UNITED STATES DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. 

Venice Jet Center, LLC, ) 

) 

Complainant, ) C 5 

) FAA Docket No. 16-09-05 o 

) 

) ~Q 

City of Venice, Florida, ) 

) 

Respondent. ) 

) 

NOTICE OF EXTENSION OF TIME 

On July 6, 2009, Venice Jet Center, LLC, ("VJC") filed a Complaint in the abovecaptioned matter. On July 10, 2009, the Federal Aviation Administration (FAA) 

docketed the instant complaint and issued a Notice requesting that an Answer be filed 

within twenty (20) days or on August 3, 2009. On July 23, 2009, Counsel for Respondent 

City of Venice, Florida, ("Venice"), submitted a Motion for Extension of Time to File 

Answer for Sixty (60) days. Respondent contends that its initial review of the complaint 

and its exhibits which total 240 pages require a significant amount of time to analyze and 

answer and that counsel was recently retained in this matter. 

On July 27, 2009, Complainant VJC submitted its opposition to a request to the City's 

request. However, Complainant states that it does not oppose a 30-day extension. 

Complainant's opposition to 60 days was based on its contention that, if granted. 

Respondent's Motion would significantly prejudice the VJC (and other non-parties) 

which is currently in federal receivership and that Respondent did not establish adequate 

ground(s) for the extension. The Motion fiirther provides that Respondent was served a 

courtesy copy of the Complaint in early July 2009 and has therefore been aware about the 

allegations contained in the Complaint. 

FAA typically seeks concurrence from both sides when an extension request for 

submission of pleadings is under consideration. However, the parties are not in 

agreement here. Although Part 16 is intended to expedite substantially the handling and 

disposition of airport-related complaints, the regulation provides that an extension of time 

may be granted where necessary or appropriate for a fair and complete hearing of the 

matters before the Agency. 
The Agency hereby grants a 30-day extension, rather than a 60-day extension, for the 

following reasons: 

In consideration of the pleadings and the Complaint, while this Part 16 case presents 

some issues which are more complicated than the typical Part 16 case, the VJC is in 

federal receivership in SEC v. Arthur Nadal et al. Case No. 8:09-cv-87-T-26TBM )(M.D. 

Fla.). A 60-day extension could arguably prejudice the VJC (and non-parties) in its 

proceeding to obtain fiinds on behalf of VJC and non-parties who were defrauded out of 

hundreds of millions of dollars by VJC's previous owner. 

The Agency also finds that a 60-day extension is not warranted since Respondent appears 

to have been aware of the allegations contained in the Complaint for a considerable 

amount of time. In its Opposition, Complainant contends that Respondent is fully aware 

of the issues raised in the complaint and was put on notice about the allegations in the 

complaint as Complainant's counsel provided a courtesy copy of the complaint on or 

about July 1, 2009. The complaint was filed on July 10,2009. It is also clear that 

Counsel for the Respondent has been familiar with the dispute between the parties since 

December 23, 2008 when it provided a v^ritten legal opinion to the City of Venice. 

Finally, Counsel for the Complainant agrees to a 30-day extension. 

Based on all of the above reasons, the Agency grants a 30-day extension of time to 

Respondent to file an Answer. 

Please contact me at (202) 267-3211 with any additional questions or concerns. 

Elizabeth hU&etQ CJ ^ T 

Senior Attorney 

Airports & Environmental Law Division 

Federal Aviation Administration 

Washington, D.C. 20591 

Elizabeth.Head@faa.gov 
CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on August 3,2009,1 caused to be placed in the United States 

mail (first class, postage paid) and delivered a true copy of the foregoing document 

address to: 

Gianluca Morello, Esq 

Dominique Pearlman, Esq. 

Counsel for Complainant 

Fowler White Boggs PA 

501 E. Kennedy Blvd. 

Suite 1700 

Tampa FL 33602 

(via telecoper no. 813-229-8313) 

Robert C. Anderson, Esq. 

City Attorney 

Hall & Anderson, P.A. 

1314 East Venice Avenue, Suite E 

Venice, Florida 34285 

Thomas R. Devine, Esq. 

Counsel for Respondent 

Kaplan Kirsch & Rockwell, LLP 

1001 Connecticut Ave., NW 

Suite 800 

Washington, D.C. 20036 

(via telecopier no. 202 955-5616 

Peter J. Kirsch, Esq. 

Kaplan Kirsch & Rockwell LLP 

1675 Broadway, Suite 2300 

Denver, Colorado 80202 

Arthur P. Berg 

Kaplan Kirsch & Rockwell LLP 

641 Lexington Avenue, Suite 1409 

New York, New York 10022 

ACO-lOO 

FAA Part 16 Airport Proceedings Docket (AGC-610) 

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