U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION, 

Complainant 

v. 

UNITED PARCEL SERVICE CO. 

Respondent 

TO: Administrative Law Judge J. E. Sullivan 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. (E11-310) 

Washington, DC 20590 

FAA Docket No. FAA 2016-4261 

Judge J. E. Sullivan 

MOTION FOR EXTENSION OF TIME 

Pursuant to 14 C.F.R. § 13.213(b), United Parcel Service Co. (a Delaware Corporation) 

("UPS Airlines") and United Parcel Service, Inc., an Ohio Corporation ("UPS Ground" 1

) and, by 

and through their undersigned counsel hereby timely file this motion requesting an extension of 

time to respond by answer or motion to the Complaint filed by the FAA on March 3, 2016. In 

support of the motion, UPS Airlines and UPS Ground state that additional time to respond is 

needed for several reasons. First, this action, FAA Docket No. 2016-4261, is related in 

numerous substantial and material ways to cases pending under FAA Docket No. 2016-4262 and 

1 This Complaint's caption identifies only UPS Airlines as the Respondent. UPS Airlines is an FAA-certificated air 

carrier. The allegations in !he Complaint, however, are directed to UPS Ground, which is a separate company from 

UPS Airlines. UPS Ground is an Ohio corporation and is not an FAA-certiiicated air carrier, but is instead a ground 

transportation and logistics company. UPS Airlines' and UPS Ground's joint motion for extension of time to 

respond to the FAA's Complaint does not waive, and the parties hereby expressly reserve, their rights to seek 

dismissal ofihe FAA's Complaint for failure to state a claim against UPS Airlines and! or UPS Ground. 
FAA Docket No. 2015-3320. UPS Airlines and UPS Ground intend to seek consolidation of 

these three actions so that the common issues presented in them can be resolved in a consistent 

and efficient manner. Second, the filing of a consolidated response may require additional 

preparation time, but should decrease the time to resolve the cases individually. Third, even if 

UPS Airlines and UPS Ground are required to respond to each case individually, additional time 

is needed to fully address the issues presented in this matter. 

An Administrative Law Judge has not yet been appointed in FAA 2016-4262 or FAA 

2015-3320. UPS Airlines and UPS Ground intend to file similar motions for extensions of time 

in those two cases and file motions to consolidate in all three actions once an Administrative 

Law Judge has been appointed in each of them. 

Wherefore, UPS Airlines and UPS Ground respectfully request that they be granted an 

extension of time to a date that is 20 days following the date upon which the forthcoming 

motions to consolidate are either granted or denied. 

DATED: March 28,2016 Respectfully submitted, 

CROWELL & MORlNG LLP 

1001 Pennsylvania Ave., NW 

Washington DC 20004-2595 

palp@crowell.com 

202- 624-2747 

202-628-5116 (Fax) 

and 

FROST BROWN TODD LLC 

Winston E. Miller 

wmiller@fbtlaw.com 

Miles R. Harrison 

mharrison@fblaw.com 

400 W. Market Street, 32"d Fl. 

2 
Louisville, KY 40202 

502-589-5400 (Main) 

502-568-0296 (Direct) 

502-581-1087 (Fax) 

Counsel for United Parcel Service Co. 

ll.y U!~Jhof 

~~~-=-----c-'-------l"-----f--'-1."'-~ j~''­ Meagha Goodwin Boyd 

meaghan. boyd@alston.com 

Alston & Bird LLP 

1201 W. Peachtree Street 

Atlanta, Georgia 30309-3424 

404.881.7245 (direct) 

404.253.8510 (direct fax) 

Counsel for United Parcel Service, Inc. 

3 
CERTIFICATE OF SERVICE 

The undersigned hereby certifies that true and correct copies of the foregoing were served 

by hand delivery or UPS Next Day Air®, as indicated below, this 28th day of March, 2016, to 

the following: 

Federal Aviation Administration 

600 Independence A venue, SW 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building-Suite 2W1000 

Administrative Law Judge J. E. Sullivan 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. (E11-310) 

Washington, DC 20590 

James H. Dtmfee Jr. 

Attorney 

Enforcement Division, Southern Team 

1701 Columbia Avenue 

College Park, GA 30337 

DATED: March 28,2016 

(original+ 1 copy) (via hand delivery) 

(via hand delivery) 

(via UPS Next Day Air) 

Paul Alp 

4