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(Exempt from Filing Fees 

Pursuant to Govt. Code § 6103) 

PAMELA J. WALLS, County Counsel (SBN 123446) 

DANA M. SMITH, Deputy County Counsel (SBN 172386) 

3535 Tenth Street, Suite 300 

Riverside, CA 92501-3674 

Telephone: (951)955-6300 

Facsimile: (951)955-6363 

Attorneys for County of Riverside 

UNITED STATES DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. 

ORANGE COUNTY SOARING 

ASSOCIATION, MARY RUST, LARRY 

TOUHINO and CHRIS MANNION, 

Complainants, 

THE COUNTY OF RIVERSIDE 

Respondents. 

Docket No. 16-09-13 

NOTICE OF MOTION AND MOTION FOR 

EXTENSION OF TIME TO FILE RESONSE TO 

COMPLAINT, DECLARATION OF PAMELA 

J. WALLS 

—-1 

TO THE FEDERAL AVIATION ADMINISTRATION AND TO ALL PARTIES ANE^HEIR 

ATTORNEYS OF RECORD: : ; § 

Please take notice that Respondent, County of Riverside, hereby submits this Notice of Motion 

and Motion for Extension of Time to File Response to Complaint pursuant to 14 C.F.R. 16.19. 

I. 

RESPONDENT'S COUNSEL REQUESTS ADDITIONAL 

TIME DUE TO AN OFFICE RELOCATION 

On November 2, 2009, Respondent's counsel received notice from the U.S. Department of 

Transportation, Federal Aviation Administration, that a complaint had been filed against it and that a 

responsive pleading would be due within 20 days of the date of the service of the notice, that date being 

November 16, 2009. 

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NOTICE OF MOTION AND MOTION FOR EXTENSION OF TIME TO FILE ANSWER TO COMPLAINT 
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The Riverside County Counsel's Office, counsel for Respondent, is in the midst of a complete 

relocation of its office. The office is being moved starting the evening of November 5, 2009. 

Additionally, due to mandatory furloughs the office is also closed every other Friday. As a result. 

Respondent is requesting a 15 day extension of time, up to and including December 1, 2009, to file a 

responsive pleading. 

II. 

COMPLAINT ANTS' ATTORNEY HAS AGREED TO THE EXTENSION 

On November 5, 2009, the attorney for the Complainants was contacted regarding an extension to 

file a responsive pleading. Ronald J. Cozad, attorney for Complainants, agreed to a 15 day extension of 

time. See Declaration of Pamela J. Walls attached hereto. 

HI. 

CONCLUSION 

The respondent has shown good cause for this request and has also obtained the consent of the 

attorney of record for the comiplainants. 

Therefore, it is respectfully requested that the request for extension of time be granted and that 

Respondent be granted up to and including December 1, 2009, to file a responsive pleading in this matter. 

PAMELA J. WALLS 

County Coimsel 

Dated: November 5. 2009 

DANA M. SMITH 

Deputy County Counsel 

Attorneys for County of Riverside 

DMS/hms 

November 5, 2009 

G;\Property\DMSmith\CASES\FAA\Motion for Extension.doc 

NOTICE OF MOTION AND MOTION FOR EXTENSION OF TIME TO FILE ANSWER TO COMPLAINT 
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ORDER 

Good cause having been shown. Respondent, County of Riverside, is hereby granted an extension 

of time up to and including December 1, 2009, to file a responsive pleading in this matter. 

IT IS SO ORDERED: 

Dated: 

NOTICE OF MOTION AND MOTION FOR EXTENSION OF TIME TO FILE ANSWER TO COMPLAINT 
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CERTIFICATE OF SERVICE 

I hereby certify that I have this day served the foregoing Notice of Motion and Motion for 

Extension of Time to File Answer to Complaint and Orderon the following persons at the following 

addresses by United States Postal Servce: 

Ronald J. Cozad, Esq. 

Law Offices of Ronald J. Cozad 

2100 Palomar Airport Road, Suite 214 

Carlsbad, CA 92011 

Colby Cataldi 

Assistant Director Aviation 

3403 Tenth Street, Suite 300 

Riverside, CA 92501 

Daryl Shippy 

Airports Manager 

37552 Winchester Road 

Murrieta CA 92563 

Sharice Jefferson 

Federal Aviation Administration 

Office of the Chief Counsel 

Attn: FAA Part 16 Airport Proceedings Docket 

AGC-610, Room 925 

800 Independence Ave., SW 

Washington DC 20591 

^{iUyJ'^y /ytmlw. 

Helen M. Sheehan 

NOTICE OF MOTION AND MOTION FOR EXTENSION OF TIME TO FILE ANSWER TO COMPLAINT