BEFORE THE

UNITED STATES DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_____________________________________

)

FRANK DRUM )

)

Complainant )

)

v. ) Docket DOT-OST-2013-0093

)

SOUTHWEST AIRLINES CO. and )

PRIMEFLIGHT AIRLINE SERVICES )

)

Respondents )

_____________________________________ )

UNCONTESTED MOTION OF SOUTHWEST AIRLINES CO.

FOR EXTENSION OF TIME TO FILE AN ANSWER

Communications with respect to this 

document should be sent to:

Ron Ricks Robert W. Kneisley

 Executive Vice President and Associate General Counsel

 Chief Legal & Regulatory Officer Leslie C. Abbott

Mark Shaw Senior Attorney

 Vice President General Counsel Southwest Airlines Co.

 and Corporate Secretary 1901 L Street, NW, Suite 640

Southwest Airlines Co. Washington, DC 20036

2702 Love Field Drive (202) 263-6284

Dallas, TX 75235-1611 bob.kneisley@wnco.com

leslie.abbott@wnco.com

June 7, 2013
1

BEFORE THE

UNITED STATES DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_____________________________________

)

FRANK DRUM )

)

Complainant )

)

v. ) Docket DOT-OST-2013-0093

)

SOUTHWEST AIRLINES CO. and )

PRIMEFLIGHT AIRLINE SERVICES )

)

Respondents )

_____________________________________ )

UNCONTESTED MOTION OF SOUTHWEST AIRLINES CO.

FOR EXTENSION OF TIME TO FILE AN ANSWER

Pursuant to Rule 405 of the Department’s Rules of Practice, Respondent 

Southwest Airlines Co. (“Southwest”), hereby requests an additional extension of 

time until June 20, 2013 to file its answer to the Complaint of Contractor 

Employees Assisting Passengers of Southwest Airlines at Philadelphia 

International Airport filed by the Service Employees International Union (“SEIU”) 

on behalf of Frank Drum (“the Complainant”) on May 7, 2013. 1 Southwest 

discussed the extension request with counsel for the Complainant on June 6, 

2013 and was advised that the Complainant consented to this motion. 

Southwest submits that good cause exists to grant this uncontested 

extension request. The new date corresponds with PrimeFlight’s answer date 

and will allow Southwest and PrimeFlight sufficient time to coordinate on their 

 

1

Southwest previously filed an Uncontested Motion for an Extension of Time until June 12, 2013.

See Southwest Motion filed on May 20, 2013 in Docket OST-2013-0093.
2

responses as needed. For example, Southwest and PrimeFlight will need to

coordinate their review of training materials, training records and a variety of

other issues pertaining to this matter. 

Granting this uncontested motion will allow Southwest to provide the 

Department with a comprehensive answer that will ensure that the record in this 

matter is both factually accurate and fully developed. The extension will thereby

facilitate the Department’s decision making without materially delaying this 

proceeding and is therefore in the public interest.

WHEREFORE, Southwest requests that the Department grant it an 

extension of time until June 20, 2013 to file its answer in this proceeding.

Respectfully submitted,

 _________________________

 Leslie C. Abbott

June 7, 2013
3

CERTIFICATE OF SERVICE

I hereby certify that on June 7, 2013, a copy of the foregoing was served 

via e-mail on the following persons:

Sam.podberesky@dot.gov

Blane.workie@dot.gov

Conor.hanlon@seiu.org

matwood@cozen.com

______________________________

Dorothy C. Sauvinet