UNITED STATES DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. 

RECEIVED 

JUN 2 4 2015 

National Business Aviation Association, Inc., et 

a!. 

PART 16 DOCKETS 

Complainants, FAA Docket No. 16-15-08 

v. 

Town of East Hampton, NY 

Respondent. 

RESPONDENT TOWN OF EAST HAMPTON, NEW YORK'S 

MOTION TO SUSPEND FILING AN ANSWER TO THE COMPLAINT UNTIL THE 

FAA RULES ON RESPONDENT'S MOTION TO DISMISS THE COMPLAINT 

Designation of persons to receive service for the Town of East Hampton, New York: 

Elizabeth Vail 

Town Attorney 

Town of East Hampton 

159 Pantigo Road 

East Hampton, NY 1193 7 

EVail@EHamptonNY.Gov 

W. Eric Pilsk 

Catherine van Heuven 

Kaplan Kirsch & Rockwell LLP 

1001 Connecticut Ave., NW, Suite 800 

Washington, D.C. 20036 

epilsk@kaplankirsch.com 

cvanheuven@kaplankirsch.com 

Telephone: (202) 955-5600 

Facsimile: (202) 955-5616 
The Town of East Hampton, New York (the "Town"), hereby moves to suspend the 

deadline for filing an Answer to the Complaint until20 days after the FAA rules on the Town's 

Motion to Dismiss the Complaint filed today. In support of its Motion, the Town states as 

follows: 

On May 20,2015, Complainants filed a Part 16 Complaint against the Town, the operator 

of East Hampton Airport ("HTO") alleging violations of Assurances 23 and 25. The Director 

docketed the Complaint on June 8, 2015. 

On June 24, 2015, the Town filed a Motion to Dismiss the Complaint. Pursuant to 14 

C.F.R. § 16.26(b)(5), if the FAA does not rule on the Motion to Dismiss within 30 days after 

Complainants' Answer to the Motion is due, the Town would have to file its Answer to the 

Complaint within the next 20 days. Because the Motion seeks dismissal of the entire Complaint, 

it would be wasteful and unduly burdensome to require the Town to prepare its Answer to the 

Complaint while the Motion to Dismiss is pending. Such an extension would not prejudice 

Complainants and would not impair the FAA's ability to address the merits of the case if 

warranted. Conversely, granting this motion would prevent the FAA from having to receive 

substantive filings that may be rendered moot, in whole or in part, by its decision on the Motion 

to Dismiss. 

Accordingly, the Town respectfully requests that the FAA suspend the Town's obligation 

to file its Answer to the Complaint until 20 days after the FAA rules on the Motion to Dismiss. 

Respectfully submitted this 24th day of June, 2015. 

2 
Elizabeth Vail 

Town Attorney 

Town of East Hampton 

159 Pantigo Road 

East Hampton, NY 1193 7 

EVail@EHamptonNY.Gov 

W. Eric Pilsk 

Catherine van Heuven 

Kaplan Kirsch & Rockwell LLP 

1001 Connecticut Ave., NW, Suite 800 

Washington, DC 20036 

epilsk@kaplankirsch.com 

cvanheuven@kap1ankirsch.com 

Telephone: (202) 955-5600 

Facsimile: (202) 955-5616 

3 
CERTIFICATE OF SERVICE 

I hereby certify that I have this 24th day of June, 2015, served the foregoing Respondent 

Town of East Hampton, New York's Motion to Suspend Filing on Answer to the Complaint 

Until the FAA Decides Respondent's Motion to Dismiss the Complaint on the following 

parties by hand delivery at the following addresses: 

Office of the Chief Counsel 

Attn: FAA Part 16 Airport Proceedings Docket, AGC-610 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, D.C. 20591 

Steve Brown 

Chief Operating Officer 

National Business Aviation Association, Inc. 

1200 G Street, NW 

Suite 1100 

Washington, D.C. 20005 

Dated this 24th day of June, 2015. 

W. Eric Pilsk 

4