BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

) 

Onetha McKnight, ) 

Nikisha Watson, ) 

Isaura Fernandez, ) 

) 

Complainants, ) 

) 

v. ) 

) 

US Airways, Inc., and ) 

Primeflight Airline Services, ) 

) 

Respondents. ) 

) 

Docket OST-2013-0091 

UNCONTESTED MOTION OF RESPONDENTS 

US AIRWAYS, INC. AND PRIMEFLIGHT AIRLINE SERVICES, INC. 

FOR EXTENSION OF ANSWER DATE 

Communications with respect to this document should be sent to: 

Mark W. Atwood 

Elizabeth J. Wadsworth 

Cozen O'Connor 

The Army and Navy Club Bldg. 

1627 I Street, N.W. 

Washington, DC 20006 

matwood©cozen.com 

Counsel for US Airways, Inc. and 

Primeflight Airline Services 

May 17, 2013 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

) 

Onetha McKnight, ) 

Nikisha Watson, ) 

Isaura Fernandez, ) 

) 

Complainants, ) 

) 

v. ) 

) 

US Airways, Inc., and ) 

Primeflight Airline Services, ) 

) 

Respondents. ) 

) 

Docket OST-2013-0091 

UNCONTESTED MOTION OF RESPONDENTS 

US AIRWAYS, INC. AND PRIMEFLIGHT AIRLINE SERVICES, INC. 

FOR EXTENSION OF ANSWER DATE 

US Airways, Inc. ("US Airways") and Primeflight Airline Services, Inc. 

("Primeflight"), Respondents in the above-cited formal complaint, request an extension 

of the filing date for their answer to this complaint under 49 C.F.R. § 302.405(a). US 

Airways and Primeflight request that they be given until June 20, 2013 to file their 

answer(s), for good cause as described below. 

On May 2, 2013, a representative of the Service Employees International Union 

("SEIU") filed and served a formal complaint against US Airways and Primeflight on 

behalf of four named employees of Primeflight. That company is the contractor 

responsible for certain passenger-handling services at Philadelphia International Airport 

on behalf of US Airways as well as several other air carriers. The complaint alleged 
certain failures on the part of US Airways and Primeflight in training the named 

Primeflight employees in carrying out their duties as wheelchair attendants. 

Under § 302.405(a), answers to the complaint would be due May 20, 2013. 1It 

will not be possible, however, for the Respondents to provide a meaningful response to 

these allegations in such a short time. The Respondents take such allegations 

seriously, and have wasted no time in commencing an inquiry into their substance. This 

has involved coordinating between carrier and Primeflight personnel, and will 

necessitate investigating employee records, conducting interviews, as well as 

coordination of the response amongst various levels of two large organizations. US 

Airways and Primeflight intend to give the Department the benefit of their best efforts on 

this matter, and they believe this will require an additional 30 days. 

Counsel for Respondents has contacted the representative of the SEIU, and he 

has no objection to this extension. 

Precedent exists for granting similar extensions of time for responding to thirdparty complaints. Most recently, in February of this year, a private citizen filed formal 

complaints against American Airlines, British Airways and Cathay Pacific Airways. 2All 

three carriers requested, and were granted, extensions of approximately 30 days, for 

essentially the same reasons as Respondents cite in the instant case. 

ACCORDINGLY, US Airways and Primeflight Airline Services submit that they 

have shown good cause for extension of the response date in this proceeding, as 

requested. 

' Due dates are calculated based on the date the complaint was received. As it was sent via 

Express Mail, it was received the day after the date on which the certificate of service was 

signed. 

Dockets OST-2013-0024, -0025 and -0027, respectively. 

2 
Respectfully submitted, 

Mark W. Atwood 

Elizabeth J. Wadsworth 

Cozen O'Connor 

The Army and Navy Club Bldg. 

1627 I Street, N.W. 

Washington, DC 20006 

matwood@cozen.com 

Counsel for US Airways, Inc. and 

Primeflight Airline Services 

May 17, 2013 

3 
CERTIFICATE OF SERVICE 

I hereby certify that on this 17 thday of May, 2013, a copy of the foregoing 

Uncontested Motion for Extension was served via electronic mail on the parties named 

below in accordance with the Department's Rules of Practice: 

Elizabeth J. Wadsworth 

Samuel Podberesky, Esq. sam.podbereskydot.gov 

Conor Hanlon conor.hanlonseiu.org