LAW OFFICE OF JOHN MIETUS, LLC

JOHN R. MIETUS, JR. (202) 747-5212 john@mietuslaw.com

9710 Traville Gateway Dr. #274 Rockville, MD 20850 (mail only)

March 9, 2021

Ms. Lauralyn Remo, Associate Director Ms. Katy O’Toole Office of Aviation Analysis, Air Carrier Fitness Division 1200 New Jersey Avenue, SE Washington DC 20590 Re: Dockets OST-2020-0041/42

Applications of Global Crossing Airlines, Inc. Dear Ms. Remo and Ms. O’Toole: By letters dated February 16 and 19, 2021, respectively, you requested additional information concerning the pending certificate applications of Global Crossing Airlines, Inc. (“GlobalX”) and a February 17 press release describing an agreement between GlobalX and Estelar Airlines of Venezuela. This is an interim response without an FAA schedule of events or complete ownership information. Fully answering questions relating to the latter requires additional material, e.g., from GlobalX’s transfer agent, that is taking some additional time to obtain. GLOBAL X WILL NOT REQUIRE SCHEDULED AUTHORITY FOR THE ESTELAR PROJECT

GlobalX’s intent is to assist Estelar in establishing Miami-Caracas/ Maracaibo service in Estelar’s name and to wet lease aircraft to Estelar for that service. Any GlobalX operations would be conducted under the DOT and FAA authority GlobalX has already requested. GlobalX does not intend to hold out or operate scheduled service in its own name at this time.

A long-term wet lease to Estelar would, of course, require a DOT statement of authorization and, under 14 C.F.R. §119.53(e), that GlobalX be “authorized under its operations specifications to conduct the same kinds of operations” as Estelar. Since one aspect of GlobalX’s business model could be wet lease service for scheduled carriers, to meet the FAA requirement it has applied to the FAA for domestic and flag operations specifications. This will give GlobalX the flexibility to operate its own charters and wet leases for charter or scheduled carriers.

DOT Fitness Division March 9, 2021

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Of course, pursuant to Order 2019-5-5 GlobalX today would receive a foreign certificate with a condition prohibiting U.S.-Venezuela air transportation. The press release addressed the parties' hopes that this policy will change. GlobalX understands that its Venezuela condition must be removed, and Estelar must receive appropriate U.S. authority, before GlobalX could operate service for Estelar. Should the current barriers to such service be removed, GlobalX’s anticipated wet lease operations would fit within the first-year operating proposal provided to DOT.

FEBRUARY 16 INFORMATION REQUEST KEY PERSONNEL

Allan McArtor was elected to the GlobalX board in January 2021 and serves as Vice Chairman. He has no information to report of the types listed in 14 C.F.R. § 204.3(l,m,o,p,q).

Mr. McArtor served as Chairman of Airbus Americas, Inc. from 2001-2018, retiring as Chairman Emeritus. Before joining Airbus he was founder, chairman, and CEO of Legend Airlines, a regional airline based at Dallas Love Field, Texas. He was appointed by President Ronald Reagan as the FAA Administrator from 1987 to 1989.

He served on the senior management team of Federal Express from 1979 to 1987 and 1989 to 1994, first as Senior Vice President Telecommunications during the development of FedEx's extensive satellite-based digital network. He returned to Federal Express as Senior Vice President Air Operations for FedEx's global airline, where he oversaw all of the airline operations including maintenance, strategic planning. and flight operations, as well as aircraft fleet acquisitions.

McArtor was an active duty Air Force officer from 1964-1979 during which he served as a combat fighter pilot, an Associate Professor of Engineering Mechanics at the Air Force Academy, and a pilot with the U.S. Air Force's Thunderbirds Aerial Demonstration Team.

He is a 1964 graduate of the U.S. Air Force Academy (BSE) where he was Cadet Wing Commander and holds a master's degree MSE from Arizona State University. In other key personnel changes: (1) Julio Berard is GlobalX’s Director of

Maintenance; Christian Toro has left GlobalX. Mr. Berard is shown on the updated February 17, 2021 PASI attached as Exhibit 19. (2) Ryan Goepel is now Executive Vice President and CFO.

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OWNERSHIP AND CITIZENSHIP Question 1 regarding ownership and citizenship requests a spreadsheet with information on GlobalX’s full complement of 6,000+ shareholders. GlobalX is preparing that spreadsheet. The following table lists the current holdings of the Wegel family and Mr. DaGrosa.

Name Relation Shares Owned % of Issued Edward Joseph Wegel Self 5,053,644 13.48% Susan A. Wegel Spouse 250,000 0.68% Alexandra H. Wegel Daughter 100,000 0.27% Kirsten Freiheit Daughter 100,000 0.27%

Joseph E. DaGrosa Jr. Self 2,960,715 8.00% Joseph E. DaGrosa Jr. TR Joba Irrevocable Trust

Trust 722,581 1.95%

Question 2 requests a list, by owner/recipient, of Restricted Share Units and Performance Share Units that have been issued. No PSUs have been issued, and a list of RSUs as of February 1, 2021 follows:

Grantee Type Date of Grant Number Vested Edward Wegel D 2020-10-28 25,000 0 Juan Nunez E 2020-10-28 25,000 0 Ryan Goepel D 2020-10-28 75,000 0 George Hambrick E 2020-10-28 25,000 0 Hector Crocker E 2020-10-28 15,000 0 Widey De Armas E 2020-10-28 15,000 0 Julio Abreu E 2020-10-28 15,000 0 Julio Berard E 2020-10-28 45,000 0 Mark Salvador E 2020-10-28 100,000 0 Edgar Green E 2020-10-28 30,000 0 David Good E 2020-10-28 20,000 0 Tracey McHale E 2020-10-28 20,000 0 Francisco Arguello E 2020-10-28 30,000 0 Steven Carbrera E 2020-10-28 20,000 0 Deborah Robinson D 2020-10-28 15,000 0 Joseph DaGrosa, Jr. D 2020-10-28 15,000 0 Alan Bird D 2020-10-28 15,000 0 Zygimantas Surintas D 2020-10-28 15,000 0 SmartLynx Airlines Malta Limited C 2020-10-28 15,000 0 Ryan Goepel D 2020-12-14 75,000 0 Marcia Tassinari E 2020-12-14 25,000 0 Lissette Rivero E 2020-12-14 10,000 0 Sheila Paine O 2020-12-14 20,000 20,000

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Olen Aasen O 2020-12-14 20,000 20,000 Lizette Hernandez E 2021-01-15 2,500 0 Luis Montiel E 2021-01-15 10,000 0 Alfredo Armas E 2021-01-15 10,000 0 Ronald Garcia E 2021-01-15 10,000 0 Haytham Ibrahim E 2021-01-15 10,000 0 Gianni Laracuente E 2021-01-15 5,000 0 Noslen Perez E 2021-01-15 5,000 0 Joanna Quintana E 2021-01-15 5,000 0 Felix Burgos E 2021-01-15 5,000 0 Marjorie Hernandez E 2021-01-15 5,000 0 Varun Nandlal E 2021-01-15 40,000 0 Alana Singh E 2021-01-15 10,000 0 Jose Gonzalez E 2021-01-15 10,000 0 812,500 40,000

In the list above, "type" denotes Company, Director, Employee, or Officer. Except as noted, 50% of the listed RSUs vest on each of the 2nd and 3rd anniversaries of the date of grant. Question 3 relates to investors Ronald Bevans and Joseph DaGrosa. Mr. Bevans actually holds his GlobalX stock personally rather than through the Wallingford Capital entity originally described. His resume is attached as Exhibit 20. JOBA Trust, which holds a portion of Mr. DaGrosa’s investment, is organized under the laws of Florida. Mr. DaGrosa is the trustee and Ms. Jessica DaGrosa, his ex-wife, is the settlor; the beneficiaries are Mr. DaGrosa and his four children, Aleck J., Benjamin M., Joseph E. (III), and Olivia L. DaGrosa All persons named are U.S. citizens.

DOT Fitness Division March 9, 2021

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FINANCIAL POSITION The Department also requests further information on GlobalX’s use of funds drawn from its GEM facility or raised through a public offering. To date, the following draws have been made on the GEM facility. Of the GlobalX shares issued, GlobalX understands that GEM today has less than 150,000 shares (0.4% of outstanding issued shares) still in their name. Information on the most recent public offerings and other stock issuances will be provided with the full shareholding information discussed above.

Date Price (CAD)

Shares Issued

Proceeds (CAD)

2020-08-26 $0.8739 473,714 413,979 2020-11-25 $0.8442 138,000 116,500 2020-12-18 $0.791 158,071 125,034 769,785 655,512 USD 485,565

Respectfully submitted,

Counsel for Global Crossing Airlines, Inc. Exhibits:

19 Revised PASI 20 Bevans resume

cc: FAA South Florida CMO

Mr. David Lusk Mr. Vincent Rossi

Law Offices Ronald T. Bevans, Jr., P.A.

1221 Brickell Avenue Suite 2660

Miami, Florida 33131

rtbevans@bevanslaw.com

General

Mr. Bevans is an attorney with over thirty-five years of legal experience

with a practice devoted primarily to transactions and civil litigation in the field

of commercial aviation. Representation has included firms and individuals

engaged in the sale, lease, purchase, overhaul and repair of commercial

transport category aircraft and engines, airlines in the U.S., Latin America, Africa

and the Middle East, MROs and parts suppliers, engine shops and financiers,

lessees and brokers of aircraft leases and sales.

Mr. Bevans has litigated in State and Federal Courts as well as before the

International Chamber of Commerce, International Court of Arbitration in

commercial aviation disputes for clients in the U.S., the Middle East and Europe.

Achievements include a multi-million award and recovery for the U.S.-based

lessor of the first Boeing commercial transport aircraft leased into the Republic

of Kazakhstan and a million-dollar award and recovery against the airline

purchaser of a client’s aircraft in the United Arab Emirates.

Aviation Business Experience:

Mr. Bevans has been part-owner of an FAA-certificated Part 135 air taxi

operator and of an FAA-certificated Part 145 engine repair station providing

hospital repair shop service and field service both located in South Florida. He

currently is a partner in an FAA-certificated Part 145 avionics repair and

modification shop. Mr. Bevans and other partners also have been active in the

purchase and sale of commercial transport category aircraft and engines.

Global Crossing AirlinesExhibit 20(2 pages)

Ronald T. Bevans, Jr. CV January 2021

2

Other Positions & Experience:

Orion Telecommunications Corp., Bayside NY – Associate Counsel

Champion Air, Minneapolis MN - Counsel

Pan American World Airways (II), Miami – Assoc. General Counsel

Eastern Air Lines, Inc., Miami – Director, Legal Affairs

Spilman, Thomas & Battle - Associate (Labor/Commercial Litigation)

Education/Professional Associations:

Mr. Bevans is a long-time member of the International Society of Transport

Aircraft Traders (ISTAT), the Air and Space Law Section of the American Bar

Association and the Greater Miami Aviation Association. He graduated from the

School of Law (J.D.) of Washington & Lee University and holds a B.A. from

Indiana University of Pennsylvania.