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, 2013BEFORE 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 allegedcertain 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. 1 It 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. 2 All 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.

2Respectfully 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

3CERTIFICATE OF SERVICE

I hereby certify that on this 17 th day 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