BEFORE THE

UNITED STATES DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________ ___________________________ )

FRANK DRUM )

)

Complainant )

)

v. ) Docket DOT

- OST

- 2013

- 0093

)

SOUTHWEST AIRLINES CO. and )

PR I MEFLIGHT 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 Ri cks 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 Secre tary 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 , 20131 BEFORE THE

UNITED STATES DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________ ___________________________ )

FRANK DRUM )

)

Complainant )

)

v. ) Docket DOT

- OST

- 2013

- 0093

)

SOUTHWEST AIRLINES CO. and )

PR IMEFLIGHT AIRLINE SERVICES )

)

Respondents )

_____________________________________ )

UNCONTESTED MOTION OF SOUTHWEST AIRLINES CO.

FOR EXTENSION OF TIME TO FILE AN ANSWER

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

Southwest Airlines Co. ( “ Southwest ” ), hereby r equests a n additional extension of

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

Employees Assisting Passengers of Southwes t 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 th e 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 S o u t h w e s t p r e v i o u s l y f i l e d a n U n c o n t e s t e d M o t i o n f o r a n E x t e n s i o n o f T i m e u n t i l J u n e 1 2

, 2 0 1 3

. S e e S o u t h w e s t M o t i o n f i l e d o n M a y 2 0

, 2 0 1 3 i n D o c k e t O S T

- 2 0 1 3

- 0 0 9 3

.2

responses as needed

. F o r e x a m p l e

, S o u t h w e s t a n d P r i m e F l i g h t w i l l n e e d t o

coordinate t h e i r r e v i e w o f t r a i n i n g m a t e r i a l s

, t r a i n i n g r e c o r d s a n d a v a r i e t y o f

o t h e r i s s u e s p e r t a i n i n g t o t h i s m a t t e r

.

G ranting 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 develope d . The extension will thereby

facilitate the Department’s decision making without materially delay ing 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 , 20133 CERTIFICATE OF SERVICE

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

via e

- mail on the following persons:

Sam.podberesky@dot.gov

Blane.workie@dot.gov

Conor.hanlon@sei u.org

m a t w o o d @ c o z e n

. c o m

______________________________ Dorothy C. Sauvinet