Schnader 

ATTORNEYS AT LAW 

Robert J. Williams 

Direct Dial412-577-5291 

Direct Fax 412-765-3858 

E-mail: rwilliams@schnader.com 

Federal Aviation Administration 

Part 16 Airport Proceedings Docket 

AGC-610 

800 Independence Ave., SW 

Suite 900-E 

Washington, DC 20591 

FIFTH AVENUE PLACE 

120 FIFTH AVENUE SUITE 2700 .PtTTSBURGH, PA 15222-3001 

412.577.5200 FAX 412.765.3858 schnader.com 

May 11,2015 RECEIVED 

MAY 12 i'.G1~ 

PART 16 DOCKETS 

VL4 U.P.S. EXPRESS 

Re: Pensacola Aviation Center LLC v. Pensacola International Airport 

Docket No. 16-12-12 

To Whom It May Concern: 

Enclosed please find the original and two (2) copies of Respondent's Motion for 

Extension of Time to Respond to Complainant's Motion to Admit Material Facts in connection 

with the above-captioned matter. 

If you have any questions, please feel free to contact me. 

/mst 

Enclosures 

cc: Leonard D. Kirsch, Esq. (w/enc.) 

Very truly yours, 

Robert J. Williams 

Schnader Harrison Segal & Lewis LLP 

PHDATA5304088_1 NEW YORK PENNSYLVANIA CALIFORNIA WASHINGTON, DC NEW JERSEY DELAWARE 
BEFORE THE UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

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= < m a Ui 0 PENSACOLA AVIATION CENTER LLC, ) 

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Complainant, ) 

v. ) 

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PENSACOLA INTERNATIONAL AIRPORT, ) 

A DIVISION OF THE CITY OF ) 

PENSACOLA, ) 

Respondent. ) 

Docket No. 16-12-12 

MOTION FOR EXTENSION OF TIME TO RESPOND 

TO COMPLAINANT'S MOTION TO ADMIT MATERIAL FACTS 

AND NOW, comes Respondent, Pensacola International Airport, by and through its 

undersigned counsel, and pursuant to 14 CFR § 16.11, hereby requests a ten (I 0) day extension 

of time to respond to Complainant's Motion to Admit Material Facts. In support of this Motion, 

Respondent states the following: 

I. On March 13, 2015, the Federal Aviation Administration ("FAA") issued to 

Respondent Pensacola International Airport, a Division of the City of Pensacola ("Pensacola") 

pursuant to 14 CFR § 16.29 a Request for Additional Information. 

2. On April20, 2015, Pensacola filed and served its responses to the FAA's Request 

for Additional Information. 

3. On May 6, 2015, Complainant filed a Motion to Admit Material Facts, inter alia, 

asserting that certain facts and inferences should be drawn from Pensacola's responses to the 

FAA's Request for Additional Information. 

4. A response to Complainant's Motion normally would be due on Monday, May 18, 

2015 (the tenth day from service falling on the preceding weekend). 

PHDATA 5303844_1 
5. However, undersigned counsel for Pensacola is out of the country on other 

business from May 11 through May 17, 20 I 5. 

6. Under the circumstances, Pensacola respectfully requests a ten (I 0) day extension 

of time for responding to Complainant's Motion. 

7. Counsel for Complainant does not object to the relief requested in this motion. 

WHEREFORE, Pensacola respectfully requests that the FAA grant a ten (I 0) day 

extension of time to respond to Complainant's Motion to Admit Material Facts. 

Respectfully submitted, 

Schnader Harrison Segal & Lewis LLP 

Suite 2700, Fifth Avenue Place 

120 Fifth Avenue 

Pittsburgh, P A I 5222 

Counsel for Respondent, Pensacola 

International Airport, a Division of the 

Date: May II, 20 I 5 City of Pensacola 

2 PHDATA 5303844_1 
CERTIFICATE OF SERVICE 

I hereby certify that on May 11, 2015, true and correct copies of the foregoing MOTION 

FOR EXTENSION OF TIME were sent by email and U.S. Mail, first class postage prepaid, to 

the following 

Leonard D. Kirsch, Esquire email: lkirsch@mklawnyc.com 

Shelley A. Ewalt, Esquire email: sewalt@mklawnyc.com 

McBreen & Kopko 

500 North Broadway 

Jericho, NY 11753 

Attorneys for Complainant 

Robert J. Williams, Esq. 

Counsel for Respondent, Pensacola 

International Airport, a Division of the 

City of Pensacola 

PHDATA 5303844_1