Docket No. 16-14-08 

Karen U. Schmitt to: 9-AWA-AGC-Part-16 

Cc: "Fiy@BetterAirports.com" 

SENT ON BEHALF OF LARRY KAPLAN 

November 7, 2014 

Office of the Chief Counsel 

Attention: FAA Part 16 Docket Clerk 

AGC-600 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, DC 20591 

Dear Office of the Chief Counsel, 

11/07/2014 04:14PM 

~!E~!EGW!E~ 

NOV 1 7 2014 

PART 16 DOCKETS 

This letter is in reference to the Complaint filed against THE WAHOO AIRPORT AUTHORITY, WAHOO 

MUNICIPAL AIRPORT, WAHOO, NEBRASKA FAA Identifier: AHQ (hereinafter "WAHOO") in Docket No. 

16-14-08. As is explained in the attached Motion for an Extension of Time to Answer the Complaint, the 

subject Complaint was accompanied by nine hundred seventeen (917) pages of allegedly supporting 

documents. In order for WAHOO and this law firm which is representing WAHOO in the subject matter 

to reasonably review the accompanying documentation prior to preparing and serving an Answer to the 

Complaint, the attached Motion requests an extension of time to December 19,2014 to serve its 

Answer. 

Best regards, 

Larry Kaplan 

~ I~ r\!1otion for &1:ension of Time to AnswerComp!ainLpdf 
DOCKET NO. 16-14-08 

MOTION FOR EXTENSION OF TIME TO ANSWER THE COMPLAINT 

Now comes THE WAHOO AIRPORT AUTHORITY, WAHOO MUNICIPAL AIRPORT, WAHOO NEBRASKA, FAA 

Identifier: AHQ, (hereinafter "WAHOO") by and through its appointed agents and counsel, KAPLAN, 

MASSAMILLO & ANDREWS, LLC, and hereby moves for an extension oftime to answer the Complaint 

filed by the Complainants Walker Ag Supply, LLC, Midwest Spray Services, LLC and Better Airports, LLCagent for Complainants (hereinafter "COMPLAINT"). In support of this Motion, WAHOO states as 

follows: 

1. The COMPLAINT was served on WAHOO on October 30, 2014. 

2. The COMPLAINT includes nine hundred and seventeen (917) accompanying pages of allegedly 

supporting documents. 

3. These documents make reference to numerous people whom COMPLAINTANTS allege are 

knowledgeable of the relevant facts alleged in the COMPLAINT. 

4. In order for WAHOO and its counsel to make diligent inquiry of the persons referenced in these 

documents prior to filing a response to the COMPLAINT, WAHOO requests an EXTENSION OF 

TIME TO ANSWER THE COMPLAINT. 

5. These documents also make reference to numerous dates, events and actions which must be 

diligently investigated in order to reasonably respond to the COMPLAINT. 

5. In order for WAHOO and its counsel to be able to reasonably review and evaluate the 917 pages 

of documents prior to filing its ANSWER, WAHOO respectfully requests that it be given until 

December 19, 2014 to file its ANSWER to the COMPLAINT. 
CERTIFICATE OF SERVICE 

Docket Number 16-14-08 

I hereby certify that I have this 7'h day of November, 2014 served the foregoing motion for an extension 

of time to answer the complaint on the following persons at the following addresses by U.S. mail. 

William Foster 

Agent for Complainants 

Better Airports, LLC 

4504 North Versailles Avenue 

Dallas, TX 75205-3015 

Telephone Number Office: 214-219-5000 

Mobile: 217-477·7077 

Email: Fly@BetterAirports.com 

" 

r 

Larry Kaplan i 

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Kaplan, Mass~llYijlo & Andrews, LLC ! ' ·~---"""'" --·-""\