Ill 

KAPLAN KIRSCH ROCKWELL 

January 16,2014 

VIA HAND DELIVERY 

Sharon Long 

Office of the Chief Counsel 

RECEIVED 

AUG 2 6 2015 

PART 16 DOCKETS 

Attn: FAA Part 16 Airport Proceedings Docket, AGC-61 0 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, D.C. 20591 

Re: National Business Aviation Association, Inc., et al. v. Town of East Hampton, NY, 

FAA Docket No. 16-15-08 

Dear Ms. Long: 

Enclosed please find for filing in the above-referenced docket one original and three 

copies of Respondent Town of East Hampton, New York's Unopposed Motion for Extension of 

Time to File Its Answer. Also enclosed is an extra copy of the Motion to be file-stamped and 

returned to the courier. 

Please feel free to contact me at (202) 955-5600 if you have any questions or require 

additional information. 

Enclosures 

cc: Mr. Steve Brown 

Attorneys at Law 

Denver a Washington, DC 

Sincerely, 

W. Eric Pilsk 

Kaplan Kirsch & Rockwell LLP tel: (202) 955-5600 

1001 Connecticut Ave., N.W., Suite 800 fax: (202) 955-5616 

Washington, DC 20036 ""w.kaplankirsch.com 
UNITED STATES DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. 

National Business Aviation Association, Inc., et 

al. 

RECEIVED 

AUG 2 6 2015 

PART 16 DOCKETS 

Complainants, 

FAA Docket No. 16-15-08 

v. 

Town of East Hampton, NY 

Respondent. 

RESPONDENT TOWN OF EAST HAMPTON, NEW YORK'S 

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE ITS ANSWER 

Designation of persons to receive service for the Town of East Hampton, New York: 

Elizabeth Vail 

Town Attorney 

Town of East Hampton 

159 Pantigo Road 

East Hampton, NY 11937 

EV ail@EHamptonNY. Gov 

W. Eric Pi1sk 

Catherine van Heuven 

Kaplan Kirsch & Rockwell LLP 

1001 Connecticut Ave., NW, Suite 800 

Washington, D.C. 20036 

epilsk@kaplankirsch.com 

cvanheuven@kap1ankirsch.com 

Telephone: (202) 955-5600 

Facsimile: (202) 955-5616 
Respondent Town of East Hampton, New York (the "Town") moves, pursuant to 14 

C.F.R. § 16.11, for a 30-day extension of time to file its Answer to the Complaint in the abovecaptioned matter. Complainant does not oppose this Motion. 

1. Complainants filed the Complaint on May 20, 2015, alleging that the Town, the 

operator of East Hampton Airport ("HTO") has violated Assurances 23 and 25. The Director 

docketed the Complaint on June 8, 2015. On June 24,2015, the Town filed a Motion to Dismiss 

the Complaint. Also on June 24,2015, the Town filed a Motion to Suspend Filing an Answer 

Until the FAA Rules on Respondent's Motion to Dismiss. The FAA did not rule on either 

motion by August 19 and, pursuant to 14 C.F.R. § 16.26(b)(5) the Town's Answer is now due on 

September 8, 2015. 

2. Due to previously scheduled vacations, a trial in an unrelated matter, and other 

previously scheduled deadlines and professional commitments, the Town needs additional time 

to prepare an Answer to the Complaint. Due to the limited staff at East Hampton Airport, and 

the Town itself, it will not be possible for the Town to locate and review all of the necessary 

information, and prepare a complete response to the Complaint, by September 8. Allowing time 

for the Town to locate and review all of the relevant documents is necessary for the Town to 

provide a complete response to the issues raised in the Complaint. 

3. In order to provide the Town with sufficient time to locate and review the relevant 

documents, and draft an appropriate response to the Complaint, the Town requests an extension 

of time until October 8, 2015, to file its Answer to the Complaint. The Town does not object to 

Complainants receiving a similar extension of time to file their Reply. 

4. The extension of time will not prejudice the FAA's investigation or its ability to 

afford appropriate relief in this case. The Town's Motion to Dismiss remains pending. 

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Moreover, this schedule will promote the efficient and just resolution of this case by providing 

FAA with a complete factual record and the considered position of the Town as the basis for its 

investigation. This will both promote the FAA's truth-finding objectives and reduce the scope of 

the investigation by FAA staff. Accordingly, the requested extensions will not adversely affect 

the parties or undermine FAA's enforcement authority. 

5. Counsel for the Town has discussed this Motion with Complainant and 

Complainant does not object to the extension. 

6. For the foregoing reasons, the Town respectfully requests that FAA grant the 

Town an extension of time until October 8, 2015, to file its response to the Complaint in this 

matter. 

Respectfully submitted this 25th day of August, 2015. 

Elizabeth Vail 

Town Attorney 

Town of East Hampton 

159 Pantigo Road 

East Hampton, NY 1193 7 

EVail@EHamptonNY.Gov 

W. Eric Pilsk 

Catherine van Heuven 

Kaplan Kirsch & Rockwell LLP 

1001 Connecticut Ave., NW, Suite 800 

Washington, D.C. 20036 

epilsk@kaplankirsch.com 

cvanheuven@kaplankirsch.com 

Telephone: (202) 955-5600 

Facsimile: (202) 955-5616 

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CERTIFICATE OF SERVICE 

I hereby certify that I have this 25th day of August, 2015, served the foregoing 

Respondent Town of East Hampton, New York's Motion for Extension of Time to File Its 

Answer on the following parties as indicated below: 

Office of the Chief Counsel 

Attn: FAA Part 16 Airport Proceedings Docket, AGC-610 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, D.C. 20591 

BY HAND DELIVERY 

Steve Brown 

Chief Operating Officer 

National Business Aviation Association, Inc. 

1200 G Street, NW 

Suite 1100 

Washington, D.C. 20005 

BY EMAIL AND US MAIL 

Dated this 25th day of August, 2015. 

W. Eric Pilsk 

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