BEFORE THE UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

PENSACOLA AVIATION CENTER LLC, ) 

) 

Complainant, ) 

v. ) 

) 

PENSACOLA INTERNATIONAL AIRPORT, ) 

A DIVISION OF THE CITY OF ) 

PENSACOLA, ) 

Respondent. ) 

Docketno. 16-12-12 

MOTION FOR EXTENSION OF TIME 

RECEIVED 

MAR 3 0 2015 

PART 16 DOCKETS 

AND NOW, comes Respondent, Pensacola International Airport, by and through its 

undersigned counsel, and pursuant to 14 CFR § 16.11, hereby requests a twenty (20) day 

extension of time to respond to the Federal Aviation Administration's March 13, 2015 Request 

for Additional Information. In support ofthis Motion, Respondent states the following: 

1. On March 13, 2015, the Federal Aviation Administration ("FAA") issued to 

Respondent Pensacola International Airport, a Division of the City of Pensacola ("Pensacola") 

pursuant to 14 CFR § 16.29 a Request for Additional Information. 

2. The Certificate of Service for the FAA's request indicates that it was served on 

March 13, 2015 via electronic mail addressed to Eric Smith at SCHNADER HARRISON SEGAL & 

LEWISLLP. 

3. That is not possible. Mr. Smith withdrew from that law firm approximately nine 

months ago. While the electronic mail system was monitored for several months after his 

departure, so that incoming correspondence could be redirected as needed, that monitoring and 

redirection was discontinued approximately three months ago. Accordingly, no email address 

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existed at SCHNADER for Eric Smith as of March 13, 2015, and no email was received on that 

date by SCHNADER's email server. 

4. Furthermore, although the Certificate indicates that the request was served on 

March 13, 2015, a hard copy of the document actually was not postmarked until four days later, 

on March 17, 2015. 

5. Accordingly, no copy of the FAA's request was received by Pensacola's counsel 

until late in the afternoon on March 20, 2015. 

6. The FAA's request seeks at least 18 categories of documents and information, 

including various updated maps, charts and diagrams from various sources, some of which are or 

may be outside Pensacola's immediate possession. 

7. Pursuant to its own terms, however, a response to the request is due twenty (20) 

days from March 13, i.e., April2, 2015. 

8. Under the circumstances, Pensacola respectfully requests a twenty (20) day 

extension of time to respond to the FAA's request, i.e., until April22, 2015. 

9. Counsel for Claimant does not object to the relief requested in this motion. 

WHEREFORE, Pensacola respectfully requests that the FAA grant a twenty (20) day 

extension of time to respond to the Request for Additional Information. 

Respectfully submitted, 

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Schnader Harrison Segal & Lewis LLP 

Suite 2700, Fifth Avenue Place 

120 Fifth A venue 

Pittsburgh, P A 15222 

Counsel for Respondent, Pensacola 

International Airport, a Division of the 

Date: March 26, 2015 City of Pensacola 

2 PHOATA 5263239_1 
CERTIFICATE OF SERVICE 

I hereby certify that on March 26,2015, true and correct copies of the foregoing 

MOTION FOR EXTENSION OF TIME were sent by e-mail and U.S. Mail, first class postage 

prepaid, to the following 

Leonard D. Kirsch, Esq. e-mail: lkirsch@mklawnyc.com 

McBreen & Kopko 

500 North Broadway 

Jericho, NY 11753 

Attorneys for Complainant 

' 

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Robert J. Will ams, Esq. 1 1> 

Counsel for Respondent, Pensacola 

International Airport, a Division of the 

City of Pensacola 

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