(Exempt from Filing Fees 

Pursuant to Govt. Code § 6103) 

PAMELA J. WALLS, County Counsel (SBN 123446) 

DANA M. SMITH, Deputy County Counsel (SBN 172386) 

3535 Tenth Street, Suite 300 

Riverside, CA 92501-3674 

Telephone: (951)955-6300 

Facsimile: (951)955-6363 

Attorneys for County of Riverside 

ffi E II ¥ 

NOV I 2 2009 

mi 

AIRPORT/ENVlffONMENTA iT/ENVWfONMENTAL 

LAW, AGC-60Q 

UNITED STATES DEPARTMENT OF TRANSPORTATON 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. 

ORANGE COUNTY SOARING 

ASSOCIATION, MARY RUST, LARRY 

TOUHINO and CHRIS MANNION, 

Complainants, 

THE COUNTY OF RIVERSIDE 

Respondent. 

Docket No. 16-09-13 

DECLARATION OF PAMELA J. WALLS IN 

SUPPORT OF MOTION FOR EXTENSION OF 

TIME TO FILE RESPONSE TO COMPLAINT 

—-i 

CTJ 

-I -T. 3 

c5 

i-^^ I am an attorney at law duly licensed to practice before all of the courts of the statS of California 

and as such I am the County Counsel for the County of Riverside. I have personal knowledge of the 

within stated facts and if called to testify could and would competently do so. 

1. On November 2, 2009,1 received notice from the U.S. Department of Transportation, 

Federal Aviation Administration, that a complaint had been filed against the County of Riverside and that 

a responsive pleading would be due within 20 days of the date of the service of the notice, that date being 

November 16, 2009. 

2. The Riverside County Counsel's Office, coimsel for Respondent, is in the midst of a 

complete relocation of its office. The office is being moved starting the evening of November 5, 2009. 

Additionally, due to mandatory furloughs the office is also closed every other Friday. As a result, 

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DECLARATION OF PAMELA J. WALLS 
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Respondent is requesting a 15 day extension of time, up to and including December 1, 2009, to file a 

responsive pleading. 

3. On November 5, 2009,1 contacted Ronald J. Cozad, the attorney for the Complainants 

regarding an extension of time to file a responsive pleading. Mr. Cozad has graciously agreed to a 15 day 

extension of tirhe for the County of Riverside to file a responsive pleading. See Exhibit "A" attached 

hereto. 

I declare under penalty of perjury that the foregoing is true and correct. 

Executed this 5**^ day of November, 2009 at Riverside, California 

PAMELA J. WALLS, 

County Counsel 

November 5, 2009 

DMS/hms 

G;\Property\DMSm.ith\CASES\F AA\Declaration.doc 

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DECLARATION OF PAMELA J. WALLS 
EXHIBIT "A" 
Walls, Pamela J. 

From: roncozad@gmail.com 

Sent: Thursday, November 05, 2009 2:27 PM 

To: Walls, Pamela J. 

Subject: Re: Orange County Soaring Association Complaint 

Attachments: TEXT.titm; Mime.822 

Confirming extension approved. 

Regards, Ron Cozad 

11/5/2009 

On Thu^ Nov 5, 2009 at 10:08 AM, Walls, Pamela 3. < P3lAlall5^co.riverside.ca.us> wrote: 

> Mr. Cozad: 

> 

> 

> 

> It was a pleasure speaking with you this morning. Thank you for 

> graciously agreeing to a 15 day extension of time to answer the 

> above-referenced complaint. JAle will prepare a written application per 

> 14 CFR 16.19 for submission to the FAA. I^e appreciate your courtesy and cooperation, 

> 

> 

> 

> Pamela J. Walls 

> 

> County Counsel 

> 

> County of Riverside 

> 

> Telephone (951) 955-6300 

> 

> Facsimile (951) 955-6363 

> 

> 

> 

> *Please note: Our office is closed every Friday thru fiscal year 

> 2009/2010 per order of the Board of Supervisors 7/21/2009,* 

> 

> NOTICE: This communication is intended for the use of the individual ^ 

> or entity to which it is addressed and may. contain attor^ney/client 

> information that is privileged, confidential and exempt from 

> disclosure under applicable law. If the reader of this communication 

> is not the intended recipient or the employee or agent responsible for 

> delivering this communication to the intended recipient, you are 

> hereby notified that any dissemination, distribution or copying of 

> this communication is strictly prohibited. If you have received this 

> communication in error, please notify us immediately by reply email or 

> by telephone and immediately delete this communication and all its attachments, 

> 

> 

> 
Law Offices of 

RONALD D. COZAD 

PREMIER DET BUILDING * McCLELLAN-PALOMAR AIRPORT 

2100 Palomar Airport Road, Suite 214 

Carlsbad, CA 92011 

Telephone (760) 431-8200 

Direct Line (760) 716-1025 

Facsimile (760) 454-1705 

roncozad(5lgmail. com 
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CERTIFICATE OF SERVICE 

I hereby certify that I have this day served the foregoing Declaration of Pamela J. Walls in Support 

of Notice of Motion and Motion for Extension of Time to File Answer to Complaint and Orderon the 

following persons at the following addresses by United States Postal Servce: 

Ronald J. Cozad, Esq. 

Law Offices of Ronald J. Cozad 

2100 Palomar Airport Road, Suite 214 

Carlsbad, CA 92011 

Colby Cataldi 

Assistant Director Aviation 

3403 Tenth Street, Suite 300 

Riverside, CA 92501 

Daryl Shippy 

Airports Manager 

37552 Winchester Road 

Murrieta CA 92563 

Sharice .Tefferson 

Federal Aviation Administration 

Office of the Chief Counsel 

Attn: FAA Part 16 Airport Proceedings Docket 

AGC-610, Room 925 

800 Independence Ave., SW 

Washington DC 20591 

Helen M. Sheehan 

DECLARATION OF PAMELA J. WALLS