### JUN. 25 2015 10 50AM NABORS NO. 5503 P 2

UNITED STATES DEPARTMENT OF TRANSPORTATION FEDERAL AVIATIONADMINISTRATION WASHINGTON, D.C. 

## RECEI!VED Aircraft Management Services, Inc. ) ) COMPLAINANT, ) ) V. ) ) SantaRosa County, Florida ) ) RESPONDENT. ) 

### JUN 252015 PART 16 DOCKETS DocketNo. 16-12-02



### SANTA ROSA COUNTY'S MOTIONFOREXTENSION OFTIME TO RESPOND TO FAA'S DIRECTOR'S DETERMINATION Respondent Santa Rosa County, Florida (hereafter, the "County"), by and through its l.Ul.dersigned col.Ul.sel; andpursuantto 14 C.F.R. §16.19, hereby files this motion for an extension oftime 

### within whichto respond to the FAA's Director's Determination, and as grounds therefor, states as follows: I. The FAA's Director's Determination was served by Federal Express on March 27, 2015. Pursuant to the Director's Determination and 14 C.F.R.§l6.33(c), the Com1ty was required to submit a Corrective Action Plan or file aNotice ofAppeal and Briefwithin 30 days after the date ofservice oftheinitial determination, orby no later than April26, 2015. 2. On April 8, 2015, the County filed a Motion for Extension ofTime requesting a 60-day extension until June 26, 2015 to respond to the Director's Determination, which was granted byan Order, dated AprillS, 2015. 3. As the County continues to coordinate with both FBO operators, additional time is needed to finalize the proposed Corrective Action Plan. Itis believed that a 60-day extension until August 25, 2015, should allow sufficient time to submit a Corrective Action Plan.

### JUN. 25 2015 10 mM NABORS 

### NO. 5503 P. 3

4. Undersigned counsel certifies that counsel for Complainant has been consulted 

### and has consentedtothe requested extension soughtby this motion. 5. 

### Counsel further avers that this motion is not interposed for any improper purpose, but is necessitated by the circumstances described above. Moreover, because the motion is consented, the e;,.iension, ifgranted, 

### will not actto prejudice any party. WHEREFORE, based upon the foregoing good cause shown, and with the consent of Complainant, the County respectfully moves for an 

### extension until August 25, 2015, within which to respond to the FAA's Director's Determination. DATED this 25th day ofJune, 2015. Respectfully submitted,



# ~ GGORYT:iThWART FloridaBarNo. 203718 WILLIAM C. GARNER FloridaBarNo. 577189 Nabors, Giblin & 

### Nickerson, P.A. 1500 Mahan Drive, Suite 200 Post Office Box 11008 Tallahassee, Florida 32302 

### (850) 224-4070 (850) 224-4073 (facsimile) gstewart@ngnlaw.com bgarner@ngnlaw.com legal-admin@ngnlaw.com ROY 

### ANDREWS FloridaBarNo. 228291 County Attorney SantaRosa County 6495 Caroline Street, Suite C Milton, Florida 32570 

### (850) 983-1857 RoyA@santarosa.tl.gov

ATTORNEYS FORRESPONDENT 

### SANTA ROSA COUNTY, FLORIDA

2

### JUN. 25.2015 I0:50AM NABORS NO. 5503 P 4

CERTIFICATE OF SERVICE I hereby 

### certify that 

### atme and correct copy ofthe foregoing 

### has been :fulnishedto the following persons at the following addresses by Electronic Mail and U.S. Mail or by Facsimile andU.S. Mail, as indicated below,this 25th day ofJune, 2015: Ryan P. Hatler, Esquire

**1£chae[J.Schofiel~Esqurre** Clark, Partington, Hart, 

### Larry,

Bond & Stackhouse Suite 800, 125 WestRomana Street Post Office Box 13010 Pensacola, Florida 32591-3010 rhatler@cphlaw.com mschofield@cphlaw.com 

### VIA ELECTRONIC AND U.S. MAIL Docketing Clerk Federal Aviation Administration 800 Independence Avenue SW Washington, D.C. 20591 Facsimile: (202) 267-5769 

### VIA FACSlMILE AND U.S. MAIL

WILLIAM C. GARNER

3