BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

Application of 

SUN AIR EXPRESS, LLC d/b/a SUN AIR 

INTERNATIONAL 

For authority to conduct scheduled passenger 

operations as a commuter air carrier under 49 

U.S.C. 41738 

) 

) 

) 

) 

) Docket OST-2011-0169 

) 

) 

) 

) 

_________________________________ ) 

SUPPLEMENT NO.2 TO THE APPLICATION OF 

SUN AIR EXPRESS, LLC d/b/a SUN AIR INTERNATIONAL 

Communications with respect to this Application should be sent to: 

Thomas L. Cooper 

Chief Executive Officer & President 

SUN AIR EXPRESS, LLC d/b/a 

SUN AIR INTERNATIONAL 

3201 Griffin Road 

Fourth Floor 

Fort Lauderdale, FL 33312 

(954) 660-9865 

FAX: (954) 359-9502 

tlcooper@gosunair.net 

Dated: January 6, 2012 

Lonnie Anne Pera 

ZUCKERT, SCOUTT & RASENBERGER, 

L.L.P. 

888 Seventeenth Street, N.W. 

Suite 700 

Washington, D.C. 20006 

(202) 973-7913 

FAX: (202) 342-0683 

lapera@zsrlaw.com 

Counsel for Sun Air Express, LLC d/b/a Sun 

Air International 
BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

Application of 

SUN AIR EXPRESS, LLC d/b/a SUN AIR 

INTERNATIONAL 

For authority to conduct scheduled passenger 

operations as a commuter air carrier under 49 

U.S.C. 41738 

) 

) 

) 

) 

) Docket OST-2011-0169 

) 

) 

) 

) ________________________________) 

Dated: January 6, 2012 

SUPPLEMENT NO. 2 TO THE APPLICATION OF 

SUN AIR EXPRESS, LLC d/b/a SUN AIR INTERNATIONAL 

By letter dated December 29, 2011, the Department requested additional information 

from Sun Air Express, LLC d/b/a Sun Air International ("Sun Air" or the "Company") in 

connection with the Application for Commuter Air Carrier Authority (the "Application"). The 

Department gave Sun Air thirty (30) days to respond to its request. Sun Air hereby submits this 

Supplement No. 2 to its previously filed Application for the purpose of providing the specific 

information that the Department requested in the December 29, 2011 letter. Sun Air is extremely 

interested in commencing its proposed scheduled commuter services and respectfully requests 

that the Department process its application promptly. 

Department Request for Information 

1. In the November 15,2011 Supplement, Sun Air submitted a Promissory Note in 

Exhibit SUN-804, verifYing the terms ofthe $100,000 line-of-credit Cooper Trading Corporation 
SUPPLEMENT NO. 2 TO APPLICATION OF 

SUN AIR EXPRESS, LLC d/b/a 

SUN AIR INTERNATIONAL 

Page 2 

("Cooper Trading") has granted to Sun Air. Sun Air also enclosed Exhibit SUN-805, the 

financial statement of Cooper Trading. 

2. The Department now requests third-party verification that Cooper Trading has the 

finances available to extend the line-of-credit. In response, Sun Air encloses in Exhibit SUN806 an original letter dated January 3, 2012 from Thomas L. Cooper, as individual, to Cooper 

Trading. In the letter, Mr. Cooper confirms that he has agreed to guarantee Cooper Trading's 

promise to extend a $100,000 line-of-credit to Sun Air. Also enclosed in Exhibit SUN-806 is the 

original letter from Merrill Lynch, verifying that Mr. Cooper has more than $2.0 million in 

available funds. Mr. Cooper will extend $100,000 of these funds to his company Cooper 

Trading, if Cooper Trading cannot otherwise provide the amounts Sun Air may draw against the 

$100,000 line of credit. 

3. To date, Sun Air has not drawn any amounts under the line-of-credit. 

4. Sun Air has demonstrated that it has sufficient funds to support its proposed 

commuter air carrier operations. Both the cash available in its account and the $100,000 line-ofcredit are sufficient to cover pre-operating costs and three months of normal operating expenses. 

WHEREFORE, Sun Air Express, LLC d/b/a Sun Air International respectfully requests 

that the Department authorize it to conduct scheduled commuter air transportation services under 
SUPPLEMENT NO.2 TO APPLICATION OF 

SUN AIR EXPRESS, LLC d/b/a 

SUN AIR INTERNATIONAL 

Page 3 

49 U.S.C. § 41738 and 14 C.F.R. Part 298. Sun Air also requests such further, different, and 

additional relief as the Department may deem to be appropriate. 

Dated: January 6, 2012 

Respectfully submitted, 

ZUCKERT, SCOUTT & RASENBERGER, L.L.P. 

_ _/ 

Suite 700 

Washington, D.C. 20006 

(202) 973-7913 

Counsel for Sun Air Express, LLC d/b/a Sun Air 

International 
January 3, 2012 

Cooper Trading Corporation 

15790 Lindbergh Lane 

Wellington, FL 3 3414 

Thomas L. Cooper 

15790 Lindbergh Lane 

Wellington, Florida 33414 

Exhibit SUN-806 

Page 3 of 3 

This letter will confirm the agreement between T. L. Cooper, individual, and Cooper 

Trading Corporation, a Florida corporation, guaranteeing Cooper Trading Corporation's 

One Hundred Thousand Dollar ($1 00,000.00) credit facility in favor of Sun Air Express, 

LLC d/b/a Sun Air International. 

Please see evidence ofthese funds in the form of an attached letter from Merrill Lynch. 

Thomas L. Cooper 

TLC/eal 

Encl. 
~~ Merrill Lynch ~ Wealth Management 

Bank of America Corporation 

January 3, 2012 

U.S. Department OfTransportation 

Office of Aviation Analysis, Air Carrier Fitness Division 

1200 New Jersey Ave., SE 

RM. W86-307 

Washington, DC 20590 

Re: Thomas L Cooper 

Dear Mr. Remo: 

Gerard Hansen 

Vice President 

Administrative Manager 

Merrill Lynch Wealth Management 

450 E. Las Olas Blvd Ste 1000 

Fort Lauderdale, Florida 33301 

954 357 4554 

800 937 0279 

FAX 954 449 6086 

Gerard_ Hansen@ml.com 

Please be advised that Mr. Thomas L Cooper has available funds at Merrill Lynch in the amount 

excessive $2,000,000 as of January 3, 2012. Mr. Thomas L. Cooper has maintained an account 

with us since March 2006 and it is in good standing. 

Sincerely, 

U 7 /--~---~ 1 

_ ' }7 //·-··~ 

Gerard Hansen 

Vice President 

Administrative Manager 

Merrill Lynch Wealth Management makes available products and services offered by Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPF&S} and other 

subsidiaries of Bank of America Corporation. 

Investment products: 

Are Not FDIC Insured Are Not Bank Guaranteed May Lose Value 

Are Not Deposits Are Not Insured by Any Are Not a Condition to Any 

Federal Government Agency Banking Service or ActMty 

MLPF&S is a registered broker-dealer, member Securities Investor Protection Corporation (SJPC} and a wholly owned subsidiary of Bank of America Corporation. 

Merrill Lynch Ute Agency Inc. is a licensed agency and wholly owned subsidiary of Bank of America Corporation. 

ADMGRLTR 
VERIFICATION 

This Second Supplement to the Commuter Air Carrier Application and the information 

therein, including the Exhibits attached hereto, are true and correct to the best of my knowledge 

and belief. Pursuant to Title 18, United States Code section 1001, I, Thomas L. Cooper, in my 

individual capacity and as the authorized representative of the Applicant, have not in any manner 

knowingly and willfully falsified, concealed or failed to disclose 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 Amended Application 

or the initial 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. 

Respectfully submitted by 

Thomas L. Cooper 

Chief Executive Officer and President 

Sun Air Express, LLC d/b/a Sun Air International 
CERTIFICATE OF SERVICE 

I hereby certify that on this 6th day of January, 2012, a copy of the foregoing 

SUPPLEMENT NO. 2 TO THE APPLICATION OF SUN AIR EXPRESS, LLC d/b/a SUN AIR 

INTERNATIONAL was served by facsimile on the parties named below: 

Mr. Edward Dasilva 

Flight Standards District Office-17 

Federal Aviation Administration 

2895 S.W. 145th Avenue 

Suite 120 

Miramar, FL 33027 

Edward.m.dasilva@faa.gov 

David M. Hernandez 

Counsel for Silver Airways Corp. 

f/k/n VP AA Co. 

VEDDER PRICE P.C. 

1401 I Street, N.W. 

Suite 1100 

Washington, D.C. 20005 

dhemandez(mvedderprice.com 

Ms. Laura Remo 

Air Carrier Fitness Division, X-56 

Office of Aviation Analysis 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E., 8th Floor 

Room W-86-306 

Washington, D.C. 20590 

Laura.remo@dot.gov