Application of 

BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

LIBERTY HELICOPTERS, INC. 

for authority to conduct scheduled passenger operations as a 

commuter air carrier under 49 U.S.C. 41738 

Docket DOT-OST-2015-0037 

SUPPLEMENT TO APPLICATION OF LIBERTY HELICOPTERS, INC. 

Communications with respect to this document should be sent to: 

Chris V ellios 

Liberty Helicopters, Inc. 

165 Western Road 

Kearny, NJ 07032 

(908) 533-9021 (phone) 

velliosc@libertyhelicopters.com 

CFO/COO 

Liberty Helicopters, Inc. 

Dated: April 30, 2015 

Paul A. Lange 

Law Offices of Paul A. Lange 

80 Ferry Boulevard 

Stratford, CT 06615 

(203) 375-7724 (phone) 

(203) 375-9397 (fax) 

pal@lopal.com 

Attorney for 

Liberty Helicopters, Inc. 
Application of 

BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

LIBERTY HELICOPTERS, INC. 

for authority to conduct scheduled passenger operations as a 

commuter air carrier under 49 U.S.C. 41738 

Docket DOT-OST-2015-0037 

SUPPLEMENT TO APPLICATION OF LIBERTY HELICOPTERS, INC. 

In response to the Department's Information Request dated April!, 2015, and pursuant to 

section 41738 of Title 49 of the United States Code (the "Statute"), Liberty Helicopters, Inc. 

("LHI") hereby submits the following additional information in support of its application for 

authority to operate scheduled passenger service as a commuter air carrier ("Application"). 

General Information 

I. DEPARTMENT REQUEST: In its application, Liberty states that flights operated 

under the proposed commuter operations will be predominantly arranged via software 

applications that allow customers to crowdsource charter flights. Please provide detailed 

information on how the proposed crowdsourcing arrangement will operate. 

LHI RESPONSE: LHI intends to use its commuter authority to operate app-scheduled 

flights arranged through third party app providers. The app providers will make the apps 

publically available for download onto a smartphone or tablet. A person must subscribe as a user 

and expressly agree to the terms and conditions associated with the app's use, which will include 
disclosures approved by DOT's Aviation Enforcement Office regarding the capacity in which the 

third party arranges flights via the app, e.g., as the agent of the customer or agent of LHI. A 

person wishing to book a flight will, after opening the application have the following options: (I) 

start a new flight at the time of their choosing ("Launch Customer") making any open seats 

available to the other app users; or (2) buy a seat on an existing flight ("Seat Customer") 

scheduled to depart at the time chosen by a Launch Customer. A flight is only scheduled when a 

Launch Customer using option l initiates a flight. A Launch Customer assumes the responsibility 

for the cost of the entire aircraft. Payment is made by credit card at the time the flight is 

arranged. 

Seat Customers may cancel their reservations by providing notice not less than 24 hours 

prior to the scheduled departure time of the flight. Upon canceling within the above stated 

parameters, Seat Customers receive a credit that may be used for future travel. No cash refunds 

are provided. A cancellation made within 24 hours of flight time will result in a forfeiture of the 

full ticket price. For any credit not used at the end of the season - currently September of the 

year purchased - Seat Customers can keep the credit in their account and use it for the balance of 

this season/next year's season and receive a one-time l 0% discount towards the purchase of 

individual seats on a scheduled flight. 

Launch Customers assume the full risk of the flight and have a responsibility to fly at the 

chosen time, with cancellation permitted only under the following conditions: 1) cancellation 

notice is provided at least 24 hours prior to the scheduled flight time AND 2) no Seat Customers 

have purchased seats on the scheduled flight. In that event, the Launch Customer may cancel the 

flight and receive a full refund. However, if one (l) or more Seat Customers have booked seats 

2 
on that flight before the cancellation notice is provided, the flight will operate and the Launch 

Customer will be charged accordingly. 

Weather Cancellations: All of LHI's flights under the Proposed Service are of very short 

duration. Passengers who experience a weather-related cancellation can elect either a full refund, 

or to be transported by car to their destination and receive a credit for the amount paid for their 

transportation. 

Credits: Credited amounts may be used for transportation through the beginning of 

September of the year of purchase. At that time, a consumer can elect to receive a full refund or 

maintain the credit and receive a 10% discount on a future flight. 

2. DEPARTMENT REQUEST: Please list subsidiaries, if any, of Sightseeing Tours 

of America, Inc. ("STA"), and include a description of each organization's principal business. 

LHI RESPONSE: See Exhibit A. 

Ownership and Key Personnel 

1. DEPARTMENT REQUEST: Resume for Mr. Drew Schaefer does not have a 

description of responsibilities handled at each place of employment. Please submit a complete 

resume, including a brief description of responsibilities held at each place of employment and 

provide compliance information as required by sections 204.3 (I), (m), ( o ), (p ), and ( q) of our 

rules. Since Mr. Schaefer holds multiple positions within ST A and subsidiaries, please indicate 

how much time he will devote to Liberty's operations. 

LHI RESPONSE: Attached hereto as Exhibit ~ is a revised resume and statement of 

Drew Schaefer. LHI and Liberty Helicopters, Inc. (N.Y.) (the operating entity for the 

sightseeing operation) are the primary operating entities of ST A, and Mr. Schaefer generally 

splits his time between both entities, depending on the season. Chris Vellios, as COO and CFO 

3 
on LHI, has primary responsibility for the day-to-day operations of LHI, including the Proposed 

Service. 

2. DEPARTMENT REQUEST: Resume provided for Mr. Steve Brown identified no 

employment between June 2008 and October 2009. Please explain the gap in employment. If he 

was unemployed, please state. 

LHI RESPONSE: On February 16, 2015, LHI hired a new Director of Maintenance, 

Benjamin Yelle to replace Mr. Brown Attached hereto as Exhibit C is the resume, statement, 

and Affidavit of Safety Compliance from Mr. Yelle. 

Financial Position 

I. DE?ARTMENT REQUEST: Please provide balance sheet and mcome 

statements, for the years 2012, 2013, and 2014 along with their explanatory footnotes. 

LHI RESPONSE: Balance Sheets and Income Statements for LHI were attached to the 

Application as Exhibit ;u. Attached as Exhibit D hereto are explanatory footnotes for the 2012, 

2013, and 2014 LHI Balance Sheets and Income Statements. 

2. DEPA TMENT REQUEST: Please submit a current (within 3 months of the date 

of the request is filed) balance sheet and income statement of Liberty along with the 

accompanying explanatory footnotes. 

LHI RESPONSE: The 2014 balance sheet and income statement submitted with the 

application as Exhibit ;u was current as of the February 20, 2015, date of filing. 

3. DEPARTMENT REQUEST: The first year forecast profit and loss statement does 

not appear to include significant expense categories such as aircraft lease and hangar expenses. 

In other words, insufficient detail was provided on the expense categories shown and, as a result, 

we cannot determine whether these expenses are reasonable. In light of the foregoing, we ask 

4 
that you provide a new first year profit and loss forecast (broken down by month or by quarter) 

which, at a minimum, provides details by expense category (direct and indirect) for all expenses 

that will be incurred in conducting the proposed commuter operations, indicating how the 

amounts were computed. These expenses should include all cash and non-cash (i.e., aircraft or 

facilities depreciation or lease expense) items that are related to the provision of the proposed 

operations. If certain of the expenses will be assumed by a third-party, Liberty should include 

footnotes to this effect and provide independent third-party verification supporting its statements. 

If certain expenses normally associated with air transportation operations will not be incurred, 

please explain. 

LHI RESPONSE: Attached as Exhibit .E are revised notes to the Proposed Service 

Details Profit and Loss Statement that is attached to the Application as Exhibit 1.2. Because LHI 

in an existing air taxi and charter provider, it does not anticipate incurring new hanger expenses 

associated with the Proposed Service. Lease expenses, where applicable, are noted as Managed 

Aircraft expenses. An example of the lease arrangement that LHI has with its sister company, 

Meridian Consulting I Corporation, Inc. is attached hereto as Exhibit E. Non-cash expenses will 

be assumed by LHI's parent, Sightseeing Tours of America, Inc. See Statement of Chris Vellios, 

attached hereto as Exhibit G. 

4. DEPARTMENT REQUEST: Please provide a detailed pre-operating expense 

forecast for the proposed commuter operations. This forecast should include, among other things, 

lease deposits and rents, legal expenses, station expenses, facility deposits and rents, training, 

insurance, general, administrative, and employee expenses and expenses related to FAA 

certification. Additionally, such list should distinguish between pre-operating expenses that have 

been paid, and those which remain to be paid. 

5 
LHI RESPONSE: As LHI noted in its application, because it is an existing Part 135 

operator that currently provides air transportation services to the same markets that it looks to 

serve with enhanced commuter authority, it does not anticipate significant pre-operating 

expenses. For example, LHI will not be leasing new aircraft or hangers. The only pre-operating 

expenses that could be attributed to the Proposed Service are the legal fees associated with the 

Application and other regulatory approvals, as well as some minor training fees. See Exhibit H. 

5. DEPARTMENT REQUEST: Generally, the air carrier must demonstrate that it 

will have available funding sufficient to cover any current working capital deficit and any preoperating expenses, as well as an average of three months of the additional operating expenses 

that would result from the expanded operation. Please provide third party verification of all 

available funds, together with a summary of all plans for additional funding required to meet the 

Department's financial fitness test. 

LHI RESPONSE: LHI intends to fund both the initial and pre-operating expenses 

through its working capital account. To the extent additional resources are required, LHI's 

parent, ST A will make additional funding available in order to cover such expenses, or any 

current working capital deficit. See Statement of Chris Vellios, attached hereto as Exhibit G. 

6 
WHEREFORE, Liberty Helicopters, Inc., respectfully requests that the Department of 

Transportation grant it the authority to conduct scheduled commuter air transportation services 

·pursuant to 49 U.S.C. § 41738 and 14 CFR Part 298. ' ~ ~ :' . ' i . ' •. 

April 30, 2015 

7 

Respectfully submitted, 

Benjamin H. Klein 

Paul A. Lange 

Law Offices of Paul A. Lange 

80 Ferry Boulevard 

Stratford, CT 06615 

(203) 375-7724 (phone) 

(203) 375-9397 (fax) 

pal@lopal.com 

Attorneys for Liberty Helicopters, Inc. 
VERIFICATION 

The contents of this application and the attached exhibits are true and correct to the best of my 

knowledge and belief. Pursuant to Title 18 U.S.C. § 1001, I Chris Vellios, in my individual 

capacity and as the authorized representative of the applicant, have not in any manner knowingly 

and willingly falsified, concealed or covered up any material fact or made any false, fictitious, or 

fraudulent statement or knowingly used any documents which contain such statements in 

connection with the preparation, filing or prosecution of the application. I understand that an 

individual who is found to have violated the provisions of 18 U.S.C. § 1001 shall be fined or 

imprisoned not more than five years, or both. 

Chris Vellios 

CFO/COO 

Liberty Helicopters, Inc. 
CERTIFICATE OF SERVICE 

I certify that on this 30 day of April 2015, I have caused the foregoing Supplement to 

Application of ~iberty Helicopters, Inc. to be served by first class mail, postage prepaid, upon 

the persons shown in the following service list: 

George BeiiDett, Manager 

DeiiDis Kaskovich, FAA Principle Operations Inspector 

Federal Aviation Administration 

Teterboro Flight Standards District Office 

Park 80 West, Plaza One 

250 Pehle Avenue, Suite 003 

Saddle Brook, NJ 07663 

Jim Brundige 

P.O. Box 836 

East Hampton, NY 1!937 

Anthony Ceglio 

Gabreski Airport, Administration Building# I 

Westhampton, NY 11978 

Helen Gill 

Montuak Airport 

P.O. Box 1477 

Montauk, NY 11954 

Benjamin H. Klein, Esq. 
Exhibit A 
Parent 

Subsidiary 

Subsidiary 

Subsidiary 

Subsidiary 

STA Organizational Chart 

Sightseeing Tours of America, Inc. ("STA") 

Description: Management Company for the four entities below 

Liberty Helicopters, Inc. (N.Y.) 

Description: Company responsible for Helicopter tour function 

100% owned by STA 

Liberty Helicopters, Inc. 

Description: Company responsible for Charter operations; Holds Part 13S certificate 

100% owned by STA 

Meridian Consulting I Corporation, Inc. 

Description: Owner of helicopter fleet 

100% owned by STA 

Aviation Technical Services, Inc. 

Description: Dormant Company for approximately 12 years; previously used for helicopter maintenance 

100% owned by STA 
Exhibit B 
DREW SCHAEFER 

152 West 57'h 52"d floor 

New York NY 10019 

dscha eS SSS@aol.com 

Employment History 

• Founder, Chairman and CEO of Sightseeing Tours of America 

and subsidiaries the parent, of Liberty Helicopters of New York 

• General Board oversight and Policy. 

• Co-Chairman of Unimed Holdings LLC 

• Board oversight and reporting 

• Director and CEO of Carnegie Hudson Resources LLC 

• Founder and general management oversight of Beard 

• Chief Operating Officer Pacific Capital Group 

• Management of operations and deal structuring 

• Founder, Chairman and CEO of the Aegis Consumer Finance Co. 

• Management oversight 

• Chairman and CEO of Americorp Financial Services 

• Management oversight 

• Executive Vice President Taxable Fixed Income at 

Donaldson, Lufkin and Jenrette 

Institutional Sales and trading 

• Sr. Vice President of EF Hutton and Company 

• lnstutional Sales and trading 

Education 

1985- Present 

2013- Present 

2007- Present 

2003-2006 

1989-1993 

1992-1997 

• Graduated from The University of Scranton with degrees in Economics and Finance 1979 - 1982 

• Manasquan High School graduated 1979 
I, Drew Schaefer, hereby certify, on this £day of April, 2015, as follows: 

I. I am the Chief Executive Officer of Liberty Helicopters, Inc. 

2. I am a citizen of the United States. 

3. I have no reportable matters pursuant to sections 204.3 (1), {m), (o), (p), or (q) of the DOT 

Rules, except for the following: 

a. with respect to section 204.3(1), a common tort action seeking damages for 

personal injury arising from a 2001 aircraft accident remains pending against 

numerous defendants including Liberty Helicopters, Inc., Liberty Helicopters, Inc. 

(NY), Liberty Helicopter Tours, Inc., Liberty Helicopters, Liberty Helicopters 

Tours, Liberty Helicopters Tours ofNew York, Inc., Drew E. Schaefer and 

Meridian Consulting Co. Inc., and is presently scheduled to proc o mediation 

within the next several weeks. 

Drew Schaefer 

Chief Executive 0 er 

Liberty Helicopters, Inc . 

• 
Exhibit C 
Date:_"'.:;-l:..:,'~~-'-/'"'-!) __ 

1) 15$enj .. ..,·..- Y~. Director of Maintenance of Sightseeing Tours of America, am a US citizen. 

2) I do not hold any stock in Liberty Helicopters or parent company Sightseeing Tours of America. 

3) I fully meet the requirements of 14 CFR 119.65 and 119.67 to act as the Director of 

Maintenance. 

4) I have no formal complaint or pending actions from the FAA or DOT. 

5) As the Director of Maintenance, I am overall responsible for the airworthiness of the aircraft on 

the company FAA Part 135 certificate. 

6) I began employment with the company :z/1 4-/t& 

I I 

Name:3M1j_-;,J Yutc. 

Director of Wlaintenance 

Liberty Helicopters Inc. 

Email Address 

Phone number 
Benjamin Yelle 

20FinnRd. Cell: 201-844-7050 

Pittstown, New Jersey 08867 

e-mail: byelle@libertyhelicopters.com 

SUMMARY 

Proven Aviation Professional with ability to manage Technical and Customer Support 

Maintenance organizations to their maximum ability, while staying within company set 

budget limits. 

• Well known and respected in the industry as an American Eurocopter, Bell 

Helicopter, Turbomeca, and Rolls Royce product expert. 

• Able to direct complex projects from concept to fully operational status. 

• Organized, highly motivated and detail directed problem solver. 

• Goal-oriented individual with strong leadership capabilities. 

PROFESSIONAL EXPERIENCE 

LIBERTY HELICOPTERS- Kearny, New Jersey 

Director of Maintenance 

2015- Present 

• Manage the maintenance operation that includes 9 Airbus AS350 helicopters 3 Airbus AS 

355 helicopters, and 1 Airbus EC 135 helicopter. 

• Develop training syllabus for maintenance personal. 

• Implemented a new aircraft tracking system. 

TSI - Pinon Hills, Ca. 

Self Employed 

2012-2015 

• Maintain and troubleshoot Bell412's,Bell206BIII, L3, U Be11222, Bell407, and AS 

350B,B2 and B3. 

• Reorganize company maintenance departments. 

• Developed a aircraft tracking system. 

• Developed an MEL for customers. 

• Developed troubleshooting procedures for various aircraft. 

HELICOPTER FLIGHT SERVICES- Teterboro, New Jersey 

Director of Maintenance 

2010-2012 

• Manage the maintenance operation that includes 5 Bell407, 1 Eurcopter AS 350B3, and 

I Sikorsky S-76C+ helicopters with 9 mechanics and support personnel 
• Developed and taught training classes for the maintenance and the pilot staff. 

• Developed the MEL for the Bell407, the Eurocopter AS350B3, and the Sikorsky S76C+. 

• Developed the Part 135 Manual for Bell407, Eurocopter AS350B3, and the Sikorsky S76C+. 

BELL HELICOPTER TEXTRON- Ft. Worth, TX 

Customer Support Representative 

1999-2010 

• Assist customers 24 hours a day, 365 days a year with maintenance problems, 

troubleshooting ASB, TB, and AD compliance, spares purchasing, and coordinating 

training needs. 

• Fourth and present assignment: Support customers in Southern California, and Southern 

Nevada; including the LAPD, LA City Fire, LA Water and Power, San Diego Fire and 

Rescue, Orange County Fire, San Diego Sheriff, San Bernardino County Sheriff, FBI, 

DEA, Air Methods, Mercy Air, Reach Air, Harrison Ford, and many other Law 

Enforcement, EMS, Fire Departments, and Corporate operators. 

• Third assignment: Northeast U.S., New York and all of New England including the New 

Y ark State Police, New Y ark City Police, Connecticut State Police, New Hampshire 

State Police, Mercy Air, Patricia Cornwell, and many other Law Enforcement, Fire, 

EMS, and Corporate operators. 

• Second assignment: Gulf States, PHI, Air Logistics, ERA, Rotorcraft Leasing, Louisiana 

State Police, Arkansas State Police, Little Rock PD and all of the other Bell operators in 

Louisiana, and Arkansas. 

• First assignment: Bell430 operated by the Ruler of Bahrain, Sheik Hamad bin Isa AI 

Khalifa. Maintained the aircraft and all records. Held training class for the local Bahraini 

mechanics, and pilots. 

DUBAI AIR FORCE- Dubai, United Arab Emirates 

Director of Maintenance 

1993- 1999 

• Managed the maintenance operation that included 59 aircraft, 49 helicopters, I 0 fixed 

wing, with 160 maintenance and support personnel. 

• Develop training and taught classes for pilot ground school for Bell 206Bill, Bell 

205Al, Bell212, Bell214B, Agusta Bell412SP, AgustaBe11412HP, Aerospatiale341G 

Gazelle, Alenia Aermacchi M-346 fighter jets, Pilatus PC-7and CASA 235M operated 

by the organization. 

• Managed a budget of$ 12,000,000.00 

ARABIAN HELICOPTERS- Riyadh, Saudi Arabia 

Director of Maintenance 

1989-1993 
• Managed maintenance organization for Ministry of Defense and Aviation(MODA) 

operating 9 Aerospatiale 365N, 6 Bell212, 2 Lear 35, I Gulfstream G2, 1 Gulfstream G3 

and a crew of 85 maintenance and support personnel. 

• Implemented training for all maintenance personnel in order to insure a safe operation. 

• Managed a budget of$ 8,000,000.00 

VOYAGEUR HELICOPTERS- Jupiter, Florida 

President/Owner/Director of Maintenance 

1984-1989 

• Established a business in south Florida maintaining Bell, Aerospatiale, McDonald 

Douglas and Agusta helicopters. Built the business from 6 customer aircraft to 49 

customer aircraft in six months operating out of south Florida, and Puerto Rico. 

• Managed all aspects of the maintenance that included maintaining 25 AS350, 5 AS 355, 3 

SA 341,2 MD500, and 15 Bell206, 2 205A1 and 2 A109C helicopters. 

• Helicopters operations included Law Enforcement, Fire Fighting, EMS, Agricultural 

work, and Filming. 

• Company consisted of 12 employees and a budget of$ 750,000. 

AEROSPA TIALE HELICOPTER CORP.- Grand Prairie, TX. 

Technical Representative 

1980-1984 

• Traveled all over the US and Canada in supporting Aerospatiale Helicopters operators 

with maintenance problems, troubleshooting and with ASB, TB, and AD compliance. 

• Supported and traveled with Marketing Managers to assist in the sale of our product 

throughout North America. 

• Supported all existing EMS programs, and set up new programs. 

AVIATION MEDICAL SERVICES- Houston, Texas 

Director of Maintenance 

1975-1980 

• Managed all maintenance for an operation of 19 Aerospatiale SA 3!6B, 3 Aerospatiale 

319B, and 5 AS 350 D helicopters located in 22 states. Managed a crew of 35 mechanics 

with my headquarters in Houston, Texas at Hermarm Hospital. 

• Responsible for setting up all new programs. We were the only EMS operation in the 

world at the time. 

ROCKY MOUNTAIN HELICOPTERS· Provo, Utah 

Field Maintenance Troubleshooter 

1973-1975 
o Assist field mechanics with troubleshooting problems in the field. Bell 206BIII, 205Al, 

212, 214B, Aerospatiale 316B, 315B,319B, and Hughes 500 C&D. 

INLAND HELICOPTERS- Grants Pass, Oregon 1969-1973 

Aircraft Mechanic 

o Performed maintenance on all our aircraft located all over the country, on fire fighting , 

seismic, geological surveys. 

UNITED STATES MARINE CORPS 1965-1969 

o Performed duties as Crew Chief, mechanic, Supervisor in the U.S and Vietnam. 

o Performed duties as Force Recon in the U.S. and Vietnam. 

LICENSES: FAA Airframe and Powerplant # 2184743 

FAA Inspection Authorization# 2184743 

FAA Private Pilot SEL # 2184743 

ACCREDITATIONS and FACTORY SCHOOLS 

Aerospatiale 350 Field Maintenance 

Aerospatiale 350 Overhaul Maintenance 

Aerospatiale 355 Field Maintenance 

Aerospatiale 365N Filed Maintenance 

Aerospatiale 365N2 Field Maintenance 

Lycoming T53 Field Maintenance 

Lycoming LTS 101 Field Maintenance 

Allison 250C20F Filed Maintenance 

Turbomeca Arriel I C Field Maintenance 

Allison 250 C40 Field Maintenance 

Baker School of Aeronautics !A Course 

Bell 204 Field Maintenance 

Bell 222 Field Maintenance 

Bell430 Field Maintenance 

Bell 430 Electrical Maintenance 

Bel1430 AFCS Maintenance 

Bell 407 Field Maintenance 

Bell 407 Electrical Maintenance 

Bell 407 Overhaul Maintenance 

Bell 427 Field Maintenance 

Bell 214ST Field Maintenance 

Bell412 Field Maintenance 

Bell 412 Electrical Maintenance 

Bell 412 AFCS Maintenance 

Bell 412 Component Overhaul 

American Management Courses 
How to Manage Priorities 

Taking Control with Time Management 

The Complete Training Course for Managers 

Finance and Accounting for Nonfinancial Managers, Second Edition 

Fundamentals of Budgeting for Nonfinancial Managers 

How to Build Effective Financial Reporting Systems 

How to Plan You Company Budget, Fifth Edition 

How to Prepare a Financial Forecast 

Fundamentals of Inventory Management and Control, Third Edition 

How to Manage Maintenance 

How to Plan and Manage Warehouse Operations, Second Edition 

ISO 900 I :2000 Making the Transition 

HONORS AND AWARDS 

Letter of Appreciation- Col. Mohammad AI Housum RSAF 

Letter of Appreciation- Col. Abdul Kareem AI Saeed Dubai Air Force 

Letter of Appreciation- Col. Mohammad AI Musalam Amiri Air Wing 

Letter of Appreciation - Vice President Mike Blake Bell Helicopter 

Letter of Appreciation- Francois Magnan PSE Medium Group 

Letter of Appreciation- Carey Bonds Vice President Bell Helicopter 

Letter of Appreciation- John Murphy CEO Bell Helicopter 

REFERENCES 

Dan Prairie- Bell Helicopter C.S.R. Northern Calif./Northern Nev.- 916-990-8112 

Jack Quebedeaux- Bell Helicopter C.S.R.- Gulf States- 337-754-5059 

Ron Orndoff- Bell Helicopter C.S.R. -Northeast -717-919-9853 

Debbie Ginn Frost- Uniflight- 972-400-4175 
AFFIDAVIT OF SAFETY COMPLIANCE 

STATE OF tlewJe~y I 

COUNTY OF /.J1JDSOp 

Benjamin Yelle, being first duly sworn, deposes and says: 

I am duly elected, qualified, and serving as Director of Maintenance of Liberty Helicopters, Inc., 

and I am authorized to and do make this affidavit for it. 

All aircraft owned and leased by Liberty Helicopters, Inc. have been certified by the Federal 

Aviation Administration and currently comply with all applicable Federal Aviation 

Administration Safety Standards under Part 135, as well as the noise standards of Part 36, of the 

Federal Aviation Regulations 

Subscribed and sworn to before me this _if_ day of /Jp~; INotary PUbliC 

'2015. 

MARILYN BELO 

Commission# 2184499 

Noterv Public, State of New Jersey 

Mv Commission Expires A~QUII 11, 2016 
Exhibit D 
LIBERTY HELICOPTERS, INC. 

NOTES TO FINANCIAL STATEMENTS 

DECEMBER 31, 2012 

1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES 

Revenue Recognition - Revenue is recognized at the time services are performed. All revenue is recognized 

net of any related sales taxes. 

Cash and Cash Equivalents- For purposes of the financial statements, the Company considers all highly liquid 

investments purchased with original maturities of three months or less to be cash equivalents. 

Accounts Receivable - The Company carries its accounts receivable at cost less any allowance for doubtful 

accounts. On a periodic basis, the Company evaluates its accounts receivable and establishes allowances for 

doubtful accounts based on a history of past write-offs, collections and current credit conditions. 

Property and Equipment - Property and equipment is stated at cost. Expenditures for maintenance, repairs and 

minor renewals are expensed as incun·ed. When assets are retired, or otherwise disposed of, the related cost 

and accumulated depreciation are removed from the respective accounts and any profit or loss on such 

disposition is included in operations. 

Depreciation - Depreciation of non component parts is provided in amounts sufficient to relate the cost of 

depreciable assets to operations over their estimated service lives on the straight-line method. The Company 

uses a combination of the straight-line and accelerated methods of depreciation for tax purposes. 

Estimated useful lives on non-component parts are as follows: 

Furniture, machinery and equipment 

Automobiles 

Computers 

Years 

3- 10 

5 

3- 7 

Inventory - Inventories are prepaid supplies that are used to maintain the helicopter fleet. These items are 

carried at the lower of cost or market, with cost being determined by a manner that approximates the first-in, 

first out method 

Estimates - The preparation of consolidated financial statements in conformity with generally accepted 

accounting principles requires management to make estimates and assumptions that affect certain reported 

amounts and disclosures. Accordingly, actual results could differ from those estimates. 

Impairment - The Company reviewed long-lived assets, including identifiable intangibles, for impairment 

when events or changes in circumstances indicate that the carrying value of an asset may not be recoverable. If 

impairment indicators are present and the estimated future undiscounted cash flows are less than the carrying 

value of the long-lived assets, the carrying value is reduced to the estimated fair value as measured by the 

discounted cash flows. 
Income taxes - The Company accounts for income taxes under the asset and liability method, which requires 

the recognition of deferred tax assets and liabilities for the expected future tax consequences of events that have 

been included in the financial statements. Under this method, deferred tax assets and liabilities are determined 

based on the differences between the financial statements and tax basis of assets and liabilities using enacted 

tax rates in effect for the year in which the differences are expected to reverse. The effect of a change in tax 

rates on deferred tax assets and liabilities is recognized in income in the period that includes the enactment 

date. 

The Company records net deferred tax assets to the extent it believes that it is more likely than not that these 

assets will be realized. In making such detetmination, the Company considers all available positive and 

negative evidence, including scheduled reversal of deferred tax liabilities, projected future taxable income, tax 

planning strategies and recent results of operations. In the event the Company was to determine that it would be 

able to realize the deferred income tax assets in the future in excess of their net recorded amount, the Company 

would adjust the valuation allowance, which would reduce the provision for income taxes. 

The Company files a consolidated federal income tax return with its subsidiaries. For state income tax 

purposes, the Company and its subsidiaries generally file separate tax returns except in several states where 

they file on a unitary basis. The Company is not aware of any unrecognized tax benefits/provisions at 

December 31, 2012. The Company's U.S. Federal and State income tax returns prior to fiscal year 2009 are 

closed and management continually evaluates expiring statutes of limitations, audits, proposed settlements, 

changes in tax law and new authoritative rulings. 

The Company recognizes interest and penalties associated with tax matters as part of the income tax provision 

and includes accrued interest and penalties with the related tax liability in the balance sheet. 

2. PROPERTY AND EQUIPMENT 

Property and equipment at December 31,2012, consisted of the following: 

Equipment, furniture and leasehold improvements 

Less: Accumulated depreciation 

3. CONCENTRATION OF RISK 

240,475.66 

104,347.76 

$ 136,127.90 

Company's financial instruments that are exposed to concentrations of credit risk consist primarily of cash and 

cash equivalents and trade accounts receivable. The Company places its cash and temporary cash investments 

with high credit quality institutions. At times, such investments may be in excess of the FDIC insurance limit. 

The Company may be affected by general economic conditions due to the severe adverse domestic and global 

economic conditions and disruptions in the financial and credit markets. These conditions may have an effect 

on the availability of short and long-term debt financing and the various industries in which the Company 

provides services. These conditions could have a material adverse effect on the Company's results of 

operations, financial condition, and liquidity. 

4. LEASE OBLIGATIONS 

The Company leases the helicopter fleet under an aircraft dry lease agreement from its sister company, 

Meridian Consulting I Corporation, Inc. Liberty pays a fixed monthly payment plus a variable hourly rate. 
5. LITIGATION 

The Company is a defendant in a lawsuit for alleged personal injury damages resulting from a helicopter 

accident that occurred on June 13, 2001. Four of the six passengers that were on board have already settled with 

the Company. The two remaining claimants have acquired new counsel with new claims and damage theories. 

It is uncertain whether the remaining insurance coverage will be sufficient to cover the verdict. Legal counsel 

views an outcome above the remaining insurance coverage as unlikely. Plaintiffs have not provided a demand 

for settlement despite counsel's requests for one. No trial date has been set as of the date the financial 

statements were issued. 
LIBERTY HELICOPTERS, INC. 

NOTES TO FINANCIAL STATEMENTS 

DECEMBER 31, 2013 

1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES 

Revenue Recognition - Revenue is recognized at the time services are performed. All revenue is recognized 

net of any related sales taxes. 

Cash and Cash Equivalents- For purposes of the financial statements, the Company considers all highly liquid 

investments purchased with original maturities of three months or less to be cash equivalents. 

Accounts Receivable - The Company carries its accounts receivable at cost less any allowance for doubtful 

accounts. On a periodic basis, the Company evaluates its accounts receivable and establishes allowances for 

doubtful accounts based on a history of past write-offs, collections and current credit conditions. 

Property and Equipment - Property and equipment is stated at cost. Expenditures for maintenance, repairs and 

minor renewals are expensed as incurred. When assets are retired, or otherwise disposed of, the related cost 

and accumulated depreciation are removed from the respective accounts and any profit or loss on such 

disposition is included in operations. 

Depreciation - Depreciation of non component parts is provided in amounts sufficient to relate the cost of 

depreciable assets to operations over their estimated service lives on the straight-line method. The Company 

uses a combination of the straight-line and accelerated methods of depreciation for tax purposes. 

Estimated useful lives on non-component parts are as follows: 

Furniture, machinery and equipment 

Automobiles 

Computers 

Years 

3- 10 

5 

3-7 

Inventory - Inventories are prepaid supplies that are used to maintain the helicopter fleet. These items are 

carried at the lower of cost or market, with cost being determined by a manner that approximates the first-in, 

first out method 

Estimates - The preparation of consolidated financial statements in conformity with generally accepted 

accounting principles requires management to make estimates and assumptions that affect certain reported 

amounts and disclosures. Accordingly, actual results could differ from those estimates. 

Impairment - The Company reviewed long-lived assets, including identifiable intangibles, for impairment 

when events or changes in circumstances indicate that the carrying value of an asset may not be recoverable. If 

impairment indicators are present and the estimated future undiscounted cash flows are less than the carrying 

value of the long-lived assets, the carrying value is reduced to the estimated fair value as measured by the 

discounted cash flows. 
Income taxes - The Company accounts for income taxes under the asset and liability method, which requires 

the recognition of deferred tax assets and liabilities for the expected future tax consequences of events that have 

been included in the financial statements. Under this method, deferred tax assets and liabilities are determined 

based on the differences between the financial statements and tax basis of assets and liabilities using enacted 

tax rates in effect for the year in which the differences are expected to reverse. The effect of a change in tax 

rates on deferred tax assets and liabilities is recognized in income in the period that includes the enactment 

date. 

The Company records net deferred tax assets to the extent it believes that it is more likely than not that these 

assets will be realized. In making such determination, the Company considers all available positive and 

negative evidence, including scheduled reversal of deferred tax liabilities, projected future taxable income, tax 

planning strategies and recent results of operations. In the event the Company was to determine that it would be 

able to realize the deferred income tax assets in the future in excess of their net recorded amount, the Company 

would adjust the valuation allowance, which would reduce the provision for income taxes. 

The Company files a consolidated federal income tax return with its subsidiaries. For state income tax 

purposes, the Company and its subsidiaries generally file separate tax returns except in several states where 

they file on a unitary basis. The Company is not aware of any unrecognized tax benefits/provisions at 

December 31, 2013. The Company's U.S. Federal and State income tax returns prior to fiscal year 2010 are 

closed and management continually evaluates expiring statutes of limitations, audits, proposed settlements, 

changes in tax law and new authoritative rulings. 

The Company recognizes interest and penalties associated with tax matters as part of the income tax provision 

and includes accrued interest and penalties with the related tax liability in the balance sheet. 

2. PROPERTY AND EQUIPMENT 

Property and equipment at December 31, 2013, consisted of the following: 

Equipment, furniture and leasehold improvements 

Less: Accumulated depreciation 

3. CONCENTRATION OF RISK 

288,287.98 

144,899.50 

$ 143,388.48 

Company's financial instruments that are exposed to concentrations of credit risk consist primarily of cash and 

cash equivalents and trade accounts receivable. The Company places its cash and temporary cash investments 

with high credit quality institutions. At times, such investments may be in excess of the FDIC insurance limit. 

The Company may be affected by general economic conditions due to the severe adverse domestic and global 

economic conditions and disruptions in the financial and credit markets. These conditions may have an effect 

on the availability of short and long-term debt financing and the various industries in which the Company 

provides services. These conditions could have a material adverse effect on the Company's results of 

operations, financial condition, and liquidity. 

4. LEASE OBLIGATIONS 

The Company leases the helicopter fleet under an aircraft dry lease agreement from its sister company, 

Meridian Consulting I Corporation, Inc. Liberty pays a fixed monthly payment plus a variable hourly rate. 
5. LITIGATION 

The Company is a defendant in a lawsuit for alleged personal injury damages resulting from a helicopter 

accident that occurred on June 13, 200 I. Four of the six passengers that were on board have already settled with 

the Company. The two remaining claimants have acquired new counsel with new claims and damage theories. 

It is uncertain whether the remaining insurance coverage will be sufficient to cover the verdict. Legal counsel 

views an outcome above the remaining insurance coverage as unlikely. Plaintiffs have not provided a demand 

for settlement despite counsel's requests for one. No trial date has been set as of the date the financial 

statements were issued. 
LIBERTY HELICOPTERS, INC. 

NOTES TO FINANCIAL STATEMENTS 

DECEMBER 31,2014 

1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES 

Revenue Recognition - Revenue is recognized at the time services are performed. All revenue is recognized 

net of any related sales taxes. 

Cash and Cash Equivalents- For purposes of the financial statements, the Company considers all highly liquid 

investments purchased with original maturities of three months or less to be cash equivalents. 

Accounts Receivable - The Company carries its accounts receivable at cost less any allowance for doubtful 

accounts. On a periodic basis, the Company evaluates its accounts receivable and establishes allowances for 

doubtful accounts based on a history of past write-offs, collections and current credit conditions. 

Property and Equipment- Property and equipment is stated at cost. Expenditures for maintenance, repairs and 

minor renewals are expensed as incurred. When assets are retired, or otherwise disposed of, the related cost 

and accumulated depreciation are removed from the respective accounts and any profit or loss on such 

disposition is included in operations. 

Depreciation - Depreciation of non component parts is provided in amounts sufficient to relate the cost of 

depreciable assets to operations over their estimated service lives on the straight-line method. The Company 

uses a combination of the straight-line and accelerated methods of depreciation for tax purposes. 

Estimated useful lives on non-component parts are as follows: 

Furniture, machinery and equipment 

Automobiles 

Computers 

Years 

3- 10 

5 

3 - 7 

Inventory - Inventories are prepaid supplies that are used to maintain the helicopter fleet. These items are 

carried at the lower of cost or market, with cost being determined by a manner that approximates the first-in, 

first out method 

Estimates - The preparation of consolidated financial statements in conformity with generally accepted 

accounting principles requires management to make estimates and assumptions that affect certain reported 

amounts and disclosures. Accordingly, actual results could differ from those estimates. 

Impairment - The Company reviewed long-lived assets, including identifiable intangibles, for impairment 

when events or changes in circumstances indicate that the carrying value of an asset may not be recoverable. If 

impairment indicators are present and the estimated future undiscounted cash flows are less than the carrying 

value of the long-lived assets, the carrying value is reduced to the estimated fair value as measured by the 

discounted cash flows. 
Income taxes - The Company accounts for income taxes under the asset and liability method, which requires 

the recognition of deferred tax assets and liabilities for the expected future tax consequences of events that have 

been included in the financial statements. Under this method, deferred tax assets and liabilities are determined 

based on the differences between the financial statements and tax basis of assets and liabilities using enacted 

tax rates in effect for the year in which the differences are expected to reverse. The effect of a change in tax 

rates on deferred tax assets and liabilities is recognized in income in the period that includes the enactment 

date. 

The Company records net deferred tax assets to the extent it believes that it is more likely than not that these 

assets will be realized. In making such determination, the Company considers all available positive and 

negative evidence, including scheduled reversal of deferred tax liabilities, projected future taxable income, tax 

planning strategies and recent results of operations. In the event the Company was to determine that it would be 

able to realize the deferred income tax assets in the future in excess of their net recorded amount, the Company 

would adjust the valuation allowance, which would reduce the provision for income taxes. 

The Company files a consolidated federal income tax return with its subsidiaries. For state income tax 

purposes, the Company and its subsidiaries generally file separate tax returns except in several states where 

they file on a unitary basis. The Company is not aware of any unrecognized tax benefits/provisions at 

December 31, 2014. The Company's U.S. Federal and State income tax returns prior to fiscal year 2011 are 

closed and management continually evaluates expiring statutes of limitations, audits, proposed settlements, 

changes in tax law and new authoritative rulings. 

The Company recognizes interest and penalties associated with tax matters as part of the income tax provision 

and includes accrued interest and penalties with the related tax liability in the balance sheet. 

2. PROPERTY AND EQUIPMENT 

Property and equipment at December 31, 2014, consisted of the following: 

Equipment, furniture and leasehold improvements 

Less: Accumulated depreciation 

3. CONCENTRATION OF RISK 

343,405.99 

187,842.57 

$ 155,563.42 

Company's financial instruments that are exposed to concentrations of credit risk consist primarily of cash and 

cash equivalents and trade accounts receivable. The Company places its cash and temporary cash investments 

with high credit quality institutions. At times, such investments may be in excess of the FDIC insurance limit. 

The Company may be affected by general economic conditions due to the severe adverse domestic and global 

economic conditions and disruptions in the financial and credit markets. These conditions may have an effect 

on the availability of short and long-term debt financing and the various industries in which the Company 

provides services. These conditions could have a material adverse effect on the Company's results of 

operations, financial condition, and liquidity. 

4. LEASE OBLIGATIONS 

The Company leases the helicopter fleet under an aircraft dry lease agreement from its sister company, 

Meridian Consulting I Corporation, Inc. Liberty pays a fixed monthly payment plus a variable hourly rate. 
5. LITIGATION 

The Company is a defendant in a lawsuit for alleged personal injury damages resulting from a helicopter 

accident that occurred on June 13, 200 I. Four of the six passengers that were on board have already settled with 

the Company. The two remaining claimants have acquired new counsel with new claims and damage theories. 

It is uncertain whether the remaining insurance coverage will be sufficient to cover the verdict. Legal counsel 

views an outcome above the remaining insurance coverage as unlikely. Plaintiffs have not provided a demand 

for settlement despite counsel's requests for one. No trial date has been set as of the date the financial 

statements were issued. 
Exhibit E 

Confidential Treatment sought for Exhibit E 
Exhibit F 

Confidential Treatment sought for Exhibit F 
Exhibit G 
Statement of Chris Vellios 

Sightseeing Tours of America, Inc. (STA) will make funding available to Li berty Helicopters, Inc. to cover 

any working capital deficit, cover pre-operating expenses as well as an average of three months of 

additional operating expenses. In addition, STA will assume all non-cash expenses (such as depreciation) 

associated with Liberty Helicopters, Inc. proposed service. 

Chris Velllos 

Chief Financial Officer and Chief Operating Officer of Sightseeing Tours of America, Inc. 

Chris Vellios 

Chief Financial Officer and Chief Operating Officer of Liberty Helicopters, Inc. 
Exhibit H 
Pre-operating Expense Forecast 

Pre-operating Legal Fees $42,400 (open balance) 

Staff training $2,500 (paid)