BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

)

VICTOR CHERENFANT, )

RAINER DAHM, )

JEAN MOLIERE, )

GLORIA NEJJAR, and )

JAMES SIMEON, ) DOCKET

)

C omplainants, ) 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, 2013BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

)

VICTOR CHERENFANT, )

RAINER DAHM, )

JEAN MOLIERE, )

GLORIA NEJJAR, and )

JAMES SIMEON, ) DOCKET

)

C omplainants, ) DOT

- OST

- 2013

- 0097

against )

)

SPIRIT AIRLINES, INC. and )

DIRECT AIRLINE SERVICES, INC., )

)

Respondents. )

____________________ ________________ )

UNCONTESTED MOTION OF RESPONDENT

SPIRIT AIRLINES, INC

. FOR EXTENSION OF ANS WER DATE

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

Air lines, Inc. (“Spirit”) hereby move s 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 request s 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.

S pirit 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 theM otion 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 invest igate 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, 2013CERTIFICATE OF SERVI CE

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

e lectronic 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