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BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

Application of 

Menagerie Enterprises, Inc. 

d/b/a Monarch Air 

for authority to conduct scheduled 

passenger ()perations as a commuter air 

carrier under 49 U.S. C. § 41738 

DOCKET 2014-0192-

MOTION OF RISE ALPHA, LLC 

FOR CONFIDENTIAL TREATMENT UNDER 14 C.F.R. ·§ 302.12 

Nick Kennedy 

Founder and Chief Executive Officer 

Rise Alpha, LLC 

7363 Herb Kelleher 

Dallas, TX 75235 

David T. Denney, Esq. 

The Law Offices of David T. Denney, P.C. 

8350 N. Central Expressway, Suite 925 

Dallas, TX 75206 

January 23,2015 

January 23,2015 

PatriciaN. Snyder 

G. Brent Connor 

Thompson Hine LLP 

1919 M Street, NW 

Suite 700 

Washington, DC 20036-1600 

(202) 263-4189 

pat.snyder@thompsonhlne.com 

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BEFORE THE 

DEPARTMENT OF TRANSPORTATION ... n. 11 a 

OFFICE OF THE SECRETARY . Z~\5 W·\ :;: 3 •··• .)· ~, : 

WASHINGTON, D.C. 

Application of 

Menagerie Enterprises, Inc. 

d/b/a Monarch Air 

for authority to conduct scheduled 

passenger operations as a commuter air 

carrier under 49 U.S.C. § 41738 

DOCKET 2014-0192-

MOTION OF RISE ALPHA, LLC 

FOR CONFID~NTIAL TREATMENT UNDER 14 C.F.R. § 302.12 

Pursuant to 14 C.P.R. § 302.12, Rule 12 of the Department's Rules of Practice, 

Rise Alpha, LLC hereby moves to withhold from public disclosure Exhibits 1-4 of its 

January 23,2015, Response to Second Information Request Rise is providing this 

confidential information in support of the above-captioned application for the issuance of 

commuter air carrier authority. Rise Alpha, LLC is the owner of Rise LLC, which is 

acting as ticket agent on beha..J.f of its members in chartering an aircraft from Monarch 

Air, and vvishes to be of assistance to.the Department as it reviews Monarch Air's fitness. 

These documents are being filed with this Motion in a sealed envelope marked 

•· ,, 

"Confidential Materials- Rule 12 TreatmentRequested." In support of this Motion, Rise 

submits the following: 

The infonnation in Exhibits 1 through 4 is provided to the Department to verify 

that Rise has the necessary financial wherewithal to fulfill any financial commitment 

made to or on behalf of Monarch Air. This information is (1) commercial or financial, 

January 23,2015 

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Motion of Rise Alpha, Inc. 

For Confidential Treatment 

Page 2 of3 

(2) obtained from a person outside the government that is not even the applicant, and (3) 

privileged or confidential and thus qualifies for confidential treatment under Exemption 4 

of the Freedom of Information Act, 5 U.S.C. § 552(b)(4). 

Release of this information would cause substantial harm to the competitive 

position of Rise Alpha, LLC, the individual from whom the information was obtained. 

As mentioned before, Rise is not an applicant in this ·proceeding and should be given 

greater deference since its role here is limited. Exhibits 1-4 contains Rise's financial 

statements , loan agreements and verification of cash on hand. This information discloses 

Rise's capital structure, which competitors could use to better understand Rise's unique 

business model. The business model, as has been previously explained, is an innovative 

and creative way to benefit travelers whose travel requirements require last-minute 

reservations and fast, hassle-free air travel. No other program like it exists, and 

disclosure ofits capital plan could enable a competitor an opportunity to copy the 

business model. Moreover, the information in this exhibit is det8.i..led arid would not 

-otherwise be made accessible to persons outside the company. 

Provision of this detailed information is not required in the public interest, since 

the Department needs this information only to verify information being provided by 

Monarch Air to establish its fitness. 

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Motion of Rise Alpha, Inc. 

For Confidential Treatment 

Page 3 of3 

Wherefore, Rise Alpha, LLC respectfully requests that the Department grant 

confidential treatment to this information under Rule 12 of its Procedural Rules and such 

other and further relief as the public interest may require. 

Attachments: 

Index 

Certificate of Service 

Exhibits 

Submitted by, 

v&.W~ G. Brent Connor 

Counsel for Rise Alpha, LLC. 

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INDEX 

1. Rise Unaudited Financial Statement as ofn/30/14 

2. First Financial Bank Letter confirming total cash balance at 1/21/15 

3. Liberty Capital Bank Letter confirming total cash balance at 1/21}15 

4. Liberty Capital Bank Commerc~al Line of Credit Agreement and Note 
CERTIFICATE OF SERVICE 

I hereby certify that on January 23; 2015, I served the foregoing motion for confidential 

treatment by flrst-class mail, postage prepaid, upon the persons shown in the following 

service list. 

G. Brent Connor 

SERVICE LIST 

Cameron Baker 

FAA N oj.ih Dallas Flight Standards District Office 

8700 Freeport}arkway 

Irving, TX 75063 

Director of Operations 

Love Field Airport 

Love Field Terminal Building 

8008 Cedar Springs Road, LB 16 

Dallas, TX 75235 

Director of Operations 

William P. Hobby Airport 

780(} Airport Blvd. 

Houston, TX 77061 

Director of Operations 

Austin-Bergstrom International Airport 

3600 Presidential Blv.d~ 

Austin, TX 78719 

Director of Operations 

San Antonio International Airport 

9800 Airport Blvd. 

San Antonio, TX 782 I 6