RECEIVED 

U.S. DEPARTMENT OF TRANSPORTATION JAN 0 9 2017 

OFFICE OF HEARINGS 

WASHINGTON, D.C. HEARING DOCf<ET 

In the matter of: 

PUERTO RICO POLICE DEPT. 

Respondent 

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FAA Docket No. FAA-2013-1086 

Case No. 2011S0190181 

Judge J.E. Sullivan 

RESPONSE TO MOTION REOUESTING EXTENSION OF TIME 

As described in the FAA's Motion to Compel, the Respondent did not timely respond to 

the FAA's November 1, 2016 discovery requests and did not respond to the FAA's December 

15, 2016 attempt to contact Responde!!! about the lack of a response. After the FAA placed its 

Motion to Compel in the mail on December 20, 2016, the FAA received from Respondent a 

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Motion Requesting Extension of Tirn'e. 1 Respondent's reque~t for an extension' of tiine appears 

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moot. To the extent that it is not moot, the FAA opposes iuiy funher extension. . .. 

Respondent's Motion Requesting an Extension of Time was, based on the December 7, 

2016, signature date on the document, sought an extension of 20 days from the original due date 

of the discovery responses (from December 9, 2016 to December 29, 2016). If the Motion is 

taken as requesting a 20-day extension from the mailing date of the Motion, then an additional 

20 days would extend the due date to January 5, 2017. Given that a motion conference on this 

subject is scheduled for January 11, 2017, Respondent's request for an extension of time appears 

moot. 

To the extent that Respondent's request istitk:en to encompass any period of time after 

January 11, 2017 in lieu of granting the FAA's Motion to' COin pel, the FAA opposes that reque'st. 

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1 Although the Certificate of Service on the Motion Requesting Extension of Rime is dated on December 7, 2016, 

the copy received by the FAA was postmarked December 16, 2016. 

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As evidenced by the December 7, 2016 signature date on its request for extension of time, 

Respondent was aware as of that date that it was not going to be able to timely respond to the 

FAA's discovery requests. However, Respondent did not at that time contact the FAA or the 

court to address the situation. Nor did Respondent respond to the FAA when contacted about its 

failure to timely respond to the FAA's discovery requests. Respondent has provided no 

explanation of what information needs to be compiled or verified for it to respond to the FAA's 

discovery request, see Motion Requesting Extension of Time ~ 2, or an explanation of why this 

information still needs to be gathered and verified more than two years after the commencement 

of this litigation. Further, even if Respondent legitimately cannot respond to some discovery 

requests, Respondent has provided no explanation for why it has provided no response to any 

discovery request. While the FAA acknowledges that, if the Judge grants the FAA's motion to 

compel, that grant will necessarily come with some additional time for the Respondent to 

respond, such additional time should be minimal and should come only under an order 

compelling compliance, rather than as part of a distinct extension of time (to possibly be 

followed by a renewed motion to compel). 

Respectfully submitted this 3rd day of January, 2017, 

CHRISTOPHER R. S VENSON 

Attorney 

Office of the Chief Counsel, Enforcement Division 

1701 Colmnbia Avenue, College Park, GA 30337 

email: chris.stevenson@faa.gov 

Telephone: ( 404) 305-5200 (main) 

(404) 305-5208 (direct) 

(404) 305-5223 (facsimile) 

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CERTIFICATE OF SERVICE 

I hereby certify ihat on this date, I have sent by U.S. Certified Mail- return receipt 

requested and facsimile, a copy of ihe foregoing Response to Motion for Extension of Time in 

the matter of Puerto Rico Police Department, FAA Docket No. FAA-2013-1086, Case No. 

2011S0190181, to: 

Nazihra M. Abdulrahrnan Soler 

Office of Legal Affairs 

Puerto Rico Police Department 

P.O. Box 71200 

San Juan, PR 00936 

fax: (787) 781-7993 

The Honorable J.E. Sullivan 

Office of Hearings, M-20 

U.S. Department of Transportation 

(one copy via certified mail and one facsimile) 

1200 New Jersey Avenue, S.E. (Ell-310) 

Washington, D.C. 20590 

fax: (202) 366-7536 

In addition, I hereby certify that on this date, I have sent by U.S. Certified Mail- return 

receipt requested, the original and one copy of the foregoing document to: 

Hearing Docket 

Federal Aviation Administration 

800 Independence A venue, SW 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2Wl 000 

r{.uu:.~ ~~RALDJENN GS 

Program Analyst 

lJA_M: ::.: 4 2017 

Date: 

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