BEFORE THE UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION PENSACOLA AVIATION CENTERLLC, ) ) Complainant, ) v. ) ) PENSACOLA INTERNATIONAL AIRPORT, ) A DIVISION OF THE CITY OF ) PENSACOLA, ) Respondent. ) Docketno. 16-12-12

MOTION FOREXTENSION OF TIME 

## RECEIVED MAR 302015 PART 16 DOCKETS

AND NOW, comes Respondent, Pensacola International Airport, byand through its undersigned counsel, and pursuant to 14 CFR § 16.11, hereby requests a twenty (20) day extension oftime to respond to the Federal Aviation Administration's March 13, 2015 Request for Additional Information. In support ofthis Motion, Respondent states the following: 1. OnMarch 13, 2015, the Federal AviationAdministration ("FAA") issued to Respondent PensacolaInternational Airport, a Division ofthe City ofPensacola ("Pensacola") pursuant to 14 CFR § 16.29 aRequest for Additional Information. 2. The Certificate ofService for the FAA'srequest indicates that it was served on March 13, 2015 via electronic mail addressed to Eric Smith at SCHNADER HARRISON SEGAL & LEWISLLP. 3. That is notpossible. 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 SCHNADERfor Eric Smith as ofMarch 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 ofthe document actually was not postmarked until four days later,
onMarch 17, 2015. 5. Accordingly, no copy ofthe FAA's request was receivedbyPensacola's counsel until late inthe afternoon onMarch 20, 2015. 6. The FAA'srequest seeks at least 18 categories ofdocuments and information, including various updated maps, charts and diagrams from various sources, some ofwhich are or may be outside Pensacola's immediate possession. 7. Pursuant to its ownterms, 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 atwenty (20) day extension oftime to respond to the FAA's request, i.e., 

### until April22, 2015. 9. Counsel for Claimant does not objectto the reliefrequested in this motion. WHEREFORE, Pensacolarespectfully requests that the FAA grant atwenty (20) day extension oftime 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 Avenue Pittsburgh, PA 15222 Counsel for Respondent, Pensacola International Airport, a Division ofthe Date: March 26, 2015 City ofPensacola 2 PHOATA 5263239_1CERTIFICATE OF SERVICE I hereby certifythat onMarch 26,2015, true and correct copies ofthe foregoing MOTION FOREXTENSION 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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# l; lu.dttdt;"o--' OJ>??/\. Robert J. Will ams, Esq. 1 

## 1> Counsel for Respondent, Pensacola International Airport, a Division ofthe City ofPensacola

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