EXHIBIT H

LAW O FFICE OF J OHN MIETUS, LLC 12505 PARK POTOMAC A VE, FLOOR 6

POTOMAC, MD 20854

November 6, 2020

BY ELECTRONIC MAIL

Ms. Laura Remo Associat e Director (Fitness), Office of Aviation Analysis Mr . J erish Var ghese Transportation Industry Analyst U .S. Depart ment of Transportation 1200 New J ersey Avenue, SE vVashington, DC 20590

JOHN R. MIErus, JR. (202) 747-5212

iohn@mietuslaw.com

Re: Miami Air Int ernational, Inc., Docket OST-2020-0098 DOT Request Letter dated October 14, 2020

Dear Ms. Remo and Mr. Varghese:

By Order 2020-9-6 issued September 15, 2020, t he Department approved the transfer to Miami Air International, Inc. ("Miami Air") of the interst ate certificate held by a prior carrier wit h the same name. In the above-captioned Letter , the Departmen t requests that Miami Air answer sever al questions concerning the carrier , its owner and key personnel, and the owners and key personnel of any relevant corporations. Caribbean Sun Airlines, Inc. d/b/a World Atlantic Airlines ("WAA'') is a relevant corporation in that it is owned in common by Mr . Tomas Romero ("Romero") with Mia mi Air . For the sake of good order, vVAA's reportable matters are included in this response, thou gh t he Department indicated in its Letter that it will review matters relating to vVAA in a separat e proceeding.

PENDING CASES

The first, unnumbered question request s the "cur rent status of all pending cases," but also refers to "investigation[s], complaint[s], and action[s]." Each term relates to a different subsection in 14 C.F .R. § 204.3. Question 3 of the Letter also specifically rela t es t o charges of certain business practices or fraud, felony, or antitrust violation and thus is covered in th is section. Thus, Miami Air here is providing an updated response here, as to t he following, listed entities and individuals, to subsections (1), (m), (o), (p), and (q):

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November 6, 2020 Page 2

Miami Air Tomas Romero, owner of 100% of Miami Air and of WAA Key personnel of Miami Air, namely:

Armando Martinez, President and Director Tomas Romero, Chief Executive Officer Iraq Pacheco, Chief Financial Officer and Director Al Arias, V.P. Sales & Marketing and Director Other Key Personnel John Valentine, Director of Operations Daniel Sweitzer, Chief Pilot Nelson Gonzalez, Director of Maintenance Bruce Embree, Director of Quality Control Dustin Quiel, Director of Safety

WAA Key personnel of WAA, namely: Messrs. Romero, Pacheco, and Arias Patrick Joseph, VP/Director of Safety & Security

Other Key Personnel Richard Semon, Director of Operations Robert Muise, Chief Pilot Pedro Ruiz, Director of Maintenance Victor Gonzalez, Director of Quality Tomas Romero The Letter identified two lawsuits naming Romero as a defendant. Synovus Bank was dismissed on October 6, and Rodriguez was filed the day the Order was issued. Their status follows:

Synovus Bank v. Romero, Case 20-cv-23267 (S.D. Fla., amended complaint filed Sept. 30, 2020, dismissed Oct. 6, 2020). This case involved alleged defaults by WAA on a loan agreement, with Romero as guarantor. On August 6, 2020, the initial Synovus complaint named only Romero, who responded that WAA was a necessary party to any litigation. WAA and Romero negotiated a settlement with Synovus, and WAA paid an agreed amount. The Court then dismissed this case at the request of Synovus.

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November 6, 2020 Page 3

Amasvido Rodriguez v. Romero, Case 2020-019539-CA-01 (Fla. 11th Jud. Cir. filed Sept. 11, 2020). As background, Romero and Rodriguez co-founded the Miami Tech MRO facility that has since been sold. Today the facility is named iAero Tech and is an affiliate of Swift Air, LLC d/b/a iAero Airways, which is also iAero Tech’s major customer. Romero is of the opinion that Rodriguez refiled this litigation, which he had previously agreed to dismiss, as a reaction to Romero’s purchase of Miami Air, which will provide healthy competition for iAero Airways. The original litigation, Case 2019-015898-CA-01 (Fla. 11th Jud. Cir. filed May 23, 2019), alleged a financial interest in WAA and sought damages in excess of $3.6 million. However, the parties jointly stipulated to the lawsuit’s dismissal on April 21, 2020. No litigation was pending in this dispute when Miami Air’s July 1, 2020 transfer application (the “Application”) was filed. Romero was surprised when Rodriguez re-filed the litigation days before the Department approved Miami Air’s transfer. The new complaint, as the Department noted, alleges breach of an oral joint venture agreement and of fiduciary duty. Romero was served with notice of the present lawsuit on September 17, 2020. On October 19 Romero moved to dismiss this second lawsuit on the grounds that WAA was not included in the action and that an oral joint venture of the type alleged by Rodriguez is not enforceable under Florida law.1

A lawsuit listed in the Application was settled and dismissed with prejudice on July 14, 2020.

Luis Alberto Ramirez v. Thomas E. Romero et al., Case 2020-010525-CA-43 (Fla. 11th Jud. Cir. filed May 17, 2020). Ramirez had filed a derivative action in which Ramirez alleged that Romero acted wrongfully with respect to a company Romero does not own.

1 Florida’s Statute of Frauds, Fla. Stat. § 725.01, provides:

No action shall be brought ... upon any agreement that is not to be performed within the space of 1 year from the making thereof, ... unless the agreement or promise upon which such action shall be brought, or some note or memorandum thereof shall be in writing and signed by the party to be charged therewith or by some other person by her or him thereunto lawfully authorized.

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Romero is now a defendant in one newly-filed case:

Regions Bank v. Professional Contractors Service, Inc., Tomas Romero, Amasvido Rodriguez, and Maritza Cruz Rodriguez, Case 2020-022626-CA-01 (Fla. 11th Jud. Cir. filed Oct. 20, 2020). The complaint alleges that: Romero was one of three guarantors for a loan to the named company; after the company’s 2013 default, the parties reached a settlement requiring monthly repayments; and those repayments stopped with a payment due Jan. 6, 2016. The current amount alleged to be due is $334,816. Romero intends to answer the complaint and defend his interests.

As noted in the Application, cases against Romero and Miami Tech alleging violations of Florida’s Deceptive and Unfair Practices Act and fraud in 2015 and 2017 were dismissed. Except as listed above, Romero has no other information to report. NTSB investigations involving Miami Air and WAA The Application listed two pending NTSB investigations, one each against Miami Air and WAA. The Miami Air investigation is still pending, but a final report has since been issued in the WAA matter. Miami Air Miami Air, as an entity, has no information to report. World Atlantic Airlines World Atlantic, as an entity, has pending lawsuits to report:

TMC Engine Center, Inc. v. Caribbean Sun Airlines, Inc., Case 2020-012237-CA-01 (Fla. 11th Jud. Cir. filed June 9, 2020). The complaint alleged that WAA owes $220,280 to TMC for various engine repair services. On November 5, 2020 the parties reached a settlement agreement, and WAA expects the lawsuit to be dismissed in due course.

Passenger injury-related lawsuits against World Atlantic. On April 20, 2018,

WAA Flight 708, an MD-83, experienced a failure of the right main landing gear while landing at the Alexandria International Airport in Louisiana (the “Incident”). All passengers successfully evacuated the aircraft following the Incident, and there were no reported injuries. However, on April 17, 2019, fifteen Flight 708 passengers, consisting of thirteen private security guards, one ICE Agent, and one flight nurse (“Plaintiffs”), filed suit against World

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Atlant ic in Cameron County, Texas (the "Tort Suits"), alleging that t hey sustained back, shoulder and neck injuries as a result of the Incident . vVorld Atlant ic tendered t he Lawsuits to its insurers and is being defended wit hout reservation . World Atlant ic's insurers appointed defense counsel, are holding reserves sufficient to resolve t he pending Lawsuits, and have already reached settlements to resolve two of the Plaintiffs' Lawsuits.

World Atlantic removed the Lawsuits from Cameron County, Texas, to the Feder al District Court for the Southern District of Texas based on diversity jur isdiction. vVorld Atlantic then filed a motion to dismiss for lack of personal jur isdiction over World Atlantic in Texas. On November 2, 2020, the remaining Plaintiffs conceded t he lack of personal jurisdiction in Texas and agreed to dismissal of t heir lawsuits wit hout prejudice. The remaining Plaint iffs intend to re-file their Lawsuits against World Atlan tic in Miami, Florida. Appointed counsel for World Atlant ic will continue to defend the Lawsuits when t hey are re-filed. Settlemen t discussions as to some of t he remaining Plaintiffs remain ongoing.

Key personnel not previously a ddressed above

vV A.A's Chief Pilot has a roughly $6,000 ju dgment in favor of Capitol One Credit t hat his accountant is working to resolve.

Except as list ed above, key personnel of Miami Air and World Atlantic have no additional information to repor t.

UPDATED THIRD-PARTY VERIFICATION OF FUNDS

Question 1 of the Letter requests updated information on the funds committed by Miami Air and Romero in the Application, which stated:

To meet the Department's fin ancial fi tness test, Miami Air wi ll require a commitment of $3.9 mill ion. Miami Air itself today holds about $3.8 million in cash. Further, company owner Tomas Romero is committing up to $4.5 mill ion from his personal funds to support t he resumption of Miami Ai r service. Exhibit 10 contains his commitment letter and t hird-party verifications of Miami Air and Romero f unds available.

Attached to th is letter are updated th ird-party ver ifications for the bank account s of Romero and Miami Air (which recently changed banks) . Romero's commitment letter in Exhibit 10 remains effective. Miami Air , of course, has been incur ring some

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pre-operating expenses and paying aircraft deposits, accounting for the reduction in its cash available. Nonetheless, Romero continues to commit funding that, with amounts held by Miami Air, exceeds DOT’s calculated funding requirement of $3.9 million. As requested, Miami Air is also attaching, accompanied by a motion for confidential treatment, a Confidential Exhibit consisting of an updated, personal financial statement for Romero.

INTER-COMPANY FINANCIAL TRANSACTIONS Question 2 of the Letter requests “any inter-company financial transactions that have been made in the last six months.” Miami Air did transfer funds to support WAA during a period when the latter’s operations and revenue had declined precipitously due to the global pandemic. As the Department is aware, Romero had prefunded Miami Air with $3.8 million months before it expected to begin operations. Romero also expected to personally receive in Summer 2020 just over $3 million in escrowed funds from the 2019 sale of a non-carrier business, and he expected to contribute this to WAA if necessary. However, Romero had not yet received the funds when WAA suddenly required an unexpected amount of funding. Thus, Romero relied on Miami Air to temporarily fund WAA’s needs, knowing that his escrowed receivable could replenish Miami Air within weeks. The key Miami Air transfer to WAA was to cover amounts due from WAA to Synovus Bank. As described above, WAA had temporarily become unable to make payments on a Synovus loan, and in July Romero began negotiating with Synovus to address this issue. To prepare for a settlement, Romero therefore transferred funds from Miami Air to WAA. Synovus ultimately declared the loan defaulted and called due the entire balance. While sorting out the Synovus matter, Romero received the escrowed funds he was awaiting on August 14. Romero then contributed a further $3 million to Miami Air on August 22 to restore its fund balance. Apart from Miami Air’s temporary coverage of WAA’s loan repayment, Miami Air also transferred smaller amounts to WAA on several occasions to cover specific WAA expenses; an example might be WAA’s acquisition of a needed, costly aircraft part. WAA has been repaying Miami Air for these transfers as funds become available. Further, Romero’s top-off contribution to Miami Air has, as the third-party verification of Miami Air’s bank account indicates, maintained sufficient funding at Miami Air.

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Page 7

A monthly summary of financial transfers between Miami Air and W AA is attached. Transfers from Miami Air to W AA are marked "TRF OUT," and transfers from W AA back to Miami Air are marked "TRF IN."

NEXT STEPS

Miami Air acknowledges that the Department has deferred issuance to Miami Air of an effective, interstate air carrier certificate; its foreign certificate is in the presidential review process. Until effective authority is issued, Miami Air assures the Department that it will provide promptly any information Miami Air may undergo in areas involving fitness (i.e., management, operating plans or financial condition, compliance disposition, or ownership).

The carrier is eager to rehire over 300 former employees, acquire aircraft, and begin operations during these trying times of a global pandemic. Thus, Miami Air is committed to obtaining effective authority as expeditiously as possible and respectfully requests that the Department promptly review this response.

Respectfully submitted,

~etus,Jr. Counsel for Miami Air International, Inc.

Attachments Bank letters (CONFIDENTIAL) Romero financial statement Monthly inter-company transfer balances Certification

cc: Service list

October 21st, 2020

RE: Miami Air International, Inc. Account number ****6896 Date open: October 6, 2020

To whom it may concern,

City National Bank Bci FINANCIAL GROUP

Please be advised that Miami Air International, Inc. maintains several account relationships with our

Bank. All accounts have been handled in an excellent and professional manner.

Currently the account balance in the above referenced account is:

$3,010,000.00 USD

Should you have any questions regarding the aforementioned, please feel free to contact me directly at 954.261.1139.

Sincerely,

// ,j/r?Y',, Hugo Carreno First Vice-President

Commercial Banking Officer

PO Box 025620 Miami, FL 33102-5620 citynational .com Member FDIC I Equal Housing Lender

October 22nd, 2020

RE: Tomas Emilio Romero Account number ****4235 Date open: June 191h, 2014

To whom it may concern,

City National Bank 8ci FINANCIAL GROUP

Please be advised that Mr. Tomas Romero has been a client of our financial institution since 2013.

During this time, he has maintained several account relationships with our Bank. All accounts have been handled in an excellent and professional manner. Currently the account balances in the above referenced account is:

$4,133,617.25 USD

Should you have any questions regarding the aforementioned, please feel free to contact me directly at 954.261.1139.

Sincerely, C):/'

or;f?" Hugo Carreno First Vice-President

Commercial Banking Officer

PO Box 025620 Miami, FL 33102-5620 citynational.com Member FDIC I Equal Housing Lender

MIAMI AIR INTERNATINAL

Monthly Transfer Balances

Between MAI and WAA

Month TRF IN TRF OUT Balance

June 10000 -130000 (120,000.00)

July -3025000 (3,025,000.00)

August 255000 -85000 170,000.00

September 776000 -1322000 (546,000.00)

October 235000 -312000 (77,000.00)

(3,598,000.00)$

CERTIFICATION

The contents of the attached submission and exhibits are true and correct to the best of my knowledge and belief. Pursuant to Title 18 United States Code Section 1001, I, 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 application. I understand that an individual who is found to have violated the provisions of 18 U.S.C section 1001 shall be fined or imprisoned not more than five years, or both.

MIAMI INTERNATIONAL AIR, INC.

' By: ~ f=_(c)

ns: Owvi er.

Date: ty~v b /J.,MO,