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UNITED STATES OF AMERICA

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, D.C.

FLIGHTLINE GROUND, INC. d/b/a )

FLIGHTLINE FIRST, )

)

Complainant )

)

v. ) DOCKET NO. 16-11-01

)

LOUISIANA DEPARTMENT OF )

TRANSPORTATION AND DEVELOPMENT, )

AS SUCCESSOR TO THE LOUISIANA )

DIVISION OF ADMINISTRATION and THE )

BOARD OF COMMISSIONERS FOR THE )

MANAGEMENT OF THE LAKEFRONT )

AIRPORT; NON-FLOOD PROTECTION )

ASSET MANAGEMENT AUTHORITY, )

AS SUCCESSOR TO THE BOARD OF )

COMMISSIONERS OF THE ORLEANS )

PARISH LEVEE DISTRICT and ORLEANS )

PARISH LEVEE DISTRICT, DIVISION OF )

NON-FLOOD ASSETS )

)

Respondents )

RESPONDENT’S FIRST MOTION TO EXTEND TIME

TO REBUT THE COMPLAINANT’S RESPONSE TO THE

ANSWER OF THE MANAGEMENT AUTHORITY

COMES NOW Respondent, Non-Flood Protection Asset Management Authority,

successor to the Board of Commissioners of the Orleans Levee District and Division of

Administration, State of Louisiana, the governing the authority of the Non-Flood Assets of

the Orleans Levee District (“OLD”) including the New Orleans Lakefront Airport

(“Management Authority” or “Respondent”), through undersigned counsel and, pursuant

to 14 C.F.R. Section 16.19(a), moves to extend the time to rebut Complainant’s Response

to the Answer of the Management Authority based upon the following:
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1.

Complainant’s response to the Answer of the Management Authority contains new

allegations which should have been included in the Complaint and further contains the

Affidavit of Michael A. Hodges which was also not included in the Complaint.

2.

Respondent requires additional time to rebut these new matters brought forth in

Complainant’s Response.

3.

Complainant’s counsel, in an email to opposing counsel on April 8, 2011 asked if

they were amenable to an extension of time until May 3, 2011 in which to file Respondent’s

rebuttal.

4.

Neither counsel for the Louisiana Department of Transportation and Development

nor counsel for Complainant oppose or object to an extension until May 3, 2011.

5.

Counsel for Complainant was allowed two extensions of time to file its Response

to the Answer of the Management Authority.

WHEREFORE, Respondent prays that it be allowed an extension of time to rebut

Complainant’s response to the Answer of the Management Authority until May 3, 2011.
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Respectfully submitted this 13 day of April, 2011. th

GERARD G. METZGER (APLC)

BY: s/Charles T. Curtis, Jr. 

GERARD G. METZGER

EMAIL: gerry@metzgerlawfirm.com

CHARLES T. CURTIS, JR.

EMAIL: ccurtis@metzgerlawfirm.com

829 BARONNE STREET

NEW ORLEANS, LA 70113

TELEPHONE: (504) 581-9322

FACSIMILE: (504) 581-2773

AND

J. E. MURDOCK, III

5034 NEBRASKA AVE.

WASHINGTON, D.C. 20008

TELEPHONE: (202) 333-5986

EMAIL: sandy_murdock@yahoo.com

ATTORNEYS FOR RESPONDENT,

NON-FLOOD PROTECTION ASSET

MANAGEMENT AUTHORITY and

ORLEANS LEVEE DISTRICT,

DIVISION OF NON-FLOOD ASSETS
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CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing Answer on the following

persons at the following address via electronic mail:

Office of the Chief Counsel

Attn: FAA Part 16 Airport Proceedings Docket

AGC-610

Federal Aviation Administration

800 Independence Ave., S.W.

Washington, DC 20591

Email: 9-AWA-AGC-Part-16@faa.gov

Alan Armstrong, Esq.

2900 Chamblee-Tucker Road

Building 5, Suite 350

Atlanta, GA 30341

Email: alan@alanarmstronglaw.com

Counsel for Complainant,

Flightline Ground, Inc. d/b/a Flightline First

Brandon Brown, Esq.

1201 Capital Access Road

Baton Rouge, LA 70804

Email: brandon.brown@la.gov

Counsel for Respondent,

Louisiana Department of Transportation and Development

Dated this 13 day of April, 2011. th

 s/Charles T. Curtis, Jr. 

CHARLES T. CURTIS, JR.

Counsel for Respondent, Non-Flood Protection 

Asset Management Authority and Orleans Levee District,

Division of Non-Flood Assets