BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

! r.· ~ ".? 

L(: L 

In the matter of the cancellation of the 

Air Taxi authority issued to: Docket DOT -OST -2012-0022 

VIH COUGAR HELICOPTERS, INC. 

MOTION OF VIH COUGAR HELICOPTERS, INC. 

TO WITHHOLD INFORMATION FROM PUBLIC DISCLOSURE 

Communications with respect to this document should be sent to: 

David M. Nadler 

David Y. Yang 

Andrew E. Smith 

DICKSTEIN SHAPIRO LLP 

1825 Eye Street, NW 

Washington, DC 20006 

Telephone: (202) 420-2200 

Facsimile: (202) 420-2201 

nadlerd@dicksteinshapiro .com 

yangd@dicksteinshapiro.com 

smitha@dicksteinshapiro.com 

Counsel to VIH Cougar Helicopters, Inc. 

Dated: September 21, 2012 

"' ,, f 

'·' ~ 

DSMDB-3099607vl 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

In the matter of the cancellation of the 

Air Taxi authority issued to: 

I 

I 

I Docket DOT -OST -2012-0022 

VIH COUGAR HELICOPTERS, INC. 

I 

I ____________________________I 

MOTION OF VIH COUGAR HELICOPTERS, INC. 

TO WITHHOLD INFORMATION FROM PUBLIC DISCLOSURE 

Pursuant to Rule 12 of the Rules of Practice (14 C.F.R. § 302.12) for the Department of 

Transportation ("Department"), VIH Cougar Helicopters, Inc. ("VIH Cougar"), by and through 

the undersigned counsel, hereby moves to withhold from public disclosure unredacted versions 

of the documents set forth in Exhibit A (collectively, "the Documents"), which were provided to 

the Department in response to the Department's August 24, 2012 Request for Information in the 

above-captioned proceedings. 

I. BACKGROUND AND ARGUMENT 

The Documents contain confidential commercial and personal information that is exempt 

from public disclosure pursuant to Exemption 4 of the Freedom of Information Act ("FOIA"), 5 

U.S.C. § 552, the Trade Secrets Act, 18 U.S.C. § 1905, and all other applicable statutory and 

regulatory prohibitions against the public disclosure of sensitive, non-public information. 

Redacted, public versions of the Documents were filed with the Department's Docketing Office 

for inclusion onto Docket No. DOT-OST-2012-0022. 

Exemption 4 ofFOIA protects all matters that are "trade secrets and commercial or 

financial information obtained from a person and privileged or confidential." 5 U.S.C. 

DSMDB-3099607vl 
§ 552(b)(4). To fall within the purview of Exemption 4, information must be: (1) commercial or 

financial in nature; (2) obtained from a person or by the Government; and (3) confidential or 

privileged. See e.g., Watkins v. US. Bureau ofCustoms and Border, 643 F.3d 1189, 1194 (9th 

Cir. 2011); see also, Public Citizen Health Research Group, 704 F.2d at 1290 (D.C. Cir. 1983). 

In addition, the Trade Secrets Act, 18 U.S.C. § 1905, prohibits Government personnel from 

disclosing confidential information unless disclosure would be allowed under FOIA Exemption 

4. See Canadian Commercial Corp. v. Dept. of Air Force, 514 F.3d 37, 39 (D.C. Cir. 2008) 

(citing CNA Fin. Corp. v. Donovan, 830 F.2d 1132, 1151 (D.C. Cir. 1987)). Notably, in seeking 

Exemption 4 protection, a person need not prove with certainty that it will suffer competitive 

harm by the release of its commercial or financial information. McDonnell Douglas Corp. v. 

United States, 375 F.3d 1182, 1187 (D.C. Cir. 2004) (sufficient to trigger Exemption 4 protection 

where person shows that it is likely that competitive harm would result); see also General Elec. 

Co. v. Dep't ofthe Air Force, 648 F. Supp. 2d 95, 103-04 (D.D.C. 2009) (holding that a 

contractor is not required to show how exactly a competitor would use its information to gain a 

competitive advantage). 

Here, the Documents satisfy the Exemption 4 requirements. Specifically, the Documents 

are commercial or financial in nature, they are maintained confidentially, and they are not 

available to the general public. See Declaration of Christopher G. Turner ("Turner Decl.") at~ 6. 

Indeed, VIH Cougar takes reasonable efforts to guard against unauthorized dissemination of the 

Documents, thereby protecting their commercial value. !d. at~ 6. More specifically, the 

Documents contain confidential, commercial information regarding VIH Cougar's organization, 

operations, capabilities, strategic alliances, suppliers, vendors, and customer base, including the 

terms and conditions of those business arrangements. !d. at ~ 5. The Documents also contain 

2 

DSMDB-3099607vl 
confidential, commercial information ofnonparties to these proceedings (such as Construction 

Helicopters, Inc. ("CHI") and Heligroup Fire, LLC ("Heligroup")) regarding the same or similar 

subjects and concerns. !d. Accordingly, ifthe Documents were publicly disclosed, the 

information would allow competitors (such as Petroleum Helicopters, Inc.) insights into sensitive 

subjects such as the number of aircraft that operated by the companies, the capabilities of those 

aircraft, the capabilities and services provided by the companies, the location of any bases and 

facilities, the names of the pilots who fly for the companies and the crews which service the 

aircraft, the vendors that support the companies and the types of services that they provide, and 

most importantly, the identities of the companies' customers, the services that are being 

procured, and the terms on which they are being procured. All of this information would assist 

in determining where the companies operate and what they presently do, as well as in predicting 

the industries, sectors, and/or geographic locations or markets in which they may be likely to 

expand. Thus, all of this information would be useful to competitors in pursuing current or 

identifying prospective business opportunities. 

Under these circumstances, the public disclosure of the Exhibit A Documents in their 

unredacted forms would give competitors access to commercially sensitive and valuable 

information that they would not otherwise have but for these proceedings - a particular concern 

for the affected nonparties here- and the information inequality would likely place VIH Cougar 

and these nonparties at an unfair competitive disadvantage in relation to these competitors when 

pursuing the same or similar business opportunities or formulating and/or executing strategic 

alliances and similar pursuits. !d. 

Moreover, it is well-established that the confidential information ofnonparties (such as 

CHI and Heligroup) is particularly deserving of protection because they have no connection to 

3 

DSMDB-3099607vl 
the merits or resolution of the proceedings. See, e.g., Confederated Tribes of Siletz Indians of 

Oregon v. Weyerhauser Co., 340 F. Supp. 2d 1118, 1124 (D. Or. 2003) (redacting portions of 

trial exhibits to protect interests of the nonparty reflected in those exhibits); Crane Helicopter 

Servs., Inc. v. United States, 56 Fed. Cl. 313, 327 (Fed. Cl. 2003) (holding that sealed trial 

exhibits containing trade secrets of nonparty manufacturer would remain under seal after trial to 

protect manufacturer's competitive advantage). In this case, both CHI and Heligroup are 

American companies, and neither is substantively connected to the citizenship issues regarding 

VIH Cougar, nor are they alleged to be under any foreign influence of control themselves. 

Thus, because the Documents that regard CHI and Heligroup have no real connection to the 

instant proceedings, there is no public interest that would warrant their disclosure. In addition, 

the Documents also contain certain personal identifiers, such as home addresses, home phone 

numbers, and the names of non-principal, line employees. This sensitive, personal information is 

also confidential and its release would violate company policies for safeguarding the privacy 

interests of employees. 

Finally, because the impetus behind the Department's Rule 12 procedures is to ensure 

that a company's confidential commercial and personal information is protected to the maximum 

practicable while also ensuring that the public has adequate access to the relevant facts, it is 

appropriate to consider whether disclosure of the Documents would be central to understanding 

the proceedings underlying this case, particularly since nonparty confidential information is also 

involved. VIH Cougar contends that it is not. The Department has stated that it is most 

concerned with the identity of the principals involved in the VIH Cougar restructuring, and has 

advised that this information should be disclosed because it is needed for the public to 

understand any conclusions that are reached by the Department in this matter. The redactions 

4 

DSMDB-3099607vl 
that VIH Cougar has posted on the public docket provide all of this information and, thus, 

properly addresses the Department's stated concerns while maintaining under seal confidential 

information that the public does not need to see, in an effort to promote the regulatory and 

statutory rights ofVIH Cougar and any nonparties to have their personal and business-sensitive 

information protected to the fullest extent of the law. See Zenith Radio Corp. v. Matsushita Elec. 

Indus. Co., 5298 F. Supp. 866, 0907-08 (E.D. Pa. 1981) (finding that public's presumption of 

access to commercial information designated as confidential was weak, where public's general 

interest in the underlying litigation was satisfied by court's unsealing of other documents and the 

protected information was commercially sensitive). 

II. CONCLUSION 

For the foregoing reasons, the Department should grant VIH Cougar's motion and not 

disclose the unredacted Documents in Exhibit A that have been provided to the Department in 

response to the Department's August 24, 2012 Requests for Information. 

Dated: September 21, 2012 

::spec~ly~~ 

5 

David M. Nadler 

David Y. Yang 

Andrew E. Smith 

DICKSTEIN SHAPIRO LLP 

1825 Eye Street, NW 

Washington, DC 20006 

Telephone: (202) 420-2200 

Facsimile: (202) 420-2201 

nadlerd@dicksteinshapiro.com 

yangd@dicksteinshapiro.com 

smitha@dicksteinshapiro.com 

Counsel to VIH Cougar Helicopters, Inc. 

DSMDB-3099607vl 
CERTIFICATE OF SERVICE 

I certify that I have on this 21st day of September 2012 served the foregoing upon the 

persons listed below: 

Susan L. Kurland 

Office of the Assistant Secretary for 

Aviation and International Affairs 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Room W96-495 

Washington, DC 20590 

Lauralyn Remo 

Office of the Assistant Secretary for 

Aviation and International Affairs 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Room W96-495 

Washington, DC 20590 

Jonathan Blank 

John Longstreth 

Timothy Hobbs 

K&L Gates LLP 

1601 K Street NW 

Washington, DC 20006-1600 

Peter Lynch, AGC-300 

Asst. Chief Counsel for Enforcement 

Federal Aviation Administration 

800 Independence Ave. SW 

Washington, DC 20591 

William J. Weber 

Certification Section Manager 

FAAAFS-900 

45005 Aviation Drive Suite 131 

Dulles, VA 20166 

Roy Hardie 

Aviation Safety Inspector 

Federal Aviation Administration 

1601 Lind Avenue SW, Suite 260 

Renton, W A 98057 

Andrew E. Smith 

6 

DSMDB-3099607vl 
I 

I 

I -

! 

EXHIBIT A 
EXHIBIT A 

INDEX OF CONFIDENTIAL INFORMATION 

AND DOCUMENTS TO BE WITHHELD FROM THE PUBLIC: 

CONFIDENTIAL ITEM# TITLE/DESCRIPTION 

1. The document entitled "VIH Cougar's Response To The 

Department's Order Of August 24, 2012," which is being filed 

in response to the Department's Information Request of August 

24, 2012. Confidential information contained within this 

document is in response to Information Request No.6, 8, 12 & 

13. 

2. The document entitled "Share Purchase & Sale Agreement" 

being filed as Tab 1.A in response to Information Request No. 

1. 

3. The document entitled "Consent to Act as Director and Officer 

- Christopher G. Turner" being filed as Tab 1.E in response to 

Information Request No. 1. 

4. The document entitled "Consent to Act as Director and Officer 

-James R. Russell" being filed as Tab 1.F in response to 

Information Request No. 1. 

5. The document entitled "Consent to Act as Director and Officer 

-Kenneth Norie" being filed as Tab l.G in response to 

Information Request No. 1. 

6. The document entitled "Consent to Act as Director and Officer 

-Mary E. Comazzi" being filed as Tab 1.H in response to 

Information Request No. 1. 

7. The document entitled "Unanimous Shareholder Agreement" 

being filed as Tab 1.I in response to Information Request No. 1. 

8. The document entitled "Release of Liability" being filed as Tab 

1.J in response to Information Request No. 1. 

9. The document entitled "Consulting Contract" being filed at Tab 

1.K in response to Information Request No. 1. 

10. The document entitled "Loan Agreement" being filed at Tab 

1.L in response to Information Request No. 1. 

11. The document entitled "Summary of the Terms of the Sale" 

being filed at Tab l.Q in response to Information Request No. 

1. 

12. The document entitled "Affidavit of William MacDonald" 

being filed at Tab 10.A in response to Information Request No. 

10. 

13. The document entitled "Employee List" being filed at Tab 9.A 

in response to Information Request No.9. 

14. The document(s) collectively entitled "Asset Acquisition 

Agreement with Schedule A through G" being filed at Tab 12.A 

DSMDB-3099607vl 
in response to Information Request No. 12. 

15. The document(s) collectively entitled "Aircraft Sub Lease 

Agreement and Amendment" being filed at Tab 12.B in 

response to Information Request No. 12. 

16. The document(s) collectively entitled "VIH Aerospace related 

Purchase Orders, Service Orders and Invoices" being filed at 

Tab 12.C in response to Information Request No. 12. 

17. The document(s) collectively entitled "Invoice Between VIH 

Cougar and CHI" being filed at Tab 12.D in response to 

Information Request No. 12. 

18. The document(s) collectively entitled "VIH Helicopters Ltd. 

Invoices, Credit Notes and Related Amendments" being filed at 

Tab 12.E in response to Information Request No. 12. 

19. The document entitled "Technical Support Order 

#001/11/06/2012" being filed at Tab 13.A in response to 

Information Request No; 13. 

20. The document entitled "Helicopter Technical Support 

Agreement" being filed at Tab 13 .B in response to Information 

Request No. 13. 

21. The document entitled "Subcontract Agreement" being filed at 

Tab 13.C in response to Information Request No. 13. 

22. The document entitled "Subcontract Agreement" being filed at 

Tab 13.D in response to Information Request No. 13. 

23. The document entitled "Technical Support Order 

#001/17/07/2012" being filed at Tab 13.E in response to 

Information Request No. 13. 

24. The document entitled "Helicopter Technical Support 

Agreement" being filed at Tab 13 .F in response to Information. 

Request No. 13. 

25. The document entitled "Subcontract Agreement" being filed at 

Tab 13.G in response to Information Request No. 13. 

26. The document entitled "Technical Support Order 

#001117/07/2012" being filed at Tab 13.H in response to 

Information Request No. 13. 

27. The document entitled "Helicopter Technical Support 

Agre~ment" being filed at Tab 13 .I in response to Information 

Request No. 13. 

28. The document(s) collectively entitled "Lease agreements 

related to N139WH" being filed at Tab 14.A in response to 

Information Request No. 14. 

29. The document(s) collectively entitled "Lease agreements 

related to N901VH" being filed at Tab 14.B in response to 

Information Request No. 14. 

30. The document(s) collectively entitled "Lease agreements 

related to N920VH" being filed at Tab 14.C in response to 

Information Request No. 14. 

2 

DSMDB-3099607vl 
31. The document(s) collectively entitled "Lease agreements 

related to N921 VH" being filed at Tab 14 .D in response to 

Information Request No. 14. 

32. The document(s) collectively entitled "Lease agreements 

related to N925VH" being filed at Tab 14.E in response to 

Information Request No. 14. 

3 

DSMDB-3099607vl 
EXHIBIT B 
BEFORE THE 

DEPARTMENT OF TRANSl10RTATION 

OFFICE OF TliE SECRETARY 

WASHINGTON, D.C. 

In the matter of the ca.m:ellation of the 

Air Taxi authority issued to: 

I 

I 

I 

I 

Docket DOT-·OST-2012-0022 

VIH COUGAR HELICOPTERS, INC. I ___ I 

I, Christopher G. Turner, hereby declare as follows pursuant to 28 U.S.C. § 1746: 

1. I am the President and Secretary of VIH Cougar Helicopters, Inc. ("VII-I Cougm:") and 

have served in that position since June 27, 2012. I am also the President of Construction 

Helicopters, Inc. ("CHI"), a position which I have held since 1995. I have also been the owner 

of CHJ since 1997. 

2. I vmrk and reside in the State of Michigan. I am the primary contact for both companies 

for any government requests for information or investigations. I am familiar with the documents 

at i8sue here as well as VIH Cougar's and CHI's policies regarding the dissemination of their 

information. 

3. The facts stated in this declaration are based upon my personal knowledge, on my review 

and familiarity with VIH Cougar and CHI business records that are maintained in the ordinary 

course of business, and on information collected by other Vl.H Cougar and CHI employees and 

by counsel. I am competent to testify to the statements herein and would so testify if called to do 

so. 

4. I have reviewed the documents outlined below and the information contained in VIH 

Cougar's Response document, which I understand, on information and belief, is being provided 
to the Department in connection with the above-captioned proceedings in response to certain 

Requests for Information that were issued by the Department of Transportation on or about 

August 24, 2012. I reference all of the documents and the information contained in VlH 

Cougar's Response herein collectively as "the Documents." 

5. The Documents contain conf1dential, commercial information regarding VIH Cougar's 

organization, operations, capabilities, strategic alliances, suppliers, vendors, and customer base, 

including the tenns and conditions of those business arrangements. The Documents also contain 

confidential, commercial information of non-parties to these proceedings, such as CHI, regarding 

the :same or similar subjects and concerns. 

6. The Documents are commercially-valuable and confidential, and some also include 

confidential personal information. Both VIH Cougar and CHI take reasonable steps to guard 

against any unauthorized dissemination ofthis inh1rmation, thereby protecting its commercial 

value. The release of this confidential, commercial information would give direct competitors of 

VIH Cougar and CHI (such as Petroleum Helicopters, Inc., which I understand is a participant in 

these proceedings) access to sensitive and valuable information that they would not otherwise 

have but for these proceedings- a particular concern for non-parties such as CHI -and the 

infc•nnation inequality would likely place VIH Cougar and CHI at an unf'air competitive 

disadwmtage in relation to those competitors when pursuing the same or similar business 

opportunities or formulating and/or executing strategic alliances and similar pursuits. 

7. Based on my review and understanding, a description of the confidential documents and 

infonnation is as follows: 

2 
a. The document "Share Purchase & Sale Agreement" being filed as Tab l.A in 

response to Information Request No. 1 contains confidential information. Specifl.cally, the 

document contains commercially sensitive contractual terms and conditions. 

b. The document "Consent to Act as Director and Oft1cer- Christopher G. Turner" 

being filed as Tab l.E in response to Information Request No. 1 contains confidential 

infonnation. Specifically, the document contains a personal home address. 

c. The document "Consent to Act as Director and Officer- James R. Russell" being 

filed as Tab LF in response to Information Request No. 1 contains confidential inforn1ation. 

Specifically, the document contains a personal home address. 

d. The document '<Consent to Act as Director and Officer-· Kenneth Norie" being 

filed as Tab 1. Gin response to Information Request No. 1 contains confidential information. 

Specifically, the document contains a personal home address. 

e. The document "Consent to Act as Director and Officer- Mary E. Comazzi" being 

flied as Tab l.H in response to Information Request No. 1 contains confidential information. 

Specifically, the document contains a personal home address. 

f. The document "Unanimous Shareholder Agreement" being filed as Tab 1.I in 

response to Information Request No. 1 contains confidential information. Specifically, the 

document contains commercially sensitive contractual tem1s and conditions. 

g. The document "Release of Liability" being filed as Tab l.J in response to 

Information Request No. 1 contains confidential information. Specifically, the docmnent 

contains commercially sensitive contractual terms and conditions. 

3 
h. The document "Consulting Contract" being filed at Tab l.K in response to 

Information Request No. 1 contains confidential information. Specifically, the document 

contains commercially sensitive contractual terms and conditions. 

r. The document "Loan Agreement" being filed at Tab l.L in response to 

Information Request No. 1 contains confidential information. Specifically, the document 

contains commercially sensitive contractual terms and conditions. 

j. Some ofthe information in the document "Summary ofthe Terms of the Sale" 

being filed at Tab l.Q in response to Information Request No. 1 contains confidential 

information. Specifically, the document contains commercially sensitive contractual terms and 

conditions. 

k. Some of the information contained in the written Response to Information 

Request No. 6 is confidentiaL Specifically, the response contains commercially sensitive 

contractual terms and conditions. The response also contains commercially sensitive information 

related to a non-parties business plans, strategies and contractual agreements. 

I. Some of the information contained in the written Response to Information 

Request No. 8 is confidential. Specifically, the response contains commercially sensitive 

infonnation related. to changes in management and the strategic responsibilities of key personnel. 

m. The document "Aff:idavit of William MacDonald" being :filed at Tab 10.A in 

response to Intormation Request No. 10 contains confidential information. Specifically, the 

affidavit contains commercially sensitive information related to changes in management and the 

strategic responsibilities of key personnel. 

n. The document "Employee List" being fi1ed at Tab 9.A in response to Information 

Request No.9 contains confidential information. Specifically, the document contains 

4 
confidential personal information regarding the citizenship and employment status ofVIH 

Cougar employees and non-party workers. The response also contains commercially sensitive 

infonnation related to valuable talent and talent retention. Furthermore, VIH Cougar has an 

obligation and a duty to protect sensitive information and identities of its employees and the 

employees of its non-pmiy contractors. 

o. Some of the information contained in the written Response to Information 

Request No. 12 is confidential. Specif!eally, the response contains commercially sensitive 

comractual terms and conditions. The response also contains commercially sensitive information 

related to a non-parties business plans, strategies and contractual agreements. 

p. The document(s) "Asset Acquisition Agreement with Schedule A through G" 

being filed at Tab 12.A in response to Information Request No. 12 contains confidential 

infcm1ation. Specifically, the document(s) contain commercially sensitive contractual terms and 

conditions. 

q. The documcnt(s) "Aircraft Sub Lease Agreement and Arnendment" being filed at 

Tab 12.B in response to Information Request No. 12 contains confidential infonnation. 

Speciflca1ly, the document(s) contain commercially sensitive contractual terms and conditions of 

a non-pmiy. 

r. The document(s) "VIH Aerospace related Purchase Orders, Service Orders and 

Invoices" being filed at Tab :1 2.C in response to Information Request No. 12 contains 

confidential information. Specifically, the document(s) contain commercially sensitive business 

information of a non-party related to past purchases and service. 

s. The document(s) "Invoice Between VIH Cougar and CHf"' being llled at Tab 

l2.D in response to Infc>rmation Request No. 12 contains confidential information. Specif!cal ly, 

5 
the document(s) contain commercially sensitive business infbrmation of a non-party related to 

past purchases and service. 

t. The document(s) ''VIH Helicopters Ltd. Invoices, Credit Notes and Related 

Amendments" being ±!led at Tab 12.E in response to Information Request No. 12 contains 

confidential information. Specifically, the document(s) contain commercially sensitive business 

information of a non-party related to past purchases and service orders. 

u. Some of the information contained in the written Response to Information 

Request No. 13 is confidentiaL Specifically, the response contains commercially sensitive 

information related to VIH Cougar's business plans, strategies and contractual agreements. 

v. The document "Technical Support Order #001111/06/2012" being filed at Tab 

13.A in response to Information Request No. 13 contains confidential information. Specifically, 

the document contains commercially sensitive contractual terms and conditions. 

w. The document ''Helicopter Technical Support Agreement" being filed at Tab 13.B 

in response to Information R<-;quest No. 13 contains confidential information. Speciflcally, the 

document contains commercially sensitive contractual tenns and conditions. 

x. The document "Subcontract Agreement" being filed at Tab 13.C in response to 

Information Request No. 13 contains confidential infonnation. Specifically, the document 

contains commercially sensitive contractual terms and conditions. 

y. The document "Subcontract Agreement" being filed at Tab 13.D in response to 

Infonnation Request No. 13 contains confidential information. Specifically, the document 

contains commercially sensitive contractual terms and conditions. 

6 
z. The document "Technical Support Order #00 1/17/07/20 12" being filed at Tab 

13.E in response to Information Request No. 13 contains confidential information. Specifically, 

the document contains commercially sensitive contractual tenns and conditions. 

aa. The document "Helicopter Technical Support Agreement" being filed at Tab 13.F 

in response to Information Request No. 13 contains confidential infonnation. Specifically, the 

document eon-::ains commercially sensitive contractual terms and conditions. 

bb. The document ''Subcontract Agreement" being 11led at Tab 13. G in response to 

Information Request No. 13 contains confidential information. Specifically, the document 

contains commercially sensitive contractual terms and conditions. 

cc. The document "Technical Support Order #00 l/17 /07 /2012" being filed at Tab 

13.H in response to Information Request No. 13 contains confidential information. Specifically, 

the document contains eommercially sensitive contractual terms and conditions. 

dd. The. document "Helicopter Technical Support Agreement'' being filed at l'ab 13.I 

in response to Infonnation Request No. 13 contains confidential infmmation. Specifically, the 

document contains commercially sensitive contractual tenns and co11clitions. 

ee. The document(s) "Lease agreements related to N139'vVH" being filed at Tab 14.A 

in response to Infonnation Request No. 14 contains confidential infommtion. Specifically, the 

doc:ument(s) contain commercially sensitive contractual terms and conditions. 

ff. The document(s) "Lease agreements related to N901VH" being filed at Tab 14.B 

in response to Information Request No. 14 contains confidential information. Specifically, the 

document(s) contain commercially sensitive contractual terms and conditions. 

7 
gg. The document(s) "Lease agreements related to N920'VH" being filed at Tab 14.C 

in r,;sponse to Information Request No. 1.4 contains confidential information. Specifically, the 

document(s) contain commercially sensitive contractual terms and conditions. 

hh. The document(s) "Lease agreements related to N921 VH" being filed at Tab 14.D 

in response to Information Request No. 14 contains confidential information. Specifically, the 

document(s) contain commercially sensitive contractual terms and conditions. 

11. The document(s) "Lease agreements related to N925VH" being filed at Tab l4.E 

in response to Information Request No. 1.4 contains confidential information. Specifically, the 

document(s) contain commercially sensitive contractual terms and conditions. 

I declare under penalty of perjury pursuant to the laws of the United States of America 

that the foregoing is true and correct. 

Executed on September 21, 20 12 

Christopher G. Turner 

8