Steven 0. Rosen, OSB #785009 

Rosen@RosenLawFirm.com 

Elizabeth M. FeITarini OSB #944859 

Ferrarini@RosenLawFirm.com 

The Rosen Law Firm, P.C. 

1000 SW Broadway, Suite 1220 

Portland, OR 97205 

Telephone: (503) 525-2525 

Facsimile: (503) 525-2526 

Attorneys for Defendant 

Spirit Airlines, Inc. 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

PORTLAND DIVISION 

TIMOTHY MEACHAM, 

Plaintiff, 

v. 

SPIRIT AIRLINES INC.; KERRIE 

CONRAD, and; AIRPORT 

TERMINAL SERVICES, INC., a 

Missouri Corporation, 

Defendants. 

Case No. 3:15-cv-00338-SI 

DEFENDANT SPIRIT AIRLINES 

INC.'S UNOPPOSED MOTION 

FOR EXTENSION OF DEADLINE 

TO ANSWER FIRST AMENDED 

COMPLAINT 

CERTIFICATE OF COMPLIANCE WITH LR 7-l(a) 

I hereby certify that defense counsel for Spirit Airlines, Inc. has confe1Ted 

with counsel for the plaintiff in a good faith effort to resolve this matter. Plaintiff 

Page I of 3 - Defendant Spirit Airlines. Inc. 's Unopposed Motion 

for Extension of Deadline to Ans\ver First 

Aincnded Con1plaint 

The Rosen La\\ Firm. P.C. 

1000 S\\' Broadway. Suite 1220 

Ponland. Oregon 97205 

Phom.;: (503) 525-2525; Fax: (503) 525-2526 

Case 3:15-cv-00338-SI Document 26 Filed 06/22/15 Page 1 of 4
and Spirit Airlines, Inc. have agreed to the following request, and this motion is 

unopposed. 

MOTION 

Pursuant to LR 16-3, defendant Spirit Airlines, Inc. moves the Court for an 

extension of time to Wednesday, July 22, 2015 to file its Answer or otherwise 

respond to the plaintiff's First Amended Complaint. 

MEMORANDUM IN SUPPORT OF MOTION 

Plaintiff filed his First Amended Complaint on June 4, 2015. Rules l 5(a)(3) 

and 6( d) of the Federal Rules of Civil Procedure would require Spirit Airlines to 

file its Answer to plaintiffs First Amended Complaint by June 22, 2015. 

Steven Rosen is the trial attorney for this matter. He has been out of the 

office for an extended period of time due to illness, including more than 3 weeks in 

the hospital for treatment of meningitis and pneumonia. He remains out of the 

office while recuperating. Spirit Airlines requests an additional 30 days to 

investigate the amended claims and allegations and to draft its Answer to the First 

Amended Complaint with the input and advice of attorney Steven Rosen. 

Defense counsel for Spirit Airlines spoke with Mr. Ball, counsel for the 

plaintiff, on June 22, 2015 and requested 30 days of additional time to prepare and 

file an Answer to the First Amended Complaint. Mr. Ball agreed with that request 

Page ::Z of 3 - Defendant Spirit Airlines. Inc. ·s Unopposed Motion 

for Extension of Deadline to Ans\ver First 

An1ended Co1nplaint 

The Rosen La\\ FirnL P.C. 

!000 S\V Broad\\ay. Suite 1220 

Portland. Oregon 97205 

Phone: (503) 525-2525: Fax: (:'i03J 525-2526 

Case 3:15-cv-00338-SI Document 26 Filed 06/22/15 Page 2 of 4
and defendant Spirit Airlines seeks court approval of the extension of time in 

accordance with FRCP l 5(a)(3), LR 16-3, and LR 29-1. 

It is not expected that this requested extension of time will cause any 

significant delay in the progression of the action. 

This motion is made in good faith and not for purposes of delay. Spirit 

Airlines respectfully requests that the Court grant its request for a 30-day extension 

of time to answer the First Amended Complaint. 

DATED this 22nd of June, 2015. 

s/ Elizabeth M. Fenarini 

Elizabeth M. Ferrarini, OSB # 944859 

F errarini@RosenLawFirm.com 

Of Attorneys for Defendant Spirit Airlines, Inc. 

Page 3 of 3 Defendant Spirit Airlines, Inc. ·s Unopposed Motion 

for Extension of Deadline to AnS\Yer First 

An1ended Con1plaint 

The Rosen La\Y Firm. P.C. 

1000 S\\" Broad\\ay. Suite 1220 

Portland. Oregon 97205 

Phone: (503) 525-2525; Fax: (S03) 52)-2526 

Case 3:15-cv-00338-SI Document 26 Filed 06/22/15 Page 3 of 4
CERTIFICATE OF SERVICE 

I hereby certify that I served a copy of the foregoing DEFENDANT 

SPIRIT AIRLINES INC.'S UNOPPOSED MOTION FOR EXTENSION OF 

DEADLINE TO ANSWER FIRST AMENDED COMPLAINT by the 

following indicated method or methods: 

~ Notice of this filing will be sent by e-mail to plaintiff's counsel by operation 

of the Court's electronic filing system. Parties may access this filing 

through the Court's CM/ECF system. 

Mr. William Ball 

Attorney William Ball, LLC 

420 SW Washington, Suite 400 

Portland, OR 97204 

Attorney for plaintiff Timothy Meacham 

Mr. John Barhoum 

Mr. Michael A. Miller 

Chock Barhoum LLP 

121 SW Morrison, Suite 415 

Portland, OR 97204 

Attorneys for Defendants Kerrie 

Conrad and Airport Terminal 

Services, Inc. 

DATED this 22nd day of June, 2015. 

Mr. William Katt 

Mr. John Loringer 

Wilson Elser Moskowitz Edelman 

& Dicker LLP 

740 N. Plankinton Ave., Ste 600 

Milwaukee, WI 53203 

Attorneys for Defendants Kerrie 

Conrad and Airport Terminal 

Services, Inc. 

s/ Elizabeth M. Ferrarini 

Elizabeth M. Ferrarini, OSB #944859 

Page 1 - Certificate of Service The Rosen La\\ Firm. P.C. 

100() S\\' Broad\\ay. Suite 1220 

Portland. Oregon 97205 

Phone (503) 52:'-2525: Fa\: (503) 525-2526 

Case 3:15-cv-00338-SI Document 26 Filed 06/22/15 Page 4 of 4