# C04.S 9 Z1NOR
July 24, 2014 Mark W. Atwood Direct Phone 202-463-2513 Direct Fax 202-478-2751 matwood@cozen.com 

## Ms. Lauralyn Remo Chief Air Carrier Fitness Division Department of Transportation 1200 New Jersey Ave., S.W. Washington, DC 20590
Re: Western Global Airlines, LLC -- Effectiveness of Certificate Authority
Dear Ms. Remo: Western Global Airlines, LLC ("Western Global") is submitting herewith information required by Orders 2014-2-21 and 2014-4-27 for activation of the carrier's certificates for interstate and foreign charter air transportation of cargo and mail. The certificates require, as a condition of their effectiveness, that the carrier submit the following: (a) A copy of the holder's Air Carrier Certificate and Operations Specifications from the Federal Aviation Administration (FAA) authorizing such operations; (b) A certificate of insurance on OST Form 6410 evidencing liability insurance coverage meeting the requirements of 14 CFR 205.5(b) for all of its aircraft; (c) A statement of any changes the holder has undergone in its ownership, key personnel, operating plans, financial posture, or compliance history, since the date of the Show Cause Order in this case; (d) A revised list of pre-operating expenses already paid and those remaining to be paid, as well as independent verification that the holder has available to it funds sufficient to cover any remaining pre-operating expenses and to provide a working capital reserve equal to the operating costs that would be incurred in three months of operations. Western Global is hereby submitting responses to items (b) through (d); the FAA certificate and op specs (item (a)) have not yet been issued. However, as the carrier's final proving flight is scheduled to be completed on July 25, we anticipate that the certificate and op specs will be issued the following Monday, July 28. Thus, in order to expedite the Department's review of the required materials, we are supplying all except the last piece. Accordingly, in response to item (b), I am attaching DOT Form 6410, dated July 23, 2014, showing current insurance coverage for the carrier's fleet exceeding the requirements of section 205.5 of the Department's rules. (Exhibit 1)

1627 I Street, NW Suite 1100 Washington, D.C. 20006 202.912.4800 800.540.1355 202.861.1905 Fax cozen.com

## Ms. Lauralyn Remo

July 24, 2014 Page 2
In response to item (c), I have the following information. Since the issuance of the Show-Cause Order (2014-2-11, February 25, 2014), there have been no changes in the ownership or key personnel of Western Global. The company's financial posture is essentially unchanged. The company has had no accidents or incidents, nor have any enforcement matters been initiated during the relevant period pertaining to the carrier, any relevant corporation, persons having an interest in any relevant corporation, or any personnel employed or to be employed by any relevant corporation, or that would otherwise have to be disclosed under Section 204.3(o) or (p). In response to item (d), there are no further pre-operating expenses to be paid; with the completion of the proving flights, all will have been paid in full. Exhibit 2 contains a third-party verification from J.P. Morgan Private Bank, verifying that James and Carmit Neff each have inexcess of $5 million in their personal accounts, which is well in excess of the expected threemonth average operating cost. Mr. and Mrs. Neff have already established that they are prepared to use their personal funds to underwrite losses during the first year of operation. Western Global also requests that the Department waive the six-day waiting period for effectiveness specified in the Orders so that it may make the authority effective and permit revenue flights to commence as soon as the FAA authority is received. The carrier will file those documents with the Department as soon as they are received from the FAA. Western Global Airlines accordingly requests that the Department activate its certificate authority for foreign air transportation as granted by Orders 2014-2-21 and 2014-4-27, as soon as the FAA certificate and op specs are provided to the Department. Respectfully submitted, 

# 4czt

Mark W. Atwood Counsel for Western Global Airlines, LLC

cc: Catherine O'Toole Dockets OST-2013-105 and -106

# EXHIBIT 1

AGENCY DISPLAY OF ESTIMATED BURDEN The public reporting burden for this collection of information is estimated to average 30 minutes per response. If you w sh to comment on the accuracy of the estimate or make suggestions for reducing this burden, please direct your comments to the Department of Transportation at the following address: U.S. Department of Transportation Office of Aviation Analysis, X-56 400 7th Street, SW. Washington, DC 20590 

### US. Department of Transportation 

### Office of the Secretary of Transportation OMB No. 2106-0030 

## U.S. AIR CARRIERS CERTIFICATE OF INSURANCE POLICIES OF INSURANCE FOR AIRCRAFT ACCIDENT BODILY INJURY

AND PROPERTY DAMAGE LIABILITY

FILING INSTRUCTIONS: File an original of this form with the FAA, Air Transportation Div., AFS-260, 800 Independence Ave., SW., Washington, DC 20591. NOTE: If Block 2B on the reverse is filled in because the insured is an air taxi operator conducting scheduled passenger service (i.e., a commuter air carrier), file an original of this form with the Air Carrier Fitness Div., X-56, Office of Aviation Analysis, Dept. of Transportation, 400 7th St., SW., Washington, DC 20590. (Please type information, except signatures.)



### THIS CERTIFIES THAT: SEE ATTACHED (Name of Insurer) 

### has issued a policy or policies of Aircraft Liability Insurance to Western Global Airlines, LLC 

### 5566 Broadcast Court, Sarasota, FL 34240 

### FAA Certificate Number (Name, address and FAA Certificate number of Insured U.S. Air Carrier) 

### effective from July 7, 2014 

### until ten (10) days after written notice from the insurer or carrier of the intent to terminate coverage is received by the Department of Transportation. NOTE: Part 205 of the Department's Regulations does not allow for a predetermined termination date, and a certificate showing such a date is unacceptable.
1. The Insurer (Check One): 

# El is licensed to issue aircraft insurance policies in the United States;

• is licensed or approved by the government of to issue aircraft insurance policies; or E is an approved surplus line insurer in the State(s) of 2. The insurer assumes, under the policy or policies listed below, aircraft accident liability insured to minimums at least equal to the following during operation, maintenance, or use of aircraft in "air transportation" as that term is defined in 49 U.S.C. 40102. 

### (Complete applicable section(s) below): A. U.S. AIR TAXI OPERATORS WITH PART 298 AUTHORITY ONLY 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). 

### (Check separate or combined coverage as appropriate): O Separate Coverages: Minimum Limit

Policy No. Type of Liability Each Person Each Occurrence Bodily Injury Liability (Excluding Passengers) $ 75,000 $300,000 Passenger Bodily Injury $ 75,000 $75,000 x 75% of total number of passenger seats installed in aircraft Property Damage $100,000

• Combined 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 (excluding passengers), property damaged, and passenger bodily injury. Policy No. Amount of Coverage 111 This policy covers CARGO operations only and excludes passenger liability insurance.

OST Form 6410B. U.S. COMMUTER AND CERTIFICATED 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). 

### (Check separate or combined coverage as appropriate): 

## LI Separate Coverages: 

### Minimum Limit

Policy No. Type of Liability Each Person Each Occurrence

Combined Bodily Injury (Excluding Passengers other than cargo attendants) and Property Damage Liability Passenger Bodily Injury

Combined 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 (excluding passengers), property damaged, and passenger bodily injury. 

### Policy No. Amount of Coverage



## 111 This policy covers CARGO operations 

### only and 

### excludes passenger liability insurance.
C. U.S. CERTIFICATED AIR CARRIERS OPERATING LARGE AIRCRAFT The aircraft covered by this policy are LARGE AIRCRAFT (i.e., with more than 60 passenger seats or with a maximum payload capacity of more than 18,000 pounds). (Check 

### separate or combined coverage as appropriate): 

### I Separate Coverages: 

### Minimum Limit

Policy No. Type of Liability Each Person Each Occurrence

Combined Bodily Injury (Excluding Passengers other than cargo attendants) and Property Damage Liability Passenger Bodily Injury Combined 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 (excluding passengers), property damaged, and passenger bodily injury. 

### Policy No. SEE ATTACHED Amount of Coverage $750,000,000 

## 111 This policy covers CARGO operations 

### 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 Registration No. 

## El Operations conducted with all aircraft operated by the insured 

## n Operations conducted with the following types of aircraft: 

## LI Operations with the following aircraft: (Use additional page if necessary)

4. Each policy listed in this certificate meets or exceeds the requirements in 14 CFR Part 205. 

### SEE ATTACHED JLT AEROSPACE (North America) Inc. (Name of Insurer) (Name of Broker, if applicable) 2300 Dulles Station Blvd., Ste 230 (Address) (Address) Herndon, VA 20171 (City, State, Zip Code) (City, State, Zip Code) Tracy Myers Contact (person who can verify the effectiveness of the coverage) (Officer or authorized representative) 703

- 459

- 2393 / 703

- 459

- 2381 (Area Code, Phone Number) (Area Code, Fax Number) (Area Code, Phone Number) (Area Code, Fax Number)



### (Signature, if applicable) (Signature) July 23, 2014 

### Date) (Date)

OST Form 6410SECURITY SHEET

POLICY TERM: July 7, 2014 to July 7, 2015, on both dates at 12:01 A.M. Local Standard Time at the address of the Named Insured.

INSURER POLICY NUMBER Member Companies of Global Aerospace, Inc. 343185/14 One Sylvan Way Parsippany, NJ 07054 SHARE 10.00%

Starr Surplus Line Insurance Company per Starr Aviation Agency, Inc. 3353 Peachtree Road NE, Suite 1000 Atlanta, GA 30326 Ironshore Specialty Insurance Company per Starr Aviation Agency, Inc. 3353 Peachtree Road NE, Suite 1000 Atlanta, GA 30326 XL Specialty Insurance Company One World Financial Center 200 Liberty Street, 3 rd Fl. New York, NY 10281 StarNet Insurance Company Per Berkley Aviation, LLC 1101 Anacapa Street, Suite 200 Santa Barbara, CA 93101 Member Companies of La Reunion Aerienne 134 Rue Danton 92300 Levallois-Perret SASLAMR63622114-01 9.50%

IHM100189-01 5.50%

UA00010029AV14A 7.50%

BA-14-07-00109 5.00%

2014/60184 15.00%

Great American Insurance Company, Inc. QS2406150-00 3.30% 197 State Highway 18, Suite 3000 East Brunswick, NJ 08816
Torus Insurance (Europe) Limited 29153D140AAV 4.50% Genferstrasse 35 8002 Zurich Underwriters at Lloyds of London, J51410079 20.70% British Insurance Companies and Others Per JLT Specialty Limited The St Botolph Building 138 Houdsditch London EC3A 7AW
Isosceles Insurance Ltd. WG-01-001-14 19.00% Cedar House 41 Cedar Avenue Hamilton HM 12, Bermuda

TOTAL 100.00%

SEVERAL LIABILITY NOTICE The subscribing insurers' obligations under contracts of insurance to which they subscribe are several and not joint and are limited solely to the extent of their individual subscriptions. The subscribing insurers are not responsible for the subscription of any co-subscribing insurer who for any reason does not satisfy all or part of its obligations. LSW 1001 (Insurance)

### Best Regard

ood Account Officer JP Morgan Private Bank 

# EXHIBIT 2

July 21, 2014

James K Neff Chief Executive Officer Western Global Air, LLC 5566 Broadcast Ct. Sarasota, FL. 32420

Re: Confirmation of Account Balances

Dear Mr. Neff: Pursuant to your request, this letter will confirm that JP Morgan has balances in excess of $5,000,000.00 for each of the below individual accounts:

• Carmit (Sunny) P. Neff in excess of $5,000,000.00

• James K. Neff in excess of $5,000,000.00

T1115 Lt IIER AND ANY INFORMATION PROVIDED IN CONNECTION HEREWITH ARE FURNISHED ON THE CONDITION THAT THEY ARE STRICTLY CONFIDENTIAL, THAT NO LIABILITY OR RESPONSIBILITY WHATSOEVER IN CONNECTION HEREWITH SHALL ATTACH TO JPMCB OR ANY OF ITS OFFICERS, EMPLOYEES, OR AGENTS, THAT THIS REPORT MAKES NO REPRESENTATIONS REGARDING THE GENERAL CONDITION OF THE SUBJECT, [ITS MANAGEMENT] OR [ITS/HIS/HER] FUTURE ABILITY TO MEET [ITS/HIS/HER] FUTURE ABILITY TO MEET [ITS/HIS/HER] OBLIGATIONS, AND THAT ANY INFORMATION PROVIDED IS SUBJECT TO CHANGE WITHOUT NOTICE.

500 Stanton f Orisitiana Road, Newark, Delaware 1a713-2107 ER. Morgan Servici.s, tnc as agent for ;PMorgan Close Bank, N.A.