BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_________________________________________ 

 ) 

Application of ) 

 ) 

EASTERN AIR LINES GROUP, INC. ) DOCKET OST-2014-0012/13

 ) 

for a Certificate of Public Convenience ) 

and Necessity (Interstate Passenger ) 

Charter Service) ) 

_________________________________________ )

MOTION OF EASTERN AIR LINES GROUP, INC.

FOR CONFIDENTIAL TREATMENT

Communications with respect to this document should be sent to:

Edward J. Wegel

President and CEO

EASTERN AIR LINES GROUP, INC.

Building 5A, Miami Int’l Airport

Miami, FL 33142

(305) 869-4249

ed.wegel@easternairlines.aero 

John R. Mietus, Jr.

Law Office of John Mietus, LLC

6701 Democracy Blvd., Suite 300

Bethesda, MD 20817-7500

(202) 747-5212

john@mietuslaw.com 

Counsel for EASTERN AIR LINES

GROUP, INC.

July 18, 2014
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_________________________________________ 

 ) 

Application of ) 

 ) 

EASTERN AIR LINES GROUP, INC. ) DOCKET OST-2014-0012/13

 ) July 18, 2014

for a Certificate of Public Convenience ) 

and Necessity (Interstate Passenger ) 

Charter Service) ) 

_________________________________________ )

MOTION OF EASTERN AIR LINES GROUP, INC.

FOR CONFIDENTIAL TREATMENT

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

§ 302.12, Eastern Air Lines Group, Inc. respectfully moves to withhold from 

public disclosure the contents of Confidential Exhibits D-G produced in 

response to the Department’s May 12, 2014 information request and referred 

to in the “Update Letter” that Eastern is filing simultaneously with this 

motion. In accordance with Rule 12, the exhibits have been marked 

“Confidential” and are being filed under seal.

Confidential Exhibits D and E contain detailed, sensitive information 

relating to VV-DC Eastern Investments, LLC and its stockholder and creditor 

arrangements with Eastern. The ownership and control of VV-DC, and the 

substance of its arrangements with Eastern, have been described publicly in

the Update Letter. However, the documents included in the Confidential 

Exhibits provide specific details concerning the business relationships 
Eastern

Motion 

Page 2 

between VV-DC, its owners and managers, and Eastern, including financial 

terms and information about private funds that support the VV-DC line of 

credit. This information is not public, and disclosure could cause these 

companies and individuals commercial harm. The Department routinely 

grants confidential treatment to such private information. See, e.g., Cargo 

360, Inc., Order 2005-12-19 at 9-10; Prime Air, Inc. dba TransMeridian 

Airlines, Order 1995-6-25 at 8-9. 

Confidential Exhibit F is an updated copy of Eastern’s Private 

Placement Memorandum. It includes financial and business information and 

forecasts at a level of detail, and for a forecast horizon, well beyond that 

which is required by the Department’s Rules, and such information would not 

normally be released to the public. The Department has granted confidential 

treatment to similar, private securities offering documents. See, e.g., 

SkyLink Airways, Inc. dba Maxjet, Order 2005-1-1 at 10.

Confidential Exhibit G contains an updated list of FAA certificate 

numbers for key personnel who hold such certificates. The Department 

previously has found that confidential treatment of such numbers is 

appropriate, among other reasons, because they may be keyed to social 

security numbers and are otherwise private. See, e.g., Rhoades Aviation, Inc. 

dba Transair, Order 2013-1-13, at 7. 

In sum, the information sought to be withheld from public disclosure 

meets Department precedent for nondisclosure and the standards found in