BEFORE THE

UNITED STATES DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_____________________________________

)

FRANK DRUM )

)

Complainant )

)

v. ) Docket DOT-OST-2013-0093

)

SOUTHWEST AIRLINES CO. and )

PRIMEFLIGHT AIRLINE SERVICES )

)

Respondents )

_____________________________________ )

UNCONTESTED MOTION OF SOUTHWEST AIRLINES CO.

FOR EXTENSION OF TIME TO FILE AN ANSWER

Communications with respect to this 

document should be sent to:

Ron Ricks Robert W. Kneisley

 Executive Vice President and Associate General Counsel

 Chief Legal & Regulatory Officer Leslie C. Abbott

Mark Shaw Senior Attorney

 Vice President General Counsel Southwest Airlines Co.

 and Corporate Secretary 1901 L Street, NW, Suite 640

Southwest Airlines Co. Washington, DC 20036

2702 Love Field Drive (202) 263-6284

Dallas, TX 75235-1611 bob.kneisley@wnco.com

leslie.abbott@wnco.com

May 20, 2013
1

BEFORE THE

UNITED STATES DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_____________________________________

)

FRANK DRUM )

)

Complainant )

)

v. ) Docket DOT-OST-2013-0093

)

SOUTHWEST AIRLINES CO. and )

PRIMEFLIGHT AIRLINE SERVICES )

)

Respondents )

_____________________________________ )

UNCONTESTED MOTION OF SOUTHWEST AIRLINES CO.

FOR EXTENSION OF TIME TO FILE AN ANSWER

Pursuant to Rule 405 of the Department’s Rules of Practice, Respondent 

Southwest Airlines Co. (“Southwest”), hereby requests a three week extension of 

time until June 12, 2013 to file its answer to the Complaint of Contractor 

Employees Assisting Passengers of Southwest Airlines at Philadelphia 

International Airport filed by the Service Employees International Union (“SEIU”) 

on behalf of Frank Drum (“the Complainant”) on May 7, 2013. Southwest 

discussed the extension request with counsel for the Complainant on May 17, 

2013 and was advised that the Complainant consented to this motion. 

Southwest submits that good cause exists to grant this uncontested 

extension request. As outlined below, Southwest requires additional time to 

research and respond to the allegations alleged by the Complainant. 

Specifically, Southwest legal and customer advocacy personnel will need to 

coordinate with the company’s airport management at the Philadelphia 
2

International Airport (“PHL”) and review documents provided by PrimeFlight 

Aviation Services (“PrimeFlight”), for its answer. In addition, Southwest may 

deem it necessary to produce employee or contractor affidavits in support of its 

answer. Preparing these documents will require additional time and 

coordination.

Granting this uncontested motion will allow Southwest to provide the 

Department with a comprehensive answer that will ensure that the record in this 

matter is both factually accurate and fully developed. The extension will thereby

facilitate the Department’s decision making without materially delaying this 

proceeding and is therefore in the public interest.

WHEREFORE, Southwest requests that the Department grant it an 

extension of time until June 12, 2013 to file its answer in this proceeding.

Respectfully submitted,

 _________________________

 Leslie C. Abbott

May 20, 2013
3

CERTIFICATE OF SERVICE

I hereby certify that on May 20, 2013, a copy of the foregoing was served 

via e-mail on the following persons:

Sam.podberesky@dot.gov

Blane.workie@dot.gov

Conor.hanlon@seiu.org

______________________________

Dorothy C. Sauvinet