Benjamin H. Klein) 

THE KLEIN FIRM LLC 

61 Broadway, Suite 2125 

New York, NY 10006 

Phone: (212) 658-1219 

Fax: (646) 368-8401 

bklein@thekleinfirm.com 

UNITED STATES DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Mansfield Heliflight, Inc. 

Complainant, 

v. Docket No. 16-14-06 

City of Burlington, Vermont 

Respondent. 

I 

UNOPPOSED MOTION OF MANSFIELD HELIFLIGHT FOR AN 

EXTENSION OF TIME 

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 of time 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 of this 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-day 
extension of the 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 of time 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. Pursuant to the Part 16 rules of procedure, 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's reply 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 of which will require a significant amount of time to carefully consider. As 

mentioned above, the undersigned, a solo practitioner, has a significant number of preexisting commitments in the month of October, not the least of which is the impending birth 

of his first child. Given this, Mansfield believes that a 42-day extension of time is both 

necessary and appropriate "for a fair and complete consideration of the matters before the 

agency." §16.11(a). 

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5. On October 3, 2014, the undersigned contacted Pablo 0. Nuesch, counsel for 

Respondent, who advised that the City would not oppose this request. 

CONCLUSION 

For the foregoing reasons, Mansfield respectfully requests a 42-day extension of time 

to file its reply and answer to Respondent's Consolidated Answer, Motion for Summary 

Judgment, and Motion to Dismiss, making such due on or before November 24, 2014. 

Dated October 3, 2014 

Respectfully submitted, 

Benjamin H. Klein 

THE KLEIN FIRM LLC 

61 Broadway, Suite 2125 

New York, NY 10006 

Phone: (212) 658-1219 

Fax: (646) 368-8401 

bklein@thekleinfirm.com 

Attorney for Complainant 

3 
CERTIFICATE 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: 

City of Burlington 

Attn: Gregg Meyer, Esq. 

Burlington City Attorney's Office 

149 Church Street 

Burlington, VT 05401 

gmeyer@burlingtonvt.gov 

William F. Ellis 

McNeil, Leddy & Sheahan P.C. 

271 South Union Street 

Burlington, VT 05401 

wellisC£Umcneilvt.con1 

Pablo 0. Nuesch 

Spiegel & McDiarmid LLP 

187 5 Eye Street, NW 

Suite 700 

Washington, DC 20006 

pablo.nuesch@spiegelmcd.cotn 

Attorneys, for Respondent 

Dated October 3, 2014 

Benjamin H. Klein 

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