UNITED STATES DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Pro-Flight Aviation, Inc. 

Complainant, 

V. Docket No. 16-15-03 

City of Renton, Washington 

Respondent. 

/ 

UNOPPOSED MOTION OF PRO-FLIGHT AVIATION FOR AN EXTENSION 

OF TIME 

Complainant Pro-Flight Aviation, Inc. ("PFA"), pursuant to 14 C.F.R. § 16.19 and 

§ 16.11(a), hereby requests leave to file and files this motion for a 30-day extension of time 

from the current due date to file its answer to Respondent City of Renton, Washington's 

("City" or "Respondent") Motion for Summary Judgment. In support of this motion, PFA 

states as follows: 

1. On January 28, 2015, PFA filed a Part 16 Complaint ("Complaint") against 

Respondent. On February 06, 2015, the FAA issued a notice that the Complaint had been 

docketed. 

2. On February 17, 2015, Respondent moved for an extension of time, and by 

order dated March 11, 2015, the Administrator granted Respondent a 45-day extension of 

time to answer or otherwise respond to the Complaint. On April 17, 2015, Respondent filed 

its Motion for Summary Judgment, and Complainant received the Motion for Summary 

Judgment on April 20, 2015. 
3. Pursuant to the Part 16 rules of procedure, an answer to Respondent's Motion 

for Summary Judgement is due within 10 days of service, plus five days when service is 

made by first class or certified mail. 14 C.F.R. §§ 16.17(c) and 16.26(c)(3). Accordingly, 

PFA's answer is currently due on May 5, 2015. 

4. This request for an extension of time is not being made to delay the 

proceeding. Respondent has presented a number of issues in its forty-six page Motion for 

Summary Judgment that PFA will need to respond to, all of which will require a significant 

amount of time to carefully consider. Given this, PFA believes that a 30-day extension of 

time is both necessary and appropriate "for a fair and complete consideration of the matters 

before the agency." § 16.11(a). 

5. On April 21, 2015, the undersigned contacted Zanetta L. Fontes, counsel for 

Respondent, who advised that the City would not oppose this request. 

CONCLUSION 

For the foregoing reasons, Pro-Flight respectfully requests a 30-day extension of time 

to file its answer to Respondent's Motion for Summary Judgment, making such due on or 

before June 4, 2015. 

Dated Apri123, 2015 Respectfully su mitt d 

Z a 

Bernard A. Paholke 

Vice President 

Pro-Flight Aviation, Inc 

Complainant 

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CERTIFICATE OF SERVICE 

I hereby certify that in accordance with 14 CFR §§ 16.15 and 16.13(h), I have this 

day, the 23 dof April 2015, served the foregoing Motion for extension of time on the 

following persons by electronic mail: 

City of Renton 

Attn: Zanetta Fontes 

Senior Assistant City Attorney's Office 

1055 South Grady Way 

Renton, WA 98057 

zfontesgrentonwa.gov 

Federal Aviation Administration Part 16 Docket Clerk 

Office of the Chief Counsel 

Attention: FAA Part 16 Docket Clerk 

AGC-600 

Federal Aviation Administration 

800 Independence Avenue SW. 

Washington, DC 20591 

9-AWA-AGC-Part-16@faa.gov 

zn- P'ZA 

Bernard A. Paholke 

Vice President 

Pro-Flight Aviation, Inc 

750 W. Perimeter Rd Unit #1 

Renton, WA 98057 

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