### BEFORE THE 

## RECEIVED FC::B 

## 19 2015 FEDERALAVIATION ADMINISTRATION WASHINGTON, D.C. PART 

### 16DOCKETS

UNITED AIRLINES, INC., Complainant, v. 

### THE PORT AUTHORITY OF NEW YORK AND NEW JERSEY, Respondent. Docket FAA-16-14-13



### MOTION OF UNITED AIRLINES, INC. FORAN EX'l'ENSION OF TIME TO ANSWER RESPONDENT'S MOTION FOR SUMMARY JUDGMENT Communications withrespect to this document shouldbe addressed to: Keith

### J. Harrison Gerald 

### F. Murphy Steven

### J. Seiden 

### CROWELL & 

### MORING LLP 1001 PennsylvaniaAvenue, NW Washington, DC 20004 (202) 624-2500 RobertS. Span Alan 

### K. Steinbrecher Sophy Chen 

### STEINBRECHER & 

### SPAN LLP 1155 F Street, N.W., Suite 1050 Washington, DC 20004 (202) 559-8680 rspan@steinbrecherspan.com



### Counselfor UnitedAirlines, Inc.BEFORE THE FEDERALAVIATION ADMINISTRATION WASHINGTON, D.C.

UNITED AIRLINES, INC., Complainant, v. THE PORTAUTHORITY OF NEW YORK AND NEWJERSEY, Respondent. Docket FAA-16-14-13

MOTION OF UNITED AIRLINES, INC. FORAN EXTENSION OF TIME TO ANSWER RESPONDENT'S MOTION FOR SUMMARY JUDGMENT Complainant United Airlines, Inc. ("United") hereby moves pursuant to 14 C.F.R. 

### § 16.19(e) for an extension oftime of30 days (to March 27, 2015) to answer Respondent The PortAuthority ofNew York and New Jersey's ("The Port Authority") February 10, 2015 Memorandum ofPoints and Authorities in Support ofits Motion for SummaryJudgment Dismissing the Complaint (the "Motion"). Part 16 provides that an extension oftime maybe granted where necessary or appropriate for a fair and complete consideration ofmatters before the agency. 

### See 14 C.F.R. 

### § 16.ll(a). The PortAuthority filed the Motion with the FAA on February 10, 2015 and served it on United's counsel via U.S. mail. Accordingly, under the Rules ofPracticefor Federally-Assisted Airport Enforcement Proceedings, the last date for United to
answer the Motion is 10 days after February 10 (see 14 C.F.R. 

### § 16.19(c)), plus five additional days because the Motion was served by mail (see 14 C.F.R. 

### § 16.17(c)), or February 25, 2015. An extension oftime untilMarch 27, 2015 is necessary and appropriate under the circumstances because itwill allow Unitedto devote sufficient time and resources to adequately review and address the allegations, assertions, andreliefrequested inthe Motion, which consists ofa 41-page Memorandum ofPoints and Authorities, a 20-page Statement ofMaterial Facts, three Declarations ranging from 13 to 17 pages, and voluminous Exhibits. United notes thatthe PortAuthority was granted a 33-day extension to file a responsive pleadingto United's December 10, 2014 Complaint. 

### See FAA Order dated January 6, 2015 in this docket. Accordingly, granting United's request herein would be consistent with FAA's past exercise ofprocedural discretion in this matter. In addition, counsel for the PortAuthority has indicated that it will not oppose United's request to extendthe February 25, 2015 deadline to March 27, 2015. For the foregoing reasons, United respectfully requests that the deadline for United to file an answer to the Motion be extended to March 27, 2015.

2

### February 18, 2015

3 

### Respectfully submitted,



# !2iJ"S~~ ' Robert S. Span Alan K. 

### Steinbrecher Sophy Chen STEINBRECHER & 

### SPAN 

### LLP 1155 F Street, N.W., Suite 1050 Washington, DC 20004 (202) 559-8680 rspan@steinbrecherspan.com

Counsel for UnitedAirlines, Inc.

### CERTIFICATE OF SERVICE
I certify that I have this date served the foregoing Motion ofUnitedAirlines, Inc. for an Extension ofTime to Answer Respondent's Motion for Summary Judgment on the following persons via personal service, in accordance withthe Department's Rules ofPractice: ChiefCounsel Attn: FAA Part 16 Docket Clerk AGC-600 Federal Aviation Administration 800 Independence Ave., SW Washington, DC 20591

February 18, 2015 Carlene V. Mcintyre, Esq. Assistant General Counsel PortAuthority ofNew York and New Jersey 225 ParkAvenue South, 15th Floor New York, NY 10003

Steven J. Seiden