BenjaminH. Klein) THE KLEIN FIRMLLC 61 Broadway, Suite 2125 NewYork, NY 10006 Phone: (212) 658-1219 Fax: (646) 368-8401 bklein@thekleinfirm.com UNITED STATES DEPARTMENT OFTRANSPORTATION FEDERAL AVIATIONADMINISTRATION WASHINGTON, DC
Mansfield Heliflight, Inc. Complainant, v. DocketNo. 16-14-06 City ofBurlington, Vermont Respondent. 

### I UNOPPOSED MOTION OFMANSFIELD HELIFLIGHTFORAN EXTENSION OFTIME Complainant Mansfield Heliflight, Inc. ("Mansfield"), by and through the undersigned counsel, and,pursuant to 14 C.F.R. § 16.19 and §16.11(a), hereby requests leave to file and files this motion for a 42-day extension oftime from the current due date to file its reply and answer to Respondent City of Burlington, Vermont's ("City" or "Respondent") Answer, Motion for Summary Judgment, and Motion to Dismiss. In support ofthis motion, Mansfield states as follows: 1. On July 29, 2014, Mansfield filed a Part 16 Complaint ("Complaint") agail}st Respondent. On August 14, 2014, the FAA issued a notice that the Complaint had been docketed. On August 19, 2014, Respondent sought Complainant's consent to a 30-dayextension ofthe period in which it was to answer or otherwise respond to the Complaint, making the due date for such answer, October 3, 2014. Complainant agreed not to oppose Respondent's request, but noted that, due to the undersigned's calendar during the month of October, Mansfield would likely require an extension oftime to reply or answer any papers filed by Respondent on October 3rd. 2. On August 21, 2014, Respondent moved for an extension of time, and by order dated September 5, 2014, Respondent's unopposed motion was granted. On October 2, 2014, Respondent filed its Answer, Motion for Summary Judgment, and Motion to Dismiss. 3. Pursuantto the Part 16 rules ofprocedure, any answer or reply to these filings is due within 10 days of service. 14 C.F.R. §§ 16.23(e), 16.26(b)(3) and 16.26(c)(3). Accordingly, Mansfield'sreply and answer is currently due on October 13, 2014. 4. This request for an extension of time is not being made to delay the proceeding. Respondent has presented a number of issues in its sixty-page Consolidated Answer, Motion to Dismiss, and Motion for Summary Judgment that Mansfield will need to respond to, all ofwhich will require a significant amount oftime to carefully consider. As mentioned above, the undersigned, a solo practitioner, has a significant number of preexisting commitments inthe month ofOctober, not the least ofwhich is the impending birth ofhis first child. Given this, Mansfield believes that a 42-day extension oftime is both necessary and appropriate "for a fair and complete consideration ofthe matters before the agency." §16.11(a).



### 25. On October 3, 2014, the undersigned contacted Pablo 0. Nuesch, counsel for Respondent, who advisedthatthe City would notoppose this request. CONCLUSION Forthe foregoing reasons, Mansfieldrespectfully requests a 42-day extension oftime to file its reply and answerto Respondent's ConsolidatedAnswer, Motion for Summary Judgment, and Motionto Dismiss, making such due onorbefore November 24, 2014. Dated October 3, 2014

Respectfully submitted, BenjaminH. Klein THE KLEINFIRMLLC 61 Broadway, Suite 2125 NewYork, NY 10006 Phone: (212) 658-1219 Fax: (646) 368-8401 bklein@thekleinfirm.com Attorney for Complainant

3CERTIFICATE OF SERVICE I hereby certify that in accordance with 14 CFR §§ 16.15 and 16.13(h), I have this day, the 3rd of October 2014, served the foregoing Motion for extension of time on the following persons by electronic mail: CityofBurlington Attn: Gregg Meyer, Esq. BurlingtonCityAttorney's Office 149 Church Street Burlington, VT 05401 gmeyer@burlingtonvt.gov WilliamF. Ellis McNeil, Leddy & SheahanP.C. 271 SouthUnion Street Burlington, VT 05401 wellisC£Umcneilvt.con1 Pablo 0.Nuesch Spiegel & McDiarmidLLP 1875 Eye Street, NW Suite 700 Washington, DC 20006 pablo.nuesch@spiegelmcd.cotn Attorneys,for Respondent
Dated October3, 2014
BenjaminH. Klein

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