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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 oftime 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 ofthis Amended Motion, Respondent states as follows: 1. The Federal Aviation Administration ("FAA") mailed the Notification ofthe Complaint to respondent on October 27,2014.
2. The law firm ofKaplan, Massamillo and Andrews LLC was subsequentlyretained 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 ofthe relevant facts alleged in the Complaint.
5. Respondent filed its original Motion for an Extension ofTime onNovember 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, butRespondents have notyetreceived service ofthis response.
7. Respondent's counsel Larry Kaplan contacted William Foster, the agent for the Complainant, on November 18,2014to 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, butreferred Mr. Kaplanto the Complainant's response to Respondent's Motion for anExtension ofTime, whichhas not yet been served upon the Respondent.
8. During Mr. Kaplan's conversation with Mr. Foster, Mr. Kaplan asked Mr. Foster ifthe Complainant would accept electronic service, and Mr. Fosterrefused onbehalfof Complainant.
9. In order for Respondent and its counsel to make diligent inquiry ofthe persons referenced in these documents prior to filing a response to the Complaint, Respondentrequests an extension oftime to file a response.
10. These documents also make reference to numerous dates, events and actions which must be diligently investigated in orderto reasonably respond to the Complaint.11. In order for Respondent and its counsel to be able to reasonably review and evaluate the 917 pages ofdocuments prior to filing its Answer, Respondent respectfully requests that itbe given until December 19, 2014 to file its Answer to the Complaint. WHEREFORE, Respondent prays that the FAA grant its Motion for an Extension ofTime, to December 19,2014,to respond to Complainant's Complaint.

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### {~/\ Larry Kaplan,VEsq. \ Kaplan, Massamillo & Anarews LLCCERTIFICATE OF SERVICE Docket Number 16-14-08 I hereby certify that I have this day served the Respondentthe Wahoo Airport Authority's Amended Motion for an Extension ofTime to Answer the Complaint onthe following entities and persons atthe following addresses by FedEx.
Office ofthe ChiefCounsel 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....- \ /\{ 1

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