BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

)

VICTOR CHERENFANT, )

RAINER DAHM, )

JEAN MOLIERE, )

GLORIA NEJJAR, and )

JAMES SIMEON, ) DOCKET

)

Complainants, ) DOT-OST-2013-0097

against )

)

SPIRIT AIRLINES, INC. and )

DIRECT AIRLINE SERVICES, INC., )

)

Respondents. )

____________________________________)

UNCONTESTED MOTION OF RESPONDENT 

SPIRIT AIRLINES, INC. 

FOR EXTENSION OF ANSWER DATE

Communications with respect to this document should be sent to:

Joanne W. Young

David M. Kirstein

Kirstein & Young, PLLC

1750 K Street, N.W.

Suite 200

Washington, D.C. 20006

(202) 331-3348 (telephone)

(202) 331-3933 (facsimile)

Attorneys for

SPIRIT AIRLINES, INC.

May 20, 2013
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

)

VICTOR CHERENFANT, )

RAINER DAHM, )

JEAN MOLIERE, )

GLORIA NEJJAR, and )

JAMES SIMEON, ) DOCKET

)

Complainants, ) DOT-OST-2013-0097

against )

)

SPIRIT AIRLINES, INC. and )

DIRECT AIRLINE SERVICES, INC., )

)

Respondents. )

____________________________________)

UNCONTESTED MOTION OF RESPONDENT 

SPIRIT AIRLINES, INC.

FOR EXTENSION OF ANSWER DATE

Pursuant to section 302.405(a) of the Department’s procedural regulations, Spirit 

Airlines, Inc. (“Spirit”) hereby moves for an extension of time to file answer(s) to the above 

captioned Complaint for both itself and Direct Airline Services, Inc. (“DAS”) with whom Spirit 

contracts for passenger handling services at FLL. Spirit requests that Respondents be given until 

June 5, 2013 to respond to this Complaint. Aldo Muirragui, the SEIU attorney representing the 

Complainants, indicated on May 20, 2013 that he has no objection to granting this motion. Good 

cause exists for this short, 15-day extension.

Spirit and DAS require additional time to prepare their response(s) to the allegations 

contained in the Complaint. Respondents promptly began investigating the matter upon its 

filing. However, due to the extensive operations of both Spirit and DAS at FLL and the 
Motion of Respondent Spirit Airlines, Inc.

DOT-OST-2013-0097

2

necessity to coordinate the investigation and a response between the two corporations, additional 

time is needed to accurately and completely respond to the Complaint. This request is in the 

public interest because the ability to more fully investigate and develop a response will assist the 

DOT in its review of this matter and will not unduly delay the proceedings. 

Respectfully submitted,

__________________________

Joanne W. Young

David M. Kirstein

Kirstein & Young PLLC

1750 K Street N.W.

Suite 200

Washington, D.C. 20006

(202) 331-3348 (telephone)

(202) 331-3933 (facsimile)

Attorneys for

SPIRIT AIRLINES, INC.

May 20, 2013
CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing Uncontested Motion for Extension by 

electronic mail on the following persons:

Aldo Muirragui

Service Employees International Union 32BJ

amuirragui@seiu32bj.org

Samuel Podberesky, Esq.

Assistant General Counsel 

for Aviation Enforcement and Proceedings

sam.podberesky@dot.gov

Jeffrey R. Anderson

Vice President Airports & Administration

Direct Airline Services

andersonj@directairlineservices.com

__________________________

Lyndsey Grunewald

May 20, 2013