6,690 6,690 9,815 9,815 9,815 9,815 13,739 13,739 18,460 18,460 23,980 

176 176 176 176 176 176 176 176 176 176 176 176 

187 187 192 192 197 197 207 207 207 207 207 207 

311 311 311 415 415 415 415 518 518 622 622 725 

650 650 650 953 953 953 953 1,334 1,334 1,792 1,792 2,327 

157 10 21 136 - - 112 10 5 10 11 - 98 39 36 36 36 36 96 37 37 37 37 37 

144 143 140 159 157 159 157 175 175 187 190 202 

3,057 3057 3 057 4,102 4,102 4,102 4,102 5,415 5,415 6 ,994 6,994 8,641 

353 352 559 1,051 1,051 1,051 1,051 1,562 1,582 2,221 2,221 2,968 

156 153 155 240 240 240 240 346 347 471 471 616 

93 93 93 203 203 203 203 366 366 439 439 512 

71 71 71 71 71 71 71 71 71 71 71 71 

22 22 22 22 22 22 22 22 22 22 22 22 

17 16 16 17 16 16 17 17 17 18 17 17 

5,494 5,279 5,498 7,774 7,639 7,641 7,823 10,273 10,269 13,265 13,268 16,720 

1,195 1,411 1,192 2,041 2,176 2,174 1,992 3.465 3,469 5,195 5,192 7,260 

Revenue assum(!tions basis of calculations 

DEC JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV 

3t 30 28 31 30 31 30 3t 31 30 31 30 

Cargo Cargo Cargo Cargo Cargo Cargo Cargo Cargo Cargo Cargo Cargo Cargo 

2 2 2 2 2 2 2 2 2 2 2 2 

160 160 160 160 160 160 160 160 160 160 160 160 

$50.000 $50,000 $50,000 $50,000 $50.000 $50,000 $50,000 $50,000 $50.000 $50,000 $50,000 $50,000 

$2,001 $2,001 $2,001 $2,001 S2 001 $2,001 $2,001 $2,001 $2,001 $2,001 $2,001 $2,001 

Passenger Passenger Passenger Passenger Passenger Passenger Passenger Passenger Passenger Passenger Passenger Passenger 

3 3 3 4 4 4 4 5 5 6 6 7 

115 115 115 145 145 145 145 175 175 205 205 235 

$13,300 $13.300 $13 300 $13,300 $13,300 $13.300 $13,300 $13 300 $13.300 $13 300 $13,300 $13 300 

$4,589 $4,589 $4,569 $7,714 $7,714 $7,714 $7,714 $11 ,638 $11.638 $16 359 $16,359 $21 ,879 

Total 

25.212 

122.493 

~705 

2 112 

2 389 

5596 

14,340 

470 

562 

1,989 

59,239 

16,045 

3,677 

3,211 

848 

264 

200 

110,943 

36,762 

m 

)( 

J: 

-tu 

--4 

.a::a. 
FOOTNOTES 

Cargo A ~reran @ 6 P1lots and one Mx per AC as contracted 

2 cargo/3 passenger aircraft increasing over the twelve months to 2 cargo and 8 scheduled a~rcraft based on contract revenue 

Revenue only power by the hour lease payments for Cargo Passenger aircraft leases are deferred tong term toab:llty 

Salanes for Operations Management PersoMel & Contractors 

Average of 3 0 p1lot crews & \4 flight attendants per operational aircraft monthly 

Heavy Chech. engine mx • LLP's reserved at 5640 per block hour and AC rotables. expendables hne mx are reserved at 5300 per block hout 

Pilot. Flight Anendant. Maintenance. Loadrnaster. D•spatcher. Haz Mat. Secunty & TSA Recurrent Tra1mng for all personnel 

Flight Operahons: Dispatchers. Flight Planning. Flight Tracking, Airport Performance Data 

Monthly premium cost on monthly increase from 5 to \0 aircraft coverage on an annualized baSIS 

10 International fuel@ \,450 gallons per hour@ S3 07 per gallon per block flight hour 

11 Assumes \ tanding for 5 flight hours charter and scheduled llights. Cargo fuel is a pass thru 

12 Catenng and drinks/snacks expenses for passengers and crew for all nights 

1

' All scheduled crews one home rotaion monthly Includes all ground transport for flight crews 

Covers teased Facilities. Storage Utilities. off1ce expenses. payroll services, bank charges, postage, sh1pp1ng. and miscellaneous expenditures 

,. MarkeMg. engineering technical, accounting, legal. and aviat1on professional consultants 

" Telephones. company·w•de cell phones, 1ntemet serv1ces. and aircraft communica11on systems 
ROHAN RAMBARAN, 14-cv-1 0138 CS 

on bchnlf of themselves :and all othc1·s similnl'ly 

situated, 

Pheintiffs, 

v. 

DYNAMIC Ali{WA YS, LLC 

A Vie·giniu Limited Liability Compuny, 

Dcfcndun ts. 

-----------------------------------' 

Case No. 

JURY TRIAL DEMANDED 

CLASS ACTION COMPLAINT- DEMAND FOR JUL~Y TRIAL 

Plaintiffs, Moses V. Rambarran ("Rambarran") and Rohan Rambaran 

("Rambaran") individually and on behalf of all others similarly situated ("the Class"), 

bring this action against Defendant Dynamic Airways, LLC, a Virginia Limited Liability 

Company ("Dynamic Airways"). Rumbarran and Rambaran seek certification of their 

claims against Dynamic Airways as a class action. Plaintiffs, by and through their 

attorneys, submit this Class Action Complaint (the "Complaint") and allege as follows: 

NATURE OF THE ACTION 

I. This proposed class action concerns Dynamic Airways' violations of the 

Articles of the Convention lor the Unification ofCcrwin Rules I(Jr lrllcrmttional Carriage 

by Air (Montreal, Canada, May 28, 1999), commonly referred to us the Montreal 

Convention (hereinafter, the "Montreal Convention"), which is an international treaty 

ratified by the: United States in 2003 and which governs and regulates claims by consumers 
(

Guyana

). This service was advertised and promoted by Dynamic Airways to 

individuals, including individuals of Guyanese descent living in the United States. 

Rambarran and Rumbnnm purchased round-trip busincss-cluss tickets from Dynamic 

Airways for travel from New York, New York to Georgetown, Guyana, Flight No. 2D0401 (IlK), although the flight was also designated as Flight 403, scheduled for check-in 

on December 22, 2014, at I 0:00p.m., departure on December 23, 2014, at I :00 a.m., with 

a return round-trip on January 9, 2014, ut 5:30p.m. (hereinalh:r, "the Flight"). Upon 

nrrival at JFK on December 22, 2014, Ramharran and Rambanm learned that hundreds of 

people who had purchased tickets from Dynamic Airways for travel to Guyana had been 

waiting at JFK for days. Hundreds of people were told to wait at the airp011, and were 

continually promised that the flight was delayed but would be leaving. Representatives of 

Dynamic Airways notified Rambnrran and Rambaran that the flight was cancelled and they 

should return the following day, December 23, 2014, for a December 23, 2014 dcpm1urc nt 

7:00P.M. Rmnburrun and Rmnbnrnn returned the following day, along with hundreds of 

other passengers, and from approximately 3:00P.M. on December 23,2014, until2:00 

A.M. on December 24111, representatives of Dynamic Airways continued to promise a 

depm1ure. On December 2411\ at approximately 2:00 A.M., passengers were finally told 

that the flight would not depart. An article published in the New York Post on December 

26. 2014, reports that approximately 45 disgruntled passengers picketed the airline, and 

also reports that Dynamic Airways announced that no llightto Guyana would depat1until 

December 27,2014. As of December 26, 2014, Dynamic Airways had failed to refund 

2 
all passengers who have requested refunds und delay damages pursuant to the Montreal 

Convention . 

. JURISDlCTION AND VENUE 

2. This Court has jurisdiction over this matter pursuant to federal question 

jurisdiction, 28 U.S.C. § I 331. in that: 

(a) This Complaint is under the Montreal Convention, which is an 

intcrnnt ional treaty: 

(b) The United States is a signatory to the Montreal Convention; and 

(c) 28 U.S.C. § 1331 provides that this court shall have original jurisdiction 

of all civil actions arising under treaties of the United States. 

3. Pursuant to the provisions of the Montreal Convention, dclny damages per 

passenger is limited under Article 22 of the Montrenl Convention to 4,694 Special 

Drawing Rights ("SDR") 1 and ns of December 24, 20 I 4, one SDR equaled $1.449060 

US, so the Article 22 limit is $6,801.89 per passenger. 1-Iowcvcr, pmsuant to Article 22 (5) 

of the Montreal Convention. the limitation on dnmnges, "shall not apply if it is proved thnt 

the damage resulted from an act or omission of the carrier, its servants or agents, done with 

intent to cause d<tmage or recklessly and with knowledge that damage would probably 

' An SOR is a currency basket oflJS Oollars, .Japanese Yen, Pound Sterling, and Euro, 

calculnted by the International Monetary Fund, and the value of on SDR as of December 

14.2014, is posted by the IMF at http://www.iml'.org/cxternal/np/ftn/data/rms_sdrv.aspx 

The original limit was 4,150 SDR, which was adjusted and increased to 4,694 SDR, 

''Adjustments to Liability Limits Uoverned by the Montrenl Convention Effective 

December 30,2009,74 r.R. 59017-18 (Nov. 16, 2009). 

3 
may be brought at the option ofthe plaintiff at the place of destination. The flight in 

question was an international night tl·om JFK to Guyana, Rambarran nnd Rambnran both 

booked and paid for round·trip flights, and the destination of the flight was therefore New 

York. The '·place of destination" tor purposes of Article 33 in the context of a round-trip 

airline tlcl<et is the ultimate destination specified by the contract of carriage, not the 

outbound leg of the trip.2 The place of destination is New York, New York, and venue is 

therefore appropriate in this Court. 

5. This case is properly maintainable as a class action pursuant to and in 

accoJClance with Rule 23(a) ofthe Federal Rules of Civil Procedure in that: 

(a) The Class is so numerous that joinder of all members is impractical; 

(b) There arc substantial questions of law and fact common to the 

Class including those set forth in greater particularity below; 

(c) This case is pwpcrly maintainable as a class action pursuant to Rule 

23(b) of the Federal Rules of Civil Procedure, in that: 

i. Questions of law and fact enumerated below, which are 

all common to the Class, predominate over any questions of law or fact affecting only 

individual members of the Class; 

11. A class action is superior to any other type of action for 

the lair and efficient adjudication of the controversy; 

Baah I'. 473 f. Supp. 2"11 591 (S.D. N.Y. 2007). 

4 
4. The Court has personal jurisdiction over Dynamic Airways, which has 

sufficient minimum contacts with the State of New York because Dynamic Airwnys has 

conducted business in New York and has availed ilsclfofNew York's markets through its 

operations, of'fices, sales, and marketing efforts, and has engaged in such effor1s within the 

Southern IJistrict of New York by adver1ising to residents of New York who live within 

the geographical boundaries of the United States District Cour1 for the Southern District, 

including Plaintiff Rumbarran, a substantial part of the events or omissions giving rise to 

this claim occurred in the Southern District of New York, and venue in this Cour1 is 

therefore appropriate pursuant to 29 U.S.C. § 1391. 

PARTIES 

5. Plaintiffs Rambarran and Rambaran are permanent residents of, and 

domiciled in, Westchester County, New York. 

6. Defendant Dynamic Airwnys LLC, is a Virginia Limited Liability 

Company, which is registered to do business in the state or North Carolina, and which 

advertises to the public at httpJ/www.airdynamic.com (the "Website") that it is 

licensed hy the United States Federal A vintion Authority to operate a commercial 

airline, and advertises that its principal place of business is in North Carolina. At its 

intemet site, it claims: 

a. To have a Oeet of Boeing 767-200/300 aircraft; 

b. To have operated wide-body aircraft since 2009, backed by highly trained 

5 
Website to be: 

• We deliver on our commitment to excellence. 

• Dedication to reliability and customer service. 

• Connecting people through reliable and friendly air travel. 

• Treating people with dignity and respect. 

• We operme our aircraft to the highest standards to meet all 

regulatory requirements in modern aviation industry. 

• Taking pride in making sure our customers are happy. 

d. To have a "Policy On Delays and Cmtcellations,'' nnd claims th<H if n 

night is delayed or cancdled, a Dynnmic Airways representative will 

contract all passengers with available options; 

c. Regarding Flight Irregularities, Dynamic Airways represents on its 

website: 

"Flight Irregularities 

Whnt arc Dynumic Airways' Distress J>nsscngcr Compensution policies? 

Dynamic Airways Customer Service Plan will ensure flight interruptions will 

be relayed to Customers as soon as practicable. Review Dynamic Airways' 

Flight Irregularities Policy." 

7. Although IJynamic Airways claims to have a "rlight Irregularities 

Policy'' and n "Policy on Delays and Cancellations,'' which passengers ure directed to 

refer to, neither of these "policies" arc published on the Website. 

8. Dynamic Airways does publish its "Contract of Carriage," attached 

hereto and made a part hereof as Exhibit A, which provides, in pertinent part: 

a. Paragraph 8.a provides that the Montreal Convention applies to all 

internationultravel; and 

6 
9. Plaintiffs Moses V. Rambarrnn and Rohan Rambaran are residents of 

Westchester County, New York. 

10. Rambarran and Rambaran purchased and were sold business-class 

round-trip tickets for Dynamic Airways' l'light No.: 20-040 I (1-U(), with check in 

December 22, 2014 @ I 0:00P.M, departure New York (.JFK) Decernher 23rd, 2014 

@ I :00 A.M Terminal 1, return January 9, 2014 @ 5:30P.M, and arrival, New York 

(Jl,K) at 10:00 P.M, with total cost per round-tl'ip ticket of$1,335.60. 

II. On December 22. 2014, Rmnbarran and Rambaran arrived for check in 

approximately 10:30 PM, arrived at.IFK terminal I, and immediately witnessed nn 

t!slimatcc.l 500 people on check in line that circled around Terminal I. 

12. Rarnbarran and Rarnbaran inquired about business-class check in line, 

and were informed to line up at a certain location. 

13. Rambarran inquired as to the volume of people awaiting check in, and 

was told by both waiting passengers and representatives of Dynamic Airways that 

hundreds of passengers were left stranded fi·om previously cancelled Oights and some 

had slept <It the airport since Saturday night (December 20th, 20 14). 

14. Upon locating a Dynamic Airways employee and inquiring, Rambarran 

was informed in no uncertain terms that the Flight would not he listed, it was 

cancelled and the Dynamic Airways cmployl!c dircctl!d R<~mbarnm to rctum the next 

day, Dcccmbcr23, 2014, at3:00 P.M for check in and departure at 7:00P.M. 

15. Rambarran and Rambaran l(lllow~d instructions and rcwrncd to .JFK at 

7 
17. Rornbarron and Rarnbaran were instructed by a Dynamic Airways 

cmployet.! to start a business class line. 

I 8. Approximately 6:30 or 7:00P.M, after waiting an estimate of3 hours 

with little or no information from any airline personnel, Rambarran and Rambaran 

were the first passengers to be checked in and issued boarding passes. 

19. Rambarran and Rambaran each checked in two (2) pieces of luggage 

und both carried a single carry on. 

20. Representatives of Dynamic Airways told Rambarran and Rambaran 

thut Dt.!parture was at 9:45 P .M and to proceed to Gate I. 

2 J • Rambarran and Rambaran ate dinner within the gate area, incurring the 

cost of dinner, purchased duty free goods, and proceeded to the boarding area of Gate 

I. 

22. At Gate I, Rambarran and Rambaran were among what appeared to be 

}00-200 passengers. 

23. At approximately 8:30P.M the boarding agents asked passengers to 

form three (3) Jines, a business class line, Rows 3-16, and 17-24. 

24. The captain and night crew, arrived at the Gate area at approximately 

9:00 P .M, consisting of a Captain, a Co-Captain, four ( 4) females and one ( l) male 

flight attendant. 

25. The night Crew boarJed at approximately 9:15-9:30 P.M 

26. As described hereinafter. passengers were len wuiting on line li·om 

8 
protested for information us to why passengers were left to stand waiting to board and 

approximately I 0-12 wh!.!t:lchairs lined up with dderly infirm passengers 

28. Passengers demanded water und none was immediately given. 

Rambarran bought 10 bottles nf water and gave a bottle to each person in a 

wheelchair. 

29. More than an hour aller Rambarran purchased water for the passengers 

in the wheelchairs, the night attendants brought out a flight and offered people 

water, juice, or sodas. 

30. A man at the gate stated that he was the Manager of Dynamic Airways 

but he gavc I itlle information about the status of the flight. 

31. At approximately I 0:00P.M, Rambarran and Rambaran were told by 

one of the two female gute agcnls that they were "processing the pnperwork and that 

there were having issues but that we would begin boarding in twenty (20) minutes." 

32. After more than an hour had passed, at approximately II :00 P.M. and 

no further information had been provided, passengers were extremely lh1strated and 

vocal izctl demands to know the status of the llight. 

33. Shortly atler I I :00 P.M the male Dynamic Airways Mannger 

announced at the gate a stntement to the effect that, "we hove a minor issue and we 

are making a major effort to fix it". 

34. I le then disappeared well into midnight and passengers were lcfl with 

no answers. 

9 
shortly. 

36. Passengers were left with no further inf(wmation until approximatdy 2 

A.M when they continued their demands lor the truth to be told, and the male manager 

rcappcnrcd again and said "We have bad ncws ... wc arc cancelling the night". 

37. This was done after a lcmnle manager at Chcck·ln, told Rambarnm 

specifically "Notlo worry, you will get to Guyana" among many other reassurances; 

in fact, that female manager was telling passengers repeatedly "Everyone will get on 

the plane, not to worry". 

38. Between 2:00A.M and 3:00A.M, bags were made available at 

carousel No.I. 

39. Rambarran and Rambaran arrived at their homes in Westchester, New 

York al approximutely 4:00A.M. on December 2411 \2014. 

40. Rambnrnm received an em<lil message from Dynamic Ailways on 

December 23, 2014, at 4:33 A.M., staling: 

DUE TO DELAY ON 22ND DEC WE ARE OPERATING 

ALTERNATIVE SCIIEDULE IN ORDER TO 

ENABLE ALL PASSENGERS TO REACII TIIEIR FAMILIES 

BEFORE CHRISTMAS PLEASE NOT (sic) 

TIIAT YOUR FLIGIIT NUMBER OR TIME l-IAS BEEN 

CHANGED UPDATE YOUR ITINARARY (sic) 

THANK YO U FOR TilE UNOI·,RSTANDIN(i 

41. Rambarnm received an cmailmcssugc fl·om Dynamic Airways on 

December 23, 2014, at 6:29 P.M., slating: 

10 
42. Although Dynamic Airways had sent emails on December 23,2014, 

Dynamic Aitways has sent no further email notifications since December 23, 2014, 

Dynamic Airways provided no further email updates ufler Rambarrun and Rambaran 

were told on December 24111 , 2014, that the night was cancelled. 

43. By virtue of the foregoing, Dynamic Airways failed to tukc all 

mcasun:s that reasonably be required to avoid the damage to the passengers nnd 

it was not impnssihk (1)1' Dynamic A irw<l)'S to take such measurcs. 

44. Dynamic Airways failed to take all precautions that arc appropriate to 

the risk of delay for passengers, <llld failed to lake measures reasonably available to 

Dynamic J\ irways thnt would be calculated to prevent the subject loss. 

45. Dynamic Airways Htiled to utilize any automated n.:-booldng system, 

tailed to search oth«:r cnrriers for next available nights, failed to assist passengers to 

rc-book on other available flights to avoid delay, nnd failed lo implement feasible 

alternatives lt>l' passengers to avoid delay. 

46. Oynamic Airways failed to actrcnsonably prior to cancelling the flight 

and upon cancellation fitilcd to actrcasomebly to avoid passenger dcluy. 

47. The claims of Rambnrran. Rambnran. nnd the Class come within the 

swpe of the Montreal l'o11vcntiun. and Dynamil: Airways carriage agreement 

specifically states that it is subject to the rvlontrcal Convention, and by taking the 

ll.wcgoing action, Dynmnic Airways violated the terms or l.:.xhibit J\ nnd the terms or 

thl' Montreal Convention, and pursuant thereto, aJI pnssengers arc en! it led to delay 

II 
communication ii·om Dynamic Airways to learn \vhethcr Dynamic Airways \vould 

transport them to their destination. 

49. The New York Post reported on Decembcr26, 2014, that Dynamic 

Airways wns transporting passengers to Guyana on December 27, 2014, hut 

Rambarmn nnd Rnmbnrnn received no tlirccl communications fi·om Dynamic /\irways 

lo passengers confirmed that ini(Jrmalinn. 

50. Dynamic Airway:-; ha:-; never advised Rmnbarnm. Rmnbaran. or the 

Class, tlwt it would nnttransportl{:unbarmn, Rambmnn. or the Class, but instead, has 

ftliled lo take rca:,onablc n1ca~urc'> to comn1unicatc and has len passengers without 

in ICn mat ion. without a refund, and without assistance to 1 e-book. 

51. Each passenger carried on a flight operated by Dynamic Airways is 

issued a ticket which is includes the Contruct of Carriage, Exhibit A, which subjects 

Oynamic Airways to the Montreal Convention. 

CLASS ACTION ALLEGATIONS. 

52. Plaintiff.c; bring this action on their own behalf and on behalf of a class 

of all other persons similarly situated (the "Class"), pursuant to Rule 23 or the Federal 

Rules of Civil Pro<.:cdure. 

53. Plaintiffs bring this action as class representatives to recover 

compensution required to be puid under the Montreal Convention and lor breach of 

Exhibit/\. 

54. This action sntisfics the numerosity, commonality, typicnlily, adequacy, 

12 
(a) Such person had a conlirmcd reservation on a !light operated 

by Dynamic Airways by motorized fixed wing nircraft 

scheduled to travel between JFK and Georgetown, Guyana, 

during the month of December, 20 14; and 

(b) Such night was delayed or cancelled; and 

(c) Such person affected by delay was delayed for at least three hours; and (d) Such person has not received compensation and issued Dynamic 

Airways a release of claims. 

56. Excluded from the Class arc: 

(a) Dcfendnnts and uny entities in which Defendants have a 

controlling interest; 

(b) Any entities in which Defendants' officers, directors, or 

employees ure t!mployed and any of the legal representatives, 

heirs, successors or assigns of Defcndmlls; 

(c) The Judge to whom this case is assigned and any member of 

the Judge's immediate family and any other judicial officer 

assigned to this case; 

(d) All persons or entities that properly execute und timely file a 

request for exclusion fl·om the Class or as the Cout1 otherwise 

directs; 
Class before the CoUJt determines whether certilication is appropriate. 

58. The Class is numerously comprised of over I 00 people and most likely 

thousands of people who were booked to be passengers on flights operated by, or to be 

operated by, Dynamic Airways, to Guyam.1, during December 2014, the joinder of 

which in one uctiun would be impracticable. The exact number or identi ficatiun of the 

Class members is presently unknown. The identity of the Class members is 

ascertainable. In addition to manifests, databases and rolls maintained by Dynamic 

Airways and its agents, the Class members may be located and informed of the 

pendency of this action by a combination or electronic bulletins, e-mail, direct mail 

and public notice, or other means. The disposition of the claims of the proposed class 

members through this class action will benetit both the parties and the Cmnt. 

59. Common questions of law and fact predominate over individual issues. 

There is a wdl-defined community of interest in the questions or law and fact involved art\!cting members of the Class. The questions of law and tact common to the 

Class predominate over questions affecting only individual Class members, and 

include, but<lrc not limited to, the following: 

a) Whether the Muntrc<JI Convention rel(uires Dynumic Airways to 

compensation to the Class members; 

b) Whethe•· Dynamic Airways' is entitled to the linbility caps of Article 

22 of the Montreal Convention; 

c) Whether Dynamic Airways acted unreasonably and with knowledge 

14 
been entitled to receive financial compensation pursuant to the 

Montreal Convention and having not received such compensation. 

Plaintiffs and the Class members have similarly suftercd hann 

arising from Dynamic Airways' delay of passengers, its failure to 

act reasonably to avoid damage, and its failure to immediately 

refund airfnrcs, rc-book and failure to pay compensation as alleged 

in this Complaint. 

60. A class action is the best available method for the efficient adjudication of 

this litigation because individual litigation of Class members' claims would be 

impructicublc and individual litigation would be unduly bun.lcnsom~: to th~: courts. B~:causc 

of Lh~: silc of each individual Class member's claims, it would not be practicable for Class 

members to individually seck legal redress for the wrongs identified in this Complaint. 

Without the class action vehicle, the Class would have no reasonable remedy and would 

continue to suffer losses, as Dynamic Airways continues to fail to compensate passengers 

us required under the Montreal Convention and Exhibit A. Further, individual litigation has 

the potential to result in inconsistent or contradictory judgments. A class action in this case 

presents fewer management problems and provides the benefits of single adjudication, 

ceo nom ics of scale, and compn.:hcnsivc supervision by a single court. 

15 
62. The foregoing constitutes passenger delay in violation of the policies 

and Contmct ofCarriagt: or Dynamic Airways, Exhibit A, and Plaintiffs and the Class 

arc entitled to compensation pursumlt to the provisions of the Montreal Convention. 

63. Duc to the reckless and unreasonable actions ofDynnmic Airways, Pl:~intil"ls arc entitled to compensation in excess of the liability dumagc cap of 4,694 

SDR. 

REQUEST FOR RELIEF: 

W hcrd(xc; Plaint i fls, individually and on behalf of the Cbss, request: 

A. That the Court determines that this action may be maintained as a class 

action under Rule 23 of the Federal Rules of Civil Procedure; that the Plaintiffs arc 

proper dass representatives; and that the best practicable notice of this action be given 

to members of the Class represented by the Plaintiffs; 

B. That judgment be entered against Dynamic Airways and in favor of 

Plaintiffs nnd the Class on the Cause of Action in this Complaint, for actual, 

<;ompcn~atory damages in nn amount to be determined at trial: 

C. ·1 hat judgment be entered imposing interest on damages, litigation 

costs. ami attorneys' fees against Lufthansa; and 

D. For such other relief <&S this Court may deem appropriate . 

• JURY DEMAND Plaintiff~ demand a trial by jury on all issues so triable. 

16 
NY JJmNo.41 7 1674 

535 Central J\ venue 

St. Petersburg, FL 3J70 I 

727-823-3222 

727-H95-3222 Tclcli1:< 

727-480-4425 Cellular 

don@ln wus.com 

Attorney lor Pia inti l'f's 

17 
with annual revenues of 65 million dollars, operating Airbus A·320's and Boeing B·727's to 

over 25 destinations. 

• Senior Vice Presjdent of Flight Operations and Director of Operations for Eos Airlines, an 

FAR 121 International Flag Airline operating B·757s 

o Member of an eight·man certification team 

o Certification for Eos, FAR 121 Flag Airline, was completed in a record eight months. 

o After certification, received ETOPS approval in five months (by FAA guidance, this is 

a one year program), Lower Landing Minimum CAT 1118 approval in six months. 

o Team leader and Captain on proving runs for both certifications. 

• CEO and Founder DIA, FAR 135 International and Domestic Charter Operation 

o Certification leader for DIA, CEO, Director of Operations and Chief Pilot for an FAR 

135 asrline 

As CEO of Trans Meridian Airlines. FAR 121 airtine operating under Flag, Domestic, and 

Supplemental Certification, responsible for overall management and control of all airline activities, 

recruitment and selection of key management personnel and directly involved and responsible for 

negotiations and implementation of all charter contracts, facility contracts, aircraft leases and 

employee contracts. Established and maintained budget controls for all departments. Moved 

certificate from Houston to Atlanta with no interruption of service, added Flag and Domestic 

Certification to Supplemental Certification and added second aircraft type to certificate. 

As Senior VP Flight Operations and Director of Operations for Eos Airlines, had complete control and 

final authority over all airline operations. Directly responsible for management of Pilots, Systems 

Operations Control and Crew Scheduling, Dispatchers, Crew Schedulers, Staffing and Scheduling of 

Pilots and Flight Attendants, all Regulatory Training and Technical Publications. In addition, held the 

position of Une Captain, LCA, and had an FAR 9414 exemption/authorization to do initial Captain 

Observations. 

Wrote Flight Operations Manual. Aircraft Operations Manual, Training Manual, and MEL for 

certification. 

White Senior Vice President and Director of Operations, Eos AirHnes awarded "Best Business Travel 

Airlines", ranked #1 in on·time arrival on the New York·London route, achieved documented 97% 

customer satisfaction rating and a 99.6% completion rate. 

W1th all three of the above airlines, worked directly with the FAA Principal Operations Inspector, 

worked directly with the Pilots and contract negotiations. 

Commercial flying experience that spans over 30 years, to every continent in the world except 

Antarctica, including polar routes, with excess of 20,000 total flight hours, under FAR Part 121 and 

135 operations. Experience in a variety of aircraft including the A·300, B-727, B-737, B-747 (SP, 100. 

200, and 400), 8·757, B-767, B-777, CE-500, DC-3, DC-8, DC-9, DC-10, L-188, L-1011 as well as a 

variety of corporate aircraft. Have held posibons of Captain, Co-Pilot, Flight Engineer, LCA, Check 

Pilot, FAR 9414 exemption/authorization, Check Engineer. and Instructor. 
Crew Scheduling, Dispatchers, Crew Schedulers, Staffing and Scheduling of Pilots and Flight 

Attendants, all Regulatory Training. Dynamic International Airways operates five Boeing 767s 

worldwide, both passenger and cargo. 

Propeller Advisors 2013- 2015 

Aviation Consultant Group 

Chief Operating Officer 

Propeller Advisors provides expert analysis, experienced guidance and advice for clients 

dealing with complex aviation and transportation issues. Our areas of expertise include 

acquisition and disposition of aircraft, engineering, fleet planning, finance, procurement, sales 

and marketing, supply chain management, as well as an in-depth understanding of the 

regulatory environment surround1ng the FAA, ICAO. EASA, TSA, security, airports, 

certification, IOSA and ATOS inspections. Propeller Advisors is a subsidiary of Propeller 

Investments. a private equity firm which specializes in targeted investments in the aviation 

and transportation sectors 

Falcon Air Express 2011-2013 

121 Supplemental Airline 

Director of Operations 

As Director of Operations had operational control and final authority over all airline 

operations. Directly responsible for management of Pilots, Systems Operations Control and 

Crew Scheduling, Dispatchers, Crew Schedulers, Staffing and Scheduling of Pilots and Flight 

Attendants, all Regulatory Traming and Technical Publications. Falcon Air Express had three 

bases in the US where we flew for the U.S. Immigration and Customs Enforcement as well as 

a base in Curacao where Falcon provided scheduled sub-service for Dutch Antilles Express 

to the Umted States. 

Ascend Airlines 2008-2009 

121 Supplemental Airline 

Chief Operations Officer 

Joined Ascend Airlines during the Research and Development phase to design and launch a 

private luxury supplemental airline operating long haul flights to high profile destinations 

throughout the western hemisphere. During this penod worked directly with Boeing, Airbus 

and BMW Designworks USA, Inc. to develop and design new luxury aircraft meeting both 

passenger requirements and aircraft performance requirements. Developed aircraft and crew 

schedules allowing for maximum utilization of aircraft with minimum staffing. Worked with 

airport management to locate and design specialized ground handling requirements. Had 

preliminary conversations with FAA in preparation for certification. With the collapse of the 

economy, project was shelved indefinitely until a more favorable climate exists 
o Pilots o Dispatchers o Crew Schedulers 

o Training o Technical Publications 

• Additional Authorizations 

o Aircraft Acceptance Test Pilot 

o Line Check Captain 

o FAA 9414 approval to g1ve 1n1tial Captain Observation Check 

o Mamtenance Dehver Pilot 

United Airlines 1990-2004 

121 Flag, Domestic Airline 

Captain 

• Pilot on a variety of aircraft including 8-737, 8-747 (SP, 100, 200, and 400), 8-757, 8-

767, 8-777 and DC-8 

• ETOPS, Trans-Atlantic, Trans-Pacific, intra-Europe, intra-Asia, South America, US 

domestic routes and polar routes to Asia 

• Captain, Co-Pilot, and Flight Engineer 

Trans Meridian Air Lines 1996-1997 

121 Supplemental Airline 

CEO and President 

• In 1996, took a leave of absence from United Airlines for one year to accept a position at 

Trans Meridian Air L1nes as CEO and President. Employed over 140 pilots and over 200 

flight attendants. Responsible for the overall operation and management with annual 

revenues of over 65 million dollars. Operated to more than 25 destinations throughout the 

US, Mexico and the Caribbean operating A-320's and 8-727's. Operated A-320's with 

augmented crews on extended range flights. While CEO of Trans Meridian, added Flag 

and Domestic Operations to our certificate and added a second fleet type to certificate 

(8-727). Moved the certificate and company headquarters from Houston, Texas to 

Atlanta, Georgia- including all administrative personnel, flight operations, dispatch and 

crew scheduling. Replaced several key personnel who could not relocate. 

Dodson International Airlines 

135 Charter Airline 

Founder, CEO, Director of Operations, and Chief Pilot 

• Founded Dodson International Air as a Part 135 charter airline 

1987 -Current 

• Wrote all manuals includmg the Operations Manual, Pilot Training Manual and MELs 

• Directed the certification process and proving runs 

• Grew company to more than ten aircraft in passenger and cargo operations 

• DIA has never rece1ved any type of violation or infraction 
Eastern Airlines 1989 

121 Flag, Domestic Airline 

Captain 

• Pilot on a variety of aircraft including A-300, 8-727, 8-757, DC-9, DC-10, L-188, and L1011 • Flew domestic and international operations in Europe, South America, the Caribbean, 

Mexico and Canada 

• Flight Instructor and Check Airman 

• Captain, Co-Pilot, and Flight Engineer 

Citizenship 

Umted States of America 

Licenses and certificates 

Airline Transport Pilot #1747197- B-737, 8-747, 8-757, 8-767, 8-777, DC-3, DC-9 and C500 

Flight Engineer #1851675 -Turbo Propeller Powered and Turbo Jet Powered 

FCC License Federal Flight Deck Officer License #P101560 

Education 

Military 

Georgia Institute of Technology- Mechanical Engineer 

Georgia Military Institute- Army Officer School 

United States Army, 151 Lt., Honorable Discharge 

• Graduated #1 Officer Candidate School 

• Graduated #1 in Basic Training Battalion 

• Perfect Score- Physical Combat Proficiency Test 

Letter of Recommendation Attached 
CERTIFICATE OF SERVICE 

I hereby certify that I have this 11 th day of February, 2015, caused the foregoing 

document to be served upon each person listed below via e-mail: 

gmurphy@crowell.com 

dan .weiss@united .com 

steve.morrissey@united .com 

anita.mosner@hklaw.com 

jennifer.nowak@hklaw.com 

sascha.vanderbellen@delta.com 

chris.walker@delta .com 

cefelts@fedex.com 

robert.wirick@aa.com 

howard .kass@aa .com 

francis .heil@aa.com 

Dwight.moore@ustranscom .mil 

perkmann@cooley.com 

jhill@cooley.com 

john.s.duncan@faa.gov 

brian.hedberg@dot.gov 

brett. kruger@dot.gov 

reese.davidson@dot.gov 

robert.finamore@dot.gov 

esta.rosenberg@dot.gov 

todd. homan@dot.gov 

peter. irvine@dot.gov 

laura.remo@dot.gov 

damon .walker@dot.gov 

Benjamin .taylor@dot.gov 

james.verre@faa .gov 

eng lets@state .gov