UNITED STATES DEPARTMENT OF TRANSPORTAT ON 

FEDERAL AVIATION ADMINISTRATION AIRPORT/ENVIRONMENTAL 

WASHINGTON, DC I WVUGC ^ 

i T 

SEP 1 1 2009 It!/ 

Venice Jet Center, LLC 

Complainant, 

V. FAA Docket No. 16-09-05 

City of Venice, Florida 

Respondent. 

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COMPLAINANT VENICE JET CENTER LLC'S 

UNOPPOSED REOUEST FOR EXTENSION OF TIME TO FILE REPLY 

Complainant, Venice Jet Center ("VJC"), by and through the undersigned counsel, 

files this unopposed request for extension to file a reply and, in support thereof, states as 

follows: 

1. On September 2, 2009, Respondent City of Venice ("Venice") filed its answer 

to Venice Jet Center's ("VJC") Part 16 Complaint. Pursuant to C.F.R. § 16.23(j), Venice 

contemporaneously filed a 55-paged motion to dismiss, which attached a significant record 

and raised numerous legal and factual arguments. 

2. Despite the Receiver's desire to progress this matter in a timely fashion, 

additional time is required to sufficiently address arguments raised in the answer and motion 

to dismiss. 

3. By rule, VJC's reply is due on September 15, 2009 or thirteen (13) calendar 

days after service of the answer and motion to dismiss by mail. VJC respectfially requests a 
fifteen (15) day extension through and including Wednesday, September 30, 2009 to file a 

reply to the answer and motion to dismiss. 

4. The undersigned has corresponded with counsel for Venice and Respondent 

has no objection to a fifteen day extension. 

5. VJC, therefore, respectfiilly requests that the FAA grant it an extension to file 

a reply until Wednesday, September 30,2009. 

CERTIFICATE OF SERVICE 

I hereby certify that I have served the foregoing on the following persons at the 

following address by overnight mail on September 10,2009: 

Office of the Chief Counsel Jonathan Cross 

Attn: FAA Part 16 Airport Proceedings Manager 

Docket, AGC-610 Airports and Environmental Law division 

Room 925 Federal Aviation Administration 

Federal Aviation Administration 800 Independence Ave., S.W. 

800 Independence Ave., S.W. Washington, DC 20591 

Washington, DC 20591 Facsimile (202) 267-5769 

Original and 3 copies by overnight 1 Copy 

delivery 

I hereby further certify that I have served the foregoing on the following persons at 

the following address by electronic mail on September 10, 2009: 

Elizabeth J. Head 

Senior Attorney 

Airports & Environmental Law Division 

Federal Aviation Administration 

Washington, D.C. 20591 

Elizabeth.Head@faa.gov 

I hereby further certify that I have served the foregoing on the following persons at 

the following address by overnight mail and facsimile on September 10,2009: 
V • 

Thomas R. Devine 

Kaplan Kirsch & Rockwell LLP 

1001 Connecticut Ave. NW, Ste. 800 

Washington, DC 20036 

Telephone: (202) 955-5600 

Facsimile (202) 955-5616 

Robert C. Anderson 

Hall & Anderson, P.A 

1314 East Venice Avenue, Suite E 

Venice, Florida 34285 

Facsimile: 941.480.1446 

edMma^v^ 

Giahluca Mof^lo, FBN 034997 

ianluca.Morello@fowlerwhite.com 

)ominique Pearlman, FBN 0044135 

Dominique.Pearlman@fowlerwhite.com 

FOWLER WHITE BOGGS, P.A. 

501 E. Kennedy Blvd., Suite 1700 

Tampa, FL 33602 

Phone (813) 228-7411 

Fax (813) 229-8313 

Attorneys for the Complainant, Venice Jet 

Center, LLC 

42329603V1