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DOCKET NO. 11> 14-08 ~~IU~;~ 1014 J 

RESPONDENT THE WAHOO AIRPORT AUTHORITY'S ~~!I)~~~lf9J EXTENSION OF TIME TO ANSWER THE COMPLAINT 

Now comes Respondent THE WAHOO AIRPORT AUTHORITY, WAHOO 

MUNICIPAL AIRPORT, WAHOO NEBRASKA, FAA Identifier: AHQ, (hereinafter 

"Respondent") by and through its appointed agents and counsel, KAPLAN, MASSAMILLO & 

ANDREWS, LLC, and hereby moves for an extension of time to answer the Complaint filed by 

the Complainants Walker Ag Supply, LLC, Midwest Spray Services, LLC and Better Airports, 

LLC- agent for Complainants. In support of this Amended Motion, Respondent states as 

follows: 

1. The Federal Aviation Administration ("FAA") mailed the Notification of the Complaint 

to respondent on October 27,2014. 

2. The law firm of Kaplan, Massamillo and Andrews LLC was subsequently retained to 

represent Respondent. 

3. The Complaint comprises nine hundred and seventeen (917) accompanying pages of 

allegedly supporting documents. 

4. These documents make reference to numerous people whom Complainants allege are 

knowledgeable of the relevant facts alleged in the Complaint. 

5. Respondent filed its original Motion for an Extension of Time on November 7, 2014 via 

electronic filing to the FAA, and paper service upon Complainant's counsel. 
6. Complainant's counsel has apparently responded to this motion, but Respondents have 

not yet received service of this response. 

7. Respondent's counsel Larry Kaplan contacted William Foster, the agent for the 

Complainant, on November 18,2014 to inquire whether he would be opposed to 

Respondent's request for additional time to respond; however, Mr. Foster did not respond 

to Mr. Kaplan with an affirmative response, but referred Mr. Kaplan to the Complainant's 

response to Respondent's Motion for an Extension of Time, which has not yet been 

served upon the Respondent. 

8. During Mr. Kaplan's conversation with Mr. Foster, Mr. Kaplan asked Mr. Foster if the 

Complainant would accept electronic service, and Mr. Foster refused on behalf of 

Complainant. 

9. In order for Respondent and its counsel to make diligent inquiry of the persons referenced 

in these documents prior to filing a response to the Complaint, Respondent requests an 

extension of time to file a response. 

10. These documents also make reference to numerous dates, events and actions which must 

be diligently investigated in order to reasonably respond to the Complaint. 
11. In order for Respondent and its counsel to be able to reasonably review and evaluate the 

917 pages of documents prior to filing its Answer, Respondent respectfully requests that 

it be given until December 19, 2014 to file its Answer to the Complaint. 

WHEREFORE, Respondent prays that the FAA grant its Motion for an Extension of Time, to 

December 19,2014, to respond to Complainant's Complaint. 

s~rritted, 

I I I , I I 

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Larry Kaplan,VEsq. \ 

Kaplan, Massamillo & Anarews LLC 
CERTIFICATE OF SERVICE 

Docket Number 16-14-08 

I hereby certify that I have this day served the Respondent the Wahoo Airport Authority's 

Amended Motion for an Extension of Time to Answer the Complaint on the following entities 

and persons at the following addresses by FedEx. 

Office of the Chief Counsel 

Attention: FAA Part 16 Docket Clerk, AGC-600 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, DC 20591 

William Foster 

Agent for Complainants 

Better Airports, LLC 

4504 North Versailles Avenue 

Dallas, TX 75205-3015 

Telephone Number Office: 214-219-5000 

Mobile: 217-477-7077 

Email: Fly@BetterAirports.com 

Date: November 18, 2014 

Larry Kaplan 

Kaplan, 1).assr.f ·1o & Andrews, 

LLG .... - \ /\{ 

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