UNITED STATES DEPARTMENT OF TRANSPORTION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. 

Venice Jet Center, LLC, 

Complainant, 

FAA Docket No. 16-09-05 

City of Venice, Florida, 

Respondent. 

— I 

CO 

RESPONDENT CITY OF VENICE'S UNOPPOSED MOTION 

FOR EXTENSION OF TIME TO FILE REBUTTAL 

Designation of persons to receive service for the City of Venice, Florida: 

T;_ 

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Robert C. Anderson 

City Attorney 

Hall & Anderson, P.A. 

1314 East Venice Avenue, Suite E 

Venice, Florida 34285 

randerson(a).hall-anderson.com 

Telephone: (941) 480-0999 

Facsimile: (941)480-1446 

Thomas R. Devine 

Kaplan Kirsch & Rockw^ell LLP 

1001 Connecticut Ave NW, Suite 800 

Washington, DC 20036 

tdevinefSikaplankirsch.com 

Telephone: (202) 955-5600X568 

Facsimile: (202) 955-5616 

Arthur P. Berg 

Kaplan Kirsch & Rockwell LLP 

641 Lexington Avenue, Suite 1409 

New York, New York 10022 

aber g(a),kaplankirsch. com 

Telephone: (212)328-9515 

Facsimile: (646)514-5440 
1. Respondent City of Venice ("the City") moves, pursuant to 14 C.F.R. § 16.11, for 

an extension of time to file its Rebuttal in the above-captioned matter. This request for 

extension is unopposed by the Complainant, Venice Jet Center, LLC. 

2. By rule, the City's Rebuttal is due on October 13, 2009, ten days from September 

30,2009 (the date of service of Venice Jet Center's Reply) plus three days for service by 

mail. The City requests an extension of the deadline for filing its Rebuttal of fifteen 

additional days, until October 28, 2009. 

3. As acknowledged in footnote 1 on page 1 of its Reply, Complainant Venice Jet 

Center raised new matters in its Reply, which the City needs time to analyze and address. 

4. The City Attorney, Robert Anderson, who will participate in the substantive 

analysis and response to the Reply, is unavailable to discuss the case with the 

undersigned counsel until the week of October 5,2009. 

5. On October 2, 2009, Counsel for Respondent, Thomas R. Devine, contacted 

Coimsel for Complainant, Dominique Pearlman, to request Complainant's consent to this 

motion. Counsel for Complainant indicated that Complainant has no objection to an 

extension of 15 days. 
6. The City therefore respectfully requests that the FAA grant it an extension to file 

a Rebuttal until Wednesday October 28, 2009. 

Respectfiilly submitted this 5th day of October, 2009: 

Robert C. Anderson, Esq. 

City Attorney 

Hall & Anderson, P.A. 

1314 East Venice Avenue, Suite E 

Venice, Florida 34285 

randerson@hall-anderson.com 

Telephone: (941) 480-0999 

Facsimile: (941)480-1446 

T -1^- h^ 

Thomas R. Devine, Esq. 

Kaplan Kirsch & Rockwell LLP 

1001 Connecticut Avenue, NW, Suite 800 

Washington, DC 20036 

tdevine(a),kaplankirskch.com 

Telephone: (202) 955-5600 X568 

Facsimile: (202)955-5616 

Arthur P. Berg, Esq. 

Kaplan Kirsch & Rockwell LLP 

641 Lexington Avenue, Suite 1409 

New York, New York 10022 

aberg@kaplankirsch.com 

Telephone: (212) 328-9515 

Facsimile: (646)514-5440 
CERTIFICATE OF SERVICE 

I hereby certify that I have this day served the foregoing City of Venice's 

Unopposed Motion for Extension of Time to File Rebuttal on the following party at 

the following address by overnight mail only: 

Office of the Chief Counsel 

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

Room 925 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, DC 20591 

Original and 3 copies by overnight delivery 

I also hereby certify that I have this day served the foregoing City of Venice's 

Unopposed Motion for Extension of Time to File Rebuttal on the following party at 

the following address by overnight mail and facsimile: 

Gianluca Morello, Esq. 

Dominique Pearlman, Esq. 

Fowler White Boggs, P.A. 

501 E. Kennedy Blvd., Suite 1700 

Tampa, FL 33602 

Fax No. (813) 229-8313 

1 copy 

I also hereby certify that I have this day served the foregoing City of Venice's 

Unopposed Motion for Extension of Time to File Rebuttal on the following persons 

via facsimile and electronic mail at the following addresses: 

Jonathan Cross 

Manager 

Airports Law Branch, AGC-610 

Office of the Chief Counsel 

Federal Aviation Administration 

800 Independence Avenue, S.W., RM 923M 

Washington, DC 20591 

(202) 267-5769 

jonathan.cross@faa.gov 

1 copy 

Elizabeth Head 

Airports Law Branch, AGC-610 

Office of the Chief Counsel 

Federal Aviation Administration 

800 Independence Avenue, S.W., RM 923M 

Washington, DC 20591 

(202) 267-5769 

elizabeth.head(a).faa.gov 

1 copy 

Dated this 5th day of October, 2009: