~lE~[ED\W!E~ 

FEDERAL AVIATION ADMINISTRATION JAN 0 5 :Jl) 15 

UNITED STATES DEPARTMENT OF TRANSPORTATION 

------------------------------------------------------------------------------ -f-'JiRT 16 DOCKETS 

UNITED AIRLINES, INC., 

Complainant, 

v. 

Docket No. 

16-14-13 

THE PORT AUTHORITY OF NEW YORK AND NEW JERSEY, 

Respondent. 

----------------------------------------------------------------------------------}[ 

MOTION OF RESPONDENT 

THE PORT AUTHORITY OF NEW YORK AND NEW JERSEY 

FOR AN EXTENSION OF TIME TO MOVE TO DISMISS THE COMPLAINT, OR FOR 

SUMMARY JUDGMENT, OR TO FILE AN ANSWER TO THE COMPLAINT 

Communications with respect to this document should be addressed to:. 

Carlene V. Mcintyre 

Assistant General Counsel 

Arnold D. Kolikoff 

Attorney 

Faith Tabafunda 

Attorney 

Law Department 

The Port Authority ofNew York and New Jersey 

225 Park A venue South, 14th Floor 

New York, N.Y. 10003 

Telephone: (212) 435-3503 

Attorneys for Respondent 

The Port Authority of New York and New Jersey 
FEDERAL AVIATION ADMINISTRATION 

UNITED STATES DEPARTMENT OF TRANSPORTATION 

----------------------------------------------------------------------------------)( 

UNITED AIRLINES, INC., 

Docket No. 16-14-13 

Complainant, 

v. 

THE PORT AUTHORITY OF NEW YORK AND NEW JERSEY, 

Respondent. 

----------------------------------------------------------------------------------)( 

MOTION FOR AN E)(TENSION OF TIME TO MOVE TO DISMISS THE 

COMPLAINT, OR FOR SUMMARY JUDGMENT, OR TO FILE AN ANSWER TO THE 

COMPLAINT 

Respondent The Port Authority ofNew York and New Jersey ("the Port Authority"), 

hereby moves pursuant to 14 C.F.R. § 16.19 (e) for an extension of time to and including 

February 10, 2015 to move to dismiss the Complaint herein pursuant to 14 C.F.R. § 16.26 (b), or 

for summary judgment pursuant to 14 C.F .R. § 16.26 (c), or to file an Answer to the Complaint 

herein pursuant to 14 C.F .R. § 16.23 (d), based upon the Declaration of Carlene V. Mcintyre 

dated January 2, 2015 annexed hereto. 

Dated: January 2, 2015 

Carlene V. Mcintyre 

Assistant General Counsel 

Arnold D. Kolikoff 

Attorney 

Faith Tabafunda 

Attorney 

Respectfully submitted, 

Law Department 

The Port Authority of New York and New Jersey 

225 Park Avenue South, 14th Floor 

New York, N.Y. 10003 

Telephone: (212) 435-3503 

Attorneys for Respondent 

The Port Authority of New York and New Jersey 
TO: 

Office of the Chief Counsel 

Attention: FAA Part 16 Airport Proceedings Docket, AGC-600 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington D.C. 20591 

Keith J. Harrison, Esq. 

Gerald F. Murphy, Esq. 

Steven J. Seiden, Esq. 

Crowell & Moring LLP 

1001 Pennsylvania Avenue, NW 

Washington, DC 20004 

(202) 624-2500 

RobertS. Spau, Esq. 

Alan K. Steinbrecher, Esq. 

Sophy Chen, Esq. 

Steinbrecher & Spau LLP 

1155 F Street, N.W., Suite 1050 

Washington, DC 20004 

(202) 559-8680 

Attorneys for Complainaut 

2 
FEDERAL AVIATION ADMINISTRATION 

UNITED STATES DEPARTMENT OF TRANSPORTATION 

----------------------------------------------------------------------------------)( 

UNITED AIRLINES, INC., 

Complainant, 

v. 

THE PORT AUTHORITY OF NEW YORK AND NEW JERSEY, 

Respondent. 

----------------------------------------------------------------------------------)( 

DECLARATION OF CARLENE V. MCINTYRE 

I, Carlene V. Mcintyre, declare as follows: 

Docket No. 

16-14-13 

1. I am Assistant General Counsel in the Law Department of the Respondent The 

Port Authority of New York and New Jersey ("the Port Authority") assigned to represent the 

Port Authority in this matter. In that capacity, I am fully familiar with the facts set forth herein. 

2. This Declaration is submitted in support of the motion of the Port Authority 

pursuant to 14 C.F.R. §§ 16.19 (e) for an extension of time to and including February 10, 2015 

for the Port Authority to either (a) move to dismiss the Complaint; or (b) move for summary 

judgment; or (c) file its Answer to the Complaint. 

3. On December 19,2014, the Complaint was docketed by the Office of Chief 

Counsel. Accordingly, under the Rules of Practice for Federally-Assisted Airport Enforcement 

Proceedings, the last date for the Port Authority, to move to clismiss the Complaint, or to move 

for summary judgment, or to file its Answer to the Complaint, is 20 days after December 19, 

2014, or January 8, 2015. 14 C.F.R. §§ 16.23 (d), 16.26 (b), 16.26 (c) 

4. Taking into account the numerous and wide ranging allegations in the Complaint, 

the intervening holiday season, and the need to include and address lease agreements between 
Complainant and the Port Authority that are not included in the Complaint, additional time is 

needed to adequately respond to the Complaint. 

5. By counsel, Complainant has indicated that it will not oppose the Port Authority's 

request to extend the January 8, 2015 deadline to and including February 10,2015. 

6. For the foregoing reasons, the Port Authority respectfully requests that the 

deadline for the Port Authority to move to dismiss the Complaint, or for summary judgment, or 

to file its Answer to the Complaint, be extended to and including February 10,2015. 

I declare under the penalty of perjury under the laws of the United States of America that 

that the foregoing is true and correct. 

Executed at New York, New York, on January 2, 2015. 

2 
FEDERAL AVIATION ADMINISTRATION 

UNITED STATES DEPARTMENT OF TRANSPORTATION 

----------------------------------------------------------------------------------)( 

UNITED AIRLINES, INC., 

DocketNo. 16-14-13 

Complainant, 

v. 

THE PORT AUTHORITY OF NEW YORK AND NEW JERSEY, 

Respondent. 

----------------------------------------------------------------------------------)( 

CERTIFICATE OF SERVICE 

I hereby certifY that I have this day served the foregoing Motion For An Extension Of 

Time To Move To Dismiss The Complaint, Or For Summary Judgment, Or To File An Answer 

To The Complaint, of the Respondent The Port Authority OfNewYork and New Jersey on the 

persons set forth below at the addresses indicated by placing the same in (1) a properly 

addressed, post-paid First Class Mail wrapper in the custody of the United States Postal Service 

within the State ofNew York and (2) a properly addressed, pre-paid wrapper for overnight 

delivery service in the custody of Federal Express within the State of New York. 

Dated: January 2, 2015 

Carlene V. Mcintyre 

Assistant General Counsel 

Arnold D. Kolikoff 

Attorney 

Faith Tabafunda 

Attorney 

Addressees: 

Law Department 

The Port Authority of New York and New Jersey 

225 Park Avenue South, 14th Floor 

NewYork,N.Y. 10003 

Telephone: (212) 435-3503 

Attorneys for Respondent 

The Port Authority of New York and New Jersey 

Senior Paralegal Specialist 
Office of the Chief Counsel 

Attention: FAA Part 16 Airport Proceedings Docket, AGC-600 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington D.C. 20591 

Keith J. Harrison, Esq. 

Gerald F. Murphy, Esq. 

Steven J. Seiden, Esq. 

Crowell & Moring LLP 

1001 Pennsylvania Avenue, NW 

Washington, DC 20004 

(202) 624-2500 

RobertS, Span, Esq. 

Alan K. Steinbrecher, Esq. 

Sophy Chen, Esq. 

Steinbrecher & Span LLP 

1155 F Street, N.W., Suite 1050 

Washington, DC 20004 

(202) 559-8680 

Attorneys for Complainant 

2