U.S. Department ofTransportation Federal Aviation Administration Office ofthe Chief Counsel

NOTICE OF DOCKETING 800 Independence Ave., S.W. Washington, D.C. 20591

Please be advised that the complaint filed on behalfofJet Center Partners, LLC, ("Complainant") against the County ofMontrose, Colorado ("Respondent") filed under the Rules ofPractice for Federally Assisted Airport EnforcementProceedings, Title 14 ofthe Code ofFederal Regulations part 16 (14 CFRpart 16), has been docketed by the Federal Aviation Administration's (FAA) Office ofthe ChiefCounsel, as DocketNo. 16-15-11, on August 26, 2015.
The Respondent is required to file an answer to the complaint within 20 days ofthe date of service ofthis notice. See 14 CFR § l6.23(d). The answer shall deny or admit the allegations made in the complaint and shall assert any affirmative defenses.
In lieu ofan answer, the Respondent may file a motion to dismiss the complaint or a motion for summaryjudgment onthe complaint. See 14 CFR 

### § 16.26. The Respondent may move for dismissal ofthe entire complaint or move for dismissal ofspecific issues from adjudication. The motion mustbe filed within 20 days after the date ofservice ofthis notice ofdocketing. See 14 CFR 

### § 16.26. Ifsuch a motion is filed under 

### § 16.26, an answer mustbe filed within 20 days ofthe date ofservice ofan FAA order denying all orpart ofthat motion. See 14 CFR 

### § 16.23(d).
The Complainantmay file a reply within 10 days ofthe date ofservice ofthe answer. The Respondent may file a rebuttal within 10 days ofthe date ofservice ofthe Complainant's reply. See 14 CFR 

### § 16.23( e

### )-(f). The answer, reply, and rebuttal, like the complaint, shall be accompanied by supporting documentation upon which the parties rely. The answer, reply, and rebuttal shall each contain a concise but complete statement ofthe facts relied upon to substantiate the answers, admissions, denials, or averments made. See 14 CFR 

### § 16.23(g), (i). Amendments or supplements to the pleadings will not be allowed without showing good
cause through a motion and supporting documents. See 14 CFR § 16.23G).
All documents filed with the FAA in this proceeding shall be served (and include a certificate ofservice) bythe persons filing them on all parties to the proceeding, and with the Office of the ChiefCounsel as follows: FAA Part 16 Docket Clerk, AGC-600, Federal Aviation Administration, 800 Independence Avenue SW, Washington, DC 20591. See 14 CFR §§ 16.13, 16.15. With the exception ofelectronic filing or unless otherwise specified, an executed original and three copies ofeach document shall be filed with the Part 16 Docket Clerk. One ofthe three copies shall not be stapled, bound or hole-punched. See 14 CFR 

### § 16.13( c).Pursuant to 14 CFR 

### § 16.13(h), electronic filing ofpart 16 documents is permitted under the following guidelines:

• Parties may send e-mails containing their pleadings as an attachment. The attachment(s) shall be Adobe PDF file(s). The subject line ofthe e-mail must containthe names ofthe complainant andrespondent, as well as the FAA docket number, ifassigned. The size ofthe email may not exceed 10MB.

• E-mail filings shall be sentto the FAA Docket Clerk at 9-AWA-AGC-Part16@faa.gov and the opposing party (only ifthe opposing party has agreed with the complainant in writing to participate in electronic filing; otherwise service mustbe made pursuant to 14 CFR 

### § 16.15). The FAA will not provide any acknowledgement orreceipt to parties filing electronically.

• A party filing electronically must provide the FAA Docket Clerk and the opposing party an e-mail address designating its representative to receive electronic pleadings and documents by e-mail.

• A party availing itselfofelectronic filing as described in this document and 14 CFR 

### § 16.13(h) waives its rights under part 16 to service by any other means from the opposing party or FAA. 2

• A party filing electronically will include with its pleadings a certificate ofservice stating the method as electronic by or via e-mail. Inregard to computation of time, the date ofthe e-mail is not included inthe computation oftime under this part. 

### See 14 CFR 

### § 16.17(a). Parties will start the count as ofthe day following the date the e-mail was sent. 1
The Department ofTransportation (DOT) uses the government-wide Federal Docket Management System (FDMS) at http://www.regu1ations.gov. Accordingly, iffiling paper documents withthe FAA, 

### please ensure that at least one ofthe required copies is unbound and without tabs. Exhibit numbers in unbound copies should be noted on the first page ofeach exhibit or in divider pages. The FAA will forward all electronic submissions (like the paper submissions) to FDMS for public viewing.

### 1·.**~ (~**  · · . • · 1

### /,v{-?,--== , Eliza ethNewrn Senior Attorney, Airport Law Branch Office ofthe ChiefCounsel

1This paragraph exempts only the parties from the filing requirements under 14 CFR § 16.13(a)-(c). Ifa party subsequently decides to "opt-out" ofelectronic filing, it must notifY the FAA Docket Clerk and opposing party in writing. See 14 CFR § 16.13(h)(4). The electronic filing method may be used in lieu ofor in addition to the existing requirements set forth in part 16.CERTIFICATE OF SERVICE



### I HEREBY CERTIFY that on , I caused to be placed in the United States Mail (first class mail, p tage paid) orpersonally delivered a true copy ofthe foregoing NOTICE OF DOCKETING ad' essed to:
Counsel for Complainant
Leonard D. Kirsch Shelley A. 

### Ewalt McBreen & 

### Kopko 500 North Broadway Jericho, NY 11753 Respondent Lloyd Arnold Director ofAviation Montrose Regional Airport 2100 Airport Road Montrose, CO 81401
Counsel for Respondent

Bobbee J. Musgrave Bryan Cave LLP 1700 Lincoln Street, Suite 4100 Denver, CO 80203-4541
Hand-Delivered to:
FAA Part 16 Airport Proceedings Docket (AGC-600) FAA Office ofAirport Compliance and Management Analysis (AC0-100)

Christopher Huch Airports & 

### Environmental Law Division FAA Office ofthe ChiefCounsel 3