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

UNITED STATES DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. RECEI!VED 

Aircraft Management Services, Inc. ) 

) 

COMPLAINANT, ) 

) 

V. ) 

) 

Santa Rosa County, Florida ) 

) 

RESPONDENT. ) 

JUN 2 5 2015 

PART 16 DOCKETS 

Docket No. 16-12-02 

SANTA ROSA COUNTY'S MOTION FOR EXTENSION OF TIME 

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; and pursuant to 14 C.F.R. §16.19, hereby files this motion for an extension 

of time within which to 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 a Notice of Appeal and Brief within 30 days 

after the date of service of the initial determination, or by no later than April26, 2015. 

2. On April 8, 2015, the County filed a Motion for Extension of Time requesting a 

60-day extension until June 26, 2015 to respond to the Director's Determination, which was 

granted by an 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. It is 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 consented to the requested extension sought by 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, if granted, will not act to 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 of June, 2015. 

Respectfully submitted, 

Florida 

GGORYT:iThWART ~ Bar No. 203718 

WILLIAM C. GARNER 

Florida Bar No. 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 

Florida Bar No. 228291 

County Attorney 

Santa Rosa County 

6495 Caroline Street, Suite C 

Milton, Florida 32570 

(850) 983-1857 

RoyA@santarosa.tl. gov 

ATTORNEYS FOR RESPONDENT SANTA ROSA COUNTY, FLORIDA 

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JUN. 25.2015 I 0:50AM NABORS NO. 5503 P 4 

CERTIFICATE OF SERVICE 

I hereby certify that a tme and correct copy of the foregoing has been :fulnished to 

the following persons at the following addresses by Electronic Mail and U.S. Mail or by 

Facsimile and U.S. Mail, as indicated below, this 25th day of June, 2015: 

Ryan P. Hatler, Esquire 

1£chae[J.Schofiel~Esqurre 

Clark, Partington, Hart, Larry, 

Bond & Stackhouse 

Suite 800, 125 West Romana 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 

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