Attachment 1-7-10 Globalstar Mo

1-7-10 Globalstar Mo

MOTION submitted by Globalstar

motion

2010-01-07

This document pretains to SAT-AMD-20091221-00147 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2009122100147_794419

WILMERHALE Samir C. Jain January 7, 2010 +1 202 663 6083 (t) +1 202 se3 6363 (f) samir.jain@wilmerhale.com FILED ELECTRONICALLY VIA IBFS Ms. Mindel De La Torre Chief, International Bureau Federal Communications Commission Washington, D.C. 20554 Re: FCC File No. SAT—MOD—20080904—00165 FCC File No. SAT—AMD—20091221—00147 MOTION FOR LEAVE TO DEFER OPPOSITION DEADLINE Dear Ms. De La Torre: On December 21, 2009, Globalstar Licensee LLC, GUSA Licensee LLC, and GCL Licensee LLC (collectively "Globalstar") filed an amendment to Globalstar‘s application for modification of its mobile satellite service space station license and an application for modification of its mobile satellite service earth station and mobile earth terminal licenses in the above—referenced proceedings ("Amendment and Application).l/ On December 31, 2009, Iridium Satellite LLC ("Iridium") filed an opposition to Globalstar‘s Amendment and Application,"" notwithstanding the fact that the International Bureau has not yet issued a Public Notice pursuant to section 25.151 of the Commission‘s rules seeking comment on the Amendment and Application. In order to eliminate the need for Globalstar to file multiple oppositions in response to Iridium‘s pleading, as well as to any other pleadings that may be submitted once Globalstar‘s Amendment and Application is placed on Public Notice (which Globalstar hopes will happen in the near future), Globalstar respectfully requests permission to defer filing its opposition to Iridium‘s pleading until the deadline set forth in section 25.154(c) of the Commission‘s rules for opposing formal petitions to deny Globalstar‘s Amendment and Application.®‘ As Iridium V See Globalstar Licensee LLC, GUSA Licensee LLC, and GCL Licensee LLC — Amendment To Application For Modification of Mobile Satellite Service Space Station License and Application For Modification of Mobile Satellite Service Earth Station and Mobile Earth Terminal Licenses, File Nos. SAT—MOD—20080904—00165, SAT—AMD—20091221—00147 (filed Dec. 21, 2009). 2 See Opposition of Iridium Satellite LLC (filed Dec. 31, 2009) ("Iridium Opposition"). 3 * Under section 25.154, once Globalstar‘s Amendment and Application is placed out for comment, parties will have 30 days in which to file petitions to deny, and Globalstar will have 10 days after that in which to oppose them. See 47 C.F.R. § 25.154. Wilmer Cutler Pickering Hale and Dorr u», 1875 Pennsylvania Avenue NW, Washington, DC 20006 Beijing Berlin Boston Brussets Frankfurt London Los Angeles New York Oxford Palo Alto Waltham Washington

WILMERHALE January 7, 2010 Page 2 recognizes in its Opposition, "Globalstar‘s application. .. warrants a Public Notice so that all interested parties will be alerted to Globalstar‘s proposals and can participate in the proceeding.”i/ Iridium further states in its pleading that it "reserves the right to file a Petition to Deny pursuant to Section 25.154" after Globalstar‘s Amendment and Application is placed on Public Notice."" By promptly placing Globalstar‘s Amendment and Application out for comment, the Bureau will ensure that all interested parties are given notice of, and have a full and fair opportunity to comment on, it. Globalstar can then file a consolidated response to any and all oppositions, petitions, and comments, including Iridium‘s opposition. This will avoid the need for overlapping and repetitive filings that likely would result if Globalstar were required to respond seriatim to Iridium‘s pleading and then to any formal Petitions to Deny its Amendment and Application that may be filed once it is placed out for comment. Accordingly, Globalstar hereby requests leave to file a consolidated opposition to Iridium‘s opposition and any petitions that may be submitted once Globalstar‘s Amendment and Application is placed on Public Notice, in accordance with the deadline established by section 25.154. Establishment of a consolidated opposition deadline will not harm any party to this proceeding and will serve the public interest by enabling all interested parties to participate in the proceeding and avoiding the need for the parties to file, and the Bureau to consider, repetitive pleadings. Respectfully submitted, /s/ Samir C. Jain Samir C. Jain Counsel to Globalstar Licensee LLC co: (By Email) Robert Nelson Cassandra Thomas Stephen Duall Karl Kensinger Jennifer Hindin See Iridium Opposition at 1 n.1. 5 Id.


Document Created: 2019-04-09 17:38:35
Document Modified: 2019-04-09 17:38:35
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