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BEFORE THE DEPARTMENT OFTRANSPORTATION 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 CONFIDENTIALTREATMENT UNDER 14 C.F.R.

### ·§ 302.12 

### Nick Kennedy Founder and ChiefExecutive Officer Rise Alpha, LLC 7363 Herb Kelleher Dallas, TX 

### 75235 David T. Denney, Esq. The Law Offices ofDavid 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 MenagerieEnterprises, Inc. d/b/a MonarchAir 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 Pursuantto 14 C.P.R. 

### § 302.12, Rule 12 ofthe Department's Rules ofPractice, Rise Alpha, LLC hereby moves to withhold from public disclosure Exhibits 1-4 ofits January 23,2015, Response to Second Information Request Rise is providing this confidential information in support ofthe above-captioned application for the issuance of commuter air carrier authority. Rise Alpha, LLC is the owner ofRise LLC, which is acting as ticket agent onbeha..J.fofits members in chartering an aircraft from Monarch Air, and vvishes to be ofassistance to.the Department as 

### it reviews MonarchAir's fitness. These documents are being filed withthis Motion in a sealed envelope marked

•· ,, "Confidential Materials- Rule 12 TreatmentRequested." In support ofthis Motion, Rise submits the following: The infonnation in Exhibits 1through 4 is provided to the Department to verify that Rise has the necessary financial wherewithal to fulfill any financial commitment made to or on behalfofMonarch 

### Air. This information is (1) commercial or financial, January 23,2015 . . ; . i.**~** ·.. \ ... ··::····.·................. . 

### Motion ofRise Alpha, Inc. For Confidential Treatment Page 2 of3 (2) obtained from aperson outside the governmentthat is not even the applicant, and (3) privileged or confidential and thus qualifies for confidential treatment underExemption 4 ofthe Freedom ofInformation Act, 5

### U.S.C. § 

### 552(b)(4). Release ofthis information would cause substantial harm to the competitive position ofRise 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 ofcash 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 beenpreviously explained, is an innovative and creative way to benefittravelers whose travel requirements require last-minute reservations and fast, hassle-free air 

### travel. No otherprogram 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 ofthis 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. '. •.

;._.·Motion ofRise 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 ofits Procedural Rules and such other and further reliefas the public interest may require.

Attachments: Index Certificate 

### ofService 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. FirstFinancial BankLetter confirming total cashbalance at 1/21/15 3. Liberty Capital Bank Letter confirming total cashbalance at 1/21}15 4. Liberty Capital Bank**Commerc~al** Line ofCreditAgreement andNote

### 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 FAANoj.ih Dallas Flight Standards District Office 8700 Freeport}arkway Irving, TX 75063 Director ofOperations LoveField Airport LoveField 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 ofOperations Austin-Bergstrom International Airport 3600 Presidential**Blv.d~** Austin, TX 78719 Director ofOperations San Antonio International Airport 9800 Airport Blvd. SanAntonio, TX 782 I 6