BEFORE THE U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. RECEIVED 

) 

VIRGINIA ONE DEVELOPMENT, LLC, et al., ) 

) 

Complainants, ) 

) 

v. ) 

) 

THE CITY OF ATLANTA, GEORGIA, ) 

) 

Respondent. ) 

_____________________________) 

MAR 1 0 2015 

PART 16 DOCKETS 

FAA Docket No. 16-12-09 

RESPONDENT THE CITY OF ATLANTA, GEORGIA'S CONSENTED MOTION FOR 

EXTENSION OF TIME TO FILE BRIEF IN RESPONSE TO APPEAL 

Respondent, the City of Atlanta, Georgia ("City of Atlanta"), by and through its 

undersigned counsel, pursuant to 14 C.F.R. § 16.19(e), respectfully moves for a short extension 

of time up to and including April 7, 2015, in which to file its brief in response to the appeal brief 

filed by Complainants Virginia One Development, LLC, R. W. Parsons, Inc. d/b/a Clubhouse, D. 

Scott Henderson d/b/a Avery Park, Colony Camp Creek, LLC, and Crossing Townhomes, LLC 

(collectively, "Complainants"). In support of its motion, Respondent states as follows: 

1. On January 26, 2015, the Director of the Office of Airport Compliance and 

Management Analysis issued his Determination dismissing Complainants' Part 16 proceeding 

and finding that the City of Atlanta is not in violation of its federal obligations set forth in its 

airport grant assurances and existing federal statutes. 

2. On February 25, 2015, Complainants filed their Appeal from the Director's 

Determination ("Appeal Brief') and served their Appeal Brief on counsel for the City of Atlanta 

via electronic mail. 
3. Title 14 C.F.R. § 16.33(d) provides that "[a] reply to an appeal brief may be filed 

within 20 days after the date of service of the appeal." 

4. Accordingly, the City of Atlanta's reply to Complainants' Appeal Brief IS 

currently due on March 17,2015. 

5. Title 14 C.F.R. § 16.19(e) allows a pmiy to seek an extension of time provided 

that a written motion seeking such an extension is filed at least three business days before the 

document is due. 

6. Given the many argmnents set forth in Complainants' Appeal Brief and the 

voluminous record associated with this proceeding, the City of Atlanta requires additional time 

beyond the twenty-day period established in 14 C.F.R. § 16.33(d) to prepare the City of Atlanta's 

responsive brief. 

7. Accordingly, the City of Atlanta respectfully requests an extension of twenty-one 

days up to and including April 7, 2015, in which to file its responsive brief to Complainants' 

Appeal Brief. 

8. By electronic mail dated Mm·ch 4, 2015, Complainants' counsel Steven Taber, 

indicated that Complainants consent to an extension of time up to and including April 7, 2015, 

for the City of Atlanta to file its responsive brief. 

WHEREFORE, Respondent, the City of Atlanta, Georgia, respectfully requests an 

extension of time up to and including April 7, 2015, in which to file its responsive brief to 

Complainants Appeal Brief. 
Dated: March 6, 2015 

Respectfully submitted, 

THOMPSON HINE LLP 

By L7~ 

John L. Watkins 

Georgia BarNo. 740515 

john. watkins@thompsonhine.com 

Roy E. Hadley, Jr. 

Georgia Bar No. 003730 

rov.hadley@thompsonhine.com 

Two Alliance Center 

3560 Lenox Road, Suite 1600 

Atlanta, Georgia 30326-4266 

Phone: (404) 541-2900 

Fax: (404) 541-2905 

Eric N. Heyer 

District of Columbia Bar No. 500095 

eric.heyer@.thompsonhine.com 

1919 M Street, N.W., Suite 700 

Washington, D.C. 20036 

Phone: (202) 331-8800 

Fax: (202) 331-8330 

Counsel for Respondent, 

The City of Atlanta, Georgia 
CERTIFICATE OF SERVICE 

I hereby ce1iif)' that on this 6th day of March, 2015, I caused a true and correct copy of 

the foregoing Consented Motion for Extension of Time to be served via electronic mail and first 

class mail, postage prepaid, on the following: 

Steven M. Taber, Esq. 

TABERLAWGROUP, P.C. 

1 League, #6003 6 

Irvine, California 92602 

staber@taberlaw.com 

Counsel for Complainants 

Eric N. Heyer