Attachment Attachment A

This document pretains to ITC-T/C-20170928-00157 for Transfer of Control on a International Telecommunications filing.

IBFS_ITCTC2017092800157_1282877

                                      Before the
                       FEDERAL COMMUNICATIONS COMMISSION
                                Washington, D.C. 20554

 In the Matter of                                              )
                                                               )
Gridley Telephone Company,                                     )
and                                                            )
Gridley Communications, Inc.                                  )
                                                              )
        Transferors,                                          )       File No.
                                                              )
and                                                           )
                                                              )
Egyptian Communication Services, Inc.                         )
       Transferee.                                            )
                                                              )
For Consent to Transfer Control pursuant to Section 214       )
of the Communications Act of 1934, as amended                 )
               JOINT APPLICATION FOR TRANSFER OF CONTROL OF
                DOMESTIC AND INTERNATIONAL AUTHORIZATIONS

        Gridley Telephone Company ("GTC") and Gridley Communications, Inc. ("GCI") and

their immediate parent company Mail Holdings, Inc. (collectively "Transferors") and Egyptian

Communication Services, Inc. ("Transferee" or "ECSI") hereby request authorization for the

transfer of control of GTC and GCI to ECSI. (Transferors and Transferee collectively referred to

as the "Applicants" or individually as an "Applicant.") This Application is being filed

simultaneously with the International Bureau and the Wireline Competition Bureau. Applicants

submit that prompt grant of both applications will serve the public interest.

                                          I. Background

       GTI is a rural incumbent local exchange carrier ("ILEC") operating in a discrete area of

north central Illinois, providing local exchange and exchange access service to approximately

765 residential and 310 business access lines in such rural area. GTI is a wholly—owned

subsidiary of Mail Holdings. GCI is a reseller of long distance services operating in and around


the service area of GTC. GCI provides its resold long distance service to approximately 824

 customers. GCI is a wholly—owned subsidiary of Mail Holdings, Inc.

        ECSI is a wholly—owned subsidiary of Egyptian Telephone Cooperative Association

("ETCA®"). ETCA is a rural ILEC operating in discrete areas in the southwest corner of the State

of Illinois, providing local exchange and exchange access service to approximately 1,950

residential and 390 business access lines in such rural area. ECSI also operates as a reseller of

long distance services in and around the areas service by ETCA. ECSI provides its resold long

distance service to approximately 2,240 customers.

        Pursuant to the proposed transaction, ECSI will purchase from Mail Holdings, Inc., 100%

of the ownership interest of GTC and of GCI.‘ After the contemplated transaction, GTC and

GCI will continue to exist and operate in their respective service territories, under the same

names, and providing service pursuant to existing rates, terms and conditions. The proposed

transactions will, accordingly, be transparent to consumers.

                               II. Description of the Transaction

       This application proposes the transfer of control of the Section 214 authorizations held by

GTC and GCI to ECSI through the purchase of each of these companies‘ stock from Mail

Holdings, Inc. The Applicants have also sought authorization from the Illinois Commerce

Commission to conduct the proposed transaction.

       After the proposed transaction, GTC and GCI will continue to operate in the same service

territory, and under the same names. GTC and GCI will continue to offer their respective

services pursuant to their respective current rates, terms and conditions. No carrier change




‘ As part of the underlying transaction, ECSI will also purchase from Mail Holdings, Inc., the
100% of its stock of Gridley Cable, Inc., a sister company to GTI and GCI.


charges are associated with the transaction, and no customer service or billing contact

information will change as a result of the transfer. The transaction will not affect customers‘

preferred carrier freezes.

               III. Transfer of Control of International Section 214 Authorization

        Applicant GCI resells switched international long distance toll services to residential and

business customers pursuant to an international Section 214 authorization granted by the

Commission under File No. ITC—214—19960315—00004.> In accordance with the requirements of

Section 63.24(e) of the Commission‘s Rules, Applicants submit the following information:

(1)     Name, address and telephone number of each applicant.

Transferors:

Gridley Telephone Company
Gridley Communications, Inc.

108 East Third Street
Gridley, Illinois 61744
Phone: (309) 747—2221
Fax: (309) 747—2888

Transferee:

Egyptian Communication Services, Inc.
1010 W. Broadway
Steeleville, Illinois 62288
Phone: (618) 774—1000
Fax: (618) 774—1025




 The information contained herein references both Gridley Telephone Company ("GTC") and
Gridley Communications, Inc. ("GCI"). The combined GTC and GCI information is provided
because it is relevant to the Applicants‘ responses in Section IV infra regarding the transfer of
the GTC and GCI domestic Section 214 authorizations. As noted in this Section III, the only
international authorization is that held by GCI. GTC has no international Section 214
authorization.


(2)     Government, state or territory under the laws of which each corporate or
        partnership applicant is organized.

        GTC and GCI are each corporations organized under the laws of the State of Illinois.

Mail Holdings, Inc. is a corporation organized under the laws of the State of Delaware. ECSI is

a corporation organized under the laws of the State of Illinois.

(3)    Name, title, post office address, and telephone number of the officer or contact point
       to whom correspondence concerning the application is to be addressed.

For Gridley Telephone Company and Gridley Communications, Inc.:

Mr. Charles T. Lake, Managing Director
Signal Equity Partners II, L.P.
805 Third Avenue, Suite 1460
New York, NY 10022
clake@signal—equity.com
Phone: (646) 580—3195
Fax: (212) 208—4433

For Egyptian Communication Services, Inc.:

Mr. Kevin J. Jacobsen
Chief Executive Officer
Egyptian Communication Services, Inc.
1010 W. Broadway
Steeleville, Ilinois 62288
kjacobs@egyptian.net
Phone: (618) 774—1000
Fax: (618) 774—1025

       With a copy to:

Thomas J. Moorman
Woods & Aitken LLP
5151 Wisconsin Ave., NW., Suite 310
Washington, DC 20016
Phone: (202) 944—9502
Fax: (202) 944—9501


 (4)    Statement as to whether the applicants had previously received authority under
        Section 214 of the Act.

        GTC holds a blanket domestic Section 214 authorization as provided for under 47 C.F.R.

§ 63.01. GCI holds a blanket domesfic Section 214 authorization as provided for under 47

C.F.R. § 63.01and holds an international Section 214 authorization under File No. ITC—214—

19960315—00004. ECSI holds a blanket domestic Section 214 authorization as provided for

under 47 C.F.R. § 63.01and holds an international Section 214 authorization under File No. ITC—

96—161. Egyptian Telephone Cooperative Association, Inc., the parent company of ECSI, holds

a blanket domestic Section 214 authorization as provided for under 47 C.F.R. § 63.01.

(5)    Name, address, citizenship and principal business of any person or entity that
       directly or indirectly owns at least ten percent of the equity of the applicant entities.

Transferor:

       As noted above, GTC and GCI are each owned 100% by Mail Holdings, Inc.

       Mail Holdings, Inc.‘s common stock is owned 100% by American Broadband Acquisition Corp.

("ABAC").

       ABAC is owned 100% by ABB Holdeco, Inc. ("Holdco"), a U.S. corporation organized

under the laws of the State of Delaware. The 10% or greater shareholders of Holdco are

American Broadband Communications, LLC ("American Broadband") (20%) (a U.S. limited

liability company organized under the laws of the State of Delaware), Signal Equity Partners II,

L.P. ("Signal") (41.50%) (a U.S. Limited Partnership organized under the laws of the State of

Delaware) and SM Investors II, L.P. ("SMI—II") (a U.S. Limited Partnership organized under the

laws of the State of Delaware engaged in investments) (12%).


        American Broadband‘s only 10% or greater shareholder is the Estate of Patrick L. Eudy

 (the "Estate").> Signal understands that Ms. Jane R. Eudy is the Personal Representative of the

 Estate and a U.S. citizen.




* The Estate is also the indirect 10% or greater owner of the following telecommunications
carriers operating in discrete areas of the United States that are outside of the State of Kansas and
Georgia: (a) Arlington Telephone Company, a Nebraska corporation and ILEC, that provides
local exchange and exchange access services in and around Arlington, Nebraska; (b) The Blair
Telephone Company, a Nebraska corporation and ILEC, that provides local exchange and
exchange access services in and around Blair, Kennard and Fort Calhoun, Nebraska; (c) Eastern
Nebraska Telephone Company, a Nebraska corporation and ILEC, that provides local exchange
and exchange access services in and around Walthill, Macy, Winnebago, Rosalie, Osmond,
Meadow Grove, Carroll and Belden, Nebraska; (d) Rock County Telephone Company, a
Nebraska corporation and ILEC, that provides local exchange and exchange access services in
and around Bassett and Newport, Nebraska; (e) HunTel Cablevision d/b/a HunTel
Communications, a Nebraska corporation and CLEC, that provides local exchange and exchange
access services in and around Lyons, Oakland and Tekamah, Nebraska, and is also an
 interexchange carrier ("IXC") that resells interstate interexchange and international long distance
 services throughout the Nebraska areas served by the above—listed affiliated Nebraska ILECs; (£)
Holway Telephone Company, a Missouri corporation and ILEC, that provides local exchange
and exchange access services in and around Maitland, Missouri; (g) K.L.M. Telephone
Company, a Missouri corporation and ILEC, that provides local exchange and exchange access
services in and around Rich Hill, Missouri; (g) Holway Long Distance Company, a Missouri
corporation and IXC that resells interstate interexchange and international long distance services
in and around Maitland, Missouri; (h) KLM Long Distance Company, a Missouri corporation
and IXC that resells interstate interexchange and international long distance services in and
around Rich Hill, Missouri; (i) Interior Telephone Company, an Alaska corporation and ILEC,
that provides local exchange and exchange access services in Alaska; (j) Mukluk Telephone
Company, Inc., an Alaska corporation and ILEC, that provides local exchange and exchange
access services in Alaska; (k) TelAlaska Long Distance, Inc., an Alaska corporation that resells
interstate interexchange and international long distance services; (1) TelAlaska Cellular, Inc., an
Alaska corporation that provides mobile voice and data services in Alaska, and is the licensee of
Cellular Radio Service Stations WQIQ306, Alaska Rural Service Area 2 — Bethel (Cellular
Market Area 316) and WQIQ308, Alaska Rural Service Area 1 — Wade (Cellular Market Area
315); (m) Cameron Communications, LLC ("Cameron Communications"), a Louisiana limited
liability company that resells interstate interexchange and international long distance services
under the trade name of Cameron Long Distance in the ILEC and CLEC exchanges served by
Cameron Telephone Company, LLC ("Cameron Telephone"), Elizabeth Telephone Company,
L.L.C. ("‘Elizabeth") and L.B.H., LLC ("LBH") in Cameron, Allen, Vernon, Rapides and
Beauregard Parishes in southwestern Louisiana, and in Jefferson, Chambers, Liberty and
Galveston Counties in southeastern Texas; (n) Cameron Telephone, a Louisiana limited liability
company and ILEC that provides local exchange telephone and exchange access services in the
Cameron, Carlyss, Creole, Grand Chenier, Hackberry, Holly Beach and Johnson Bayou

                                                 6


        Signal controls Holdco as Signal is able to designate and has designated the majority of

the Board of Directors of Holdeo. This control, in turn, has allowed Signal to designate those

individuals that oversee the day—to—day operations of GTC and GCL.

        At the same time, however, Signal‘s operations are controlled by its General Partner

("GP"), Signal Equity Advisors, II, LLC ("SEA I")." SEA—II owns a 2.94 percent GP interest in

Signal. SEA—II owners of 10% or greater are each citizens of the United States and are Timothy

P. Bradley (22.3%); Alfred J. Puchala, Jr. (22.3%); Christopher Nolen (19.6%); Malcom C.

Nolen (19.6%) and Charles T. Lake II (11.2%)."



exchanges in Cameron and Calcasieu Parishes in southwestern Louisiana and also provides local
exchange telephone and exchange access services in the Nome and High Island exchanges in
Jefferson, Chambers, Liberty and Galveston counties in southeastern Texas; (0) Elizabeth, a
Louisiana limited liability company and ILEC that provides local exchange telephone and
exchange access services in the Elizabeth, Pitkin and Sugartown exchanges in Allen, Vernon,
Rapides and Beauregard Parishes in southwestern Louisiana; (p) LBH, a Louisiana limited
liability company that provides broadband voice, video and data services as a CLEC in Grand
Lake and Sweetlake in Cameron Parish, and in Moss Bluff in Calcasieu Parish, in southwestern
Louisiana. In addition, the Estate indirectly has a greater than 10% ownership interest in the
following telecommunications carriers: (a) Dialog Telecommunications, Inc., which provides
voice and data services as a CLEC in Kentucky, Mississippi and North Carolina; (b) Acorn
Telephone LLC, which provides voice and data services as a CLEC in Kentucky; and (c) AMA
Communications LLC, which provides voice and data services, resold interstate interexchange
and international long distance services, as a CLEC in Texas.
* In its pro forma filing in 2009, GCI noted that Garden House LLC (a U.S. limited liability
company organized under the laws of the State of Delaware and whose principal business is
investment) was the only entity with a non—controlling derivative ownership interest of 10% or
greater in GCI. This same ownership structure applied to GTC as well. Garden House, LLC was
owned 95% by Eliot Nolen, a U.S. citizen and investor. Garden House, LLC has been dissolved
and no entity or individual within Signal now has a derivative ownership interest in GTC or GCI
of greater than 10%.
° Affiliates of American Broadband and SEA—II also are affiliated with other entities with
ownership in other telecommunications carriers operating in discrete areas of the United States
including: Georgetown Telephone Company, Inc. ("Georgetown"), a rural ILEC in the State of
Mississippi that also through a separate operating division provides resold interstate
interexchange and, operating under authority of its parent company, American Georgetown, Inc.,

                                                7


        There are no owners of SMI —II with successive multiplied interests of 10% or greater in

 GTC or GCI. SMI—II is controlled by S. Muocio & Co. LLC ("SMC"), a U.S. limited liability

company, organized under the laws of the State of Delaware. SMC is controlled and operated by

Salvatore Muoio, who is a U. S. citizen.©

        Following closing (1) GTC will continue to operate as an ILEC serving its same

respective exchange, and using in its respective operations the same assets as it did prior to the

closing and (2) GCI will continue to operate as a provider of resold interstate interexchange and

international services in and around the areas served by GTC.

Transferee:

       ECSI is a wholly—owned subsidiary of Egyptian Telephone Cooperative Association, Inc.

("ETCA®").

       ETCA is a telephone cooperative and no individual or entity owns 10% or more of

ETCA. Operational control of ETCA and thus ECSI rests with the ETCA Board of Directors

and its President and CEO. The individuals comprising the Board of Directors and the President

and CEO of ECTA are as follows:




international long distance services in and around the areas served by Georgetown); Zenda
Telephone Company, Inc. ("Zenda") (a rural ILEC operating in the State of Kansas); West Side
Telecommunications ("West Side") (a rural ILEC operating in the State of West Virginia);
Miller Telephone Co. (Miller") (a rural ILEC operating in the State of Missouri); and Tel—
Atlantic Communications, Inc. (which, through various dba‘s provides resold interstate
interexchange and international long distance services in and around the service areas of Zenda,
West Side, and Miller.
° SMC also controls SM Investors, L.P., a U.S. limited partnership organized under the laws of
the State of Delaware ("SMI"), and Mr. Muoio. SMI is also controlled by its general partner
SMC. SMI has a non—controlling 4% ownership interest in Holdco.


 Name                     Title                  Occupation                      Citizenship

 Phil Carson              Director               Minister                        U.S.

 Rudy Eggemeyer           President              Farmer                          U.S.

 Curtis Wolfe            Director                Retired                         U.S.

 David Goetting          Vice President          Farmer                          U.S.

 Jonathan Krause         Director                Service Manager                 U.S.

Kenny Hollmann           Asst. Sec/Treas.        Grain Facility Manager          U.S.

David Ibendahl           Director                Farmer                          U.S.

Kevin Nurnberger         Director                Retired                         U.S.

Susan B. Wennemann Sec/Treas.                   Retired                          U.S.

Kevin J. Jacobsen        CEO                    Telecom Exec.                    U.S.

The address for each of these individuals is: 1010 W. Broadway, Steeleville, Illinois 62288.

        ECSI and therefore ETCA have two telecommunications carrier wireless affiliates.‘

ESCTI‘s ownership in such affiliates is non—controlling.

(6)     Certification as to whether or not Transferee is, or is affiliated with, a foreign
        carrier.

        ECSI certifies that it is not a foreign carrier in any country, nor is it affiliated with any

foreign carrier.




‘ Specifically, and as the Commission‘s records will reflect, ECSI is the owner of a non—
controlling interest in: (1) SI Wireless, a holder of several broadband PCS and common carrier
microwave licenses as well as the lessee of other spectrum; and (2) in SI Spectrum, a licensee of
broadband PCS spectrum.


 (7)    Certification as to whether or not Transferee seeks to provide international
        telecommunications services to any country for which certain conditions are true.

        ECSI certifies that it does not, through GCI, seek to provide international

telecommunications services to any destination country to which 47 C.F.R. § 63.18(j)(1) through

(j)(4) applies.

(8)     Showing regarding provision of international telecommunications service to a
        country where the applicant is a foreign carrier or is affiliated with a foreign
        carrier.

        N/A

(9)     Regulatory classification under Section 63.10 of the Rules for foreign—affiliated
        carrier.

        N/A

(10)    Certification that applicant has not agreed to accept special concessions directly or
        indirectly from any foreign carrier.

        ECSI certifies that it (a) has not agreed to accept special concessions directly or indirectly

from any foreign carrier with respect to any U.S. international route where the foreign carrier

possesses market power on the foreign end of the route and (b) will not enter into such

agreements in the future.

(11)   Certification pursuant to 47 C.F.R. §§ 1.2001—1.2003 that no party to the application
       is subject to denial of federal benefits pursuant to section 5301 of the Anti—Drug
       Abuse Act of 1988, 21 U.S.C. § 583.

       Applicants hereby certify, pursuant to 47 C.F.R. §§ 1.2001—1.2003, that to the best of

their knowledge, information, and belief, no party to the application is subject to denial of federal

benefits pursuant to section 5301 of the Anti—Drug Abuse Act of 1988, 21 U.S.C. § 583.

(12)   Qualification for streamlined processing.

       This Application qualifies for streamlined processing under Sections 63.12(a) and (b) of

the Commission‘s rules. No party is affiliated with any foreign carrier in any destination market.


                                                 10


No party has an affiliation with a dominant US carrier whose international switched or private

line services the applicants seek authority to resell, and none is anticipated as a result of the

public offering which likely will result in widely held interests. No party to this application

seeks authority to provide switched basic services over private lines to a country for which the

Commission has not previously authorized the provision of switched services over private lines.

Authorization is sought to complete a public sale that would continue the current operations as a

non—dominant carrier reselling the international switched services of one or more unaffiliated US

carriers.

                IV. Transfer bf Control of Domestic Section 214 Authorizations

        Pursuant to Section 63.04(b) of the Commission‘s Rules, Applicants submit information

required pursuant to Sections 63.04(a)(1) through 63.04(a)(12) of the Commission‘s Rules:

(1)     The name, address and telephone number of each applicant.

        See Section III.(1).

(2)     The government, state, or territory under the laws of which each corporate or
        partnership applicant is organized.

        See Section III.(2).

(3)     The name, title, post office address, and telephone number of the officer or contact
        point, such as legal counsel, to whom correspondence concerning the application is
        to be addressed.

       See Section III.(3).

(4)    The name, address, citizenship and principal business of any person or entity that
       directly or indirectly owns at least ten (10) percent of the equity of the applicant,
       and the percentage of equity owned by each of those entities (to the nearest one (1)
       percent).

       See Section III.(5).




                                                 11


 (5)    Certification pursuant to §§1.2001 through 1.2003 of this chapter that no party to
        the application is subject to a denial of Federal benefits pursuant to section 5301 of
        the Anti—Drug Abuse Act of 1988. See 21 U.S.C. 853.

        See Section III.(11).

(6)     Description of the transaction.

        Please see Section II.

(7)     Description of the geographic areas in which the transferor and transferee (and
        their affiliates) offer domestic telecommunications services, and what services are
        provided in each area.

Transferors:

        GTC is a rural ILEC operating in a discrete area of north central Illinois, providing local

exchange and exchange access service to approximately 765 residential and 310 business access

lines in such rural area. GCI is a wholly—owned subsidiary of GTC. GCI is a reseller of long

distance services operating in and around the service area of GTC. GCI provides its resold long

distance service to approximately 824 customers.

Transferee:

       ECSI is a wholly—owned subsidiary of ETCA. ECSI also operates as a reseller of long

distance services in and around the areas service by ETCA. ECSI provides its resold long

distance service to approximately 2,240 customers.

(8)    Statement as to how the application fits into one or more of the presumptive
       streamlined categories in Section 63.03 of the Commission‘s Rules or why it is
       otherwise appropriate for streamlined treatment.

       Applicants request streamlined treatment of this Application in accordance with Sections

63.03(b)(2)(ii) and (iii). With respect to Section 63.03(b)(2)(iii), GTC serves fewer than two (2)




                                                12


 percent of the nation‘s subscriber lines installed in the aggregate nationwide," and the transaction

 will result in no new overlapping or adjacent service areas with another incumbent local

 exchange carrier. See Attachment A. With respect to Section 63.03(b)(2)(ii), neither ECSI or

the telephone company affiliate of ECSI — ETCA —— provide competitive telephone exchange

services or exchange access services within the service area of the current GTC. See 47 C.F.R. §

63.03(b)(2)(ii). Moreover, neither GCI nor ECSI provide telephone exchange service or

exchange access. See id. Thus, the presumptive streamlining of the instant Application is proper

under Section 63.03(b)(2)(i1) and (iii) of the Commission‘s Rules.

(4)     Identification of all other Commission applications related to the same transaction.

        Because Transferors hold no wireless licenses," no applications other than the instant

joint application seeking authorization to transfer control of domestic and international 214

authorities will be filed with the Commission.

(5)     Statement of whether the applicants are requesting special consideration because
        either party to the transaction is facing imminent business failure.

        Neither party to the transaction is facing imminent business failure. Therefore, Applicants

are not requesting special consideration for this reason.




® As of June 30, 2016, the Commission reported that the retail switched access lines were
approximately 62,276,000 nationwide. See Voice Telephone Services: Status as ofJune 30, 2016
(Industry Analysis and Technology Division, Wireline Competition Bureau, April, 2017),
Figure 2. GTC‘s approximate 1,070 access lines are far less than 2% of the nation‘s access lines
reported by the Commission. Even if ETCA‘s access lines of approximately 2,240, the
combination of GTC‘s access line counts and that of ETCA results in a total of approximately
3,310 access lines, again far less than 2% of the nation‘s access lines reported by the
Commission.
° The Applicants note that Gridley Cable, Inc. holds a receive—only earth station authorization.
See Call Sign EQO50250. The authority requires post—consummation notification to the
Commission regarding the planned transfer of control Gridley Cable, Inc. to ECSI.


                                                 13


 (6)   Identification of any separately filed waiver requests being sought in conjunction
       with the transaction

       No separately filed waiver requests are being sought in conjunction with the transaction.

(7)    Statement showing how grant of the application will serve the public interest,
       convenience and necessity, including any additional information that may be
       necessary to show the effect of the proposed transaction on competition in domestic
       markets

       Applicants respectfully submit that a grant of this application for the transfer of control of

the Companies is in the public interest. Upon consummation of the contemplated transaction,

GTC and GCI will continue to provide the same high quality, modern services to their current

respective subscribers as those provided today, and will do so in a manner that will render the

transfers for which authorization is sought herein transparent to their respective customers.

ECSI‘s management has a demonstrated commitment to the provision of high quality

telecommunications services in rural areas of the State of Illinois and will continue and advance

that commitment through the operations of GTC and GCI, which commitments will redound to

the benefit of GTC and GCI customers.




                                                14


                                          V. Conclusion

        For the foregoing reasons, the Applicants respectfully the expeditious grant of this

Application.

                                              Respectfully submitted,

                                              Gridley Telephone Company
                                              Gridley Communications, Inc.
                                              Eg \ptian Communication Services, Inc.




                                              Thomas J. Moorman

                                             Woods & Aitken LLP
                                             5151 Wisconsin Ave., N.W.
                                             Suite 310
                                             Washington, DC 20016
                                             (202) 944—9502

                                             Their Counsel

Date:   September 28, 2017




                                               15


                  Attachment A




                                 ~— Gridley
                                   Telephone
                                   Company




Egyptian      _
Telephone
Cooperative
Association


                                        DECLARATION

        I, Charles T. Lake, Treasurer of Mail Holdings, Inc. (the "Company") (the immediate
parent company of Gridley Telephone Company and Gridley Communications, Inc.), do hereby
declare under penalties of perjury that I have read the foregoing "Joint Application for Transfer
of Control of Domestic and International Authorizations," and the information contained therein
regarding the Company and its affiliates is true and accurate to the best of my knowledge,
information, and belief.



 Mfi 7                                                       Date:    _/ ,&’Z f/,} 5
Charles T. Lake
Treasurer
Mail Holdings, Inc.


                                        DECLARATION

         L, Kevin J. Jacobsen, Chief Executive Officer of Egyptian Communication Services, Inc.
(the "Company"), do hereby declare under penalties of perjury that I have read the foregoing
"Joint Application for Transfer of Control of Domestic and International Authorizations," and
the information contained therein regarding the Company andits affiliates is true and accurate to
the best of my knowledge, information, and belief.


     /                                                               5  é%/?.u/?m
  .[                                                        Date: _&7/4
Kevin J. Jacobsen
Chief Executive Officer
Egyptian Communication Services, Inc.


                                 CERTIFICATE OF SERVICE

       I, Thomas J. Moorman, of Woods & Aitken LLP, 5151 Wisconsin Avenue, N.W., Suite
310, Washington, DC 20016, do hereby certify that on this 28" day of September, 2017, the
foregoing "Joint Application for Transfer of Control of Domestic and International
Authorizations" was mailed, first class postage prepaid, to the following:
                                                           ‘\



                                                           /?Mw /é”%j//{fl
                                                         Thomas ;f/Moorman

The Honorable Bruce Rauner
Office of the Governor
207 State House
Springfield, IL 62706

US Department of Defense
Assistant Secretary for Network
       Information and Integration (NIT)
6000 Defense Pentagon
Washington, DC 20301—6000

Department of State
EB/CIP/SCA
Room 4826
2201 C Street, N.W.
Washington, DC 20520

*Jodie May
Wireline Competition Bureau
Federal Communications Commission
445 12" Street, S.W.
Washington, D.C. 20554

*David Krech and Sumita Mukhoty
International Bureau
Federal Communications Commission
445 12"" Street, S.W.
Washington, D.C. 20554

* via email



Document Created: 2017-09-28 14:56:34
Document Modified: 2017-09-28 14:56:34

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