UNITED STATES OF AMERICA 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. 

PRO-FLIGHT AVIATION, INC. ) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

Complainant 

v. 

CITY OF RENTON MUNICIPAL 

AIRPORT 

Respondent 

Docket No. 16-15-03 

__________________________ ) 

RESPONDENT'S UNOPPOSED MOTION FOR AN 

EXTENSION OF TIME TO FILE ITS ANSWER AND ITS RESPONSE 

TO MOTJON OF PRO-FLIGHT AVIATION FOR PRELIMINARY INJUNCTION 

Comes now, the City Renton Municipal Airport (RNT), Respondent, pursuant to 14 

C.P.R. §16.11(a), and requests an extension of time to file its Answer to the Part 16 

Complaint (Complaint) and its Response to Motion of Pro-Flight Aviation for Preliminary 

Injunction. Respondent requests an extension to August 7, 2015. Counsel for Pro-Flight 

Aviation, Inc., Benjamin Klein, has agreed to this extension. 

1. Pro-Flight Aviation, Inc. (PFA) filed a Part 16 Complaint (Complaint) on January 

28, 2015. The matter was docketed on February 6, 2015. 

2. Respondent moved for an extension of time to respond to the Complaint. PFA 

agreed to an extension of 30 days. Thereafter, on March 11, 2015, an extension of 45-days 

was granted. The due date for a response to the Complaint was April17, 2015. 

3. On that date, RNT filed a Motion for Summary Judgment. PFA sought an extension 

of the due date for its response to RNT's motion. RNT did not oppose the motion. The 
extension was granted and the due date for PFA's response to RNT's Motion for Summary 

Judgment was extended to June 4, 2015. 

4. PFAfiled a timely response on June 4, 2015. Thirty days therefrom is July 3, 2015. 

Having received no decision on the Motion for Summary Judgment by that date, and 

pursuant to 14 C.F.R. §16.26(b)(4), RNT's Answer became due on July 27, 2015. 

RNT now seeks an extension of time to file its Answer, currently due on July 27, 2015, to 

August 7, 2015. 

5. On July 17, 2015, PFA filed a Motion for Preliminary Injunction. Pursuant to 14 

C.F.R. §16.19 (c), RNT's response to said motion is due on July 27, 2015. RNT now seeks an 

extension of time to file its response to PFA's Motion for Preliminary Injunction, currently 

due on July 27, 2015, to August 7, 2015. 

6. On July 21, 2015, RNT received by e-mail the Order from the Director denying its 

Motion for Summary Judgment. 

7. This motion to extend time is due to the city's attorney's schedule. Counsel has 

numerous litigation matters that are paralleling each other. She had scheduled her time to 

produce the Answer on July 27, 2015. However, the addition of having to respond to the 

Motion for Preliminary Injunction in this matter and having received last minute motions 

in other matters has diverted her limited time to properly respond to both the Complaint 

and the Motion for Preliminary Injunction. Additionally, counsel will be out of town and 

unavailable between July 28 through July 31, 2015. 

8. Extending the due date for the Answer as well as the response to the Motion for 

Preliminary Injunction is necessary and appropriate " .. .for a fair and complete 

consideration of the matters before the agency .... " (See, 14 C.F.R. §16.11 (a).) 

Page I 2 
RELIEF REQUESTED 

RNT seeks an extension of time to file its Answer to the Part 16 Complaint on August 

7, 2015. RNT seeks an extension of time to file its Response to the Motion of Pro-Flight 

Aviation For Preliminary Injunction on August 7, 2015. 

Dated this 22nd day ofJuly, 2015. 

Respectfully submitted, 

,_f<(yJ_,~ 

( Zane L. Fontes, WSBA 9604 

\~i f Renton, City Attorney's Office 

1055 So. Grady Way 

Renton, WA 98057 

( 425) 430-6486 

zfontes@rentonwa.gov 

CERTIFICATE OF SERVICE 

I, Zanetta L. Fontes, hereby certify that on 22 July, 2015, I caused the subjoined 

Motion For An Extension of Time in the matter of Pro-Flight Aviation, Inc. v. City of Renton 

Municipal Airport, Docket# 16-15-03, to be served by e-mail transmission upon the 

following: 

Federal Aviation Administration 

Part 16 Docket Clerk 

Office of the Chief Counsel 

Attention: FAA Part 16 Docket Clerk 

AGC-600 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, D.C. 20591 

9-AWA-AGC-Part-16@faa.gov 

Benjamin H. Klein 

Law Offices of Paul A. Lange, LLC 

80 Ferry Boulevard 

Stratford, CT 06615 

bhk@lopal.com 

Zane L. Fontes, WSBA 9604 

\__s~r Assistant City Attorney 

Page 13