### UNITED STATES DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, D.C. 

## RECEIVED Aircraft Management Services, Inc. ) 

### APR 92015 ) 

### COMPLAINANT, ) PART 16 DOCKETS ) v. ) ) 

### DocketNo. 16-12-02 Santa Rosa County, Florida ) ) 

### RESPONDENT. )

SANTA ROSA COUNTY'S MOTION FOREXTENSION OF TIME TO RESPOND TO FAA'S DIRECTOR'S DETERMINATION 

### Respondent SantaRosa County, Florida (hereafter, the "County"), by and through its undersigned counsel, and pursuant to 14 C.P.R. §16.19, hereby files this motion for an extension oftime within which to respond to the FAA's Director's Determination, and as grounds therefor, states as follows: I. 

### Tbe FAA's Director's Determination was served by Federal Express on March 27, 2015. Pursuant to the Director's Determination and 14 C.F.R.§16.33(c), the County must submit a Corrective Action Plan or file aNotice ofAppeal and Briefwithin 30 days after the date ofservice ofthe initial determination, or by no later than April 26, 2015. 2. Due to the time required to coordinate with the FBO operators and obtain the necessary approvals from the Board ofCounty Commissioners ("Board"), which only meets twice a month after public notice of its agenda, additional time is needed to respond to the FAA's Director's Determination in a manner complying with County procedures for obtaining approval ofthe Board. It 

### is believed that a 60-day extensionuntil June 26, 2015, should allow sufficient time, consistent with County procedures, to submit a CorrectiveActionPlan or file aNotice ofAppeal and Brief. 3. Undersigned counsel certifies that counsel for Complainant has been consulted andhas consentedto the requested extension soughtbythis motion. 4. Counsel further avers that this motion is not interposed for any improper purpose, but is necessitated by the circumstances described above. Moreover, because the motion is consented, the extension, ifgranted, will not act to prejudice anyparty. WHEREFORE, based upon the foregoing good cause shown, and with the consent of Complainant, the County respectfully moves for an extension until June 26, 2015, within which to respond to the FAA's Director's Determination. DATEDthis 8th day ofApril, 2015. Respectfully submitted,

# ~--c~--- GREGORYT. STEWART Florida BarNo. 203718 WILLIAM C. GARNER FloridaBarNo. 577189 Nabors, Giblin & Nickerson, P.A. 1500 Mahan Drive, Suite 200 Post Office Box 11008 Tallahassee, Florida 32302 (850) 224-4070 (850) 224-4073 (facsimile) gstewart!alngnlaw.com bgarner(iiJngnlaw.com legal-admin(a)ngnlaw.com ROYANDREWS FloridaBarNo. 228291 County Attorney SantaRosa County 6495 Caroline Street, Suite C Milton, Florida 32570 (850) 983-1857 RoyA@santarosa.tlgov

ATTORNEYS FORRESPONDENT SANTA ROSA COUNTY, FLORIDA

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### CERTIFICATE OF SERVICE I hereby certifythat a true and correct copy ofthe foregoing has been furnished to the following persons at the following addresses by Electronic Mail and U.S. Mail orby Facsimile and U.S. Mail, as indicated below, this 8'11 day ofApril, 2015: RyanP. Hatler, Esquire Michael J. Schofield, Esquire Clark, Partington, Hart, Larry,

Bond & Stackhouse Suite 800, 125 WestRomana Street Post Office Box 13010 Pensacola, Florida 32591-3010 rhatler(illcphlaw.com mschofield@cphlaw.com 

### VIAELECTRONIC AND U.S. MAIL Docketing Clerk Federal Aviation Administration 800 Independence Avenue SW Washington, D.C. 20591 Facsimile: (202) 267-5769 

### VIAFACSIMILE AND U.S. MAIL

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