BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

) 

Victor Cherenfant, ) 

Rainer Dahm, ) 

Jean Moliere, ) 

Gloria Nejjar, ) 

James Simeon, ) 

1 

Complainants, ) 

) 

v. ) 

) 

US Airways, Inc., and ) 

Direct Airline Services, Inc., ) 

) 

Respondents. ) 

) 

Docket OST-2013-0096 

UNCONTESTED MOTION OF RESPONDENTS 

US AIRWAYS, INC. AND DIRECT AIRLINE SERVICES, INC. 

FOR EXTENSION OF ANSWER DATE 

Communications with respect to this document should be sent to: 

Mark W. Atwood 

Elizabeth J. Wadsworth 

Cozen O'Connor 

The Army and Navy Club Bldg. 

1627 I Street, N.W. 

Washington, DC 20006 

matwood@cozen.com 

Counsel for US Airways, Inc. and 

Direct Airline Services, Inc. 

May 22, 2013 

LEGAL\16562540\1 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

) 

Victor Cherenfant, ) 

Rainer Dahm, ) 

Jean Moliere, ) 

Gloria Nejjar, ) 

James Simeon, ) 

) 

Complainants, ) 

) 

v. ) 

) 

US Airways, Inc., and ) 

Direct Airline Services, Inc., ) 

) 

Respondents. ) 

) 

Docket OST-2013-0096 

UNCONTESTED MOTION OF RESPONDENTS 

US AIRWAYS, INC. AND DIRECT AIRLINE SERVICES, INC. 

FOR EXTENSION OF ANSWER DATE 

US Airways, Inc. ("US Airways") and Direct Airline Services, Inc. ("DAS"), 

Respondents in the above-cited formal complaint, request an extension of the filing date 

for their answer to this complaint under 49 C.F.R. § 302.405(a). US Airways and DAS 

request that they be given until June 22, 2013 to file their answer(s), for good cause as 

described below. 

On May 7, 2013, a representative of the Service Employees International Union 

("SEIU") filed and served a formal complaint against US Airways and DAS on behalf of 

five named employees of DAS. That company is the contractor responsible for certain 

passenger-handling services at Ft. Lauderdale-Hollywood International Airport on behalf 

LEGAL\ 16525909\1 
of US Airways as well as several other air carriers. The complaint alleged certain 

failures on the part of US Airways and DAS in training the named DAS employees in 

carrying out their duties as wheelchair attendants. 

Under § 302.405(a), answers to the complaint would be due May 22, 2013. 1It 

will not be possible, however, for the Respondents to provide a meaningful response to 

these allegations in such a short time. The Respondents take such allegations 

seriously, and have wasted no time in commencing an inquiry into their substance. This 

has involved coordinating between carrier and DAS personnel, and will necessitate 

investigating employee records, conducting interviews, as well as coordination of the 

response amongst various levels of two large organizations. US Airways and DAS 

intend to give the Department the benefit of their best efforts on this matter, and they 

believe this will require an additional 30 days. 

Counsel for Respondents has contacted the representative of the SEIU, and he 

has no objection to this extension. 

Precedent exists for granting similar extensions of time for responding to thirdparty complaints. Most recently, in February of this year, a private citizen filed formal 

complaints against American Airlines, British Airways and Cathay Pacific Airways. 2All 

three carriers requested, and were granted, extensions of approximately 30 days, for 

essentially the same reasons as Respondents cite in the instant case. 

ACCORDINGLY, US Airways and Direct Airline Services submit that they have 

shown good cause for extension of the response date in this proceeding, as requested. 

' Due dates are calculated based on the date the complaint was received. As it was sent via 

Express Mail, it was received the day after the date on which the certificate of service was 

signed. 

2Dockets OST-2013-0024, -0025 and -0027, respectively. 

2 

LEGAL\16525909\1 
Resprtfully submitted, 

Mark W. Atwood 

Elizabeth J. Wadsworth 

Cozen O'Connor 

The Army and Navy Club Bldg. 

1627 I Street, N.W. 

Washington, DC 20006 

matwoodAcozen.com Counsel for US Airways, Inc. and 

Direct Airline Services, Inc. 

May 22, 2013 

3 

LEGAL\16525909\1 
, 

CERTIFICATE OF SERVICE 

I hereby certify that on this 22 ndday of May, 2013, a copy of the foregoing 

Uncontested Motion for Extension was served via electronic mail on the parties named 

below in accordance with the Department's Rules of Practice: 

Elizabeth J. Wadsworth 

Samuel Podberesky, Esq. sam.podbereskyAdot.qov 

Aldo Muirragui AMuirraguiseiu32bj.org 

LEGAW 6562543\1