U.S. Department of

Transportation Office of the Secretary OfTransportation June 13,2014
Mr. Robert P. Silverberg Silverberg Goldman & Bikoff, L.L.P. Georgetown Place, Suite120
. 1101 30TH Street, N.W. Washington, DC 20007
Dear Mr. Silverberg: 

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We have completed our initial review of the information Gulf & Caribbean Cargo, Inc. ("G&CC"), provided in support ofits request to remove the condition that limits the number of large aircraft itmay operate. This review has revealed the need for additional and/or clarifying information before we can complete our review of G&CC. Specifically, in the application, you state that G&CCand Shadrack, LLC ("Shadraek") entered into an Agreement and Plan of' Recapitalization in December 2013 and atthat time, amended the air carrier's Articles ofIncorporation. In addition, you also state that G&CC now has two classes of common stock. In light ofthe foregoing, we ask that you please provide the following: (I) Agreement and Plan ofRecapitalization entered between G&CC and Shadrack. (2) G&CC's amended Articles ofIncorporation. (3) Please identify the citizenship ofeach owner ofG&CC, provide the type and number of shares held by each owner, and provide the compliance history information as required by sections 204.3(1), (m), (0), and (P) ofourrules. (4) Please state the total number of shares issued, authorized and outstanding for each class of stock. In addition, we remind G&CC that it should promptly provide the Department with any information regarding changes it may undergo in areas affecting its fitness (i.

### e., management, operating plans or financial condition, compliance disposition, or ownership) while under review by the Department.2

Please include the following certification signed by arepresentative ofthe air carrier [who shall be aprincipal owner, senior officer, orinternal counsel ofthe carrier]: The contents of this submission and the attached exhibit (s) are true and correct to the best ofmy knowledge and belief. Pursuant to Title 18United States Code Section 100I, 1

### [the individual signing theapplication, whoshallbeaprincipal owner, senior officer,

.or internal counsel ofthe applicant], in my individual capacity and as the authorized representative ofthe applicant, have not in any manner knowingly and willfully falsified, concealed or failed to disclose any material fact or made any false, fictitious, or fraudulent statement orknowingly used any documents which contain such statements in connection with the preparation, filiI!g or prosecution of the application. I understand that an individual who is found tohave violated the provisions of 18U.S.C section 100I shall be fined orimprisoned notmore than five years, orboth. Thank you for your cooperation inthis matter. Iask that you respond fully to this request within 30 days of this letter. If you have any questions regarding this letter or the requested information, please feel free to contact Shabu Thomas at (202) 366-9721.

Laur ~ 

### J. Remo Chief, Air Carrier Fitness Division Office ofAviation Analysis

cc: Dockets DOT-OST-1996-1023

DOT-OST-1996-1071
Mr. Russel J Megargle (FAA) POI