UNITED STATES DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. RECEIVED 

Aircraft Management Services, Inc. ) APR 9 2015 

) 

COMPLAINANT, ) PART 16 DOCKETS 

) 

v. ) 

) 

DocketNo. 16-12-02 

Santa Rosa County, Florida ) 

) 

RESPONDENT. ) 

SANTA ROSA COUNTY'S MOTION FOR EXTENSION OF TIME 

TO RESPOND TO FAA'S DIRECTOR'S DETERMINATION 

Respondent Santa Rosa 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 of time 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 a Notice of Appeal and Brief within 

30 days after the date of service of the 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 of County 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 of the Board. It is believed that a 60-day extension 
until June 26, 2015, should allow sufficient time, consistent with County procedures, to 

submit a Corrective Action Plan or file a Notice of Appeal and Brief. 

3. Undersigned counsel certifies that counsel for Complainant has been 

consulted and has consented to the requested extension sought by this 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, if granted, will not act to prejudice any party. 

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. 

DATED this 8th day of April, 2015. 

Respectfully submitted, 

GREGORYT. 

~--c~--- STEWART 

Florida Bar No. 203718 

WILLIAM C. GARNER 

Florida Bar No. 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!alngnla w. com 

bgarner(iiJngnlaw.com 

legal-admin(a)ngnlaw.com 

ROY ANDREWS 

Florida Bar No. 228291 

County Attorney 

Santa Rosa County 

6495 Caroline Street, Suite C 

Milton, Florida 32570 

(850) 983-1857 

Roy A@santarosa.tl gov 

ATTORNEYS FOR RESPONDENT SANTA ROSA COUNTY, FLORIDA 

2 
CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing has been furnished to 

the following persons at the following addresses by Electronic Mail and U.S. Mail or by 

Facsimile and U.S. Mail, as indicated below, this 8'11 day of April, 2015: 

Ryan P. Hatler, Esquire 

Michael J. Schofield, Esquire 

Clark, Partington, Hart, Larry, 

Bond & Stackhouse 

Suite 800, 125 West Romana Street 

Post Office Box 13010 

Pensacola, Florida 32591-3010 

rhatler(illcphlaw.com 

mschofield@cphlaw.com 

VIA ELECTRONIC AND U.S. MAIL 

Docketing Clerk 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, D.C. 20591 

Facsimile: (202) 267-5769 

VIA FACSIMILE AND U.S. MAIL 

3