Motion to Accept "Response to Reply to Opposition" (July 18, 2000)

0100-EX-RR-1999 Text Documents

Maritime Telecommunications Network, Inc.

2001-08-15ELS_47825

                                                                                  ORIGINAL
                                Federal Communications Commission                       RECEIVED
                                        Washington, D.C. 20554
                                                                                          JUL 18 2000
Application of Maritime                  )
Telecommunications Network, Inc.         )       FCC File No. 0100-EX-RR-1995            m%mm COMLIISSIOH
                     .                                                                          THE SECaEtaRY
for Renewal of Experimental              )
Authorization Call Sign KI2XEE           )

To:       Chief, Office of Engineering and Technology


             MOoTION TO ACCEPT "RESPONSE TO REPLY TO OPPOSITION®"

          Maritime Telecommunications Network, Inc. ("MTN"), by its attorneys, hereby requests that

the Commission accept for filing the "Response to Reply to Opposition" being simultaneously filed

by MTN. The Fixed Wireless Communications Coalition ("FWCC"), the Association of American

Railroads ("AAR"), the American Petroleum Institute ("API"), the Association of Public—Safety

Communications Officers International ("APCO"), and the United Telecom Council (formerly the

Utilities Telecommunications Council or "UTC") (hereinafter collectively referred to as "Joint

Petitioners") filed their "Reply to Opposition" ("Reply") on June 15, 2000.

      |   In their Reply the Joint Petitioners took a new approach to their earlier baseless argument that

MTN is causing disruptive interference to fixed microwave facilities. In taking a new approach, they

presented new technical discussion from M. Philip Salas, their technical expert. Because MTN has


                                                2

never had an opportunity to respond to the new technical information, it is seeking an opportunity

to file its response.

                                             Respectfully submitted,

                                             MARITIME TELECOMMUNICATIONS
                                             NETWORK, INC.



                                             mebab)Arraa—
                                                 NClen E. Disewhaus
                                                 Eliot J. Greenwald

                                             Its Attorneys
                                             SWIDLER BERLIN SHEREFF FRIEDMAN, LLP
                                             3000 K Street, NW., Suite 300
                                             Washington, D.C. 20007
                                             (202) 424—7500

July 18, 2000


                                 CERTIFICATE OF SERVICE

        I, Penny Jackson, hereby certify that on this 18" day of July, 2000, copies of the attached,
MOTION TO ACCEPT "RESPONSE TO REPLY TO OPPOSITION", were sent via U.S.
Mail, to the following:


*Dale N. Hatfield, Chief                              *Ari Fitzgerald
Office of Engineering and Technology                  International Bureau
Federal Communications Commission                     Federal Communications Commiussion
445 12"" Street, S.W. — Room 7—C155                   445 12"" Street, S.W.
Washington, DC 20554                                  Washington, DC 20554

*Bruce A. Franca, Deputy Chief                        *Sylvia T. Lam
Office of Engineering and Technology                  Engineer, Satellite Engineering Branch
Federal Communications Commission                     Satellite and Radio Communication
445 12" Street, S.W. — Room 7—C153                    Division
Washington, DC 20554                                  International Bureau
                                                      Federal Communications Commission
*Charles J. Iseman                                    445 12"" Street, S.W.
Chief, Spectrum Policy Branch                         Washington, DC 20554
Office of Engineering and Technology
Federal Communications Commission                     William T. Hatch
445 12th Street, S.W.                                 Associate Administrator
Washington, DC 20554                                  Office of Spectrum Management
                                                      NTIA
*Donald Abelson, Chief                                14" & Constitution Avenue, N.W.
International Bureau                                  Washington, DC 20230
Federal Communications Commission
445 12" Street, S.W. — Room 6—C750                    Wayne V. Black
Washington, DC 20554                                  Peter A. Saari
                                                      Keller and Heckman LLP
*Steven Spaeth                                        1001 G Street, NW., Suite 500 West
International Bureau                                  Washington, DC 20001
Federal Communications Commussion
445 12"" Street, SW. — Room 6—B434                    Julian L. Shepard
Washington, DC 20554                                  Verner, Liipfert, Bernhard, McPherson
                                                       and Hand, Chartered
*Thomas P. Stanley                                    901 — 15°" Street, NW, Suite 700
Office of Engineering and Technology                  Washington, DC 20005—2301
Federal Communications Commission
445 12"" Street, S.W. — Room 3—C460
Washington, DC 20554


Jeffrey L. Sheldon                    Leonard R. Raish
Thomas Goode                          Mitchell Lazarus
UTC                                   Fletcher, Heald & Hildreth, P.L.C.
1140 Connecticut Avenue, NW., #1140   1300 North 17"" Street, 11"" Floor
Washington, DC 20036                  Arlington, VA 22209




                                      Cum Jucten
                                              Pennyr Jackson
*Via Hand Delivery



Document Created: 2001-08-15 11:41:45
Document Modified: 2001-08-15 11:41:45

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