UNITED STATES DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

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Docket No. 16-08-05 j 

ALCA, INC., CYLINDER SHOP, INC. I 

SUNCOAST AVIATION, I 

AIRCRAFT PARTS AND NATIONAL 

AVIAION, 

Complainants, 

V. 

MIAMI-DADE COUNTY, FLORIDA, 

Respondent. 

LfW..AGC-60b' '' 

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I 

MIAMI-DADE COUNTY'S 

MOTION FOR ENLARGEMENT OF TIME 

CD 

no 

P\jrsuant to Title 14, § 16.209 of the Code of Federal Regulations, Respondent;^^ S 

MIAMI-DADE COUNTY ("County"), by and through undersigned counsel, requests an "~ 

enlargement of time of sixty (60) days to file its responsive pleading to the complaint 

filed by the five (5) named Complainants (the "Complainants" or sometimes collectively referred 

to as "ALCA"), and says the following: 

1. Although the Part 16 Complaint was served on the Hon. Carlos Alvarez, Mayor of 

Miami-Dade County on May 27,2008, neither Miami-Dade County's Aviation Department 

("MDAD") that is responsible for the operation of Opa-locka Executive Airport ("OPF") nor the 

Miami-Dade County Attorney's Office has any record of having received the Docketing Notice 

of May 27,2008. Under the Docketing Notice, the Coimtys answer was due to be filed on or 

before June 16,2008. 

OFFICE OF COUNTY ATTORNEY, MIAMI-DADE COUNTY, FLORIDA 
Docket No. 16-08-05 

2. Having just received the Docketing Notice, and being faced with a Part 16 

Complaint involving factual differences among the five named Complainants and MDAD, the 

County respectfiilly requests an Enlargement of Time for sixty (60) days fi-om the date on which 

the County Attorney's Office effectively received the Docketing Notice, which was July 21, 

2008. If the Motion for Enlargement of Time is granted, the Respondents' responsive pleading 

shall therefore be due on or before Friday, September 19,2008. 

3. Counsel for MDAD has discussed the Motion for lEnlargement of Time with 

Counsel for the Complainants, who does not oppose this motion based on certain conditions that 

are acceptable to the Respondent. 

WHEREFORE, Respondent respectfiilly requests that the Coimty be granted an extension 

of time until Friday, September 19,2008, within which to file its responsive pleading in order to 

allow the County to have a fiill and fair opportunity to fiilly investigate and respond to the claims 

presented. This request is not sought for the purpose of delaying the proceedings. 

Respectfiilly submitted. 

R.A. CUEVAS, JR. 

MIAMI-DADE COUNTY ATTORNEY 

By: 

DAVID M. MURRAY 

Assistant County Attorney 

Florida Bar No. 0291330 

Email: dmmurrav@miami-airport.com 

Thomas P. Abbott 

Assistant County Attorney 

Florida Bar No. 102920 

Email: tabbott(a),niiami-airport.com 

Aviation Division 

P. O. Box 025504 

Miami, Florida 33102-5504 

Telephone No. (305) 876-7040 

Facsimile No. (305)876-7294 

OFFICE OF COUNTY ATTORNEY, MIAMI-DADE COUNTY, FLORIDA 
Docket No. 16-08-05 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and correct copy of the foregoing was sent by 

telefacsimile and United States mail this ^f2^a y of July 2008, to: 

Michael A. Pizzi, Jr., Esq. 

15271 N.W. 60 Avenue 

Suite 206A 

Miami Lakes, FL 33014 

Telefacsimile: 305.231.2123 

Email: mpizzijr@vahoo.com 

Sharice Jefferson 

Airports & Environmental Law Div. 

Office of the Chief Counsel 

Federal Aviation Administration 

800 Independence Ave., S.W. 

Washington, D.C. 20591 

Elizabeth Newman 

FAA Part 16 Airport Proceedings Docket 

(AGC-610) 

Federal Aviation Administration 

800 Independence Ave., S.W. 

Washington, D.C. 20591 

Airport Compliance Division 

Office of Airport Safety and Standards 

AAS-400 

By: 

DAVID M. MURRAY 

THOMAS P. ABBOTT 

OFFICE OF COUNTY ATTORNEY, MIAMI-DADE COUNTY, FLORIDA