Denis Law ~" . c· f . --~M=ayo2r' ______ ,_,._..···· 1":~·". '. · ·. Ity O /!~ " ·I '

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Office of the City Attorney - Lawrence Jc Warren 

Senior.Assistant City Attorneys 

Mark Barber 

Zan etta L. Fontes 

Garmon Newsom II" 

RECEIVED. ' " ' 

FEB 2 42015 

Prosecuting Attorneys 

Shawn E. Arthur 

Alex Tuttle 

EddieJ.Aubrey 

Iva Clark 

17February2015 . PART16 DOCKETS 

Office of the ChiefCounsel 

Attention FAA PART 16 Docket Clerk, AGC-600 · 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, DC 20591 

RE: ' Request for Extension to Answer Part 16 Complaint 

Pro-Flight Aviation v .. City of Renton. Docket# 16-15-03 

Dear Sir or Madam: 

I am in r~ceipt of the Notice of Docketing, dated 5 February 2015, sent vi.a UnitedStates Postal Service. · 

Pursuant to 14 c'FR 16.17 (c), Renton hasan additional five days to resp9nd to the Compl~int, making 

the due date, 3 March 2015. fwrite to ask for an extension of time for the filing of the City's Answer. I .·. · 

am asking for a twelve (12) week extension to May 26, 2015. My reasons follow: . 

1. Our City Attorney's office is currently understaffed due to the recent departure of a 

Senior Assistant CityAttorney:- Those of us who remain are filling in to cover the 

· projects that had been assigned to our formeremployee before his departure. 

2 .. The Renton Municipai'Airport is also experiencing a temporary reduction in personnel. 

Recently, two members of the four person office left Renton's employ; to join the 

Federal Aviation Administration.(FAA). This re~ults ina reduction in staff time availabl~ . 

to find arid collect the supporting docurr1entation to submit with the CitY's Answer: 

. . . 

3. Another time consuming aspect relates to the fact that two former .members of the 

Airport's staff have left the city's employ to join the FAA. One of those former 

employees is Ryan Zulauf, the former Airport Manager. His name.appears frequently in 

the materiiJ.Is submitted by Complainant. Renton will need to inte'rview Mr. Zulauf to 

determine what information he has to bear 0 n this Part 16 Complaint. Renton might 

n~ed to secure te.stimciny from Mr. Zulauf. In order to do that, we need to seek· 

permission from the FAA Administrator: And, while Mr. Zulaufs testimony would be. 

related to his factual knowledge from his time with the City rather than in his' capacity as. 

1055 South Grady Way • Renton, Washington 98057 • (425)430-6480 I Fax (425) 430-6498 • rentonwa.gov 
Office of the Chief Counsel 

17 February 2015 

Page 2 of2 

an employee of the FAA (so, I am hopeful that permission will be granted), we do need 

to seek that permission. And, in the event we are not able to secure that permission, 

we will need the additional time to determine other means to obtain admissible 

evidence.· 

4. Prior to the Complainant's filing of this Complaint, Renton and the Complainant had 

arrived at a possible resolution. ·However; that proposal required cooperation from 

Boeing. Renton attempted to initiate discussion with Boeing's property management 

personnel. However, due to a misunderstanding on Boeing's part, a meeting was not 

scheduled prior to the filing of the Complaint. Now that the Part 16 Complaint has been 

filed, a different avenue of discussion is available. This office has been in contact with 

Boeing's attorney and we have started to disc.uss a plan with Boeing, which plan is. 

consistent with. the proposal to which the Complainant had previously agreed. This 

negotiation process with Boeing will take time. And, at this time, it is not clear whether 

the proposal to which the Complainant was agreeable before the filing of the Complaint 

will still be acceptable now. So, negotiations between the three parties will take time. 

I recognize that I am asking for a long extension. It just so happens that the timing of this Part 16 

Complaint comes when we face some unique problem~; .Consequently, Renton is a:Skingfor a twelve 

(12) week extension to May 26, 2015. Thankyou for your kind consideration of this request. 

cc: Jay Covington, CAO 

Gregg Zimmerman, PW Administrator 

Jonathan Wilson, Airport Ma·nager 

Lawrerice J. Warren, City Attorney 

Bernard Paholke, Complainant· 

YftFV"'\-r-tJ_Iy yours, 

// . I ~-/?./ . . . / ·7;£/.::tc-Lx;~ ! . ·· ~~~tta L. Fontes \J ior Assistant City Attorney . 
Office of the City Attorney - Lawrence J. Warren . 

Senior.Assistant City Attorneys 

Mark Barber 

Zanetta L. Fontes 

Garmon Newsom II 

Prosecuting Attorneys 

Shawn E. Arthur 

. AlexTuttle · Eddie J.Aubrey 

Iva Clark 

CERTIFICATE OF SERVICE 

I hereby certify that I have this day served the foregoing letter by United States Post01 Service, 

regulor mail/requesting an ext~nsion to Answer the Part 16 Complaint, on the following persons atthe 

following addresses by United States Postal Service: 

Office ofthe Chief Counsel 

Attention FAA PART 16 Docket Clerk, AGC-600 

Federal Aviation Administration 

800 Independence Avenue.SW 

Washington, DC 20591 · 

Arid 

Bernard Paholke 

Pro-Flight Aviation, Inc. 

750Perimeter Road, Unit #1 

Renton, WA 98057 

. Dated this 1-7'" day of February, 20).5 

··~ .. '73('.•.· .. ·······.··.··.·.·'· .. · .... ·· ( -~ . '_L........- . r. r~ 

/ •_ ~~ -,c·~) 

Zan tta L. Fontes 

S ior Assis_tant City Attorney 

1 055 South Grady Way • Renton,Wasbington 98057 • (425) 430-6480 I Fax (4;5) 430·6498 • rentonwa.gov