NWMC Request for Ext

REQUEST submitted by Northwest Missouri Cellular Limited Partnership

Request for Extension of Time

2015-11-30

This document pretains to ITC-T/C-20151008-00236 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTC2015100800236_1116385

Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of ) ) International Section 214 Authorization for ) File Nos. ITC-214-20010427-00255 Assignment of Transfer of Control of Northwest ) ITC-T/C-20151008-00236 Missouri Cellular Limited Partnership To: Chief, International Bureau REQUEST FOR EXTENSION OF TIME OR ACCEPTANCE NUNC PRO TUNC Northwest Missouri Cellular Limited Partnership (“NWMC”), by its counsel, and pursuant to Section 63.20(d) of the Rules and Regulations of the Federal Communications Commission (“FCC” or “Commission”), hereby requests an extension of time, until November 30, 2015, in which to file the Opposition to Petition to Deny or Supplement or Informal Objection (“Opposition”) or requests acceptance of the Opposition nunc pro tunc. The Opposition opposes the Petition to Deny or Informal Request for Commission Action (“Petition”) filed on October 16, 2015, by Nicholas Robb (the “Receiver”), as court-appointed receiver for Oregon Farmers Mutual Telephone Company requesting that the Commission deny the application of NWMC filed October 8, 2015, and supplemented November 2, 2015, File No. ITC-TC-20151008-00236 (“ITC Application”) notifying the Commission of the involuntary pro forma transfer of control of NWMC. To the extent that the formal petition to deny process applies to this matter, the Opposition would have been due October 30, 2015. Counsel for NWMC, however, did not receive service copies of the Petition and only learned of the existence of the Petition while reviewing the IBFS on November 17, 2015.1 1 In IBFS, the Petition appears to be related to the International Section 214 Authorization, but not associated with the ITC Application itself. Following communication with counsel for NWMC, counsel for the Receiver submitted an erratum to the Petition revising the Certificate of Service to indicate delivery via U.S. Mail and not email, see Erratum to Petition To Deny Or 1

Counsel for NWMC contacted counsel for the Receiver, and counsel for the Receiver has consented to this request. Counsel for NWMC also contacted Sumita Mukhoty to notify Commission staff of this request and of the forthcoming Opposition. There is good cause for grant of this request since the Opposition provides the Commission with critical information relevant to its consideration of the ITC Application. Moreover, substantially identical issues already are before the Commission in connection with FCC Form 603 File No. 0006932939 regarding the wireless licenses held by NWMC. It would be efficient for the relevant FCC Bureaus to coordinate regarding these matters as appropriate rather than needlessly bifurcating them or requiring NWMC to file another application at a later time. For the forgoing reasons, the Commission should extend the time for filing the Opposition until November 30, 2015, or accept the Opposition nunc pro tunc. Respectfully submitted, Northwest Missouri Cellular Limited Partnership By: ____________________ Gregory W. Whiteaker Robin E. Tuttle Herman & Whiteaker, LLC 6720-B Rockledge Drive, Suite 150 Bethesda, MD 20817 (202) 600-7274 Its Attorneys November 30, 2015 Informal Request for Commission Action, (filed Nov. 18, 2015), but due to apparent delivery or other problems, Counsel for NWMC did not receive a copy via U.S. Mail. 2

CERTIFICATE OF SERVICE I, Gregory W. Whiteaker, an attorney with the law firm Herman & Whiteaker, LLC, do hereby certify that I caused a copy of the foregoing Request for Extension of Time or Acceptance Nunc Pro Tunc to be served, as specified, this 30th day of November, 2015, on the following: Via First-Class Mail: John A. Pendergast, Esq. Benjamin H. Dickens, Jr. Salvatore Taillefer, Jr., Esq. Blooston, Mordkofsky, Dickens, Duffy & Pendergast, L.L.P. 2120 L Street, N.W., Suite 300 Washington, DC 20037 __________________________ Gregory W. Whiteaker !


Document Created: 0710-04-28 00:00:00
Document Modified: 0710-04-28 00:00:00
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