BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________) In the Matter of ) ) Establishment of Slot Exemption Proceedings ) Docket DOT-OST-2012-0029 At Ronald Reagan Washington National Airport ) Pursuant to 49 U.S.C. § 41718 ) __________________________________________)

MOTION FOR LEAVE TO FILE AND MOTION TO STRIKE OF ALASKA AIRLINES, INC. Megan Lawrence, Esq. Managing Director, Government and Community Relations Megan.Lawrence@alaskaair.com Kyle Levine, Esq. Deputy General Counsel and Managing Director, Legal Kyle.Levine@alaskaair.com ALASKA AIRLINES, INC. 19300 Pacific Highway South Seattle, WA 98188 Marshall S. Sinick, Esq. Marshall.Sinick@squiresanders.com Edward W. Sauer, Esq. Edward.Sauer@squiresanders.com Squire Sanders (US) LLP 1200 19th Street, NW, Suite 300 Washington, DC 20036 (202) 626-6651 Counsel for Alaska Airlines, Inc.

DATED: April 10, 2012BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

__________________________________________) In the Matter of ) ) Establishment of Slot Exemption Proceedings ) Docket DOT-OST-2012-0029 At Ronald Reagan Washington National Airport ) Pursuant to 49 U.S.C. § 41718 ) __________________________________________)

MOTION FOR LEAVE TO FILE AND MOTION TO STRIKE OF ALASKA AIRLINES, INC. Alaska Airlines, Inc. (“Alaska”) respectfully files this motion for leave to file its motion to strike, as set forth below, supplementary pleadings filed in the captioned docket by various applicants. Since the March 27, 2012 comment submission deadline multiple supplements have been filed in this proceeding, many of which address substantive issues in this case. The Department of Transportation (“Department”) should accept this brief motion and strike all supplementary pleadings other than those consisting of supporting letters and the one limited pleading filed by Virgin America clarifying the readiness of its A319 aircraft. Since March 27, no fewer than four “supplements” and “responses” have been filed in this docket by Sun Country, Southwest, Frontier and JetBlue. 1 None of these supplemental filings were authorized by the Department’s Notice instituting this case, and none of them add anything of substance to the record. Instead, the supplemental filings are duplicative of arguments made previously in comments submitted on March 27, and contain replies to the March 27 comments of other applicants. Regardless of the content, the Department should not

1 Alaska does not object to the Motion for Leave to File and Response of Virgin America, Inc., or its Erratum, filed on March 30 and April 2, respectively, in response to Alaska’s Reply Comments. Virgin America clarifies that its CFM56 engines will be upgraded prior to any potential commencement of service in the DCA-San Francisco market.entertain supplemental substantive pleadings in an expedited case such as this one. The

Department was given only ninety days from passage of the FAA Modernization and Reform Act on February 14, 2012, to render its final decision in this case. The Department and its staff should not be burdened with the unprecedented and seemingly unending submission of multiple late comments cast in the form of supplemental pleadings. Each applicant had an opportunity to submit its comments on March 27, and there is no justification for allowing the submission of further unauthorized substantive pleadings. Alaska has not—and will not—submit supplemental pleadings reiterating its March 27 comments or in reply to arguments raised by other applicants. Instead, Alaska will limit any supplemental filings to the submission of supporting letters as all applicants should and as has occurred in all previous beyond-perimeter slot proceedings. Alaska therefore moves the Department to strike the supplemental pleadings of Sun Country, Frontier, Southwest and JetBlue, and any additional supplemental pleadings filed by any party to this proceeding that consist of anything other than letters and statements of support. Respectfully submitted,

________________________________ Marshall S. Sinick, Esq. Marshall.Sinick@squiresanders.com Edward W. Sauer, Esq. Edward.Sauer@squiresanders.com Squire Sanders (US) LLP 1200 19th Street, NW, Suite 300 Washington, DC 20036 (202) 626-6651

DATED: April 10, 2012CERTIFICATE OF SERVICE

I hereby certify that one copy of the foregoing Motions of Alaska Airlines, Inc. has this day been served on each of the following individuals via telecopier or email. susan.kurland@dot.gov ; todd.homan@dot.gov ; james.dann@dot.gov; grady.stone@dot.gov; brian.ctr.meehan@faa.gov john.allen@faa.gov dan.weiss@coair.com ; steve.morrissey@united.com ; jonathan.linde@united.com rbkeiner@crowell.com carl.nelson@aa.com sascha.vanderbellen@delta.com ; jeff.morgan@delta.com jhill@dlalaw.com ; robert.land@jetblue.com jyoung@yklaw.com ; dkirstein@yklaw.com bob.kneisley@wnco.com ; leslie.abbott@wnco.com john.varley@virginamerica.com howard.kass@usairways.com ; benjamin.slocum@usairways.com john.fredericksen@suncountry.com agoerlich@ggh-airlaw.com patrick.rizzi@hoganlovells.com anita.mosner@hklaw.com rick.finn@portofportland.com hbrown@san.org Michael.Daum@cantwell.senate.gov Alexandra.Hackbarth@wyden.senate.gov James.Feldman@begich.senate.gov

______________________________ Marshall S. Sinick DATED: April 10, 2012