C;Jl-\s{t AM ~Il. C~\At_cl'~;!i (:. )bj'~\:y~f'" ZUCKERT SCOUTT [y RASENBERGER. L.L.P.

Size: px
Start display at page:

Download "C;Jl-\s{t AM ~Il. C~\At_cl'~;!i (:. )bj'~\:y~f'" ZUCKERT SCOUTT [y RASENBERGER. L.L.P."

Transcription

1 C;Jl-\s{t AM ~Il. C~\At_cl'~;!i (:. )bj'~\:y~f'" ZUCKERT SCOUTT [y RASENBERGER. L.L.P..3.'18 ~e\'enteenth StrFet.,"1'1 v\~lshjr1:j,ton, DC 20(XJ6-33,19 Tdephone 1202J 208-R';(,() F,LX [202J 7,42-U6W, \, W\." zsria,'vcom LONNIE ANNE PERA DIRECT DIAL (202) BY AND BY HAND Chief, Special Authorities Division, X-46 Office oflntemational Aviation U.S. Department of Transportation 1200 New Jersey Avenue, S.E., 8 th Floor Room W Washington, D.C Re: Gulfstream Air Charter, Inc. Objection to Spirit Request for Waiver Dear Ms. Archer: Gulfstream Air Charter, Inc. ("Gulfstream" or the "Company") hereby responds to the March 29, 2011 request by Spirit Airlines for a waiver of the Department of Transportation's Part 212 and 380 financial security requirements (the "Spirit Request"). As is discussed in more detail below, Spirit Airlines has made incorrect statements about the Cuba charter market in general and about the Company in particular. Gulfstream respectfully urges the Department to not grant a blanket waiver to Spirit Airlines based upon these statements. According to the Request, Spirit will provide charter air transportation services between Hollywood Fort Lauderdale International Airport ("FLL") and Havana, Cuba ("HA V") for travelers, who are licensed by the Office of Foreign Assets Control ("OF AC") to engage in travel related transactions with respect to Cuba (hereinafter "Licensed Travelers"). It appears that Spirit proposes to provide these services on its own and not as a direct air carrier for an OF AC licensed charter operator (a "Carrier Service Provider"). To do so, Spirit must (a) hold an effective Carrier Service Provider ("CSP") license issued by OF AC, so that it can apply for landing rights in Cuba, enter into ground arrangements in Cuba, and operate to/from Cuba, (b) obtain Part 380 authorization from the Department upon filing a public charter prospectus, (c) maintain the financial security arrangements required in Sections 212.7, 212.8, , and of the Department's Regulations, and Cd) comply with all other applicable mles and regulations relating to the Cuba charter f1ights. Spirit seeks a waiver of ( c) and makes statements in support of this waiver. Many of its statements are incorrect.

2 ZlJCKERT SCOUTT [;r RASENBERGER, L.L.P. Page 2 I. Spirit Airlines Does Not Appear to Hold a CSP License Spirit acknowledges that "air service to Cuba remains restricted to licensed charter tlights." Spirit Request at 2. Yet, Spirit does not seem to comply with the OFAC licensing requirements. OF AC requires that charter operators and air carriers obtain CSP licenses before they engage in any transactions relating to transportation services to Cuba. Charter operators, therefore, must obtain CSP licenses before they enter into charter agreements with direct air carriers and apply for other required authorizations and permits (including landing rights in Cuba and Part 380 authorization from the Department). Air carriers, likewise, must obtain CSP licenses before they may apply for these same authorizations and permits. In fact, if a carrier such as Spirit Airlines wants to market and sell charter air transportation services to Cuba on its own, it must hold an effective CSP license. To the extent that Spirit wishes to sell tickets on the flights, it must obtain a Travel Service Provider ("TSP") license as well. And if it hopes that travel agencies will sell tickets on the Spirit charter flights, it must ensure that each agency has an effective TSP license. Spirit has not indicated that it will comply with any of these rules. In fact, it has not stated in the Request that it even holds an effective CSP license. OFAC's most recent list of Authorized Service Providers, moreover, does not confirm that Spirit holds either the CSP or TSP license. See April 18,2011 List of Authorized Service Providers at: tsp.pdf How is it then that Spirit can submit a request for a waiver, let alone apply for landing rights in, and offer charter air transportation services to, Cuba? Gulfstream respectfully objects to the grant of any waiver to an air carrier that does not hold required OF AC license. II. OFAC Regulations And Rules Do Not Replace The Department's Consumer Protection Requirements Spirit further states that OF AC requires air carriers "to certify that their financial responsibility to operate the flights." See Spirit Request at 2 (citing Circular 2006 at Appendix I, page 7). Spirit then suggests that it should not have to comply with DOT's financial security requirements because the certification of financial ability somehow protects passenger payments. There is nothing in Circular 2006 to suggest or state this. The certification to which Spirit refers is a statement that applicants must make in their CSP license applications. According to Circular 2006 Appendix I, applicants must certify that they are currently able "to be responsible for all of the financial requirements inherent in the operation of the Flights." OFAC further requires that applicants provide "a detailed estimate of each relevant expense in the operation of the Flights." The estimate and the certification together are intended to demonstrate that applicants know the expenses they will incur in

3 ZUCKERT SCOtJTT [y RASENBERGER, L.L.P Page 3 arranging/operating charter flights and can pay those expenses. Nothing in Circular 2006 states that the certification extends to financial security arrangements to protect passenger payments. Nor does Circular 2006 state that the certification in any way replaces DOT's consumer protection requirements. The fact that Circular 2006 references the Operator-Participant Contract but not DOT's financial security requirements, moreover, does not mean that the financial security requirements are not necessary or do not apply. Appendix II of Circular 2006 certainly does incorporate the DOT Operator-Participant Contract requirement into OFAC's screening procedures. OFAC, however, does not "provide specific operator-participant contract requirements" as Spirit states. To the contrary, OF AC establishes a rule as to the documentation Carrier Service Providers must receive when a Licensed Traveler makes a reservation or purchases a ticket. It is DOT - not OF AC - that requires all charter passengers to receive, review and sign the Operator-Participant Contract. And it is DOT - not OF AC - that requires charter operators and air carriers to enter into financial security arrangements for protecting passenger payments. Circular 2006 does not change or replace DOT's requirements. Gulfstream objects to any suggestion that OF AC has responsibility for ensuring that passenger payments are protected. OFAC's application process does not replace the need for DOT's financial security requirements, particularly in the U.S.-Cuba market. III. DOT's Financial Security Requirements Do Not Impose Burdensome Transaction Costs That Result In Fare Increases As its main argument, Spirit contends that the costs of maintaining DOT-required financial security arrangements have resulted in high fares to Licensed Travelers. It further argues that Spirit would be able to offer lower fares to Licensed Travelers, if it did not have to enter into financial security arrangements. Spirit Request at 3 and 5. Gulfstream respectfully objects to the notion that the costs of maintaining a $200,000 surety bond or letter of credit and a depository arrangement are burdensome transaction costs that have significantly impacted its fares. Gulfstream certainly has costs of arranging charter flights to Cuba. Not only must it pay the direct air carrier for operating the charter flights, but it also must pay (a) fuel surcharges to the direct air carrier, (b) landing fees, ground handling charges, and related service fees to Havanatur, S.A., the Cuban entity responsible for flight clearances and services in Cuba, (c) advertising costs to U.S. companies, and (d) various other expenses. These other expenses include DOT's prospectus filing fees, Florida Seller of Travel application and renewal fees, operating bank account fees, depository bank account fees, letter of credit fees, business insurance premiums, legal fees and costs, office supply costs, etc. Gulfstream establishes its fares for the DOT-approved charter flights based upon all of these costs.

4 ZUCKERT SCOUTT [y RASENBERGER, L.L.P. Ms. T orlanda Archer Page 4- While the Company does consider the costs of maintaining a $200,000 letter of credit and a depository arrangement (the "financial security costs") in determining its fares, these financial security costs are nominal in comparison to the other costs. For the year 2010, Gulfstream paid less than $4.00 in financial security charges on behalf of each Licensed Traveler booked on a charter flight it arranged to Cuba. This per passenger charge did not impact significantly the airfare Gulfstream offered in Nor does Gulfstream expect the financial security costs to necessarily cause higher airfares in I Spirit claims that it is "an experienced, financially stable, low-cost air carrier" that has "adequate financial reserves to assure reimbursement of charter participant funds in the event of an improper nonperformance of service." Spirit Request at 3-4. With this experience, Spirit should be able to negotiate similar financial security arrangements as Gulfstream. In this case, it could comply with DOT's financial security requirements without facing any unduly burdensome costs. IV. Spirit Airlines Has Made Inaccurate Statements About The Company Gulfstream is quite surprised at some of the statements and suggestions Spirit has made about the Cuba charter business in general and the Company in particular. The Request demonstrates that either Spirit does not have a full understanding of the Cuba market or it has a negative view of Gulfstream (as well as other Carrier Service Providers). To ensure that the Department has accurate information about the Company, Gulfstream corrects the inaccurate statements. A. Spirit is Wrong in Alleging That a Cartel/Monopoly Exists Spirit states that the charter companies "'are a virtual cartel that control the travel sector from the U.S. to Cuba, charging egregious fees in collusion with the Cuban authorities. '" Spirit Request at 3. While Spirit quotes another source to make this point, it clearly believes this is the case. After all, Spirit states that its proposed charter air transportation services are "necessary to meet... demand and prevent monopolistic pricing stmctures." Id. at 4. While the annual financial security cost attributable to each Licensed Traveler is nominal, the time involved in managing passenger payments forwarded to the depository bank is not insignificant. Gulfstream estimates than an employee spends between 3 and 5 hours each week preparing (1) an accounting of the payments (including amount paid and name of Licensed Traveler), (2) the flight payment certificate(s) for the amount to be paid to the direct air carrier for each flight, and (3) the flight completion certificate(s) stating the date on which each flight was completed. If the Department grants a waiver to Spirit, the Company will seek a similar waiver, so that it can minimize employee time and expenses in performing these functions.

5 ZUCKERT SCOUTT [y RASENBERGER, L.L.P. Ms. T orlanda Archer Page 5 Gulfstream vehemently opposes these statements and any suggestion that it (a) is part of a cartel, (b) controls the travel sector, (c) charges egregious fares and fees, or (d) is acting in collusion with Havanatur or with any other entity (U.S., foreign, or Cuban). Gulfstream has arranged charter air transportation to Cuba since 2003 (Gulfstream International Airlines arranged the charter flights from 1998 until 2003). It has excellent business relationships with direct air carriers, Travel and Carrier Service Providers, and Havanatur. These business relationships have been established through arms-length negotiations. They are entirely consistent with OFAC's Circular 2006 and with other applicable U.S. laws rules and regulations. Gulfstream is not part of a cartel or monopoly, and it is not in collusion with any entity to set prices or to engage in any prohibited practices. Importantly, Gulfstream has had a mission to provide charter air transportation services to/from Cuba, using reliable and safe airlines, 2 at best possible fare it can offer, given the high cost of chartering the aircraft, the rising fuel prices, and other required charges that are directly related to the charter flights (including landing fees, ground handling charges, insurance premiums for business liability insurance, etc.). Gulfstream's fares are solely within its discretion and are directly related to all of these costs. For Spirit to suggest that it is colluding with any entity to set fares is bordering on slander. And for Spirit to suggest that Gulfstream's fares are not appropriate given the various costs is completely inaccurate. B. Spirit is not Correct in Stating That Only a Handful of Carrier Service Providers Arrange Charter Flights to Cuba Spirit expressly states that only "a handful of charter companies regularly" arrange charter flights to Cuba before the 2004 OF AC changes that restricted Cuban American travel. See Spirit Request at 3. It also states that even after OFAC changed the travel restrictions in September 2009, "only a small number of charter operators" are servicing the Cuba market. Id. at 3-4. These statements are not correct. Prior to the 2004 OF AC changes, at least seven charter operators holding CSP licenses arranged charter flights, on a weekly basis, between three U.S. airports and five Cuban destinations. The three U.S. airports were Miami International Airport (MIA); lfk International Airport (JFK); and Los Angeles International Airport ("LAX"). The five Cuban destinations were Havana; Cienfuegos; Camaguey; Holguin; and Santiago. In 2009, before OF AC expanded the travel restrictions, an eighth charter operator returned to the Cuba charter market. Since 2009, eight charter operators have arranged charter flights between the three airports (including for a period of time LAX) and the five Cuban airports. This is not a 2 Gulfstream has chartered aircraft from reputable U.S. airlines, including American Eagle Airlines, Continental Airlines and Miami Air International.

6 ZUCKERT SCOUTT 6- RAsENBERGER, L.L.P. Page 6 small number of service providers, but rather a significant number given the existing travel restrictions to Cuba. C. Spirit is not Correct in Suggesting that the Carrier Service Providers are not Meeting Demand Spirit further maintains that its services are necessary to meet current demand. Spirit Request at 4. Spirit appears to suggest that the existing eight Carrier Service Providers are not meeting demand. Any such suggestion is not correct. The number of charter flights Gulfstream arranges depends upon several factors. Obviously, one ofthese factors is demand. 3 If more Licensed Travelers demand transportation than is currently offered, Gulfstream will consider adding flights. But it cannot do so without also considering whether Havanatur will grant landing rights for those additional flights. This is not a market whereby any Carrier Service Provider can simply add flights. A Carrier Service Provider should never ignore Cuba's requirements,just to flood the market with flights. The bottom line is that the Company (as well as other Carrier Service Providers) will add charter flights, ifthere is demand by Licensed Travelers and if all required authorizations and clearances will be granted. D. Spirit is not Correct in Suggesting that Carrier Service Providers are Motivated to Cancel Flights When Demand is low Spirit, lastly, maintains that it (a) will "prevent stranding passengers" when mechanical problems occur and (b) avoid cancelling flights when demand is low. Spirit Request at 4. As support, the airline states that "charter operators... may be motivated to cancel flights when demand is low." Id. Spirit, by contrast, "does not foresee cancellations" because - as it suggests - its services are reliable and those of charter operators are not. Id. at 4-5. Nothing could be further from the truth in the Cuba market. While Gulfstream is not an air carrier, it is a DOT -authorized indirect air carrier. And it charters aircraft from safe and reliable direct air carriers. If those carriers cannot operate a particular flight during Customs business hours, Gulfstream immediately arranges for alternate charter air transportation. Licensed Travelers will not be stranded as a result of a direct air carrier's mechanical problems; Gulfstream sees to it that Licensed Travelers are transported to their ultimate destination. 3 The Company questions how Spirit can make any statements about demand in the Cuba market. Spirit has not sold a single ticket for travel to Cuba. Nor should it have done so. As OFAC's April2011 List of Authorized Service Providers shows, Spirit does not have a TSP license.

7 ZUCKERT SCOUTT [y RASENBERGER. L.L.P. Ms. T orlanda Archer April 19, 2011 Page 7 In addition, Gulfstream has never cancelled a charter flight "when demand was low." It is not motivated to do so for a number of reasons. First, since day one, it has been committed to offering charter air transportation in accordance with DOT Regulations. It would never deviate from DOT rules by cancelling a flight for low demand. Second, Gulfstream values its customers. It has contracted with reputable U.S. direct air carriers - even when the charter price was higher than that of low cost or charter carriers - to ensure that the charter flights would operate as scheduled (and as approved by the Department). It also chooses reputable carriers because cancelling flights would irreparably impair the Company's reputation in a highly regulated and competitive market. Third, under most if not all charter agreements, the direct air carriers impose high fees when a charter operator cancels a flight. These contractual requirements tend to remove any motivation (which Gulfstream does not have) to cancel flights. Gulfstream does not wish to suggest that it has never cancelled flights. Since 2003, it has had to do so as a result of circumstances beyond its control. For example, Gulfstream has had to cancel some flights when hurricanes and tropical storms temporarily closed the airports in Cuba. Gulfstream, in these cases, ensured that Licensed Travelers were accommodated on other DOTapproved charter flights. In addition, after OF AC amended the Regulations in June 2004 to restrict travel to Cuba, Gulfstream had no choice but to cancel some flights and to substitute other flights with smaller aircraft. The Company did so, not because of low demand, but rather because of "no demand". There simply were fewer Licensed Travelers as a result ofofac's regulatory change. No Carrier Service Provider can guarantee that a flight will not be cancelled. Some circumstances (such as those relating to severe weather) are simply beyond the Carrier Service Provider's control. Even Spirit understands this. After all, it was forced to cancel scheduled flights in June 2010 as a result oflabor disputes. Given Spirit's own history of canceling flights, it is remarkable that Spirit would suggest that charter operators are more likely to cancel flights than air carriers. Gulfstream certainly has never cancelled charter flights because some seats were not filled. And while some flights had to be cancelled or delayed as a result of unforeseen circumstances, Gulfstream has made alternate arrangements - including contracting with different carriers - to accommodate Licensed Travelers. Any suggestion that it would strand passengers is not only wrong but also offensive. * * * * Gulfstream does not object to a Carrier Service Provider offering public charter air transportation to Cuba, in accordance with OF AC and DOT requirements. It, however, does take

8 ZlTCKERT SCOUTT 6- RASENBERGER, L.L.p. Page 8 issue with the Department granting a waiver of the financial security requirements based upon inaccurate and (in some cases) inflammatory statements. For this reason, Gulfstream objects to Spirit's waiver request. Respectfully submitted, 'ZUCKERT, SCOUTT & RASENBERGER, L.L.P. By: Lonnie Anne Pera Attorneys for Gulfstream Air Charter, Inc. cc: Ms. Joanne M. Young (by ) Mr. David W. Kirstein Counsel for Spirit Airlines, Inc. Ms. Susan Jollie (by ) Counsel for C&T Charters Mr. Pierre Murphy (by ) Counsel for Wilson International Services, Inc. Mr. Josh Romanow (by ) Counsel for Xael Charters, Inc. Mr. Charles Bishop (by ) Office of Foreign Assets Control U.S. Department of the Treasury Mr. Gilberto Torres Vela (by ) Office of Cuban Affairs U.S. Department of State

Category: ( ) ( ) ( ) ( ) ( ) ( ) R/T O/W R RP +I/L +Land Svs TSP# TSP Name:

Category: ( ) ( ) ( ) ( ) ( ) ( ) R/T O/W R RP +I/L +Land Svs TSP# TSP Name: XAEL Charters, Inc. RESERVATION FORM PLEASE USE 1 SHEET (XAEL needs the Original of this form prior to departure date. Please attach a copy of License) Outbound Flight#: Return Flight#: Outbound Date:

More information

CIRCULAR 2006. TRAVEL, CARRIER and REMITTANCE FORWARDING SERVICE PROVIDER PROGRAM OFFICE OF FOREIGN ASSETS CONTROL

CIRCULAR 2006. TRAVEL, CARRIER and REMITTANCE FORWARDING SERVICE PROVIDER PROGRAM OFFICE OF FOREIGN ASSETS CONTROL CIRCULAR 2006 TRAVEL, CARRIER and REMITTANCE FORWARDING SERVICE PROVIDER PROGRAM OFFICE OF FOREIGN ASSETS CONTROL March 2006 CIRCULAR 2006 Subject TABLE OF CONTENTS Page I. Overview 3 II. Service Provider

More information

2. APPLICABILITY. This AC provides information for any person who engages in public aircraft operations (PAO) as defined by the statute.

2. APPLICABILITY. This AC provides information for any person who engages in public aircraft operations (PAO) as defined by the statute. U.S. Department of Transportation Federal Aviation Administration Advisory Circular Subject: Public Aircraft Operations Date: 2/12/14 Initiated by: AFS-800 AC No: 00-1.1A Change: 1. PURPOSE. This advisory

More information

TRAVEL APPLICATION FORM

TRAVEL APPLICATION FORM Page 1 of 5 TRAVEL APPLICATION FORM Full Name (as on passport): Home Address: Birth Date: Passport Number: Citizenship: First M.I. Last street city state zip Birth Place Exp.Date (must be valid for six

More information

One Card Office Division of Student Affairs

One Card Office Division of Student Affairs One Card Office Division of Student Affairs THIS AGREEMENT, made and entered into this day of, 20 ( Effective Date ) is between The University of Connecticut, on behalf of its One Card Office and, having

More information

CIRCULAR 2012. TRAVEL, CARRIER and REMITTANCE FORWARDING SERVICE PROVIDER PROGRAM OFFICE OF FOREIGN ASSETS CONTROL

CIRCULAR 2012. TRAVEL, CARRIER and REMITTANCE FORWARDING SERVICE PROVIDER PROGRAM OFFICE OF FOREIGN ASSETS CONTROL CIRCULAR 2012 TRAVEL, CARRIER and REMITTANCE FORWARDING SERVICE PROVIDER PROGRAM OFFICE OF FOREIGN ASSETS CONTROL July 2012 CIRCULAR 2012 Subject TABLE OF CONTENTS Page I. Overview 3 II. Service Provider

More information

CIRCULAR 2012. TRAVEL, CARRIER and REMITTANCE FORWARDING SERVICE PROVIDER PROGRAM OFFICE OF FOREIGN ASSETS CONTROL

CIRCULAR 2012. TRAVEL, CARRIER and REMITTANCE FORWARDING SERVICE PROVIDER PROGRAM OFFICE OF FOREIGN ASSETS CONTROL CIRCULAR 2012 TRAVEL, CARRIER and REMITTANCE FORWARDING SERVICE PROVIDER PROGRAM OFFICE OF FOREIGN ASSETS CONTROL July 2012 CIRCULAR 2012 Subject TABLE OF CONTENTS Page I. Overview 3 II. Service Provider

More information

PLEASE READ COMPLETE ALL FORMS CAREFULLY, LEGIBLY AND COMPLETELY INSURANCE IN CUBA

PLEASE READ COMPLETE ALL FORMS CAREFULLY, LEGIBLY AND COMPLETELY INSURANCE IN CUBA REGISTRATION - CUBA MISSION January 17 January 22, 2016 PLEASE READ COMPLETE ALL FORMS CAREFULLY, LEGIBLY AND COMPLETELY INSURANCE IN CUBA In case you need medical treatment, hospitals and clinics for

More information

March 1, 2011. Mr. Brian Cook Vice President Airline and Passenger Solution Line 3100 Cumberland Blvd. Atlanta, GA. 30339. Dear Mr.

March 1, 2011. Mr. Brian Cook Vice President Airline and Passenger Solution Line 3100 Cumberland Blvd. Atlanta, GA. 30339. Dear Mr. U.S. Department of Transportation Assistant Secretary ; '~', 1200 New Jersey Avenue, SE Washington, DC 20590 Office of the Secretary of Transportation March 1, 2011 Mr. Brian Cook Vice President Airline

More information

BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C. ) ) ) ) )

BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C. ) ) ) ) ) BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C. Application of DELTA AIR LINES, INC. for an exemption and frequency allocation (New York Buenos Aires Docket OST-05-21069 ANSWER OF THE PORT AUTHORITY

More information

TEXAS FAIR PLAN PRODUCER REQUIREMENTS AND PERFORMANCE STANDARDS

TEXAS FAIR PLAN PRODUCER REQUIREMENTS AND PERFORMANCE STANDARDS Producer Requirements Page 1 TEXAS FAIR PLAN PRODUCER REQUIREMENTS AND PERFORMANCE STANDARDS The following Texas FAIR Plan Association ( Association ) requirements and producer performance standards (

More information

Other Cuban Journeys

Other Cuban Journeys Other Cuban Journeys Scheduled travel dates Full name as it appears on your passport: please print clearly! Last Name: Middle Name: First Name: Address: City & State: Zip: Telephone: Home: Email Cell Phone:

More information

Terms and Conditions for signing up and/or using the Name Your Own Commission program

Terms and Conditions for signing up and/or using the Name Your Own Commission program Terms and Conditions for signing up and/or using the Name Your Own Commission program 1. Eligibility a. Membership in the Spirit Airlines, Inc. ("Spirit") Name Your Own Commission program ("NYOC") is herein

More information

Other Cuban Journeys Registration Form

Other Cuban Journeys Registration Form Other Cuban Journeys Registration Form (Application to visit Cuba) Full name as it appears on your passport: please print clearly! Last Name: Middle Name: First Name: Address: City & State: Zip: Telephone:

More information

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF TRADING AND MARKETS July 19,2012 Janet M. Angstadt, Esq. Muchin Rosenman LLP 525 W. Monroe Street Chicago, IL 60661-3693

More information

APPENDIX FOR U.S. SECURITIES TRADING

APPENDIX FOR U.S. SECURITIES TRADING APPENDIX FOR U.S. SECURITIES TRADING This Appendix applies in respect of securities trading services in U.S. Securities provided by ICBCIS to the Client. In the event that there is any inconsistency between

More information

SEC Adopts Rules on Compliance Programs for Funds & Advisers

SEC Adopts Rules on Compliance Programs for Funds & Advisers Investment Management Group Legal Update: SEC Adopts Rules on Compliance Programs for Funds & Advisers If you have questions or would like additional information on the material presented herein, please

More information

AGENCY: Federal Aviation Administration (FAA), Department of Transportation.

AGENCY: Federal Aviation Administration (FAA), Department of Transportation. This document is scheduled to be published in the Federal Register on 05/11/2016 and available online at http://federalregister.gov/a/2016-11116, and on FDsys.gov [4910-13] DEPARTMENT OF TRANSPORTATION

More information

Charter Service Agreement

Charter Service Agreement Charter Service Agreement This Charter Service Agreement ("Agreement") is effective as of the day it is executed by and between Apollo Jets, LLC, a New York limited liability company with its primary place

More information

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, DC 20549. May 14,2010

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, DC 20549. May 14,2010 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, DC 20549 DIVISION OF TRADING AND MARKETS May 14,2010 Mr. Ernest E. Badway 100 Park Avenue, Suite 1500 New York, NY 10017 Re: Grant of No-Action

More information

United States Sanctions: General Considerations for Minority Investment

United States Sanctions: General Considerations for Minority Investment United States Sanctions: General Considerations for Minority Investment BY BEHNAM DAYANIM & CAROLYN MORRIS This Stay Current provides a general overview of considerations and parameters for US minority

More information

SUBJECT: TRAVEL. This policy establishes guidelines for business travel arrangements and travel expense reimbursements.

SUBJECT: TRAVEL. This policy establishes guidelines for business travel arrangements and travel expense reimbursements. SUBJECT: TRAVEL 1.0 SCOPE This policy establishes guidelines for business travel arrangements and travel expense reimbursements. 2.0 IMPLEMENTATION This policy shall be adhered to by the staff of all Authority

More information

ICM Brokers. Introducing Broker Agreement

ICM Brokers. Introducing Broker Agreement ICM Brokers PROFILE SECTION Company name: Company address: City and country: Web address: Nature of business: Title: Mr Miss Mrs Other First name: Second name: Family name: Date of birth: (dd/mm/yy) Nationality:

More information

MEMBERSHIP, ENTERING INTO AN AGREEMENT AND RESPONSIBILITIES OF THE COMPANY

MEMBERSHIP, ENTERING INTO AN AGREEMENT AND RESPONSIBILITIES OF THE COMPANY GENERAL These terms and conditions shall apply to the Finnair Corporate Programme (hereinafter Programme ). Apart from these terms and conditions, no other rules are applicable. The Programme is designed

More information

Law Offices of David E. Wise, P.C. Attorney at Law 9901 IH-10 West, Suite 800 San Antonio, Texas 78230 (210) 558-2858.

Law Offices of David E. Wise, P.C. Attorney at Law 9901 IH-10 West, Suite 800 San Antonio, Texas 78230 (210) 558-2858. Law Offices of David E. Wise, P.C. Attorney at Law 9901 IH-10 West, Suite 800 San Antonio, Texas 78230 (210) 558-2858 December 21, 2010 Pink OTC Markets, Inc. Attn: Issuer Services 304 Hudson Street Second

More information

BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C. ) ) ) ) ) ) )

BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C. ) ) ) ) ) ) ) BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C. Application of HYPERION AVIATION LTD for an exemption pursuant to 49 U.S.C. 40109 and a foreign air carrier permit pursuant to 49 U.S.C. 41301 (EU-U.S.

More information

s TE p T O E & J O H N s 0 N LLP

s TE p T O E & J O H N s 0 N LLP s TE p T O E & J O H N s 0 N LLP ATTORNEYS AT LAW Kenneth Ewing 202.429.6264 kewing@steptoe.com 1330 Connecticut Avenue, NW Washington, DC 20036-1795 Tel 202.429.3000 Fax 202.429.3902 Steptoe.com The Honorable

More information

DOT REGULATIONS AS TO PASSENGER DELAYS AND RIGHTS, AND THEIR RAMIFICATIONS Katherine A. Staton, Esq. Partner, Jackson Walker L.L.P.

DOT REGULATIONS AS TO PASSENGER DELAYS AND RIGHTS, AND THEIR RAMIFICATIONS Katherine A. Staton, Esq. Partner, Jackson Walker L.L.P. DOT REGULATIONS AS TO PASSENGER DELAYS AND RIGHTS, AND THEIR RAMIFICATIONS Katherine A. Staton, Esq. Partner, Jackson Walker L.L.P. I. THE HISTORY BEHIND THE TARMAC DELAY REGULATIONS On April 29, 2010,

More information

P.L.2011, CHAPTER 118, approved August 19, 2011 Senate, No (Third Reprint)

P.L.2011, CHAPTER 118, approved August 19, 2011 Senate, No (Third Reprint) - C.:-. Title. Subtitle. Chapter. (New) Employee Leasing Companies. - - C.:- to :- - Note P.L.0, CHAPTER, approved August, 0 Senate, No. (Third Reprint) 0 AN ACT concerning employee leasing companies,

More information

October 1, 2015. Exemption No. 11797A Regulatory Docket No. FAA 2015 1053

October 1, 2015. Exemption No. 11797A Regulatory Docket No. FAA 2015 1053 October 1, 2015 Mr. Jeffrey J. Antonelli Counsel for Leading Edge Technologies, Inc. Antonelli Law 100 North LaSalle Street, Suite 2400 Chicago, IL 60602 Dear Mr. Antonelli: Exemption No. 11797A Regulatory

More information

June 2,2008 ?&Q-QT\~ Background

June 2,2008 ?&Q-QT\~ Background DAVIDL. LAKEY,M.D COMMISSIONER TEXAS DEPARTMENT OF STATE HEALTH SERVICES RECEIVED JUN 04 20@8 OPINION COMMITTEE June 2,2008 1100 W. 49' Street. Austin, Texas 78756 1-888-963-7111. htto:llwww.dshs.state.h.us

More information

General Counsel M~Y 2 1 2014

General Counsel M~Y 2 1 2014 U.S. Department of Transportation Office of the Secretary of Transportation General Counsel M~Y 2 1 2014 J,, '< 1200 New Jersey Ave., S.E. Washington, DC 20590 Ms. Gina Amacher Director Minnesota Department

More information

AMENDMENT NO. 1 TO OPERATING AGREEMENT FOR NON-SIGNATORY PASSENGER AIR CARRIERS FOR TAMPA INTERNATIONAL AIRPORT TAMPA, FLORIDA BY AND BETWEEN

AMENDMENT NO. 1 TO OPERATING AGREEMENT FOR NON-SIGNATORY PASSENGER AIR CARRIERS FOR TAMPA INTERNATIONAL AIRPORT TAMPA, FLORIDA BY AND BETWEEN AMENDMENT NO. 1 TO OPERATING AGREEMENT FOR NON-SIGNATORY PASSENGER AIR CARRIERS FOR TAMPA INTERNATIONAL AIRPORT TAMPA, FLORIDA BY AND BETWEEN HILLSBOROUGH COUNTY AVIATION AUTHORITY AND SHUTTLE AMERICA

More information

2009 2010 SYMPOSIUM REGISTRATION PACKET OFAC License #: CT-13006

2009 2010 SYMPOSIUM REGISTRATION PACKET OFAC License #: CT-13006 2009 2010 SYMPOSIUM REGISTRATION PACKET OFAC License #: CT-13006 **************************** DO NOT WRITE IN THIS AREA ********************************* NAME: APPLICATION STATUS: TRAVEL DATES: NOTES:

More information

KUSHILAND EXPEDITIONS & TOURS SAFARIS LTD TERMS & CONDITIONS

KUSHILAND EXPEDITIONS & TOURS SAFARIS LTD TERMS & CONDITIONS KUSHILAND EXPEDITIONS & TOURS SAFARIS LTD 1. CONTRACT TERMS & CONDITIONS Your contract is with KUSHILAND EXPEDITIONS & TOURS SAFARIS Ltd (hereinafter called KUSHILAND, we or us ). We draw your attention

More information

Cross Sound Rewards Program Terms & Conditions

Cross Sound Rewards Program Terms & Conditions Cross Sound Rewards Program Terms & Conditions General Membership Guidelines for the Cross Sound Rewards Program (the Program ) 1. Membership in the Program is open to any individual age 18 years or older,

More information

PROFESSIONAL/CONSULTING SERVICES AGREEMENT

PROFESSIONAL/CONSULTING SERVICES AGREEMENT This SERVICES AGREEMENT ( Agreement ) is entered into by and between the undersigned, ( Contractor ), (Social Security Number or Federal I.D. No.), located at and Texas Southern University ( TSU ), an

More information

UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION OFFICE OF THE SECRETARY WASHINGTON, D.C.

UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION OFFICE OF THE SECRETARY WASHINGTON, D.C. Order 2008-7-14 Served: July 14, 2008 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION OFFICE OF THE SECRETARY WASHINGTON, D.C. Ninety-day Notice of Piedmont Airlines, Inc., to terminate service at:

More information

Internal Revenue Service Number: 200422052 Release Date: 5/28/04 Index Number: 0561.05-00, 0562.03-02, 0851.00-00, 0852.01-00

Internal Revenue Service Number: 200422052 Release Date: 5/28/04 Index Number: 0561.05-00, 0562.03-02, 0851.00-00, 0852.01-00 Internal Revenue Service Number: 200422052 Release Date: 5/28/04 Index Number: 0561.05-00, 0562.03-02, 0851.00-00, 0852.01-00 ------------------------------ ----------------------------- ----------------------

More information

Chief, Property Management Division. Mandatory Training and Certification for USDA Fleet Card

Chief, Property Management Division. Mandatory Training and Certification for USDA Fleet Card United States Department of Agriculture Office of the Assistant Secretary For Administration Office of Procurement and Property Management 300 7 th Street Southwest Room 377 Reporters Building Washington,

More information

UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY OFFICE OF THE COMPTROLLER OF THE CURRENCY ) ) ) ) ) ) ) ) ) ) ) ) STIPULATION AND CONSENT ORDER

UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY OFFICE OF THE COMPTROLLER OF THE CURRENCY ) ) ) ) ) ) ) ) ) ) ) ) STIPULATION AND CONSENT ORDER UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY OFFICE OF THE COMPTROLLER OF THE CURRENCY #2005-12 In the Matter of: Chicago Title Insurance Company Settlement Agent for: Whitney National Bank New

More information

UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION In re: ) Chapter 11 ) ATA HOLDINGS CORP., and ) Case Nos. 04-19866 and 04-19874 CHICAGO EXPRESS AIRLINES, INC., ) (Jointly

More information

N.J.A.C. 6A:27, STUDENT TRANSPORTATION TABLE OF CONTENTS

N.J.A.C. 6A:27, STUDENT TRANSPORTATION TABLE OF CONTENTS N.J.A.C. 6A:27, STUDENT TRANSPORTATION TABLE OF CONTENTS SUBCHAPTER 1. GENERAL PROVISIONS 6A:27-1.1 Scope 6A:27-1.2 Purpose 6A:27-1.3 Authority 6A:27-1.4 Students who shall be transported 6A:27-1.5 Students

More information

Number: 200636085 Release Date: 9/8/2006 Internal Revenue Service. Department of the Treasury Washington, DC 20224. Index Number: 162.

Number: 200636085 Release Date: 9/8/2006 Internal Revenue Service. Department of the Treasury Washington, DC 20224. Index Number: 162. Number: 200636085 Release Date: 9/8/2006 Internal Revenue Service Index Number: 162.04-03 ---------------------------- ------------------------------------------------- ---------------------------- -----------------------

More information

Use of United States Flag Air Carriers From General Services Administration 41 CFR 301-3 and 301-10

Use of United States Flag Air Carriers From General Services Administration 41 CFR 301-3 and 301-10 Fly America Act The Fly America Act was enacted in 1974 to mandate the use of U.S. flag air carriers for federally funded international travel. Since the Fly America Act s enactment, innumerable changes

More information

Air SERBIA addendum to the IATA PSAA and ARC agreement

Air SERBIA addendum to the IATA PSAA and ARC agreement Air SERBIA addendum to the IATA PSAA and ARC agreement February, 2016 V 1.0 Your travel agency ( Agent ) has entered into the IATA Passenger Sales Agency Agreement (the IATA PSAA ) or with respect to travel

More information

December 11, 2015. CBOE Futures Exchange, LLC Rule Certification Submission Number CFE-2015-034

December 11, 2015. CBOE Futures Exchange, LLC Rule Certification Submission Number CFE-2015-034 December 11, 2015 Mr. Christopher Kirkpatrick Secretary Commodity Futures Trading Commission Three Lafayette Centre 1155 21st Street, N.W. Washington, D.C. 20581 Re: CBOE Futures Exchange, LLC Rule Certification

More information

Payment Partner (Online Bill Pay) Terms and Conditions

Payment Partner (Online Bill Pay) Terms and Conditions Payment Partner (Online Bill Pay) Terms and Conditions A. Personal Users of Payment Partner B. Small Business Users of Payment Partner Atlantic Stewardship Bank s Payment Partner Terms and Conditions are

More information

TOURISM INDUSTRY ACT 1992

TOURISM INDUSTRY ACT 1992 Travellers Outbound Terms & Conditions Fourth Schedule (Subparagraph 6(1)(m)(ii)) TOURISM INDUSTRY ACT 1992 TOURISM INDUSTRY (TOUR OPERATING BUSINESS AND TRAVEL AGENCY BUSINESS) REGULATIONS 1992 STANDARD

More information

U.S. Bankruptcy Basics

U.S. Bankruptcy Basics SHEPPARD MULLIN SHEPPARD MULLIN RICHTER & HAMPTON LLP A T T O R N E Y S A T L A W U.S. Bankruptcy Basics Sheppard, Mullin, Richter & Hampton LLP Edward H. Tillinghast, III etillinghast@sheppardmullin.com

More information

Info NEWS MEDIA GUIDE

Info NEWS MEDIA GUIDE Info Office of Public Affairs Miami-Dade Aviation Department P.O. Box 592075 Miami, Florida 33159 Phone: (305) 876-7017 Fax: (305) 869-1270 www.iflymia.com NEWS MEDIA GUIDE Table of Contents Introduction.............................

More information

HOUSE BILL No. 2087. By Committee on Insurance 1-26. AN ACT enacting the Kansas professional employer organization licensing

HOUSE BILL No. 2087. By Committee on Insurance 1-26. AN ACT enacting the Kansas professional employer organization licensing Session of 00 HOUSE BILL No. 0 By Committee on Insurance - 0 0 AN ACT enacting the Kansas professional employer organization licensing act. Be it enacted by the Legislature of the State of Kansas: Section.

More information

December 12, 2012. C.F. Muckenfuss, III Gibson, Dunn & Crutcher LLP 1050 Connecticut Avenue, N.W. Washington, DC 20036-5306

December 12, 2012. C.F. Muckenfuss, III Gibson, Dunn & Crutcher LLP 1050 Connecticut Avenue, N.W. Washington, DC 20036-5306 O Comptroller of the Currency Administrator of National Banks 250 E Street, SW Licensing Activities Washington, DC 20219 202-649-6260 December 12, 2012 C.F. Muckenfuss, III 1050 Connecticut Avenue, N.W.

More information

UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION

UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION SECURITIES ACT OF 1933 Release No. 9404 / May 22, 2013 ADMINISTRATIVE PROCEEDING File No. 3-15329 UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION In the Matter of CITY OF SOUTH MIAMI,

More information

REPORT ON LIMITED LINES INSURANCE JANUARY 15, 2014. MSAR No. 9844

REPORT ON LIMITED LINES INSURANCE JANUARY 15, 2014. MSAR No. 9844 REPORT ON LIMITED LINES INSURANCE JANUARY 15, 2014 MSAR No. 9844 For more information concerning this document, please contact: Nancy J. Egan Assistant Director of Government Relations Maryland Insurance

More information

The Atlantic Building 950 F Street, NW Washington, OC 20004-1404. 202-239-3300 Fax: 202-654-4963 www.alston.com. Direct Dial: 202-239-3463

The Atlantic Building 950 F Street, NW Washington, OC 20004-1404. 202-239-3300 Fax: 202-654-4963 www.alston.com. Direct Dial: 202-239-3463 A I S--'1ri'ON s r -1_)1) _jk_ - - & \ _ 1.11' The Atlantic Building 950 F Street, NW Washington, OC 20004-1404 202-239-3300 Fax: 202-654-4963 www.alston.com David A Brown Direct Dial: 202-239-3463 Email:

More information

MEMBERSHIP, ENTERING INTO AN AGREEMENT AND RESPONSIBILITIES OF THE COMPANY

MEMBERSHIP, ENTERING INTO AN AGREEMENT AND RESPONSIBILITIES OF THE COMPANY GENERAL These terms and conditions shall apply to the Finnair Corporate Programme (hereinafter Programme ). Apart from these terms and conditions, no other rules are applicable. The Programme is designed

More information

In re: Docket ID Number DOT-OST-2015-0013, Geographic-Based Hiring Preferences in Administering Federal Awards

In re: Docket ID Number DOT-OST-2015-0013, Geographic-Based Hiring Preferences in Administering Federal Awards May 6 th, 2015 United States Department of Transportation Docket Management Facility 1200 New Jersey Avenue S.E. W12-140 Washington, D.C. 20590-0001 In re: Docket ID Number DOT-OST-2015-0013, Geographic-Based

More information

PREPARED MANAGERS, LLC LIMITED AGENCY AGREEMENT. THIS INDEPENDENT AGENCY AGREEMENT, (this Agreement ) is made and entered into between

PREPARED MANAGERS, LLC LIMITED AGENCY AGREEMENT. THIS INDEPENDENT AGENCY AGREEMENT, (this Agreement ) is made and entered into between PREPARED MANAGERS, LLC LIMITED AGENCY AGREEMENT THIS INDEPENDENT AGENCY AGREEMENT, (this Agreement ) is made and entered into between PREPARED MANAGERS, LLC (the Company ) and (the Agent ). Prepared Managers,

More information

TERMS AND CONDITIONS

TERMS AND CONDITIONS TERMS AND CONDITIONS 1. Definitions. Buyer means the person, corporation or other entity purchasing Products from Seller. Products means all goods and materials to be provided pursuant to this Sales Acknowledgment.

More information

All references to booking engine in these Terms of Use are deemed to include reference to all bookings made through Argus Car Hire call centre.

All references to booking engine in these Terms of Use are deemed to include reference to all bookings made through Argus Car Hire call centre. Terms and Conditions IMPORTANT LEGAL NOTICE Introduction This legal notice applies to the entire contents of this booking engine. Please take some time to read these Terms and Conditions of Use ( Terms

More information

15 February 2012. Elizabeth M. Murphy Secretary Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-1090

15 February 2012. Elizabeth M. Murphy Secretary Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-1090 Elizabeth M. Murphy Secretary Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-1090 Re: Prohibitions and Restrictions on Proprietary Trading and Certain Interests in, and Relationships

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Number: 201350032 Release Date: 12/13/2013 Index Numbers: 61.53-00, 79.00-00 ----------------------- --------------------------- ---------------- Department of the Treasury Washington,

More information

Delivered electronically via www.regulations.gov

Delivered electronically via www.regulations.gov Docket Operations, M 30 U.S. Department of Transportation 1200 New Jersey Avenue, SE Room W12 140 West Building Ground Floor Washington, DC 20590 0001 Delivered electronically via www.regulations.gov RE:

More information

BROKER SALESPERSON INDEPENDENT CONTRACTOR AGREEMENT. THIS AGREEMENT is entered into this day of, 20, between ( Broker ) and ( Salesperson ).

BROKER SALESPERSON INDEPENDENT CONTRACTOR AGREEMENT. THIS AGREEMENT is entered into this day of, 20, between ( Broker ) and ( Salesperson ). BROKER SALESPERSON INDEPENDENT CONTRACTOR AGREEMENT THIS AGREEMENT is entered into this day of, 20, between ( Broker ) and ( Salesperson ). RECITALS: Broker is engaged in business as a duly licensed real

More information

Return completed applications to: APAC-Texas, Inc. P.O. Box 20779 Beaumont, TX 77720 (409) 866-1444 Phone (409) 866-5541 Fax

Return completed applications to: APAC-Texas, Inc. P.O. Box 20779 Beaumont, TX 77720 (409) 866-1444 Phone (409) 866-5541 Fax Return completed applications to: APAC-Texas, Inc. P.O. Box 20779 Beaumont, TX 77720 (409) 866-1444 Phone (409) 866-5541 Fax APPLICATION FOR BUSINESS CREDIT Date: NOTE: This application for Business Credit

More information

Safar Flyer Corporate: even more generous with corporates!

Safar Flyer Corporate: even more generous with corporates! With the Corporate program, employees earn Miles for every travel for their own account and the account of their corporation. Please fill in this form and send it to the address: safarflyercorporate@royalairmaroc.com

More information

F I R M B R O C H U R E

F I R M B R O C H U R E Part 2A of Form ADV: F I R M B R O C H U R E Dated: 03/24/2015 Contact Information: Bob Pfeifer, Chief Compliance Officer Post Office Box 2509 San Antonio, TX 78299 2509 Phone Number: (210) 220 5070 Fax

More information

CHAPTER 260. AN ACT concerning employee leasing companies. BE IT ENACTED by the Senate and General Assembly of the State of New Jersey:

CHAPTER 260. AN ACT concerning employee leasing companies. BE IT ENACTED by the Senate and General Assembly of the State of New Jersey: CHAPTER 260 AN ACT concerning employee leasing companies. BE IT ENACTED by the Senate and General Assembly of the State of New Jersey: C.34:8-67 Definitions relative to employee leasing companies. 1. For

More information

PERFORMANCE BOND INSTRUCTIONS (FEB 2015)

PERFORMANCE BOND INSTRUCTIONS (FEB 2015) PERFORMANCE BOND INSTRUCTIONS (FEB 2015) 1. Introduction a. Procurement Services Division has posted two distinct performance bond forms. One is an indemnity bond. The other is a completion bond. The nature

More information

1. Terms and Conditions

1. Terms and Conditions TRADING AGREEMENT The Trading Agreement (hereinafter referred to as the Agreement ) is made and entered into by and between Simple Trading Corporation Limited (hereinafter referred to as Simple Trade )

More information

August 23, 2002. Critical Air Medicine, Inc. Corporate Headquarters Attn: Sagi Kfir, Esq. General Counsel 4141 Kearny Villa Road San Diego, CA 92123

August 23, 2002. Critical Air Medicine, Inc. Corporate Headquarters Attn: Sagi Kfir, Esq. General Counsel 4141 Kearny Villa Road San Diego, CA 92123 August 23, 2002 Critical Air Medicine, Inc. Corporate Headquarters Attn: Sagi Kfir, Esq. General Counsel 4141 Kearny Villa Road San Diego, CA 92123 Re: City of Austin, Texas Ordinance - Cease and Desist

More information

EMPLOYERS' LIABILITY (COMPULSORY INSURANCE) (GENERAL) (JERSEY) REGULATIONS 1973

EMPLOYERS' LIABILITY (COMPULSORY INSURANCE) (GENERAL) (JERSEY) REGULATIONS 1973 EMPLOYERS' LIABILITY (COMPULSORY INSURANCE) (GENERAL) (JERSEY) REGULATIONS 1973 Revised Edition Showing the law as at 1 January 2006 This is a revised edition of the law Employers' Liability (Compulsory

More information

CHAPTER 5: TRAVEL 5.1 POLICY

CHAPTER 5: TRAVEL 5.1 POLICY CHAPTER 5: TRAVEL 1. Policy 2. Travel Authorization 3. Travel Advance 4. Allowable Expenses While In Travel Status 5. Non-Allowable Travel Expenses While in Travel Status 6. Certification and Approval

More information

2A. Investment Objective Definitions. Capital Preservation - a conservative investment strategy characterized by a desire to avoid risk of loss;

2A. Investment Objective Definitions. Capital Preservation - a conservative investment strategy characterized by a desire to avoid risk of loss; CUSTOMER ACCOUNT AGREEMENT This Customer Account Agreement (the Agreement ) sets forth the respective rights and obligations of Apex Clearing Corporation ( you or your or Apex ) and the Customer s (as

More information

BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, DC

BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, DC BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, DC Motion of AIRLINES for AMERICA (A4A REGIONAL AIRLINES ASSOCIATION (RAA Docket DOT-OST-2013- for a temporary exemption from 14 C.F.R. 259.4 MOTION

More information

Company Agreement for airline services

Company Agreement for airline services Company Agreement for airline services Between The Customer And Scandinavian Airlines System Denmark-Norway-Sweden 1 Contents 1 Company Agreement for airline services...3 1.1 Content and scope of the Agreement...3

More information

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 REPLY TO OPPOSITIONS TO PETITION FOR RECONSIDERATION

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 REPLY TO OPPOSITIONS TO PETITION FOR RECONSIDERATION Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of Implementation of Section 621(a)(1) of the Cable Communications Policy Act of 1984 as amended by the Cable Television

More information

National Stock Exchange, Inc. Waive-In Equity Trading Permit Holder Application

National Stock Exchange, Inc. Waive-In Equity Trading Permit Holder Application National Stock Exchange, Inc. Waive-In Equity Trading Permit Holder Application Equity Trading Permit Holders ( ETP Holders ) of the National Stock Exchange, Inc. ( NSX ) in good standing as of May 30,

More information

Insurance Producer Agreement

Insurance Producer Agreement Insurance Producer Agreement Section 1 - Producer s Authority The Producer shall periodically submit risks to the Company for its consideration as authorized by the Company. These risks shall be located

More information

EAGLE PARENT, INC EPICOR SOFTWARE CORPORATION ACTIVANT SOLUTIONS, INC. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY. (As Adopted - July 2011)

EAGLE PARENT, INC EPICOR SOFTWARE CORPORATION ACTIVANT SOLUTIONS, INC. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY. (As Adopted - July 2011) EAGLE PARENT, INC EPICOR SOFTWARE CORPORATION ACTIVANT SOLUTIONS, INC. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY (As Adopted - July 2011) 1.0 FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY ( FCPA

More information

Re: Hawaii Certificate of Need Program Requirements for Air Ambulance Operators

Re: Hawaii Certificate of Need Program Requirements for Air Ambulance Operators U.S. Department GENERAL COUNSEL 400 Seventh St., S.W. of Transportation Washington, D.C.20590 Office of the Secretary of Transportation Gregory S. Walden Counsel for Pacific Wings, L.L.C. Patton Boggs

More information

FEDERAL ELECTION COMMISSION Washington, DC 20463. September 15, 2000

FEDERAL ELECTION COMMISSION Washington, DC 20463. September 15, 2000 FEDERAL ELECTION COMMISSION Washington, DC 20463 September 15, 2000 CERTIFIED MAIL RETURN RECEIPT REQUESTED ADVISORY OPINION 2000-20 Brett G. Kappel Powell, Goldstein, Frazer & Murphy LLP Sixth Floor 1001

More information

Excise Tax Changes Under SAFETEA and the Energy Act; Dye Injection. This notice modifies Notice 2005-4, 2005-2 I.R.B. 289, as modified by Notice

Excise Tax Changes Under SAFETEA and the Energy Act; Dye Injection. This notice modifies Notice 2005-4, 2005-2 I.R.B. 289, as modified by Notice Part III - Administrative, Procedural, and Miscellaneous Excise Tax Changes Under SAFETEA and the Energy Act; Dye Injection Notice 2005-80 Section 1. PURPOSE This notice modifies Notice 2005-4, 2005-2

More information

Josephine Cicchetti (202) 965-8162 jc@jordenusa.com. December 22, 2005

Josephine Cicchetti (202) 965-8162 jc@jordenusa.com. December 22, 2005 1025 Thomas Jefferson Street, N.W. Suite 400 East Washington, D.C. 20007-5208 (202) 965-8100 Fax: (202) 965-8104 Josephine Cicchetti (202) 965-8162 jc@jordenusa.com 777 BRICKELL AVENUE SUITE 500 MIAMI,

More information

AUDIT REPORT AIRCRAFT AND AIR SERVICE MANAGEMENT PROGRAMS DOE/IG-0437 JANUARY 1999

AUDIT REPORT AIRCRAFT AND AIR SERVICE MANAGEMENT PROGRAMS DOE/IG-0437 JANUARY 1999 DOE/IG-0437 AUDIT REPORT AIRCRAFT AND AIR SERVICE MANAGEMENT PROGRAMS JANUARY 1999 U.S. DEPARTMENT OF ENERGY OFFICE OF INSPECTOR GENERAL OFFICE OF AUDIT SERVICES January 25, 1999 MEMORANDUM FOR THE SECRETARY

More information

*This information brochure has been issued pursuant to provisions of EC 261/2004 Regulation of the European Parliament and European Union Council.

*This information brochure has been issued pursuant to provisions of EC 261/2004 Regulation of the European Parliament and European Union Council. TURKISH AIRLINES COMPENSATION AND SERVICE SYSTEM that will provided to our Customers in case of Denied Boarding*, Flight Cancellations and Long Delays in Turkish Airlines flights departing from EU countries

More information

Decision. Prisoner Transportation Services, LLC; V1 Aviation, LLC; AAR Aircraft Services. Matter of: B-292179; B-292179.2; B-292179.3.

Decision. Prisoner Transportation Services, LLC; V1 Aviation, LLC; AAR Aircraft Services. Matter of: B-292179; B-292179.2; B-292179.3. United States General Accounting Office Washington, DC 20548 Comptroller General of the United States Decision Matter of: File: Prisoner Transportation Services, LLC; V1 Aviation, LLC; AAR Aircraft Services

More information

USAA @ February 13, 2012

USAA @ February 13, 2012 SÇ ^ USAA @ 9800 Fredericksburg Road ^nt0n ' 0, Texas 7^288 February 13, 2012 Office of the Comptroller of the Currency 250 E Street, SW Mail Stop 2-3 Washington, DC 20219 regs. comment s@occ. trecis.gov

More information

d.b.a. North State Communications First Revised Page 1 Canceling Original Page 1 INFORMATIONAL TARIFF INTERSTATE OPERATOR SERVICES

d.b.a. North State Communications First Revised Page 1 Canceling Original Page 1 INFORMATIONAL TARIFF INTERSTATE OPERATOR SERVICES d.b.a. North State Communications First Revised Page 1 Canceling Original Page 1 INFORMATIONAL TARIFF INTERSTATE OPERATOR SERVICES REGULATIONS AND SCHEDULE OF CHARGES APPLICABLE TO OPERATOR SERVICES FURNISHED

More information

MAXIMUM INDEMNITY PER COVERED PERSON

MAXIMUM INDEMNITY PER COVERED PERSON American Express Cathay Pacific Credit Card / American Express Cathay Pacific Elite Credit Card Travel Accident Insurance ACE Insurance Limited (hereinafter called the "Company") hereby certifies an American

More information

AMERICAN EXPRESS. Merchant Site Terms and Conditions

AMERICAN EXPRESS. Merchant Site Terms and Conditions AMERICAN EXPRESS Merchant Site Terms and Conditions The Merchant Site is provided by American Express Banking Corp (referred to as American Express, our, us or we ). These Merchant Site Terms and Conditions

More information

EXHIBIT B-1 INSURANCE REQUIREMENTS FOR CONSTRUCTION CONTRACTS ABOVE $30,000

EXHIBIT B-1 INSURANCE REQUIREMENTS FOR CONSTRUCTION CONTRACTS ABOVE $30,000 INSURANCE REQUIREMENTS F CONSTRUCTION CONTRACTS ABOVE $30,000 Indemnity To the fullest extent allowed by law, the Contractor shall indemnify, defend, and hold harmless the County of Santa Clara (hereinafter

More information

https://securetravel.webjet.com.au/webjettsa/default.aspx

https://securetravel.webjet.com.au/webjettsa/default.aspx Page 1 of 7 View free t Thank you for booking with Webjet Your Itinerary details are outlined below. This confirmation will also be sent by email within 24 hours. If you do not receive, please access your

More information

Cape Verde Jetaway Booking Terms and Conditions

Cape Verde Jetaway Booking Terms and Conditions Cape Verde Jetaway Booking Terms and Conditions Your contract Your holiday arrangements are booked through Cape Verde Jetaway Limited. Our registered office is at 32 Vereker Road, London, W14 9JS and our

More information

OCTOBER 23, 2013. Sincerely,

OCTOBER 23, 2013. Sincerely, OCTOBER 23, 2013 Mr. C. Milton May, Jr. Chief Operating Officer Treetop Midstream Services, LLC 602 Crescent Place Suite 100 Ridgeland, MS 39157 Re: CPF No. 2-2013-6003 Dear Mr. May: Enclosed please find

More information

COMMERCIAL GENERAL LIABILITY ENHANCEMENT ENDORSEMENT

COMMERCIAL GENERAL LIABILITY ENHANCEMENT ENDORSEMENT COMMERCIAL GENERAL LIABILITY UI GL 39 04 14 COMMERCIAL GENERAL LIABILITY ENHANCEMENT ENDORSEMENT The Commercial General Liability Enhancement Endorsement is an optional endorsement that provides coverage

More information

CREDIT REPAIR ORGANIZATIONS ACT 15 U.S.C. 1679 et. seq.

CREDIT REPAIR ORGANIZATIONS ACT 15 U.S.C. 1679 et. seq. CREDIT REPAIR ORGANIZATIONS ACT 15 U.S.C. 1679 et. seq. Please note that the information contained herein should not be construed as legal advice and is intended for informational purposes only. In addition,

More information

WEBSITE AND ONLINE PURCHASE TERMS AND CONDITIONS ( WOPTC )

WEBSITE AND ONLINE PURCHASE TERMS AND CONDITIONS ( WOPTC ) WEBSITE AND ONLINE PURCHASE TERMS AND CONDITIONS ( WOPTC ) 1. Thank you ( passenger or you or your ) for visiting Shaheenair.com which includes all services, facilities and information available or accessible

More information