BEFORE THE RECEIVED 

FC::B 19 2015 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. PART 16 DOCKETS 

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. 

FOR AN EX'l'ENSION OF TIME TO ANSWER RESPONDENT'S MOTION FOR 

SUMMARY JUDGMENT 

Communications with respect to this document should be addressed to: 

Keith J. Harrison 

Gerald F. Murphy 

Steven J. Seiden 

CROWELL & MORING LLP 

1001 Pennsylvania Avenue, 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 

Counsel for United Airlines, Inc. 
BEFORE THE 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. 

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. 

FOR AN 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 of time of 30 days (to March 27, 2015) to answer 

Respondent The Port Authority of New York and New Jersey's ("The Port 

Authority") February 10, 2015 Memorandum of Points and Authorities in Support 

of its Motion for Summary Judgment Dismissing the Complaint (the "Motion"). 

Part 16 provides that an extension of time may be granted where necessary or 

appropriate for a fair and complete consideration of matters before the agency. See 

14 C.F.R. § 16.ll(a). 

The Port Authority 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 of Practice 
for 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 of time until March 27, 2015 is necessary and 

appropriate under the circumstances because it will allow United to devote 

sufficient time and resources to adequately review and address the allegations, 

assertions, and reliefrequested in the Motion, which consists of a 41-page 

Memorandum of Points and Authorities, a 20-page Statement of Material Facts, 

three Declarations ranging from 13 to 17 pages, and voluminous Exhibits. United 

notes that the Port Authority was granted a 33-day extension to file a responsive 

pleading to 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 of procedural discretion in this matter. In 

addition, counsel for the Port Authority has indicated that it will not oppose 

United's request to extend the 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 

United Airlines, Inc. 
CERTIFICATE OF SERVICE 

I certify that I have this date served the foregoing Motion of United Airlines, 

Inc. for an Extension of Time to Answer Respondent's Motion for Summary 

Judgment on the following persons via personal service, in accordance with the 

Department's Rules of Practice: 

Chief Counsel 

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 

Port Authority of New York and New 

Jersey 

225 Park Avenue South, 15th Floor 

New York, NY 10003 

Steven J. Seiden