BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

) 

Frank Drum, ) 

) 

Complainant, ) 

) 

v. ) 

) 

Southwest Airlines Co., and ) 

PrimeFlight Airline Services, ) 

) 

Respondents. ) 

) 

Docket OST-2013-0093 

UNCONTESTED MOTION OF RESPONDENT 

PRIMEFLIGHT 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 

Primeflight Airline Services 

May 31, 2013 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

) 

Frank Drum, ) 

) 

Complainant, ) 

) 

v. ) 

) 

Southwest Airlines Co., and ) 

PrimeFlight Airline Services, ) 

) 

Respondents. ) 

) 

Docket OST-2013-0093 

UNCONTESTED MOTION OF RESPONDENT 

PRIMEFLIGHT AIRLINE SERVICES, INC. 

FOR EXTENSION OF ANSWER DATE 

PrimeFlight Airline Services, Inc. ("PrimeFlighr), a Respondent in the abovecited formal complaint, requests an extension of the filing date for its answer to this 

complaint under 49 C.F.R. § 302.405(a). PrimeFlight requests that it be given until June 

20, 2013, to file its answer, for good cause as described below. 

On May 2, 2013, a representative of the Service Employees International Union 

("SEIU") filed and served a formal complaint against Southwest Airlines Co. 

("Southwest") and PrimeFlight on behalf of Frank Drum, an employee of PrimeFlight. 

That company is the contractor responsible for certain passenger-handling services at 

Philadelphia International Airport ("PHL") on behalf of Southwest as well as several 

other air carriers. The complaint alleges certain failures on the part of Southwest and 

PrimeFlight in training Mr. Drum in carrying out his duties as a wheelchair attendant. 
Under Section 302.405(a), PrimeFlight's answer to the complaint was due on 

May 20, 2013. 1Because PrimeFlight was named as a respondent in two additional 

DOT complaints filed by the SEIU on behalf of several other PrimeFlight employees at 

PHL, 2and only recently was able to obtain counsel in this matter, PrimeFlight was 

unable to respond to the Complaint by the May 20, 2013, deadline. Given the 

extraordinary nature of facing three complaints filed with the Department at the same 

time, PrimeFlight respectfully suggests that good cause existed for its delay in 

responding. 

Additionally, due to the number of SEIU complaints that it is facing, PrimeFlight 

requests that it be granted an extension until June 20, 2013, to file an answer in this 

matter. This deadline will correspond with the extension date granted to PrimeFlight 

and US Airways in the SEIU's complaint on behalf of other PrimeFlight employees at 

PHL, as well as the June 20, 2013, response date requested by PrimeFlight in its 

pending motion to extend the answer date in OST-2013-0092 (which also concerns 

PrimeFlight's operations at PHL). As stated in its extension request in each of these 

proceedings, PrimeFlight simply cannot provide a meaningful response to the 

allegations without this additional time. It will need to coordinate between Southwest's 

personnel and its own employees in framing its answer to the complaint, which will 

require investigating employee records, conducting interviews, and coordinating 

responses amongst various levels of two large organizations. PrimeFlight intends to 

1Due 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. 

2See OST-2013-0091, Onetha McKnight, et al. v. US Airways and PrimeFlight at PHL, and 

OST-2013-0092, Kyla Thorington, et al. v. United Airlines and PrimeFlight at PHL. 

2 
give the Department the benefit of its best efforts on this matter, and believes it will be in 

a position to do so by June 20, 2013. 

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

has no objection to this extension. Additionally, precedent exists for granting this 

extension, since the Department to-date has granted all motions to extend the response 

time in those SEIU proceedings where requested. 3 

ACCORDINGLY, PrimeFlight Airline Services submits that it has shown good 

cause for its failure to file a response by the initial May 17, 2013, answer deadline, as 

well as good cause for an extension of this response date to June 20, 2013. 

Respectfully submitted, 

A , 09/P 

Mark W. Atwood 

e AA 

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 

PrimeFlight Airline Services 

May 31, 2013 

3See Notice dated May 20, 2013, in OST-2-13-0091 granting US Airways and PrimeFlight an extension 

until June 20, 2013 to respond to the complaint; Notice dated May 20, 2013, in OST-2013-0092, granting 

United Airlines an extension until May 31, 2013; Notice dated May 21, 2013, in OST-2013-0093, granting 

Southwest Airlines an extension to June 12, 2013; Notice dated May 23, 2013, in OST-2013-0096, 

granting US Airways and Direct Airline Services until June 22, 2013; and Notice dated May 22, 2013, in 

OST 2013-0097, granting Spirit Airlines and Direct Airline Services an extension to June 5, 2013. 

3 
CERTIFICATE OF SERVICE 

I hereby certify that on this 31st day 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. 

Conor Hanlon 

Robert W. Kneisley, Esq. 

Leslie C. Abbott, Esq. 

sam.podbereskyAdot.gov 

conor.hanlonseiu.org bob.kneisleyRwnco.com 

leslie.abbott@wnco.com