BEFORE THE

UNITED STATES DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________ ___________________________ )

FRANK DRUM )

)

Complainant )

)

v. ) Docket DOT

- OST

- 2013

- 0093

)

SOUTHWEST AIRLINES CO. and )

PR IMEFLIGHT 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 Ri cks 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, 20131 BEFORE THE

UNITED STATES DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________ ___________________________ )

FRANK DRUM )

)

Complainant )

)

v. ) Docket DOT

- OST

- 2013

- 0093

)

SOUTHWEST AIRLINES CO. and )

PR IMEFLIGHT AIRLINE SERVICES )

)

Respondents )

_____________________________________ )

UNCONTESTED MOTION OF SOUTHWEST AIRLINES CO.

FOR EXTENSION OF TIME TO FILE AN ANSW ER

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

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

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

Employees Assisting Passe ngers 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 th e extension request with counsel for the Compla inant 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 th e company’s airport management at the Philadelphia2

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 document s w i l l 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 delay ing this

proceeding and is therefore in the public interest.

WHEREFORE, Southwe st 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, 20133 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

______________________________ Dorot hy C. Sauvinet