1 UNITED STATES OF AMERICA

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

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. )

COMPLAINANT’S SECOND MOTION TO E XTEND TIME

TO RESPOND TO THE ANSWER OF THE MANAGEMENT AUTHORITY

COME S NOW, Flightline Ground, Inc., Complainant in the above

- captioned matter,

pursuant to 14 C.F.R. § 16.19(a) and moves to extend the time to respond to the Answer of the

Non

- Flood Protection Asset Management Authority, as successor to the Board of Commission ers

of the Orleans Parish Levee District and Orleans Parish Levee District Division of Non

- Flood

Assets (the “Management Authority”) based upon the following :

1

.

A matter arose beyond the control of Complainant’s counsel precluding a complete

Response to the Answer of the Management Authority being served by Monday, April 4, 2011.2 2

.

Complainant ’ s counsel, in an e

- mail to opposing counsel of March 27, 2010, asked if

they objected to Complainant having a short extension until April 7, 2011.

3

.

Neither counsel for the Management Authority nor counsel for the Louisiana Department

of Transportation and Development oppose or object to an extension whereby the Complain ant

may file its Response to the Answer of the Management Authority by Thursday, April 7 , 2011.

WHEREFOR E, Complainant prays t hat the Complainant have an extension of time to

respond to the Answer of the Management Authority until Monday, April 4, 2011

.

Respectfully submitted, this 2 8 th day of March, 2011.

s / Alan Armstrong

____________________________________ Alan Armstrong

Georgia Bar No. 022075

Counsel for Complainant

Alan Armstrong Attorney at Law

2900 Chamblee Tucker Road

Building 5, Suite 350

Atlanta, Georgia 30341

P: 770.451.0313

F: 770.451.0317

alan@alanarmstronglaw.com3 CERTIFICATE OF SERVICE

I hereby certify that the foregoing C omplainant’s Second M otion to Extend Time to Respond to

the Answer of the Management Authority h as been served upon Brandon Brown, Esq., Counsel for the

Louisiana Department of Transportation and Development via electronic mail at brandon.brown@la.gov

and also that a copy of same has been served upon Charles Curtis, Esq. , by electronic mail at

ccurtis@metzgerlawfirm. com

, counsel for the Non

- Flood Protection Asset Management Authority (the

“authority”) and also Gerard Metzger, Esq., counsel for the A uthority be electronic mail at

gerry@metzgerlawfirm.com

.

This the 2 8 th day of March , 201 1

.

s / Alan Armstrong

________________________________ Alan Armstron g Alan Armstrong Attorney at Law

2900 Chamblee Tucker Road

Building 5, Suite 350

Atlanta, Georgia 30341

P: 770.451.0313

F: 770.451.0317

alan@alanarmstronglaw.com