Denis Law

**~"** . 

# c· f .



# --~M=ayo2r'

# ______,_,._..····

**1":~·".** 

# '. · ·. Ity O



# /!~ 

# "·I ' 1;;·•



# r~:it::l~ **F<tj,'·iJ[,/-~-,~~** 

# .)

**J>~.~JJlJ,l1}.~J,;**'!.J. jj

Office ofthe CityAttorney - Lawrence JcWarren Senior.Assistant CityAttorneys Mark Barber ZanettaL. Fontes Garmon Newsom II" 

# RECEIVED.

' " ' 

## FEB 

## 242015 Prosecuting Attorneys Shawn E.Arthur AlexTuttle EddieJ.Aubrey Iva Clark 17February2015 

### .PART16 DOCKETS Office ofthe 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-FlightAviation 

### v.. City of Renton. Docket# 16-15-03 DearSiror Madam: I am in



## r~ceipt ofthe Notice of Docketing, dated

### 5 February2015, sent vi.a UnitedStates Postal Service. · Pursuantto 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 toaskfor an extension oftime for the filing ofthe City's Answer. I .·. · am asking for atwelve (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 thathad been assigned toourformeremployee 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 stafftime



### availabl~ . tofind arid collect the supporting docurr1entation to submit with theCitY'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 formerAirportManager. His name.appears frequently in the materiiJ.Is submitted by Complainant. Renton will need to inte'rviewMr. Zulauf to determinewhat 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 withthe City ratherthan in his' capacity as.
1055 South GradyWay • Renton,Washington 98057 • (425)430-6480 I Fax (425)430-6498 • rentonwa.govOffice ofthe 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 ofthe Complaint. Nowthat 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 whichthe Complainant was agreeable before the filing ofthe Complaint will still be acceptable now. So, negotiations between the three parties will taketime. I recognize that I am asking for a long extension. Itjust so happens thatthe timing ofthis Part 16 Complaint comes when we face some unique

**problem~;** .Consequently, Renton is a:Skingfor a twelve (12) week extension to May26, 2015. Thankyou foryour kind consideration ofthis 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 iorAssistant City Attorney .Office ofthe CityAttorney - 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

Ihereby certify that I have this day served the foregoing letter by United States Post

### 01 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 iorAssis_tant City Attorney

1055South GradyWay • Renton,Wasbington 98057 • (425) 430-6480 I Fax (4;5) 430·6498 • rentonwa.gov