Apr 14 2010 3:31PM JMRfl G01G643597 p.l 

Larry L. Davis 

1412 Fourth Ave. 

Jackson, MS 39023 

(601) 212-0297 

davisl3030@hotmail.com 

April 12.2010 

Office of the Chief Counsel 

FAA Part 16 Airport Proceedings Docket, AGC-61 0 

Room 925 -" \- 0 

Federal Aviation Administration j c-;cr§' 

800 Independence Avenue, S.W. .. ^ 

Washington, DC 20591 o & 

Attention: Part 16 Docket Clerk 

Re: Larry L. Davis vs. Jackson Municipal Airport Authority 

FAA Docket No. 16-10-01 

Concerned; 

Enclosed are an original and three (3] copies of a Motion to Deny Extension Of 

Time to File an Answer to Complaint (the "Motion"), which was filed in the above 

referenced matter on behalf of the Jackson Municipal Airport Authority (the 

'Authority"). The Motion includes a Certificate of Service indicating concurrent 

sen/ice of the Motion on the Respondent's Counsel and the FAA. As requested 

in the Notice of the filing of the Complaint received by the me on March 18, 

2010, one copy of the Motion is unbound. 

Sincere 

t^ 

Lorry L, Davis 
Apr 14 2010 3:32PM JMRR G016G43597 p.2 

April 14, 2010 

Page 2 

Enclosures 

Cc: Alan L. Moore (Personal Delivery) 

Baker Donelson Bearman Caldwell & Berkowitz, PC 

4268 1-55 North 

Meadowbrook Office Park 

Jackson, Mississippi 39211 

Post Office Box 14167 

Jackson, Mississippi 39236 

Raymond Veatch 

Senior Attorney 

Airports Law Brach, AGC-610 

Office of the Chief Counsel 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, DC 20591 

Sharice Jefferson 

Legal Assistance 

Airports & Environnnental Law Division 

Office of the Chief Counsel 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, DC 20591 
Hpr 14 2010 3:32P M JMRR G01GG43597 p. 3 

UNITED STATES DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. 

Larry L. Davis COMPLAINANT 

vs. Docket NO. 16-10-01 

Jackson Municipal Airport Authority RESPONDENT 

COMPLAINANT 'S MOTION TO DENY RESPONDENT COUNSEL'S MOTION FOR EXTENSION OF 

TIME TO FILE AN ANSWER TO COMPLAINT 

I Larry L. Davis the Connplainant, respectfully oppose the Respondents' motion for on 

additional thirty (30) days' to file their Answer to the Complaint in the above referenced 

matter. Respondents have not offered good cause for extending the time to respond 

to the Complaint. The Respondents simply state that they hove to prepare its answer, 

inten/iew four senior staff members and conduct relevant research. This should have 

been noted and commonly understood by the Respondents Counsel on March 7, 2010, 

the date of notice of service served upon the Respondents by the Complainant. 

1. The Respondents received notice of filing of the complaint in this matter from the 

Federal Aviation Administration ("FAA") on March 23, 2010, by L).S. Mail. I the 

complainant, duly served an original and a true and correct electronic copy of the 

above referenced complaint to Mr. Dirk B. Vanderleest Chief Executive Office and 

Mr. George E. Irvin, %^.. Chairman of the Board of Commissioners, Jackson Municipal 

Airport Authority, on March 2, 2010 in compliance with 14 CFR 16 Part 15(a). 

My understanding from the notice of filing of the complaint letter received from FAA 

and signed by Raymond Veatch, Attorney and Sharice Jefferson, Airport and 

Environment Law Division of the Office of Chief Council dated March 18, 2010 

required the named Respondents to file and answer within twenty days of the dote 

of service of the Notice...which was March 18, 2010, in compliance with 14 CFR 16 

Part 23[d]. The notice did not state within 20 days of the postmark, twenty working 

days or within twenty days of receive. It clearly states within twenty days of the 

date of service. 

The certificate of service date (found on page 2 of the letter of notice) is March 18, 

2010. Therefore the last date to file would have been April 7, 2010. Additionally, as 

provided in 14 CFR 16.17(c) allowing three days for mail delivery, the named 

respondents was required to file and answer by April 10, 2010. Providing that April 

10, 2010 was a Saturday, the filing was due the following Monday April 12, 2010, the 

date the Respondents Counsel filed Motion for Extension. Therefore the 

Complainant contents that the Motion for Extension of Time was untimely filed. 
Rpr 14 2010 3:32PM JMRR G01GG43597 p.4 

2. The Respondents state "in order to prepare its Answer, the Respondent must 

assemble and review numerous documents and inten/iew at least four senior 

members of the Respondent's staff, as well as conduct relevant legal research." 

The Complainant contents that legal Council representing the Respondents hove 

been engaged by the Respondents for well over fifteen years. The same legal 

Counsel advises the Respondents on all internal and external policy and legal 

matters, on a daily basis. This Counsel attends all Respondent Board of 

Commissioners meetings and provides Council to both the Administrative body ond 

the Board of Commissioners on all matters. This Counsel has first hand and intimate 

knowledge of all policies...proposed or implemented by the Respondents over the 

period in question. 

This Counsel interacts with the Senior Staff of the Respondent's operation on a daily 

basis...no assembly of personnel is required. All DBE goals advertised to the general 

public on behalf of the Respondent are posted through this Counsel's office. All the 

Respondents contracts containing DBE goals were and are written by this Counsel. 

What research do they have to do? When the Respondents set DBE goals on 

contracts they should hove already performed the due diligence required to justify 

these goals; this information should be readily available for public review and 

comment. 49 CFR Par 26 § 26.45 & § 26.51. They either have the documents or they 

do not...it is all pasted tensed, v/hat research is required? All federal grants applied 

for and processed by the Respondent come from and go through the offices of this 

same Counsel. 

Respondents hove not offered good cause for extending the time to respond to the 

Complaint. Moreover, the filing of the Motion for Extension was untimely. Thus, I the 

Complainant respectfully request that Respondents' Counsel's Motion to Extend 

Respondents' Time to Answer the Complaint be denied. 

All communications with respect to this complaint should be addressed to: Lorry L. 

Davis, 1412 Fourth Ave., Jacl<son, MS 30203, (601) 212-0297, daYlsl3030@hotmall.com. 

Respectfully submitted, 

Lany L. Davis 

Complainant 
Rpr 14 2010 3:32P M JMRR G01GG43597 p. 5 

CERTIFICATE OF SERVICE 

I hereby certify that I have this day served the foregoing Motion for Denial of Extension of Time 

to File an Answer to Complaint on the following persons at the following addresses by the 

methods of service indicated: 

Alan L. Moore (Personal Delivery) 

Baker Donelson Bearman Caldwell & Berkowitz, PC 

4268 1-55 North 

Meadowbrook Office Park 

Jackson, Mississippi 39211 

Post Office Box 14167 

Jackson, Mississippi 39236 

Office of the Chief Counsel (Facsimile 202-267-5769 & Mail Delivery by U.S. Mail) 

FAA Part 16 Airport Proceedings Docket, AGC-6JO 

Room 925 

Office of the Chief Counsel 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, DC 20591 

This, the 14th day of April, 2010. 

Larry L. Davis 

Complainant