FAA Part 16 Docket Clerk 

AGC-600 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, DC 20591 

June 5 2015 

HOWARD C. JONES II 

ATTORNEY AT LAW 

howardcjones@attglobal.net 

105 WEST FOURTH STREET, SUITE 400 E 

WINSTON-SALEM, NC 27101 

TELEPHONE: 336.750.0860 

FAX: 336.727.1085 

Rr=CEIVED 

JUN 9 2015 

PART 16 DOCKETS 

Re: William Alfred Hicks, Jr. A/KIA Billy Hicks V. City Of Mount Airy, North 

Carolina; And The County Of Surry, North Carolina; Through The Mount Airy/Surry 

County Airport Authority; FAA Docket No. 16-15-07 

Dear FAA Part 16 Docket Clerk: 

Enclosed please find an original and three copies (one of which has not been 

stapled) of respondents' Consent Motion for Extension of Time (with attached certificate 

of service) and U"proposed order. 

Thank for your consideration of this matter 

Sincerely, 

Ho 

cc: counsel of record 
UNITED STATES DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

WILLIAM ALFRED HICKS, JR. 

a!k/a BILLY HICKS 

Complainant, 

vs. 

CITY OF MOUNT AIRY, NORTH 

CAROLINA; and the COUNTY OF SURRY, 

NORTH CAROLINA; through the MOUNT 

AIRY/SURRY COUNTY AIRPORT 

AUTHORITY 

Respondent. 

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FAADocketNo. 16-15-07 

CONSENT MOTION FOR 

EXTENSION OF TIME 

RECEIVED 

'JUN 9 2015 

PART 16 DOCKETS 

The City of Mount Airy, the County of Surry and the Mount Airy/Surry County Airport 

Authority (hereinafter jointly referred to as "respondents") hereby jointly move this tribunal for 

an order granting each of these respondents an extension of time to respond to the complaint and 

as grounds therefore state: 

'' 

1. Undersigned counsel represent that they have conferred with counsel of record for 

the complainant, Randolph M. James, and obtained consent for this motion. A copy of the email 

confirming consent is attached hereto as Exhibit 1. 

2. Undersigned counsel represent that this motion is made in good faith and not for 

the purpose of delay. 

3. On M;1y 26 2015, the Office of the Chief Counsel served the Mount Airy/Surry 

County Airport Authority with a Notice of Docketing of the Part 16 complaint in this matter by 

I 
mail. Without an extension (and including the five days for mailing), respondents would have 

until Saturday June 20, or Monday June 22 to file a response to the complaint. 

4. Undersigned counsel need additional time to prepare their responses to the 

complaint. In addition to being 49 pages long and having voluminous exhibits, the complaint 

asserts multiple areas of alleged failure to comply with grant assurances. For these reasons, 

undersigned counsel. need additional time prepare a response to the complaint. Undersigned 

counsel also need additional time to coordinate between their respective clients - the City of 

Mount Airy, the County of Surry and the Mount Airy/Surry County Airport Authority, in order 

to try and consolidate (where feasible) their responses. 

WHEREFORE, the City of Mount Airy, the County of Surry and the Mount Airy/Surry 

County Airport Authority respectfully request that this tribunal grant each of these respondents 

an extension of time through and including August 3, 2015 for each respondent to file their 

responses to the complaint by answer or appropriate motion(s) under 14 CPR 16.23 or 16.26 and 

such other relief as this tribunal deems just and proper. 

Respectfully submitted, this the 5th/ y of June 2015. 

Ho 

105 Wes ourth Street 

Suite 40 -E 

Winston-Salem, NC 2710106 

Telephone: (336) 750-0860 

Fax: (336) 727-1085 

-~-"-~------

Email: howardcjonesii@gmail.com 

Attorney for Mount Airy/Surry County Airport Authority 

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Edwin M. Woltz Attorney at Law PLLC 

· · 119 Rawley Avenue 

Mount Airy, NC 27030 

Telephone: (336) 786 5556 

Fax: (336) 789 0651 

Email: woltz@woltzlaw.us 

County Attorney for County of Surry, North Carolina 

3 
"(,?lim]) bell Law Group, PLL,C 

E, Independence Blvd. 

PO Box 1846 

Mount Airy, North Carolina 27030 

Phone: (336) 719-1700 

Fax: (336) 719-1703 

Email: hugb(q),clgnc.com 

City Attorney f(Jr City of Mount Airy, North Carolina 

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CERTIFICATE OF SERVICE 

I, Howard C. Jones II, certifY that on June 5 2015 I filed and served this CONSENT 

MOTION FOR EXTENSION OF TIME and the PROPOSED ORDER for the same by 

placing the original thereof and three copies to the FAA, and a copy to counsel of record, in 

prepaid first class or express envelopes in the custody of the United States Mail addressed as 

follows: 

FAA Part 16 Docket Clerk 

AGC-600 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, DC 20591 

Randolph M. James 

Attorney for Plaintiffs 

Randolph M. James, P.C. 

P.O. Box 20069 

Winston-Salem, NC 27120 

Attorney For Complainant 

Edwin M. Woltz 

119 Rawley A venue 

Mount Airy, NC 27030 

Attorney for the County of Surry, North Carolina 

Hugh B. Campbell;m 

235 E. Independence Blvd. 

PO Box 1846 

Mount Airy, North Carolina 27030 

Attorney for the City of Mount Airy, North Carolina 

5 
Friday, June 5, 2015 at 7:52:03 AM Eastern Daylight Time 

Subject: RE: Hicks 16-15 

Date: Tuesday, June 2, 2015 at 6:47:03 PM Eastern Daylight Time 

From: Randy James 

To: howardcjonesii@gmail.com 

CC: 'Edwin M. Woltz', Randy James, Billy Hicks 

Yes, I consent to the extension you have requested on behalf of all of the entities. 

Randy James 

Randolph M. James, P.C.' 

Attorneys 

116 North Spruce Street 27101 

PO Box 20069 

Winston-Salem, NC 27120 

""""~""""-'-'-"'"- (ph one) 

.336-7~4-9722 (fax) 

~w.tt11jam.es1a,);/.C01n 

Professional Responsibility Rule 4.2 Notice: 

Please be advised that the inclusion of any particular person as a recipient of this email (and speci!ically the inclusion 

of any client of Randolph M. James, P.C'.) does not constitute express or implied consent to opposing counsel to 

''Reply All" to this message·or otherwise communicate with clients of the firm. 

This transmission is intended by the sender and proper recipient to be confidential, intended only for the proper recipient and may 

contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you are not the 

intended recipient. you are notified that the dissemination, distribution or copying of this message is strictly prohibited. If you 

receive this message in error, or are not the proper recipient, please notify the sender at either the e-mail address or telephone 

number above and delete this e-mail from your computer. Receipt by anyone other than the proper recipient is not a waiver of any 

attorney-client, work product, or other applicable privilege. Thank you 

From: Howard Jones [mailto:howardcjonesii@gmail.com] 

Sent: Tuesday, June 02, 2015 6:39PM 

To: Randy James 

Cc: 'Edwin M. Woltz' 

Subject: Hicks 16-15 

Importance: High 

Page 1 of2 
Randy: 

As discussed, I have be'en retained to represent the Authority in the Part 16 Complaint filed by Mr. 

Hicks. I have conferred with Ed Woltz, the County Attorney, and Hugh Campbell, the City Attorney. For 

tlie sake of brevity, we will be filing a joint motion for an extension of time to file a response to the 

complaint. You and I previously discussed an extension, but I wanted to get confirmation in an email 

to attach the same to the motion. 

The Notice of docketing was servd served via mail on May 26, 2015. By my calculations, without an 

extension, respondents would have until due June 20 (20 days and 5 for mailing under 14 CFR 16.17) 

which is a Saturday so that would make it June 22. 

Can you consent to an extension until August 3, 2015 for each respondent (the Authority, the City, and 

the County) to file their responses to the complaint under 14 CFR 16.23 or 16.26? 

While we not know until we have each had additional time to review the complaint, it is my hope that 

the extra time will enable us to have all entities adopt one response. 

Thanks, 

Howard 

Page 2 of2 
UNITED STATES DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

WILLIAM ALFRED HICKS, JR. 

a/Ida BILLY HICKS 

Complainant, 

vs. 

CITY OF MOUNT AIRY, NORTH 

CAROLINA; and the COUNTY OF SURRY, 

NORTH CAROLINA; through the MOUNT 

AIRY/SURRY COUNTY AIRPORT 

AUTHORITY 

Respondent. 

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FAA Docket No. 16-15-07 

ORDER ON CONSENT 

MOTION FOR 

EXTENSION OF TIME 

THIS MATTER coming on to be heard, and being heard, upon consent motion of 

respondents the City of Mount Airy, the County of Surry and the Mount Airy/Surry County 

Airport Authority (hereinafter jointly referred to as "respondents") for an order extending the 

time within which to respond to the complaint; 

IT IS ORDERED that the time for each of these respondents to file their responses to the 

complaint under 14 CFR 16.23 and 16.26 is hereby extended through and including August 3, 

2015. 

This the __ day of _______ ,, 2015. 

Randall S. Fiertz 

Director 

Office of Airport Compliance and Management Analysis