Legal Department ---------------- -------------------------- -- - ----------------- - --- ---- --------- -------------------- -;-?oo-Pennsy!vanta-Avenue~--Nw----

Express 

January 5, 2015 

Federal Aviation Administration 

600 Independence Ave., NW 

Wilbur Wright Building-Suite 2Wl 000 

Washington, DC 20591 

Attn: Hearing Docket Clerk, AGC-430 

Re: In the Matter of Federal Express Corporation 

FDMS 2014-0864 (FAA Case No. 2014SW700042) 

Dear Hearing Docket Clerk: 

Suite 950 

Washington, DC 20006 

RECEIVED 

JAN 06 2015 

HEARING DOCKET 

Please find enclosed an original and one copy of Federal Express Corporation's Uncontested 

Motion and Order to Extend Time for Answer to Complainant's First Set of Requests for 

Admission, Interrogatories, Request for Production of Documents and Notice of Deposition, 

which we are filing in the above referenced matter. 

Copies of this letter, the Answer, and the Notice of Appearance are also being served via Federal Express on 

the FAA Office of Regional Counsel and the Administrative Law Judge assigned to this matter. 

Sincerely, 

FEDERAL EXPRESS CORPORATION .. , 

/ 

z . 

Greg. S 

Attorney for Respondent 

1700 Pennsylvania Ave., NW 

Suite 950 

Washington, DC 20006 

202-393-9285 

greg.stofko@fedex.com 

Enclosure 

Cc: Mr. James Archier, FAA Office of the Regional Counsel 

The Honorable Richard C. Goodwin 
U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

IN THE MATTER OF: 

) 

) 

) FAA Case No. 2014SW700042 

) (Civil Penalty Action) 

FEDERAL EXPRESS CORPORATION 

Respondent. 

The Honorable Rich;trd C. Goodwin 

) 

) 

) FDMS no. 2014-0864 

) 

UNCONTESTED MOTION TO EXTEND TIME 

RECEIVED 

JAN 0 6 2015 

HEARING DOCKET 

FOR ANSWER TO COMPLAINANT'S FIRST SET OF REQUESTS FOR ADMISSION, 

INTERROGATORIES, REQUEST FOR PRODUCTION OF DOCUMENTS AND 

NOTICE OF DEPOSITION 

Federal Express Corporation, by and through its attorneys, moves that pursuant to the 

Rules of Practice, 14 C.F.R. 13.213 (a), that the time within which to file an Answer to 

Complainant's First Set of Requests for Admission, Interrogatories, Request for Production of 

Documents and Notice of Deposition ("discovery requests") in this matter be extended to and 

include February 2, 2015 and, in support thereof states: 

1. Complainant served the discovery requests on December 11, 2014, with a due 

date for response of January 12, 2015. 

2. Counsel for Federal Express Corporation has contacted counsel for the Federal 

Aviation Administration who agreed to an extension of time for Federal Express Corporation to 

file its Answer to the discovery requests. 
WHEREFORE, Federal Express Corporation requests that an extension of time within 

which Federal Express Corporation may respond to the discovery request be granted. 

By: 

Respectfully submitted, 

Federal Express Corporation 

/7 

.~ ... ~· Greg S,t .· /" o ~· / 

Atto / ey for Resp dent 

1700 Pennsylvania Ave., NW 

Suite 950 

Washington, DC 20006 

(202) 393-9285 

greg.stofko@fedex.com 
CERTIFICATE OF SERVICE 

I hereby certify that the foregoing document has been sent via Federal Express to the 

following: 

Federal Aviation Administration 

600 Independence Avenue, SW 

Wilbur Wright Building- Suite 2W1000 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

Mr. James Archier, Complainant's Counsel 

Federal Aviation Administration 

Office of the Regional Counsel 

2601 Meacham Boulevard 

Fort Worth, Texas 76137 

The Honorable Richard C. Goodwin, Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. (Ell-310) 

Washington, DC 20590 

TEL: 202-366-5121 Staff Assistant 

F AX:202-366-7536 

Dated this 5th day ofJanuary, 2015. 

By: h~···· 

tf4stofko / 

(1'\,ttorney for Refpondent ./ 

1700 Pennsylvania Ave., NW 

Suite 950 

Washington, DC 20006 

(202) 393-9285 

greg.stofko@fedex.com 
U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

IN THE MATTER OF: 

FEDERAL EXPRESS CORPORATION 

Respondent. 

The Honorable Richard C. Goodwin 

) 

) 

) FAA Case No. 2014SW700042 

) (Civil Penalty Action) 

) 

) 

) FDMS no. 2014-0864 

) 

UNCONTESTED ORDER GRANTING MOTION TO EXTEND TIME 

FOR ANSWER TO COMPLAINANT'S FIRST SET OF REQUESTS FOR ADMISSION, 

INTERROGATORIES, REQUEST FOR PRODUCTION OF DOCUMENTS AND 

NOTICE OF DEPOSITION 

The Court, having reviewed Respondent's Motion To Extend Time for Answer to 

Complainant's First Set of Requests for Admission, Interrogatories, Request for Production of 

Documents and Notice of Deposition, and being otherwise fully advised on the premises; 

IT IS HEREBY ORDERED that the Motion is granted. Federal Express Corporation is 

granted additional time within which to respond to the Complaint and shall file its Answer to 

Complainant's First Set of Requests for Admission, Interrogatories, Request for Production of 

Documents and Notice of Deposition on or before February 2, 2015. 

Administrative Law Judge 

Date: __________ _