BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

_________________________________________ ) Application of ) ) EASTERN AIR LINES GROUP, INC. ) DOCKET OST- 201 4-0 012/13 ) 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 Jo hn 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, 2014BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

_________________________________________ ) Application of ) ) EASTERN AIR LINES GROUP, INC. ) DOCKET OST

- 201 4-0 012/13 ) July 1 8 , 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 withh old 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 wit h Rule 12, the exhibits have been marked “Confidential” and are being filed under seal. Confidential Exhibit s 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 relationshipsEastern Motion Page 2 between VV

- DC, its owners and managers, and Eastern, including financial terms and information about private fu nds 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
3 60, 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 a n 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., Rhoad es 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