U.S. Department 

of Transportation 

Federal Aviation 

Administration 

NOTICE OF DOCKETING 

800 Independence Ave., S.W. 

Washington, D.C. 20591 

Please be advised that the complaint filed by Mansfield Heliflight, Inc. ("complainant") 

against the City of Burlington, Vermont (respondent") filed under the Rules of Practice for 

Federally Assisted Airport Enforcement Proceedings, Title 14, Part 16 of the Code of Federal 

Regulations ("14 CFR Part 16"), has been docketed by the Federal Aviation Administration's 

Office of the Chief Counsel, as Docket No. 16-14-06 on August 14,2014. 

The respondent is required to file an answer to the complaint within 20 days of the date of 

service of this notice. See 14 CFR §16.23 (d). The answer shall deny or admit the allegations 

made in the complaint, and shall assert any affirmative defense. 

In lieu of an answer, the respondent may file a motion to dismiss the complaint or a motion 

for summary judgment on the complaint. See 14 CFR § 16.26. The respondent may move 

for dismissal of the entire complaint or move for dismissal of specific issues from 

adjudication. The motion must be filed within 20 days after the date of service of this notice 

of docketing. See 14 CFR § 16.26. If such a motion is filed under 14 CFR § 16.26, an 

answer must be filed within 20 days of the date of service of an FAA order denying all or 

part of that motion. See 14 CFR § 16.23 (d). 

The complainants may file a reply within 10 days of the date of service of the answer. The 

respondent may file a rebuttal within 10 days of the date of service of the complainants' 

reply. See 14 CFR § 16.23( e) and (f). The answer, reply, and rebuttal shall, like the 

complaint, be accompanied by supporting documentation upon which the parties rely. The 

answer, reply, and rebuttal shall each contain a concise but complete statement of the facts 

relied upon to substantiate the answers, admissions, denials, or averments made. See 14 CFR 

§ 16.23 (g) and (i). Amendments or supplements to the pleadings will not be allowed 

without showing good cause through a motion and supporting documents. See 14 CFR § 

16.23 G). 

All documents filed with the FAA in this proceeding shall be served (and include a certificate 

of service) by the persons filing them on all parties to the proceeding, and on the FAA at the 

FAA Part 16 Airport Proceedings Docket, AGC-600, Federal Aviation Administration, 800 

Independence Avenue, SW, Washington, DC, 20591. See 14 CFR §§ 16.13 and 16.15. 

Unless otherwise specified, an executed original and three (3) copies of each and every 

document shall be filed with the FAA Part 16 Airport Proceedings Docket. See 14 CFR § 

l6.13(c). 

Pursuant to 14 CFR § 16.13(h), electronic filing of Part 16 documents is permitted under the 

following guidelines: 
• Parties may send e-mails containing their pleadings as an attaclnnent. The 

attachment(s) shall be Adobe PDF file(s). The subject line of the e-mail must 

contain the names of the complainant and respondent, as well as the FAA docket 

number, if assigned. The size of the email may not exceed 10MB. 

• E-mail filings shall be sent to the FAA Docket Clerk at 9-A WA-AGC-Part16@faa.gov and the opposing party (only if the opposing party has agreed with 

the complainant in writing to participate in electronic filing, otherwise service 

must be made pursuant to 14 CFR §16.15.) The FAA will not provide any 

ackuowledgement or receipt to parties filing electronically. 

• A party filing electronically must provide the FAA Docket Clerk and the 

opposing party an e-mail address designating its representative to receive 

electronic pleadings and documents by e-mail. 

• A party availing itself of electronic filing as described in this document and 14 

CFR § 16.13 (h) waives its rights under Part 16 to service by any other means 

from the opposing party or FAA. 

• A party filing electronically will include with its pleadings a certificate of service 

stating the method as electronic by or via e-mail. In regard to computation of 

time, the date of the e-mail is not included in the computation of time under this 

part. See 14 CFR § 16.17 (a). Parties will start the count as of the day following 

the date the e-mail was sent. 1 

The Department of Transportation (DOT) uses the government-wide Federal Docket 

Management System (FDMS) at http://www.regulations.gov. Accordingly, if filing paper 

documents with the FAA, please ensure that at least one of the required copies is 

unbound and without tabs. Exhibit numbers in unbound copies should be noted on the 

first page of each exhibit or in divider pages. The FAA will forward all electronic 

submissions (like the paper submissions) to FDMS for public viewing. 

b tott Mitchell 

Attorney, Airports Law Branch 

FAA Office of the Chief Counsel 

1 Please note, this paragraph only exempts the parties from the filing requirements under 14 CPR §§ 

16.13 (a), (b), and (c). If a party subsequently decides to "opt-out" of electronic filing, it must notify 

the FAA Docket Clerk and opposing party in writing. See 14 CPR§ 16.13 (h)(4). The electronic 

filing method may be used in lieu of or in addition to the existing requirements set forth in Part 16. 
CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on AUG 14 2°14 , I caused to be placed 

with Federal Express and United States mail a true copy ofthe foregoing 

Notice of Docketing addressed to: 

Counsel for Complainant: 

Benjamin H. Klein 

The Klein Firm, LLC 

61 Broadway, Suite 2125 

New York, NY 10006 

Counsel for Respondent: 

Eileen Blackwood 

City of Burlington 

Burlington City Attorney's Office 

149 Church Street 

Burlington, VT 05401 

Hand delivered to: 

FAA Part 16 Airport Proceedings Docket, AGC-600 

FAA Airport Compliance and Management Analysis, AC0-1 00 

By: 

Sharon Long, Paralegal / 

Airports and Environmental "JI,aw Division ,,