Application of 

BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

GAMA AVIATION LIMITED 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

for an air carrier permit pursuant to 

49 U.S.C. § 41301 and for exemption 

authority pursuant to 49 U.S.C. 

§ 40109 (U.S.-European Community) 

OST-2010-__ _ 

APPLICATION OF 

GAMA AVIATION LIMITED 

FOR AN EXEMPTION AND 

FOREIGN AIR CARRIER PERMIT 

Communications with respect to this document should be sent to: 

Dated: August 9,2010 

Malcolm L. Benge 

Jonathon H. Foglia 

ZUCKERT, SCOUTT & RASENBERGER, 

L.L.P. 

888 Seventeenth Street, N.W. Suite 700 

Washington, D.C. 20006 

(202) 298-8660 

mlbenge@zsrlaw.com 

jhfoglia@zsrlaw.com 

Attorneys for 

Garna Aviation Limited 

NOTICE: ANY PERSON MAY FILE AN ANSWER TO THIS APPLICATION WITH 

THE DEPARTMENT OF TRANSPORTATION SUPPORTING OR OPPOSING THIS 

APPLICATION. ANSWERS TO THIS APPLICATION MUST BE FILED ON OR 

BEFORE AUGUST 30, 2010 AND MUST BE SERVED ON THE PARTIES NAMED IN 

THE ATTACHED SERVICE LIST. 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

GAMA A VIA TION LIMITED 

for an air carrier permit pursuant to 

49 U.S.c. § 41301 and for exemption 

authority pursuant to 49 U.S.C. 

§ 40109 (U.S.-European Community) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

OST-2010----

---------------------------) 

Dated: August 9,2010 

APPLICATION OF 

GAMA AVIATION LIMITED 

FOR AN EXEMPTION AND 

FOREIGN AIR CARRIER PERMIT 

Pursuant to 49 U.S.C. § 41301 and Parts 211 and 302 ofthe Department's regulations, 

Gama Aviation Limited ("Gama") hereby applies for a foreign air carrier permit to engage in 

charter foreign air transportation of persons, property and mail to the full extent authorized by 

the Air Transport Agreement between the European Community and its Member States, and the 

United States ("EU-US Agreement"), as further described herein. Gama further requests 

exemption authority pursuant to 49 U.S.C. § 40109 to the extent necessary to enable it to provide 

the services described below pending issuance of a foreign air carrier permit. 

Gama requests that the Department process this application in accordance with the 

streamlined regulatory procedures for licensing U.S. and foreign air carriers set forth in the 

Department's Notice dated August 23, 2005 (Docket OST-2005-22228) and issue a single order 

(1) granting Gama the requested exemption authority for a two-year period or until the requested 

permit authority becomes effective, whichever first occurs, and (2) approving the corresponding 

1 
foreign air carrier permit under the show cause procedures described in the DOT Notice. Gama 

also requests that this application be processed under the streamlined licensing procedures for 

European Union carriers described in the Department's notice dated February 19, 2009 regarding 

reciprocal recognition by the U.S. and the European Union ("EU") of regulatory determinations 

with regard to airline fitness and citizenship. 

In support of its application, Gama states as follows: 

1. Gama is applying for an exemption and a foreign air carrier permit to engage in 

charter foreign air transportation consistent with the rights conferred on EU carriers by the EUUS Agreement. 

2. Gama is an air carrier holding an Air Operator Certificate issued by the Civil 

Aviation Authority of the United Kingdom ("UK"). As the UK is a Member State of the 

European Community, Gama is eligible for the streamlined application procedures applicable to 

the licensing of air carriers subject to the EU-US Agreement. This application provides the 

information concerning Gama that is required by DOT in accordance with the EU-US reciprocal 

recognition of regulatory determinations regarding air carrier fitness and citizenship. 

3. The name and address of the applicant is: 

Gama Aviation Limited 

Business Aviation Centre 

F arnborough Airport 

Famborough 

Hampshire 

GUl46XA 

United Kingdom. 

The applicant is a company organized under the laws of England. 

4. Gama requests an exemption and a foreign air carrier permit to engage in charter 

foreign air transportation of persons, property and mail to the full extent authorized by the EU2 
US Agreement, as follows: (i) from any point or points behind any Member State of the 

European Union via any point or points in any Member State and via intermediate points to any 

point or points in the United States and beyond; (ii) between any point or points in the United 

States and any point or points in any member of the European Cornmon Aviation Area; and (iii) 

other charters pursuant to Part 212 of the Department's regulations. Gama is applying for 

authority to operate these services with business jet aircraft designed to have a maximum 

passenger capacity of not more than 60 seats or a maximum payload capacity of not more than 

18,000 pounds. 

5. The name and address of the government air transport authority with regulatory 

jurisdiction over Gama's operations is as follows: 

United Kingdom Civil Aviation Authority 

Aviation House 

Gatwick Airport South 

West Sussex 

United Kingdom 

RH60YR. 

A copy of Gama's Air Operator Certificate ("AOC") as issued by the UK Civil Aviation 

Authority is attached hereto as Exhibit A. 

6. Gama meets the Department's requirements for insurance. Appropriate OST 

Forms 6411 evidencing insurance coverage for Gama's operations with the types and amounts of 

coverage required under the Department's regulations are attached as Exhibit B. 

7. A partial waiver of the liability limitations of the Warsaw Convention (OST Form 

4523) is attached as Exhibit C. 

8. Gama is applying for authority to operate these services with business jet aircraft 

designed to have a maximum passenger capacity of not more than 60 seats or a maximum 

payload capacity of not more than 18,000 pounds. Pursuant to Order 98-1-31 issued February 3, 

3 
1998, Gama is therefore exempt from the provisions of 49 U.S.C. § 41313, which requires 

submission of an Aviation Disaster Family Assistance Plan. For the same reason, Gama is not 

required to collect passenger manifest compliance information in accordance with the provisions 

of Part 243 of the Department's regulations. 

9. The authority requested herein is consistent with the provisions of the EU-US 

Agreement. Adequate reciprocity therefore exists to approve this application. 

10. Gama will accept all terms, limitations and conditions which the Department 

normally attaches to exemption and permit authority for foreign carrier air transportation and 

will conform to the provisions of Title 49 of the United States Code, as well as the rules, 

regulations and requirements issued thereunder. 

11. Grant to Gama of the U.S. operating authority requested herein does not constitute 

a "major regulatory action" under the Energy Conservation Act of 1975, as defined in Section 

313.4(a)(l) of the Department's regulations. 

12. The verification required by § 211.1 of the Department's regulations is attached 

hereto as Exhibit D. 

4 
WHEREFORE. for the foregoing reasons, Gama Aviation Limited respectfully requests 

the Department to grant (l) a foreign air carrier permit authorizing it to engage in charter foreign 

air transportation of persons, property and mail to the full extent authorized by the EU-US 

Agreement, (ii) exemption authority pursuant to 49 U.S.c. § 40109 to the extent necessary to 

enable it to provide such services as described above pending issuance of a foreign air carrier 

permit and (iii) such other, further and different relief as may be appropriate. Gama requests that 

the exemption be granted for a two-year period. 

Dated: August 9, 2010 

5 

Respectfully submitted, 

Jonathon H. Foglia 

ZUCKERT, SCOUTT & RASENBERGER, 

L.L.P. 

888 Seventeenth Street, N.W. Suite 700 

Washington, D.C. 20006 

(202) 298-8660 

mlbenge@zsrlaw.com 

ihfoglia@zsrlaw.com 

Attorneys for 

Gama Aviation Limited 
CERTIFICATE OF SERVICE 

I hereby certify that on this 9th day of August 2010, a copy of the foregoing application ofGarna Aviation 

Limited was served by email on the parties named below: 

Jeffrey Manley 

Senior Advisor - Regulatory Affairs 

United Air Lines, Inc. 

1025 Connecticut Avenue, N.W. 

Suite 1210 

Washington, DC 20036 

jeffrey.man1ey@united.com 

R Bruce Keiner, Jr. 

Lorraine B. Halloway 

Counsel for Continental Airlines 

Crowell & Moring 

1001 Pennsylvania Avenue, N.W. 

Washington, D.C 20004 

rbkeiner@crowell.com 

Lhalloway@crowell.com 

Hershel Kamen 

Vice President-International 

and Regulatory Affairs 

Dan Weiss 

Continental Airlines, Inc. 

Government Affairs-8"' Floor 

1600 Smith Street 

DeptHQSGV 

Houston, TX 77002 

hkamen@coair.com 

dan. weiss@coair.com 

DavidL Vaughan 

Danielle Fisher 

Counsel for United Parcel Service 

Kelley Drye Collier Shannon 

3050 K Street, N.W. 

Suite 400 

Washington, D.C 20007 

dvaughan@kelleydrye.com 

dfisher@kelleydrye.com 

Alexander Van Der Bellen 

Jeff Morgan 

Sametta C Barnett 

Delta Air Lines 

1212 New York Avenue, NW 

Suite 200 

Washington, D.C 20005 

Sascha. vanderbellen@delta.com 

sametta.c.bamett@delta.com 

Jeffmorgan@delta.com 

Carl B. Nelson, Jf. 

Associate General Counsel 

American Airlines, Inc. 

1101 Seventeenth Street, N.W. 

Suite 600 

Washington, D.C. 20036 

carl.nelson@aa.com 

John L Richardson 

Counsel for Amerijet International 

John L Richardson, P.LLC 

555 13th Street, N.W. 

Suite 420 West 

Washington, D.C 20004 

jrichardson@johnlrichardson.com 

John Palo 

Vice President, Planning Military 

and Government 

Evergreen International Airlines, Inc. 

3850 Three Mile Lane 

McMinnville, OR 97128 

john.palo@evergreenairlines.com 

charters@evergreenairlines.com 

Malcolm L Benge 

Counsel for World Airways and North 

American Airlines 

Zucker!, Scoutt & Rasenberger, LLP. 

888 Seventeenth Street, N.W. 

Suite 700 

Washington, DC 20006 

mlbenge@zsrlaw.com 

Angeline Garbuzinski 

Legal and Regulatory Affairs 

Federal Express Corporation 

3620 Hacks Cross Road 

Building B, 3,d Floor 

Memphis, TN 38125 

anbird@fedex.com 

Pierre Murphy 

Counsel for Brendan Airways, LLC 

d/b/a USA 3000 Airlines and Arrow Air 

1200 New Hampshire Avenue, N.W. 

Suite 590 

Washington, D.C 20036-6802 

pmurphy@lopmurphy.com 
Thomas E. Fosko 

Vice President 

Air Transport International LLC 

2800 Cantrell Road 

Little Rock, AR 72202 

tomfosko@airtransport.cc 

Howard Kass 

Managing Director & Associate General 

Counsel 

US Airways 

1401 H Street, N.W. 

Suite 1075 

Washington, D.C. 20006 

howard _ kass@usairways.com 

John M. Allen 

Director 

Flight Standards Service 

Federal Aviation Admiuistration 

800 Independence Avenue, S.W. 

Room 821 

Washington, D.C. 20591 

john.allen@faa.gov 

Aaron Goerlich 

Counsel for Allegiant Air and Ryan 

International Airlines 

Garofalo Goerlich Hainbach PC 

1200 New Hampshire Avenue NW 

Suite 800 

Washington, D.C. 20036-6802 

agoerlich@ggh-airlaw.com 

Edward P. Fabennan 

Counsel for Frontier Airlines 

Wiley Rein LLP 

1776 K Street, N.W. 

Washington, DC 20006 

efaberman@wrf.com 

Robert P. Silverberg 

Jeffrey Johnson 

Counsel for ABX Air 

Silverberg, Goldman & Bikoff, L.L.P. 

1101 30th Street, N.W. 

Suite 120 

Washington, D.C. 20007 

rsilverberg@sgbdc.com 

jjohnson@ssgbdc.com 

2 

Marshall S. Siuiek 

Counsel for Alaska Airlines and Florida 

West International Airways 

Squire, Sanders & Dempsey 

1201 Pennsylvauia Avenue, N.W. 

Suite 500 

Washington, D.C. 20004 

msiuick@ssd.com 

Stephen H. Lachter 

Counsel for Astar Air Cargo 

Lacbter & Clements LLP 

1150 Connecticut Avenue, N.W., Ste. 900 

Washington, DC 20036 

slachter@lachter-ciements.com 

Russell E. Ponuner 

Associate General Counsel and 

Director of Regulatory Affairs 

Atlas Air, Inc. 

1747 Pennsylvauia Avenue, N.W. 

Suite 875 

Washington, D.C 20006 

rpommer@atlasair.com 

MarkW. Atwood 

Counsel for Kalitta Air and Xtra Airways 

Sher & Blackwell, L.L.P. 

1850 M Street, N.W. 

Suite 900 

Washington, D.C. 20036 

matwood@sherblackwell.eom 

Idunn@xtraairways.com 

Jonathan B. Hill 

Counsel for Hawaiian Airlines and letBluc 

Dow Lohnes 

1200 New Hampshire Avenue, N.W. 

Suite 800 

Washington, DC 20036-6802 

jhill@dowlohnes 

John S. Fredericksen 

Vice President and General Counsel 

MN Airlines, LLC dba Sun Country 

Airlines 

1300 Mendota Heights Road 

Mendota Heights, MN 55120 

john.fredericksen@suncountry.com 
Joanne W. Young 

Counsel for Spirit Airlines 

Kirstein & Young PLLC 

1001 Peunsylvania Ave., N.W. 

Snite 600 South 

Washington, DC 20004 

jyoung@yklaw.com 

William C. Evans 

John R. Mietus, Jr. 

Counsel for Centurion Air Cargo and Trade 

Winds Airlines 

Law Office of John Mietus, LLC 

6701 Democracy Boulevard 

Suite 300 

Bethesda, MD 20817 

bill@mietuslaw.com 

john@mietuslaw.com 

Kevin Montgomery 

Peter Beckett 

Polar Air Cargo, Inc. 

1747 Pennsylvania Avenue, N.W. 

Suite 875 

Washington, D.C 20006 

kcvin.IDontgomery@ polaraircargo.com 

peter.beckett@polaraircargo.com 

3 

Thomas A. Gillies 

Chief Operating Officer 

Southern Air Inc. 

117 Glover Ave. 

Norwalk, CT 06850 

tgillies@southemair.com 

Jonathan Blank 

1. Timothy Hobbs 

Counsel for Capital Cargo International 

Airlines 

Kirkpatrick & Lockhart 

Preston Gates Ellis LLP 

1601 K Street NW 

Washington, DC 20006 

jonathan.blank@klgates.com 

tim.hobbs@k1gates.com 

Oakley Brooks 

President and CEO 

Paul Doell 

National Air Carrier Association 

1000 Wilson Boulevard 

Suite 1700 

Arlington, Virginia 22209 

obrooks@naca.cc 

pdoell@naca.cc 
Exhibit A 

Exhibit B 

Exhibit C 

ExhibitD 

Index to Exhibits 

Homeland Air Operator 

Certificate 

OST Forms 6411, "Foreign Air 

Carriers - Certificate of 

Insurance" 

OST Form 4523 Agreement 

Verification Statement 
EXHIBIT A 

Homeland Air Operator Certificate 
AOC No. GB 1068 

AOC Issue No. 11 

Pa .e No.1 ot3 

UNITED KINGDOM 

CIVIL AVIATION AUTHORITY 

AIR OPERATOR CERTIFICATE 

GRANTED PURSUANT TO ANNEX III TO REGULATION (EEC) NO.392211991 

OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL TO 

GAM A AVIATION LIMITED 

of 

Farnborough Airport 

This certificate certifies that Gama Aviation Limited is authorised to pertorm commercial 

air operations, as defined in the attached operations specifications, in accordance with the 

Operations Manual and Annex III to Regulation (EEC) No. 3922/1991 of the European 

Parliament and of the Council. 

This certificate shall not be valid during the continuance of the breach of any condition 

thereof; provided that a breach of a condition which relates to a particular type of aircraft 

only shall not render this certificate invalid in respect of any other type of aircraft. 

This certificate is not transferable and is effective from the date of signature and shall 

remain in force unless varied, suspended or revoked. 

Issued at: GatwicK 

Date: ..... .2~ ... ~~ .. ~'j ...... 

for the Civil Aviation Authority 

AIL 24 27103/09 

Signature ... \:~i ............ .. 

Name: Captain A G W Porter 

Title: Head of Flrght Operations 

Inspectorate (2) 

AOC.N9.·GS;r1ilU 

QpsSpecl$$)jeNp,'16 

PalleNo.3 Ilfa 

. UNITED KINGDOM ' ,- ,-' - . 

AIR OPERATOR CERJIFICATJ;: 

GAMA AVIATION LIMITED 

. . 

OPE;:RATIONS SPECIFICATIONS continued 

SfSpe§lal Authorisatlons{ Approvals 

Beech 290 Su~rKing Air 

aM12&SOJ'lf$ laO 

SA, 125SeI'leS 1000 

Lnrj.t:4S; 

EtI. MNPS . EtI EGAC AirspaceB-RNAV (ICAO RNAV-5) 

a RVSM 

.... '. 8Q~I.er·.Chan"l'9er601/604 ... Qulfstream,1'l . 

GIlIf,~ Gs'&ll 

EJ1Ibnteta.s.135j'W; 

EtlMNPS 

. cEQ E¢ACl\irspaceB-RNAV (I¢AORNAV-5) aRVSM .. 

E10 . ,R{!lp10(Remote or Oceanic Airspace) 

GfCOntlnued'A!rworthlness 

ThiS'information omitted With theiapprovaLO!"th~ QivILMlatioRAIJ\I)QTi!y. . . 

OClOtlnuec;Aii'\'ll>FIhineSs,1!1all~~l')t 

OrgiinISatkln8pproyaJ I APprO~lCertl1iP$1lj ..... , .. 

NUI)1~ UICMG,0080 ·c. .... .' 

MMagingDit'e<:tor (Al;cQlIntabl&>MMs9ilrl 

Operations DiJeelor. . 

Head .of 1l'Iiinmg'S!ifndards Gro..mdQP!l('!ltionscMa~ge;­

Continuing AirwqrthinessMapag,er 

Title: Head of Fligh\Operatjons 

Inspectorate (Aeropilillles) 

Date: 1-1 December 2009 
O·PERA TfONSAPPROVAL .. EU-oPS 

GAMAAVIA'rION liMITED 

AOCN().G,~.10~· 

ApprovpHl\lsl,IeNQ. 1'1' 

Pas~No.1 (lf4 

1. T/:!eUnited Kingdom Civil AViation Authority herebyapPrQvesfuEI.<PfocedlJlJ3s 

oontainedin the Operations Manual of GAMA AVIATION lIMIi15O.{'1heAPsrBt9r'), 

relating to any. of the Annex III to Regulation (EEC) No.~92211991 (·EU-OPg~). I 

!:ASA-Part M I Air Navigation Order requirements. specified.infue S¢hedl,llehereto, 

only to the extent that the requirements relate tqthe types of operations pennitted 

under Air Operator Certificate number G6 1068. 

2. Any arilen.dri1ents to the text of the Operations Manuals listed in the 'Sched~!e - Tht;l 

SpeeifiedRequirements' to this approval document shaUbe notifj~ 10 .the CM.in 

WOrmS by.the.Operator before implementation ofthe text . 

. $, ·.It\is.AJ:Iprovsl Is nQI trart$ferable and Ist;lffecti~e from!~ dateof!'$igQa(ure ~tiifshali ... .(t;llJl~inil\force unl\jss vaned,siIspended OI'fI3Vok.ed. 

" . ". "" fJate110ecember 2009 

M2923/04/09 
OPiRATIONSAPPROVAL - EU-OPS Aoe No. OB 1()'$~ 

Appr¢Y$U§I!l.!1;i NP.17 

Pa~NP. 2t!f4 

GAMA AVlA'foiON UMI1'ED 

. SCHEDULE -THE SPEClflEDREaUIREMENTS 

Ale. ·;~200~perKingAir 

BAe;125SenesSOO 

:aM12l'iSenes100l! 

1,~lJllt 45 ' . ;llorl\l5aRlier On.llenger 6011604 

GulfstresmN 

GU!f!lI$li)\G~50 

Erobl'ller EMB-1351lJ 

BEle<;b.2I)O·SuperKin9 Air 

. BAe 125S8rilil$8'Oo 

'BAe125.Sertes 1000 . Leadef46 

· BOmbardier.Ohallenger 60.11604 

". .GulfstreanfiV , 

;. Gu~rif'G550 ... " .. Eri;blaer~S:43513J 

Be8Ch 200. Super King Air 'l3Ae125~ri!!S 8()O .. 

BAe 125 Senes.1000· 

· l-earjel45 

Bombardier.Ohallenger80.1l604 

· GuIfs~mIV 

Gulflitre<lm G550 

Embraer EMB'135 BJ 

Nl29Zl/04109 

o MaDRaf 

Pert A 

Part A 

Part A 

Part A 

Part A 

Part A 

Part A . Part A 

PartS 

PartS 

PartB 

PartS 

. Part B 

parts . PailS· ' . 

Parts 

Parts 

ParfS 

PartB 

PartS 

part a 

,parlS 

patts 

pattl;l 

'p"rt A 

Part A 

·Part.A 

parrA 

Part A 

PaltA . 

Part A 

Part'A 

parte 

Parte 

PSrtO 

Parte 

parte 

Parte 

Parte 

Parte 

'ANO 20OSArtlcl(lS2: The ~f:!lespeeffleQf9I 

flight;!lnd(juty timelimitaliOn$,;ll1d .~, 

requirmnenfS. . 

OPS 1.il30(a): the Minimum Equipi)\elltLisl . 

. OPS1;1~S(a):. ,Ihe ·oper<\t.OJ'A eXercising operaHonalQ9J\trot .' . . . -cc 
, Y' 

O~ERATIONSA:PPROVAL- EU-OPS AQC No.GS 1068 

ApprO~ll~ueN~;17 

Rage No, 3.of4 

GAMA.A'l/fATlON.UMITE:D 

SCHEDULE - CON'I'1NUet> 

AlCT' 

'Beech'200Super King Air . 

13Ae 1251WJEl!! 800" . 

BAe.125:senes .1000 

l#a~.<I$. 

:Bombardier ChaHenger 601/604 

Gvlrsti'l!3rrt IV . GuifsireamG550 

E;mbrilerEMB,135 BJ 

CBe\i6h200S11perKing Air 

SAe 125 Senes 600 . 

. BAa 12SSelies 1000 . Learjal.45 . 

Bomba.i'dier Challenger 601/604 Gu!'fl\trealjl N . .. . ... 

GulfSlteam-G550 ...•.. 

Embraer.~a,.135 B,J 

~aooSupetKlh9A1r 

BAEt12:s-.~aoo· • 

BAe126Senes1000 

L~'ir45 . 8Qmbardier Challenger 6011604 

Gtllf$tfearTi IV 

'G~lfitream G550 

. EmbfaerEMB'135 BJ 

All 29 Z3lO4109 

o Man Ref 

parts B & C 

Parts B& C 

Parts B & C 

PartsB & C 

PartsB& C 

PartsS& C 

Parts S & C . PartsB & C . 

Part A 

Part A 

Part A 

Part A 

Part A 

Part A 

Rartk' 

P.artA 

PElrtB 

PartS 

Patt:B 

PlI)tB 

PMB 

PartB 

PartS 

PartB 

PartS 

RartB 

PattO 

'PanD 

PElrt'o 

Patto 

PllttO . RartO 

Pail 0 

PartS 

Parts'A&D 

Pa"its.A&O 

Parts AS. 0 

Parts A & 0 

Parts A & 0 

PartsA& 0 

Parts A & 0 

Parts A & 0 

OPS 1.2!iO(bj:lhemeth6cf.. s~'for 

establishing minlmurn fiightaltitucles. 

OPfI'1ABO(aJ( : 1I1e. '. ttta\(irilUjn' . pa$~engef' 

geeMa capacity In Indi)liduaf'aeropulOes:' 

OPS'1.96~iI)(2); tMS~ed. fllgh(~0tr~ .... . recurrentllalillrfg arid Cj1eCklng:~taml11j!y·.)· ........ .. 

OPS U80:speclfledpr~dUresenabffi!9"flj9.tlt· . 

crew to operate more lhan.o.oe.t\'Pe or I(Srla1il'cOf' aeroplane. .. 
OPiRATlQNSAPPROVAL - EU-OP$ Aoe NO. Ga'1068 

Apprciv<!1 ISsue N(), t1 . pagEiNo. 4 of4 .. 

G~A~VIATION"'IMITEO 

SCHEDULE - GONTJNUED 

&ell¢~()Oayper King Air 

·SAe125~~rjes800 

. BAe12S$erles.1000 . 

L<$~t45 

Bornb'lJtller Ohallenger 601/604 

.GIIJfl;tream IV 

G~lfslrearn G550 

Emllr'ler EMB·135 BJ 

AIL 29 23/04109 

o Man Ref 

Parts A&D 

PartsA& D 

PartsA& D 

PartsA& D 

PaFlsA& D 

PartsA& D 

Parts A & D 

PartsA& D 

OPS 1.1220(a}:. spec s\!!ff1f,!i!!mg' 

programmaor appropriate tcr~lev~lofinwn~ed 

involvernwt in hendlingor caJIYlng Danflel'P~, 

Goods, . 

-',-'( 
EXHIBITB 

OST Fonns 6411, "Foreign Air Carriers - Certificate of Insurance" 
0 

AGENCY DISPLAY OF ESTIMATED BURDEN 

The public reporting burden for this. collection of information Is estimated to average 30 minutes per response. If YQu wish to 

comment on the a~urat+Y of the estimate (It make suggestions for reducing this burdeR, please direct your comments to: U.S. 

Department of Transportation, Office of Aviation Analysis. x...ss, 400 th St., SW"I Washington. D.C, 20590. According to Ihe 

PapelWtlrk Reduction Act of 1995, n.o persons are required to respond to a coUection of information unless It displays a valid OMS 

control number. 

Office of the Secretary NOTE: For information on where to file completed copies of this form, see FlUNG INSTRUCTIONS below. of Transportation 

OMS No. 2106-0030 e Ires 2-28-2011 

FOREIGN AIR CARRIERS· CERTIFICATE OF INSURANCE 

POLiCiES OF .INSURANCE FOR AIRCRAFT ACCIDENT BODilY INJURY 

AND PROPERTY DAMAGE lIABiliTY 

FlUNG INSTRUCTIONS: File a signed original or this fonn with the Federal Aviation Administration, Air Transportation OiV .• AF5-260, 800 Independence 

Ave., SW., Washin¢on, DC 20591. (See EXCEPTION below.) 

EXCEPTION: If Section 2.A. is fiUed in because the insured is a CanadIan Cherfer Air Taxi ~rator. file an original of this form with the U.S. Department 

ofTran$portation, Special Authorities Division (X-46), 400 7th Slr"t, SW, Washington, D.C. 20590 

(Please type information, except signatures.) 

THIS CERTIFIES THAT: Lloyd's Underwriters and Certain Insurance CompanIes 

(Name of Insurer) 

has issued a policy or policies of Aircraft Liability Insurance to GAMA GROUP LIMITED AND lOR GAMA AVIATION LIMITED 

Business Aviation Centre, Famborough, Hampshire,GUl4 6XA,UK FAA Certificate Number 

(Name, addrese ar'td FAA Certificate number of Insured Foreign Air carrier) 

effective from 31st December 2009 until ten (10) days afterwritlen nolice from the insurer or carrier of the intent 

to lerminate coverage is received by the Department of Transportation. 

NOTE: Part 205 ofthe Department's Regulations does not allow for a predetermined termination datel and a certificate showing such a 

date Is unacceptable, 

1. The Insurer (Check One): 

0 is licensed to issue aircraft insurance policies in the Un~ed States; 

Ox is licensed or approved by the government of UK to issue aircraft insurance policies; or 

0 is an approved surplus line insurer in the State(s) of 

2. The insurer assumes, under the policy or policies listed below, aircraft accldent liabIlIty Insured to minimums at least equal to the 

following during operation, malntenancel or use of aircraft In "foreign air Iransportafion~ as that term is defined in 49 U,S,C. 40102. 

(Complet§. al2l2t{,Mle §~~tiQQ A, ~ Q( C below); 

A. CANADIAN CHARTER AIR TAXI OPERATORS WITH PART 294 AUTHORITY ONLY 

Tho aircraft covered by this policy have: (1) 30 or fewer p .... nger seats and a maximum payload capacity of 7,500 pounds or 

less; and/or (2) a maximum authorized takeoff weight on wheefs of no more than 35,000 pounds, (Complete separate qrCQmPined 

covfl@aa 8S BPPropriAte): 

0 Separate Coverages: Minil1J.U!D. UmH 

Pglicy. No. Tl:'l26 of UabiltJ.x Each QersQn Each Occu!1Jl.nce 

Combined Bodily Injury (Excluding Passengers other 

lhan cargo attendanls) and Property Damage Liability $75,000 $2,000,000'(8 •• note) 

Passenger Bodily Injury $75,000 $75,000 x 15% of 

total number of 

passenger seats 

installed in aircraft 

0 CombJned Coverage: This combined coverage is a single limit of liability for each occurrence at least equal to the required 

minimums stated above for bodily injury (ex(:ludlng passengers), property damage, and passenger bodily injury. 

Polley No. Amount of Coverage U.S. Dollars 

0 This polfcy covers CARGO operations only and ex.cludes passenger liability insurance. 

NOTE: If the aircraft covered by this pOlicy have more·than 30 passenger seats or more than a maximum payload capacity of 

7,500 pounds, the minimum limit per occurrence shall be $20,000,000. 

osr Form 6411 
B. FOREIGN AIR CARRIERS OPERATING SMALL AIRCRAFT 

The aircraft covered by this policy are SMALL AIRCRAFT (i.e .. with 60 or fewer passenger seats or with a maximum payload 

capacity of 18.000 pounds. or less). (Complete separate or combined coverage as appropriate); 

o Separate Co~ges: Miafmum Limit 

PoIicv No. Type of Uabiffty 

Combined Bodily Injury (Excluding Passengers other 

than cargo attendan-re;) and Property Oamage Liability 

Passenger 80dily Injury 

Each person 

$300,000 

~,OOO 

Each OCwrrence 

$2,000,000 

$300,000 x 75% of 

total number of 

passenger seats 

installed In aircraft 

(]: Combined Coverage: This combined coverage Is a single limit or liability for each occurrence at least equal to the required 

minimums sLated above for bodily injulY (excluding passengeNi), property damaged, and passenger bodily injury. 

Policy No. AB000750D Amount of Coverage As attached schedule.S. Dollar. 

o This policy covers CARGO operations only and f;)l(cludes passenger liability insurance. 

c. FOReIGN AIR CARRIERS OPERATING LARGE AIRCRAFT 

The aircraft covered by this policy are LARGE AIRCRAFT (i.e., wilh more than 60 passenger seats or with a maximum payload 

capacity of more 1han 18,000 pounds). (Complete separate orcombJned coverage as aPOfQpriate): 

o Separale Cove"'lles: Mjnjroum Umit 

Policy No Tvpe of Uebi/itv Each person Each Occurrence 

Combined Bodily Injury (Excluding Passengers other 

than eargo attendants) and Properly Damage Liability $300,000 

$300,000 

$20,000,000 

$300,000 X 76% of 

10tal number of 

passenger se~& 

installed In airCraft 

Passenger Bodily Injury 

o Combined Coverage~ This combined coverage is a single limit of liability for each occurrence at least equal to the required 

minimums staled above for bodily injury (excluding passengers), property damaged, and passenger bodily injury. 

Policy No. _____________ _ Amount of Coverage _________ U"S, Dollars 

o This policy covers CARGO operations only and eKCludss passenger liability ins.urance. 

3. The policy or policies listed in this certificate insure(s) (Check One): 

o Operations conducted with alf aircraft operated by the insured 

o Operations conducted with the following types of aircraft: 

~ Operations with the following aircraft: {Use addilional Daile If neteSiary) 

Make and Model 

As attached schedule 

FAA or Foreign Flag 

Reql!J!mlloo No. 

4. Each poJicy listed in this certificate meets or excee<fs the requirements in 14 CFR Part 205. 

Lloyd's Underwrilers and Certain Insurance Companies Cooper Gay & Co Ltd 

(Name of Insurer) (Name of Broker, if &ppHcabls) 

(Address) 

(City, Slat., Zip COda) 

ConlSct (ptHSOn who can verify the effectiVeness o( the coverage) 

f 

(Area Code, Pnone Number) (Area Code, Fax Nl,1mber) 

(Signafure. it applICable) 

(Date) 

52 Leadenhall Street 

(Addross) 

London EC3A 2EB 

(City, state, Zip COde) 

M Lovill 

(Off1c6r Dr sl,Jthoriled representative) 

+ 44(0)207 204 488} f + 44(0)207204 4893 

(A",a Coda, P"%7 A(M Fax Numbe~ 
GAMA GROUP LIMITED and lor GAMA AVIATION LIMITED 

Schedule of Aircraft attaching to OST Fonn 6411 

Aircraft 

Leatjet45 

Leatjet 45 

Hawker 800XP 

Hawker 125-800B 

Hawker 125 -1 000 

ChaIJenger 604 

ChaIJenger 604 

Gulfstream G550 

Registration 

G-GMAA 

G-ZXZX 

G-CDLT 

G- JJSI 

G-GMAB 

G-LVLV 

G-XONE 

G-CGUL 

Limit of LiabiJity(CSL) 

usn 200,000,000 

usn 200,000,000 

usn 350,000,000 

usn 200,000,000 

usn 200,000,000 

usn 250,000,000 

usn 250,000,000 

usn 300,000,000 
1<"'1,\\ 

~~; omcc of the Secretory 

ofTrnnspol1otion 

AGENCY DISPLAY OF ESTIMATED BURDEN 

The public reporting blJfoen for this collection of informa1ion Is estimated to average 30 minutes per response. If you wish 

10 comment on the accuracy of (he estimate or make suggestions for reducing Ihis burden. please direct your comments to; 

U.S. Department of TransportaUon. Office of Aviation Analysis, X~56. 1\00 7th st., SW •.• Washingfon, D,C, 20590. According 

10 the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless it displays 

a valid OMS control number. 

NOTE: For information on where to file completed copies of this form, see FILING INSTRUCTIONS below. 

OMS No. 2106-0030 Expires 9..30·2007 

FOREIGN AIR CARRIERS· CERTIFICATE OF INSURANCE 

POLiCIES OF INSURANCE FOR AIRCRAFT ACCIDENT BODILY INJURY 

AND PROPERTY DAMAGE LIABILITY 

FILING INSTRUCTIONS: File U signed original or this fon'rJ with the Federal Aviation Administration, Air Transportation Dill., AFS-260, 800 

Independence Ave" SW" Washington, DC 20591. (See EXCEPTION below.) 

EXCEPTION: If Secllon 2.A. is filled in because the insured is a CDnacJilW ClJarter Air Taxi Operator, file an original or this form with the U.S. 

Department 

ofTransporialion, Special Authorilles Division (X-46), 400 ill Street. SW, Washington, D,C. 20590 

(Please type information, Bxcep( signa/ures.) 

THIS CERTIFIES THAT: G-LosP\L A-ElZ-o-'?:'RrI.C.E u~eQ\t>.i~ .. -"n.~fr l"\4\:t-\~{.{t--xz.s. L-n') .. c-/o Y\t\"'w~~)::1 1\'-I\f\""f\GN L\D .. 

(Name of Insurer) 

has issued a policy or policies of Aircraft liability Insurance to SI.L-'1'BZ S~\Nc.- f"\1\~".,H\CSE.M.~ ~- "~/oR.... ~A. k-J\f'!:1\(1N 

L'\D. 10/8 'ya~\c:... f'~c.E l£€9b ~~i '2~'S. FAA Certtnoate Number::::;:::;c-_~ __ 

(Name, address and FAA Certificate number of Insured Foreign Air Carrier) 

effective from 2.l\-~ '3UI-'-f '2..0\ 0 until ten (10) days after wrlUen notice from the insurer or carrier of the intent 

to terminate coverage Is received by the Department of Transpor1alion. 

NOTE: Part 205 of the Department's Regulatlonli does not allow for a predetermined termination date, and a certificate showing SUch a date is 

unacceptable. 

~Ure.7Q~~~r-------------------~----~ Insurer (Check One): ____ ------~~--------------------------_1- T~e o is licensed to issue aircraft insurance policies in lhe United Slates; 

K is licensed or approved by the government of UK _10 issue aircraft insurance policies; or 

"'": ____ ~D~~i:s~a:n~a:p~p~ro~v~e~d~s:ur~p:ll:ls~":n:e~ln~s~u:~:r~ln~lh~e;S~'~at:e:(S~)~O~f:;:::;;::;;;;:;:::~~~-.-__ ~c-~_-cc-,-~~ 2. The 

Jnsurer assumes, under the policy or policies lisled beloW, aircraft accident liability insured 10 minimums at least equal to the following during 

operatton, maintenance, or use of aircraft in nforeign air transportation" as that (erm is defined in 49 U.S.C. 40102. 

(Complete applicable seclion A B or C belowl; 

A. CANADIAN CHARTER AIR TAXI OPERATORS WITH PART 294 AUTHORITY ONLY 

The aircraft covered by this policy have: (1) 30 or fewer passenger seats and a maximum payload capacily oj 7,500 pounds or Jess; and/or 

(2) a maximum authorized takeoff Weight on wheels of no more than 35,000 pounds, (Complere separate or c:ombined coverage as 

[JDPropriaio): 

8 Separate Coverages: Minimum Umi! 

Po/icvNo. Type of Uebifily Eacfl porson Eacl) Occurrence 

Combined Bodily Injury (Excluding Passengers other 

Ihan cargo altendants) and Property Damage Liability 

Passenger Bodily lnJury $75,000 

$75,000 $2,OOO,OOO*(S813 note) 

$75,000 x 75% of 

lotal number of 

passenger seals 

installed in aircraft 

o Combined Coverage: This combined coverage Is a single limil of liability for each occurrence alleast equal 10 the required minimums 

slaled above for bodily injury (excluding passengers), property damage, and passenger bodily Injury, 

Policy No. ____________ _ Amounl of Coverage' _________ U.S, Dollars 

fJ This policy covers CARGO operations only and excludes passenger liability insurance. 

NOTE: If Ille aircraft covered by this policy have more than 30 passenger sBals or more than a maximum payload capacity of 7,500 

pounds, the minimum limit per occurrence shall be $20,000,000. 

'-----------------------------------------------
OST F orm 6411 

B. FOREIGN AIR CARRIERS OPERATING SMALL AIRCRAFT 

The aircraft covered by this policy are SMALL AIRCRAFT (i.e., with 60 or fewer passenger seals or with a maximum payload 

capacity of 18,000 pounds or less), (!&ml2l@ltJ sOQarate orcombifJed coverage I1S ;w.Pfo{Jriale): 

U Separate Coverages: Minimum Umif 

Polio'l.No. T'lae of Liflbilif'l EfJJ;,h fl8rson Each Occurranc(J 

Combined Bodily Injury (Excluding Passengers other 

than cargo attendants) and Property Damage Liability $300,000 $2.000,000 

Passenger Bodily Injury $300,000 $300,000 x 75% of 

total number of 

passenger seats 

inslaUed in aircraft 

~ Combined Coverage: This combined coverage Is a single limit of liability for each occurrence at leasl equal 10 the required mlnlrrmms 

stated above rOf bodily injury (excluding passengers), property damaged, and passenger bodily injury. 

Po';cyNo. Amount of Coverage '-SDloca ,CCG U.S. Dollars 

0 This policy covers CARGO operalions only and excludes passenger liability insurance. 

.. __ C. fOREIGN AIR CARRIERS OPERATING LARGE AIRCRAFT --- The aircraft covered by this policy are LARGE AIRCRAFT (i.e., wilh more than 60 passenger seals or with a maximum payload capacity of 

more than 18,000 pounds), (Camp./efe s611.8rafe oreombined coverage n~ ae.ll.fDQ.riafe): 

0 Separale Coverages: Minimum Limit 

PoJic\f,No. T~l1~ of Uabilitl/.. _'£f!e/l {lerson Eaell Occurrence 

Combined Bodily Injury (Excluding Passengers other 

than cargo atlendanls) and Property Damage Liabitity $300,000 $20,000,000 

Passenger Bodily Injury $300,000 $300,000 x 75% or 

total number of 

passenger seats 

Installed in aircraft 

0 Comllined Coverage: This combilled coverage is a single limit of liability for ea~h occurrence at least equal to the required minimums 

slated above for bodily injury (excluding passengers), property damaged, and passenger bodily injury. 

Po/ieyNo. Amount of Coverage U.S. Dollars 

0 This policy covers CARGO operalions only and excludes passenger liability insurance. 

~ 

---

3. The policy or policies listed in this certificate insure(s) (Check One': Make and Model FAA or Foreign Flag 

Regi~!rallon No. 

-

0 OperatIons conducted wllh all aIrcraft operated by tile insured 

Lc(o;l\c..'/ IeeO G-I.'&RE' )fit" Operations conducted with the following types of aircraft: £t-\~~82., 

LJ Operations with Ille follOWing aircraft: (Use additional page if necessary) 

. . 

---

4. Each policy listed in this certificate meets or exceeds Ihe requlremen1s in 14 CFR Part 205. 

C:j'"\.G~P!.L ~'>~""'" u.N."tl ~e..wR.\:n N<r ""'",<\<l8Z.". L~. 1<i'N""~ ~\~ON L'D 

(Namo of Insurer) (Name of Srokar, if applicable) 

c..LQ , w"..,."" ""-'<> M\ M""\cr\'~ = 1.>,/'5\ G-Q..~ su.~OL¥:.. ~'" (Address) (AddrBss) 

Lo\'-l\)ON ~F\ G~s. 

(City, Stafe, Zip Code) 

(Cfty, Stale, Zip Code) 

C, CoI'!l<>ELL.. 

Contact (person who can verify the effectiveness of the coverag.e) (Officer or authorlled represenlafive) 

.\1.1.\>''20::1 <Ie?.. "iSOC> / .:\: I.", Wl 'ILk !Sell. a '>1.1.1.1. L.(,.,'n.&-'iin~o / -\-lUl,2.ol"102.. It'lUG 

(Area Codo, Phone Number) (Amu Code, Fax Number) (Area Code, Phone Number) (Area Code, Fax Number) 
(Signature, If applicable) 

",Irs-II Q 3:lAU2L /0 

(Da'e) , 
EXHIBITC 

OST Form 4523 Agreement 
u.S. Department of Transportation 

Office of the Secretary of Transportation AGREEMENT 

Docket CST 95-236 

The undersigned carriers (herem after referred to as "the Carriers") hereby agree as follows: 

1. Each of the Carriers shall, effective May 16, 1966, include the following in its condItions of carriage, including tarrffs embodying 

conditions of carnage filed by it with any government: 

"The Carrier shall avail itself of the [imitation of liability provided in the Convention for the Unificaflon of Certain Rules 

Relating to International Carriage by Air signed at Warsaw October 12th, 1929, or provided in the said Convention as amended by 

the Protocol signed at The Hague September 28th, 1955. However, in accordance with Article 22(1) of said Convention, or said 

Convention as amended by said Protocol, the Carrier agrees that, as to all international transportation by the Carrier as defined in 

the said Convention or said Convention as amended by said Protocol, which, according to the contract of Carriage, includes a 

point in the United States of America as a point of origin, point of destination, or agreed stopprng place 

(1) The limit of liability for each passenger for death, wound'lng, or other bodily 'rnjury shall be the sum of US $75,000 

inclusive of legal fees and costs, except that, in case of a claim brought in a State where provision is made for separate 

award of legal fees and costs, the limit shall be the sum of US $58,000 exclusive of legal fees and costs 

(2) The Carrier shall not, with respect to any claim arising out of the death, wounding, or other bodily injury of a passenger, 

avail itself of any defense under Article 20(1) of said Convention or said Convention as amended by said Protocol. 

Nothing herein shall be deemed to affect the rights and liabilities of the Carrier with regard to any claim brought by, on behalf 

of, or in respect of any person who has willfully caused damage which resulted in death, wounding, or other bodily injury of a 

passenger." 

2, Each Carrier shall, at the time of delivery of the ticket, furnish to each passenger whose transportation is governed by the 

Convention, or the Convention as amended by the Hague Protocol, and by the special contract described in paragraph 1, the following 

notice, which shall be printed in type at least as large as 10 point modern type and in ink contrasting with the stock on (i) each ticket; (ii) 

a piece of paper either placed in the ticket envelope with the ticket or attached to the ticket; or (iii) on the ticket envelope: 

··ADVICE TO INTERNATIONAL PASSENGER ON LIMITATION OF LIABILITY 

Passengers on a journey involving an ultimate destination or a stop in a country other than the country of origin are adVised 

that the provisions of a treaty known as the Warsaw Convention may be applicable to the entire journey, including any portion 

entirely within U,e country of origin or destination. For such passengers on a journey to, from, or with an agreed stopping place in 

the United Stat~s of Ameri{::a, th~ Convention and special contracts of carriage embodied in applicable tariffs provide that the 

liabililyof Gama AVlatlon Ltd. 

[certain r 

[(name of carrier) and certain other} carriers parties to such special contracts for death of or personal injury to passengers is 

limited in most cases to proven damages not to exceed US $75,000 per passenger, and that this liability up to such limit shall not 

depend on negligence on the part of the carrier, For such passengers traveling by a carrier not a party to such special contracts or 

on a journey not to, from, or having an agreed stopping place in the United States of America, liability of the carrier for death or 

personal injury to passengers is limited in most cases to approximately US $10,000 or US $20,000_ 

The names of Carriers parties to such special contracts are available at all ticket offices of such carriers and may be 

examined on request. 

Additional protection can usually be obtained by purchasing insurance from a private company. Such insurance is not 

affected by any limitation of the carrier's liability under the Warsaw Convention or such special contracts of carriage. For further 

information please consult your airline or insurance company representative." 

3. [This Agreement was filed with the Civil Aeronautics Board of the United States. The Board approved it by Order E-23680, 

adopted May 13, 1966. The Agreement (Agreement 18900) became effective May 16,1966. On January 1, 1985, this Agreement 

became the responsibility of the Department of Transportation (DOT) by operation of law,] 

4. This Agreement may be signed in any number of counterparts, all of which shall constitute one Agreement. Any Carrier may 

become a party to this Agreement by signing a counterpart hereof and depositing it with DOT. 

5, Any Carrier party he·reto may withdraw from this Agreement by giving twelv notice Of withdrawal to DOT 

*Either alternative may be used, 

(S!gnature and Dat,!,eb~...!~~",,~~~~~=::=~o;;:::'lL(jU~~'-'=r~2o\.~'o:o::: 

M OO,. 'A,,-.! A ~ ~QL. r ,-;-,,, (Printed Name and Title) ..!...-'..LttY---V""'''-'=-_'-_________ ~ __ L.A::-==_~ 

and the other Carriers parties to the Agreement. 

CST Form 4523 (Formerly CAB Form 263) 

(Name and Address of Carrier) ____ -;:-:-:-:-;---::""':-:--=-:-:-:-;--;-::-;: _____ _ 

6AMA AVIAT I ON LTD 

Btl51NE:55 AVN CENTRE 

FARNBOROUGH A I RPORT 

HANTS 6U14 6XA 
EXHIBITD 

Verification Statement 
VERIFICATION 

Pursuant to Title 18 United States Code 1001, I, Marwan A. Khalek, in my individual 

capacity and as the authorized representative of Gama Aviation Limited, have not in any manner 

knowingly and willfully falsified, concealed or failed to disclose any material fact or made any 

false, fictitious, or fraudulent statements in connection with the preparation, filing or prosecution 

of the foregoing pleading. I understand that an individual who is found to have violated the 

provisions of 18 U.S.c. Section 100 I shall be fined or imprisoned not more than five years, or 

both. 

~arw:in A.Xhalek 

C.E.O. 

August 09th 2010