OCT. 19.2012 4:29PM GRAY ROBINSON PA N0.7132 P. 2 

JEP.!J,RTMENT OF ~ ilANSPORTATlON "~·'"'vrT onp:Hl.TlQt,jQ U.S.DEPART:MENT OF TRANSPORTATION:: \. r _I ln •• IHJ 

OFFICE OF HEARINGS ,., 

FEDERAL AVIATION ADMINISTRATieNOL T 2 b p 2: 2 3 

FEDERAL AVIATION ADJv.IINISTRATION, 

Complainant, 

vs. 

BRAILLE BATTERY, INC., 

Respondent. 

FAA Docket No. [to be assigned] 

FAA Case No. 201180700298 

FDMS No. FAA-201200781 

MOTION FOR EXTENSION OF TIME TO FILE RESPONSIVE PLEADING 

Respondent, BRAILLE BATTERY, INC. (hereinafter "Respondent"), by and through its 

undersigned counsel, and pursuant to 14 CFR Section 13.213, hereby files its Motion for 

Extension of Time to File a Responsive Pleading (the "'Motion") and in support states as follows: 

L On or about June.29, 2012, Respondent filed its request for a hearing. 

2. On July 10,2012, Petitioner, FEDERAL AVIATION ADMINISTRATION 

(hereinafter "Petitioner"), served the Respondent with a Complaint (the "Complainf'). 

3. On or about August 8, 2012, Respondent filed a motion for extension of time 

requesting an additional six:ty ( 60) days to file an answer or appropriate motion pursuant to 14 

CFR Section 13209. Said motion requested an extension of time to October 15, 2012. 

4. The undersigned subsequently received an Order entered by this Court setting 

forth the deadline of October 25,2012 to conduct a Rule 26(f) planning meeting and prepare a 

jointly written proposed scheduling/discovery plan. The undersigned interpreted and calendared 

the October 25,2012 deadline as the deadline to file an answer or responsive pleading. 
OCT.19.2012 4:29PM GRAY ROBINSON PA NO. 7132 P. 3 

5. In atl abundance of caution, Respondent is filing this motion to ensure the 

Respondent's Answer is appropriately filed and considered by the Administrative Law Judge. 

6. Petitioner faxed a settlement offer to Respondent on October 12, 2012, and 

Respondent is considering said offer. 

7. Petitioner and Respondent are in settlement discussions) and we believe the 

parties are optimistic that a settlement can be achieved. In light of the likelihood of settlement, 

granting the request for extension of time is appropriate. 

8. Respondent has not filed this Motion for the purpose of delay, and Petitioner will 

not be prejudiced by the Administrative Law Judge's grant of the relief requested. 

WHEREFORE, Respondent respectfully requests the Administrative Law Judge, to the 

extent required, grat;tt an extension of time to file its response pmsuant to 14 CPR Section 13.209 

to the date of this motion and the accompanying Answer and for such further relief as the 

Administrative Law Judge deems just, equitable and proper. 

2 

CHARLES R. FLETCHER, ESQ. 

Florida Bar No. 0093920 

charles.fletcher@gray-robinson.com 

GRA YROBINSON, P.A. 

201 N. Franklin Street, Suite 2200 

Tamp~ Florida 33602 

(813) 273-5000 

Fax: (813) 273-5145 

Attorneys for Respondent 
OCT.19.2012 4:29PM GRAY ROBINSON PA N0.7132 P.4 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished 

via electronic transmission (Gerald.Ellis@faa.gov) and via U.S. Mail to Gerald A- Ellis, Esq., 

Office of the Regional Counsel, AS0-7, Federal Aviation Administration, P.O. Box 20636, 

Atlanta, GA 30320 and via facsimile transmission (202-493-5142) and FedEx to the following 

this on this t114ia.y of October, 2012: 

Federal Aviation Administration (original+ 1 copy) 

600 Independence Avenue, SW 

Wilbur Wright Building-. Suite 2Wl000 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

# 350816& vl 

Attorney 

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