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 FORAN 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, pursuantto 14 C.P.R. §16.11(a), and requests an extension oftime to file its Answer to the Part 16 Complaint (Complaint) and its Response to Motion ofPro-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-FlightAviation, Inc. (PFA) filed a Part 16 Complaint (Complaint) on January 28, 2015. The matterwas docketed on February 6, 2015. 2. Respondent moved for an extension oftime to respond to the Complaint. PFA agreed to an extension of30 days. Thereafter, on March 11, 2015, an extension of45-days
was granted. The due date for a response to the Complaint was April17, 2015. 3. On that date, RNT filed a Motion for SummaryJudgment. PFA sought an extension ofthe due date for its response to RNT's motion. RNT did not oppose the motion. Theextension 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 SummaryJudgment bythat date, and pursuantto 14 C.F.R. §16.26(b)(4), RNT's Answer became due on July 27, 2015. RNT now seeks an extension oftime 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. Pursuantto 14 C.F.R. §16.19 (c), RNT's response to said motion is due on July 27, 2015. RNT now seeks an extension oftime 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 SummaryJudgment. 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 ofhaving 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 properlyrespond to both the Complaint and the Motion for Preliminary Injunction. Additionally, counsel will be out oftown and unavailable betweenJuly 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 ofthe matters before the agency...." (See, 14 C.F.R. §16.11 (a).) Page 

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### RELIEF REQUESTED RNT seeks an extension oftime to file itsAnswerto the Part 16 Complaint on August 7, 2015. RNT seeks an extension oftimeto file its Response to theMotion ofPro-Flight Aviation For Preliminary Injunction onAugust 7, 2015.
Dated this 22nd dayofJuly, 2015. Respectfully submitted,



# ,_f<(yJ_,~ ( Zane L. Fontes, WSBA 9604

**\~i** fRenton, CityAttorney's Office

1055 So. GradyWay Renton, WA 98057 (425) 430-6486 zfontes@rentonwa.gov


### CERTIFICATE OF SERVICE I, Zanetta L. Fontes, hereby certifythaton 22 July, 2015, I caused the subjoined Motion ForAn Extension ofTime in the matterofPro-FlightAviation, Inc. v. City ofRenton Municipal Airport, Docket# 16-15-03, to be servedby e-mail transmission uponthe following: FederalAviation Administration Part 16 Docket Clerk Office ofthe ChiefCounsel Attention: FAA Part 16 Docket Clerk AGC-600 FederalAviation Administration 800 IndependenceAvenue SW Washington, D.C. 20591 9-AWA-AGC-Part-16@faa.gov Benjamin H. Klein Law Offices ofPaul A. Lange, LLC 80 Ferry Boulevard Stratford, CT 06615 bhk@lopal.com

Zane L. Fontes,WSBA 9604



### \__s~r Assistant City Attorney Page 13